ML21351A248

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Trp 26 St. Lucie SLRA - Fire Protection Breakout Questions
ML21351A248
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 12/17/2021
From: Leslie Terry
NRC/NRR/DNRL
To:
Rodriguez-Luccioni H
References
EPID L-2021-SLR-0002
Download: ML21351A248 (18)
v • d • e


Text

St. Lucie Nuclear Plant, Units 1 and 2, Subsequent License Renewal Application (SLRA)

Breakout Audit Questions Technical Reviewer Leslie Terry 12/ 13 /2021 Technical Branch Chief Steven Bloom 12/13/2021 Breakout Session Date Time Applicant Staff NRC staff To be filled out by PM during breakout TRP 026: Fire Protection SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion 1

2.3.3.5, 2.4.17, 3.3, 3.5, Appendix A1 Section 19.2.2.15 and Table 19-3, Appendix A2 Section 19.2.2.15 and Table 19-3, Appendix B Section B.2.3.15 2.2-38, 2.4-36, 3.3-76, 3.5-142, A1-21, A1-76, A2-21, A2-77, B-121 Item 3.3-1, 255 in NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, identifies the aging effects for fire damper assemblies as loss of material due to general, pitting, crevice corrosion; cracking due to SCC; hardening, loss of strength, shrinkage due to elastomer degradation. The term fire damper assembly includes both the frame and the damper as evidenced by the aging effects requiring management as cited in GALL-SLR Item 3.3-1, 255. For example, hardening and loss of strength would not be applicable aging effects if the intent of the GALL-SLR were to only manage aging effects associated with housings, which are typically constructed of steel materials.

The NRC staff is seeking clarification on the materials of construction of the fire damper assemblies and the applicable aging affects for the fire damper assemblies.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion The following SLRA sections and tables refer to fire damper housing instead of fire damper assembly:

Section 2.3.3.5 Table 2.4-17 Table 3.5.2-17 SLRA Table 3.3-1 refers to steel [emphasis added] fire damper assemblies.

SLRA Table 3.5.2-7 cites GALL-SLR Item 3.3-1, 255 for managing loss of material for the steel [emphasis added] fire damper housing exposed to air by the Fire Protection program.

Section 19.2.2.15 in SLRA Appendices A1 and A2 state, No visual indication of loss of material, cracking, or elastomer degradation as applicable on fire damper assemblies. In addition, Enhancement c) in Table 19-3 of SLRA Appendices A1 and A2 state, Enhance plant procedures to specify that any loss of material (e.g., general, pitting, or crevice corrosion), cracking, or elastomer degradation (e.g., hardening, loss of strength, or shrinkage) as applicable to the fire damper assembly is unacceptable. These statements also appear in Section B.2.3.15 in SLRA Appendix B and NEESL00008-REPT-051, Revision 0, St. Lucie Units 1 and 2 Subsequent License Renewal Aging Management Program Basis Document -

Fire Protection. The NRC staff notes that these statements appear to infer that materials other than steel are used for construction of the fire damper assemblies,

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion however, SLRA Table 3.5.2-7 only includes items for managing loss of material for the steel fire damper housing.

Please state the material of construction for the fire damper assemblies other than the housing, which appear to be steel, that perform their intended isolation function in the closed position and state the basis for why the aging effects cited in GALL-SLR Item 3.3-1, 255 are not applicable to portions of the fire damper assembly other than the housing.

2 3.5 3.5-71, 3.5-87, 3.5-92, 3.5-95, 3.5-99, 3.5-114, 3.5-119, 3.5-125 SLRA Table 3.5.2-1 cites a fire barrier intended function for the following components:

  • Air locks, maintenance hatch and accessories
  • Construction hatch and cover
  • Containment vessel nozzle (electrical)
  • Containment vessel nozzle (fuel transfer)
  • Containment vessel nozzle (mechanical)
  • Miscellaneous steel (missile barriers, hatch frame covers, framing for radiant energy shields, etc.)

The NRC staff is seeking clarification on programs other than the Fire Protection program managing aging effects associated with the fire barrier intended function. The staff is seeking clarification on the intended function of the airtight doors in the reactor auxiliary building. In addition, the staff is seeking clarification of the fire protection intended function for the Concrete curbs (Unit 2, 2B switchgear room) (accessible) in the turbine building.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion Concrete: columns, foundation, pedestals, roof, shield walls (accessible)

Concrete: columns, pedestals, roof, shield walls, slabs SLRA Table 3.5.2-4 cites a fire barrier intended function for the following components:

Concrete: foundation/base mat, dome, shield walls, etc.

Concrete: roof/dome, shield walls (Unit 2 only) (accessible)

SLRA Table 3.5.2-5 cites a fire barrier intended function for the following components:

Concrete: enclosure foundations, roof, walls (accessible)

Concrete: roof, slabs, walls Concrete: roof, slabs, walls (accessible)

Miscellaneous steel (i.e., missile barrier doors) (Unit 2 only)

SLRA Table 3.5.2-6 cites a fire barrier intended function for the following components:

Concrete: foundation/base mat, walls (inaccessible)

Concrete: slabs, walls, roofs Concrete: Slabs, walls, roofs, trenches (accessible)

Concrete: slabs, walls, roofs, trenches Concrete: walls, roofs (accessible)

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion SLRA Table 3.5.2-10 cites a fire barrier intended function for the following components:

Airtight doors Concrete: exterior walls, roofs (accessible)

Concrete: foundation/base mat, exterior walls (inaccessible)

Concrete: roofs, slabs, walls Concrete: roofs, slabs, walls (accessible)

Miscellaneous steel (i.e., radiation shielding, missile barriers, hatch frame covers, etc.)

Reinforced concrete masonry block walls (see Breakout Question 5 regarding AMR item)

Unreinforced concrete masonry block walls (see Breakout Question 5 regarding AMR item)

SLRA Table 3.5.2-11 cites a fire barrier intended function for the following components:

Concrete: foundations, slabs (accessible)

Miscellaneous steel (i.e., missile barriers, steel grating, etc.)

SLRA Table 3.5.2-13 cites a fire protection

[emphasis added] intended function for the Concrete curbs (Unit 2, 2B switchgear room)

(accessible).

However, the Fire Protection program is not credited to manage the aging affects for any of these components.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion It is unclear to the NRC staff whether the programs credited to manage the applicable aging effects are capable of ensuring the fire barrier intended function is maintained during the subsequent period of extended operation.

Specifically, it is unclear whether the inspections and acceptance criteria for the credited programs are equivalent to those in the Fire Protection program; the credited programs perform inspections on the same frequency as required by the Fire Protection program; and the credited programs procedures have been updated, if necessary, to ensure the fire barrier intended function is maintained during the subsequent period of extended operation.

The component types in SLRA Tables 2.4-1 and 3.5.2-1 differ. For example, SLRA Table 2.4-1 refers to Containment vessel nozzles while SLRA Table 3.5.2-1 refers Containment vessel nozzle (electrical),

Containment vessel nozzle (fuel transfer),

and Containment vessel nozzles (mechanical). The component types in SLRA Tables 2.4-2 and 3.5.2-2 differ. For example, SLRA Table 2.4-2 refers to Concrete: columns, foundation, pedestals, roof, shield walls while SLRA Table 3.5.2-2 refers to Concrete: columns, foundation, pedestals, roof, shield walls (accessible).

The component types in SLRA Tables 2.4-4 and 3.5.2-4 differ. For example, SLRA Table 2.4-4 refers to Concrete: roof/dome, shield walls (Unit 2 only) while SLRA Table 3.5.2-4 refers to Concrete: roof/dome, shield walls (Unit 2 only) (accessible). The component

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion types in SLRA Tables 2.4-5 and 3.5.2-5 differ. For example, SLRA Table 2.4-5 refers to Concrete: roof, slabs, walls while SLRA Table 3.5.2-5 refers to both Concrete: roof, slabs, walls and Concrete: roof, slabs, walls (accessible). The component types in SLRA Tables 2.4-6 and 3.5.2-6 differ. For example, SLRA Table 2.4-6 refers to Concrete: walls, roofs while SLRA Table 3.5.2-6 refers to Concrete: roof, slabs, walls and Concrete:

walls, roofs (accessible). SLRA Table 2.4-10 does not cite a fire barrier intended function for airtight doors, however, SLRA Table 3.5.2-6 does. The component types in SLRA Tables 2.4-10 and 3.5.2-10 differ. For example, SLRA Table 2.4-10 refers to Concrete: exterior walls, roofs while SLRA Table 3.5.2-10 refers to Concrete: exterior walls, roofs (accessible).

The component types in SLRA Tables 2.4-11 and 3.5.2-11 differ. For example, SLRA Table 2.4-11 refers to Concrete: foundations, slabs while SLRA Table 3.5.2-10 refers to Concrete: foundations, slabs (accessible).

The component type in SLRA Tables 2.4-13 and 3.5.2-13 differ. For example, SLRA Table 2.4-13 refers to Concrete curbs (Unit 2, 2B switchgear room) while SLRA Table 3.5.2-13 refers to Concrete curbs (Unit 2, 2B switchgear room) (accessible).

SLRA Table 2.1-1 includes fire barrier and fire prevention intended functions.

However, SLRA Tables 2.4-13 and 3.5.2-13 cite a fire protection intended function for the Concrete curbs (Unit 2, 2B switchgear room) (accessible).

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion 3

2.3.3.5, 2.3.3.12, 3.3 2.3-37, 2.3-56, 3.3-222 SLRA Section 2.4.17 states, Fire dampers are evaluated with Ventilation in Subsection 2.3.3.15. The NRC staff notes that Ventilation is in SLRA Section 2.3.3.12, not 2.3.3.15. Fire dampers do not appear to be addressed in SLRA Section 2.3.3.12. In addition, SLRA Tables 2.3.3-12 and 3.3.2-12 do not include fire dampers or any component types with a fire barrier intended function.

Please discuss the statement in SLRA Section 2.4.17 regarding fire dampers being evaluated with Ventilation.

The NRC staff is seeking clarification on the statement in SLRA Section 2.4.17 regarding fire dampers being evaluated with Ventilation.

4 2.4, 3.3, 3.5, Sections 19.2.2.32 of SLRA Appendices A1 and A2, Section B.2.3.32 of SLRA Appendix B 2.4-23, 3.3-59, 3.5-116, A1-34, A2-34, B-244 As stated in Breakout Question 3, SLRA Tables 2.4-10 and 3.5.2-10 include reinforced and unreinforced concrete masonry block walls with a fire barrier intended function.

These appear to be the only masonry walls with a fire barrier intended function identified in the SLRA. SLRA Table 3.5.2-10 cites GALL-SLR Item 3.5-1, 070 for only managing cracking of the reinforced and unreinforced concrete masonry block walls exposed to uncontrolled indoor air by the Masonry Walls program.

The NRC staff notes that GALL-SLR Item 3.3-1, 179 manages cracking and loss of material [emphasis added] of structural masonry fire barrier walls exposed to air by the Fire Protection and Masonry Walls programs. In addition, the staff notes that GALL-SLR Item 3.3-1, 060 manages cracking and loss of material [emphasis added] of structural reinforced concrete fire barrier walls, ceilings, and floors exposed to air by The NRC staff is seeking clarification on masonry fire barrier walls, including where they are located, the applicable aging effects, and the programs managing the applicable aging effects.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion the Fire Protection and Structures Monitoring programs.

SLRA Table 3.3-1 states that GALL-SLR Item 3.3-1, 179 is not used and that GALL-SLR Items 3.3-1, 267, 3.3-1, 268, and 3.3-1, 269 are used for fire barriers exposed to air. The NRC staff notes that these items are for subliming compounds, cementitious coatings, and silicates used as fireproofing/fire barriers, not structural masonry fire barrier walls.

SLRA Table 3.3-1 also states that GALL-SLR Item 3.3-1, 060 is not used and that GALL-SLR Item 3.5-1, 067 is used for reinforced concrete structural fire barriers. However, as noted above, SLRA Table 3.5.2-10 cites GALL-SLR Item 3.5-1, 070 for only managing cracking of the reinforced concrete masonry block walls.

The NRC staff notes that Section 19.2.2.32 of SLRA Appendices A1 and A2 and Section B.2.3.32 of SLRA Appendix B state, Masonry walls that are fire barriers are also managed by the PSL Fire Protection AMP

[aging management program]. However, the Fire Protection program is not cited for the masonry fire barrier walls.

In addition, Section 4.1 of NEESL00008-REPT-051 states that masonry fire walls are inspected for cracking and loss of material

[emphasis added].

Please discuss the following:

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion

  • Are the only masonry walls with a fire barrier intended function those identified in SLRA Tables 2.4-10 and 3.5.2-10?
  • Why loss of material was not cited as an applicable aging effect for the reinforced and unreinforced concrete masonry block walls with a fire barrier intended function.
  • Which AMR item will be cited to manage the applicable aging effects for masonry fire barrier walls?

5 3.3 3.3-159 SLRA Table 3.3.2-15 cites GALL-SLR Items 3.3-1, 058 and 3.3-1, 121 for managing aging effects for the carbon steel Tank (Unit 1 cable spreading from halon tank). However, these items are for steel piping and piping components. Industry standard note A is cited which is Consistent with component

[emphasis added], material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP is consistent with NUREG-2191 AMP description.

Please discuss the use of industry standard note A.

The NRC staff is seeking clarification on the use of industry standard note A for the carbon steel Tank (Unit 1 cable spreading from halon tank).

6 3.5.2.1.17 3.5-17, 3.5-142 SLRA Section 3.5.2.1.17 refers to fire retardant coatings. In addition, SLRA Table 3.5.2-17 refers to fire retardant coating conduit plugs and cable tray penetration seals.

Please discuss the types of fire retardant coatings used at St. Lucie and confirm they are adequately covered in the SLRA, i.e.,

material, aging effects, managing program.

The NRC staff is seeking clarification of the fire retardant coatings used at St. Lucie 7

3.5 3.5-70, 3.5-144 GALL-SLR Item 3.5-1, 100 manages cracking and loss of material [emphasis added] of aluminum and stainless steel support The NRC staff is seeking why SLRA Table 3.5-1 cites the ASME Section XI, Subsection

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion members, welds, bolted connections, and support anchorage to building structure exposed to air and condensation by either the One-Time Inspection, Structures Monitoring, or External Surfaces Monitoring of Mechanical Components programs.

For GALL-SLR Item 3.5-1, 100, SLRA Table 3.5-1 cites either the One-time Inspection, ASME Section XI, Subsection IWF [emphasis added], or External Surfaces Monitoring of Mechanical Components programs. In addition, SLRA Table 3.5-1 states, for GALL-SLR Item 3.5-1, 100, that The Fire Protection (B.2.3.16) AMP is credited with managing loss of material [emphasis added]

in stainless steel fire barrier penetrations and radiant energy shields.

SLRA Table 3.5.2-17 cites the Fire Protection program for managing cracking and loss of material [emphasis added] for aluminum and stainless steel penetration seals and stainless steel miscellaneous barriers and radiant energy shields.

Please discuss why SLRA Table 3.5-1 cites the ASME Section XI, Subsection IWF program and why it does not discuss that the Fire Protection AMP is credited with managing both cracking and loss of material of aluminum and stainless steel fire barrier penetrations and stainless steel radiant energy shields.

IWF program and why it does not discuss that the Fire Protection AMP is credited with managing both cracking and loss of material of aluminum and stainless steel fire barrier penetrations and stainless steel radiant energy shields.

8 3.5 3.5-142 SLRA Table 3.5.2-17 cites GALL-SLR Item 3.3-1, 057 for managing aging effects for the silicone foam conduit plugs. However, this item is for elastomer fire barrier penetration The NRC staff is seeking clarification on the use of industry standard note B for the silicone foam conduit plugs.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion seals. Industry standard note B is cited which is Consistent with component

[emphasis added], material, environment, aging effect, and AMP listed for NUREG-2191 line item. AMP has exceptions to NUREG-2191 AMP description.

Please discuss the use of industry standard note B.

9 Table 19-3 in Appendices A1 and A2, Section B2.3.15 in Appendix B A1-76, A2-77, B-121 SLR-ISG-2021-02-Mechanical, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20181A434) added GALL-SLR Items 3.3-1, 267, 268, and 269. The aging effects for subliming compounds, cementitious coatings, and silicates used as fireproofing/fire barriers exposed to air are loss of material, change in material properties, cracking/delamination, and separation [emphasis added].

These aging effects are consistent with Section 6, Fire Barriers, of EPRI 3002013084, Long-Term Operations: Subsequent License Renewal Aging Affects for Structures and Structural Components (Structural Tools), November 2018.

The NRC staff notes that SLRA Table 3.5.2-17 cites separation as an applicable aging effect for components where GALL-SLR Items 3.3-1, 267, 268, and 269 are cited.

The NRC staff is seeking clarification on why the enhancement to the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements do not include separation as an applicable aging effect.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion Table 19-3 in SLRA Appendices A1 and A2, and Section B2.3.15 in SLRA Appendix B include the following enhancement to the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements:

Enhance plant procedures to specify that subliming, cementitious, and silicate materials used in fireproofing and fire barriers will be inspected for loss of material, change in material properties, and cracking/delamination.

The enhancement does not include separation.

The NRC staff notes there are inconsistencies in NEESL0008-REPT-051.

Sections 4.1, 4.4, and 4.6 discuss enhancing procedures to inspect subliming compounds, cementitious coatings, and silicates for separation (please note that these sections do not refer to separation consistently).

However, Sections 4.3, 4.5, 6.0, and 7.0 do not.

Given that EPRI 3002013084 cites separation as an aging effect for subliming compounds, cementitious coatings, and silicates used as fireproofing/fire barriers and SLRA Table 3.5.2-17 cites separation as an applicable aging effect, please discuss why the Fire Protection program enhancement does not include separation.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion 10 Section 19.2.2.16 in Appendices A1 and A2, Section B2.3.15 in Appendix B A1-21, A2-22, B-121 The corrective actions program element in GALL-SLR AMP XI.M26 states, During the inspection of penetration seals, if any sign of degradation is detected within that sample, the scope of the inspection is expanded to include additional seals in accordance with the plants approved fire protection program.

Section 19.2.2.16 in SLRA Appendices A1 and A2, and Section B2.3.15 in SLRA Appendix B state, During the inspection of penetration seals, if any sign of abnormal degradation [emphasis added] is detected within the sample, the inspection sample size is expanded, in accordance with the approved PSL fire protection program, to include an additional 10 percent of each type of sealed penetration.

The NRC staff notes that Sections 4.5, 4.6, and 4.7 of NEESL0008-REPT-051 refer to abnormal degradation.

Given that GALL-SLR AMP XI.M26 states any sign of degradation, please discuss what is meant by abnormal degradation.

The NRC staff is seeking clarification on what is mean by abnormal degradation.

11 2.4.17 2.4-34 SLRA Section 2.4.17 states, Penetration seals are provided to maintain the integrity of fire barriers at barrier penetrations. The types of materials used for the various penetrations range from silicone gels

[emphasis added] for piping and heating, ventilation, and air conditioning (HVAC) penetrations to grouts [emphasis added] for conduit and plumbing.

The NRC staff is seeking clarification on silicone gels and grout.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion SLRA Table 3.5.2-17 does not appear to include AMR items for managing applicable aging effects for silicone gels or grouts.

The NRC staff notes that 1-FPSP-15.01 and 2-FPSP-15.01 states that the application of grout or concrete shall be considered an extension of the fire barrier floor, wall, or ceiling and not a unique fire barrier penetration. However, it is unclear from the SLRA that the AMR items for fire barrier floors, walls, ceilings include applied grout or concrete penetration seals.

Please discuss where silicone gels are addressed. In addition, discuss whether a clarification regarding the treatment of grout should be added to the SLRA.

12 2.4.17, 3.5 2.4-36, 3.5-142 SLRA Table 2.4-17 include fire doors -

watertight with a fire barrier and flood barrier intended function. SLRA Table 3.5.2-17 cites GALL-SLR item 3.3-1, 059 for managing loss of material of the steel watertight fire doors by the Fire Protection program.

Please discuss how the Fire Protection program will adequately manage the flood barrier intended function. In addition to loss of material, are there other aging effects related to the flood barrier intended function?

The NRC staff is seeking clarification on the Fire Protection program managing the flood barrier intended function.

13 N/A N/A Section 3.3 of NEESL0008-REPT-051 states that periodic visual inspection of the external surfaces of the halon fire suppression system will be performed every 18 months.

However, Section 4.4 of NEESL0008-REPT-051 states that visual inspections are performed at last once per 90 days and periodic functional testing and air flow testing The NRC staff is seeking clarification on the frequency of the visual inspection and functional test of the halon fire suppression system.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion is performed every 18 months. These frequencies are consistent with what are in Revision 18 of ADM-19.00, Fire Protection Plan.

Please confirm the NRC staffs understanding that the halon fire suppression system is visually inspected every 90 days and functionally tested every 18 months.

14 N/A N/A Section 6.1 of EPRI 3002013084, Long-Term Operations: Subsequent License Renewal Aging Effects for Structures and Structural Components (Structural Tools),

November 2018, states, in part, wire and other appurtenances used to secure fire wrap to the item being protected - is considered to be part of the fire wrap itself.

Please discuss whether materials are used to secure fire wraps. If so, please discuss where they are addressed in the SLRA, including AMR items for managing applicable aging effects.

The NRC staff is seeking clarification on materials used for securing fire wraps.

15 N/A N/A The Fire Protection Program Owner Interview states, Fire penetration seals (or barriers) are currently not part of the program.

However, it appears that the current program does include fire penetration seals and fire barriers. Therefore, the statement in the interview is confusing.

The NRC staff is seeking clarification of the statement regarding fire penetration seals and fire barriers in the Fire Protection Program Owner Interview.

16 N/A N/A Section 4.6 of NEESL00008-REPT-051 includes acceptance criteria for elastomer materials, subliming materials, and silicate materials of age-related degradation no longer than 12 inches or wider than 1/32 inch. This section references procedures 1-FPSP-15.01 and 2-FPSP-15.01. However, these documents do not appear to include The NRC staff is seeking clarification on the basis for the length and width limits for elastomer, subliming, and silicate materials.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion the basis or the reference containing the basis for the length and width limits.

Please discuss the basis for the length and width limits for elastomer, subliming, and silicate materials.

17 N/A N/A Section 4.1 of procedures 1-FMM-99.12, Revision 5, and 2-FMM-99.12, Revision 6, state, as a corrective action, to install steel screws in holes identified on doors or frames.

Procedure 1-FMM-99.12 also states installing steel screws if the holes are for purposes other than for installation of cushioning devices.

The acceptance criteria program element in GALL-SLR AMP XI.26 states no visual indications of holes. Both procedures include a NOTE in Section 4.1 that states, Doors and frames must be free of holes.

Please discuss whether there are limitations on the use of this corrective action (e.g., the type of hole). In addition, provide the basis for when this corrective action is performed that the door maintains its required hourly fire rating.

The NRC staff is seeking clarification on the corrective action of installing steel screws in holes on doors and frames.

18 Section 19.2.2.15 in Appendix A2 A2-21 Section 19.2.2.15 in SLRA Appendix A2 states, The PSL Fire Protection AMP includes periodic inspection and testing of the halon fire suppression systems.

Given that Unit 2 does not include a halon fire suppression system, please discuss the inclusion of this statement in the Unit 2 Updated Final Safety Analysis Report (UFSAR) supplement.

The NRC staff is seeking clarification on the discussion of halon fire suppression systems in the Unit 2 UFSAR supplement.

SLRA Section SLRA Page Question / Issue Why are we asking?

Outcome of Discussion 19 3.5 3.5-17, 3.5-142 SLRA Section 3.5.2.1.17 and SLRA Table 3.5.2-17 include several materials used as fireproofing/fire barriers. However, procedures 1-FPSP-15.01 and 2-FPSP-15.01 appear to identify materials that may not be included in the SLRA. For example, Flamemastic, marinite board covered in Flamemastic, silicone impregnated boot material, etc.

Please discuss whether additional materials used as fireproofing/fire barriers discussed in the procedures should be added to SLRA Section 3.5.2.1.17 and SLRA Table 3.5.2-17.

The NRC staff is seeking clarification on whether additional materials used as fireproofing/fire barriers discussed in the procedures should be added to SLRA Section 3.5.2.1.17 and SLRA Table 3.5.2-17.

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