Text

Response (60-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805
	ML15079A025
Person / Time
Site:	Robinson
Issue date:	03/16/2015
From:	Glover R; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15079A023	List: RNP-RA/15-0023, Response (60-Day) to Request for Additional Information Associated with License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805;
References
	RNP-RA/15-0023
	Download: ML15079A025 (66)
	v • d • e

SECURITY-RELATED INFORMATION - WITIDIOLD UNDER 10 CFR 2.390 R. Michael Glover

( -, DUKE H. B. Robinson Steam Electric Plant Unit 2 ENERGY Site Vice President Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 O: 843 8571704 F: 843 857 1319 Mike. Glover@d11ke-e11ergy.com 10 CFR 2.390 Serial: RNP-RA/15-0023 MAR 1 6 Wl5 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 I RENEWED LICENSE NO. DPR-23 RESPONSE (60-DAY) TO REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH LICENSE AMENDMENT REQUEST TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) STANDARD 805

REFERENCES:

1. Letter from W. R. Gideon (Duke Energy Progress) to U. S. Nuclear Regulatory Commission (USN RC) (Serial: RNP-RA/13-0090), License Amendment Request (LAR) to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition), dated September 16, 2013, ADAMS Accession No. ML13267A211

2. Letter from Martha Barillas (USN RC) to Site Vice President, H. B. Robinson Steam Electric Plant (Duke Energy Progress), H.B. Robinson Steam Electric Plant, Unit 2-Request for Additional Information on License Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection (TAC No.

MF2746), dated October 23, 2014, ADAMS Accession No. ML14289A260

Dear Sir/Madam:

This letter supersedes Serial No. RNP-RA/14-0122, submitted on November 24, 2014, which contained the 60-Day responses to Reference 2. Upon additional review of the original submittal, Duke Energy Progress, Inc. recognized the need to withhold security-related information contained in Enclosure 2 consistent with Reference 1 and pursuant to 10 CFR 2.390.

By letter dated September 16, 2013 (Reference 1) Duke Energy Progress, Inc. submitted a license amendment request to adopt a new risk-informed performance-based fire protection licensing basis for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2).

During the week of September 22, 2014, the NRC conducted an audit at HBRSEP2 to support development of questions regarding the license amendment request. On October 23, 2014 the Attachment C to Enclosure 2 of this letter contains SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

Upon removal of Attachment C from Enclosure 2, this letter is decontrolled.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Serial: RNP-RA/15-0023 Page2 NRC provided a set of requests for additional information regarding the license amendment request (Reference 2). That letter divided the requests for additional information into 60-day, 90-day, and 120-day required responses. Enclosure 1 provides the Duke Energy Progress responses to the 60-day requests for additional information. Enclosure 2 provides the updated Variance From the Deterministic Requirements (VFDR) list for Fire Area A 18. Duke Energy Progress, Inc. considers the enclosed VFDR list contained in Enclosure 2 a revision to Attachment C of the Transition Report, originally submitted via Reference 1, to be sensitive information and requests it be withheld from public disclosure pursuant to 10 CFR 2.390.

Please address any comments or questions regarding this matter to Mr. Richard Hightower, Manager- Nuclear Regulatory Affairs at (843) 857-1329.

There are no new regulatory commitments made in this letter.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March f~ ,

2015.

ichael Glover Site Vice President RMG/jmw Enclosures cc: Mr. V. M. Mccree, NRC, Region II Ms. Martha C. Barillas, NRC Project Manager, NRR NRC Resident Inspector, HBRSEP2 Ms. S. E. Jenkins, Manager, Infectious and Radioactive Waste Management Section (SC)

(w/o Enclosure 2)

U. S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0023 64 Pages (including this cover page)

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING VOLUNTARY FIRE PROTECTION RISK INITIATIVE

REQUEST FOR ADDITIONAL INFORMATION VOLUNTARY FIRE PROTECTION RISK INITIATIVE DUKE ENERGY PROGRESS H. B ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 Fire Protection Engineering (FPE) RAI 01 License Amendment Request (LAR) (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13267A211), Attachment A, Table B-1, Section 3.3.5.3 identified complies with clarification for the use of Frequently Asked Question (FAQ) 06-0022, Electrical Cable Flame Propagation Tests (ADAMS Accession No. ML091240278), i.e., flame propagation tests acceptable by the NRC. However, there is no description of how FAQ 06-0022 is being applied. Describe the specific application of this FAQ. Describe which aspects of the FAQ are being credited in lieu of meeting the National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (NFPA 805), 2001 Edition, Section 3.3.5.3 requirement.

Response

FAQ 06-0022 evaluates currently recognized flame propagation tests to the IEEE 383-1974 Standard, the United States (US) Nuclear Regulatory Commission (NRC) minimum test standard, and acceptance criteria for cable flame propagation tests. Table 2, in the Summary of Results section of FAQ 06-0022, provides a summary of the testing methods that are more severe than IEEE 383-1974. Non-IEEE-383-1974 qualified cables used at RNP are IEEE-383-1974 equivalent since they meet the cable standards identified in Table 2 of FAQ 06-0022, except for some original PVC jacketed cabling. Depending on when the PVC jacketed cables were installed, they might not have met the requirements of IEEE-383-1974 or equivalent. The original cables not meeting the requirements of IEEE-383-1974 or equivalent were coated with fire retardant material which meets or exceeds the original cable coating requirements to prevent propagation of fire.

The cable coatings utilized were asbestos-free Flamemastic 77 as manufactured by Flamemaster Corporation and/or Quelpyre Mastic 703B as manufactured by Qulecor, Inc. and/or Intumastic 285 as manufactured by Carboline, Inc.

A revision to LAR Attachment A, Table B-1, Section 3.3.5.3 will be submitted with the 120 day RAI responses.

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FPE RAI 07 LAR Attachment S, Table S-1, Implementation Item 3 indicates that Hemyc fire barrier wrap was replaced with Interam E54A for protecting the Component Cooling Water pump power cables. However, Promatec MT wrap is also described in the LAR Attachment C, in an Existing Engineering Equivalency Evaluation for fire areas A3, A6, and A11, addressing protection of the Steam Generator Blowdown System lines and penetrations.

a. Provide a description of any other credited Hemyc or Promatec MT fire barriers used for the Nuclear Safety Capability Assessment (NSCA).

b. Where Hemyc or Promatec MT is used, provide the basis for barriers' credited rating as an ERFBS or any other credited uses.

c. Describe any other ERFBS and passive fire protection features that are credited for the NSCA and explain how they were identified as being required for this purpose. Provide the technical justification (e.g., test certification, for their use or credit).

d. Identify and describe any proposed plant modifications to these barriers.

e. If performance-based methods are used, include a discussion of the safety margin and defense-in-depth (DID) considered in the evaluation.

Response

a. Per a review of the applicable Fire Safety Analysis (FSA) calculations, only evaluations RNP-M/MECH-1850, RNP-M/MECH-1849 and RNP-M/MECH-1854, identify the use of Promatec MT material as part of the configuration of several fire barrier penetration seals, including those accommodating the steam generator blowdown lines. These fire barrier penetration seal configurations were evaluated as acceptable under Existing Engineering Equivalency Evaluation (EEEE) RNP-M/MECH-1677 and RNP-M/MECH-1682. It was concluded in these referenced evaluations that the combination of the silicone foam seal within the barrier itself, and the coverage and shielding provided by the Promatec "MT" blanket wrap on both sides of the penetrations provides assurance that the composite assembly is capable of withstanding the fire challenge which would be imposed by the fire hazards present within the associated fire zones.

b. No Hemyc or Promatec MT materials are credited as Electrical Raceway Fire Barrier System (ERFBS) barriers or any other credited uses other than the non-standard fire barrier penetration seal configurations that were evaluated to meet Table B-1, Section 3.11.4, requirements with a Complies Via Engineering Evaluation basis. Design and installation deviations pertaining to passive fire protection features are evaluated on a fire zone basis as acceptable under EEEEs RNP-M/MECH-1677 and RNP-M/MECH-1682. These evaluations determined that the non-standard fire barrier penetration seal configurations are adequate for the hazards present in these Fire Areas and are acceptable based on a defense in depth approach that utilizes the fire resistance characteristics of the as built conditions, presence of ignition sources, arrangement, quantity, and type of combustibles present, active and passive fire protection features present, segregation of safe shutdown trains, and fire brigade response for both sides of the fire barriers in question. As a result, the justification of the as built configuration is not reliant on strict combustible loading limits, but a defense in depth approach that includes various fire protection features.

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Engineering Evaluation EE-90-025 provides additional details and historical information on these penetration seal configurations that use Promatec MT materials along with silicone foam. It was concluded in these referenced evaluations that the combination of the silicone foam seal within the barrier itself, and the coverage and shielding provided by the Promatec "MT" blanket wrap on both sides of the penetrations, provides assurance that the composite assembly is capable of withstanding the fire challenge which would be imposed by the fire hazards present within the fire zones.

c. The only ERFBS configurations credited are the completed modifications to the A and C Component Cooling Water (CCW) Pump power supplies that are detailed in the License Amendment Request (LAR) Attachment S-1, Item #3. The configurations are not credited in the PRA or NSCA and are only credited for defense-in-depth (DID) during the fire risk evaluation in the Fire Safety Analysis (FSA).This modification previously replaced the existing Hemyc fire barrier wrap materials with a one hour rated barrier configuration on the CCW Pumps A & C power supply raceways. The Hemyc wrap was replaced with Interam E54A material.

FSA evaluation RNP-M/MECH-1848 for Fire Area C credits the wrapped configurations for defense-in-depth (DID) purposes only. The one hour rated ERFBS for the power cables to Component Cooling Pumps A and C, automatic smoke and heat detection, and partial area coverage wet pipe sprinkler system over the Component Cooling Pumps, the required equipment will remain available to support safe shutdown in the event of a fire.

As discussed in the LAR B-1 Table section 3.11.5 reference GID/R87038-0014, Design Basis Document; Fire Barrier System, Rev. 3 states:

Cable fire wraps are used as localized fire barriers in the Component Cooling Pump Room to protect electrical circuits where the redundant trains are in the same area. These wraps are intended to provide at least 1-hr protection.

The fire endurance test methodology and acceptance criteria to tests serving as the qualification for the 3M Interam wrap system at HBR2 is that outlined in NRC GL 86-10 Supplement 1, Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area, dated March 25, 1994.

The PCI Promatec fire tests, which serve as the primary qualification basis for Interam wrap, are denoted CTP-1198, CTP-1199, CTP- 2005, CTP-2009, and CTP-2011. These tests were performed to meet the acceptance criteria specified by NRC GL86- 10, Supplement 1.

The following summaries on the above PCI Promatec fire tests were obtained from Section B.7.1 of reference GID/R87038/0014:

Fire test CTP-1198 is a 1-hour fire endurance test of various Interam Wrap configurations and materials. This test is utilized as part of the basis for qualification of the Interam Wrap installed on junction and pull boxes at HBR2. The junction box tested was 12" x 12" x 8" which was tested in free air (away from structure). It was covered by three layers of Interam E54A utilizing the Page 3

same materials and installation techniques as the Interam Wrap coverage on the junction boxes and pull boxes at HBR2. There was no cable loading in the tested junction box. The Interam E54A fire barrier system installed on the tested junction box met the acceptance criteria of NRC GL 86-10, Supplement 1 for a 1-hour enclosure.

Fire Test CTP-1199 is a 1-hour fire endurance test of various Interam Wrap configurations. This test is utilized as the basis for qualification of the installed Interam Wrap on conduits in free air (away from structure) and part of the basis for qualification of the Interam Wrap installed on conduits against structure. 1" and 5" conduits, individually wrapped with Interam Wrap, were tested in free air. These conduits had vertical and horizontal sections, radial bends and 90° lateral bend condulet fittings (LBDs). The protected commodities were covered with three layers of Interam E54A material. The conduits and supports were covered utilizing the same materials and installation techniques as the Interam Wrap coverage on the conduits at HBR2. There was no cable loading in the tested conduits. The Interam E54A fire barrier system installed on the tested commodities met the acceptance criteria of NRC GL 86-10, Supplement 1 for a 1-hour enclosure.

Fire Test CTP-2005 is a 3-hour fire endurance test of various Interam Wrap configurations. This test is used as the basis for qualification for installed Interam Wrap for raceways at silicone foam penetration seals. While this was a 3 -hour test, the collar installed at the structural interface utilized the same material and installation techniques utilized for the collars installed for the 1-hour Interam Wrap configurations. The collar tested was comprised of two layers of Interam E54A material. The Interam E54A fire barrier system installed on the tested commodities met the acceptance criteria of NRC GL 86-10, Supplement 1 for a 3-hour enclosure.

Fire Test CTP-2009 is a 3-hour fire endurance test of various Interam Wrap configurations. This test is used as the basis for qualification for installed Interam Wrap for raceways at grouted penetrations and for raceways wrapped against structure. While this was a 3-hour test, the collar installed at the concrete/grout interface and the coverage flaring out onto the concrete structure utilized the same material and installation techniques utilized for the 1-hour configurations. The collar tested was comprised of two layers of Interam E54A material. The coverage flaring out at structure tested was 3 layers of Interam E54A material attached to the structure with anchor bolts. The Interam E54A fire barrier system installed on the tested commodities met the acceptance criteria of NRC GL 86-10, Supplement 1 for a 3-hour enclosure.

Fire Test CTP-2011 is a 1-hour fire endurance test of a large (6' - 3" x 4' 8" x 2' 6") box constructed of Unistrut P1000 members welded into a framework lattice and covered with steel wire mesh. The box assembly was covered with three layers of Interam E54A material. This test is utilized as the basis for qualification of the Interam Wrap interface with structure which is installed on the pull box at HBR2. The box was covered utilizing the same materials and installation techniques as the Interam Wrap coverage on the junction and pull boxes at HBR2.

There was no cable loading in the tested box assembly. The Interam E54A fire barrier system installed on the tested box assembly met the acceptance criteria of NRC GL 86-10, Supplement 1 for a 1-hour enclosure.

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Per section B.7.2 of reference GID/R87038/0014: Interam E54A is installed on 3" and 4" conduits including horizontal and vertical runs, radial bends and LBDs and on junction and pull boxes (one - 16" x 20" x 11" junction box, one - 24" x 24" x 12" junction box and one 18" x 18" x 10.5" pull box). These Interam Wrap configurations are required to provide a 1-hour fire barrier in accordance with the acceptance criteria of NRC GL 86-10, Supplement 1.

Per section B.8.0 of reference GID/R87038/0014: Full-scale fire endurance tests performed by PCI Promatec under CTP-1198, CTP-1199, CTP-2005, CTP-2009, and CTP-2011 in accordance with NRC GL 86-10, Supplement 1 and supporting engineering evaluation for the coverage on the supports qualified the 3M Interam E54A coverage on the 3" and 4" conduits, the junction and pull boxes and the supports as a 1-hour fire rated barrier. The conclusions described below can reasonably be drawn:

No significant variations exist between the Interam Wrap configurations installed on conduits at HBRSEP and the tested configurations.

Interam Wrap configurations installed on junction/pull boxes at HBRSEP both at structure and away from structure are supported by designs qualified by testing and/or engineering evaluation.

Interam Wrap configurations installed at HBRSEP at wall penetrations are supported by designs qualified by a design qualified by testing.

Interam Wrap configurations installed at HBRSEP at structures are supported by designs qualified by testing.

Based on the engineering evaluation, the Interam Wrap coverage on supports at HBRSEP is adequate to attenuate excessive conduction of heat into the raceway fire barriers by exposed portions of attached supports.

Therefore, based on the considerations, Interam Wrap configurations installed HBRSEP are bounded by similar configurations qualified by testing and I or by engineering evaluations for a 1-hour fire endurance testing.

The scope of EC 63687 details the replacement of existing Hemyc Wrap on the CCW Pumps A and C power supply raceways (conduit nos. DS503 and DS504 for the CCW Pump A and conduit nos. 24137 and 24138 including pull box for the CCW Pump C) with a one-hour rated 3M Interam E54A fire wrap system. In addition, the new Interam E54A wrap system covered junction boxes at the CCW Pump A and C motors.

As discussed previously these 1-hour rated configurations are not credited in the PRA or NSCA.

These configurations are only credited for defense-in-depth (DID) during the fire risk evaluation in the Fire Safety Analysis (FSA).

d. No modifications are planned or were credited as ERFBS barriers other than the A and C CCW pump power supplies detailed in the LAR Attachment S-1, Item # 3, that were completed and discussed previously [only credited for defense-in-depth (DID)].

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An evaluation of Defense-In-Depth (DID) and Safety Margin was performed for all fire areas (documented in Calculations RNP-M/MECH-1844 through RNP-M/MECH-1874) as detailed in project procedure FPIP-129, NFPA 805 Fire Safety Analysis. This evaluation was performed for all areas, regardless of whether National Fire Protection Association (NFPA) 805 compliance was demonstrated using a performance based approach or a deterministic approach.

Attachment C of the LAR includes a summary description of the methodology and criteria used to determine which recovery actions and other fire protection features were retained as defense-in-depth. A similar discussion of how the safety margin determination was evaluated was also included.

FPE RAI 09 In LAR Attachment L, Request 1, the licensee states that FAQ 06-0022 concluded that the NFPA 262, Standard Method of Test for Flame Travel and Smoke of Wires and Cables for Use in Air-Handling Spaces, test is equivalent to the IEEE-383-1974 test and therefore, IEEE cable is inherently equivalent to plenum rated cable and acceptable to be routed above suspended ceilings.

While FAQ 06-0022 documented that the NFPA 262 is a more stringent fire test than the IEEE [Institute of Electrical and Electronic Engineers]-383 test, and therefore, IEEE cable is inherently equivalent to plenum rated cable and acceptable to be routed above suspended ceilings.

While FAQ 06-0022 documented that the NFPA 262 is a more stringent fire test than the IEEE-383 test, the reverse is not true. A cable that passes the IEEE-383 flame test does not necessarily pass the NFPA 262 test. Describe whether the assumption of equivalence between the IEEE-383-1974 and NFPA 262 tests is relied upon and if so, revise the request as needed (i.e., clarify if this is no longer the case).

Response

The assumption of equivalence between the IEEE-383-1974 and NFPA 262-2002 stated in the LAR Attachment L, Request 1 is not accurate. The Control Room (FZ 23), Inside AO Office and old Turbine Building RCA Entrance (FZ 25A) are the only locations in the Power Block that have cables above suspended ceilings. The basis of this request is that all electrical wiring above the control room partial suspended ceiling is in conduit except for short flexible connectors to lighting fixtures. According to the FAQ 06-0021, cable air drops of limited length (~3 feet) are considered acceptable. There is a limited quantity of cabling and wiring above the suspended ceilings, and no equipment important to nuclear safety is located in the vicinity of these cables. The Inside AO Office and old Turbine Building RCA Entrance (FZ 25A) are not risk significant. Neither of the rooms nor the cables are safety-related.

In addition, the existing fire detection capability and/or the control room operators who are continuously present in the area would identify the presence of smoke.

A revision to LAR Attachment L will be submitted with the 120 day RAI responses. The revision will include text revisions to Approval Request 1 and the Basis for the Request.

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FPE RAI 10 LAR Attachment S, Table S-2 states the fire probabilistic risk assessment (FPRA) follows the methodology of FAQ 08-0046, Incipient Fire Detection Systems, (ADAMS Accession No. ML093220426) for the Very Early Warning Fire Detection Systems (VEWFDS) in Fire Areas A16-18, which includes the main control room (MCR). LAR Section 4.8.3.2.5 also identifies the installation of a VEWFD system in the cable spreading room. In addition, LAR Section 4.8.3.2.6 indicates that the VEWFD system installation in the main control boards (MCB) is credited in the FPRA. Provide the following additional information for all VEWFD systems:

a. Because of the various vendor types VEWFD systems, provide a description of the VEWFD system being installed or considered. If the system has not yet been designed or installed, provide the design features for the proposed system along with a comparison of these specified design features to their role in satisfying or supporting the risk reduction features being credited in FAQ 08-0046. Include in this discussion the installation testing criteria to be met prior to operation.

b. Describe the physical separation of the cabinets in which in-cabinet VEWFD is being installed or credited.

c. Describe how each cabinet will be addressable by the detection system. Describe whether the sampling will be independent for each cabinet or will samples be taken by a common header, for instance.

d. Based on the operator recognizing the impacted cabinet(s) fire location sufficiently early, describe what operator actions are necessary to limit fire impact and allow safe shutdown of the plant from the control room. Describe how the operator will be made aware of what must be done to remain in the control room for plant shutdown.

e. Where area-wide VEWFD is being credited, provide a discussion of the system including the design criteria, operator response required, and the justification for the credit being taken in comparison to FAQ 08-0046.

f. Provide the codes of record for the design, installation, and testing of VEWFD systems.

g. Identify the implementation item in LAR Attachment S for VEWFD procedure development and training.

Response

a. The VEWFDS being installed will be an air-aspirated detection system provided by Safe Fire Detection Inc. (SAFE). The design will support satisfying the risk reduction features described in FAQ 08-0046, for in-cabinet systems. For area-wide VEWFDS, Fire PRA will assume Prompt detection and use the control room suppression curve. No Fire PRA credit will be taken for VEWFDS in the Main Control Room. The testing criteria will meet NFPA 72, and specifically, NFPA 76 for the transport time and obscuration requirements.

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b. Each cabinet in which in-cabinet VEWFDS is being installed will be physically separated from adjoining cabinets. Each individual cabinet will have one or two sample ports inside. The physical separation in cabinets outside the Main Control Room, is sheet metal, typically found in cabinet construction, that create separation barriers between panel sections.

c. The VEWFDS will be addressable on a zone basis. Each VEWFDS detector will be comprised of one to four zones. Each addressable zone will have as little as one cabinet and at most nine cabinets. Each zone, regardless of the number of cabinets it is monitoring, will have one header.

d. When an alert or alarm signal is received, an operator and an I&C technician immediately respond to the area. At this point, a continuous fire watch has been established, and will remain in place until the event is concluded. All responding operators are qualified to use a fire extinguisher if needed, and additionally, are fire brigade qualified. The responding operator will be in constant contact with the control room, constantly assessing the situation and communicating back to the control room operators.

e. The area-wide VEWFDS design will consist of four zones. Two zones will be located at the ceiling and cover one half of the room each. Two zones will be located in close proximity to the two open relay racks. There will also be a sampling ports located at the rooms exhaust vents.

Operator response to the area-wide VEWFDS will be immediate for any signal (trouble, alert, alarm), and the Instrumentation and Control (I&C) technician with the portable sensing equipment (this is a handheld VEWFDS detector) will immediately respond to alerts and alarms.

The FPRA credit assumes Prompt detection and uses the control room suppression curve.

f. The NFPA codes of record for the design, installation, and testing of VEWFD systems will be NFPA 72, latest edition at time of installation, National Fire Alarm and Signaling Code. NFPA 76, latest edition at time of installation, Standard for the Fire Protection of Telecommunications Facilities will be used specifically for transport time and obscuration requirements only.

g. Committed modifications #1 and #2 from Table S-2 will be installed as an Engineering Change (EC). The EC that is being developed for the VEWFDS will include:

d Revisions to the operating procedures used for personnel responding to fire (trouble, alert, and alarm) d Training (in-class and practical) required for the I&C technician who will respond to alert and alarms with the portable sensing equipment to assist the operator with pin-pointing the exact location of the fire These changes will be similar to the changes made at Harris Nuclear Plant for their installation of the VEWFDS.

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FPE RAI 11 LAR Attachment A, Element 3.3.5.3, describes the basis for acceptability of original plant cable but does not describe the current plant standard for cable installation or identify whether changes to the current specification are necessary for transition. Describe the current plant standard for cable installation relative to the requirements of NFPA 805 Section 3.3.5.3, and identify any changes necessary for implementation, and post-transition.

Response

Design Basis documents DBD/R87038/SD16 and DBD/R87038/SD62 define the functional requirements, regulatory requirements, commitments relative to system design, and the original design codes and standards of record for the electrical distribution system. These requirements are also reflected in section 8.3 of the UFSAR. DBD/R87038/SD62 sections 3.5.1.3.2, 3.5.1.3.3, and 3.5.1.3.5 state that (with only the exceptions listed in 3.5.1.3.5) all cabling installed at HBR shall meet the IEEE 383-1974 vertical flame test qualification requirements. Implementation of NFPA 805 and post transition support of the program will not change these cabling/ raceway requirements.

New cable installations at RNP will be controlled by the plant modification process (Procedure EGR-NGGC-0005). The modification process will implement the standards for installation of new cabling at Robinson using the procedures and drawings contained in the Plant Operating Manual (POM). These are controlled documents and are used in the design process to control the installation and testing of plant cabling. The following is a list of the documents used by the design and installation groups.

DBD/R87038/SD16 Design Basis Document (Electrical Power System)

DBD/R87038/SD62 Design Basis Document (Cable and Raceway System)

HBR2-0B060 Electrical Design and Installation Practices (Controlled by the Electrical Design Organization)

L2-E-017 Specification for Control Cable and Low Voltage Power Cable EGR-NGGC-028 Engineering Evaluations EGR-NGGC-0100 Electric Distribution System Change Control EGR-NGGC-0103 Power Cable Sizing EGR-NGGC-0105 Control Cable Sizing EGR-NGGC-0155 Specifying Electrical/I&C Modification Related Testing EGR-NGGC-0356 Electrical Raceway Design CM-303 Installation of Environmentally Qualified or Safety Related Taped Splices MMM-028 Control of Field Issued Material MMM-053 Electrical Installation Page 9

MOD-008 Station Blackout Engineering Screening Capability MOD-026 Cable Design for the HB Robinson Plant MCP-NGGC-0401 Material Acquisition-Procurement, Receiving, and Shipping Cable and conduit design and pull criteria for cable pulls shall be in accordance with MOD-026.

Installation of conduit, cable, electrical terminations, splices, and grounding shall be in accordance with HBR2-0B060. All cable pulls shall be documented per MMM-053.

Any replacement of existing cabling (non-IEEE 383) will be implemented using an appropriate Engineering product produced using the documents listed above.

Replacement of existing cabling that currently meets the IEEE 383 requirements will be controlled by the Work Control process using the appropriate procedures listed above to provide the guidance and controls for cable replacement and raceway adequacy.

Based on the above, no changes to the current design basis, specifications, standards, or features are required for transition to NFPA 805, or its post transition support.

FPE RAI 12 The discussion in LAR Section 4.7.1 indicates that a design-basis document (DBD) has been created, but also describes (in the last paragraph) what the document will contain. There is no specific mention of the DBD in LAR Attachment S, "Modifications and Implementation Items," although it may be included in LAR Attachment S, Table S-3, Implementation Item 7. Clarify if the DBD will require an update, and if so, identify the implementation item associated with that updated action.

Response

The DBD consists of the Fire Safety Analysis (FSA) calculations for each plant fire area and the NFPA 805 Code Compliance Calculation as described in the LAR. These documents have been created as part of transition as is stated in the LAR. They will be finalized and issued as part of transition to NFPA 805 under the implementation EC. This is included under Implementation Item 6 of Table S-3 of the LAR.

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FPE RAI 13 LAR Attachment S, Table S-2, Implementation Item 5 proposes that a modification to ensure configuration meets crediting 10-minute delay on cables in the Cable Spread Room and the E1/E2 Switchgear Rooms. Provide the following:

a. Description of the type and extent of barriers being installed.

b. The rated configuration being met for the barriers.

c. Whether the requirements of NFPA 805 Section 3.11.5 for ERFBS will be met or some other standard including the technical justification for the standard used.

d. Describe the purpose of the 10-minute delay.

Response

a. The physical barriers installed for cables in the Cable Spread Room and the E1/E2 Switchgear Room will delay cable damage for at least 10 minutes. The design is not developed far enough to know the exact type and extent of the barriers being installed.

b. The configuration of the installed barrier will ensure the 10 minute time delay for cable damage in the affected areas.

c. Depending on the solution chosen, the appropriate standard will be applied for that installation to ensure the configuration complies with the FPRA assumptions.

d. The purpose of the 10 minute time delay is to allow time for Halon to actuate in the fire area and extinguish the fire before any damage to the cables would occur.

Safe Shutdown Analysis (SSA) Request for Additional Information (RAI) 01 LAR Section 4.2.1.2, under the heading Results, states that the NFPA 805 licensing basis for the plant is to achieve and maintain hot shutdown conditions following a fire. Later in the same section, the LAR describes stabilization in hot standby as the point for determining long term decay heat removal and inventory/pressure control strategies. Provide clarification regarding the safe and stable condition the licensee is assuming in its analyses (i.e., hot standby or hot shutdown).

Response

H.B. Robinson defines safe and stable conditions as those corresponding to hot standby. Decay heat is removed from the RCS via the steam generators and the auxiliary feed system. As defined in the plant technical specifications, hot standby is Keff < 0.99 and an average reactor coolant temperature > 350°F.

It does not include the RHR system for shutdown cooling.

A revision to LAR Section 4.2.1.2 will be submitted with the 120 day RAI responses.

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SSA RAI 04 LAR Attachment G references both LAR Attachment S, Table S-2, Committed Modifications, and LAR Attachment S, Table S-3, Implementation Items, in the discussion for the same implementation items related to incorporating recovery actions in post-fire shutdown procedures, updating training processes, assessing the physical feasibility of new NSCA actions, and updating plant calculations. Based on the content of these items, confirm that both LAR Attachment S, Table S-2 and LAR Attachment S, Table S-3 are the appropriate references.

Response

The reference to Table S-2 should be S-3. The Implementation items to update the NSCA are captured in Implementation Items 7 and 8 of Table S-3.

A revision to LAR Attachment G will be submitted with the 120 day RAI responses.

SSA RAI 05 LAR Attachment S, Table S-3, Implementation Item 8 involves the performance of a feasibility study specifically for new actions taken to reduce self-induced station blackout areas in the plant. Clarify if this implementation item is the same, or has the same scope, as the physical feasibility assessment of new NSCA recovery actions as described in LAR Attachment G. Provide additional information to clarify any remaining feasibility analysis described in LAR Attachment S, Table S-3 and the potential impact on the NSCA, if any.

Response

The two items cited are the same. RNP had previously developed calculation RNP-E-8.050, Appendix R Transient Analysis and Timeline Evaluation For H.B. Robinson- Unit No. 2, to document feasibility for Appendix R response time critical manual operator actions that are credited with mitigating postulated fire induced damage. RNP-E-8.050 identifies the required times in which the actions need to be performed, as well as a feasibility check for the individual actions. For those actions that are not changed for NFPA 805, the feasibility performed under Appendix R is still applicable. New recovery actions will be incorporated into Calculation RNP-E-8.050. The Engineering Change (EC) process for transition to NFPA 805 will provide the vehicle for updates to calculation RNP-E-8.050 and any additional procedure revisions required for the transition, including the Dedicated Shutdown Procedures (DSPs).

For transition to NFPA 805, DSPs are being revised or developed to eliminate reliance on the Self Induced Station Blackout (SISBO) strategy. The procedure review process for Dedicated Shutdown Procedures is performed in accordance with OMM-043, Verification and Validation. Checklists provided in OMM-043 are completed during the procedure review process dependent on the scope of the change. Changes to DSPs that affect time critical actions in the field require a walk through validation, as well as a time critical action validation to ensure the actions can be performed within the time requirements identified in RNP-E-8.050 for that particular action.

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SSA RAI 06 A few of the completed modifications identified in LAR Attachment S, Table S-1 (i.e., Items 8, 14, and 15) are described merely as Protect the . with no description of how the components/cables were protected. Provide additional information regarding the means of protection performed for those completed modifications.

Response

Additional Discussion for the modifications are below as requested.

Table S-1 Item 8:

Problem Statement: Hot short cases were identified for a postulated fire in the Turbine Building that could result in the loss of capability of the Emergency Diesel Generators to supply electrical power to the Emergency Buses. This potentially results in unrecoverable plant conditions or equipment damage.

Modification: Protect the E-Bus Incoming Line Breakers from Spurious Operations for a Postulated Fire in the Turbine Bldg.

==

Description:==

Re-design the closing control circuit of the Emergency Bus Incoming Line Breakers by adding an auxiliary relay in the RTGB breaker closing circuit.

Table S-1 Item 14:

Problem Statement: Resolve the issue of the loss of wide range Steam Generator level indication for a postulated fire in the Turbine Building and the Auxiliary Feedwater Pump Room.

Modification: Protect Steam Generator Wide Range Level Indication From a Postulated Fire in the MDAFW Pump Room and the Turbine Bldg.

==

Description:==

Install Isolators for SG Wide Range Level Indicators Table S-1 Item 15:

Problem Statement: Due to postulated fires in Fire Areas A5, E and G1 cables that are required to close the MSIVs from the control room are subject to the fire-induced hot-shorts that could cause the MSIVs to fail as-is in the open position.

Modification: Protect Steam Isolation Valve Circuits.

==

Description:==

Physically separate the target conductors from their source in each of the affected MSIV control circuits to prevent fire induced circuit spurious operations.

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SSA RAI 07 LAR Attachment B, Element 3.5.2.1, states that CT [current transformer] circuits of concern have been identified and the final disposition of the potential fire scenarios will be assessed as part of the SSA/Fire PRA transition to NFPA 805, and then refers to an implementation item in LAR Attachment S, Table S-3. However, no implementation item related to CT circuits was identified in LAR Attachment S, Table S-3. Additionally, LAR Section 4.2.1.1 states that the evaluation concludes that this failure mode is unlikely for CTs that could pose a threat to safe shutdown equipment. From the above statement, it would appear that the evaluation has been completed. Provide clarification as to whether the CTs analysis has been completed, if not, provide the appropriate implementation item in LAR Attachment S, Table S-3.

Response

An evaluation considering the potential for secondary fires resulting from an open circuit on all CT secondary circuits at RNP has been performed and is documented in EC 93120. This evaluation first identified all CT circuits at RNP, their turns ratio, and impacted systems and fire areas. The following design considerations were used to evaluate the potential for adverse impacts to Safe Shutdown equipment resulting from a secondary fire caused by fire-induced CT secondary lead damage. All CTs were dispositioned as requiring no further action by virtue at least one of these design considerations:

1. For CT turns ratios of <1200:5, the results of EPRI document NUREG/CR-7150, Joint Assessment of Cable Damage and Quantification of Effects from Fire, Vol. 1 was referenced. Based on theoretical evaluation and test data this study concludes that this theoretical failure mode (secondary fire caused by a CT secondary open circuit) is incredible for CTs with low turns ratio (1200:5). EC 93120 also references Palisades NPP Report EA-APR-95-034 which concludes that CTs with a turns ratio <800:5 present no concern.

2. For CTs with high turns ratios (>1200:5), EPRI document NUREG/CR-7150 states that other than internal CT damage, no further adverse effects are expected to occur as a result of the open circuit condition. Note that the study concluded that though the likelihood of secondary fires in higher ratio CTs is very low, the absence of test data suggests that the failure mode of concern could not be classified as incredible and that to permanently resolve the concern, the PIRT panel recommends that additional testing be performed. Nuclear Tracking Mechanism (NTM) 622628 is open to capture the results of any future testing performed on higher turns ratio CTs and re-evaluate the CTs of concern as needed.

3. CTs whose secondary circuit does not leave the fire area which contains the power supply of concern were excluded. The technical basis for exclusion is that safe shutdown assumes fire damage throughout the fire area. This exclusion applies to deterministically dispositioned fire areas.

4. Fire induced damage to transformer and differential CT circuits will result in protective actuation of the parent component thereby isolating power to the CT.

5. CTs located in switchgear or components that are not credited for SSD were excluded.

The EPRI and Palisades documents referenced above also corroborate the conclusions of June 27 1984 NRC document NOE97-1380, Attachment 1, Brookhaven National Laboratory/NRC Correspondence on Current Transformers.

Page 14

This evaluation also considers that, to date, there continues to be no operational experience substantiating this theoretical failure mode in any nuclear or non-nuclear application.

A revision to LAR Attachment B, Alignment Basis for Element 3.5.2.1 to remove reference to Implementation item in Attachment S, Table S-3 will be submitted with the 120 day RAI responses.

SSA RAI 08 LAR Section 4.2.3, Licensing Action Transition, states that since the exemptions are either compliant with 10 CFR 50.48(c) or no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), CP&L requests that the exemptions listed in Attachment K be rescinded as part of the LAR process. However, LAR Attachment K, Exemption from the Requirements of Section III.O of Appendix R to 10 CFR Part 50 is identified as being necessary for transition. Address whether the subject exemption should be carried forward with the transition.

Response

It is H.B. Robinsons intent to transition the Exemption from the Requirements of Section III.O of Appendix R to 10 CFR Part 50 into the new NFPA 805 licensing basis.

As noted in Section 4.2.4 of the LAR, HBRSEP is transitioning one Licensing Action. This exemption will remain part of the post-transition licensing basis. The exemption from Section III.O of Appendix R was granted by the NRC to the extent that a reactor coolant pump lube oil collection system is not provided. In lieu of installing such a system, fixed fire suppression is maintained and additional detection and dikes were installed in the pump bays. Also, the Containment Spray system serves as a backup fire suppression system with Sodium Hydroxide isolated. This is further explained in Attachment K.

Attachment K lists each pre-transition exemption from Appendix R in its own individual section. At the end of each section, there is a Transitioned box to the right and just above the list of references that pertain to the discussion of that particular exemption. For the Exemption from Section III.O, this box is checked, indicating that it is H.B. Robinsons intent to have this exemption be transitioned into the NFPA 805 fire protection program as previously approved (NFPA 805 Section 2.2.7). This licensing action is considered compliant under 10 CFR 50.48(c).

Thus, all pre-transition Licensing Actions are either compliant with 10 CFR 50.48(c) or no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), and will not be transitioned as exemptions into the NFPA 805 fire protection program.

A revision to LAR Section 4.2.3 will be submitted with the 120 day RAI responses.

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SSA RAI 10 LAR Attachment D, Implementation Guidance F.3 states that recovery actions were not used in any fire area to restore a KSF path in order to eliminate a pinch point. However, later in the same section, the review proposed several recovery actions or other actions to (1) ventilate the emergency diesel generator (EDG) room, (2) energize supplement plant equipment, and (3) remove power from certain motor operated valves (MOVs). If the proposed recover actions are finalized, describe how the feasibility evaluation will be performed for such actions.

Response

Actions above that were identified in Attachment D and called recovery actions or other actions are beneficial actions that could be taken but are not used by the analysis to recover pinch points. Pinch Points are addressed by fire risk management actions that are identified in plant outage procedures with additional actions to be taken for high risk evolutions. These fire risk management actions are discussed in LAR Attachment D, Implementation Guidance F.4.

No additional actions beyond normal plant operating procedures are credited for Non-Power Operations (NPO). A proposed change to de-energize components in the shutdown cooling flowpath to prevent spurious operation and potential loss of shutdown cooling (i.e., SI-860A(B) and SI-861A(B)) could be considered pre-emptive actions but were not used to recover a pinch point by the analysis.

No recovery actions are used to restore a pinch point following a fire event during NPO, therefore evaluation of feasibility is not required.

SSA RAI 12 In LAR Attachment C, the VFDR list for Fire Area A18 is missing the "Failure Impact" discussion. Provide an updated VFDR list for Fire Area A18.

Response

In LAR Attachment C, the VFDR list for Fire Area A18 is revised to include Failure Impact information.

The revised Fire Area A18 VFDR list is attached in Enclosure 2.

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Fire Modeling (FM) Request for Additional Information (RAI) 01.b NFPA 805, Section 2.4.3.3, states that "the PSA [probabilistic safety assessment] approach, methods, and data shall be acceptable to the AHJ [authority having jurisdiction] ... "

The NRC staff noted that fire modeling comprised the following:

- Fire Dynamics Tools (FDTs) were used for zone of influence (ZOI) calculations of cabinets, pumps, motors, oil fires and transient fire sources, and to evaluate the development and timing of Hot Gas Layer (HGL) conditions in selected compartments.

- The Consolidated Fire Growth and Smoke Transport (CFAST) model was used to calculate MCR abandonment times and to determine HGL temperature, optical density and Halon system activation time for a specific analysis in Fire Zone 20.

- The FLASH-CAT model was used to calculate the fire propagation in a vertical stack of horizontal cable trays in Fire Zone 20.

- The Generic Fire Modeling Treatments (GFMTs) were used to determine 'initial' severity factors.

LAR Section 4.5.1.2, "Fire PRA," states that fire modeling was performed as part of the FPRA development (NFPA 805 Section 4.2.4.2). Reference is made to LAR Attachment J, "Fire Modeling V&V

[verification and validation]," for a discussion of the acceptability of the fire models that were used.

Regarding the acceptability of the PRA approach, methods, and data:

b. Explain how the effect of the increased heat release rate (HRR) due to fire propagation in cable trays was accounted for in the ZOI, HGL, and multicompartment analysis (MCA) calculations; or provide technical justification for ignoring this effect.

Response

Based on the amount of combustibles (generally cable trays in the ZOI), the fire growth is estimated using guidance from NUREG/CR-6850, Appendix R. The fire propagation among a stack of vertical cables trays follows this general timeline:

TIMELINE TIMELINE DESCRIPTION T1 Time to build ignition source fire to scenario HRR = 12 minutes T2 Time to ignite the first target (tray) based on NED-M/MECH-1009 T3 Time to ignite second tray = T2 + 4min T4 Time to ignite third tray = T3 + 3min T5 Time to ignite fourth tray = T4 + 2min T6 Time to ignite fifth tray = T5 + 1min TX Time to ignite X tray = previous tray + 1min Page 17

The following properties are assigned to the horizontal cable fire growth for RNP based on NUREG/CR-6850 and NUREG/CR-7010:

Cable Tray Width 0.61 m Typical tray width HRR per unit area 250 kW/m2 NUREG/CR-7010, section 10.1 Using the values listed above, the heat release rate for the cable trays is calculated as the surface area of the tray multiplied by the heat release rate per unit area. The angle of 35° described in Appendix R.4.2 of NUREG/CR-6850 is used for determining the length of the cable trays in the stack above the ignition source so that the appropriate burning surface for each tray is determined.

The total fire growth is based on adding the source fire HRR plus each tray HRR per unit time. Fire spread in each tray is assumed to be offset by the burnout. If the fire grows large enough to support a HGL, the time to HGL can be estimated. An adjustment was made to the process of calculating the time to HGL by using cumulative HRR by comparing the energy required to produce an HGL to the total energy produced by the fire. The MCA was performed the same way as the HGL analysis.

FM RAI 01.c NFPA 805, Section 2.4.3.3, states that "the PSA [probabilistic safety assessment] approach, methods, and data shall be acceptable to the AHJ [authority having jurisdiction] ... "