HNP-08-119, Non-Security Sensitive Version of Supplement to Request for License Amendment to Adopt NFPA 805 Performance-Based Standards for Fire Protection for Light Water Reactor Generating Plants (2001) Edition

Non-Security Sensitive Version of Supplement to Request for License Amendment to Adopt NFPA 805 Performance-Based Standards for Fire Protection for Light Water Reactor Generating Plants (2001) Edition

ML090500552
Person / Time
Site:	Harris
Issue date:	02/05/2009
From:	Corlett D Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-119
Download: ML090500552 (101)

Text

PrLgress Energy FEB 0 5 2009 Serial: HNP-08-119 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NON-SECURITY SENSITIVE VERSION OF SUPPLEMENT TO REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805 PERFORMANCE-BASED STANDARDS FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION)

Reference:

Letter from C. L. Burton to the Nuclear Regulatory Commission (Serial: HNP-08-113), "Supplement to Request for License Amendment to Adopt NFPA 805 Performance-Based Standards for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," dated November 14, 2008 Ladies and Gentlemen:

Harris Nuclear Plant's NFPA 805 License Amendment Request Supplement 1 (Reference) included Attachments containing sensitive information submitted under 10 CFR 2.390(d)(1).

Enclosed please find non-security sensitive versions, in which the information previously identified as security sensitive has been redacted, of the following Attachments:

• Attachment A - NEI 04-02 Table B-i - Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

" Attachment G - Operator Manual Actions - Transition to Recovery Actions Attachment S - Plant Modifications

• Attachment W - Internal Events PRA Quality Attachment X - Fire PRA Quality Please refer any questions regarding this submittal to me at (919) 362-3137.

Sincerely, David H. Corlett Supervisor - Licensing/Regulatory Programs Harris Nuclear Plant Progress Energy Carolinas, Inc.

Harris Nuclear Plant P. 0. Box 165 New Hill, NC 27562 146(

HNP-08-119 Page 2 DHC/kms

Enclosures:

1.

Attachment A - NEI 04-02 Table B-I - Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3) - Non-Security Sensitive

2.

Attachment G - Operator Manual Actions - Transition to Recovery Actions -

Non-Security Sensitive

3.

Attachment S - Plant Modifications - Non-Security Sensitive

4.

Attachment W - Internal Events PRA Quality - Non-Security Sensitive

5.

Attachment X - Fire PRA Quality - Non-Security Sensitive

Progress Energy HNP NFPA 805 Transition Report PrgesEeryHPNPA85TasiinRpr Attachment A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

(Non-Security Sensitive) 47 Pages Page A HNP NFPA 805 Transition Report - Redacted[I]

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Repuirements/Guidance Reference Document Document Detail 3.1 General 3.1* General.

This chapter contains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features.

These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.

N/A 3.2.1 Intent.

A site-wide fire protection plan shall be established. This 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 implement all fire protection program activities N/A N/A - General statement; No technical requirements HNP-M/BMRK-0011, Code All Compliance Evaluation NFPA 805,2003, Rev. 000 3.2 Fire Protection Plan N/A N/A - General statement; No technical requirements No Additional Clarification 3.2.1 Intent Complies FPP-001, Fire Protection Program Manual, Rev. 029 All 3.2.2 Management Policy Direction and Responsibility.

3.2.2.1 [Management Policy on Senior Management]

3.2.2.2 [Management Policy on Daily Administration]

3.2.2.3 [Management Policy on Interfaces]

3.2.2* Management Policy Direction and Responsibility.

Complies A policy document shall be prepared that defines management authority and responsibilities and establishes the general policy for the site fire protection program.

3.2.2.1*

Complies The policy document shall designate the senior management position with immediate authority and responsibility for the fire protection program.

3.2.2.2*

Complies The policy document shall designate a position responsible for the daily administration and coordination of the fire protection program and its implementation.

3.2.2.3*

Complies The policy document shall define the fire protection interfaces with other organizations and assign responsibilities for the coordination of activities. In addition, this policy document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.

No Additional Clarification No Additional Clarification No Additional Clarification No Additional Clarification FPP-001, Fire Protection Program Manual, Rev. 029 FPP-001, Fire Protection Program Manual, Rev. 029 FPP-001, Fire Protection Program Manual, Rev. 029 FPP-001, Fire Protection Program Manual, Rev. 029 All All Section 4.2.6 Section 4.0 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 1 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

3.2.2.4 [Management Policy on AHJ]

3.2.3 Procedures Requirements/Guidance 3.2.2.4*

The policy document shall identify the appropriate AHJ for the various areas of the fire protection program.

Compliance Statement Compliance Basis Complies Reference Document I FPP-001, Fire Protection Program Manual, Rev. 029 Document Detail Section 3.2 3.2.3* Procedures.

Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:

(1)

• Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program (2)

• Compensatory actions implemented when fire protection systems and other systems credited by the fire protection program and this standard cannot perform their intended function and limits on impairment duration (3)

• Reviews of fire protection program -

related performance and trends (4) Reviews of physical plant modifications and procedure changes for impact on the fire protection program (5) Long-term maintenance and configuration of the fire protection program (6) Emergency response procedures for the plant industrial fire brigade.

3.3 Prevention.

A fire prevention program with the goal of preventing a fire from starting shall be established, documented, and implemented as part of the fire protection program. The two basic components of the fire prevention program shall consist of both of the following:

(1) Prevention of fires and fire spread by controls on operational activities (2) Design controls that restrict the use of combustible materials The design control requirements listed in the remainder of this section shall be provided as described.

Complies No Additional Clarification FPP-001, Fire Protection Program Manual, Rev. 029 3.3 Prevention Complies No Further Clarification FPP-001, Fire Protection Program Manual, Rev. 029 Sections 8.2 and 8.3 and Attachment 1

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Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.3.1 Fire Prevention for Operational Activities.

3.3.1.1 General Fire Prevention Activities.

3.3.1 Fire Prevention for Operational Activities.

The fire prevention program activities shall consist of the necessary elements to address the control of ignition sources and the use of transient combustible materials during all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.

3.3.1.1 General Fire Prevention Activities.

The fire prevention activities shall include but not be limited to the following program elements:

(1) Training on fire safety information for all employees and contractors including, as a minimum, familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms (2)

• Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identified (3)

• Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized.

Complies (1) Complies (2) Complies (3) Complies No Additional Clarification No Additional Clarification No Additional Clarification No Additional Clarification Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 SHNPP FSAR 9.5.1 FAQ 06-0028, Rev. 002 GNB07H, HNP Site Specific Orientation GNR01 N, Plant Access Requalification AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026 FPP-001, Fire Protection Program Manual, Rev. 029 OMM-001, Operations-Conduct of Operations, Rev. 067 AP-930, Plant Observation Program, Rev. 005 FPP-001, Fire Protection Program Manual, Rev. 029 ADM-NGGC-0104, Work Management Process, Rev.

030 EGR-NGGC-0005, Engineering Change, Rev.

026 Document Detai.

Section 8.2 Section 8.3 Section 8.3 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 3 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.3.1.2 Control of Combustible Materials 3.3.1.2" Control of Combustible Materials.

Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:

(1)

• Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.

(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.

(4)

• Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.

(5)

• Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

(6)

• Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

(1) Complies No Additional Clarification Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 FPP-004, Transient Combustible Control, Rev.

019 Document Detail Section 8.3 All (2) Complies with Clarification FPP-001, Fire Protection Program Manual, Rev. 029 FPP-004, Transient Combustible Control, Rev.

)19 Section 8.3 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 4 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance

(;ompliance Statement Compliance Basis (3) Complies with Clarification 3.3.1.2 Control of Combustible Materials 3.3.1.2* Control of Combustible Materials.

Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:

(1)

• Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.

(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.

(4)

• Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.

(5)

• Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

(6)

• Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 FPP-004, Transient Combustible Control, Rev.

019 Document Detail Section 8.3 (4) Complies (5) Complies No additional clarification No additional clarification FPP-001, Fire Protection Program Manual, Rev. 029 FPP-004, Transient Combustible Control, Rev.

019 FPP-001, Fire Protection Program Manual, Rev. 029 HNP-M/BMRK-0014, Code Compliance Evaluation NFPA 30, Flammable and Combustible Liquids Code, Rev. 0 FAQ 06-0020, Rev. 001 FPP-004, Transient Combustible Control, Rev.

019 Section 8.3 Section 8.3 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 5 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.3.1.2 Control of Combustible Materials Requirements/Guidance 3.3.1.2" Control of Combustible Materials.

(6) Complies Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:

(1)

• Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.

(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.

(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.

(4)

• Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.

(5)

• Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

(6)

• Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

No Additional Clarification Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 NFPA 51B Code Calculation, NFPA 51B Code Calculation FPP-008, Control of Fuel Gases and Oxygen, Rev. 008 HNP-M/BMRK-0014, Code Compliance Evaluation NFPA 30, Flammable and Combustible Liquids Code, Rev. 0 FPP-004, Transient Combustible Control, Rev.

019 FAQ 06-0020, Rev. 001 Document Detai.

Section 8.3 3.3.1.3 Control of Ignition Sources 3.3.1.3.1 [Control of Ignition Sources Code Requirements]

3.3.1.3 Control of Ignition Sources N/A N/A - General statement no technical requirements No Additional Clarification 3.3.1.3.1*

A hot work safety procedure shall be developed, implemented, and periodically updated as necessary in accordance with NFPA 518, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

3.3.1.3.2 Smoking and other possible sources of ignition shall be restricted to properly designated and supervised safe areas of the plant.

Complies FAQ 06-0020, Rev. 001 HNP-M/BMRK-0013, Code Compliance Evaluation NFPA 51B, Std for Fire Prevention in use of cutting and welding processes, Rev. 00, 3/28/2008 SHNPP FSAR 9.5.1 AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026 FPP-001, Fire Protection Program Manual, Rev. 029 All 3.3.1.3.2 [Control of Ignition Sources on Smoking Limitations]

Complies No Additional Clarification Section 6.2.6.5 Section 8.3.2 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 6 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.3.1.3.3 [Control of 3.3.1.3.3 Ignition Sources for Leak Open flames or combustion-generated smoke shall not be Testing]

permitted for leak or air flow testing Complies Complies No Additional Clarification No Additional Clarification Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026 Document Detail Section 8.3.2e 3.3.1.3.4 [Control of Ignition Sources on Portable Heaters]

3.3.1.3.4*

Plant administrative procedure shall control the use of portable electrical heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

3.3.2 Structural.

Walls, floors, and components required to maintain structural integrity shall be of noncombustible construction, as defined in NFPA 220, Standard on Types of Building Construction.

Section 5.3 3.3.2 Structural.

Complies Via Previous Approval SHNPP FSAR 9.5.1 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 9.5.1.4 Section C.5.A(9)

SER - SSER4 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 7 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.3.3 Interior Finishes 3.3.3 Interior Finishes.

Interior wall or ceiling finish classification shall be in accordance with NFPA 101, Life Safety Code, requirements for Class A materials. Interior floor finishes shall be in accordance with NFPA 101 requirements for Class I interior floor finishes.

Compliance Statement Compliance Basis Complies via Previous Approval Reference Document Shearon Harris FSAR, Shearon Harris FSAR NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Document Detail Section 9.5.1, page 9.5.1-14 to 9.5.1-14a Section 9.5.1.4 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 8 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Reference Document 3.3.4 Insulation Materials 3.3.4 Insulation Materials.

Complies via Previous Thermal insulation materials, radiation shielding materials, Approval ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Shearon Harris SER, Shearon Harris SER FSAR 9.5.1 Document Detail Section 9.5.1 Section 9.5.1.4 9.5.1.2.2 3.3.5 Electrical.

N/A N/A N/A - General statement; No technical requirements No Additional Clarification 3.3.5.1 [Electrical Wiring 3.3.5.1 Complies Above Suspended Ceiling Wiring above suspended ceiling shall be kept to a Limitations]

minimum. Where installed, electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers.

Shearon Harris FSAR, Shearon Harris FSAR NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Section 9.5.1 Section C.5.a(11)

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

3.3.5.2 [Electrical Raceway Construction Limits]

3.3.5.3 [Electrical Cable Flame Propagation Limits]

Requirements/Guidance 3.3.5.2 Only metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. FlexiblE metallic conduits shall only be used in short lengths to connect components.

3.3.5.3*

Electric cable construction shall comply with a flame propagation test as acceptable to the AHJ.

Exception: Existing cable in place prior to the adoption of this standard shall be permitted to remain as is.

Compliance Statement Compliance Basis Complies with Clarification Complies with Clarification Reference FAQ 06-0021.

Flame propagation testing as defined in FAQ 06-0022.

Reference Document Shearon Harris FSAR, Shearon Harris FSAR NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 FAQ 06-0021, Rev. 001a FAQ 06-0022, AHJ Acceptable Cable Flame Tests NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Shearon Harris FSAR, Shearon Harris FSAR NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Shearon Harris FSAR, Shearon Harris FSAR Document Detail Section 9.5.1.2.2 Section 9.5.1.4 section 9.5.1, page 9-49 section 9.5.1, page 9.5.1-18 3.3.6 Roofs.

3.3.6 Roofs.

Metal roof deck construction shall be designed and installed so the roofing system will not sustain a self-propagating fire on the underside of the deck when the deck is heated by a fire inside the building. Roof coverings shall be Class A as determined by tests described in NFPA 256, Standard Methods of Fire Tests of Roof Coverings.

Complies No Additional Clarification Pg 9-48 section 9.5.1, page 9.5.1-15 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 10 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Compliance Basis Reference Document Document Detail Section 9.5.1.2.2 SSER 2 3.3.7 Bulk Flammable Gas Storage.

3.3.7 Bulk Flammable Gas Storage.

Bulk compressed or cryogenic flammable gas storage shall not be permitted inside structures housing systems, equipment, or components important to nuclear safety.

Complies via Previous Approval FSAR 9.5.1 NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 11 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detai; HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 12 of 46 Page A HNP NFPA 805 Transition Report - Rev la.docx 11/10/2008 Transition Tool Version 1.0.5

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.3.7.1 [Bulk Flammable Gas Location Requirements]

3.3.7.1 Complies via Previous Storage of flammable gas shall be located outdoors, or in Approval separate detached buildings, so that a fire or explosion will not adversely impact systems, equipment, or components important to nuclear safety. NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites, shall be followed for hydrogen storage.

AR 200493200493 11/1/2007 AR 206165206165 11/19/2007 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 13 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.3.7.2 [Bulk Flammable Gas Container Restrictions]

3.3.7.2 Outdoor high-pressure flammable gas storage containers shall be located so that the long axis is not pointed at buildings.

Complies No Additional Clarification Reference Document NUREG-1038 Supplement 4, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 4, 10/11/1986 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Shearon Harris FSAR, Shearon Harris FSAR FPP-008, Control of Fuel Gases and Oxygen, Rev. 008 Document Detail C.5.d.(2)

Section 9.5.1 page 13 3.3.7.3 [Bulk Flammable Gas Cylinder Limitations]

3.3.8 Bulk Storage of Flammable and Combustible Liquids.

3.3.7.3 Flammable gas storage cylinders not required for normal operation shall be isolated from the system.

3.3.8 Bulk Storage of Flammable and Combustible Liquids.

Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code.

Complies No Additional Clarification Complies with Clarification LAP-83-306 HNP-M/BMRK-0014, Code Compliance Evaluation NFPA 30, Flammable and Combustible Liquids Code, Rev. 0 page 266 SER open item 109 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 14 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.3.9 Transformers.

3.3.10 Hot Pipes and Surfaces.

3.3.11 Electrical Equipment Requirements/Guidance 3.3.9* Transformers.

Where provided, transformer oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function.

3.3.10* Hot Pipes and Surfaces.

Combustible liquids, including high flashpoint lubricating oils, shall be kept from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

Administrative controls shall require the prompt cleanup of oil on insulation.

3.3.11 Electrical Equipment Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment.

Complies Complies Complies No Additional Clarification No additional clarification FAQ 06-0024 Rev 0 Reference Document EC 48017, Xmer pit sizing, 9/8/2006 OMM-016, Operators Rounds, Rev. 062 FPP-004, Transient Combustible Control, Rev.

019 FPP-004, Transient Combustible Control, Rev.

019 Document Detail Section 5.3.10 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 15 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail Section 9.5.1 sh 1-7 3.3.12 Reactor Coolant 3.3.12* Reactor Coolant Pumps.

Pumps.

For facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall be provided with an oil collection system. The oil collection system shall be designed and installed such that leakage from the oil system is safely contained for off normal conditions such as accident conditions or earthquakes. All of the following shall apply.

(1) The oil collection system for each reactor coolant pump shall be capable of collecting lubricating oii from all potential pressurized and nonpressurized leakage sites in each reactor coolant pump oil system.

(2) Leakage shall be collected and drained to a vented closed container that can hold the inventory of the reactor coolant pump lubricating oil system.

(3) A flame arrestor is required in the vent if the flash point characteristics of the oil present the hazard.of a fire flashback.

(4) Leakage points on a reactor coolant pump motor to be protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactor coolant pumps.

(5) The collection basin drain line to the collection tank shall be large enoughto accommodate the largest potential oil leak such that oil leakage does not overflow the basin.

Complies Via Previous Approval Shearon Harris FSAR, Shearon Harris FSAR 1364-053480, RCP-GEN ASSY OIL SPILL PROTECTION SYS, Rev. 001 2165-S-0685, SFD -

CONTM'T, TURBINE BLDG &

TANK AREA & SEC. BLD, Rev. 027 LER 97-10 NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 HNP HNPSSCA Review PE ver 1.0.5 Build 20 05-06-2008 Working Copy.mdb Page 16 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.4 Industrial Fire Brigade.

N/A N/A N/A - General statement; No technical requirements HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 17 of 46 Page A HNP NFPA 805 Transition Report - Rev la.docx 11/10/2008 Transition Tool Version 1.0.5

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Requirements/Guidance Reference Document Document Detaii 3.4.1 On-Site Fire-Fighting Capability.

3.4.1 On-Site Fire-Fighting Capability.

All of the following requirements shall apply.

(a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting)

(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department Physicians (b)

• Industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.

(c) During every shift, the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance Exception: Sufficient training and knowledge shall be permitted to be provided by an operations advisor dedicated to industrial fire brigade support criteria.

(d)

• The industrial fire brigade shall be notified immediately upon verification of a fire.

(e) Each industrial fire brigade member shall pass an annual physical examination to determine that he or she can perform the strenuous activity required during manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.

Complies with Clarification NFPA 1500 and NFPA 1582 are not applicable HNP-M/BMRK-0012, Code to HNP as defined within their respective Compliance Evaluation NFPA scope statements.

600, Standards on Industrial Fire Brigades, Rev. 0, 3/27/2008 QCC FP FBBCERTH, INITIAL FIRE BRIGADE MEMBER CERTIFICATION CARD FBBCERTH, Rev. 006 FAQ 06-0007, Rev. 003 FPP-001, Fire Protection Program Manual, Rev. 029 FPP-002, Fire Emergency, Rev. 031 Shearon Harris FSAR, Shearon Harris FSAR Section 4.3.3 section 8.1.7 pg 9.5.1-57 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 18 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.4.2 Pre-Fire Plans.

3.4.2* Pre-Fire Plans.

Complies with Current and detailed pre-fire plans shall be available to the Clarification industrial fire brigade for all areas in which a fire could jeopardize the ability to meet the performance criteria described in Section 1.5.

Reference Document FPP-001, Fire Protection Program Manual, Rev. 029 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Document Detail Section 8.6.3-Fire Pre-Plans HNP HNP_SSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 19 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document

• Document Detail Section 8.6.3-Fire Protection Plans 3.4.2.1 [Pre-Fire Plan Contents]

3.4.2.1*

Complies with The plans shall detail the fire area configuration and fire Clarification hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.

FPP-001, Fire Protection Program Manual, Rev. 029 FPP-002, Fire Emergency, Rev. 031 FAQ 06-0025, Approved Fire Pre-plan Scope / Content HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 20 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.4.2.2 [Pre-Fire Plan Updates]

3.4.2.2 Pre-fire plans shall be reviewed and updated as necessary.

3.4.2.3*

Pre-fire plans shall be available in the control room and made available to the plant industrial fire brigade.

3.4.2.4*

Pre-fire plans shall address coordination with other plant groups during fire emergencies.

Complies No Additional Clarification FPP-001, Fire Protection Program Manual, Rev. 029 FP-002, Fire Emergency PRO-NGGC-0204, Procedure Review and Approval, Rev.

009 FPP-001, Fire Protection Program Manual, Rev. 029 Section 8.6.3-Fire Pre-Plans 3.4.2.3 [Pre-Fire Plan Locations]

3.4.2.4 [Pre-Fire Plan Coordination Needs]

Complies No Additional Clarification Section 8.6.3 Complies with Clarification FPP-002, Fire Emergency, Rev. 031 FPP-001, Fire Protection Program Manual, Rev. 029 Section 8.6.5-Fire

Response

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Requirements/Guidance 3.4.3 Training and Drills.

3.4.3 Training and Drills.

a) Complies with Industrial fire brigade members and other plant personnel NFPA 600 who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.

(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply.

(1) Plant industrial fire brigade members shall receive training consistent with the requirements contained in NFPA 600, Standard on Industrial Fire Brigades, or NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, as appropriate.

(2) Industrial fire brigade members shall be given quarterly training and practice in fire fighting, including radioactivity and health physics considerations, to ensure that each member is thoroughly familiar with the steps to be taken in the event of a fire.

(3) A written program shall detail the industrial fire brigade training program.

(4) Written records that include but are not limited to initial industrial fire brigade classroom and hands-on training, refresher training, special training schools attended, drill attendance records, and leadership training for industrial fire brigades shall be maintained for each industrial fire brigade member.

(b) Training for Non-Industrial Fire Brigade Personnel.

Plant personnel who respond with the industrial fire brigade shall be trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.

(c)

• Drills. All of the following requirements shall apply.

(1) Drills shall be conducted quarterly for each shift to test the response capability of the industrial fire brigade.

(2) Industrial fire brigade drills shall be developed to test and challenge industrial fire brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall evaluate the industrial fire brigade's abilities to react, respond, and demonstrate proper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.

(3) Industrial fire brigade drills shall be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards.

(4) Drill records shall be maintained detailing the drill scenario, industrial fire brigade member response, and No Further Clarification.

Reference Document TPP-2119, Emergency Services Training Program, Rev. 011 HNP-M/BMRK-0012, Code Compliance Evaluation NFPA 600, Standards on Industrial Fire Brigades, Rev. 0, 3/27/2008 Document Detail FAQ 06-0007, Rev.

003 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 22 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance ability of the industrial fire brigade to perform as a team.

(5) A critique shall be held and documented after each drill.

Compliance Statement Compliance Basis Reference Document Document Detai!

b) Complies c) Complies No Additional Clarification No Additional Clarification EGR-NGGC-0007, Fire Brigade Program, Rev. 0 HNP-M/BMRK-0012, Code Compliance Evaluation NFPA 600, Standards on Industrial Fire Brigades, Rev. 0, 3/27/2008 HNP-M/BMRK-0012, Code Compliance Evaluation NFPA 600, Standards on Industrial Fire Brigades, Rev. 0, 3/27/2008 TPP-219, Emergency Services Training Program, Rev. 011 3.4.4 Fire-Fighting Equipment.

3.4.5 Off-Site Fire Department Interface.

3.4.5.1 Mutual Aid Agreement.

3.4.5.2 Site-Specific Training.

3.4.4 Fire-Fighting Equipment.

Protective clothing, respiratory protective equipment, radiation monitoring equipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrial fire brigade. This equipment shall conform with the applicable NFPA standards.

N/A 3.4.5.1 Mutual Aid Agreement.

Off-site fire authorities shall be offered a plan for their interface during fires and related emergencies on site.

3.4.5.2* Site-Specific Training.

Fire fighters from the off-site fire authorities who are expected to respond to a fire at the plant shall be offered site-specific training and shall be invited to participate in a drill at least annually.

Complies with Clarification IPP-630, Respiratory Irotection Program, Rev. 020

hearon Harris FSAR,

hearon Harris FSAR Section 9.5.1, page 9.5.1-25 & 26 N/A Complies Complies N/A - General statement; No technical requirements No Additional Clarification No Additional Clarification FPP-001, Fire Protection Program Manual, Rev. 029 TPP-219, Emergency Services Training Program, Rev. 011 TPP-219, Emergency Services Training Program, Rev. 011 FPP-001, Fire Protection Program Manual, Rev. 029 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 23 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.4.5.3 Security and Radiation Protection.

3.4.6 Communications.

3.4.5.3* Security and Radiation Protection.

Plant security and radiation protection plans shall address off-site fire authority response.

3.4.6* Communications.

An effective emergency communications capability shall be provided for the industrial fire brigade.

Complies Complies No Additional Clarification No Further Clarification PLP-201, Emergency Plan, Section 4.7 Rev. 052 HNP Physical Security and Safeguards Contingency Plan (SGI)

SP-015, Emergency Plan Support, Rev. 016 FPP-001, Fire Protection Program Manual, Rev. 029 FSAR Section 9.5.2, Communication System 8.5.4.c/ 8.6.1 3.5 Water Supply N/A N/A N/A - General statement; No technical requirements 3.5.1 [Water Supply Flow Code Requirements]

3.5.1 A fire protection water supply of adequate reliability, quantity, and duration shall be provided by one of the two following methods.

(a) Provide a fire protection water supply of not less than two separate 300,000-gal (1,135,500-L) supplies.

(b) Calculate the fire flow rate for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This fire flow rate shall be based on 500 gpm (1892.5 L/min) for manual hose streams plus the largest design demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulically least demanding portion of fire main loop out of service.

Complies Via Previous Approval Shearon Harris SER, Shearon Harris SER Shearon Harris FSAR Amendment 53 Pg 9-51 section 9.5.1, page 9.5.1-20 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 24 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Compliance Basis 3.5.2 [Water Supply Tank 3.5.2*

Complies with Code Requirements]

The tanks shall be interconnected such that fire pumps Clarification can take suction from either or both. A failure in one tank or its piping shall not allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

Reference Document Shearon Harris FSAR Amendment 53 NUREG 1083, NUREG 1083 Shearon Harris FSAR, Shearon Harris FSAR Document Detail section 9.5.1, page 9.5.1-21 sec 9.5.1, pg 9-21 Exception No. 1: Water storage tanks shall not be required when fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated.

Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.

3.5.3*

Complies Fire pumps, designed and installed in accordance with NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.

3.5.3 [Water Supply Pump Code Requirements]

Compliance with NFPA 20-1972 is as identified Shearon Harris FSAR within calculation HNP-M/BMRK-0007.

Amendment 53 FAQ 06-0008, NFPA Code Evaluations HNP-M/BMRK-0007, Code Compliance Evaluation NFPA 20 - Centrifugal Fire Pumps, Rev. 001 section 9.5.1, page 9.5.1-21 3.5.4 [Water Supply Pump Diversity and Redundancy]

3.5.4 At least one diesel engine-driven fire pump or two more seismic Category I Class IE electric motor-driven fire pumps connected to redundant Class IE emergency power buses capable of providing 100 percent of the required flow rate and pressure shall be provided.

Complies No Additional Clarification Shearon Harris FSAR Amendment 53 section 9.5.1, page 9.5.1-21 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 25 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.5.5 [Water Supply Pump Separation Requirements]

Reg u irements/Gu idance Reference Document Document Detail section 9.5.1, page 9.5.1-21 3.5.5 Complies via Previous Each pump and its driver and controls shall be separated Approval from the remaining fire pumps and from the rest of the plant by rated fire barriers.

Shearon Harris FSAR Amendment 53 NUREG 1083, NUREG 1083 3.5.6 [Water Supply Pump Start/Stop Requirements]

3.5.7 [Water Supply.

Pump Connection Requirements]

3.5.8 [Water Supply Pressure Maintenance Limitations]

3.5.9 [Water Supply Pump Operation Notification]

3.5.6 Fire pumps shall be provided with automatic start and manual stop only.

3.5.7 Individual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizing valves between connections.

3.5.8 A method of automatic pressure maintenance of the fire protection water system shall be provided independent of the fire pumps.

3.5.9 Means shall be provided to immediately notify the control room, or other suitable constantly attended location, of operation of fire pumps.

Complies Complies Complies Complies No Additional Clarification No Additional Clarification No Additional Clarification No Additional Clarification Shearon Harris FSAR Amendment 53 2165-S-0555, Rev. 18 Shearon Harris FSAR Amendment 53 2165-S-0557, Rev. 7 2165-S-0556, Rev. 13 NUREG 1083, NUREG 1083 Shearon Harris FSAR Amendment 53 Shearon Harris SER, Shearon Harris SER Shearon Harris FSAR Amendment 53 section 9.5.1, page 9.5.1-22 section 9.5.1. page 9.5.1-21A section 9.5.1, page 9.5.1-22 sec 9.5.1, pg 9.5.1-22 section 9.5.1, page 9.5.1-21A HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 26 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.5.10 [Water Supply Yard Main Code Requirements]

3.5.10 An underground yard fire main loop, designed and installed in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be installed to furnish anticipated water requirements.

Complies HNP complies with NFPA 24-1977 as described in HNP-M/BMRK-0008.

Reference Document Shearon Harris FSAR Amendment 53 HNP-M/BMRK-0008, Code Compliance Evaluation NFPA 24 - Standard for Outside Protection, Rev. 001 FAQ 06-0008, NFPA Code Evaluations Document Detail section 9.5.1, page 9.5.1-22 HNP HNP SSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 27 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.5.11 [Water Supply 3.5.11 Complies via Previous Yard Main Maintenance Means shall be provided to isolate portions of the yard fire Approval Issues]

main loop for maintenance or repair without simultaneously shutting off the supply to both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.

ýhearon Harris FSAR Section 9.5.1, page

,mendment 53 9.5.1-23

ýhearon Harris SER, Shearon pg 9.5.1-51 and 52 larris SER HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 28 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 3.5.12 [Water Supply Compatible Thread Connections]

3.5.12 Threads compatible with those used by local fire departments shall be provided on all hydrants, hose couplings, and standpipe risers.

Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate training and procedures are provided.

Complies Shearon Harris FSAR Amendment 53 section 9.5.1, page 9.5.1-23 3.5.13 [Water Supply Header Options]

3.5.14 [Nater Supply Control Valve Supervision]

3.5.13 Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, Code for Power Piping, are used for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve.

3.5.14*

All fire protection water supply and fire suppression system control valves shall be under a periodic inspection program and shall be supervised by one of the following methods.

(a) Electrical supervision with audible and visual signals in the main control room or other suitable constantly attended location.

(b) Locking valves in their normal position. Keys shall be made available only to authorized personnel.

(c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner/operator.

Complies with Clarification Shearon Harris FSAR Amendment 53 FPT-3002, Fire Main Valve Position Verification, Quarterly Interval, Modes: All, Rev. 018 FPP-001, Fire Protection Program Manual, Rev. 029 NUREG-1 038 Supplement 3, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 3, 5/1/1986 Shearon Harris FSAR Amendment 53 section 9.5.1, page 9.5.1-23 All 9.5.1 section 9.5.1, page 9.5.1-23 Complies via Previous Approval HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 29 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.5.15 [Water Supply Hydrant Code Requirements]

Requirements/Guidance Reference Document 3.5.15 Complies via Previous Hydrants shall be installed approximately every 250 ft (76 Approval m) apart on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system.

Exception: Mobile means of providing hose and associated equipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses.

Shearon Harris FSAR Amendment 53 NUREG-1038 Supplement 4, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 4, 10/1/1986 Document Detail section 9.5.1, page 9.5.1-23 3.5.16 [Water Supply Dedicated Limits]

3.5.16*

The fire protection water supply system shall be dedicated for fire protection use only.

Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis.

Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section.

License Amendment Required Shearon Harris FSAR kmendment 53 3D-149, Fire Protection System, Rev. 017 section 9.5.1, page 9.5.1-20 section 5.2 3.6 Standpipe and Hose Stations.

N/A N/A N/A - General statement; No technical requirements HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 30 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Compliance Basis Reference Document 3.6.1 [Standpipe and Hose Station Code Requirements]

3.6.1 Complies Via For all power block buildings, Class Ill standpipe and hose Previous Approval systems shall be installed in accordance with NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems.

NUREG-1038 Supplement 4, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 4, 10/1/1986 NUREG-1038 Supplement 1, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 1,6/1/1984 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 HNP-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001 SHNPP FSAR 9.5.1 Document Detail section 9.5.1 section 9.5.1 Section 9.5.1 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 31 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

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Requuirements/Guidance Reference Document Document Detail 3.6.2 [Standpipe and Hose Station Capability Limitations]

3.6.2 Complies A capability shall be provided to ensure an adequate water flow rate and nozzle pressure for all hose stations. This capability includes the provision of hose station pressure reducers where necessary for the safety of plant industrial fire brigade members and off-site fire department personnel.

No Additional Clarification NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 HNP SER initial and Supplement 4 SHNPP FSAR 9.5.1 AR 25032, Evaluation of NFPA 14 Deviations, 4/15/2002 HNP-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001 AR 76621, Evaluate Electrical Nozzles, 11/12/2003 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 32 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.6.3 [Standpipe and Hose Station Nozzle Restrictions]

3.6.3 The proper type of hose nozzle to be supplied to each power block area shall be based on the area fire hazards.

The usual combination spray/straight stream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or present an electrical hazard to fire-fighting personnel. Listed electrically safe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed.

Complies No Additional Clarification Reference Document NFPA 14-1976, Standpipes and Hose Stations NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 HNP SER initial and Supplement 4 Shearon Harris FSAR, Shearon Harris FSAR AR 76621, Evaluate Electrical Nozzles, 11/12/2003 AR 25032, Evaluation of NFPA 14 Deviations, 4/15/2002 Document Detail Section 9.5.1 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 33 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail Section 9.5.1 3.6.4 [Standpipe and 3.6.4 Hose Station Earthquake Provisions shall be made to supply water at least to Provisions]

standpipes and hose stations for manual fire suppression in all areas containing systems and components needed to perform the nuclear safety functions in the event of a safe shutdown earthquake (SSE).

Exception: For existing plants that are not capable of meeting this requirement, provisions to restore a water supply and distribution system for manual fire-fighting purposes shall be made. This provisional manual fire-fighting standpipe/hose station system shall be capable of providing manual fire-fighting protection to the various plant locations important to supporting and maintaining the nuclear safety function. The provisions for establishing this provisional system shall be preplanned and be capable of being implemented in a timely manner following an SSE.

Complies via Previous Approval Shearon Harris FSAR, Shearon Harris FSAR NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 HNP-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001 HNP SER initial and Supplement 4 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 34 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

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Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

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Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.6.5 [Standpipe and Hose Station Seismic Connection Limitations]

Reg uirements/Guidance Reference Document Document Detail 3.6.5 Where the seismic required hose stations are cross-connected to essential seismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement.

License Amendment Required HNP SER initial and Supplement 4 OP-139, Service Water System, Rev. 066 HNP-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001 SW-0087, ESW Supply to AFW Pumps, Air Compressors and Fire Protection, Rev. 001 NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Shearon Harris FSAR, Shearon Harris FSAR P&L 4.0.24 Section 9.5.1 3.7 Fire Extinguishers.

3.7 Fire Extinguishers.

Where provided, fire extinguishers of the appropriate number, size, and type shall be provided in accordance with NFPA 10, Standard for Portable Fire Extinguishers.

Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.

Complies with Clarification 166-S-2120 to 2127, WPB

ire Hazards Analysis

)rawings, Rev. latest 166-S-2112-2116, FHB Fire lazards Drawings, Rev. latest Zeg Evaluation 01-0682,

'onformance with NFPA 10,

ev. 0, 4/26/2001 166-S-2135, ESWISS Fire lazards Analysis Drawing, Zev. latest INP-M/BMRK-0005, CODE

'OMPLIANCE EVALUATION IFPA 10, PORTABLE FIRE

.XTINGUISHERS, Rev. 001 166-S-2129-2133 (TB), TB ire Hazards Analysis

)rawings, Rev. latest HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 37 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.8 Fire Alarm and Detection Systems.

3.8.1 Fire Alarm.

Requirements/Guidance Reference Document Document Detail N/A N/A N/A - General statement; No technical requirements 3.8.1 Fire Alarm.

Alarm initiating devices shall be installed in accordance with NFPA 72, National Fire Alarm Code&. Alarm annunciation shall allow the proprietary alarm system to transmit fire-related alarms, supervisory signals, and trouble signals to the control room or other constantly attended location from which required notifications and response can be initiated. Personnel assigned to the proprietary alarm station shall be permitted to have other duties. The following fire-related signals shall be transmitted:

(1) Actuation of any fire detection device (2) Actuation of any fixed fire suppression system (3) Actuation of any manual fire alarm station (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device (6) Indication of alarm system trouble condition 3.8.1.1 Means shall be provided to allow a person observing a fire at any location in the plant to quickly and reliably communicate to the control room or other suitable

.constantly attended location.

3.8.1.2 Means shall be provided to promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriate course of action:

(1) General site population in all occupied areas (2) Members of the industrial fire brigade and other groups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services Complies FSAR 9.5.1 HNP-M/BMRK-0001, CODE COMPLIANCE EVALUATION NFPA 72E, AUTOMATIC FIRE DETECTORS, Rev. 001 HNP-M/BMRK-0002, CODE COMPLIANCE EVALUATION NFPA 72D, PROPRIETARY PPROTECTIVE SIGNALING SYSTEM, Rev. 001 3.8.1.1 [Fire Alarm Communication Requirements]

3.8.1.2 [Fire Alarm Prompt Notification Limits]

Complies Complies No Additional Clarification No Additional Clarification FPP-002, Fire Emergency, Rev. 031 FPP-002, Fire Emergency, Rev. 031 Section 8.6.1 page 13 Section 8.6.1 page 13 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 38 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Compliance Basis Complies 3.8.2 Detection.

3.8.2 Detection.

If automatic fire detection is required to meet the performance or deterministic requirements of Chapter 4, then these devices shall be installed in accordance with NFPA 72, National Fire Alarm Code, and its applicable appendixes.

Reference Document FSAR 9.5.1 HNP-M/BMRK-0001, CODE COMPLIANCE EVALUATION NFPA 72E, AUTOMATIC FIRE DETECTORS, Rev. 001 HNP-M/BMRK-0002, CODE COMPLIANCE EVALUATION NFPA 72D, PROPRIETARY PPROTECTIVE SIGNALING SYSTEM, Rev. 001 Document Detail 3.9 Automatic and N/A Manual Water-Based Fire Suppression Systems.

3.9.1 [Fire Suppression 3.9.1*

System Code If an automatic or manual water-based fire suppression Requirements]

system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:

(1) NFPA 13, Standard for the Installation of Sprinkler Systems (2) NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection (3) NFPA 750, Standard on Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems N/A N/A - General statement; No technical requirements Complies with Clarification

)BD-317, WATER BASED 3UPPRESSION SYSTEMS, Rev. 04, 8/25/2004 HNP-M/BMRK-0009, Code Compliance Evaluation NFPA 13, Sprinkler Systems, Rev.

001, 12/13/2004 3.9.2 [Fire Suppression System Flow Alarm]

3.9.3 [Fire Suppression System Alarm Locations]

3.9.2 Each system shall be equipped with a water flow alarm.

3.9.3 All alarms from fire suppression systems shall annunciate in the control room or other suitable constantly attended location.

Complies Complies No Additional Clarification No Clarification Required SHNPP FSAR 9.5.1 Amendment 48 SHNPP FSAR 9.5.1 Amendment 48 Section 9.5.1, page 9.5.1-23 Section 9.5.1, page 9.5.1-25 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 39 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detail 9-51 3.9.4 [Fire Suppression System Diesel Pump Sprinkler Protection]

3.9.4 Diesel-driven fire pumps shall be protected by automatic sprinklers.

Complies via Previous Approval UREG-1038, Safety valuation Report Related to e Operation of the Shearon arris Nuclear Power Plant, nits 1 and 2 - Docket Nos.

TN-50-400 and STN 50-401, ev. Original, 11/1/1983 HNPP FSAR 9.5.1 3.9.5 [Fire Suppression System Shutoff Controls]

3.9.6 [Fire Suppression System Valve Supervision]

3.9.5 Each system shall be equipped with an OS&Y gate valve or other approved shutoff valve.

Complies No Additional Clarification Shearon Harris FSAR, Shearon Harris FSAR Section 9.5.1, page 9.5.1-23 section 9.5.1, page 9.5.1-23 3.9.6 Complies via Previous All valves controlling water-based fire suppression Approval systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.

NUREG-1038 Supplement 3, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 3, 5/1/1986 Shearon Harris FSAR Amendment 53 OP-149, Fire Protection, Rev.

037 3.10 Gaseous Fire Suppression Systems.

N/A N/A N/A - General statement; No technical requirements HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 40 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report-Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

3.10.1 [Gaseous Suppression System Code Requirements]

3.10.2 [Gaseous Suppression System Alarm Location]

3.10.3 [Gaseous Suppression System Ventilation Limitations]

3.10.4 [Gaseous Suppression System Single Failure Limits]

3.10.5 [Gaseous Suppression System Disarming Controls]

Requirements/Guidance Reference Document Document Detail 3.10.1 If an automatic total flooding and local application gaseous fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:

(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems 3.10.2 Operation of gaseous fire suppression systems shall annunciate and alarm in the control room or other constantly attended location identified.

3.10.3 Ventilation system design shall take into account prevention from over-pressurization during agent injection, adequate sealing to prevent loss of agent, and confinement of radioactive contaminants.

3.10.4*

In any area required to be protected by both primary and backup gaseous fire suppression systems, a single active failure or a crack in any pipe in the fire suppression system shall not impair both the primary and backup fire suppression capability.

3.10.5 Provisions for locally disarming automatic gaseous suppression systems shall be secured and under strict administrative control.

N/A Gaseous suppression not used at HNP.

N/A N/A Gaseous suppression not used at HNP.

Gaseous suppression not used at HNP.

N/A Gaseous suppression not used at HNP.

N/A Gaseous suppression not used at HNP.

Gaseous suppression not used at HNP.

Gaseous suppression not used at HNP.

3.10.6 [Gaseous 3.10.6*

Suppression System C02 Total flooding carbon dioxide systems shall not be used in Limitations]

normally occupied areas.

3.10.7 [Gaseous 3.10.7 Suppression System C02 Automatic total flooding carbon dioxide systems shall be Warnings]

equipped with an audible pre-discharge alarm and discharge delay sufficient to permit egress of personnel.

The carbon dioxide system shall be provided with an odorizer.

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Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance 3.10.8 [Gaseous 3.10.8 Suppression System C02 Positive mechanical means shall be provided to lock out Required Disarming]

total flooding carbon dioxide systems during work in the protected space.

Compliance Statement Compliance Basis Reference Document Document Detail N/A N/A Gaseous suppression not used at HNP.

Gaseous suppression not used at HNP.

3.10.9 [Gaseous Suppression System Cooling Considerations]

3.10.10 [Gaseous Suppression System Decomposition Issues]

3.11 Passive Fire Protection Features 3.10.9 The possibility of secondary thermal shock (cooling) damage shall be considered during the design of any gaseous fire suppression system, but particularly with carbon dioxide.

3.10.10 Particular attention shall be given to corrosive characteristics of agent decomposition products on safety systems.

3.11 Passive Fire Protection Features.

This section shall be used to determine the design and installation requirements for passive protection features.

Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals. Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.

3.11.1 Building Separation.

Each major building within the power block shall be separated from the others by barriers having a designated fire resistance rating of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or by open space of at least 50 ft (15.2 m) or space that meets the requirements of NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures.

Exception: Where a performance-based analysis determines the adequacy of building separation, the requirements of 3.11.1 shall not apply.

3.11.2 Fire Barriers.

Fire barriers required by Chapter 4 shall include a specific fire-resistance rating. Fire barriers shall be designed and installed to meet the specific fire resistance rating using assemblies qualified by fire tests. The qualification fire tests shall be in accordancewith NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials.

N/A N/A Gaseous suppression not used at HNP.

N/A - General statement; No technical requirements 3.11.1 Building Separation.

Complies No Additional Clarification 2165-G-0002, PLOT PLAN, Rev. 023 E-5525, Safe Shutdown Analysis in Case of Fire, Rev.

015 2165-G-0003, SITE PLAN, Rev. 018 FSAR 9.5.1 LAP-83-479, Point by Point Comparison of HNP with NUREG-0800 NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.11.2 Fire Barriers.

Complies No Additional Clarification Conformance Sec.

C.5a(6), pg 43 Section 9.5.1.4, pg 9-47 & 48 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 42 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref.

Requirements/Guidance Compliance Statement Compliance Basis 3.11.3 Fire Barrier Penetrations.

3.11.3* Fire Barrier Penetrations.

Penetrations in fire barriers shall be provided with listed fire-rated door assemblies or listed rated fire dampers having a fire resistance rating consistent with the designated fire resistance rating of the barrier as determined by the performance requirements established by Chapter 4. (See 3.11.3.4 for penetration seals for through penetration fire stops.) Passive fire protection devices such as doors and dampers shall conform with the following NFPA standards, as applicable:

(1) NFPA 80, Standard for Fire Doors and Fire Windows (2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety Code Exception: Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, a performance-based analysis shall be required to assess the adequacy of fire barrier forming the fire boundary to determine if the barrier will withstand the fire effects of the hazards in the area. Openings in fire barriers shall be permitted to be protected by other means as acceptable to the AHJ.

Complies Via Previous Approval Reference Document NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 SHNPP FSAR 9.5.1 LAP-83-479, Point by Point Comparison of HNP with NUREG-0800 NUREG-1038, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 Document Detail Complies with Clarification NLS-86-137, Rev 3 Point by Point Comparison of HNP to Requirements of NUREG 0800, 5/7/1986 Shearon Harris FSAR, Shearon Harris FSAR HNP-M/BMRK-0004, Code Compliance Evaluation NFPA 90A, Air Conditioning and Ventilating Systems (1981),

Rev. 001 NUREG-1038 Supplement 4, Safety Evaluation Report Related to the Operation of the Shearon Harris Nuclear Power Plant, Unit 1 - Docket No. STN-50-400, Rev. SSER 4, 10/1/1986 HNP-M/BMRK-0003, Code Compliance Evaluation NFPA 80, Standard for Fire Doors and Windows, Rev. 001 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 43 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document 3.11.4 Through Penetration Fire Stops.

3.11.4* Through Penetration Fire Stops.

Complies Via Through penetration fire stops for penetrations such as Previous Approval pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, and similar building service e.quipment that pass through fire barriers shall be protected as follows.

(a) The annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire-resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. The assembly shall be qualified by tests in accordance with a fire test protocol acceptable to the AHJ or be protected by a listed fire-rated device for the specified fire-resistive period.

(b) Conduits shall be provided with an internal fire seal that has an equivalent fire-resistive rating to that of the fire barrier through opening fire stop and shall be permitted to be installed on either side of the barrier in a location that is as close to the barrier as possible.

Exception: Openings inside conduit 4 in. (10.2 cm) or !ess in diameter shall be sealed at the fire barrier with a fire-rated internal seal unless the conduit extends greater than 5 ft (1.5 m) on each side of the fire barrier. In this case the conduit opening shall be provided with noncombustible material to prevent the passage of smoke and hot gases. The fill depth of the material packed to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application.

NUREG-1038, Safety Evaluation Report Related to

.he Operation of the Shearon

-Harris Nuclear Power Plant, Jnits 1 and 2 - Docket Nos.

3TN-50-400 and STN 50-401, Rev. Original, 11/1/1983 LAP-83-479, Point by Point Comparison of HNP with NUREG-0800 Document Detai' Section 9.5.1.4, pg 9-47 Conformance Sec C.5.a(3), pg 39 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 44 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

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Table B NFPA 805 Ch. 3 Transition Compliance Statement Compliance Basis NFPA 805 Ch. 3 Ref.

Requirements/Guidance Reference Document Document Detaii 3.11.5 Electrical Raceway 3.11.5* Electrical Raceway Fire Barrier Systems (ERFBS). Complies with Fire Barrier Systems ERFBS required by Chapter 4 shall be capable of resisting Clarification (ERFBS).

the fire effects of the hazards in the area. ERFBS shall be tested in accordance with and shall meet the acceptance criteria of NRC Generic Letter 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Safe Shutdown Trains Within the Same Fire Area." The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The fire barrier system's ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated.

Exception No. 1: When the temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, "Fire Endurance Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevated temperatures shall be demonstrated. Qualification demonstration of these cables shall be performed in accordance with the electrical testing requirements of Generic Letter 86-10, Supplement 1, Attachment 1, "Attachment Methods for Demonstrating Functionality of Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure."

Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements-as specified by the AHJ at the time of acceptance.

M1L061140227, Issuance of Amendment on use of Fire Resistive Cable, 5/1/2006 HNP HNPSSCA Review PE ver 1.0.5 Build 20_05-06-2008_Working Copy.mdb Page 46 of 46 11/10/2008 Transition Tool Version 1.0.5 Page A HNP NFPA 805 Transition Report - Rev la.docx

Progress Energy HNP NFPA 805 Transition Report Attachment G - Operator Manual Actions - Transition to Recovery Actions (Non-Security Sensitive)

G.1

Background

NEI 04-02 suggests that a licensee submit a summary of its approach for addressing the transition of OMAs as recovery actions in the LAR (Regulatory Position C.1 and NEI-04-02, Rev. 1, Section 4.6). As a minimum, NEI 04-02 suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensee's methodology.

This process is addressed in draft FAQ 07-0030. The process in draft FAQ 07-0030 was discussed at the September 29, 2008 public meeting on the Harris Nuclear Plant LAR (ML082600736) and at the October 3, 2008 public meeting on the Pilot Plant LARs Lessons Learned (ML082520076).

Sections G.2 through G.7 provide the process from draft FAQ 07-0030 and the results of the HNP review. Section G.8 provides HNP specific supplemental information.

G.2 Operator Manual Action Transition Methodology The following process was utilized for transitioning OMAs:

" Establishment of OMA Evaluation Groups. See discussion in Section G.3.

" Determination of whether a transitioning OMA is a post-transition recovery action, a defense-in-depth action, or neither. See discussion in Section G.4.

" Evaluation of the additional risk presented by the use of recovery actions credited in the analysis post-transition as a compliance strategy. See discussion in Section G.5.

" Evaluation of the feasibility of the recovery and DID actions credited in the analysis post-transition. See discussion in Section G.6.

E Evaluation of the reliability of recovery actions credited in the analysis post-transition as a compliance strategy. See discussion in Section G.7.

Note: Section 1.6.52 of NFPA 805 dated 2001 provides a definition'of rec6veiy-action:!,

"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."

Based on this definition, Alternative Shutdown actions (Bin D OMAs) at:the primary control station are not considered recovery actions.

NFPA 805 does not provide a definition of "primary control station'." Since no definition is provided, the definition of "emergency control station" from Regulatory Guide 1.189, Revision 1 will be utilized. as the definition of "primary control station".in a post-transitionNFPA 805 program:

"A location outside the main control room where actions are taken by operations personnel to manipulate plant systems and controls to achieve safe shutdown of the reactor."

Page G HNP NFPA805 Transition Report - Redacted[I]..

Progress Energy HNP NFPA 805 Transition Report For the purposes of recovery action definition, primary control stations include remote/alternative shutdown panels, valve control stations, local instrumentation/monitoring panels, and component controls provided at motor control panels, load centers, switchgear, etc.

Local manual valve operation, repairs, and operation of components manually at the component location or breaker due to loss of power/control are not considered primary control stations.

A clarification on the definition of recovery actions/primary control stations was presented by the NRC at the October 3, 2008 public meeting on Pilot Plant LARs lessons learned (ML082520076).

NFPA 805 does not specifically define DID actions that operations may take to respond to a fire (e.g., opening breakers, manually positioning valves). The process for determining whether a pre-transition OMA should be classified as a DID action is discussed in Section G.4.

G.3 Establishment of OMA Evaluation Groups G.3.1 Process Figure G-1 depicts the general process for establishing OMA evaluation groups. This process

'bins' transitioning OMAs. The 'bin' identifiers are for ease of reference. In following the chart, once the action is defined for the first time it is "binned" and not considered for any other categorization.

Action is taken inside of No Action taken to Achieve &

No Action is a Normally No ction Credited for App.

No th Mi Cnto Ro? aitinCldShtowManually Operated R Section 111.G.3 tt~ Man Cntrl RomMaitai Cod SutdwnSwitchlnalve (NUREG-0800) C5.c).

BinA5mBBin C

EiD Yes Yes Yes Yes Figure G-1 General Process to Transition Operator Manual Actions (Ref. FAQ 06-0012)

Page G HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report OMAs that are allowed and/or have been previously reviewed and approved by the NRC (as documented in an approved exemption/deviation/SER) can be transitioned without using the change evaluation process.

This process was established in FAQ 06-0012 (Closure Memo ML072340368). Examples of the OMA bins and clarification on the process are provided in FAQ 06-0012.

G.3.2 Results A list of pre-transition OMAs and the results of the binning process is provided in Table G-2.

G.4 Characterization of Post-Transition Actions G.4.1 Process In addition to the determination of the OMAs that require a change evaluation (i.e.,

determination of OMA evaluation groups in Section G.3), the process outlined in Figure G-2 was used to determine the scope of recovery actions and defense-in-depth actions that will remain following NFPA 805 transition.

Page G HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Doument Resuit -

I I

Reoey cin Additional Risk of No FurthereAction I

Y

.es Recovery Action Review As NECESSARY Procedure Revisions / Feasibility Assessment Figure G-2 Determination of Post-Transition Recovery Actions and Necessary Supporting Analyses G.4.1.1 FAQ 06-0012 OMA Binning Process The process begins with the binning of all pre-transition OMAs per FAQ 06-0012, as described in Section G-3. The outcome of the binning process, with respect to the determination of credit taken for recovery actions, could result in the following categories, based upon draft FAQ 07-0030:

" Bin H OMAs, which should be addressed by the RI-PB change evaluation process.

" Pre-transition allowed OMAs, which do not conflict with regulatory requirements (Bins B, C, E, F, and G). 4 These actions should be assessed in the OMA Transition Review to determine if the actions should be:

o Recovery actions, or o

DID actions, or o

Neither recovery actions nor DID actions.

4 Bin A (Actions taken in the main control room) are not considered OMAs (pre-transition) or recovery actions (post-transition), and can be excluded from additional consideration.

Page G HNP NFPA 805 Transition Report - Rev i.docx

Progress Energy HNP NFPA 805 Transition Report

" Bin D OMAs to support implementation of alternative shutdown capability per 10 CFR 50, Appendix R, Section III.G.3 (C.5.c of NUREG-0800) are allowed under the current regulations. Due to the unique circumstances associated with alternative shutdown capability, these actions should be retained as recovery actions.5

" Bin F OMAs are those not associated with alternative shutdown that have prior NRC approval. These actions may be treated as recovery actions without additional OMA Transition Review. A licensee may choose to treat these in other Bins as appropriate and disposition them in accordance with the process.

G.4.1.2 Other Variances from Deterministic Requirements Depending on how variances from the deterministic requirements are characterized, a variance may or may not be designated as a Bin H OMA. For example, a variance may be characterized as a cable lacking protection/separation per the pre-transition deterministic criteria. In these instances, the change evaluation will initially assess the condition for acceptability without crediting an OMA. An output of the change evaluation may be the need for a recovery action (that did not exist as a pre-transition OMA), or the need for a post-transition defense-in-depth action (that did not exist as a pre-transition OMA). These actions should be included as part of the OMA Transition Review.

G.4.1.3 NFPA 805 Change Evaluation - Process Bin H OMAs were evaluated as part of the RI-PB change evaluation process, as described in Section 4.5 of this transition report. Typically, the condition that necessitated the need for the pre-transition OMA is evaluated. For example, the condition could be a spurious operation of a component due to potential fire damage to a cable. If the OMA is credited to meet the change evaluation acceptance criteria and is modeled in the Fire PRA, then the OMA is considered a post-transition recovery action.

If the OMA is not credited to meet the change evaluation acceptance criteria, the OMA was included with the currently allowed OMAs as part of the OMA Transition Review to determine if the OMA should be characterized as a post-transition 'defense-in-depth' action.

G.4.1.4 OMA Transition Review Process

'OMA Transition Review' is the process for reviewing OMAs that are not initially categorized as recovery actions to determine if they warrant additional consideration as recovery actions, defense-in-depth actions, or neither.

The first step in the OMA transition review was to assess allowed OMAs characterized as Bin B, C, E, F, and G for their necessity in the Fire PRA. This step is intended to identify OMAs that are modeled in the Fire PRA and are credited as providing a risk benefit worthy of characterization as a 'recovery action'. Those OMAs that are either not modeled in the Fire PRA or that are modeled in the Fire PRA but do not provide a fire risk benefit worthy of characterization as a 'recovery action' were assessed further for retention as a defense-in-depth 5 Note that the definition of recovery actions in Section 1.6.52 of NFPA 805 includes only those actions

"...outside of the main control room or outside of the primary control station(s)...". Therefore, Bin D OMAs at the primary control station are not considered recovery actions and need not be addressed by the OMA Transition Review for additional considerations, other than impact of these primary control station actions on the performance of other actions (e.g., timing, coordination of actions, etc.).

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Progress Energy HNP NFPA 805 Transition Report action. This determination of risk is part of the process for evaluating the additional risk of the use of recovery actions discussed in Section G.5.

The second step of the OMA transition review determined whether these remaining OMAs (including those that were not credited as recovery actions in the change evaluations) should be considered as DID actions. This review required judgment and was based on factors such as:

" Relevant scenarios in the Fire PRA that involve the OMA/cable discrepancy of concern.

For example, an action that was not credited as a recovery action may exist in a fire area with higher fire risk or in scenarios with a high calculated CCDP/CDF. These types of actions would be considered good candidates for DID actions.

" The timing of the action.

An OMA, although not considered a recovery action, may need to be accomplished in a short time frame (for example, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) under deterministic fire damage assumptions.

" Integration of other elements of defense-in-depth.

A fire area with an inadequate balance of defense-in-depth elements may warrant strengthening of the third element of defense in depth: "Providing an adequate level of fire protection for SSCs important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed"(NFPA 805 Section 1.2(3)). For example, an area without automatic detection and a high scenario CCDP may warrant a defense-in-depth action. Although the OMA Transition Review is not a formal change evaluation, the principles in NEI 04-02 Section 5.3 can be used as a guide for review of defense-in-depth.

" Additional actions related to modeling differences between the Fire PRA and NSCA.

There are known modeling differences between a Fire PRA and NSCA due to different success criteria, end states, etc. Although an OMA may be associated with a function that is not considered a significant contribution to CDF, the OMA may be considered important enough to the NSCA to retain as a DID action. An example would be components in the NSCA associated with maintaining natural circulation at a PWR that are not modeled explicitly in the Fire PRA since they are not part of a core damage sequence.

Resolution of vulnerabilities identified as part of the Fire PRA related to the loss of function associated with the pre-transition allowed OMAs should be included in the overall integrated decision-making process associated with the NFPA 805 transition. For example, the fire-induced cable losses prompting the need for an allowed OMA may be a significant contributor to risk in the Fire PRA. Although a change evaluation is not required to address these risk contributors, other decisions to reduce fire risk from the PRA insight may include enhancements to address these items.

G.4.2 Results Each pre-transition OMA was characterized as a 'recovery action, 'defense-in-depth action', or neither. There were no Bin H OMAs that were transitioned as recovery actions. The only OMAs that have been retained as Recovery Actions are those being credited for Alternative Shutdown (Bin D). Those 'defense-in-depth actions' that will continue to be used in the fire safe Page G-6-- HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 905 Transition Report shutdown procedures are required to meet the feasibility criteria provided in Section G.6. A list of pre-transition OMAs and their characterization as a 'recovery action, 'defense-in-depth action', or neither is provided in Table G-2.

G.5 Evaluation of the Additional Risk of the Use of Recovery Actions G.5.1

Background

NFPA 805 Section 4.2.3.1 does not allow recovery actions when using the deterministic approach to meet the nuclear safety performance criteria. However, the use of recovery actions is allowed by NFPA 805 using a performance-based, risk informed approach, provided that the additional risk presented by the recovery actions has been evaluated by the licensee in accordance with NFPA 805 Section 4.2.4.

Section 4.2.4 of NFPA 805 (2001) states:

"4.2.4* Performance-Based Approach. This subsection shall provide for a performance-based alternative to the deterministic approach provided in 4.2.3. When the use of recovery actions has resulted in the use of this approach, the additional risk presented by their use shall be evaluated. When the fire modeling or other engineering analysis, including the use of recovery actions for nuclear safety analysis, is used, the approach described in 4.2.4.1 shall be used. When fire risk evaluation is used, the approach described in 4.2.4.2 shall be used."

The explanatory material in Appendix A to NFPA 805 states:

"A.4.2.4 Where recovery actions are the primary means to recover and re-establish any of the nuclear safety performance criteria (e.g., inventory and pressure control; decay heat removal), in lieu of meeting the deterministic approach as specified by 4.2.3, risk can be increased. The risk for the fire area and the risk presented by the implementation of recovery actions to recover the nuclear safety function should be compared to the risk associated with maintaining the function free of fire damage in accordance with the deterministic requirements specified in Chapter 4. Additional fire protection systems and features might have to be provided in the fire area to balance the risk."

The treatment of additional risk may vary in approach based on its characterization in previous steps and its level of modeling in the Fire PRA. The categories used to define the methods for treatment of additional risk presented by the use of recovery actions are:

" Alternative Shutdown Recovery Actions (G.5.2)

" Non-Alternative Shutdown Actions (G.5.3)

In addition, the review of potential negative risk for OMAs is discussed in Section G.5.4.

G.5.2 Alternative Shutdown Recovery Actions G.5.2.1 Process Due to the unique circumstances associated with alternative shutdown capability, the Bin D actions should be retained as recovery actions by the NSCA. The Fire PRA performed as part of NFPA 805 transition included the evaluation of alternative shutdown fire areas. The Page G HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report additional risk presented by the use of recovery actions for alternative shutdown fire areas (addressed by 10 CFR 50, Appendix R Section III.G.3/NUREG-0800 Section C.5.c) was addressed by inclusion of these fire areas in the Fire PRA performed as part of the NFPA 805 transition.

OMAs relied upon in alternative shutdown fire areas can be assessed qualitatively or quantitatively to determine risk impact. OMAs may or may not be explicitly modeled in the Fire PRA for alternative shutdown fire areas. Fire areas relying on control room abandonment for pre-transition deterministic compliance (e.g., Control Room fires) are modeled in the Fire PRA using guidance from NUREG/CR-6850 Task 11 (Section 11.5.2). The alternative shutdown recovery actions are not explicitly modeled in the Fire PRA.

OMAs that can contribute significantly to the overall integrated decision-making process associated with the NFPA 805 transition should be identified.

An alternative approach to characterization of the Bin D OMAs as recovery actions would be to eliminate/modify the Bin D OMAs using the change evaluation process as part of the NFPA 805 transition process.

G.5.2.2 Results The alternative safe shutdown recovery actions are not modeled in the fire PRA for those fire scenarios in the Main Control Room that result in control room abandonment. This provides a bounding evaluation. For other areas where the alternative safe shutdown actions could be implemented, the recovery actions that are included in the fire PRA are those actions that have been previously modeled in the PRA. An example would be manually starting an auxiliary feed water pump to provide a secondary heat sink. This action is included when appropriate or subsumed within related operator actions in the PRA.

G.5.3 Non-Alternative Shutdown Actions G.5.3.1 Process G.5.3.1.1 Change Evaluation Recovery Actions Pre-transition unallowed OMAs (Bin H OMAs per FAQ 06-0012) that are to be credited as recovery actions in a RI-PB change evaluation, including modeling in the Fire PRA, should be specifically addressed using the Fire PRA for additional risk presented by their use. NFPA 805, Section 4.2.4.2 states that the risk evaluation should compare the risk associated with implementation of the deterministic requirements with the proposed alternative (in this case the recovery actions).

G.5.3.1.2 Other Actions (e.g., Defense-in-Depth)

NFPA 805 requires the evaluation of additional risk when the use of recovery actions is credited to meet the nuclear safety performance criteria. Since these actions are defense-in-depth actions, an assessment of the additional risk is not necessary. Note that a negative risk impact described in NEI 04-02 Section B.2.2.4.3.3 provides a mechanism for identifying adverse risk associated with performing an OMA.

Note: As part of the Fire PRA development, OMAs were typically not included in the Fire PRA model unless a more realistic treatment could result in a risk benefit. Therefore, a detailed assessment of risk of performing these actions is not necessary and the risk of the individual scenarios without credit for the action would bound the risk of crediting the action in the Fire Page G HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report PRA. This bounding approach would be applicable to any actions determined not to be modeled in the Fire PRA as part of Step 1 of the OMA Transition Review and that should be retained as a defense-in-depth action. While the process shown in Figure G-2 does not explicitly require an assessment of the additional risk (since defense-in-depth actions are not

'credited recovery actions'), the bounding approach envelopes any additional risk associated with these actions. Due to the low risk benefit of performance of defense-in-depth actions, the additional effort per NUREG 1852 does not add measurable benefit.

G.5.3.1.3 Recovery Actions For pre-transition allowed OMAs that were credited in the Fire PRA model (i.e., those that were already included as well as those that were added to the model), a quantitative assessment of risk similar to that required for a Bin H (unallowed) manual action should be performed (or a qualitative bounding assessment) to determine if the action provides a risk benefit worthy of characterization as a recovery action. In this assessment, similar to the evaluation of a variance, the additional risk presented by the use of the action is essentially a comparison of the risk of the action compared to maintaining the function free of fire damage.

G.5.3.2 Results The only recovery actions that are being retained are Bin D actions, and they have been addressed in the discussion above.

The other OMAs credited in the deterministic safe shutdown analysis were considered for inclusion in the fire PRA. However, it was concluded that the limited credit that could be given to these actions in the PRA would not result in a significant reduction in CDF. Therefore, no additional actions were included in the fire PRA model, and no other actions are credited as recovery actions. These actions were reviewed for retention as defense-in-depth actions.

G.5.4 Fire PRA Review for Negative Risk Impact G.5.4.1 Process In addition to the evaluation of risk presented by the use of recovery actions per Section 4.2.4 of NFPA 805, additional reviews should be performed to determine those actions that could have a negative impact on plant risk. If recovery actions are determined to have a negative risk impact, they should be resolved during NFPA 805 implementation via an alternate strategy that eliminates the need for crediting the action for success in the NSCA. Defense-in-depth actions should also be evaluated to ensure there are no adverse impacts on NSCA performance.

G.5.4.2 Results Pre-transition OMAs were reviewed to determine those that when implemented could have a negative effect on the PRA results by increasing the Core Damage Frequency (CDF) or Large Early Release Frequency (LERF). Those OMAs with negative effects are being revised by implementing alternate strategies to eliminate their need, or the action has been modified to mitigate the negative effects. The Fire PRA does not credit these actions. Thus, there are no adverse effects from these actions.

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Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report G.6 Evaluation of the Feasibility of Recovery and Defense-in-Depth Actions G.6.1 Process Recovery actions and defense-in-depth actions were evaluated against the feasibility criteria shown below in Table G-1.

Table G-1 Feasibility Criteria -Recovery Actions and Defense-in-Depth Actions (Based on NFPA 805 Appendix B.5.2(e)and NEI 04-02 Revisionl)

I Demonstrations The proposed recovery actions should be verified in the field to ensure the action can be physically performed under the conditions expected during and after the fire event.

2 Systems and Indications Consider availability of systems and indications essential to perform the recovery action.

3 Communications The communications system should be evaluated to determine the availability of communication, where required for coordination of recovery actions.

4 Emergency Lighting*

The lighting (fixed and/or portable) should be evaluated to ensure sufficient lighting is available to perform the intended action.

5 Tools-Equipment*

Any tools, equipment, or keys required for the action should be available and accessible. This includes consideration of SCBA and personal protective equipment if required. (This includes staged equipment for repairs).

6 Procedures Written procedures should be provided.

7 Staffing Walk-through of operations guidance (modified, as necessary, based on the analysis) should be conducted to determine if adequate resources are available to perform the potential recovery actions within the time constraints (before an unrecoverable condition is reached), based on the minimum shift staffing. The use of essential personnel to perform actions should not interfere with any collateral industrial fire brigade or control room duties.

8 Actions in the Fire Area*

When recovery actions are necessary in the fire area under consideration or require traversing through the fire area under consideration, the analysis should demonstrate that the area is tenable and that fire or fire suppressant damage will not prevent the recovery action from being performed.

9 Time*

Sufficient time to travel to each action location and perform the action should exist. The action should be capable of being identified and performed in the time required to support the associated shutdown function(s) such that an unrecoverable condition does not occur. Previous action locations should be considered when sequential actions are required.

10 Training Training should be provided on the post-fire procedures and implementation of the recovery actions.

II Drills Periodic drills that simulate the conditions to the extent practical, (e.g., communications between the control room and field actions, the use of SCBAs if credited, the appropriate use of operator aids)

• This feasibility criterion will be performed for time critical recovery and DID actions (less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />)

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Progress Energy HNP NFPA 805 Transition Report G.6.2 Results G.6.2.1 MSO Impact on Thermal-Hydraulic Analyses The review of fire-induced multiple spurious operations (MSOs) is described in Attachment F.

The MSO reviews identified new spurious combinations that have been included in the Fire PRA. Those MSOs that could result in unrecoverable plant conditions based on the plant's current thermal-hydraulic analyses are being addressed through the modification process and/or risk informed performance based evaluations as summarized in the individual change evaluations. The pre-transition operator manual actions (OMAs) that are being retained as post-transition recovery actions or defense-in-depth (DID) actions must still meet the feasibility criteria identified in Table G-1. These criteria include consideration of the time available to complete the action before the plant is placed in an unrecoverable condition or unrecoverable equipment damage occurs for time critical actions.

In the event a new MSO combination is identified that requires further review in the Nuclear Safety Capability Assessment, and consideration is being given to using either a DID action or a recovery action to mitigate the plant impact, then the adequacy of the existing thermal-hydraulic analyses will be reviewed. Additional thermal-hydraulic analysis will be performed if necessary.

If the new thermal-hydraulic analysis concludes that adequate time is not available to complete the proposed action, than an alternative strategy will be implemented to resolve the MSO.

The Fire PRA is an integrated model that includes the thermal-hydraulic response of the plant.

Thus, the Fire PRA incorporates the effects of multiple failures and their potential impact on plant parameters and plant response. Those MSOs that were determined by the MSO Expert Panel review to be potentially significant were added to the PRA model, if they were not already included, such that their risk significance could be addressed. Any new MSOs identified in the future that are considered to be potentially risk-significant will be treated in a similar manner and added to the Fire PRA such that the potential risk impact can be assessed.

G.6.2.2 Thermal-Hydraulic Analyses used in Feasibility Evaluation The feasibility analysis is contained in an Appendix to the Safe Shutdown Analysis calculation.

The feasibility analysis includes a timed simulation to document that actions being performed are bounded by plant thermal-hydraulic analyses that support the nuclear safety performance criteria. In some instances, proposed actions were determined to be not feasible (not bounded by the results of thermal-hydraulic analyses) such that it was not possible to demonstrate that the proposed action could be successfully performed within the required time frame to prevent an unrecoverable condition, or a condition not analyzed in the existing safe shutdown analysis.

In these cases, modifications are being implemented to address these issues.

Modifications that provide the greatest improvement to plant response and operator timelines include:

EC 70350 EC 70895 EC 54065 EC 67772 EC 69501 EC 70350 and EC 70895 will insure RCP Seal Integrity, RCS Inventory Control, and Decay Heat Removal are restored prior to reaching an unrecoverable condition. See Attachment S for additional information describing these modifications.

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Progress Energy HINIP NFPA 805 Transition Report As part of NFPA 805 transition, the feasibility analysis will incorporate, as appropriate, the results of any additional thermal-hydraulic analyses and/or feasibility simulations that may be performed.

G.6.2.3 Summary All recovery actions and defense-in-depth actions were evaluated against the feasibility criteria established in Table G-1. The feasibility analysis (results of the timed simulation) is contained in an Appendix to the Safe Shutdown Analysis calculation.

G.7 Demonstrating Reliability G.7.1 Process The reliability of actions addressed by this process depends upon its characterization.

The reliability of recovery actions that are modeled specifically in the Fire PRA is addressed using Fire PRA methods (i.e., HRA).

The reliability of recovery actions that were pre-transition alternative/dedicated shutdown actions (i.e., actions not at a primary control station), if modeled specifically in the Fire PRA, is addressed using Fire PRA methods (i.e., HRA). Actions not explicitly modeled due to bounding treatment for additional risk (as described in Section G.6) do not require explicit reliability determination due to the bounding treatment.

Defense-in-depth actions, by definition, do not have additional risk presented by their use and have been evaluated for potential negative risk impact. Therefore, they should be addressed by feasibility, but no explicit treatment of reliability is required (e.g., per NUREG-1852 or other methods).

G.7.2 Results No OMA was 'added' to the Fire PRA model as none were deemed to provide significant reduction in risk as part of Fire PRA development. For the most part, the pre-transtion OMAs are relatively simple and highly reliable (i.e., open and close breakers, open and close valves, start pumps, etc.).

G.8 Supplemental Information The following information is provided to support the transition of OMAs to recovery actions.

Clarification on fire event confirmation is provided to support the CLB positions. In addition, the use of RI-PB approaches can demonstrate limitations on fire damage that support less complex SSD procedures than those associated with full area exposure fires.

G.8.1 Clarification of Event Confirmation The pre-transition compliance strategy for a given fire area may include one or more OMAs to ensure the credited safe shutdown path is free of fire damage. For alternate shutdown, 10 minutes of operator time is assumed to be available to perform the transfer actions before any spurious equipment operations are postulated to occur. Embedded in this compliance strategy is the assumption that the 10 minute time frame does not start until confirmation of a severe fire and the decision is made to abandon the control room. A severe fire is one that is spreading beyond the initial piece of equipment or cabinet and is adversely affecting plant control or control room habitability.

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ProAress EnerAv HNP NFPA 805 Transition Report The exact time of ignition is difficult to identify. The time of recognition is more readily identifiable through the activation of fire detection, fire suppression, equipment failure, personnel notification, or a combination thereof. The time of confirmation is defined as when a qualified individual goes to the location, concludes the fire event is active, and determines that the fire is severe or represents a challenging scenario. In some cases, the time between ignition and confirmation is immaterial. For example, an MCC fire may result in a spurious operation; however, if the MCC is well sealed and would not involve external targets, this fire is not likely to evolve into a severe or challenging fire. In other words, an MCC fire may self-extinguish or contain the fire to the point of origin (the MCC itself) before any action to initiate the fire SSD procedure is required.

For alternative shutdown scenarios, the decision to abandon the main control room is tied to confirmation of a challenging or severe fire. Therefore, linking confirmation of such a fire to the beginning of the 10 minute time frame to complete transfer to the ACP and other primary control stations before any spurious equipment operations occur is not only consistent with the CLB, it is also consistent with the practical implementation of any SSD strategy requiring control room abandonment. Industry test data as discussed in a recent draft revision to NEI 00-01 (ML080310056), while not conclusive, supports the assumption that spurious operations will not occur immediately upon exposing cables to fire effects. According to the draft revision to NEI 00-01, the average time to failure exceeded 30 minutes for thermoset cables and 15 minutes for thermoplastic cables.

The time period of propagation is necessary before there can be progressive degradation or loss of plant equipment. During this propagation period the fire would produce heat and smoke which allows time for detection and suppression activities to occur.

G.8.2 Risk-Informed, Performance-Based Fire Response While the Fire PRA assumes that multiple failures including spurious operations associated with cables within the zone of influence for each fire ignition source take place simultaneously (with no credit for any delay until spurious operations occur), an actual fire involving exposed cable bundles or trays is not expected to result in spurious operations before 10 minutes.

Therefore, to avoid taking preemptive actions that are potentially adverse to risk, an assessment of the fire severity by the operators must precede implementation of the appropriate SSD strategy to determine that the fire is challenging to SSD. The actions taken, therefore, may include only a specific selection of the steps outlined in the bounding SSD strategy to ensure separation between the redundant and alternate trains credited for the fire area as a whole.

Failure to recognize that each fire may not require the same bounding SSD strategy could have negative implications on overall fire risk. Some actions may involve removing power to credited equipment to preclude spurious operation. As part of FAQ 07-0030, operator actions are reviewed for potential negative risk impact to address the potential for procedural actions that would eliminate credited equipment that has not been damaged directly by the fire (see Section G.5.4). If the action is symptom/target based, then there is no impact on the base Fire PRA assumptions, since the Fire PRA would not be impacted by removing power to equipment already presumed lost from fire damage. For example, if the containment spray pump control cables (that could lead to spurious pump start) are not within the zone of influence for a given scenario, then preemptive actions to trip containment spray and remove power would not be taken.

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Progress Energy HNP NFPA 805 Transition Report If these actions are purely "zone (or area) based" without consideration of fire severity rather than "symptom/target based", then the action would be reviewed against the Fire PRA to insure the action was risk neutral.

The optimized RI-PB approach is to apply a combination of the zone-based approach, which identifies the equipment that may be lost in the area, with a symptom/target based approach, which upon confirmation of a severe fire would assess the equipment expected to be lost based on that location and the ignition source.

The RI-PB approach described above will be incorporated into the HNP SSD procedures, as applicable, during the program implementation phase and will continue post-transition as changes are made to the FP program.

In conclusion, allowing a reasonable diagnostic time to define the appropriate safe shutdown strategy after confirmation of a severe fire is an appropriate RI-PB approach.

Table G-2 Legend for Action Type:

DID - Defense-in-Depth action NR - Action not required NFA - No further action required RA - Recovery Action Page G HNP NFPA 805 Transition Report - Rev 1.docx

Progress Enery HNP NFPA 805 Transition Report Pages G-15 through G-81 are SECURITY RELATED INFORMATION.

These pages are withheld under 10 CFR 2.390.

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Attachment S - Plant Modifications (Non-Security Sensitive)

The modifications necessary to support the new licensing basis are identified in this attachment (Regulatory Guide 1.205, Revision 0, Regulatory Position 0.2.2. and NEI-04-02, Revision 1, Section 4.5.1). These modifications will be complete by the end of Refueling Outage 16, currently scheduled for November 5, 2010 as described in the regulatory commitments.

Appropriate compensatory measures for any outstanding NFPA 805 related modifications will be maintained at the time of NFPA 805 program implementation until the completion of all of the NFPA 805 transition modifications as described in the table below.

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Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA Measure 54065 Prevent spurious opening of Containment Sump Recirculation valves 1CT-102 (2CT-V7SB-1) & 1CT-105 (2CT-V6SA-1)

Reduce possibility of spurious operation of 1CT-102 and 1CT-105 by replacing existing cable with fire rated Meggitt Cable.

Y Y

67742 Prevent the possibility of a fire induced inadvertent starting of the Purge Fans ES-1 (1A-NNS) and/or ES-1 (1 R-NN9.q)

Pre-fire breaker rack out position for breakers 1D21-6C:002 and 1E21-6A:002 in the OFF position to prevent the possibility of Fans ES-1 (1A-NNS) and/or ES-1,(1B-NNS) spuriously starting in the event of a fire N

N Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA MeasureI 58779 Evaluate the availability of Emergency Diesel backed AC lighting in the Main Control Room for all postulated fires outside the MCR complex (12-A-CR, 12-A-CRC1, 12-A-HV&IR) and the availability of Emergency Diesel backed AC lights for the Auxiliary Control Panel (1-A-ACP)-in the event of a fire in remote shutdown fire areas 12-A-CR, 12-A-CRC1, and 12-A-HV&IR.

Provide Emergency Lighting for the Main Control Room and the ACP. Diesel Backed lighting AC is available in the MCR for all scenarios and will be credited.

Two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> DC Emergency Lights will be added to the ACP Room.

N Y

67743 Prevent Filter backwash, Nitrogen System, and Reactor Makeup Water from affecting the RCS following a postulated fire Preclude the impact of the identified spurious valve misalignments by disabling the valves and/or their subsystems by changing normal position and depowering appropriate valves.

N N

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Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA Measure 67772 Prevent 1S1-107, 1SI-52, Cable conductors are to be Y

Y 1SI-86, 1SI-3, and 1SI-4 from replaced with Meggitt Fire Rated spuriously opening due to a Cable for the associated valves.

fire induced fault.

The following cables are:

10408M-SB 10408N-SB 10408D-SB 10407L-SA° 10407M-SA 10407D-SA 10440H-SA 10441 J-SB 10439L-SA 10408C-SB 10408E-SB 10408L-SB 10407C-SA 10407E-SA 10407K-SA 10440C-SA 10440G-SA 10456N-SA 10441 C-SB 10441 H-SB 10456L-SB 10439C-SA 10439H-SA 10456M-SA Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report s E y

P FI Table S Plant Modifications I

Rank EC Problem Statement Proposed Modification In Comp FPRA Measure Risk Informed Characterization I

68768 Reduce the risk of fire in area 1-A-BAL-B2 and add additional protection to safe shutdown related cables and components in the area.

Add a transient exclusion zone on elevation 261 of RAB to the main corridor near the B chiller.

N N

68656 1SW-1204 can open for postulated fires in 12-A-CR

-4

) A tlD l

The control wiring circuit will be modified to eliminate the possibility of a hot short maintaining the valve open following transfer by rerouting a conductor through a normally closed contact of a Transfer Relay. This will be done by modifying the transfer switch wiring, such that upon transfer to the ACP, the valve will fail closed.

N Y

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Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA Measure 68769 Address generic 92-18 MOV Protect 1CS-235 (CHARGING N

Y SSD/FP issues.

LINE ISOL) and 1AF-55, (MD AFW ISOL to A SG) so a hot

-short will not break the operator and preclude a defense in depth OMA 68645 1AF-74 Fire Da 1 A Protect 1AF-74 from Fire Y

Y S

Damage in 1-A-SWGRB and 1-A-ACP.

68648 Protect the cable 0988B AFW Isolation Signal from being received due to spurious cable interactions in 1-A-SWGRB.

Reroute existing cable out of Fire Area 1-A-SWGRB.

Y Y

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Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications In Comp Rs nomdCaatrzto Rank EC Problem Statement Proposed Modification FPRA Measu Risk Informed Characterization 68660 Protect Cable 12761J forAH-AH-6B will have its cable Y

Y 6 B-SB during a 2tated removed from 12-A-CR and fire in 12-A-CR.

routed to a MUX cabinet in 1-A-

_SWGRB where the cable already terminates.

62343 Mitigate the consequences of spuriously opening PORV, 1MS-62 due to a fire induced fault.

Protect 1 MS-62, C SG PORV from damage in 12-A-CR and 12-A-CRC1 by installing a kill switch on the ACP so the valve can be failed shut.

N Y

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Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications In Comp Rs nomdCaatrzto Rank EC Problem Statement Proposed Modification FPRA Measure Risk Informed Characterization 69501 Reduce risk in the following fire areas:

12-A-CR (Main Termination Cabinets/Inverters/MCB) 12-A-CRC1 - High Risk PICs, Isolation Cabinets, SSPS In the PIC Room 12-A-CRC1 - High Risk ARPs 1-A CSRA & CSRB-Cable Spread Rooms 1-A-SWRGA & SWGRB -

Switchgear Rooms 1-A-ACP -Auxiliary Control Panel (ACP)

Add incipient detection in the following Fire Areas in the cabinets indicated:

12-A-CR (Main Termination Cabinets/Inverters/MCB) 12-A-CRC1 - High Risk PICs, Isolation Cabinets, SSPS In the PIC Room 12-A-CRC1 - High Risk ARPs 1-A CSRA & CSRB - Cable Spread Rooms 1-A-SWRGA & SWGRB -

Switchgear Rooms 1-A-ACP -Auxiliary Control Panel (ACP)

Y Y

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Progress Energy HNP NFPA 805 Transition Report Prars EnmN NP 0 TastonRpr Table S-I - Plant Modifications Proposed Modification Rank EC Problem Statement S69501 Continued from above In Comp FPRA Measure Risk Informed Characterization Page S HNP NFPA 805 Transition Report - Rev I.docx I

Proaress Enerav HNP NFPA 805 Transition Report Proaess nerv HN NFA 80 Trasiton Rpor Table S Plant Modifications Proposed Modification Rank EC Problem Statement S69501 Continued from above In Comp FPRA Measure Risk Informed Characterization Page S HNP NFPA 805 Transition Report - Rev I.docx

Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA Measure 69501 Uontinueu irom above Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp FPRA Measure Risk Informed Characterization 68658 Prevent both 1CC-147 and 1CC-1 67 from spurious operation (open/closed) from a postulated fire in 12-A-CR.

Install fuses in control circuit to prevent fire induced spurious opening.

Y Y

53878 Prevent loss of normal charging flow path, loss of SIS flow path and/or loss of cooling to the RCP seals caused by certain postulated fires which result in multiple spurious actuations of 1CC-252, 1CS-217, 1CS-218, 1CS-219 and 1CS-220.

De-energize Charging Pump discharge header cross connect valves 1CS-217,1CS-218, 1CS-219 and 1CS-220.

Y Y

69764 Upgrade existing credited Modify ERFBS consistent to the Y

Y Hemyc applications tested configuration for the fire resistance assumed.

Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report I

Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA MeasureI 69765 Upgrade existing credited MT Modify ERFBS consistent to the Y

Y applications, tested configuration for the fire resistance assumed.

68646 Prevent High Energy Arcing Fault damage.

It is proposed to add thermal shields over Bus 1B-SB, 1B-NNS,1E-NNS, 1B1-NNS in Switchgear Room 1 B to prevent HEAF damage or to provide Hemyc fire wrap around the nearest cable tray to prevent vertical flame propagation and damage from a HEAF source fire.

Y Y

Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA MeasureI 70028 Provide dedicated access ladders at specific locations throughout the-Reactor Auxiliary Building to support manual actions for a Safe Shutdown Event (SSE).

Install dedicated ladders throughout the Reactor Auxiliary Building to support Manual Action for SSE.

N N

70350 Supply RCP Seal injection during a postulated fire.

Install new Diesel Generator and dedicated Charging Pump to supply reactor coolant pump seal injection (automatic start) with additional ability to power station essential battery chargers for new diesel output.

Y

• N Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Table S Plant Modifications Rank EC Problem Statement Proposed Modification In Comp Risk Informed Characterization FPRA MeasureL 70027 Additional cooling is required for "B" RHR pump room and B CSIP Room during a postulated fire.

Add 480 VAC Power Outlets to supply compensatory fans for cooling B RHR pump room and B CSIP Room.

N Y

70895 Protect Turbine Driven AFW This will provide additional Y

N MOVs 1AF-1 37, 143 and 149 isolation of the circuit by the from fire damage in 12-A-Transfer Switch on transfer to CR the ACP.

62820 Upgrade the reliability of the SSD communications for a postulated fire.

Study related EC to identify modification actions to ensure communication for plant areas.

Y Y

Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progqress Energy HNP NFPA 805 Transition Report roI 8

Table S Plant Modifications Proposed Modification Rank EC Problem Statement In Comp FPRA Measure Risk Informed Characterization 71147 Correct multiple spurious conditions inside MCCs (for example, where 2 high head SI valves could spuriously open due to a fire in a single MCC)

Relocation of breaker cubicles to minimize potential for internal cabinet fire exposure damage and limit fire induced damage to relevant control cables with the use of fire rated cable for internal cable runs in areas subject to fire damage.

N Y

Legend:

High = Modification would have an appreciable impact on reducing overall fire CDF.

Med = Modification would have a measurable impact on reducing overall fire CDF.

Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.

EC Number Completed Modification 48802 Remove Thermo-lag Wall and Replace with Interam Wrap in ACP 56427 Re-power 1CC-208 and 1CC-251 from an Alternate MCC 56428 Provide Alternate Power for WC-2B and 1AF-130 55938 Eliminate Non-feasible Manual Action for Dampers CZ-D73 and CZ-D74 58008 Install RWST Level Indicator at the ACP (RF-13) 59104, 60257 Install Manual Transfer Switch for C CSIP (RF-13) 52769 Establish VCT Valve Gallery as Fire Area/Install Fire Rated Cable for 1CS-165 and 1CS-166 (RF-13) 60436 Re-power 1CC-252 from Alternate MCC and Provide Cable Protection for 1CC-252 Cables (RF-13) 60434, 63858 Re-analyze Fire Area 1-A-BAL-B1 as 3 New Areas (RF-13) 60435 Provide Cable Protection for 1CH-279 Cables in 1-A-CSRB (RF-13) 60828 Evaluate Racking Out of Breaker for 1CS-167, 168, 169 and 170 During Operations Page S HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Attachment W - Internal Events PRA Quality (Non-Security Sensitive)

The following table provides required capability category for the internal events PRA for use in Fire. The Harris internal events PRA meets or exceeds the specified capability category listed.

Internal Events PRA Capability Category Required for HNP Fire PRA Evaluations Risk Insights Technical Elements Cable Separation Fire Barrier Worth (e.g. OMA, MSO, monitoring)

IE Specific Fire Specific Fire Specific Fire requirements requirements requirements AS II II II SC II II II DA SY II II II HR II II II IF None required None required None required LE II II II QU Specific Fire Specific Fire Specific Fire requirements requirements requirements MUSpecific Fire Specific Fire Specific Fire MU requirements requirements, requiremIents The following are the findings and suggestions with resolution from the Harris Internal Events only Limited Peer Review conducted in December 2007. All findings and suggestions have been resolved satisfactorily for the internal events PRA to support the use as the base model for the Harris Fire PRA.

There are no unincorporated plant changes that are being tracked for the internal events.PRA outside of those incorporated into the Fire PRA model.

Page W HNP NFPA 805 Transition Report - Redacted[l]

Progress Energy HNP NFPA 805 Transition Report Pages W-2 through W-14 are SECURITY RELATED INFORMATION.

These pages are withheld under 10 CFR 2.390.

Page W HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Attachment X - Fire PRA Quality (Non-Security Sensitive)

Identification of Application In general the PRA application is to support the transition of Fire protection regulation to NFPA 805. For this general application, variances from the deterministicregulations are identified that must be assessed for risk to determine if they can be transitioned as-is. Specifically for the Harris Nuclear Plant transition to NFPA 805 there are basically three types of PRA analyses that support this application.

Determination of Capability Categories In order to calculate CDF/LERF for this application, a fire PRA is needed. For HNP the fire PRA is built upon the internal events PRA, so that must also be assessed. Because the application is based on fire risk, only the sections of the internal events PRA that are impacted by initiating events that can be caused by fires need to be assessed when determining delta CDF for the variances presented, because the non-fire terms will cancel in the calculation. Using the single initiating event methodology and knowing that fires do not cause pipe failures, only transient sequences are required for this application. This includes the related success criteria and system models for these sequences. For these elements (AS, SC, SY, HR, LE), category II is sufficient for determination of risk insights. Capability category II is sufficient because the Fire PRA is built upon system response models, which includes the systems analysis (SY), accident sequences (AS) and the supporting success criteria (SC). These must be of sufficient detail such that important fire, system, dependencies and component interactions as well as the required mitigation equipment are accounted for. Additionally the use of human failure events both as precursors events or recovery events must be of sufficient quality to support the risk insights as to the effectiveness of these actions. Capability category II is also required for the HR high level requirements (HLRs) and associated supporting requirements (SRs). Similarly Large Early Release Frequency (LERF) or LE must also be of sufficient detail such that potentially important contributors to LERF are accounted for. For Data analysis category I is sufficient because fire failures will dominate the equipment failures.I Having the higher quality data does not have a significant impact on the delta Core Damage Frequency (CDF). SRs which have been assessed as Category I (or not met) for the stated elements of the HNP PRA will be evaluated explicitly for this application.- Internal-flood (IF)-is-not required for the application. The remaining elements (IE, QU) are addressed specifically in the SRs for fire standard. The quality of the internal events PRA is provided in Attachment W.

The NFPA 805 Fire PRA methodology is applied to variances from deterministic which have the most conservative fire methodology. The risk impact of these identified'change evaluations are based on specific fire scenario and sources. The significant imrprovement is focus of fire damage based upon individual fire sources from the previous fire deterministic evaluation of faulting entire fire zones. The more specific Fire PRA method shows that generally Category I is sufficient for fire standard elements IGN, PP, FSS, CF, HRA, SF,"UNC. Elements ES, CS, and FQ may require more realism in order to address overall risk issues, however none require higher than Category II due to the risk informed nature of this application, which also includes defense-in-depth and safety margin aspects. Other elements addressed in the fire PRA standard were not used for the HNP fire PRA and do not apply (QLS, QNS).

Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energv HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Necessary Scope and Results The HNP fire PRA is a full fire PRA developed using the guidance provided by NUREG/CR-6850. This NUREG has been referenced by Regulatory Guide 1.205 as an acceptable method for developing a fire PRA to support NFPA-805. All of the elements needed to analyze delta CDF and delta LERF are included.

Modeling of SSC's and Activities The HNP fire PRA is a full fire PRA developed using the guidance provided by NUREG/CR-6850. The steps outlined in NUREG/CR-6850 were completed to develop a fire PRA that has the necessary attributes for SSC modeling. The fire PRA used as a starting point the internal events PRA after completion work that resolved items identified by a Regulatory Guide 1.200 Gap Assessment, and the subsequent focused Peer Review. This results in all necessary SSCs and associated interactions such as Human Reliability Analysis being included in the Harris Fire PRA.

Peer Review The HNP fire PRA has been reviewed at various stages. Individual elements were shared with NRC and industry during the pilot process. A pre-application audit of the HNP fire PRA was conducted by the NRC which assessed the HNP fire PRA against the Fire PRA Standard using the industry peer review process. A partial peer review was also conducted by the PWROG.

Determination of the Standard's Scope and Level of Detail The current PRA is intended to address all areas of a fire PRA. No special issues have been identified for the application (NFPA-805) that are beyond the scope of the current standard.

Comparison of PRA Model to Standard Based on the discussions above, it is determined that there are no SR's for any elements that need to be more than Category II. SRs for AS, SC, SY, DA, LE and ES, CS, and FQ that were reviewed and determined to be "not met" or Category I are specifically addressed in the attachment W.

Comparison of Harris Fire PRA to other Fire PRA The Harris Fire PRA along with the Oconee Fire PRA are the two first PRAs developed using the guidance contained in NUREG/CR-6850. The model results and methodologies between these two efforts have been compared as part of the pilot process and the results have been shared with the NRC. It was identified that each site had uniquely identified issues caused in large part to specific plant design and arrangement. The two fire PRA Core Damage Frequencies are of the similar magnitude. No other fire PRA exists in a completed state to provide a meaningful comparison.

Use of Supplementary Analyses/Requirements None identified Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Fire PRA Capability Category Requirements To be able to support the NFPA 805 change evaluation process the Fire PRA must have certain capability categories achieved to provide proper risk insights for any change. For the changes currently under consideration for the Harris NFPA 805 the following PRA capability categories requirements are provided.

Table X NFPA 805 Application Required Capability Category Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements

_monitoring)

PP-Al Met Met Met PP-B1 1

1 1

PP-B2 I

I I

PP-B3 I

I I

PP-B4 Met Met Met PP-B5 NA NA NA PP-B6 Met Met Met PP-B7 Met Met Met PP-C1 Met Met Met PP-C2 Met Met Met PP-C3 Met Met Met PP-C4 Met Met Met Plant Partitioning Discussion Capability Category I is adequate for PP SRs because the importance of all of this issue are dependent upon the individual fire sources and the specific targets in question. The fire area definition used in analysis could be important if fire areas were qualitative screened, but HNP analysis did not screen any fire areas.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements

_monitoring)

ES-Al Met Met Met ES-A2 Met Met Met ES-A3 Met Met Met ES-A4 1/11 1/11 I/1l ES-A5 II II II ES-A6 II II II ES-B1 II II II ES-B2 II II II ES-B3 Met Met Met ES-B4 II II II ES-B5 Met Met Met ES-B6 Met Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report PrgesEeryHPNPA85TasiinRpr ES-Cl Met Met Met ES-C2 II II II ES-D1 Met Met Met Equipment Selection Discussion Capability Category II is specified in order to be able to understand the cable/ component impact on system interactions and dependency. The issues such as cable separation, fire barrier worth or risk insights such as MSO reviews are specifically concerned with the cables, which have an associated components and system interactions. In order to have a realistic delta CDF or LERF the fire PRA need to include the same level of detail as the internal event PRA, and the safe shutdown analysis.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements

_monitoring)

CS-Al Met Met Met CS-A2 II II II CS-A3 Met Met Met CS-A4 Met Met Met CS-A5 Met Met Met CS-A6 Met Met Met CS-A7 Met Met Met CS-A8 Met Met Met CS-A9 Met Met Met CS-A 0 I

1 1

CS-All NA NA NA CS-B1 I

I I

CS-Cl Met Met Met CS-C2 Met Met Met CS-C3 NA NA NA CS-C4 Met Met Met Cable Selection Discussion Capability Category II is appropriate for supporting requirement CS-A2 to allow identification of multiple hot shorts. CS-A10 can CC-I to match the plant partitioning used in the analysis. CS-B1 can be Capability Category I, for circuit overcurrent coordination, which is adequate to evaluate the changes being considered. Those SRs with NA are for assumed routing, which Harris Fire PRA did not use.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements monitoring)

QLS-A1 None None None QLS-A2 None None None QLS-A3 None None None QLS-A4 None None None QLS-B1 None None None Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report QLS-B2 None None None QLS-B3 None None None Qualitative Screening HNP did not use qualitative screening to eliminate low risk fire areas thus there are not capability categories required.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements monitoring)

PRM-A1 Met Met Met PRM-A2 Met Met Met PRM-A3 Met Met Met PRM-A4 Met Met Met PRM-A5 Met Met Met PRM-A6 Met Met Met PRM-B1 Met Met Met PRM-B2 Met Met Met PRM-B3 NA NA NA PRM-B4 NA NA NA PRM-B5 NA NA NA PRM-B6 NA NA NA PRM-B7 NA NA NA PRM-B8 Met Met Met PRM-B9 NA NA NA PRM-B10 Met Met Met PRM-B11 Met Met Met PRM-B12 Met Met Met PRM-B13 Met Met Met PRM-B14 Met Met Met PRM-CI I

I I

PRM-D1 Met Met Met Plant Response Model Discussion For supporting requirement PRM-C1 the task requirements for CC-Il are confusing and could not be understood by either the NRC staff review team or the industry review team. It is believed by Progress Energy that PRM-C1 for CC-Il requires a review of MSO that could generate new previously not considered initiating event. Since the Harris Fire PRA had a MSO review to meet other SRs, this SR is not required, thus CC-1 is adequate. PRM-B3 to 87 are "NA" because no new initiating events were identified.

Supporting Risk Insights Requirements Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements_

monitoring)

FSS-A1 Met Met Met FSS-A2 Met Met Met FSS-A3 Met Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report FSS-A4 Met Met Met FSS-A5 1/11 1/11 1/11 FSS-A6 1/11 1/11 1/11 FSS-B1 Met Met Met FSS-B2 1/11 1/11 1/11 FSS-Cl II II II FSS-C2 II/111 II/111 II/111 FSS-C3 I

I FSS-C4 I

I FSS-C5 1/11 1/11 1/11 FSS-C6 1/11 1/11 1/11 FSS-C7 Met Met Met FSS-C8 Met Met Met FSS-DI Met Met Met FSS-D2 Met Met Met FSS-D3 I

I I

FSS-D4 Met Met Met FSS-D5 1/11 1/11 1/11 FSS-D6 Met Met Met FSS-D7 I

I FSS-D8 Met Met Met FSS-D9 I

FSS-D 0 I

FSS-D1I Met Met Met FSS-EI Met Met Met FSS-E2 Met Met Met FSS-E3 I

I I

FSS-E4 NA NA NA FSS-FI 1/11 1/11 1/11 FSS-F2 I

I I

FSS-F3 NA NA NA FSS-GI Met Met Met FSS-G2 Met Met Met FSS-G3 Met Met Met FSS-G4 I

I I

FSS-G5 NA NA NA FSS-G6 I

I I

FSS-HI Met Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

Proqres. Energy HNP NIFPA 805 Transition Report FSS-H2 I

I I

FSS-H3 Met Met Met FSS-H4 Met Met Met FSS-H5 I

I I

FSS-H6 I

I I

FSS-H7 Met Met Met FSS-H8 Met Met Met FSS-H9 Met Met Met FSS-H10 Met Met Met Fire Source Selection and Analysis Discussion All of these SRs under FSS for HNP can be Capability Category I except FSS C1 and FSS C2, which should be category II. The nature of the cable separation, fire barrier worth, and MSO required more detailed fire growth in some areas. This was performed at HNP for many fire sources because the category I treatment did not provide realistic results. FSS C3 through C6, can be at Capability Category I because in general that treatment provides reasonable results. In some cases more detailed treatment was made, but may not have been required. FSS D3 cat I is appropriate, since HNP did not use qualitative screening for analysis units. Suppression system performance (D7) and potential smoke damage (D9) are acceptable at Capability Category I due to the minor impact these would have on the results. The D10 walk downs to confirm was actually performed at Category Il/111, but Category I is acceptable for the delta CDF/LERF determinations, since the detailed walk downs tend to result in smaller CDF/LERF deltas. For FSS F1 and 2 category I is more than adequate, since Harris has an open Turbine Building and all of the structural steel fires of consequences are only in the Turbine Building and the outcomes are expected to be a reactor and turbine trip with minor complications, such as a loss of off-site power.

FSS F3 is not required because the lack of a qualitative evaluation of structure steel during a turbine building oil fire does not have any measurable impact on CDF/LERF or the delta CDF/delta LERF for the changes that are being evaluated. The Harris Fire PRA already considers Turbine Building Oil fires and thus the qualitative assessment does not add any value to the results. FSS G4, and G6, which address multi-compartment analysis, can also be adequately evaluated at category I because the contribution to fire risk due to maintenance and failed barriers would be a very small additional risk (G4 and G6) and Harris does not have any active fire barriers (G5),

thus that SR is NA. The Capability Category I for FSS-H5 and 6 is acceptable. These supporting requirements address documentation of the scenarios and the statistical and parametric uncertainty. The statistical and parameter uncertainty documentation do not have a direct impact on the specific results, but do indicate areas for further investigation. For the changes being evaluated in this table fire growth, severity factor, non-suppression probabilities all are dominate contributors to uncertainty.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements

_monitoring)

IGN-A1 Met Met Met IGN-A2 NA NA NA IGN-A3 NA NA NA IGN-A4 I

I I

IGN-A5 Met Met Met IGN-A6 NA NA NA IGN-A7 Met Met Met IGN-A8 1/11 1/11 1/11 IGN-A9 Met Met Met IGN-A10 I

I I

Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Progies~ ~nergy HNP NFPA 805 Transition Report IGN-B1 Met Met Met IGN-B2 Met Met Met IGN-B3 Met Met Met IGN-B4 NA NA NA IGN-B5 Met Met Met Fire Ignition Frequency Discussion The IGN Capability Category I is adequate for the evaluation of cable separation, fire barrier worth, and risk insights such as MSO or OMA. The ignition frequency is a direct multiplier of the base CDF, and becomes less important in the delta analysis. In addition there are a number of industry concerns with how the generic ignition frequency has been determined and the potential updating of generic data will overwhelm any plant specific information. Those SRs that are "NA" are due to not updating the ignition frequency data with plant specific data.

Supporting Risk Insights Requirements Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements_

monitoring)

QNS-A1 NA NA NA QNS-B1 NA NA NA QNS-B2 NA NA NA QNS-Cl NA NA NA QNS-D1 NA NA NA QNS-D2 NA NA NA Quantitative Screening Discussion Capability Category NA would be acceptable for the Harris fire PRA because Quantitative Screening was not used in the Harris Fire PRA.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements

_monitoring)

CF-Al I

I CF-A2 Met Met Met CF-B1 Met Met Met Circuit Failure Analysis Discussion Capability Category I is adequate for the SR, CF-Al. This provides the most conservative circuit failure treatment and if acceptable results are obtained then no further work is required.

Supporting Risk Insights Requirements Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 monitoring)

HRA-A1 Met Met Met HRA-A2 Met Met Met HRA-B1 Met Met Met HRA-B2 Met Met Met HRA-B3 Met Met Met HRA-Cl Met Met Met HRA-D1 NA NA NA HRA-EI Met Met Met Page X HNP NFPA 805 Transition Report - Rev l.docx

Progress Extergy HNP NFPA 805 Transition Report PrgesEeryHPNPA85TasiinRpr Post-Fire Human Reliability Analysis Discussion All of the SRs except HRA-D1 are met. HRA-D1 will be required to be met to evaluate any credited fire operator actions (OMAs) that are used in the Fire PRA. Currently none of the fire procedure operator actions are credited in the Fire PRA, thus the current CC is "NA".

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements monitoring)

SF-Al Met Met Met SF-A2 Met Met Met SF-A3 Met Met Met SF-A4 Met Met Met SF-A5 Met Met Met SF-B1 Met Met Met Seismic/Fire Interactions Discussion All of the SRs are met.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements monitoring)

FQ-A1 Met Met Met FQ-A2 Met Met Met FQ-A3 Met Met Met FQ-A4 Met Met Met FQ-B1 Met Met Met FQ-CI Met Met Met FQ-D1 Met Met Met FQ-E1 Met Met Met FQ-F1 Met Met Met FQ-F2 Met Met Met Fire Risk Quantification All the SRs are met.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requiremernts monitoring)

UNC-AI Met Met Met UNC-A2 Met Met Met UNC-A3 Met Met Met Uncertainty and Sensitivity Analyses Discussion All the SRs are met.

Risk Insights Supporting Cable Separation Fire Barrier Worth (e.g. OMA, MSO, NFPA 805 Requirements monitoring)

MU-Al Met Met Met MU-A2 Met Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report MU-Br Met Met Met MU-B2 Met Met Met MU-B3 Met Met Met MU-B4 Met Met Met MU-B5 Met Met Met MU-B6 Met Met Met MU-CB Met Met Met MU-Dl Met Met Met MU-ED Met Met Met MU-Fl Met Met Met MU-F2 Met Met Met PRA Maintenance and Update Discussion All the SRs are met.

Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress ;7npargy HNP NFPA 805 Transition Report Progress ~;r~rqv HNP NFPA 805 Transition Report The evaluated capability after both the NRC staff review and the Industry Peer Review are provided in the following table. With the disposition of the Findings and Suggestions from both the NRC staff review and the Industry Peer Review team, the Harris Fire PRA has a PRA that meets or exceeds the quality requirements provided in Table X-1 above.

Table X HNP Summary of Evaluated Capability Fire Std NRC Staff Review Industry Peer Review Status before Final After F& 0 SR Results Results F &O resolution Resolution Status*

PP-Al Met Not Reviewed Met Met PP-B1 Not Met Not Met Not Met CC-I1/III PP-B2 Not Met Not Met Not Met CC-II/III PP-B3 N/A Not Reviewed N/A CC-I PP-B4 Met Not Reviewed Met Met PP-B5 N/A Not Reviewed N/A NA PP-B6 Met Not Reviewed Met Met PP-B7 Met Not Reviewed Met Met PP-Cl Met Not Reviewed Met Met PP-C2 Met Not Reviewed Met Met PP-C3 Not Met Not Met Not Met Met PP-C4 Met Not Reviewed Met Met ES-Al Met Not Reviewed Met Met ES-A2 Met Not Reviewed Met Met ES-A3 Met Not Reviewed Met Met ES-A4 CC-III Not Reviewed CC-III CC-III ES-A5 CC-Il Not Reviewed CC-Il CC-Il ES-A6 Not Met CC-III CC-III CC-III ES-B1 CC-III Not Reviewed CC-III CC-III ES-B2 CC-Il Not Reviewed CC-Il CC-Il ES-B3 Met Not Reviewed Met Met ES-B4 Not Met CC-III CC-III CC-III ES-B5 Met Not Reviewed Met Met ES-B6 Met Not Reviewed Met Met ES-Cl Not Met Not Met Not Met Met ES-C2 CC-Il Not Reviewed CC-Il CC-Il Page X HNP NFPA 805 Transition Report - Rev 1.docx

h','gress Ernergy HNP NFPA 805 Transition Report Table X HNP Summary of Evaluated Capability Fire Std NRC Staff Review Industry Peer Review, Status before Final After F& 0 SR Results Results F &0 resolution, Resolution'Status*

ES-D1 Not Met Met Met Met CS-Al Met Not Reviewed Met Met CS-A2 Met CC-Il CC-Il CC-Il CS-A3 Not Met Met Met Met CS-A4 Not Met Met Met Met CS-A5 Met Not Reviewed Met Met CS-A6 Met Not Reviewed Met Met CS-A7 Not Met Met Met Met CS-A8 Not Met Met Met Met CS-A9 Met Not Reviewed Met Met.

CS-A10 CC-III Not Reviewed CC-III CC-III CS-Al1 N/A Not Reviewed NA NA CS-B1 CC-Il/Ill Not Reviewed CC-Il/Ill CC-Il/Ill CS-Cl Met Not Reviewed Met Met CS-C2 Met Not Reviewed Met Met CS-C3 N/A N/A NA NA CS-C4 Not Met Met Met Met The licensee did not QLS-A1 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

The licensee did not QLS-A2 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

The licensee did not QLS-A3 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

The licensee did not QLS-A4 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

The licensee did not QLS-B31 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

I element N/A.

Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Progress Energy HNP NFPA 805 Transition Report Table X HNP Summary of Evaluated Capability Fire Std NRC Staff Review Industry Peer Review Status before Final After F& 0 SR Results Results F &0 resolution Resolution Status*

The licensee did not QLS-B2 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

The licensee did not QLS-B3 perform a qualitative QLS & QNS were not NA NA screening. This reviewed.

element N/A.

PRM-A1 Not Met Met Met Met PRM-A2 Not Met Met Met Met PRM-A3 Met Not Reviewed Met Met PRM-A4 Met Not Reviewed Met Met PRM-A5 Met Not Reviewed Met Met PRM-A6 Met Not Reviewed Met Met PRM-B1 Not Met Met Met Met PRM-B2 Met Not Reviewed Met Met PRM-B3 N/A NA N/A NA PRM-B4 N/A NA N/A NA PRM-B5 N/A N/A N/A NA PRM-B6 N/A N/A N/A NA PRM-B7 N/A N/A N/A NA PRM-B8 Met Not Reviewed Met Met PRM-B9 N/A Not Reviewed N/A NA PRM-B110 Met Not Reviewed Met Met PRM-B1 1 Met Not Reviewed Met Met PRM-B 12 Met Not Reviewed Met Met PRM-B13 Not Met Met Met Met PRM-B14 Not Met Met Met Met PRM-C1 Issue with Standard Issue with Standard Issue with Standard ASME Inquiry PRM-D1 Met Not Reviewed Met Met FSS-A1 Met Not Reviewed Met Met FSS-A2 Not Met Met Met Met Page X HNP NFPA 805 Transition Report - Rev l.docx

Progre-ss EnerqV HNP NFPA 805 Transition Report l~rogress Energy HNP NFPA 805 Transition Report Table X HNP.Summary of Evaluated Capability Fire Std NRC Staff Review Industry Peer Review' Status before Final After F& 0 SR Results Results F &0 resolution Resolution Status*

FSS-A3 Met Not Reviewed Met Met FSS-A4 Met Not Reviewed Met Met FSS-A5 CC-III Not Reviewed CC-III CC-III FSS-A6 Met Not Reviewed CC-I/Il CC-I/Il FSS-B1 Not Met Met Met Met FSS-B2 CC-III Not Reviewed CC-III cc-Ill FSS-B2-01 FSS-C1 CC-Il Not Reviewed CC-Il CC-Il FSS-C2 CC-Il/Ill Not Reviewed CC-Il/Ill CC-Il/Ill FSS-C3 CC-I1I/Il Not Reviewed CC-Il/III CC-I1I/Il FSS-C4 CC-III Not Reviewed CC-III CC-III FSS-C5 Not met CC-I/Il CC-I/Il CC-I/Il FSS-C6 CC-I/Il Not Reviewed CC-I/Il CC-I/Il FSS-C7 Met Not Reviewed Met Met FSS-C8 Met Not Reviewed Met Met FSS-D1 Not Met Met Met Met FSS-D2 Met Not Reviewed Met Met FSS-D3 CC-I CC-III CC-III CC-III FSS-D4 Met Not Reviewed Met Met FSS-D5 CC-III Not Reviewed CC-III CC-III FSS-D6 Met Not Reviewed Met Met FSS-D7 CC-I CC-I CC-I CC-I FSS-D8 Met Not Reviewed Met Met FSS-D9 CC-I CC-I CC-I CC-I FSS-D1O CC-Il/Ill Not Reviewed CC-Il/Ill CC-Il/Ill FSS-Di 1 Met Not Reviewed Met Met FSS-El Met Not Reviewed Met Met FSS-E2 Met Not Reviewed Met Met FSS-E3 Not met CC-I CC-I CC-I Page X HNP NFPA 805 Transition Report - Rev I.docx

Progress Energy HNP NFPA 805 Transition Report Table X-!2,-HNP Summary of Evaluated.Capability-Fire Stdtd N4C -Staff Review

-findustry Peer Review',

Status before Final After F& 0 SR sults

Results, F &O. rsolution Resolution Status*

FSS-E4 N/A N/A N/A NA FSS-F1 Not Reviewed CC-I/Il CC-I/Il CC-I/Il FSS-F2 Not Reviewed CC-I CC-I CC-I Not Met FSS-F3 Not Reviewed Not Met Not Met Not-Met FSS-F3-01 FSS-G1 Not Reviewed Met Met Met FSS-G2 Not Reviewed Met Met Met FSS-G3 Not Reviewed Met Met Met FSS-G4 Not Reviewed CC-Il CC-Il CC-Il FSS-G5 Not Reviewed N/A N/A NA FSS-G6 Not Reviewed CC-Il/Ill CC-Il/Ill CC-Il/Ill FSS-H1 Met Not Reviewed Met Met FSS-H2 CC-I CC-Il/Ill CC-Il/Ill CC-Il/Ill FSS-H3 Met Not Reviewed Met Met FSS-H4 Met Not Reviewed Met Met FSS-H5 CC-I CC-I CC-I CC-I FSS-H6 CC-I CC-I CC-I CC-I FSS-H7 Met Not Reviewed Met Met FSS-H8 Not Met Met Met Met FSS-H9 Not Met Met Met Met FSS-H10 Met Not Reviewed Met Met IGN-A1 Met Not Reviewed Met Met IGN-A2 N/A N/A N/A NA IGN-A3 N/A N/A N/A NA IGN-A4 CC-I CC-I CC-I CC-I IGN-A5 Met Not Reviewed Met Met IGN-A6 N/A N/A N/A NA IGN-A7 Met Not Reviewed Met Met IGN-A8 CC-III Not Reviewed CC-III CC-III Page X HNP NFPA 805 Transition Report - Rev 1.docx

Progress Energy HNP NFPA 805 Transition Report Table X-2 HNP Summary of EvaluatedCapabilit*y Fire Std NR'CStaff Review industry Peer-Review Status before Final After F& 0 SR Results' Results F &d resolution Resolution Status*

IGN-A9 Met Met Met Met IGN-A10 CC-Il Not Reviewed CC-Il CC-Il IGN-B1 Met Not Reviewed Met Met IGN-B2 Met Not Reviewed Met Met IGN-B3 Met Not Reviewed Met Met IGN-B4 N/A N/A N/A NA IGN-B5 Met Not Reviewed Met Met The licensee did not QNS-A1 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

The licensee did not QNS-B1 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

The licensee did not QNS-B2 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

The licensee did not QNS-C1 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

The licensee did not QNS-D1 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

The licensee did not QNS-D2 perform quant QLS & QNS were not N/A NA screen. Element reviewed.

N/A.

CC-11 with ASME CF-Al Met Not Met Met ith AM

____________________inquiry CF-A2 Met Not Reviewed Met Met CF-B1 Not Met Met Met Met HRA-AI Met Not Reviewed Met Met HRA-A2 Met Not Reviewed Met Met HRA-B1 Met Not Reviewed Met Met HRA-B2 Not Met Met Met Met HRA-B3 Not Met Met Met Met HRA-Cl Not Met Met Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

Lnergy HNP NFPA 805 Transition Report Ii o~r'.~ss Lncrgy HNP NFPA 805 Transition Report Table X HNP Summary of Evaluated Capability Fire-Std,,

NRC Staff Review Industry Peer Revew Status before Final After F& O SR I Resultst Results F &6 resolUtion Resolution Status*

HRA-D1 N/A N/A N/A N/A HRA-El Met Not Reviewed Met Met SF-Al Not Reviewed Not Met Not Met Met SF-A2 Not Reviewed Met Met Met SF-A3 Not Reviewed Met Met Met SF-A4 Not Reviewed I

Met Met Met SF-A5 Not Reviewed Met Met Met SF-B1 Not Reviewed Met Met Met FQ-A1 Met Not Reviewed Met Met FQ-A2 Met Not Reviewed Met Met FQ-A3 Met Not Reviewed Met Met FQ-A4 Not Met Met Met Met QF-4A-02 FQ-B1 Met Not Reviewed Met Met FQ-Cl Met Not Reviewed Met Met FQ-D1 Not Met Met Met Met FQ-D1-01 FQ-E1 Not Met Not Met Not Met Met FQ-El-01 FQ-F1 Not Met Not Met Not Met Met FQ-Fl-01 FQ-F2 Not Met Not Met Not Met Met UNC-Al Not Reviewed Met Met Met UNC-Al-01 UNC-A2 Not Reviewed Met Met Met UNC-A3 Not Reviewed Met Met Met MU-Al Met Met Met Met MU-A2 Met Not Reviewed Met Met MU-A3 Met Not Reviewed Met Met MU-B1 Met Not Reviewed Met Met MU-B2 Met Not Reviewed Met Met MU-B3 Met Met Met Met MU-B4 Not Met Not Met Not Met Met Page X HNP NFPA 805 Transition Report - Rev 1.docx

PNogess Lriergy HNP NFPA 805 Transition Report Table X-2 HNP Summary bf.Evaluate,

.Capability' Fire Std NRC Staff Review Industry Peer Review Status before Finaal After F& 0 SR Resuts

.Results..

tFAO t0 rOe solution Resolution Status*

MU-B5 Not Met Not Met Not Met Met MU-B6 Not Met Not Met Not Met Met MU-C1 Met Not Reviewed Met Met MU-D1 Met Not Reviewed Met Met MU-E1 Met Not Reviewed Met Met MU-Fl Met Not Reviewed Met Met MU-F2 Met Not Reviewed Met Met

• Those F&O noted in far right column are the findings or suggestions not incorporated, but these do not impact the Fire PRA application. In general the issue is related to numerical statistical uncertainty analysis for PRA data elements, which does not include the fire model inputs that are the major source of uncertainty. The discussion and justification are provided in the response to the individual F&O below.

I Page X HNP NFPA 805 Transition Report - Rev 1.docx

PV09 "- Lii~rgy HNP NFPA 805 Transition Report Pages X-19 through X-92 are SECURITY RELATED INFORMATION.

These pages are withheld under 10 CFR 2.390.