View source for DCL-13-065, Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, (Volume 1 of 2)

{{Adams
| number = ML13196A264
| issue date = 06/26/2013
| title = Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, (Volume 1 of 2)
| author name = 
| author affiliation = Pacific Gas &amp; Electric Co
| addressee name = 
| addressee affiliation = NRC/NRR
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person = 
| case reference number = DCL-13-065, LAR 13-03, NFPA 805
| document type = Report, Technical
| page count = 989
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Attachments C, D, G, and W Contain Security-Related Information -Withhold Under 10 CFR 2.390 Pacific Gas and Electric Company Diablo Canyon Power Plant Units 1 and 2 Docket 50-275 and 50-323 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Pacific Gas and Electric Company" Transition Report June 2013 (VOLUME I OF 2)
Attachments C, D, G, and W Contain Security-Related Information - Withhold Under 10 CFR 2.390 When separated from those attachments, this document is decontrolled.

Attachments C, D, G, and W Contain Security-Related Information - Withhold Under 10 CFR 2.390 Pacific Gas and Electric Company Diablo Canyon Power Plant Units 1 and 2 Docket 50-275 and 50-323 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
* Pacific Gas and Electric Company' Transition Report June 2013 Attachments C, D, G, and W Contain Security-Related Information - Withhold Under 10 CFR 2.390 When separated from those attachments, this document is decontrolled.

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                                                                                                                                  **4,~tt,       ~MS Ut Table of Contents Executive Sum m ary ..................................................................................................                                 iv Acronym List ................................................................................................................                          vi 1.0       Introduction .........................................................................................................                        1 1 .1           B a c kg ro u n d ...........................................................................................................        1 1.1.1     NFPA 805 - Requirements and Guidance ................................................                                      1 1.1.2     Transition to 10 CFR 50.48(c) .............................................................                                2 1.2            Purpose ........................................................................................................                     3 2.0       OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM .........................                                                                        4 2.1            Current Fire Protection Licensing Basis ...........................................................                                  4 2.2            NRC Acceptance of the Fire Protection Licensing Basis ..................................                                             4 3.0       TRANSITION PROCESS ......................................................................................                                     9 3 .1           B a c kg ro u n d ...........................................................................................................        9 3.2            NFPA 805 Process ............................................................................................                        9 3.3            NEI 04-02 NFPA 805 Transition Process .......................................................                                      11 3.4            NFPA 805 Frequently Asked Questions (FAQs) .............................................                                           12 4.0       COMPLIANCE WITH NFPA 805 REQUIREMENTS ......................................                                                                13 4.1            Fundamental Fire Protection Program and Design Elements .........................                                                  13 4.1.1     Overview of Evaluation Process .........................................................                                 13 4.1.2      Results of the Evaluation Process .......................................................                               15 4.1.3      Definition of Power Block and Plant .....................................................                               16 4.2            Nuclear Safety Performance Criteria ..............................................................                                 16 4.2.1      Nuclear Safety Capability Assessment Methodology ..........................                                             16 4.2.2      Existing Engineering Equivalency Evaluation Transition ....................                                             22 4.2.3      Licensing Action Transition ................................................................                            23 4.2.4      Fire Area Transition ............................................................................                       27 4.3            Non-Power Operational Modes .......................................................................                                30 4.3.1      Overview of Evaluation Process .........................................................                                30 4.3.2      Results of the Evaluation Process .......................................................                               33 4.4            Radioactive Release Performance Criteria ....................................................                                      34 4.4.1      Overview of Evaluation Process .........................................................                                34 4.4.2      Results of the Evaluation Process .......................................................                               34 4.5            Fire PRA and Performance-Based Approaches ......................                                                                   35 4.5.1      Fire PRA Development and Assessment ...........................................                                         35 Page i

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nn L~2 KICDA      nnIZ   Trnn&H-i^n 0&#xfd; ^.4 Mn4~n-rg Table of Contents (Continued) 4.5.2       Performance-Based Approaches .......................................................                                           42 4.6            Monitoring Program .......................................................................................                                 46 4.6.1       Overview of NFPA 805 Requirements and NEI 04-02 Guidance on the NFPA 805 Fire Protection System and Feature Monitoring P rog ra m ............................................................................................                   . . 46 4.6.2       Overview of Post-transition NFPA 805 Monitoring Program ................ 47 4.7            Program Documentation, Configuration Control, and Quality Assurance .....                                                                  52 4.7.1       Compliance with Documentation Requirements in Section 2.7.1 of NF P A 8 0 5 ..........................................................................................                    . . 52 4.7.2       Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 ..............................................................                                     55 4.7.3       Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 ............................................................................................                          59 4.8            Summary of Results .......................................................................................                                 61 4.8.1       Results of the Fire Area Review .........................................................                                      61 4.8.2       Plant Modifications and Items to be Completed During the Implementation Phase .......................................................................                                   62 4.8.3       Supplemental Information - Other Licensee Specific Issues ............. 64

==5.0         REGULATORY EVALUATION==
 ........................................................................                                                      124 5.1            Introduction - 10 CFR 50.48 .............................................................................                                 124 5.2            Regulatory Topics .............................................................................................                           128 5.2.1       License Condition Changes ...................................................................                                 128 5.2.2       Technical Specifications ............................................................                           :........... 128 5.2.3       Orders and Exemptions .........................................................................                               128 5.3            Regulatory Evaluations .....................................................................................                              128 5.3.1       No Significant Hazards Consideration ...................................................                                      128 5.3.2       Environmental Consideration .................................................................                                 129 5.4            Revision to the UFSAR .....................................................................................                               129 5.5            Transition Implementation Schedule .................................................................                                      129

==6.0          REFERENCES==
 .................................................................................................                                       130 ATTACHMENTS .........................................................................................................                                           135 A,        NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design E le m e n ts .......................................................................................................................               A-1 B,        NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review ........                                                                   B-1 C.        NEI 04-02 Table B-3 Fire Area Transition ...................................................................                                           C-1 D.        NEI 04-02 Non Power Operational Modes Transition ..................................................                                                    D-1 E.        NEI 04-02 Radioactive Release Transition ..................................................................                                            E-1 Page ii

Pacific Gas and Electric Company                                                                             NFPA 805 Transition Report Table of Contents (Continued)
F. Fire-Induced Multiple Spurious Operations Resolution ................................................                                F-1 G. Recovery Actions Transition .......................................................................................                 G-1 H. NFPA 805 Frequently Asked Question Summary Table ..............................................                                     H-1 I. D efinition of P ower Block ............................................................................................         . . I-1 J. Fire Modeling V &V .....................................................................................................        . . J-1 K. Existing Licensing Action Transition ............................................................................                   K-1 L. NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) ................ L-1 M. License C ondition C hanges .........................................................................................               M-1 N. Technical Specification Changes ................................................................................                    N-1
: 0. O rde rs and E xem ptions ...................................................................................................       0 -1 P. RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) ..................................................                                P-1 Q. No Significant Hazards Evaluations ............................................................................                     Q-1 R. Environmental Considerations Evaluation ..................................................................                          R-1 S. Modifications and Implementation Items .....................................................................                        S-1 T. Clarification of Prior NRC Approvals ............................................................................                   T-1 U. Internal Events, Internal Floods and Seismic PRA Quality .........................................                                  U-1 V. F ire P R A Q uality .......................................................................................................   . . V -1 W. Fire P R A Insights .....................................................................................................     . . W-1 Page iii

I:::Yi*r i Itlvi* .*i im m*irv Pac~ific~ Ga  andI Electric~ Conman%,                                          ;:Yadm **iv       Ru Im2r Executive Summary Pacific Gas and Electric (PG&E) Company will transition the Diablo Canyon Power Plant (DCPP) fire protection (FP) program to a new Risk-Informed, Performance-Based (RI-PB) alternative per 10 CFR 50.48(c) which incorporates by reference NFPA 805. The existing fire protection licensing basis will be superseded.
PG&E submitted Letter DCL-05-0153, "Letter of Intent to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition,"
to the Nuclear Regulatory Commission (NRC) on December 29, 2005 for DCPP to adopt NFPA 805, Performance-BasedStandardfor Fire Protection for Light Water ReactorElectric Generating Plants,2001 Edition, in accordance with 10 CFR 50.48(c), and to request a three year enforcement discretion window. The transition to the performance-based standard began in January 2006.
By letter dated March 1, 2006, the NRC acknowledged receipt of the letter of intent and granted PG&E a two year enforcement discretion period. The NRC granted PG&E a third year of enforcement discretion by letter dated April 29, 2007.
By PG&E Letter DCL-08-088, "Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) (NFPA 805) License Amendment Request," dated October 15, 2008, and in accordance with Federal Register Notice 73 FR 52705, PG&E requested that enforcement discretion be extended for DCPP until six months after the safety evaluation (SE) was issued for the second pilot plant.
By letter dated December 19, 2008, the NRC staff reviewed PG&E's request, and determined that PG&E had made substantial enough progress in its transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period was extended until six months after the date of the SE approving the second pilot plant license amendment request (LAR).
In accordance with SECY-1 1-0061, PG&E Letter DCL-1 1-076, "Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request," dated June 24, 2011, requested that the period of enforcement discretion be extended to June 28, 2013. By letter dated July 28, 2011, the NRC approved the enforcement discretion extension request.
The transition process consisted of a review and update of DCPP documentation, including the development of a Fire Probabilistic Risk Assessment (FPRA) using NUREG/CR-6850 as guidance. This Transition Report (TR) summarizes the transition process and results. This TR contains information:
     "    Required by 10 CFR 50.48(c).
* Recommended by guidance document Nuclear Energy Institute (NEI) 04-02 Revision 2 and appropriate Frequently Asked Questions (FAQs).
     "    Recommended by guidance document Regulatory Guide 1.205 Revision 1.
Section 4 of the TR provides a summary of compliance with the following NFPA 805 requirements:
     "    Fundamental Fire Protection Program Elements and Minimum Design Requirements
* Nuclear Safety Performance Criteria (NSPC), including:
* Existing Engineering Equivalency Evaluation (EEEE) Review Page iv

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* Licensing Action Transition
* Fire Area Transition
* Non-Power Operational (NPO) Modes
* Fire Risk Evaluations (FRE)
    "   Radioactive Release Performance Criteria
* Monitoring Program
* Program Documentation, Configuration Control, and Quality Assurance Section 5 of the TR provides regulatory evaluations. Associated attachments to the TR include:
* Changes to License Condition,
* Changes to Technical Specifications, Orders, and Deviations,
* Determination of No Significant Hazards and evaluation of Environmental Considerations.
The attachments to the TR include details to support the transition process and results.
Attachment H contains the approved FAQs not yet incorporated into the endorsed revision of NEI 04-02, Revision 2. These FAQs have been used to clarify the guidance in RG 1.205, Revision 1, NEI 04-02, Revision 2, and the requirements of NFPA 805 and in the preparation of this LAR.
Page v

D~L:ir anti P-dfic Gas         Elad-frie- COM   2n                                                Aorr~nnm I ia+L Z~                                                         a LnF~4i~(nn~uAr~u Acronym List AB                      Auxiliary Building ABB                     ASEA Brown Boveri ABS                     ABS Consulting Inc.
AC                      Alternating Current ACP                     Analysis Change Process ADAMS                   Agency wide Document Access and Management System ADS                     Atmospheric Depressurization System AFW                      Auxiliary Feedwater AFWS                    Auxiliary Feedwater System AHJ                     Authority Having Jurisdiction ANI / MAERP             American Nuclear Insurers / Mutual Atomic Energy Reinsurance Pool ANS                     American Nuclear Society ANSI                    American National Standards Institute AOV                     Air Operated Valve APCSB                   Auxiliary and Power Conversion Systems Branch AR                      Action Report ASD                      Alternative Shutdown ASDV                    Atmospheric Steam Dump Valve ASME                    American Society of Mechanical Engineers ASTM                    American Society for Testing and Materials ASW                     Auxiliary Saltwater ATWS                    Anticipated Transient without Scram ATWT                    Anticipated Transient without Trip AV                      Available AWP                     Administrative Work Procedure BAST                     Boric Acid Storage Tank BTP                      Branch Technical Position BWR                      Boiling Water Reactor BWROG                    Boiling Water Reactor Owner's Group Cal Fire                 California Department of Forestry and Fire CAROLFIRE                Cable Response to Live Fire (fire testing program)
CC                       Capability Category CCDP                     Conditional Core Damage Probability CCF                      Common Cause Failure CCP                      Centrifugal Charging Pump CCW                      Component Cooling Water CDF                      Core Damage Frequency CF                       Circuit Failure CET                      Containment Event Tree CFAST                    Consolidated Model of Fire Growth and Smoke Transport CFC                      Containment Fan Cooler CFCU                     Containment Fan Cooler Unit CFR                      Code of Federal Regulations CI                       Configuration Identification CKT                      Circuit CLB                      Current Licensing Basis CLERP                    Conditional Large Early Release Probability CNT                      Containment Page vi

Acrnnvm List Acronym List (Continued)
C02    Carbon Dioxide CONT   Loss of Control CP     Casualty Procedure CR     Control Room/Contractor Report CRDM   Control Rod Drive Mechanism CRVS   Control Room Ventilation System CS     Containment Spray CSD    Cold Shutdown CSD-S  Cold Shutdown - Spurious Concern CSIP   Charging/Safety Injection pump CSR    Cable Spreading Room CST    Condensate Storage Tank CT     Current Transformer, also Completion Time CTE    Completion Time Extension CVCS   Chemical and Volume Control System CVI    Containment Ventilation Isolation CWP    Circulating Water Pump DAW    Dry Active Waste DBA    Design Basis Accident DBD    Design Basis Documents DC     Direct Current DCFD   Diablo Canyon Fire Department DCM    Design Criteria Memorandum DCN    Design Change Notice DCPP   Diablo Canyon Power Plant DCPRA  Diablo Canyon Probabilistic Risk Assessment DG     Diesel Generator DH     Decay Heat DHR    Decay Heat Removal DID    Defense-in-Depth DID-RA Defense-in-Depth Recovery Action DO     Desired Open DSDP   Dedicated Shutdown Panel EC     Engineering Change ECCS   Emergency Core Cooling System ECG    Equipment Control Guideline EDF    DCPP Fire Protection Engineering Group (SAP Work Center Code)
EDG    Emergency Diesel Generator EEEE   Existing Engineering Equivalency Evaluation (also known as FHARE)
EMRV   Electro-Mechanical Relief Valve EMT    Electrical Metallic Tubing EOP    Emergency Operating Procedure EP     Emergency Power EPM    Engineering Planning and Management, Inc.
EPRI   Electric Power Research Institute EQ     Environmental Qualification ERFBS  Electrical Raceway Fire Barrier System ERO    Emergency Response Organization Page vii

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and Electric~ (Cmnanv                                                     A~ov Pac~ific~Ga Acronym List (Continued)
ES                  Equipment Selection ESF                 Engineered Safety Feature ESFAS               Engineered Safety Features Actuation System F&Os                Facts and Observations FACP                Fire Alarm Control Panel FAQ                 Frequently Asked Question FCV                 Flow Control Valve FDS                 Fire Dynamics Simulator FDT                 Fire Dynamics Tool FHA                 Fire Hazard Analysis FHARE               Fire Hazards Appendix R Evaluation (also known as EEEE)
FHB                 Fuel Handling Building FHBVS               Fuel Handling Building Ventilation System FIREPROT            DCPP Drawing 065126, Unit 1 Electrical Fire Protection Information and 065127, Unit 2 Electrical Fire Protection Information FIVE                Fire Induced Vulnerability Evaluation FMWB                Fire Modeling Work Book FP                  Fire Protection FPP                 Fire Protection Program FPRA                Fire Probabilistic Risk Assessment FQ                  Fire Risk Quantification FR                  Federal Register FRE                 Fire Risk Evaluation FSA                 Fire Safety Analysis FSS                 Fire Scenario Selection FW                  Fire Water FWS                 Fire Water System FWST                Feedwater Storage Tank GDC                 General Design Criterion/Criteria GE                  U1 & U2 Penetration Bldg East of Gridline N/General Electric GET                 General Employee Training GL                  Generic Letter GPM                 Gallons per Minute GW                  U1 & U2 Penetration Bldg West of Gridline N HCV                 Hand Control Valve HDPE                High Density Polyethylene HEAF                High Energy Arcing Fault HELB                High Energy Line Break HEP                 Human Error Probability HEPA                High Efficiency Particulate Air HFE                 Human Factors Engineering HGL                 Hot Gas Layer HRA                Human Reliability Analysis HRC                Hazard Risk Category HRE                Higher Risk Evolution HRR                Heat Release Rate HS                 Hot Short HSB                Hot Standby Page viii

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Acronym List (Continued)
HSB-S                 Hot Standby - Spurious Concern HSD                   Hot Shutdown HSDP                  Hot Shutdown Panel HSS                   High Safety Significance HVAC                  Heating, Ventilation, and Air Conditioning HX                    Heat Exchanger IA                    Instrument Air lAW                   In Accordance With IC                    Incident Commander ID                    Identification / Identify IEEE                  Institute of Electrical and Electronic Engineers lEFT                  Internal Events Fault Tree IGN                   Ignition Frequency IMC                   Inspection Manual Chapter IN                    Information Notice IND                   Loss of Indication INPO                  Institute of Nuclear Power Operations IPE                   Independent Plant Evaluation iS                    Intake Structure ISLOCA                Interfacing System Loss of Coolant Accident KSF                   Key Safety Function Kv                    kilovolt LAR                   License Amendment Request LBLOCA                Large Break Loss of Coolant Accident LCO                   Limiting Condition of Operation LCV                   Level Control Valve LERF                  Large Early Release Frequency LFS                   Limiting Fire Scenario LHUT                  Liquid Holdup Tanks LOCA                  Loss of Coolant Accident LOP                   Loss of Power LOSP                  Loss of Station Power LRS                   Liquid Radwaste System LSS                   Low Safety Significance LT                    Level Transmitter LTCW                  Long Term Cooling Water LTSP                   Long Term Seismic Program / Limiting Trip Setpoint MAAP                  Modular Accident Analysis Program MCB                    Main Control Board MCC                    Motor Control Center MCR                    Main Control Room MDAFW                 Motor Driven Auxiliary Feedwater MEFS                  Maximum Expected Fire Scenario MELB                  Moderate Energy Line Break MFW                   Main Feedwater MHIF                  Multiple High Impedance Fault ML                    Main Library (e.g. Adams Accession number)
MLOCA                 Medium Loss of Coolant Accident Page ix

Ar~rnnvm IList it Pacifir r.-qs and Electric Com-nu                                                  Acronvm Acronym List (Continued)
MMI                 Man-Machine Interface MOU                Memorandum of Understanding MOV                Motor Operated Valve MOW                Maintenance Outage Window MP                 Maintenance Procedure MQH                McCaffrey, Quintiere, and Harkleroad MS                 Main Steam MSIV               Main Steam Isolation Valve MSO                Multiple Spurious Operation MSLB               Main Steam Link Break MSPI               Mitigating Systems Performance Indicator MTC                Moderate Temperature Coefficient MU                 Make Up MWS                Makeup Water System N/A                Not applicable NA                 No Affect (in context of cable failure consequence)
NBSIR              National Bureau of Standards Information Report NEC                National Electric Code NEI                Nuclear Energy Institute NEIL               Nuclear Electric Insurers Limited NEMA               National Electrical Manufacturers Association NFPA               National Fire Protection Association NIST               National Institute of Standards and Technology NO                 Nuclear Operator NPG                Nuclear Power Group NPO                Non-Power Operation or Non-Power Operational NRC, USNRC         United States Nuclear Regulatory Commission.
NSCA               Nuclear Safety Capability Assessment NSEL               Nuclear Safety Equipment List NSPC                Nuclear Safety Performance Criteria NUMARC             Nuclear Management and Resources Council OC                 Open Circuit OCA                Owner Controlled Area OE                 Operating Experience OMA                 Operator Manual Action OOS                 Out of Service OP                 Operations, also Operating Procedure OPS                 Operations Department OS&Y                Outside Stem & Yoke OVT                 Operability Verification Testing P&ID                Piping and Instrumentation Diagram/Drawing PA                  Protected Area PB                  Performance-Based PCS                 Primary Control Station (also Process Control System)
PCT                 Peak Control Temperature
        .PCV                 Pressure Control Valve PEP                 Plant Engineering Procedure PFP                 Pre-Fire Plans Page x

Ar~rnnvm IList i~t Pacific Gas and Electric Companu                                                 Acronvrn Acronym List (Continued)
PG&E              Pacific Gas and Electric Company PIC               Process Instrumentation Cabinet PMT               Post Maintenance Test PORV              Power-Operated Relief Valve POS               Plant Operational State PP                Pump PRA               Probabilistic Risk Assessment PSA               Probabilistic Safety Assessment PSHA              Probabilistic Seismic Hazard Analysis PVC               Polyvinylchloride PWR               Pressurized Water Reactor PWROG             Pressurized Water Reactor Owner's Group QA                Quality Assurance QNS               Quantitative Screening RA                Recovery Action RAB               Reactor Auxiliary Building RAFA              Recovery Action Feasibility Assessment RAI               Request for Additional Information RAM               Radioactive Material RAW               Risk Achievement Worth RCA               Radiologically Controlled Area RCP               Reactor Coolant Pump RCS               Reactor Coolant System RCV               Radiation Control Valve RG                Regulatory Guide RHR               Residual Heat Removal RHRP              Residual Heat Removal Pump RI                 Risk-Informed RI-PB              Risk-Informed, Performance-Based RIS                Regulatory Issue Summary RISKMAN            RISKMAN PRA Software RITSTF             Risk-Informed Tech Spec Task Force RM                 Risk Management RMS                Radiation Monitoring System RP                 Radiation Protection RPM                Revolutions Per Minute RPS                Reactor Protection System RRW                Risk Reduction Worth RTB                Reactor Trip Breaker RTD                Resistance Temperature Detector RUN                Running RUNHISPEED         Run-Hi Speed (Equipment function mode)
RVRLIS             Reactor Vessel Refueling Level Indication System RWSR               Raw Water Storage Reservoir RWST               Refueling Water Storage Tank SAFE               System Assurance & Fire Protection Engineering (Software)
SBO                Station Blackout SC                 Short Circuit Page xi

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                                  =     J.                                    Acronvm List Acronym List (Continued)
SCO                   Senior Control Operator SDC                   Shutdown Cooling SDP                   Significance Determination Process SDS                   Shutdown Seal SE                    Safety Evaluation SER                   Safety Evaluation Report SF                    Seismic / Fire Interaction SFP                   Spent Fuel Pool SFPE                  Society of Fire Protection Engineers SG                    Steam Generator / Short to Ground SGTR                  Steam Generator Tube Rupture SI                    Safety Injection SLOCA                 Small Loss of Coolant Accident SM                    Shift Manager SOV                   Solenoid Operated Valve SPCC                  Spill Prevention Control and Countermeasures SPUR                  Spurious Operation SR                    Supporting Requirements SRO                   Senior Reactor Operator SRV                   Safety Relief Valve SSA                   Safe Shutdown Analysis SSC                   Systems, Structures, and Components SSD                   Safe Shutdown SSE                   Safe Shutdown Earthquake SSEL                  Safe Shutdown Equipment List SSER                 Supplemental Safety Evaluation Report SSLD                 Safe Shutdown Logic Diagram SSPS                 Solid State Protection System STD                  Standard STP                  Surveillance Test Procedure SWGR                 Switchgear TB                   Turbine Building TCOA                 Time Critical Operator Action TDAFW                Turbine Driven Auxiliary Feedwater TEDS                 Thermal Electric Design Standards T-H                  Thermal-Hydraulic TI                   Temperature Indicator TMS                  Temperature Monitoring System TR                   Transition Report (also Temperature Recorder)
TS                   Technical Specifications U1                   DCPP Unit I U2                   DCPP Unit 2 UFSAR                 Updated Final Safety Analysis Report UL                    Underwriters Laboratories UNC                   Uncertainty and Sensitivity UPS                   Uninterruptible Power Supply V&V                  Verification and Validation VAC                  Volts Alternating Current Page xii

Pw-ifid- 1--na nnel Marfrir de%    nn                                   Agrronnm I ict M   L                                                k Acronym List (Continued)
VCT                   Volume Control Tank VDC                   Volts Direct Current VDI                   Interfacing System LOCA, Discharge VEWFDS                Very Early Warning Fire Detection System VFDR                  Variance from Deterministic Requirements VSI                   Interfacing System LOCA, Suction WCAP                  Westinghouse Corporation Atomic Power WOG                   Westinghouse Owner's Group WW                    Wire to Wire YR                    Year ZOI                   Zone of Influence Page xiii

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==1.0        INTRODUCTION==

The Nuclear Regulatory Commission (NRC) has promulgated an alternative rule for fire protection requirements at nuclear power plants, 10 CFR 50.48(c), National Fire Protection Association Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, (NFPA 805) (Reference 6.2). Pacific Gas and Electric (PG&E) Company is implementing the Nuclear Energy Institute methodology NEI 04-02, "Guidance for Implementing a Risk-informed, Performance-based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2, (Reference 6.5) to transition Diablo Canyon Power Plant (DCPP) from its current fire protection licensing basis to the new requirements as outlined in NFPA 805. This report describes the transition methodology utilized and documents how DCPP complies with the new requirements.
1.1        Background 1.1.1      NFPA 805- Requirements and Guidance On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes new Risk-Informed, Performance-Based (RI-PB) fire protection (FP) requirements. Federal Regulation 10 CFR 50.48(c) incorporates by reference, with exceptions, the National Fire Protection Association's NFPA 805, 2001 Edition, as a voluntary alternative to 10 CFR 50.48 Section (b), Appendix R, and Section (f),
Decommissioning.
As stated in 10 CFR 50.48(c)(3)(i), any licensee's adoption of a RI-PB program that complies with the rule is voluntary. This rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48(b), for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48(f), plants shutdown in accordance with 10 CFR 50.82(a)(1).
NEI developed NEI 04-02 to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805. The NRC issued Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants, which endorses NEI 04-02, with exceptions, in December 2009.1 A depiction of the primary document relationships is shown in Figure 1-1:
Reference in this document to NEI 04-02 is Revision 2 and to RG 1.205 is Revision 1.
Page 1

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                                                          't NEI 04-02                                RG 1.205 a
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       .8 GUIDANCE FOR                         RI-PB FP FOR EXISTING IMPLEMENTING A RI-PS                      LIGHT-WATER NUCLEAR FP PROGRAM UNDER 10                            POWER PLANTS CFR SIOAS(c) 1*-1 Figure 1 NFPA 805 Transition - Implementation Requirements/Guidance 1.1.2      Transition to 10 CFR 50.48(c) 1.1.2.1 Start of Transition PG&E submitted a letter (DCL-05-0153) of intent to the NRC on December 29, 2005 (ML060100480) for DCPP to adopt NFPA 805 in accordance with 10 CFR 50.48(c) (Reference 6.11).
By letter dated March 1, 2006, the NRC acknowledged receipt of the letter of intent and granted PG&E a two year enforcement discretion period (Reference 6.12). The NRC granted PG&E a third year of enforcement discretion by letter dated April 29, 2007 (Reference 6.13). Therefore, the NRC considered the discretion period for DCPP, Units 1 and 2, which began on December 29, 2005, to expire on December 29, 2008.
On September 10, 2008, the NRC published in the Federal Register (73 FR 52705) a revision to its Interim Enforcement Policy regarding enforcement discretion for certain FP issues, allowing licensees the option to request an extended enforcement discretion period for submittal of a LAR ifthe licensee is pursuing transition to 10 CFR 50.48(c). This revision to the policy states that for those noncompliances that the NRC identifies during the licensee's transition process, Page 2

t .O Inmfurnlrtinn Pacif~ic Ga  andI Electric~ Comnanv1.Inrhitn this enforcement discretion policy will be in effect for up to three years from the date specified by the licensee in their letter of intent to adopt the requirements of 10 CFR 50.48(c). The enforcement discretion will continue in place, without interruption, until NRC approval of the LAR to transition to 10 CFR 50.48(c).
By letter DCL-08-088 dated October 15, 2008, and in accordance with Federal Register Notice 73 FR 52705, PG&E requested that enforcement discretion be extended for DCPP until six months after the SE is issued for the second pilot plant (Reference 6.14).
By letter dated December 19, 2008, the NRC staff reviewed PG&E's request, and determined that the licensee had made substantial enough progress in its transition to NFPA 805 to grant the additional enforcement discretion. Accordingly, the enforcement discretion period was extended until six months after the date of the SE approving the second pilot plant LAR (Reference 6.15).
In accordance with SECY-1 1-0061, "A request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," June 10, 2011 (Reference 6.10), PG&E Letter DCL-1 1-076 dated June 24, 2011, requested that the period of enforcement discretion be extended to June 28, 2013 (Reference 6.16). By letter dated July 28, 2011, the NRC approved the enforcement discretion extension request (Reference 6.17).
In accordance with NRC Enforcement Policy, the enforcement discretion period will continue, subject to submittal of an acceptable LAR, until the NRC approval of the LAR is completed.
1.1.2.2 Transition Process The DCPP NFPA 805 transition includes high level activities to:
     "   Complete safe shutdown analysis reconstitution using Nuclear Safety Capability Assessment (NSCA) guidance;
* Develop FPRAs using NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities", September 2005 (Reference 6.9), as guidance and revise Internal Events PRA to support the FPRAs; and,
     " Complete activities required to transition the pre-transition Licensing Basis to 10 CFR 50.48(c) as specified in NEI 04-02, Revision 2 and RG 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants,"
Revision 1, December 2009 (Reference 6.8).
1.2      Purpose The purpose of the Transition Report (TR) is as follows:
: 1. Describe the process implemented to transition the current FP program to comply with the additional requirements of 10 CFR 50.48(c).
: 2. Summarize the results of the transition process.
: 3. Explain the bases for conclusions that the FP program complies with 10 CFR 50.48(c) requirements.
: 4. Describe the new FP licensing basis.
: 5. Describe the configuration management processes used to manage post-transition changes to the station and the FP program, and resulting impact on the licensing basis.
Page 3

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                         .. tw- i-i, nvnl,               , f th,l     . n wr -. 1   i-    li  I   ln       ig ,n  -r.#nrlm 2.0          OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1          Current Fire Protection Licensing Basis DCPP was licensed to operate on November 2, 1984 (Unit 1) and August 26, 1985 (Unit 2).
The DCPP FP program is based on compliance with 10 CFR 50.48(a) and the following License Condition:
PG&E's DCPP Operating License Condition 2.C for Unit 1 states:
(5)         Fire Protection
: a. PG&E shall implement and maintainin effect all provisions of the approved fire protection plan as discussed in its Final Safety Analysis Report Update, in PG&E's December 6, 1984, Appendix R Report, and in the NRC staff's Fire ProtectionEvaluation in Supplements 8, 9, 13, 23, and 27 to the Diablo Canyon Safety Evaluation Report, subject to provision b below.
: b. PG&E may make changes to the approved fire protection program without priorapproval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
: c. Deleted.
PG&E's DCPP Operating License Condition 2.C for Unit 2 states:
(4)         Fire Protection (SSER 31, Section 9.6.1 and SSER 32, Section 10)
: a. PG&E shall implement and maintainin effect all provisions of the approved fire protection program as discussed in its Final Safety Analysis Report Update, in PG&E's December 6, 1984, Appendix R Report, and in the NRC staff's Fire Protection Evaluation in Supplements 8, 9, 13, 23, 27 and 31 to the Diablo Canyon Safety Evaluation Report, subject to provision b below.
: b. PG&E may make changes to the approved fire protection program without priorapproval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
: c. Deleted.
2.2          NRC Acceptance of the Fire Protection Licensing Basis In response to letters from the Director of the Division of Project Management, dated May 3, 1976, and September 30, 1976, the NRC transmitted to PG&E copies of revised Standard Review Plan 9.5.1, "Fire Protection," and Appendix A to BTP APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976." In addition to transmitting the above documents, the NRC requested that PG&E evaluate the FP provisions at DCPP Units 1 and 2. The fire hazards analysis was developed in response to this request.
On July 27, 1977, PG&E submitted Amendment 51 to its application for an operating license for Units I and 2. The amendment was titled "Fire Protection Review, Units I and 2 Diablo Canyon Site." The NRC Staff reviewed the document and issued 58 NRC FP review questions via letters dated November 9, December 9 and December 27, 1977, and January 30, 1978. PG&E responded to the questions in four letters dated February 6, July 7, August 3, and November 13, 1978. The NRC Staff documented its review and acceptance of the DCPP Fire Protection Page 4

Pnt-ifid- rna  nnA 1=1,01-fril- frk     mn D~~~~pifip~~~~~~  ,mvIf    2n4Fnprg    n~a'rvickw. nf Pvictinn Piro. Drntatrtinn Prn ran Program in Supplemental Safety Evaluation Reports (SSER) 8 dated November 15, 1978, SSER 9 dated June 1, 1980, and SSER 13 dated April 1981.
On October 1, 1981, PG&E submitted a letter documenting the Fire Protection Plan's compliance with Sections IlI.G, Ill.J, ll.L, and 111.0 of 10 CFR 50, Appendix R, for Unit 1. This submittal was required by Section 2.C(6).b of Facility Operating License DPR-76.
In a March 2, 1983, letter, PG&E committed to providing a report justifying differences between existing or proposed FP features and those requirements specified in Sections Ill.G, IlI.J, III.L and I11.0 in 10 CFR 50, Appendix R.
On July 15, 1983, PG&E supplemented the October 1, 1981 submittal by submitting its Report on 10 CFR 50, Appendix R, review for Unit 1 for NRC review and approval (Reference 6.79).
PG&E responded to questions from the NRC review and further clarified the July 15 report in letters dated September 23 and 27, 1983 (Reference 6.80); October 3, 6, 11, 14, and 21, 1983; November 4, 1983; April 17, 1984; and May 16, 1984.
In June 1984 the NRC issued SSER 23 (Reference 6.76) to document the approval of those areas for which PG&E requested deviations. The areas included in SSER 23 are identified in the summary below. The NRC Staff stipulated that several modifications be completed prior to exceeding 5 percent of power. The NRC's SSER 27 for DCPP, dated July 1984, documents the approval of.the requested modifications and the removal of the condition on the license.
On November 2, 1984, the Facility Operating License for DCPP Unit 1 was issued.
The Unit 2 report on 10 CFR 50, Appendix R, review was issued for NRC review and approval on December 6, 1984 (Reference 6.81). PG&E responded to questions from the NRC review and further clarified the December 6 report in letters dated January 29, February 4, and April 22, 1985. In April 1985, the NRC issued SSER 31 (Reference 6.77) to document the approval of those Unit 2 areas for which PG&E had requested deviations. The areas included in SSER 31 are identified in the summary below. The NRC's SSER 32 (Reference 6.78) for DCPP, July 1985, acknowledged resolution of required actions identified in SSER 31.
On August 26, 1985, the Facility Operating License for DCPP Unit 2 was issued.
On November 15, 1990, PG&E submitted a LAR to remove requirements for fire protection from the operating license and the TS in accordance with NRC guidance in Generic Letters(GLs) 86-10 and 88-12. This LAR was subsequently supplemented by letters on May 19, 1992, and October 8, 1992. On January 19, 1993, the NRC approved this request in Amendment Nos. 75 and 74 to the Facility Operating Licenses for Units 1 and 2, respectively.
In summary, the NRC granted the following deviations in NRC SER Supplement Nos. 23 and 31:
: 1) Deviations were requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the RHR Pump 1-1 and Heat Exchanger Room, and the RHR Pump 1-2 and Heat Exchanger Room. These deviations were granted in the NRC's SER Supplement No. 23. (Fire Areas 3-B-1 and 3-B-2)
: 2) Deviations were requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Centrifugal Charging Pump 1-1 and 1-2 Room, the Reciprocating Charging Pump 1-3 Room, the Turbine Driven Auxiliary Feedwater (TDAFW) Pump Area and the 4.16kV Switchgear Ventilation Fan Room. These deviations were granted in the NRC's SER Supplement No. 23. (Fire Areas 3-H-1, 3-H-2, 3-Q-1, and 13-E)
Page 5

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: 3) A deviation was requested per the July 15, 1983, and the September 23, 1983, PG&E submittals for Unit 1 for the lack of 20 feet of separation between redundant shutdown divisions, and lack of area-wide suppression and detection in the Containment Penetration Area. This deviation was granted in the NRC's SER Supplement No. 23.
(Fire Area 3-BB)
: 4) A deviation was requested per the July 15, 1983, PG&E submittal for Units 1 and 2 for the lack of 1-hour barrier enclosing one train of redundant shutdown divisions and lack of area-wide suppression and detection in the Counting and Chemical Laboratory Area.
This deviation was granted in the NRC's SER Supplement No. 23 and stated applicable to Unit 2 in NRC's SER Supplement No. 31. (Fire Area 4-A)
: 5) A deviation was requested per the July 15, 1983, PG&E submittal for Unit I for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the G Bus and H Bus Compartments. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Areas 4-A-1 and 4-A-2)
: 6) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of area-wide suppression where a 1-hour barrier encloses one redundant shutdown division in the Showers, Lockers, and Access Control Area. This deviation was granted in the NRC's SER Supplement No. 23.0 (Fire Area 4-B)
: 7) Deviations were requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of an area-wide automatic fire suppression system in areas for which an alternate shutdown is provided in the Hot Shutdown Panel and Non-vital Switchgear Room Area and the Control Room Complex (Units 1 and 2). These deviations were granted in the NRC's SER Supplement No. 23. (Fire Areas 5-A-4 and CR-1)
: 8) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Electrical Area West of Battery Room. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Area 6-A-5)
: 9) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of area-wide detection in area with a 1-hour barrier enclosing one train of redundant shutdown divisions in the Corridor Outside the Diesel Generator Room. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Area 1 1-D)
: 10) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of a 1-hour barrier enclosing one train of redundant shutdown divisions in the Component Cooling Water (CCW) Heat Exchanger Room. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Area TB-7)
: 11) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of the Auxiliary Saltwater (ASW) Pumps 1-1 and 1-2. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Areas 30-A-1 and 30-A-2)
: 12) A deviation was requested per the July 15, 1983, PG&E submittal for Units 1 and 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Diesel Fuel Oil Transfer Pump Vaults 0-1 and 0-2. This deviation was granted in the NRC's SER Supplement No. 23 and stated applicable to Unit 2 in NRC's SER Supplement No. 31. (Fire Areas 35-A and 35-B)
: 13) A deviation was requested per the July 15, 1983, and December 6, 1984, PG&E submittals for Units 1 and 2 for the lack of area-wide suppression in miscellaneous areas Page 6

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of the Auxiliary Building (AB) and Fuel Handling Building (FHB). This deviation was granted in the NRC's SER Supplement No. 23 and stated applicable to Unit 2 in NRC's SER Supplement No. 31. (Fire Area AB-1)
: 14) A deviatio&#xfd; n was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of the Emergency Diesel Generators (EDGs) 1-1, 1-2, and 1-3 (Including the air intakes and exhaust equipment). This deviation was granted in the NRC's SER Supplement No. 23.
(Fire Areas TB-1, TB-2 and TB-3)
: 15) A deviation was requested per the July 15, 1983, October 3, 1983, October 6, 1983, October 11, 1983, October 14, 1983, and May 16, 1984, PG&E submittals for Unit 1 for the lack of fire-rated doors in fire-rated barriers that separate redundant shutdown divisions. This deviation was granted in the NRC's SER Supplement No. 23. (Various Fire Areas)
: 16) A deviation was requested per the July 15, 1983, PG&E submittal for Unit 1 for the lack of fire-rated steel hatches in fire-rated barriers that separate redundant shutdown divisions. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Areas 4-B, 5-A-4, 6-A-5 and 7-A)
: 17) A deviation was requested per the July 15, 1983, and the September 23, 1983, PG&E submittals for Unit I for the emergency lighting system, which is not in strict compliance with Appendix R requirements. This deviation was granted in the NRC's SER Supplement No. 23. (Various Fire Areas)
: 18) A deviation was requested per the July 15, 1983, and the September 23, 1983, PG&E submittals for Unit 1 for the Reactor Coolant Pump (RCP) oil collection system which is not in compliance with Appendix R requirements. This deviation was granted in the NRC's SER Supplement No. 23. (Fire Area 1)
: 19) Deviations were requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the RHR Pump 2-1 and Heat Exchanger Room, and RHR Pump 2-2 and Heat Exchanger Room. These deviations were granted in the NRC's SER Supplement No. 31. (Fire Areas 3-D-1 and 3-D-2)
: 20) Deviations were requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Centrifugal Charging Pumps (CCPs) 2-1 and 2-2 Room, the Reciprocating Charging Pump 2-3 Room, and the TDAFW Pump Area. These deviations were granted in the NRC's SER Supplement No. 31. (Fire Areas 3-1-1, 3-1-2 and 3-T-1),
: 21) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 20 feet of separation between redundant shutdown divisions and lack of area-wide suppression and detection in the Containment Penetration Area. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 3-CC)
: 22) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of area-wide suppression where a 1-hour barrier encloses one redundant shutdown division in the Showers, Lockers, and Access Control Area. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 4-B)
: 23) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of an area-wide automatic fire suppression system in an area for which an alternate Page 7

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shutdown is provided in the Hot Shutdown Panel and Non-vital Switchgear Room Area.
This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 5-B-4)
: 24) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Electrical Area West of Battery Room. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 6-B-5)
: 25) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of area-wide detection in area with a 1-hour barrier enclosing one train of redundant shutdown divisions in the Corridor Outside Diesel Generator (DG) Room. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 22-C)
: 26) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of a 1-hour barrier enclosing one train of redundant shutdown divisions in the CCW Heat Exchanger Room. This deviation was granted in the NRC's SER Supplement No.
: 31. (Fire Area TB-7)
: 27) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the ASW Pumps 2-1 and 2-2. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Areas 30-A-3 and 30-A-4)
: 28) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of the EDGs 2-1 and 2-2 (including the air intakes and exhaust equipment). This deviation was granted in the NRC's SER Supplement No. 31. (Fire Areas TB-8 and TB-9)
: 29) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of fire-rated doors in fire-rated barriers that separate redundant shutdown divisions.
This deviation was granted in the NRC's SER Supplement No. 31. (Various Fire Areas)
: 30) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the lack of fire-rated steel hatches in fire-rated barriers that separate redundant shutdown divisions. This deviation was granted in the NRC's SER Supplement No. 31. (Fire Areas 4-B, 5-B-4, 6-B-5 and 7-B) 31)A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the emergency lighting system, which is not in strict compliance with Appendix R requirements. This deviation was granted in the NRC's SER Supplement No. 31.
(Various Fire Areas)
: 32) A deviation was requested per the December 6, 1984, PG&E submittal for Unit 2 for the RCP oil collection system, which is not in compliance with Appendix R requirements.
This deviation was granted in the NRC's SER Supplement No. 31. (Fire Area 9)
Page 8

Dn&#xfd;M.- f2ng&#xfd; nnA Plaw-frit- 1-n   nn                                          fl1Tr~anc~itinn Prn~r_*c M    L 3 0 Transition Process 3.0     TRANSITION PROCESS 3.1      Background Section 4.0 of NEI 04-02, Revision 2, describes the process for transitioning from compliance with the current FP licensing basis to the new requirements of 10 CFR 50.48(c). NEI 04-02, Revision 2, contains the following steps:
: 1. Licensee determination to transition the licensing basis and devote the necessary resources to it;
: 2. Submit a Letter of Intent to the NRC stating the licensee's intention to transition the licensing basis in accordance with a tentative schedule;
: 3. Conduct the transition process to determine the extent to which the current FP licensing basis supports compliance with the new requirements and the extent to which additional analyses, plant and program changes, and alternative methods and analytical approaches are needed;
: 4. Submit a LAR;
: 5. Complete transition activities that can be completed prior to the receipt of the License Amendment;
: 6. Receive an SE; and,
: 7. Complete implementation of the new licensing basis, including completion of modifications identified in Attachment S.
3.2      NFPA 805 Process Section 2.2 of NFPA 805 establishes the general process for demonstrating compliance with NFPA 805. This process is illustrated in Figure 3-1. It shows that except for the fundamental FP requirements, compliance can be achieved on a Fire Area basis either by deterministic or RI-PB methods. Consistent with the guidance in NEI 04-02, Revision 2, PG&E has implemented the NFPA 805 Section 2.2 process by first determining the extent to which its current FP program supports findings of deterministic compliance with the requirements in NFPA 805. RI-PB methods are being applied to the requirements for which deterministic compliance could not be shown.
Page 9

Pac~ific~Ga  and Elec~tric~ Comnanv                                                                                     3f0 Transition Proces E           INI fulsabe  lltm fire NFPA 805 Section 2.2(a) protectio efret (Clupter 3)
I kdentfirye hazinds        NfPA 805 Section 2.21b) tirrerip-o WPA 805 Section 2.21c)
Evatuaft conmplance to                                                                 Radiation r8*leas RFPA 805 Section 2.2(d)
I,                        NFPA 805 Section 2.2(e)
Deiwudnisdtic Approach                                                 Pertwnencoaseaad Approach EValUMaeebult    to Saetisfyperfonmaice
        -4      Maito OWW  n~nc with Olig plant                                                                                    4-cee.bealef(10 CR 50OAP f.LApproved Exanriptioe, Engineering Evoluabonti)                                                   (chapter 4)
Pof1rwmao &OR11 keeriaelic BOM             L    Engineering                  Winme Am "WONesand We dealpi beams IVeity  diatem*c roq**emnwte we met              Z~qiva~ncyj                  for eachfbe arembeting evuahsf Laimig, cnue ea.
                                                                                          *Fire Modelig boquantfy the Wreflak NFPA 805 Section 2.2M1                                               " ardegin of se"ft
                                                                                          *PSA to exarnie hoped an owierl plant 110k NFPA US Section 2.2(g)
Rhak-nfoim*d Change Evalution WPA 805 Section 2.2(h)
Evaekiue knokMpect of dcngee 10the apprared 6e6gn      Waie Nr-PA 806 Section 2.20)
E~olnentationanoo psatim                 05    NAeartion 2.2111emar Feedback Figure 3 NFPA 805 Process (NEI 04-02 Figure 3-1 based on NFPA 805 Figure 2.2)                                                        2 Note: 10 CFR 50.48(c) does not incorporate by reference Life Safety and Plant Damage/Business Interruption goals, objectives and criteria. See 10 CFR 50.48(c) for specific exceptions to the incorporation by reference of NFPA 805.
Page 10

0   1f;   t--         A C1 "; 9, - .                                                ,t   Tr~nnifirwn Dr~r%#gaa 3.3         NEI 04-02 NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a RI-PB FP program. NEI 04-02 was developed to provide guidance on the overall process (programmatic, technical, and licensing) for transitioning from a traditional FP licensing basis to one based upon NFPA 805, as shown in Figure 3-2.
Transition Report                                            Transition Report Sect. 4.1                                                  Sect. 4.2 A
U se PB Approach If             Transition Report Needed (Fire Modeling or Fire Risk Evaluations)            Sect. 4.5 Figure 3 Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]
Page 11

P=.-ifit- 1--no nnrl J=Lmi-frit- I-rh on                                      _t n Trnnaitinn Pmroac D~~r~~ifi,-~~ Ij*i       ~~ ~ni2AT~nimnPr,~e L~a2I O 3.4        NFPA 805 Frequently Asked Questions (FAQs)
The NRC has worked with NEI and two Pilot Plants, (Oconee Nuclear Station and Harris Nuclear Plant) to define the licensing process for transitioning to a new licensing basis under 10 CFR 50.48(c) and NFPA 805. Both the NRC and the industry recognized the need for additional clarifications to the guidance provided in RG 1.205, Revision 1, NEI 04-02, Revision 2, and the requirements of NFPA 805. The NFPA 805 FAQ process was jointly developed by NEI and the NRC to facilitate timely clarifications of NRC positions. This process is described in a letter from the NRC dated July 12, 2006, to NEI (ML061660105) and in Regulatory Issues Summary (RIS) 2007-19, Process for Communicating Clarifications of Staff Positions Provided in RG 1.205 Concerning Issues Identified during the Pilot Application of NFPA Standard 805, dated August 20, 2007 (ML071590227).
Under the FAQ Process, transition issues are submitted to the NEI NFPA 805 Task Force for review, and subsequently presented to the NRC during public FAQ meetings. Once the NEI NFPA 805 Task Force and NRC reach agreement, the NRC issues a memorandum to indicate that the FAQ is acceptable. NEI 04-02 will be revised to incorporate the approved FAQs. This is an on-going revision process that will continue through the transition of NFPA 805 plants.
Final closure of the FAQs will occur when future revisions of RG 1.205, Revision 1, endorsing the related revisions of NEI 04-02, are approved by the NRC. It is expected that additional FAQs will be written and existing FAQs will be revised as plants continue NFPA 805 transition after the Pilot Plant SEs.
Attachment H contains the list of approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, Revision 1, NEI 04-02, Revision 2, and the requirements of NFPA 805 and in the preparation of this LAR.
Page 12

Pled-frid- rfm  nnu                 A n (,e% linni-a uuifh NPPA %mr,   Do "irgimanta Parific   t~ac -nd Par~ifit~ r-2s  anti ~l~u-*rip C~nmnan~,                 A fl C~nmnIiani-a ~Mi*Ii M~DA Rfl~ ~nuIirDmgintc 4.0         COMPLIANCE WITH NFPA 805 REQUIREMENTS 4.1         Fundamental Fire Protection Program and Design Elements The Fundamental Fire Protection Program and Design Elements are established in Chapter 3 of NFPA 805. Section 4.3.1 of NEI 04-02, Revision 2, provides a systematic process for determining the extent to which the pre-transition licensing basis and plant configuration meets these criteria and for identifying the FP program changes that would be necessary for compliance with NFPA 805. NEI 04-02, Revision 2, Appendix B-I, provides guidance on documenting compliance with the program requirements of NFPA 805, Chapter 3.
4.1.1       Overview of Evaluation Process The comparison of the DCPP FP Program to the requirements of NFPA 805, Chapter 3, was performed and documented in Report P1890-002-001, "NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review", Revision 4, June 2013 (Reference 6.18).
Report P1890-002-001, Revision 4, used the guidance contained in NEI 04-02, Revision 2, Section 4.3.1 and Appendix B-1 (See Figure 4-1 below).
Each section and subsection of NFPA 805, Chapter 3, was reviewed against the current FP program. Upon completion of the activities associated with the review, the following compliance statement(s) was used:
        " Complies - For those sections/subsections determined to meet the specific requirements of NFPA 805.
* Complies with Clarification - For those sections/subsections determined to meet the requirements of NFPA 805 with clarification.
* Complies by previous NRC Approval - For those sections/subsections where the specific NFPA 805 Chapter 3 requirements are not met but previous NRC approval of the configuration exists.
        "  Complies with use of EEEEs - For those sections/subsections determined to be
* equivalent to the NFPA 805, Chapter 3, requirements as documented by engineering analysis.
* Submit for NRC Approval - For those sections/subsections for which approval is sought in this LAR submittal in accordance with 10 CFR 50.48(c)(2)(vii). A summary of the bases of acceptability is provided (See Attachment L for details).
Complies, with Required Action - For those sections/subsections determined to meet the specific requirements of NFPA 805 after the completion of a modification or other implementation item, such as a procedure change or a work request (See Attachment S for details).
In some cases, multiple compliance statements have been assigned to a specific NFPA 805, Chapter 3, section/subsection. Where this is the case, each compliance/compliance basis statement clearly references the corresponding requirements of NFPA 805, Chapter 3.
Page 13

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rIn~pi         onu                                                                                                                      A In (,enm            cntIci          ifh~ MIMDA Rnr o                    ,csiricailiinfa I  ccc,.. *5. .ao       a. La     rSet*    1L      0....4..s                                                                                                                               ~      . .. ,.u.      cas.                   S fl sflfls S .s.us... s.a S*s.* LC Existing Fndm tl Fire Protetin Program and Design Elemrent Enter                  In 'theComnpliance Bai Field              (n Reform    IDc ure   F-ieldI NOTE I AtIhotgh rnc luded in the wsoWtal to the NRC the basi for co.ptance i5 recorded I dthe rontom I     da. ba he foreferce purpos NOTE 2:
I   L -- - I '     *      ,
* c=    *     --* d p o,,u=
* provid          oe
* Documn e t" Openg                  Eoting Engineering Equivalency Evauation*s. previously known I GeOneric Letter 88-10 evea        , exerrltions, and devianions were performed for fire protection design venarces such as ffit protection system designs and I-nprvie                                   I --nReeentce Docum-"[ Dcuern    Fin*
tht                    l   n during                fire barner component deviation from the specific IIe poection determinihtic mqufrmenl      Section 2.2.7 of NFPA B05 sib"wseoinlng EEE that clearly demon,,rates an equivalent teld of fire protectioncompared to the deternist*tct rqireentso be            ied. ThoseEEEEs fhat demonstrate tMrt a sytem or feature is rated or complant (I.., equivatent level of protection do not need to be summarized and submitted as part of the LAR. Those EEEs against Sections 3.1 through 3,7 of NFPA BO5that detenrmne the firl pro*ecton system or featore : adequate for the hazard ae surnmarized Inthi LAR.
Enter                                       nt                   I                                                  --
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                                                                                               .. 111411iiiI    I           InReernc Doum n                        [li                  _JOp            Al remaininlter acI rquesTedae idetifiled asl 'toererrat Iterra that reference a pantrdo ification numter and deanv-nhate that the Provide: r                                Provide IoNo                            ComplianceSaeets     Fil           DREtf aI             = [,oainf,,=                -,.o,                                Revie-wo attribute wit be In comnpianceonce the iBaMIsdosea tO*QIB 12/15/10 I*                          I                    d               in:th copiac Basis Fiel              I      nRetferce Documet*   F iedI
         '      FP 80                                       Ene                    prvd vebf exep frm                        provide':"=                                                .
Chpe 3'Reqireen            Yes &#xfd;CnjiaaAprvl ocmntLcesng                                                                  . D-o-_   r.reno                 Doum nany Open=     --
Docuraenet  anyOpen Itnms round dudng Review Document    anyOpen Items foundduring isComnptiance   Ba.sFinl               IntReference  Docuanent Complancew         achi vd          Enter'Complies, with          *-             nyf                          Pd prvide                         Docmfentany Open p t_roviery                             Fedprvd8UsdretmWOe
                                          --     through a rod or other              Required Aio In  '                    he t                                Corrective Actions, as           Items noundduring action                     conmpliancefieid                 to- b taken                                  ttoe                              Review IentifyCorreenatioe      [un         - Document References numbeer   as appropdiste Figure 4 Fundamental Fire Protection Program and Design Elements Transition Process (Based on NEI 04-02 Figure 4-2) 3 3  Figure 4-1 depicts the process used during the transition and therefore contains elements (i.e., open items) that represent interim resolutions. Additional detail on the transition of EEEEs is included in Section 4.2.2.
Page 14

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4.1.2      Results of the Evaluation Process 4.1.2.1 NFPA 805, Chapter 3, Requirements Met or Previously Approved by the NRC Attachment A contains NEI 04-02, Revision 2, Table B-i, Transition of Fundamental Fire Protection Program and Design Elements. This table provides the compliance basis for the requirements in NFPA 805, Chapter 3. Except as identified in Section 4.1.2.3, Attachment A demonstrates that the FP program at DCPP either:
* Complies directly with the requirements of NFPA 805, Chapter 3,
* Complies with clarification with the requirements of NFPA 805, Chapter 3,
* Complies through the use of existing engineering equivalency evaluations which are valid and of appropriate quality,
* Complies with a previously NRC approved alternative to NFPA 805, Chapter 3, and therefore the specific requirement of NFPA 805, Chapter 3, is supplanted, or
* Complies with the completion of a required action. If DCPP will meet an NFPA 805 section and/or subsection after it completes a document revision or other action (e.g.,
procedure revision or program change), Attachment A lists one or more "Implementation Items" that DCPP is taking and that, once complete, will bring DCPP into compliance with that section and/or subsection (See Attachment S for details).
4.1.2.2 NFPA 805, Chapter 3, Requirements Requiring Clarification of Prior NRC Approval NFPA 805 Section 3.1 states in part, "Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein." In some cases prior NRC approval of an NFPA 805, Chapter 3, program attribute may be unclear. PG&E requests that the NRC concur with their finding of prior approval for the following sections of NFPA 805 Chapter 3:
* None.
4.1.2.3 NFPA 805, Chapter 3, Requirements Not Met and Not Previously Approved by NRC The following sections of NFPA 805 Chapter 3 are not specifically met nor do previous NRC approvals of alternatives exist:
* Section 3.2.3(1) - NRC approval is requested for the use of performance-based surveillance frequencies as described in Electric Power Research Institute (EPRI)
Technical Report TR-1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features", July 2003 (Reference 6.27), for the inspection, testing, and maintenance of fire protection systems and features credited by the fire protection program.
        "  Section 3.3.5.1 - NRC approval is requested for the existence of wiring (cables) above suspended ceilings.
* Section 3.3.5.2 - NRC approval is requested for the use of non-metallic conduit.
Section 3.3.7.2 - NRC approval is requested for the outdoor high-pressure flammable gas storage container configuration.
Section 3.3.8 - NRC approval is requested for the use of the existing EDG day tank withdrawal connections not having heat-actuated closure valves.
Page 15

Dn&#xfd;ifi&#xfd; 1--na nnA         ('^m nn                      A nl (enm li~nnt ~ith NIrDA   Ann~ Panu"iramanfc The specific deviation and a discussion of how the alternative satisfies 10 CFR 50.48(c)(2)(vii) requirements are provided in Attachment L. PG&E requests NRC approval of these performance-based methods.
4.1.3    Definition of Power Block and Plant Where used in NFPA 805 Chapter 3 the terms "Power Block" and "Plant" refer to structures that have equipment required for nuclear plant operations, such as Containment, Auxiliary Building, Service Building, Control Building, Fuel Building, Radioactive Waste, Water Treatment, Turbine Building, and intake structures or structures that are identified in the facility's pre-transition licensing basis.
DCPP reviewed the structures in the Owner-Controlled Area to determine those that contain equipment that is required to meet the nuclear safety and radioactive release criteria described in Section 1.5, performance criteria, of NFPA 805. This review was conducted per the guidance of NEI 04-02, Revision 2.
These structures are listed in Attachment I and define the "Power Block" and "Plant" for DCPP.
4.2      Nuclear Safety Performance Criteria The Nuclear Safety Performance Criteria (NSPC) are established in Section 1.5 of NFPA 805.
Chapter 4 of NFPA 805 provides the methodology to determine the FP systems and features required to achieve the performance criteria outlined in Section 1.5. Section 4.3.2 of NEI 04-02, Revision 2, provides a systematic process for determining the extent to which the pre-transition licensing basis meets these criteria and for identifying any necessary FP program changes.
NEI 04-02, Revision 2, Appendix B-2 provides guidance on documenting the transition of NSCA Methodology and the Fire Area compliance strategies.
4.2.1    Nuclear Safety Capability Assessment Methodology The NSCA Methodology review consists of four processes:
* Establishing compliance with NFPA 805, Section 2.4.2
* Establishing the Safe and Stable Conditions for the Plant
* Establishing Recovery Actions
* Evaluating Multiple Spurious Operations The methodology for demonstrating reasonable assurance that a fire during NPO modes will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition is an additional requirement of 10 CFR 50.48(c) and is addressed in Section 4.3.
4.2.1.1 Compliance with NFPA 805 Section 2.4.2 Overview of Process NFPA 805, Section 2.4.2, Nuclear Safety Capability Assessment states:
     "The purpose of this section is to define the methodology for performing a nuclearsafety capabilityassessment. The following steps shall be performed:
(1) Selection of systems and equipment and their interrelationshipsnecessary to achieve the nuclearsafety performance criteria in Chapter I Page 16

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                                                                         *VL*      rI QflM 0 (2) Selection of cables necessary to achieve the nuclearsafety performance criteriain Chapter 1 (3) Identification of the location of nuclearsafety equipment and cables (4) Assessment of the ability to achieve the nuclearsafety performance criteriagiven a fire in each fire area" The NSCA methodology review evaluated the existing post-fire safe shutdown analysis (SSA) methodology and NSCA methodology against the guidance provided in NEI 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis", Revision 2, May 2009 (Reference 6.4)
(ML091770265) Chapter 3, "Deterministic Methodology," as discussed in Appendix B.2 of NEI 04-02, Revision 2. The methodology is depicted in Figure 4-2 and consisted of the following activities:
* Each specific section of NFPA 805 2.4.2 was correlated to the corresponding section of Chapter 3 of NEI 00-01, Revision 2. Based upon the content of the NEI 00-01 methodology statements, a determination was made of the applicability of the section to the station.
* The plant-specific methodology was compared to applicable sections of NEI 00-01, Revision 2, and one of the following alignment statements and its associated basis were assigned to the section:
                   " Aligns
* Aligns with Intent
                   " Not in Alignment
                   " Not in Alignment, but Prior NRC Approval
                   " Not in Alignment, but no adverse consequences The comparison of the DCPP FP Program documents to NEI 00-01, Revision 2, Chapter 3 (NEI 04-02, Revision 2, Table B-2) was performed and documented in Report R1890-012-001, "Nuclear Safety Performance Analysis Methodology Review," Revision 4, June 2013 (Reference 6.19).
Results from Evaluation Process The method used to perform the NSCA with respect to selection of systems and equipment, selection of cables, and identification of the location of equipment and cables, either meets the NRC endorsed guidance from NEI 00-01, Revision 2, Chapter 3, directly or met the intent of the endorsed guidance with adequate justification as documented in Attachment B.
Page 17

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Stop 3 SStep                     2 Y"   Y"                          NOYes Actm PrMVW Figure 4 Summary of Nuclear Safety Methodology Review Process (Based on FAQ 07-0039, Revision 2) 4.2.1.2 Safe and Stable Conditions for the Plant Overview of Process The nuclear safety goals, objectives and performance criteria of NFPA 805 allow more flexibility than the previous deterministic programs based on 10 CFR 50 Appendix R and NUREG 0800, Section 9.5-1 (and NEI 00-01, Revision 2, Chapter 3) since NFPA 805 only requires the licensee to maintain the fuel in a safe and stable condition rather than achieve and maintain cold shutdown.
NFPA 805, Section 1.6.56, defines Safe and Stable Conditions as follows:
     "Forfuel in the reactorvessel, head on and tensioned, safe and stable conditions are defined as the ability to maintain Keff <0.99, with a reactorcoolant temperature at or below the requirementsfor hot shutdown for a boiling water reactorand hot standby for a pressurizedwater reactor.Forall other configurations,safe and stable conditions are defined as maintainingKeff <0.99 and fuel coolant temperature below boiling."
The nuclear safety goal of NFPA 805 requires "...reasonableassurance that a fire during any operationalmode and plant configuration will not prevent the plant from achieving and maintainingthe fuel in a safe and stable condition"without a specific reference to a mission time or event coping duration.
For the plant to be in a safe and stable condition, it is not necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R. Therefore the Unit may remain at or below the temperature defined by a hot standby/hot shutdown plant operating state for the event.
Page 18

Pprifir rZaa and   Fled-friC rn    nn P2 Fcu-*rp tiir   ~ C~nin~n40ACo nrI                          (     lmniancei~ uth NFPA 805lR "~uirernentc Results The objective of the NSCA as documented in Report R2165-004-001, "Nuclear Safety Capability Assessment (NSCA)," Revision 0, June 2013 (Reference 6.22), is to demonstrate, using either deterministic or performance based methods of NFPA 805, that DCPP can achieve and maintain Hot Standby (i.e., safe and stable) conditions following a significant and challenging fire event using either deterministic or performance based methods of NFPA 805.
The NSCA, including supporting calculations, documents this assessment of fire impact on DCPP plant systems and features required to achieve and maintain Hot Standby from at power conditions. The NSCA replaces the post-fire safe shutdown compliance assessment for each area that was previously assessed to determine compliance with 10 CFR 50, Appendix R, Section III.G.
The NSCA for DCPP includes assessment of the fire impact upon the DCPP plant systems and features that are required to achieve and maintain Mode 3 (Hot Standby per DCPP TS Table 1.1-1), from Mode 1 (Power Operation). The NSCA bounds the objective of "safe and stable" plant operation for a fire event occurring in Mode 1, Mode 2 (Startup), or Mode 3. The Mode 3 applicability for the NSCA is defined as being up to the point at which the MCC Breakers for the RHR Pump Suction Valves, RHR-1(2)-8701 and RHR-1(2)-8702, are unlocked and closed, at which point spurious operation of these valves can occur due to fire damage to the valve control circuitry. This analysis is discussed in Section 4.2.4 of this report.
As part of the transition to NFPA 805, each Fire Area was evaluated for maintaining safe and stable Hot Standby conditions through either a "Deterministic Approach" (NFPA 805, Section 4.2.3) or "Performance Based Approach" (NFPA 805, Section 4.2.4). The necessary systems and equipment have been evaluated to ensure their capability to achieve a safe and stable plant condition (Hot Standby) as described within NFPA 805, Sections 1.3 and 1.6.56.
Hot Standby is accomplished based on the following:
: 1. DCPP has design features and procedures to ensure that an adequate source of inventory is provided for long term decay heat removal in sustained Hot Standby conditions (i.e., supply from Condensate Storage Tank (CST) or Raw Water Storage Reservoir or Fire Water Storage Tank via Makeup Water System). The CST is a safety-related tank and has a total capacity of approximately 425,000 gallons. Additional volume, if required, will be provided through manual crossties to the makeup water system (MWS), which may be aligned to the AFWS. This includes the seismically qualified Fire Water Storage Tank and the Raw Water Reservoirs that have a 5 million gallon capacity. These sources of water supply ensure suction capability for Motor Driven Auxiliary Feedwater (MDAFW) Pumps 2 and 3 and TDAFW Pump 1. This will support maintaining safe and stable operations for a sustained period of time.
: 2. DCPP has design features and procedures to ensure that an adequate source of inventory is provided for Reactor Coolant System (RCS) Inventory Control in sustained Hot Standby conditions (i.e., RCS inventory makeup from the Refueling Water Storage Tank (RWST) and/or the Boric Acid Storage Tanks (BASTs) to maintain the RCS sub-cooled) utilizing the Chemical and Volume Control System. This will support maintaining safe and stable operations for a sustained period of time.
: 3. In order to maintain extended Hot Standby conditions, additional negative reactivity must be added to the RCS. This is accomplished by borating the RCS while relying on natural circulation in the RCS to ensure adequate mixing of the injected boric acid within the reactor coolant. Existing design features and procedures will ensure that an adequate Page 19

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                                                                                            *~,t..i,        C t source of RCS makeup inventory is available to maintain long term Reactivity Control to enable safe and stable operations for a sustained period of time.
: 4. DCPP has design features and procedures to ensure that diesel fuel oil for the EDGs is available (as necessary, for those Fire Areas where offsite power is not free of fire damage) to sustain extended Hot Standby conditions. This will support maintaining safe and stable operations for a sustained period of time.
For the most limiting fire scenarios, the NSCA documents the availability of long term decay heat removal provided by operation of the Residual Heat Removal (RHR) system. Following stabilization at Hot Standby, a long term strategy for reactivity control, decay heat removal, and inventory/pressure control would be determined based on the extent of equipment damage. If an assessment of the post-fire conditions indicates that it is necessary to place RHR in service, then repair activities would commence, if necessary, in a safe and controlled manner to restore plant equipment necessary for reactor cooldown.
The DCPP NPO analysis addresses fire risk during the "higher risk evolutions," which may occur in Mode 3 (from the point at which the MCC Breakers for the RHR Pump Suction Valves, RHR-1(2)-8701 and RHR-1(2)-8702, are unlocked and closed, at which point spurious operation of these valves can occur due to fire damage to the valve control circuitry), Mode 4 (Hot Shutdown), Mode 5 (Cold Shutdown), and/or Mode 6 (Refueling). The "higher risk evolutions" considered in the DCPP NPO analysis for these NPO modes are consistent with the information and technical approach provided in FAQ 07-0040. The DCPP NPO analysis (Report R2049-005-001, "Non Power Operation Modes Review," Revision 2, June 2013, Reference 6.21) is discussed in Section 4.3.
4.2.1.3 Establishing Recovery Actions Overview of Process NEI 04-02, Revision 2, and RG 1.205, Revision 1, suggest that a licensee submit a summary of its approach for addressing the transition of operator manual actions (OMA) as recovery actions in the LAR (Regulatory Position 2.2.1 and NEI-04-02, Section 4.6). As a minimum, NEI 04-02, Revision 2, suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensee's methodology.
The discussion below provides the methodology used to transition pre-transition OMAs and to determine the population of post-transition recovery actions. This process is based on FAQ 07-0030 and consists of the following steps:
* Step 1: Clearly define the primary control station(s) and determine which pre-transition OMAs are taken at primary control station(s) (Activities that occur in the Main Control Room are not considered pre-transition OMAs). Activities that take place at primary control station(s) or in the Main Control Room are not recovery actions, by definition.
     "    Step 2: Determine the population of recovery actions that are required to resolve variances from deterministic requirements (VFDRs) (to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth (DID)).
* Step 3: Evaluate the additional risk presented by the use of recovery actions required to demonstrate the availability of a success path.
* Step 4: Evaluate the feasibility of the recovery actions.
* Step 5: Evaluate the reliability of the recovery actions.
Page 20

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P2,~ifir~ (~z~c~ 2nd Fl   trir~ (~nmnz~nu Results The review results are documented in Report R2165-004-001, Revision 0, and Report R2165-042-001, "Recovery Action Feasibility Assessment Report," Revision 0, June 2013 (Reference 6.24). Refer to Attachment G for the detailed evaluation process and summary of the results from the process.
4.2.1.4 Evaluation of Multiple Spurious Operations Overview of Process NEI 04-02, Revision 2, suggests that a licensee submit a summary of its approach for addressing potential fire-induced MSOs for NRC review and approval. As a minimum, NEI 04-02, Revision 2, suggests that the summary contain sufficient information relevant to methods, tools, and acceptance criteria used to enable the NRC to determine the acceptability of the licensee's methodology. The methodology utilized to address MSOs for DCPP is summarized below.
As part of the NFPA 805 transition project, a review and evaluation of DCPP's susceptibility to fire-induced MSOs was performed. The process was conducted considering guidance from NEI 04-02, Revision 2, and RG 1.205, Revision 1, as supplemented by FAQ 07-0038, Revision 2. The Pressurized Water Reactor Owners Group (PWROG) generic MSO list included in NEI 00-01, Revision 2, dated May, 2009, was utilized. Subsequent to the completion of the review and evaluation of fire-induced MSOs at DCPP, FAQ 07-0038, Revision 3, was issued. DCPP conducted a gap analysis between FAQ 07-0038, Revision 2 and Revision 3, and determined that no revision to the evaluation of DCPP's susceptibility to fire-induced MSOs was required (Reference 6.56).
The approach outlined in Figure 4-3 (based on FAQ 07-0038) is one acceptable method to address fire-induced MSOs. This method used insights from the FPRA developed in support of transition to NFPA 805 and consists of the following:
* Identifying potential MSOs of concern.
* Conducting an expert panel to assess plant specific vulnerabilities (e.g., per NEI 00-01, Revision 2, Section F.4.2).
* Updating the FPRA model and the NFPA 805 NSCA to include the MSOs of concern.
                 " Evaluating for NFPA 805 compliance.
                 " Documenting Results.
This process is intended to support the transition to a new licensing basis. Post-transition changes would use the RI-PB change process. The post-transition change process for the assessment of a specific MSO would be a simplified version of this process, and may not need the level of detail shown in the following section (e.g., An expert panel may not be necessary to identify and assess a new potential MSO. Identification of new potential MSOs may be part of the plant change review process and/or inspection process).
Page 21

Pacific Gas and Electric Company                                      4.0 Compliance with NFPA 805 Requirements Identify Potential MSOs of Concern
* SSA Step 1                  Generic List of MSOs S      Self Assessments
* PRA Insights
* Operating Experience Expert Panel Step 2              Identify and Document MSOs of Concern Update PRA model & NSCA (as appropriate) to include MSOs of concern Step 3
* ID equipment
                                       "     ID logical relationships
                                       "      ID cables
* ID cable routing Step 4                              r                         Pursue other resolution options Compliant with Step 5                     Document Results Figure 4 Multiple Spurious Operations - Transition Resolution Process (Based on FAQ 07-0038, Revision 2)
Results Refer to Attachment F for the process used and the results.
4.2.2   Existing Engineering Equivalency Evaluation Transition Overview of Evaluation Process The EEEEs (FHAREs) that support compliance with NFPA 805, Chapter 3 or Chapter 4 (both those that existed prior to the transition and those that were created during the transition), were re-reviewed using the methodology contained in NEI 04-02, Revision 2. The methodology for performing the EEEE review included the following determinations:
* The EEEE is not based solely on quantitative risk evaluations,
* The EEEE is an appropriate use of an engineering equivalency evaluation, Page 22

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       .      The EEEE is of appropriate quality,
* The standard license condition is met,
* The EEEE is technically adequate,
* The EEEE reflects the plant as-built condition, and
* The basis for acceptability of the EEEE remains valid.
In accordance with the guidance in RG 1.205, Revision 1, Regulatory Position 2.3.2 and NEI 04-02, Revision 2, as clarified by FAQ 08-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs that demonstrate that a FP system or feature is "adequate for the hazard" are summarized in the LAR as follows:
        "     If not requesting specific approval for "adequate for the hazard" EEEEs, then the EEEE was referenced where required and a brief description of the evaluated condition was provided.
* If requesting specific NRC approval for "adequate for the hazard" EEEEs, then EEEE was referenced where required to demonstrate compliance and was included in Attachment L for NRC review and approval.
In all cases, the reliance on EEEEs to demonstrate compliance with NFPA 805 requirements was documented in the LAR.
Results
. The review results for EEEEs are documented in Report P1890-002-003, "Engineering Evaluation Review", Revision 3, June 2013 (Reference 6.20).
In accordance with the guidance provided in RG 1.205, Revision 1, Regulatory Position 2.3.2, NEI 04-02, Revision 2, as clarified by FAQ 08-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs used to demonstrate compliance with Chapters 3 and 4 of NFPA 805 are referenced in Attachment A and summarized in Attachment C as appropriate. None of the transitioning EEEEs require NRC approval.
4.2.3         Licensing Action Transition Overview of Evaluation Process The existing licensing actions (Appendix R Deviations and SEs) review was performed in accordance with NEI 04-02, Revision 2. The methodology for the licensing action review included the following:
* Determination of the bases for acceptability of the licensing action.
* Determination that these bases for acceptability are still valid and required for NFPA 805.
Results Attachment K contains the detailed results of the Licensing Action Review. The licensing actions for DCPP that were re-reviewed in Attachment K consisted of deviation requests and the associated SER and Supplements. Since DCPP initial operation was post-1979, Appendix R, compliance was uniquely established in the licensing process and exemptions were not necessary and are therefore not applicable to DCPP.
Page 23

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O The Licensing Action Review is documented in Report R2291-004-001, "Licensing Action Review Report", Revision 2, June 2013 (Reference 6.57).
The following licensing actions will be transitioned into the NFPA 805 FP program as previously approved (NFPA 805, Section 2.2.7). These licensing actions are considered compliant under 10 CFR 50.48(c):
* Units 1 and 2: Deviation from the requirements of Section III.G.2 of Appendix R for the lack of 20 feet of separation between redundant shutdown divisions and lack of area-wide suppression and detection in the Containment Penetration Areas (Fire Areas 3-BB and 3-CC; SSER 23, Section 9.6.1.4, and SSER 31, Section 9.6.1.4, respectively). (Attachment K, Items 1 and 6);
Units 1 and 2: Deviation from the requirements of Section IIl.G.2(c) of Appendix R for Units 1 and 2 for the lack of 1-hour barrier enclosing one train of redundant shutdown divisions and lack of area-wide suppression and detection in the Counting and Chemical Laboratory Area (Fire Area 4-A; SSER 23, Section 9.6.1.5; SSER 31, Section 9.6.1.5). (Attachment K, Item 2);
Units 1 and 2: Deviation from the requirements of Section IIl.G.2(c) of Appendix R for the lack of area-wide suppression where a 1-hour barrier encloses one redundant shutdown division in the Showers, Lockers, and Access Control Area (Fire Area 4-B; SSER 23, Section 9.6.1.7; SSER 31, Section 9.6.1.7). (Attachment K, Items 3 and 7);
Units 1 and 2: Deviation from the requirements of Section III.G.2(c) of Appendix R for the lack of area-wide suppression in Miscellaneous Areas of the AB and FHB (Fire Area AB-1; SSER 23 Section 9.6.1.14; SSER 31, Section 9.6.1.14).
(Attachment K, Item 4); and Units 1 and 2: Deviations from the requirements of Section 111.0 of Appendix R for the RCP oil collection systems which are not in strict compliance with Appendix R requirements (Fire Areas I and 9; SSER 23, Section 9.6.1.19 and SSER 31, Section 9.6.1.19, respectively). (Attachment K Items 5 and 8).
The following licensing actions are no longer necessary and will not be transitioned into the NFPA 805 FP program. These deviations are no longer required because the subject boundaries are addressed by an Engineering Equivalency Evaluation that is acceptable per NEI 04-02, Revision 2:
* Unit 1: Deviations from the requirements of Section IIl.G.2(a) of Appendix R for the RHR Pump 1-1 and Heat Exchanger Room and the RHR Pump 1-2 and Heat Exchanger Room for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions (Fire Areas 3-B-1 and 3-B-2; SSER 23, Section 9.6.1.2). This condition is evaluated in FHARE 157. (Attachment K, Items 10 and 11);
            "      Unit 1: Deviations from the requirements of Section III.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the CCPs 1-1 and 1-2 Room, the Reciprocating Charging Pump 1-3 Room, the TDAWF Pump Area and the 4.16 kV Switchgear Ventilation Fan Room (Fire Areas 3-H-1, 3-H-2, 3-Q-1 and 13-E; SSER 23, Section 9.6.1.3). This condition is evaluated in FHARE 157. (Attachment K, Items 12, 13, 14, and 15);
* Unit 1: Deviations from the requirements of Section IIl.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in Page 24

Pacific Gas and Electric Comnanv                       4.0 Comoliance with NFPA 805 Reauirements the G Bus Compartment and the H Bus Compartment (Fire Areas 4-A-1 and 4-A-2; SSER 23, Section 9.6.1.6). This condition is evaluated in FHARE 157.
(Attachment K, Items 16 and 17);
* Unit 1: Deviation from the requirements of Section III.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Electrical Area West of Battery Room (Fire Area 6-A-5; SSER 23, Section 9.6.1.9). This condition is evaluated in FHARE 157. (Attachment K, Item 20);
* Unit 1: Deviations from the requirements of Section III.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of ASW Pumps 1-1 and 1-2 (Fire Areas 30-A-1 and 30-A-2; SSER 23, Section 9.6.1.12). This condition is evaluated in FHARE 157. (Attachment K, Item 23);
* Units 1 and 2: Deviations from the requirements of Section IIl.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Diesel Fuel Oil Transfer Pump Vaults 0-1 and 0-2 (Fire Areas 35-A and 35-B; SSER 23 Section 9.6.1.13; SSER 31, Section 9.6.1.13). This condition is evaluated in FHARE 157. (Attachment K, Item 24);
* Unit 1: Deviations from the requirements of Section Ill.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of EDGs 1-1, 1-2, and 1-3 (Including the air intakes and exhaust equipment) (Fire Areas TB-i, TB-2, and TB-3; SSER 23, Section 9.6.1.15). This condition is evaluated in FHARE 157. (Attachment K, Item 25);
* Unit 1: Deviations from the requirements of Section IIl.G.2 of Appendix R for the lack of fire-rated doors in various fire-rated barriers that separate redundant shutdown divisions (Fire Areas not specified; SSER 23, Section 9.6.1.16). This condition is evaluated in FHARE 159. (Attachment K, Item 26);
* Unit 1: Deviations from the requirements of Section IIl.G.2 of Appendix R for the lack of fire-rated steel hatches in fire-rated barriers that separate redundant shutdown divisions (Fire Areas 4-B, 5-A-4, 6-A-5 and 7-A; SSER 23, Section 9.6.1.17). This condition is evaluated in FHARE 157. (Attachment K, Item 27);
* Unit 2: Deviations from the requirements of Section III.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the RHR Pump 2-1 and Heat Exchanger Room and RHR Pump 2-2 and Heat Exchanger Room (Fire Areas 3-D-1 and 3-D-2; SSER 31, Section 9.6.1.2). This condition is evaluated in FHARE 157. (Attachment K, Items 29 and 30);
* Unit 2: Deviations from the requirements of Section III.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the CCPs 2-1 and 2-2 Room, the Reciprocating Charging Pump 2-3 Room and the TDAFW Pump Area (Fire Areas 3-1-1, 3-1-2 and 3-T-1; SSER 31, Section 9.6.1.3).
This condition is evaluated in FHARE 157. (Attachment K, Items 31, 32, and 33);
* Unit 2: Deviation from the requirements of Section IIl.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the Electrical Area West of Battery Room (Fire Area 6-B-5; SSER 31, Section 9.6.1.9). This condition is evaluated in FHARE 157. (Attachment K, Item 34);
Page 25

Pacific~ GsQ  ~andI           (nmln~
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         "   Unit 2: Deviations from the requirements of Section III.G.2(a) of Appendix R for thei lack of 3-hour fire-rated barrier separation between redundant shutdown divisions in the ASW Pumps 2-1 and 2-2 (Fire Area 30-A-3 and 30-A-4; SSER 31, Section 9.6.1.12). This condition is evaluated in FHARE 157. (Attachment K, Item 37);
         "   Unit 2: Deviations from the requirements of Section IIl.G.2(a) of Appendix R for the lack of 3-hour fire-rated barrier separation between redundant shutdown divisions of the EDGs 2-1 and 2-2 (Including the air intakes and exhaust equipment) (Fire Areas TB-8 and TB-9; SSER 31, Section 9.6.1.15). This condition is evaluated in FHARE 157. (Attachment K, Item 38);
         "   Unit 2: Deviations from the requirements of Section III.G.2 of Appendix R for the lack of fire-rated doors in fire-rated barriers that separate redundant shutdown divisions.
(Fire Areas not specified; SSER 31, Section 9.6.1.16). This condition is evaluated in FHARE 159. (Attachment K, Item 39); and
* Unit 2: Deviations from the requirements of Section III.G.2 of Appendix R for the lack of fire-rated steel hatches in fire-rated barriers that separate redundant shutdown divisions (Fire Areas 4-B, 5-B-4, 6-B-5, and 7-B; SSER 31, Section 9.6.1.17). This condition is evaluated in FHARE 157. (Attachment K, Item 40).
The following licensing actions are also no longer required because the Fire Areas have been transitioned as performance-based areas or the deviation is no longer required to support compliance with NFPA 805:
* Units 1 and 2: Deviation from the requirements of Sections III.G.2 and III.G.3 of Appendix R for the lack of an area-wide suppression system in an area for which an alternate shutdown capability has been provided in the Hot Shutdown Panel and Non-vital Switchgear Room, and Control Room Complex Areas (Fire Areas 5-A-4, 5-B-4, and CR-1; SSER 23, Section 9.6.1.8; SSER 31, Section 9.6.1.8). (Attachment K, Items 9, 18 and 19);
* Units 1 and 2: Deviation from the requirements of Section Ill.G.2(c) of Appendix R for the lack of a 1-hour barrier enclosing one train of redundant shutdown divisions in the CCW Heat Exchanger Room (Fire Area TB-7, Fire Zones 14-E, and 19-E; SSER 23, Section 9.6.1.11; SSER 31, Section 9.6.1.11). (Attachment K, Items 22 and 36);
* Units 1 and 2: Deviations from the requirements of Section III.G.2(c) of Appendix R for the lack of area-wide detection where a 1-hour barrier encloses one redundant shutdown division in the Corridor Outside Diesel Generator Room (Fire Areas 1 1-D and 22-C; SSER 23, Section 9.6.1.10; SSER 31, Section 9.6.1.10). (Attachment K, Items 21 and 35); and
          " Units 1 and 2: Deviation from the requirements of Section IIl.J of Appendix R for the emergency lighting system in both Units which is not in strict compliance with Appendix R requirements (Fire Areas not specified; SSER 23, Section 9.6.1.18; SSER 31, Section 9.6.1.18). (Attachment K, Items 28 and 41).
Since the deviations 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), PG&E requests that the deviations that will not be transitioned as discussed above and as listed in Attachment K be rescinded as part of the LAR process. It is PG&E's understanding that implicit in the superseding of the current license condition, all prior fire protection program Safety Evaluation Reports and commitments will be superseded in their entirety.
Page 26

Pacific Gas and Electric Comnanv                       4.0 ComDliance with NFPA 805 Reauirements 4.2.4    Fire Area Transition Overview of Evaluation Process The Fire Area Transition (NEI 04-02, Revision 2, Table B-3) was performed using the methodology contained in NEI 04-02, Revision 2, and FAQ 08-0054. The methodology for performing the Fire Area Transition, depicted in Figure 4-4, is outlined as follows:
Step 1 - Assembled documentation. Gathered industry and plant-specific Fire Area analyses and licensing basis documents.
Step 2 - Documented fulfillment of nuclear safety performance criteria:
    " Assessed accomplishment of nuclear safety performance goals. Documented the method of accomplishment, in summary level form, for the Fire Area.
* Documented evaluation of effects of fire suppression activities. Documented the evaluation of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria.
* Performed licensing action reviews. Performed a review of the licensing aspects of the selected Fire Area and document the results of the review. See Section 4.2.3.
* Performed existing engineering equivalency evaluation reviews. Performed a review of existing engineering equivalency evaluations (or created new evaluations) documenting the basis for acceptability. See Section 4.2.2.
* Pre-transition OMA reviews. Performed a review of pre-transition OMAs to determine those actions taking place outside of the main control room or outside of the primary control station(s). See Section 4.2.1.3.
Step 3 - VFDR Identification and characterization and resolution considerations. Identified variances from the deterministic requirements of NFPA 805, Section 4.2.3. Documented variances as either a separation issue or a degraded FP system or feature. Developed VFDR problem statements to support resolution.
Step 4 - Performance-Based evaluations (Fire Modeling or Fire Risk Evaluations). See Section 4.5.2 for additional information.
Step 5 - Final Disposition:
* Documented final disposition of the VFDRs in Attachment C (NEI 04-02, Revision 2, Table B-3).
* For recovery action compliance strategies, ensured the manual action feasibility analysis of the required recovery actions was completed. Note: if a recovery action cannot meet the feasibility requirements established per NEI 04-02, Revision 2, then alternate means of compliance was considered.
* Documented the post-transition NFPA 805, Chapter 4, compliance basis.
Step 6 - Documented required FP systems and features. Reviewed the NFPA 805, Section 4.2.3, compliance strategies (including Fire Area licensing actions and engineering evaluations) and the NFPA 805 Section 4.2.4 compliance strategies (including simplifying deterministic assumptions) to determine the scope of FP systems and features 'required' by NFPA 805 Chapter 4. The 'required' FP systems and features are subject to the applicable requirements of NFPA 805, Chapter 3.
Page 27

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Results of the Evaluation Process Attachment C contains the results of the Fire Area Transition review (NEI 04-02, Revision 2, Table B-3). The Fire Area Transition is documented in Report R2165-008-001, "Fire Area Transition Review Report (Table B-3 Report)", Revision 1, June 2013 (Reference 6.58). On a Fire Area basis, Attachment C summarizes compliance with Chapter 4 of NFPA 805.
NEI 04-02, Revision 2, Table B-3, includes the following summary level information for each Fire Area:
* Regulatory Basis - NFPA 805 post-transition regulatory bases are included.
* Performance Goal Summary - An overview of the method of accomplishment of each of the performance criteria in NFPA 805 Section 1.5 is provided.
      " Reference Documents - Specific references to NSCA Documents are provided.
      " Fire Suppression Activities Effect on NSPC - A summary of the method of accomplishment is provided.
* Licensing Actions - Specific references to deviations that will remain part of the post-transition licensing basis. A brief description of the condition and the basis for acceptability of the licensing action is provided.
* EEEE - Specific references to EEEE that rely on determinations of "adequate for the hazard" that will remain part of the post-transition licensing basis. A brief description of the condition and the basis for acceptability is provided.
* VFDRs - Specific variances from the deterministic requirements of NFPA 805 Section 4.2.3. Refer to Section 4.5.2 for a discussion of the performance-based approach.
Page 28

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Identify INITIAL Variances From Deterministic Requirements of NFPA 805 &sect; 4.2.3 (B-3 Table)
O       to demonstrate compliance                         Section 4.2.3 of NFPA 805                                t With NFPA 805 &sect; 4.2.4.1 1   1 Document Final Disposition of VFDR Compliance options include:
Accept As Is NFPA 805 &sect; 4.2.4.1               YES         Require FP systems/features
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Criteria Met?         --                  Require Recovery Action Require Programmatic Enhancements Require Plant Modifications (B-3 Table)
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Figure 4 Summary of Fire Area Review (Based on FAQ 08-0054, Revision 1)
Page 29

Pacific Gas and Electric CornDanv                      4.0 Compliance with NFPA 805 Requirements 4.3      Non-Power Operational Modes 4.3.1    Overview of Evaluation Process PG&E implemented the process 'utlined in NEI 04-02, Revision 2, and FAQ 07-0040, Non-Power Operations Clarification. The goal (as depicted in Figures 4-5 and 4-6) is to ensure that contingency plans are established when the plant is in a Non-Power Operational (NPO) mode where the risk is intrinsically high. During low risk periods, normal risk management controls and fire prevention/protection processes and procedures will be utilized.
The process to demonstrate that the nuclear safety performance criteria are met during NPO modes involved the following steps:
    " Reviewed the existing Outage Management Processes
* Identified Equipment/Cables:
             " Reviewed plant systems to determine success paths that support each of the defense-in-depth Key Safety Functions (KSFs), and
             " Identified cables required for the selected components and determine their routing.
* Performed Fire Area Assessments (identify pinch points - plant locations where a single fire may damage all success paths of a KSF).
    " Managed pinch-points associated with fire-induced vulnerabilities during the outage.
The process is depicted in Figures 4-5 and 4-6. The results are presented in Section 4.3.2.
Page 30

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Figure 4-5 Review POSs, KSFs, Equipment, and Cables, and Identify Pinch Points Page 31

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* IC Fire Protection Higher Risk Evolution as Defined by Plant Specific          Higher Risk                 Defense-in-Outage Risk Criteria for example                            Evolution?       NDepth
: 1) Time to Boil                                                                            Actions
: 2) Reactor Coolant System and Fuel Pool Inventory
: 3) Decay Heat Removal Yes Implement Contingency Plan for Specific KSF Figure 4-6 Manage Pinch Points Page 32

Pno-ifir rnc   nnd Plarfrir (n       mn P2  ~I~tri i-fii-t'~2 C~nn~r4 2fl4                   AC-        l~mnianc with NFPA 85Rfl Pnmire  ents 4.3.2     Results of the Evaluation Process DCPP outage management procedure define "Higher Risk Evolution," however the definition does not consider time to boil, inventory, and decay heat removal capability (Reference 6.46).
As such, Report R2049-005-001, Revision 2, documents a qualitative analysis of plant conditions during NPO evolutions, which determined that the reduced inventory/mid-loop operation condition was the highest risk period. This determination was based on very short times to boil, limited methods available for decay heat removal (e.g., only RHR available), and low RCS inventory.
The NPO analysis determined that the evolutions performed, and the plant conditions experienced by DCPP during an outage are consistent with the Plant Operating States/Plant Operational States (POS) discussed in FAQ 07-0040.
The NPO analysis also discusses the POS reviewed and the systems and equipment selected.
Components were identified to provide the KSFs of Core Cooling, Inventory Control, Reactivity Control, and support functions (Process Monitoring for Inventory, and Electrical Power). The selection of equipment is logically tied to the supported KSF. Power supplies, interlocks, and supporting equipment are logically tied to their parent component. These data relationships are stored electronically for use with an analytical software tool.
For circuits associated with required components that had not been previously selected (as part of other NFPA 805 tasks), cable selection was performed per the NSCA methodology. The cables necessary to support the selected function of a component were selected and analyzed for fire impact.
In accordance with FAQ 07-0040, any plant location where a single fire may damage all success paths of a KSF is considered a 'pinch point'.
Report R2049-005-001, Revision 2, contains the NPO Fire Area assessment, the identified
 'pinch points,' and the credited actions consistent with FAQ 07-0040 to reduce fire risk. Fire modeling was not used to eliminate any Fire Area from having a pinch point.
The list of credited actions and generic recommendations specified in the NPO analysis considers the following from FAQ 07-0040:
* Prohibition or limitation of hot work in Fire Areas during periods of increased vulnerability
* Verification of operable detection and/or suppression in the vulnerable areas.
* Prohibition or limitation of combustible materials in Fire Areas during periods of increased vulnerability
* Plant configuration changes (e.g., removing power from equipment once it is placed in its desired position)
* Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability
* Use of recovery actions to mitigate potential losses of key safety functions.
* Identification and monitoring in-situ ignition sources for "fire precursors" (e.g., equipment temperatures)
* Reschedule the work to a period with lower risk or higher DID Attachment D provides additional detail for the DCPP NPO transition.
Page 33

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                                                                                                                     ~CatJtS** ~ *~, ,tO Implementation of the NPO Fire Area assessment results into the DCPP outage management processes will be completed prior to NFPA 805 Program implementation. The following implementation items are associated with the NPO transition:
       " Applicable DCPP procedures will be revised to contain guidance developed by the NPO review. This will include revising procedures as necessary to ensure that FP program, operational controls, administrative controls, and housekeeping requirements are maintained to the extent practical during NPO conditions (i~e., fire impairment compensatory measures are required when fire barriers are changed during shutdown modes and reduced inventory conditions). (See Attachment S, Table S-3, Item S-3.18)
       " The definition of Higher Risk Evolution (HRE) will be revised to be consistent with criteria in NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management,"
December 1991 (Reference 6.47) and FAQ 07-0040. This will be completed as part of NFPA 805 Program implementation. (See Attachment S, Table S-3, Item S-3.18) 4.4           Radioactive Release Performance Criteria 4.4.1         Overview of Evaluation Process The review of the FP program against NFPA 805 requirements for fire suppression related radioactive release was performed using the methodology contained in NEI 04-02, Revision 2, and subsequent guidance provided in NFPA 805 Task Force FAQ 09-0056. The methodology consisted of the following:
       " A review to "screen-in" fire zones based on the potential to contain contaminated materials during all plant operating modes, including full power and non-power conditions. The screening process considers input from Radiation Protection (RP) personnel and review of DCPP pre-fire plans. The evaluation focused on radioactive release to any unrestricted area due to firefighting activities only; radioactive release due to potential fuel cladding damage was not evaluated. The nuclear safety goal, nuclear safety objectives, and nuclear safety performance criteria specified in NFPA 805 require the prevention of fuel cladding damage. As such, radiological release due to fuel damage does not require a separate examination since no such damage is assumed to occur without violating the basic requirements of NFPA 805.
* A review of pre-fire plans and fire brigade training materials to identify FP program elements (e.g., systems / components / procedural control actions / flow paths, etc.) that are being credited to meet the radioactive release goals, objectives, and performance criteria during all plant operating modes, including full power and non-power conditions.
        " A review of engineering controls to ensure containment of gaseous and liquid effluents (e.g., smoke and fire fighting agents). This review included all plant operating modes (including full power and non-power conditions). Otherwise, a bounding analysis, quantitative analysis, or other analysis that demonstrates that the limitations for instantaneous release of radioactive effluents specified in DCPP's TS are met, was provided.
4.4.2          Results of the Evaluation Process PG&E Calculation SAP No. 9000041465 (Legacy No. M-1 176), Part 000, Version 00, "NFPA 805 Radioactive Release Review" (Reference 6.23) details the results of the screening process and review of pre-fire plans, fire brigade training materials, engineering controls, and administrative controls. DCPP Calculations DCA 9000041373-000-00 (N-315), "Liquid Effluent Page 34

All Cnmnlianrp with NFPA  Rns RPniiirPmPntq Pacific Gas and El.ctric.Co                                             .nnv.C.nwhP.Rmt Release to the Unrestricted Area Boundary Due to a Fire," and DCA 9000041374-000-00 (N-316), "Gaseous Effluent Release to the Unrestricted Area Boundary Due to Fire" (References 6.49 and 6.50) demonstrate that the liquid and gaseous effluent radioactive dose limits of 10 CFR 20 and plant TS will not be exceeded due to the effects of complete combustion of the worst case "bounding" radioactive source term, and subsequent fire suppression activities within the Owner Protected Area.
PG&E concluded that DCPP will be compliant with NFPA 805 and the guidance in NEI 04-02, Revision 2, and RG 1.205, Revision 1, upon completion of the implementation items identified in Attachment S. (See Attachment S, Table S-3, Items S-3.19 and S-3.20)
The site specific review of the direct effects of fire suppression activities on radioactive release is summarized in Attachment E.
4.5      Fire PRA and Performance-Based Approaches RI-PB evaluations are an integral element of an NFPA 805 FP program. Key parts of RI-PB evaluations include:
* A Fire PRA (discussed in Section 4.5.1 and Attachments U, V, and W).
     "   NFPA 805 Performance Based (PB) Approaches (discussed in Section 4.5.2).
4.5.1    Fire PRA Development and Assessment In accordance with the guidance in RG 1.205, Revision 1, a Fire PRA model was developed for DCPP in compliance with the requirements of Part 4 "Requirements for Fires At Power PRA," of the ASME and ANS combined PRA Standard, ASME/ANS RA-Sa-2009, "Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Application," February 2009 (Reference 6.28) (hereafter referred to as FPRA Standard). PG&E conducted a peer review by independent industry analysts in accordance with RG 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2, March 2009 (Reference 6.7) prior to a risk-informed submittal. The resulting fire risk assessment model is used as the analytical tool to perform FREs during the transition process.
Section 4.5.1.1 describes the Internal Events, Internal Floods, and Seismic PRA models.
Section 4.5.1.2 describes the FPRA model. Section 4.5.1.3 describes the results and resolution of the peer review of the FPRA, and Section 4.5.1.4 describes insights gained from the FPRA.
4.5.1.1 Internal Events, Internal Floods and Seismic PRA Introduction PG&E employs a multi-faceted approach to establishing and maintaining the technical adequacy and plant fidelity of the PRA model for DCPP. This approach includes both a proceduralized PRA maintenance and update process, and the use of self-assessments and independent peer reviews. The following information describes this approach as it applies to the DCPP PRA.
Internal Events and Internal Floods PRA Peer Review The DCPP internal events and internal floods PRA had a full scope peer review in accordance with the guidance in NEI 05-04, Industry PRA Peer Review Process. This review was conducted in December, 2012 (Westinghouse letter LTR-RAM-Il-13-002, "RG 1.200 PRA Peer Page 35

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Review Against the ASME/ANS PRA Standard Requirements for the Diablo Canyon Nuclear Plant Probabilistic Risk Assessment," March 20, 2013, Reference 6.87). The model that was reviewed was the DCPP PRA Level 1 and Level 2 Model as documented in the DCPP PRA Calculation, File No. C.9 (Reference 6.83) and DCPP Internal Flooding PRA Report (Reference 6.84). The peer review was done in accordance with Capability Category II requirements of the ASME/ANS RA-Sa-2009 Standard as endorsed by RG 1.200, Revision 2, with the full consideration of NRC regulatory positions described in Appendix A, B, and C. The peer review found the Internal Events PRA and Internal Floods model to be technically adequate. The results of this peer review, including Facts and Observations (F&O) resolutions and impact on this LAR submittal, are summarized in Attachment U.
No changes have been made to the Internal Events or Internal Floods PRA models since the Peer Review that would constitute an upgrade as defined by ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2.
Seismic PRA Peer Review PG&E conducted a Peer Review of the DCPP Seismic PRA in January 2013 (Westinghouse letter LTR-RAM-13-04, "Peer Review of Diablo Canyon Power Plant Probabilistic Risk Assessment Against the Seismic PRA Standard Supporting Requirements of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications," Reference 6.88). This review was conducted in accordance with ASME/ANS RA-Sa-2009 Standard as endorsed by RG 1.200, Revision 2. The full-scope Peer Review results are summarized in Attachment U.
No changes have been made to the Seismic PRA model since the Peer Review that would constitute an upgrade as defined by ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2.
PRA Maintenance and Upgrade The PG&E Risk Management (RM) process ensures that the applicable PRA model remains an accurate reflection of the as-built and as-operated plants. This process is defined in the DCPP risk management program, which includes PRA governing procedure TS3.NR1, "Probabilistic Risk Assessment (PRA)" (Reference 6.30), and will include new Administrative Work Procedure AWP E-028, "PRA Model Maintenance and Upgrades" (Reference 6.59)(See Attachment S, Table S-3, Item S-3.26). This procedure delineates the responsibilities and guidelines for maintaining the PRA models at DCPP. The overall PG&E risk management program, including TS3.NR1 and AWP E-028, will define the process for implementing regularly scheduled and interim PRA model updates, for tracking issues identified as potentially affecting the PRA models (e.g., due to changes in the plant, errors or limitations identified in the model, industry operational experience), and for controlling the model and associated computer files. To ensure that the current PRA model remains an accurate reflection of the as-built, as-operated plant, the following activities are routinely performed:
* Design changes are re-reviewed for their impact on the PRA model.
* New procedures and procedure changes are re-reviewed for their impact on the PRA model.
* New calculations and revisions to existing calculations are re-reviewed for their impact on the PRA model.
Page 36

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* Equipment unavailabilities are captured, and the PRA model is updated.
          " Plant specific initiating event frequencies, failure rates, and 'maintenance unavailabilities for equipment that can have a significant impact on the PRA model are updated approximately every 6 years. The last update was completed in December, 2009.
In addition to these activities, PG&E risk management procedures provide the guidance for particular risk management and PRA quality and maintenance activities. This guidance includes:
          " Documentation of the PRA model, PRA products, and bases documents.
0  The approach for controlling electronic storage of RM products including PRA update information, PRA models, and PRA applications.
* Guidelines for updating the full power, internal and external events PRA models for DCPP.
* Guidance for use of quantitative and qualitative risk models in support of the On-Line Work Control Process Program for risk evaluations for maintenance tasks (corrective maintenance, preventive maintenance, minor maintenance, surveillance tests and modifications) on systems, structures, and components (SSCs) within the scope of the Maintenance Rule (10 CFR 50.65 (a)(4)).
In accordance with this guidance, regularly scheduled PRA model updates nominally occur on an approximately 4-year cycle. PRA model updates were also performed in shorter intervals in the past to incorporate design changes, procedure changes and/or newly developed industry data and models that may have a significant impact on the plant risk results. The most recent update of the DCPP internal events PRA model was completed in November, 2012.
4.5.1.2 FPRA An FPRA model was developed for DCPP using the guidance provided in NUREG/CR-6850/EPRI TR-1011989 (including Supplement 1), EPRI TR-1016735, and draft NUREG-1921. Attachment H provides a listing of the approved FAQs that affect the overall license transition process for DCPP. The resulting FPRA model is used as the analytical tool to perform FREs during the transition process and to develop estimates of the potential change in fire related risk associated with those changes.
The FPRA was developed using the internal events PRA as a starting point. The internal events PRA was modified to capture the effects of fire, both as an initiator of an event and the subsequent potential failure modes for affected circuits or individual targets. The FPRA has been quantified using the RISKMAN PRA software. The FPRA is a Unit-specific analysis and the DCPP FPRA models each Unit with a separate set of fire scenarios and target damage sets for each scenario. The DCPP FPRA is documented in a series of reports and calculations associated with each NUREG/CR-6850 FPRA task (i.e., PRA Calculations F.3.1 through F.3.15)
(References 6.31 through 6.43).
Fire Model Utilization in the Application Fire modeling was performed as part of the FPRA development (NFPA 805 Section 4.2.4.2).
RG 1.205, Revision 1, Regulatory Position 4.2 and Section 5.1.2 of NEI 04-02, Revision 2, provide guidance to identify fire models that are acceptable to the NRC for plants implementing a risk-informed, performance-based licensing basis.
Page 37

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                                                                                                      +&#xfd; The following fire models were used:
: 1. Flame Height (Method of Heskestad)
: 2. Plume Centerline Temperature (Method of Heskestad)
: 3. Radiant Heat Flux (Point Source Method)
: 4. Plume Radius (Method of Heskestad)
: 5. Hot Gas Layer (Method of McCaffrey, Quintiere, and Harkleroad (MQH))
: 6. Ceiling Jet Temperature (Method of Alpert)
: 7. Hot Gas Layer Calculations using Consolidated Model of Fire Growth and Smoke Transport (CFAST) (Version 6)
: 8. Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios)
: 9. Heat Detection Actuation Correlation
: 10. Sprinkler Activation Correlation
: 11. Control Room Abandonment Calculation using CFAST
: 12. Temperature Sensitive Equipment Hot Gas Layer Study using CFAST
: 13. Temperature Sensitive Equipment Zone of Influence Study using FDS
: 14. Plume/Hot Gas Layer Interaction Study using FDS
: 15. Correlation for Heat Release Rates of Cables (Method of Lee)
: 16. Corner and Wall Heat Release Rate (HRR)
: 17. Correlation for Flame Spread over Horizontal Cable Trays (FLASH-CAT)
: 18. Pyrosim (Versions 2008 and 2010)
: 19. Engineering Planning and Management (EPM) Fire Modeling Workbook, Version 2 The acceptability of the use of these fire models is included in Attachment J.
4.5.1.3 Results of FPRA Peer Review

===Background===
PG&E conducted a full scope FPRA Peer Review in two phases - the first phase in 2008 that emphasized piloting the FPRA Peer Review Process, followed by the second phase in 2010 to complete the technical review.
The 2008 Peer Review (Westinghouse letter LTR-RAM-II-08-019, "Pilot Application of the Fire PRA Peer Review Process for the Diablo Canyon Power Plant Fire Probabilistic Risk Assessment," October 17, 2008, Reference 6.84) was conducted against the requirements of the ANS Standard ANSI/ANS-58, 23-2007, "Fire PRA Methodology", November 2007 (Reference 6.29). The scope of the peer review was the entire DCPP FPRA as it existed on January 7, 2008. The primary purpose of the DCPP FPRA peer review was a trial application of the FPRA peer review process as documented in NEI 07-12 and a trial application of the FPRA standard. At the time of the review, the DCPP FPRA was not complete but PG&E had exercised the key steps of the FPRA process in NUREG/CR-6850 to the extent that the peer review process could be piloted.
Page 38

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                                                                                                           ~   i At the time of the 2008 peer review:
PG&E had completed Plant Partitioning (PP), Equipment Selection (ES), Cable Selection, Ignition Frequency (IGN), and Circuit Failure (CF) Analysis. The documentation for these elements was still in draft form, and PG&E finalized the documentation after the pilot application of the peer review process was completed.
PG&E had partially completed Fire Scenario Selection (FSS), Quantitative Screening (QNS), HRA, or Fire Risk Quantification (FQ), primarily because of the iterative nature of the analysis and the sequential refinement of the analyses to further evaluate the major risk contributors. However, the analyses were sufficiently complete to allow the review team to make preliminary assessments of the technical adequacy of the DCPP processes.
        "   PG&E had not performed the Uncertainty and Sensitivity (UNC) Analysis or the Seismic/Fire Interaction (SF) Evaluations because both rely on completion of the FQ so neither of these elements could be reviewed.
* Additionally, the DCPP PRA Configuration Control program was reviewed with respect to how well it covered the basic elements of the configuration control element and the unique aspects of FPRA. This program had been established to support the internal events, at-power PRA.
The second FPRA peer review was held at the DCPP site during the week of December 6, 2010. This Peer Review was the second phase of the Peer Review conducted for the DCPP FPRA model in January 2008. The 2010 Peer Review was conducted against the requirements of Section 4 of the ASME/American Nuclear Society (ANS) Combined PRA Standard as endorsed by RG 1.200, Revision 2.
The 2010 Peer Review scope was defined in part by the 2008 Peer Review Report. Thus, the total scope of both phases of the Peer Reviews together included all technical elements of Section 4 of the Combined PRA Standard except for the Qualitative Screening task, which was not performed for the DCPP FPRA. The Peer Review Team states in the 2010 peer review report (Westinghouse letter LTR-RAM-1-11-004, "Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements From Section 4 of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications for the Diablo Canyon Plant Fire Probabilistic Risk Assessment," May 24, 2011, Reference 6.85) that although they specifically reviewed the Unit 1 PRA, the "Unit 2 model uses identical methodology and the results of the review are applicable to that model as well." The Unit 1 and Unit 2 models are documented together in the calculation files that were provided to the Peer Review Team for review. Specifically:
: 1. Plant Boundary Definition and Partitioning (PRA Calculation File F.3.1). This calculation file documents the division of Unit 1, Unit 2, and common plant areas into fire compartments. The Peer Review Team states in its assessment of the plant partitioning task that the "global analysis boundary encompasses both Unit I and Unit 2, consistent with the plant's Fire Protection Program."
: 2. Fire PRA Component Selection (PRA Calculation File F.3.2). This calculation file documents equipment selection for both Units.
: 3. Cable Selection (PRA Calculation File 134-DC-T)(Reference 6.49). This calculation file documents cable selection for both Units.
: 4. Qualitative Screening. Optional task not performed.
Page 39

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: 5. Development of Fire-Induced Risk Model.(PRA Calculation File F.3.5). This calculation file describes the development of the Fire PRA models for DCPP Unit 1 and Unit 2 for use in the quantification of the risk impact of fire events in the plant. It documents the conversion of the Unit 1 internal events PRA model into an internal events PRA model for Unit 2 and the subsequent creation of the Unit 2 fire PRA model. This calculation file also documents the quantification and quantitative screening tasks for both Units.
: 6. Fire PRA Ignition Frequency Calculation (PRA Calculation File F.3.6). This calculation file estimates the fire-ignition frequency for each fire compartment associated with either Unit.
: 7. Quantitative Screening. Quantitative screening is covered for both Units under PRA Calculation File F.3.5.
: 8. Scoping Fire Modeling. Optional task not performed.
: 9. Circuit Failure Analysis (PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version.00, "Associated CKT Analysis - Fire Protection", Reference 6.55). This calculation file evaluates, for both Units, common power supply and common enclosure associated circuits as applied to the DCPP NSCA and fire PRA.
: 10. Fire PRA Circuit Failure Mode Likelihood Analysis (PRA Calculation File F.3.10). This calculation file documents the circuit failure mode likelihood analysis for FPRA cables in both Units.
: 11. Detailed Fire Modeling (PRA Calculation Files F.3.1lb, F.3.1lc, and F.3.1ld). Much of the detailed fire modeling for Unit 1 applies to Unit 2 as well. For example, (a) the Unit 2 counterpart to the cable spreading room for Unit 1 has almost identical room geometry and fire conditions and, the CFAST results from 7A are used for Fire Area 72; (b) main control room fire modeling for both Units is described together, with any differences noted throughout; (c) the multi-compartment analysis was performed for Unit1 and Unit 0 (common compartments) and the validity was confirmed for Unit 2 by plant walkdown. In areas where separate detailed fire modeling analyses were performed, the same methods were used as were re-reviewed by the peer review team for Unit 1.
: 12. Post-Fire Human Reliability Analysis (PRA Calculation File F.3.12). The fire-context operator actions for both Units are developed in calculation file F.3.12.
: 13. Seismic Fire Interaction (PRA Calculation File F.3.13). The seismic-fire interaction review for both Units is documented in calculation file F.3.13.
: 14. Fire Risk Quantification. This task is covered under F.3.5 for both Units.
: 15. F.3.15. Uncertainty Analysis (PRA Calculation File F.3.15). The uncertainty analysis calculation file applies to both Units.
Results Section 4 of the ASME/ANS Combined PRA Standard contains a total of 182 Supporting Requirements (SRs) under thirteen technical elements, and Configuration Control from Section 1.5. The January 2008 peer review was conducted with the 2007 PRA standard, which contained 183 SRs. The differences between the two standards, as they pertain to SRs, were reconciled in the 2010 report, and are reported therein in terms of the current PRA Standard.
These 182 SRs can be grouped as follows:
0        Certain SRs were not reviewed in 2008, but were re-reviewed in 2010.
Page 40

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* Certain SRs were re-reviewed in 2008 and were not reviewed again in 2010.
* Certain SRs were re-reviewed in 2008 and again in 2010. For these SRs only the information from the 2010 review has been presented. For example, for the technical element FSS which was reviewed in both 2008 and 2010, the summary is based only on the 2010 review.
        ,  Certain SRs which were re-reviewed in 2008 were eliminated in the new PRA Standard and these have been so identified.
* Certain new SRs were added to the new Standard, and these were re-reviewed and documented in the 2010 report. (Example HRA-A3)
The table below presents an overall summary of the consolidated results of the 2008 and 2010 peer reviews for the 182 SRs.
Page 41

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REVIEW OUTCOME SRs % OF TOTAL (182)
Capability Category             Not Met   0            0.0%
Capability Category             I        2              1.1%
Capability Category             1/11      5            2.8%
Capability Category             II       13            7.1%
Capability Category              I1/111  15            8.2%
Capability Category             1II      11            6.0%
Capability Category             Met     115           63.2%
Not Reviewed                              0            0.0%
Not Applicable                           21            11.5%
Total                                   182.           100%
It can be seen from the table above that none of the SRs were judged to be not met and only two (2) of the SRs were met at Capability Category I, as defined in Part 4 of the FPRA Standard. These two SRs are discussed in Attachment V, Table V-3 (FPRA - Category I Summary). Table V-3 also listed the SRs from the 2008 Peer Review that did not meet CC-li or better quality requirements. However, as documented in Tables V-2 and V-3, these 2008 SRs were re-reviewed during the 2010 Peer Review and found to meet CC-Il or better.
F&Os were issued by the peer team as an output of the peer review. Attachment V discusses the findings of both the 2008 original and the 2010 follow-up peer reviews.
No changes have been made to the FPRA model since the Peer Reviews that would constitute an upgrade as defined by ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2.
4.5.1.4 Risk Insights Risk insights were documented as part of the development of the FPRA. The total plant fire CDF/LERF was derived using the NUREG/CR-6850 methodology for FPRA development and is useful in identifying the areas of the plant where fire risk is greatest. A review of the fire initiating events that represent more than a 0.5 percent contribution to the calculated fire risk is included as Attachment W.
4.5.2        Performance-Based Approaches NFPA 805 outlines the approaches for performing performance-based analyses. As specified in Section 4.2.4, there are generally two types of analyses performed for the performance-based approach:
* Fire Modeling (NFPA 805, Section 4.2.4.1).
      "      Fire Risk Evaluation (NFPA 805, Section 4.2.4.2).
4.5.2.1 Fire Modeling Approach The fire modeling approach was not utilized for the transition.
4.5.2.2 Fire Risk Approach Overview of Evaluation Process The FREs were completed as part of the DCPP NFPA 805 transition. These FREs were developed using procedure EPM-DP-RSD-001, "Fire Risk Evaluation" (Reference 6.45). This methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, Revision 2, and RG 1.205, Revision 1. These are summarized in Table 4-1.
Page 42

Pacific Gas and Electric Company                         4.0 Compliance with NFPA 805 Requirements Table 4-1 Fire Risk Evaluation Guidance Summary Table Document                         Section(s)                              Topic NFPA 805, 2001            2.2(h), 4.2.4, A.2.2(h), A.2.4.4,    Change Evaluation (2.2(h), 2.2.9, Edition                   D.5                                  2.4.4 A.2.2(h), A.2.4.4, D.5)
Risk of Recovery Actions (4.2.4)
Use of Fire Risk Evaluation (4.2.4.2).
NEI 04-02, Revision       4.4, 5.3, Appendix B, Appendix I,    Change Evaluation, Change 2                         Appendix J                           Evaluation Forms (App. I), No specific discussion of Fire Risk Evaluation RG 1.205, Revision 1      C.2.2.4, C.2.4, C.3.2                Risk Evaluations (C.2.2.4)
Recovery Actions (C.2.4)
During the transition to NFPA 805, variances from the deterministic approach in Section 4.2.3 of NFPA 805 were evaluated using an FRE per Section 4.2.4.2 of NFPA 805. An FRE was performed for each Fire Area containing variances from the deterministic requirements of Section 4.2.3 of NFPA 805 (VFDRs).
If the FRE meets the acceptance criteria, this is confirmation that a success path effectively remains free of fire damage and that the performance-based approach is acceptable per Section 4.2.4.2 of NFPA 805.
The FRE process consists of the following steps (Figure 4-7 depicts the FRE process used during transition. This is generally based on FAQ 08-0054, Revision 1:
Step 1 - Preparation for the FRE:
* Definition of the Variances from the Deterministic Requirements. The definition of the VFDR includes a description of problem statement and the section of NFPA 805 that is not met, type of VFDR (e.g., separation issue or degraded FP system), and proposed evaluation per applicable NFPA 805 section.
* Preparatory Evaluation - Fire Risk Evaluation Team Review. Using the information obtained during the development of the NEI 04-02, Revision 2, B-3 Table and the FPRA, a team review of the VFDR was performed. Depending on the scope and complexity of the VFDR, the team may include the Safe shutdown/NSCA Engineer, the Fire Protection Engineer, and the FPRA Engineer. The purpose and objective of this team review was to address the following:
o   Review of the FPRA modeling treatment of VFDR o   Ensure discrepancies were captured and resolved Step 2 - Performed the FRE:
* The Evaluator coordinated as necessary with the Safe shutdown/NSCA Engineer, Fire Protection Engineer and FPRA Engineer to assess the VFDR using the FRE process to perform the following:
o   Change in Risk Calculation with consideration for additional risk of recovery actions and required FP systems and features due to fire risk.
o   Fire area change in risk summary Page 43

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Step 3 - Reviewed the Acceptance Criteria:
The acceptance criteria for the FRE consist of two parts. One is quantitatively based and the other is qualitatively based. The quantitative figures of merit are ACDF and ALERF. The qualitative factors are DID and safety margin:
o    Risk Acceptance Criteria. The transition risk evaluation was measured quantitatively for acceptability using the ACDF and ALERF criteria from RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2, May 2011 (Reference 6.6), as clarified in RG 1.205, Revision 1, Regulatory Position C.2.2.4.
o    Defense-in-Depth. A review of the impact of the change on DID was performed, using the guidance in NEI 04-02, Revision 2. NFPA 805 defines defense-in-depth as:
                  -      Preventing fires from starting
                  -      Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting damage
                  -      Providing adequate level of FP for SSCs important to safety; so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.
In general, the DID requirement was considered to be satisfied if the proposed change does not result in a substantial imbalance among these elements (or echelons).
The review of DID was qualitative and addressed each of the elements with respect to the proposed change. DID was performed on a Fire Area basis.
FP features and systems relied upon to ensure defense-in-depth were identified as a result of the assessment of DID.
o    Safety Margin Assessment. A review of the impact of the change on safety margin was performed. An acceptable set of guidelines for making that assessment is summarized below. Other equivalent acceptance guidelines may also be used:
                  - Codes and standards or their alternatives accepted for use by the NRC are met, and
                  -      Updated Final Safety Analysis Report (UFSAR) or Safety analysis acceptance criteria in the licensing basis (e.g., UFSAR, supporting analyses) are met, or provides sufficient margin to account for analysis and data uncertainty.
The requirements related to safety margins for the change analysis are described for each of the specific analysis types used in support of the FRE.
Page 44

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Model            Fireuss and FireRisk     is the VFDR inHow Determine         the to Fire PRA        No  Fire PRA and Fire Evaluation Documentation Perform Fire Risk Evaluation Calculate VFDR Delta CDF And Delta LERF IReview                                                                  of Acceptance Criteria Evaluate Delta CDF And Delta LERF Evaluate the Maintenance of                      Discuss and Document in Defense-In-Depth                  s     Fire Risk Evaluation And                                Calculation Safety Margin Figure 4 Fire Risk Evaluation Process (NFPA 805 Transition)
(Based on FAQ 08-0054, Revision 1)
Page 45

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D~.i~~~aUC,,*J w~i~          L*t Results of Evaluation Process Disposition of VFDRs The DCPP NSCA and the NFPA 805 transition project activities have identified a number of variances from the deterministic requirements of NFPA 805 Section 4.2.3. These variances were dispositioned using the fire risk evaluation process.
Each variance dispositioned using an FRE was assessed against the FRE acceptance criteria of ACDF and ALERF; and maintenance of DID and safety margin criteria from Section 5.3.5 of NEI 04-02, Revision 2, and RG 1.205, Revision 1. The results of these calculations are summarized in Attachment C.
Following completion of transition activities and planned modifications and program changes, the plant will be compliant with 10 CFR 50.48(c).
Risk Change Due to NFPA 805 Transition In accordance with the guidance in RG 1.205, Revision 1, Section C.2.2.4, Risk Evaluations, risk increases or decreases for each Fire Area using FRE's and the overall plant should be provided. Note that the risk increase due to the use of recovery actions was included in the risk change for transition for each Fire Area.
RG 1.205, Revision 1, Section C.2.2.4.2, states in part:
     "The total increase or decrease in risk associatedwith the implementation of NFPA 805 for the overallplant should be calculated by summing the risk increasesand decreases for each fire area (including any risk increasesresulting from previously approved recovery actions). The total risk increaseshould be consistent with the acceptance guidelinesin Regulatory Guide 1.174. Note that the acceptanceguidelines of Regulatory Guide 1.174 may require the total CDF,LERF, or both, to evaluate changes where the risk impact exceeds specific guidelines. If the additionalrisk associatedwith previously approved recovery actions is greaterthan the acceptance guidelines in Regulatory Guide 1.174, then the net change in total plant risk incurredby any proposedalternatives to the deterministic criteriain NFPA 805, Chapter4 (otherthan the previously approved recovery actions),
should be risk neutral or represent a risk decrease."
The risk increases and decreases are provided in Attachment W.
4.6          Monitoring Program 4.6.1        Overview of NFPA 805 Requirements and NEI 04-02 Guidance on the NFPA 805 Fire Protection System and Feature Monitoring Program Section 2.6 of NFPA 805 states:
      "A monitoringprogram shall be establishedto ensure that the availabilityand reliabilityof the fire protection systems and features are maintainedand to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid."
As part of the transition review, the adequacy of the inspection and testing program to address FP systems and equipment within plant inspection and the compensatory measures programs should be reviewed. In addition, the adequacy of the plant corrective action program in determining the causes of equipment and programmatic failures and minimizing their recurrence should also be reviewed as part of the transition to a RI-PB licensing basis.
Page 46

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                                                                                                        &#xfd;+&#xfd; 4.6.2       Overview of Post-transition NFPA 805 Monitoring Program This section describes the. process that will be utilized to implement the post-transition NFPA 805 monitoring program. The monitoring program will be implemented after the SE issuance as part of the FP program transition to NFPA 805. (See Attachment S, Table S-3, Item S-3.1) The monitoring process is comprised of four phases:
* Phase 1 - Scoping
* Phase 2 - Screening Using Risk Criteria
* Phase 3 - Risk Target Value Determination
* Phase 4 - Monitoring Implementation Figure 4-8 provides detail on these processes.
The results of these phases will be documented in the DCPP NFPA 805 monitoring program evaluation to be developed during implementation.
Phase I - Scoping In order to meet the NFPA 805 requirements for monitoring, the following categories of SSCs and programmatic elements will be reviewed during the implementation phase for inclusion in the NFPA 805 monitoring program:
     " SSCs required to comply with NFPA 805, specifically:
* Fire protection systems and features
                -      Required by the NSCA
                -      Modeled in the FPRA
                -      Required by Chapter 3 of NFPA 805 4
* Nuclear Safety Capability Assessment equipment
                -      Nuclear safety equipment
                -      FPRA equipment
                -      NPO equipment
            " SSCs relied upon to meet radioactive release criteria
     "      Fire Protection Programmatic Elements Phase 2 - Screening Using Risk Criteria The equipment from Phase 1 scoping will be screened to determine the appropriate level of NFPA 805 monitoring. As a minimum, the SSCs identified in Phase 1 will be part of an inspection and test program and system/program health reporting. If not in the current program, the SSCs will be added in order to assure that the criteria can be met reliably.
The following screening process will be used to determine those SSCs that may require additional monitoring beyond normal inspection and test program and system/program health reporting and will be documented in the DCPP NFPA 805 Monitoring Program evaluation.
4 For   the purposes of the NFPA 805 Monitoring, "NSCA equipment" is intended to include Nuclear Safety Equipment, Fire PRA equipment, and NPO equipment.
Page 47

Pacific Gas and Electric Comnanv                       4.0 CornDliance with NFPA 805 Reauirements
*1. Fire Protection Systems and Features Those FP systems and features identified in Phase 1 are candidates for additional monitoring in the NFPA 805 program commensurate with risk significance.
Risk significance is determined at the component, programmatic element, and/or functional level on an individual Fire Area basis. Compartments smaller than Fire Areas may be used provided the compartments are independent (i.e., share no FP SSCs). If compartments smaller than Fire Areas are used the basis will be documented in the PRA documentation.
The FPRA is used to establish the risk significance based on the following screening criteria:
Risk Achievement Worth (RAW) of the monitored parameter _>2.0 (AND) either Core Damage Frequency (CDF) x (RAW) > 1.OE-7 per year (OR)
Large Early Release Frequency (LERF) x (RAW) > 1.OE-8 per year CDF, LERF, and RAW(monitored parameter) are calculated for each Fire Area. The 'monitored parameter' will be established at a level commensurate with the amenability of the parameter to risk measurement (e.g., a fire barrier may be more conducive to risk measurement than an individual barrier penetration).
Fire Protection systems and features that meet or exceed the criteria identified above are considered High Safety Significant (HSS) and will be included in a monitoring program contained in or equivalent to the site Maintenance Rule Program as described in DCPP Procedure MA1.ID17, "Maintenance Rule Monitoring Program" (Reference 6.60). The remaining required FP systems and features will be monitored via the existing inspection and test program and/or in the existing system / program health reporting as described in DCPP Procedures TS5.IDI, "System Engineering Program", Section 5.8, "Performance Monitoring" (Reference 6.61) and OM15.1D6, "Station Programs" (Reference 6.62).
: 2. Nuclear Safety Capability Assessment Equipment Required NSCA equipment, except the NPO scope, identified in Phase 1 will be screened for safety significance using the FPRA and the Maintenance Rule guidelines differentiating HSS equipment from Low Safety Significant (LSS) equipment. The screening will also ensure that the Maintenance Rule functions are consistent with the required functions of the NSCA equipment.
HSS NSCA equipment not currently monitored in Maintenance Rule will be included in the Maintenance Rule. All NSCA equipment that are not HSS are considered LSS and need not be included in the monitoring program.
For non-power operational modes, the qualitative use of fire prevention to manage fire risk during HREs does not lend itself to quantitative risk measurement. Therefore, fire risk management effectiveness is monitored programmatically similar to combustible material controls and other fire prevention programs. Additional monitoring beyond inspection and test programs and system/program health reporting is not considered necessary.
: 3. SSCs Relied upon for Radioactive Release Criteria The evaluations performed to meet the radioactive release performance criteria are qualitative in nature. The SSCs relied upon to meet the radioactive release performance criteria are not Page 48

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                                                                                           ~Li~~t Paii   a   nd Elec~tric Comnanv amenable to quantitative risk measurement. Additionally, since 10 CFR 20 limits (which are lower than releases due to core damage and containment breach) for radiological effluents are not being exceeded, equipment relied upon to meet the radioactive release performance criteria is considered inherently low risk. Therefore, additional monitoring beyond inspection and test programs and system/program health reporting is not considered necessary.
: 4. Fire Protection Programmatic Elements Monitoring of programmatic elements is required in order to "assess the performance of the FP program in meeting the performance criteria." These programs form the bases for many of the analytical assumptions used to evaluate compliance with NFPA 805 requirements.
Programmatic aspects include:
     " Transient Combustible Control; Transient Exclusion Zones
     "   Hot Work Control; Administrative Controls
* Impairment and compensatory measures including program compliance and effectiveness
     "   Fire Brigade Effectiveness Monitoring of programmatic elements is more qualitative in nature since the programs do not lend themselves to the numerical methods of reliability and availability. Therefore, monitoring will be conducted using fire protection system and program health programs. Some of the inputs to these programs include self-assessment, regulator and insurance company inspection reports, and compliance audits.
Phase 3 - Risk Target Value Determination Phase 3 establishes the target values for reliability and availability for the FP systems and features that met or exceeded the screening criteria and the HSS NSCA equipment established in Phase 2.
Target values for reliability and availability for the FP systems and features are established at the component level, program level, or functionally through the use of the pseudo system or
'performance monitoring group' concept. The actual action level is determined based on the number of component, program or functional failures within a sufficiently bounding time period (approximately 2-3 operating cycles). In addition, the EPRI TR 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features,"
will be used as input for establishing reliability targets, action levels, and monitoring frequency.
Attachment L includes a request for approval for the use of PB surveillance frequencies as described in EPRI TR-1 006756 for the inspection, testing, and maintenance of fire protection systems and features credited by the fire protection program.
EPRI TR-1006756 provides an accepted method to establish appropriate inspection, testing, and maintenance frequencies which ensure the required NFPA 805 availability, reliability, and performance goals are maintained. The NFPA 805 monitoring program will monitor reliability and unavailability performance to ensure that these established maintenance and surveillance frequencies are adequate to ensure the reliability and unavailability assumptions are maintained and identify when adjustments to these frequencies are required.
Since the HSS NSCA equipment has been identified using the Maintenance Rule guidelines, the associated equipment specific performance criteria will be established as in the Maintenance Rule, provided the criteria are consistent with FPRA assumptions.
Page 49

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                                                                                                             *~ct*trr   t.I.*~I When establishing the action level threshold for reliability and availability, the action level will be no lower than the FPRA assumptions. Adverse trends and unacceptable levels of availability, reliability, and performance will be reviewed against established action levels. The monitoring program failure criteria and action level targets will be documented in the NFPA 805 Monitoring Program evaluation.
Note that FP systems and features, NSCA equipment, SSCs required to meet the radioactive release criteria, and FP program elements that do not meet the screening criteria in Phase 2 will be included in the existing inspection and test programs and the system and program health programs. Reliability and availability criteria will not be assigned.
Phase 4- Monitoring Implementation Phase 4 is the implementation of the monitoring program, once the monitoring scope and criteria are established. Monitoring consists of periodically gathering, trending, and evaluating information pertinent to the performance, and/or availability of the equipment and comparing the results with the established goals and performance criteria to verify that the goals are being met.
Results of monitoring activities will be analyzed in timely manner to assure that appropriate action is taken. The corrective action process will be used to address performance of FP and nuclear safety SSCs that do not meet performance criteria.
The NFPA 805 Monitoring Program will include thresholds that define acceptable performance of programmatic elements in accordance with OM15.1D6. These could be in the form of reliability and unavailability performance criteria, or other programmatic performance measures.
All NFPA 805 monitoring that fails to meet established thresholds will be documented and evaluated by the corrective action program per DCPP procedure OM7.ID1, "Problem Identification and Resolution" (Reference 6.63). The corrective action program will be utilized to complete the casual analysis for the performance deficiency, and the identification and implementation of required corrective actions to return the performance to within the established thresholds.
For FP systems and features and NSCA HSS equipment that are monitored, unacceptable levels of availability, reliability, and performance will be reviewed against the established action levels. If an action level is triggered, corrective action in accordance with OM7.ID1 will be initiated to identify the negative trend. A corrective action plan will then be developed to ensure the performance returns to the established level.
When applicable, a sensitivity study can be performed to determine the margin below the action level that still provides acceptable FPRA results to help prioritize corrective actions ifthe action level is reached.
A periodic assessment will be performed (e.g., at a frequency of approximately every two to three operating cycles), taking into account, where practical, industry wide operating experience. This will be conducted as part of other established assessment activities. Issues that will be addressed include:
* Review systems with performance criteria. Do performance criteria still effectively monitor the functions of the system? Do the criteria still monitor the effectiveness of the FP and NSCA systems?
* Have the supporting analyses been revised such that the performance criteria are no longer applicable or new FP and NSCA SSCs, programmatic elements and/or functions need to be in scope?
* Based on the performance during the assessment period, are there any trends in system performance that should be addressed that are not being addressed?
Page 50

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                                                                                                                                                ~..a MAikM Programmatic Elements Scoping                                       to Monitor Establish risk significance                      See Part 2 of 2 for detail Phaseciteria Screening Using Risk Criteria                           Establish list of HSS Fire and NSCA SSCs (for each PMG) based on Criteria Establish Functional Failure criteria and Action Phase 3                                  Levels for each PMG Risk Target Value Determination                           Establish reliability and availability criteria oreSSCs                                                          in preventiv Smaintenance                                 & condi Aiddrddresvi                                             performance Yes accEstablish goals m          pro Monitoringcorrective action Implementation MonitorIsgoal    meuiet?
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                                                                                                                         - O    erv goa requiredred NeoN Figure  -8 (P       rt f2 c FA85Mnioig-Oeve Page 51

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Figure 4-8 (Part 2 of 2) - NFPA 805 Monitoring - Scoping and Screening 4.7         Program Documentation, Configuration Control, and Quality Assurance 4.7.1       Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 In accordance with the requirements and guidance in NFPA 805 Section 2.7.1 and NEI 04-02, Revision 2, PG&E has documented analyses to support compliance with 10 CFR 50.48(c). The analyses were performed in accordance with PG&E's processes for ensuring assumptions are clearly defined, that results are easily understood, that results are clearly and consistently described, and that sufficient detail is provided to allow future review of the entire analyses.
Analyses, as defined by NFPA 805 Section 2.4, performed to demonstrate compliance with 10 CFR 50.48(c) will be maintained for the life of the plant and organized to facilitate review for Page 52

D&#xfd;&#xfd;M&#xfd; Mno nnA =Ini-frio, ('^m   nn                   A nl (-rnninhnta uAhi~h MPJDA %mrDoniiam  antc accuracy and adequacy. Note these analyses do not include items such as periodic tests, hot work permits, fire impairments, etc.
The Fire Protection Design Basis Document described in Section 2.7.1.2 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the SE. Appropriate cross references will be established to supporting documents as required by PG&E processes. The development of the FP basis document in the form of the fire safety analysis (FSA) will be completed prior to the implementation date (see Attachment S, Table S-3, Item S-3.15). The FSA will incorporate appropriate elements of the following documents:
    " The current Fire Hazards Analysis (FHA) contained in UFSAR Appendix 9.5A,
    " Transition of Fundamental Fire Protection Program and Design Elements review results (B-1 Table, Attachment A),
* Nuclear Safety Performance Analysis Methodology review results (8-2 Table, Attachment B),
    "   Nuclear Safety Transition Fire Area Assessment review results (B-3 Table, Attachment C), including fire suppression effects review results, and
    " Fire Protection Code Conformance review (Report P1890-002-004, "Fire Protection Code Conformance Review Report" Revision 1, March 2013, Reference 6.67).
In addition, various NFPA 805 analyses have been incorporated into the DCPP configuration control program in accordance with DCPP configuration control procedures. They will be maintained as necessary for changes to plant configuration until NFPA 805 program implementation in conjunction with the FSA, when they will be implemented and supersede existing Appendix R design basis documents. These analyses include:
* Radioactive Release Review,
* Nuclear Safety Capability Assessment (NSCA),
    "    Non-Power Operations (NPO) Modes Review,
* Recovery Action Feasibility Assessment (RAFA),
* Fire Risk Evaluations, and
* Other PRA Calculations (incorporating elements shown on Figure 4-9).
Figure 4-9 depicts the planned post-transition documentation and relationships.
Page 53

Pacific Gas and Electric Comoanv                                                              4.0 Compliance with NFPA 805 Requirements
        ,,. ... .NFPA
                  . . . . 805   DOCUMENTS NSCA DATABASE fl~Non-Power1                                                         Revised License men              Equipment and                                    Condition and Data NSCA ANALYSIS Methd/Reults           Method/Results
     ' MSo.ndoool Revised UFSAR Treatments                    SSA Drawings FIRE SAFETY ANALYSIS (DBD)
NSCA SUPPORTING INFO                                    On a Fire Area Basis
                                                                         - Fire Area Description T-H                  Feasibility                - FHA Database Information Manul      Acion
                                                                         -Nuclear Safety Performance Criteria Assessment                      Compliance Summary (NEI 04-02 8-3 Table Results)
* Non-Power Evaluations Results Summary
                                                                         - Radioactive Release Summary On a Generic Basis Siis                 i             Plan DBB      sthat               B-1 Table Results B
Calculations I/s MHlF Treatment                      uprNSCA                      - Radioactive Release Monitoring
* Monitoring Program Non-Power Mode NSCA Treatment FIRE PRA Plant Partitioning Non-Power Operations Analysis Component Selection Cable Selection
     -------------------------------------------------                          Qualitative Screening Fire Risk Model Ignition Frequencies NFPA 805 FIRE RISK EVALUATIONS Scoplng Fire Modeling t                                        Detailed Circuit Analysis Fire Risk Evalua ons)                                        Circuit Failure Likelihood Analysis
    ---------------------------------------------------                         Detailed Fire Modeling Fire HRA Seismic-Fire Interactions Quantification FHA DATA                                             Uncertainty Analysis end
                     ~         ~[bFPFeatures    SystemsData Calculations DealdData FHA SUPPORT DOCUMENTATION Bold text Indicates new NFPA 805 documents Code Compliance                   FP Drawings          i Evaluations     I                                                                              *SSEL includes the entire population of equipment FP Systems and En*gineering E   lecy
                                                                                                              / cables (NSCA, NPO, PRA)
Feature DBDs                     Equivalency Radioactive rans            Release Review Analysis L----------    ---------.-.---------------------------J.
Figure 4 NFPA 805 Planned Post-transition Documents and Relationships Page 54

Pacific Gas and Electric Comoanv                          4.0 Comiliance with NFPA 805 Requirements 4.7.2    Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 Program documentation established, revised, or utilized in support of compliance with 10 CFR 50.48(c) is subject to PG&E's configuration control processes that meet the requirements of Section 2.7.2 of NFPA 805. This includes the appropriate procedures and configuration control processes for ensuring that changes impacting the FP program are reviewed appropriately. The RI-PB post-transition change process methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, Revision 2, and RG 1.205, Revision 1. These requirements are summarized in Table 4-2.
Table 4-2 Change Evaluation Guidance Summary Table Document                        Section(s)                              Topic NFPA 805, 2001            2.2(h), 2.2.9, 2.4.4, A.2.2(h),            Change Evaluation Edition                      A.2.4.4, D.5 NEI 04-02, Revision        5.3, Appendix B, Appendix I,           Change Evaluation, Change 2                         Appendix J                   Evaluation Forms (Appendix I)
RG 1.205, Revision                                            Risk Evaluation, Standard License 1                 C.2.2.4, C.3.1, C.3.2, C.4.3         Condition, Change Evaluation Process, FPRA The Plant Change Evaluation Process consists of the following 4 steps and is depicted in Figure 4-10:
* Defining the Change
* Performing the Preliminary Risk Screening
* Performing the Risk Evaluation
* Evaluating the Acceptance Criteria Change Definition The Change Evaluation process begins by defining the change or altered condition to be examined and the baseline configuration as defined by the Licensing Basis (NFPA 805 Licensing Basis post-transition):
: 1. The baseline is defined as that plant condition or configuration that is consistent with the Licensing Basis (NFPA 805 Licensing Basis post-transition).
: 2. The changed or altered condition or configuration that is not consistent with the Licensing Basis is defined as the proposed alternative.
Preliminary Risk Review Once the definition of the change is established, a screening is then performed to identify and resolve minor changes to the FP program. This screening is consistent with FP regulatory review processes in place at nuclear plants under traditional licensing bases. This screening process is modeled after the NEI 02-03 process. This process will address most administrative changes (e.g., changes to the combustible control program, organizational changes, etc.).
The characteristics of an acceptable screening process that meets the "assessment of the acceptability of risk" requirement of Section 2.4.4 of NFPA 805 are:
Page 55

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* The quality of the screen is sufficient to ensure that potentially greater than minimal risk increases receive detailed risk assessments appropriate to the level of risk.
* The screening process must be documented and be available for inspection by the NRC.
* The screening process does not pose undue evaluation or maintenance burden.
If any of the above is not met, proceed with the Risk Evaluation step.
Risk Evaluation The screening is followed by engineering evaluations that may include fire modeling and risk assessment techniques. The results of these evaluations are then compared to the acceptance criteria. Changes that satisfy the acceptance criteria of NFPA 805 Section 2.4.4 and the license condition can be implemented within the framework provided by NFPA 805. Changes that do not satisfy the acceptance criteria cannot be implemented within this framework. The acceptance criteria require that the resultant change in CDF and LERF be consistent with the license condition. The acceptance criteria also include consideration of DID and safety margin, which would typically be qualitative in nature.
The risk evaluation involves the application of fire modeling analyses and risk assessment techniques to obtain a measure of the changes in risk associated with the proposed change. In certain circumstances, an initial evaluation in the development of the risk assessment could be a simplified analysis using bounding assumptions provided the use of such assumptions does not unnecessarily challenge the acceptance criteria discussed below.
Acceptability Determination The Change Evaluations are assessed for acceptability using the ACDF (change in core damage frequency) and ALERF (change in large early release frequency) criteria from the license condition. The proposed changes are also assessed to ensure they are consistent with the DID philosophy and that sufficient safety margins were maintained.
Page 56

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No Figure 4-10 Plant Change Evaluation [NEI 04-02 Figure 5-1]
Note references in Figure refer to NEI 04-02 Sections Page 57

Pacific t-aa and   Electric Cn nanu                         (nmniance 0 Co             ith NFPA 805R RenIuire   nts f~mn~4 F~gir~tig &#xa3;c P~i~Iii~         mn4 The DCPP Fire Protection Program configuration is defined by the program documentation. To the greatest extent possible, the existing configuration control processes for modifications, calculations and analyses, and Fire Protection Program (FPP) License Basis Impact Reviews will be utilized to maintain configuration control of the FP program documents. The configuration control procedures which govern the various DCPP documents and databases that currently exist will be revised to reflect the new NFPA 805 licensing bases requirements.
Specifically, changes affecting the design, operation, or maintenance of the plant are performed in accordance with program directive CF3, "Design Control" (Reference 6.68). Specific procedures within the CF3 program (such as CF3.1D4, "Design Calculations," Reference 6.69, or CF3.1D9, "Design Change Development," Reference 6.65) ensure that reviews are performed to determine if plant changes impact the fire protection program documentation. These procedures will be revised to reflect the requirements of NFPA 805. This will be done by including screening questions specifically related to attributes that may impact NFPA 805, which will lead to a more detailed review performed by qualified fire protection, safe shutdown, and PRA personnel. This will be completed as part of LAR implementation (see Attachment S, Table S-3, Item S-3.22). Plant changes made during the transition period will be evaluated under these processes to provide assurance that they are appropriately integrated into the NFPA 805 Program and FPRA. Additionally, following completion of the configuration control process revisions described in Attachment S, Table S-3, Item S-3.22, recent plant changes will be reviewed to ensure that all plant changes are properly screened for impact to the NFPA 805 Program and the FPRA.
NFPA 805 documents will be controlled under existing DCPP configuration control processes and procedures. For example, the NSCA Database will be controlled as a design input to the NSCA in accordance with configuration control procedures contained within program directive CF3. All evaluations generated by vendors as part of the transition to NFPA area accepted by PG&E under DCPP Procedure CF3.1D17, "Design and Analysis Documents Prepared by External Contractors" (Reference 6.70), which ensures compliance with applicable quality requirements. The update of system level design basis documents to reflect the NFPA 805 role that the system components now play will be completed as part of LAR implementation (see Attachment S, Table S-3, Item S-3.21).
Revisions to documents described above, and revisions to other supporting documents (such as procedures contained within program directive OM8, "Fire Protection Program",
Reference 6.71), will in general require training to plant staff on revised requirements and expectations. This training will be developed as directed by ADI.ID2, "Procedure Process Control" (Reference 6.66), OM15.1D2, "Change Management" (Reference 6.74), and the Systematic Approach to Training described and proceduralized within program directive TQ2, "Accredited Training Programs" (Reference 6.72).
The process for capturing the impact of proposed changes to the plant on the FP Program will continue to be a multiple step review. The first step of the review is an initial screening for process users to determine if there is a potential to impact the FP program as defined under NFPA 805 through a series of screening questions/checklists contained in one or more procedures depending upon the configuration control process being used. Reviews that identify potential FP program impacts will be sent to qualified individuals (Fire Protection, Safe Shutdown/NSCA, and/or FPRA) to ascertain the program impacts, if any. If FP program impacts are determined to exist as a result of the proposed change, the issue would be resolved by one of the following:
* Deterministic Approach: Comply with NFPA 805, Chapter 3 and Section 4.2.3 requirements Page 58

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                                                                                  ~   l. N.**C d ltii UI PB Approach: Utilize the NFPA 805 change process developed in accordance with NEI 04-02, Revision 2, RG 1.205, Revision 1, and the DCPP NFPA 805 FP license condition to assess the acceptability of the proposed change. This process would be used to determine if the proposed change could be implemented "as-is" or whether prior NRC approval of the proposed change is required.
This process follows the requirements in NFPA 805 and the guidance outlined in RG 1.174, Revision 2, which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered.
4.7.3         Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 Fire Protection Program Quality During the transition to 10 CFR 50.48(c), PG&E performed work in accordance with the quality requirements of Section 2.7.3 of NFPA 805. Following transition, the existing Fire Protection Quality Assurance (QA) program will be maintained, with the addition of:
* Components and systems considered within the scope of the Fire Protection QA Program will be revised to ensure all of those components and systems required for compliance with NFPA 805.
* QA audit requirements will be evaluated for revision to include the periodic review of the
            ,Monitoring Program.
FPRA Quality Configuration control of the FPRA model will be maintained by integrating the FPRA model into the existing processes used to ensure configuration control of the internal events PRA model.
This process, which is discussed in DCPP Procedure TS3.NR1, complies with ASME/ANS RA-Sa-2009 Section 1-5 and ensures that PG&E maintains an as-built, as-operated PRA model of the plant. The process has been peer reviewed. FPRA quality is assured via the same processes applied to the internal events model.
This process follows the guidance outlined in RG 1.174, Revision 2, which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered. Although the entire scope of the formal 10 CFR 50 Appendix B program is not applied to the PRA models or processes in general, often parts of the program are applied as a convenient method of complying with the requirements of RG 1.174, Revision 2. For instance, DCPP procedure OM7.1D13, "Technical Evaluations" (Reference 6.73), which addresses appropriate review of evaluations for 10 CFR 50, Appendix B, is applied to the PRA model calculations, as well.
With respect to QA Program requirements for independent reviews of calculations and evaluations, those existing requirements for FPP documents will remain unchanged. PG&E specifically requires that the calculations and evaluations in support of the NFPA 805 LAR, exclusive of the FPRA, be performed within the scope of the QA program which requires independent review as defined by DCPP Procedures CF3.1D4 and CF3.1D15, "Development and Independent Verification of Calculations" (Reference 6.1). As recommended by NUREG/CR-6850, the sources of uncertainty in the FPRA were identified and specific parameters were analyzed for sensitivity.
Page 59

Pacific Gas and Electric ComDanv                       4.0 Compliance with NFPA 805 Requirements Specifically with regard to uncertainty, an uncertainty and sensitivity matrix was developed and included with Calculation File No. F.3.15, Uncertainty and Sensitivity Analysis, Revision 1, dated November 30, 2010. In addition, sensitivity to uncertainty associated with specific FPRA parameters was quantitatively addressed in the same calculation.
While the removal of conservatism inherent in the FPRA is a long-term goal, the FPRA results were deemed sufficient for evaluating the risk associated with this application. While PG&E continues to strive toward a more "realistic" estimate of fire risk, use of mean values continues to be the best estimate of fire risk. During the FRE process, the uncertainty and sensitivity associated with specific FPRA parameters were considered in the evaluation of the change in risk relative to the applicable acceptance thresholds.
Specific Requirements of NFPA 805 Section 2.7.3 The following discusses how the requirements of NFPA 805 Section 2.7.3 are met both for the NFPA 805 transition and for future revisions to or generation of NFPA 805 related analyses, calculations, or evaluations.
NFPA 805 Section 2.7.3.1 - Review Analyses, calculations, and evaluations performed in support of compliance with 10 CFR 50.48(c) are performed in accordance with PG&E procedures that require independent review. These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements.
NFPA 805 Section 2.7.3.2 - Verification and Validation Calculational models and numerical methods used in support of compliance with 10 CFR 50.48(c) were verified and validated as required by Section 2.7.3.2 of NFPA 805.
These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements.
NFPA 805 Section 2.7.3.3 - Limitations of Use Engineering methods and numerical models used in support of compliance with 10 CFR 50.48(c) were applied appropriately as required by Section 2.7.3.3 of NFPA 805.
These activities are controlled by program directive CF3 and other procedures that include appropriate review requirements.
NFPA 805 Section 2.7.3.4 - Qualification of Users Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805.
During the transition to 10 CFR 50.48(c), work was and will be performed in accordance with the quality requirements of Section 2.7.3 of NFPA 805. Personnel who have and will use and apply engineering analysis and numerical methods (e.g., fire modeling) in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by NFPA 805, Section 2.7.3.4.
Post-transition, for personnel performing fire modeling or FPRA development and evaluation, PG&E will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805, Section 2.7.3.4 to perform assigned work (see Attachment S, Table S-3, Item S-3.23).
Page 60

Pacific Gas and Electric Comnanv                       4.0 Compliance with NFPA 805 Requirements NFPA 805 Section 2.7.3.5 - Uncertainty Analysis Uncertainty analyses were performed as required by Section 2.7.3.5 of NFPA 805 and the results were considered in the context of the application. This is of particular interest in fire modeling and FPRA development. Note: 10 CFR 50.48(c)(2)(iv) states that NFPA 805, Section 2.7.3.5 is not required for the deterministic approach because conservatism is included in the deterministic criteria.
Uncertainty evaluations for the various tasks used to develop the FPRA model (specifically those outlined in NUREG/CR-6850) were completed. The uncertainty analyses are contained in Calculation File No. F.3.15, Uncertainty and Sensitivity Analysis, Revision 1, dated November 30, 2010. Current and future FPRA model updates will also include uncertainty evaluations.
4.8     Summary of Results 4.8.1   Results of the Fire Area Review A summary of the NFPA 805 compliance basis and the required FP systems and features is provided in Table 4-3. The table provides the following information from the NEI 04-02, Revision 2, Table B-3:
     "  Fire Area / Fire Zone: Fire Area/Zone Identifier.

== Description:==
Fire Area/Zone Description.
* NFPA 805 Regulatory Basis: Post-transition NFPA 805 Chapter 4 compliance basis (Note: Compliance is determined on a Fire Area basis therefore a compliance basis is not provided for individual fire zones.)
     "  Required FP System / Feature: Detection / suppression required in the Fire Area based on NFPA 805 Chapter 4 compliance. Other Required Features may include Electrical Raceway Fire Barrier Systems, fire barriers, etc. The documentation of required FP systems and features does not include the documentation of the Fire Area boundaries.
Fire area boundaries are required and documentation of the Fire Area boundaries has been performed as part of reviews of engineering evaluations, licensing actions, or as part of the reviews of the NEI 04-02, Revision 2, Table B-1 process. The basis for the requirement of the FP system / feature is designated as follows:
        " S - Separation Criteria: Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3
* L -Licensing Action Criteria: Systems/Features required for acceptability of an NRC approved Licensing Action (i.e., Exemptions/Deviations/Safety Evaluations)
(Section 2.2.7)
        " E - EEEE: Systems/Features required for acceptability of Existing Engineering Equivalency Evaluations (Section 2.2.7)
        "   R - Risk Criteria: Systems/Features required to meet the Risk Criteria for the PB Approach (Section 4.2.4)
* D - Defense-in-depth Criteria: Systems/Features required to maintain adequate balance of DID for a PB Approach (Section 4.2.4)
Attachment W contains the results of the FREs, additional risk of recovery actions, and the change in risk on a Fire Area basis.
Page 61

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i *&#xfd;./ Hs I   II I 4.8.2         Plant Modifications and Items to be Completed During the Implementation Phase Planned modifications, studies, and evaluations to comply with NFPA 805 are described in Attachment S. Table S-1 summarizes plant modifications that have already been implemented.
Table S-2 summarizes plant modifications that are committed for implementation. Table S-3 provides a list of those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of the new NFPA 805 FP Program at DCPP.
PG&E did not identify any: (1) known outstanding plant changes that would require a change to the FPRA model, or (2) any planned plant changes that would significantly impact the PRA model, beyond those identified and scheduled to be implemented as part of the transition to the 10 CFR 50.48(c) FPP, as set forth in the license condition.
The FPRA model represents the as-built, as-operated and maintained plant as it will be configured at the completion of the transition to NFPA 805. The FPRA model includes credit for the planned implementation of the modifications listed in Attachment S. Following completion of the modifications listed in Attachment S, additional refinements surrounding the modifications may need to be incorporated into the FPRA model. These changes are not expected to be significant and will likely result in additional risk improvement in areas where limited credit for the proposed modifications was taken. Verification of the validity of the reported change-in-risk upon completion of all modifications listed in Table S-2 of Attachment S is tracked by implementation item S-3.24 (see Attachment S, Table S-3), Item S-3.24. Any changes necessary will be evaluated by the same process used in Attachments G and W of this submittal.
Although the design details for the modifications listed in Table S-2 of Attachment S have not yet been finalized, all are active plant modification projects currently in the engineering design phase per CF4, "Modification Control" (Reference 6.64), and CF3.1D9. This section provides preliminary design information, and is presented for information.
4.8.2.1 Incipient Detection System Installation This modification will improve PG&E's ability to detect incipient fires in the Cable Spreading Room (CSR) and Solid State Protection System (SSPS) rooms (for both Units 1 and 2),
resulting in a reduction of risk that a fire will start. This modification provides an improvement in CDF and LERF for both Units.
This modification has been modeled and will be designed and installed in accordance with the guidance provided in FAQ 08-0046. Specifically, incipient fire detection is being installed and credited in in-cabinet installations in locations that are not continuously occupied. The modification will be installed per the requirements of NFPA 72, "National Fire Alarm and Signaling Code" and NFPA 76, "Standard for the Fire Protection of Telecommunications Facilities", as described in FAQ 08-0046. Other design details will satisfy other FAQ 08-0046 and Code/Standard requirements such as alert and alarm sensitivity, acceptance testing, aspiration, equipment voltage restrictions, and fast-versus-slow fire growth components.
Additionally, Equipment Control Guidelines (ECGs) will be revised as necessary to define and control compensatory measures to address the unavailability/inoperability of incipient fire detection equipment, as required in CF3.1D9 and AD1.ID2. Finally, incipient fire detection equipment will be incorporated into the DCPP NFPA 805 Monitoring Program.
The FPRA currently incorporates this modification by using the guidance in FAQ 08-0046 and other accepted methods as discussed in Section 4.5 of this LAR.
Page 62

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This modification is not required to satisfy the deterministic requirements of 10 CFR 50, Appendix R.
4.8.2.2 Hot Shutdown Panel Modifications This modification will ensure that required hot shutdown panel (HSDP) functions are independent and electrically isolated from the Main Control Room (MCR) or Cable Spreading Room (CSR) (and the converse), which will allow for achievement of performance criteria in the case of a fire in the MCR or CSR areas for both Units. Connections/interconnections with safety-related plant systems will not cause a reduction in the capability, redundancy, diversity or design margin for those systems. This modification provides an improvement in ACDF and ALERF for both Units.
To ensure Decay Heat Removal and Inventory and Pressure Control capabilities are available in the case of a fire in the MCR or CSR, the Hot Shutdown Panel for each Unit will be modified as necessary to provide the following functions:
      " Control of 10 percent Steam Dump Valves MS-1(2)-PCV-21 and 22,
      " Open/close control and position indications for Refueling Water Storage Tank (RWST) to Charging Pump Suction Header Valve SI-1 (2)-8805A,
      " Open/close control and position indications for Cold Leg Loop Charging Valves CVCS-1(2)-8107 and CVCS-1 (2)-8108 (valves are in series),
      " Open/close control and position indications for charging to Cold Leg Loop Valve CVCS-1(2)-8146 to Loop 4,
      " Steam Generator 3 and 4 level indication,
* Pressurizer level indication, and
      " RCS hot and cold leg temperature indication.
The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR.
Because this modification is required to satisfy the requirements of both NFPA 805 and 10 CFR 50, Appendix R, compensatory measures are in place and will remain in place until this modification is implemented.
4.8.2.3 RCP Seal Cooling Modification This modification will reduce the risk of a loss of coolant accident (LOCA) resulting from a loss of RCP seal cooling for both Units 1 and 2. This modification does not resolve any VFDRs and is therefore considered to be "beyond compliance". However, it provides an improvement in CDF and LERF for both Units.
The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR.
This modification is required to satisfy the performance-based requirements of NFPA 805.
Compensatory measures are currently in place under 10 CFR 50, Appendix R to mitigate the potential for loss of RCP Seal Cooling as a result of a fire. For both of these reasons, compensatory measures will remain in place until this modification and the NFPA 805 Program are implemented.
Page 63

Pacific Gas and Electric Comnanv                       4.0 Comnliance with NFPA 805 Renuirements 4.8.2.4 Electrical Raceway Fire Barrier System (ERFBS) Installation This modification will eliminate the need for a Recovery Action associated with ensuring decay heat removal capability is maintained in the event of a fire in Fire Area 3-BB, 115 foot elevation.
This modification provides an improvement in ACDF and ALERF for Unit 1.
The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR.
This modification is not required to satisfy the deterministic requirements of 10 CFR 50, Appendix R, but is intended to reduce the additional risk associated with requiring a Recovery Action in the case of a fire in Fire Area 3-BB. Therefore, no compensatory measures are in place.
4.8.2.5 Cable Re-Route This modification will eliminate the need for a Recovery Action associated with ensuring steam is available to the TDAFW pump, thus reducing the risk of a loss of decay heat removal capability. This modification provides an improvement in ACDF and ALERF for Unit 2.
This modification is installed to eliminate VFDRs from Fire Areas 5-B-4 and 6-B-4 in Unit 2 that could result in a loss of steam to the TDAFW pump.
The FPRA currently incorporates this modification by using accepted methods as discussed in Section 4.5 of this LAR.
Because this modification is required to satisfy the requirements of both NFPA 805 and 10 CFR 50, Appendix R, compensatory measures are in place and will remain in place until this modification is implemented.
4.8.3    Supplemental Information - Other Licensee Specific Issues None Page 64

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Table 4-3 Legend:
* S - Separation Criteria: Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3
* L - Licensing Action Criteria: Systems/Features required for acceptability of an NRC approved Licensing Action (i.e.,
Exemptions/Deviations/Safety Evaluations)
* E - EEEE: Systems/Features required for acceptability of EEEEs
* R - Risk Criteria: Systems/Features required to meet the Risk Criteria for the PB Approach
* D - Defense-in-depth Criteria: Systems/Features required to maintain adequate balance of Defense-in-Depth for a PB Approach Note that the NFPA 805 Regulatory basis is identified once for each Fire Area.
Page 65

Pacific Gas and Electric Company                                                                4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                    Regulatory                                     Required?
Area     Zone      Description                      Basis                Type                S   L E R       D               Notes 1            Containment Building               4.2.4.2 1       1-A  Containment Annulus Area                     Detection - Smoke               N   N   Y   Y   Y 1       1-A  Containment Annulus Area                     Feature - Radiant Energy Shield N   N   Y   N   Y 1       1-A  Containment Annulus Area                     Suppression - None 1       1-B  Reactor Steam Generator Area                 Detection - Smoke               N   Y   Y   Y   Y 1       1-B  Reactor Steam Generator Area                 Feature - None 1       1-B  Reactor Steam Generator Area                 Suppression - Wet Pipe          N   Y   Y   Y   Y I       1-C  Reactor Cavity and Operating Deck            Detection - Flame               N   N   Y   Y   Y 1       1-C  Reactor Cavity and Operating Deck            Feature - None 1       1-C  Reactor Cavity and Operating Deck            Suppression - None 2            Auxiliary Boiler                   4.2.3.2 2        2   Auxiliary Boiler                             Detection - None 2        2   Auxiliary Boiler                             Feature - None 2        2   Auxiliary Boiler                             Suppression - Wet Pipe          N   N   N   N   N 3-B-I          RHR Pump 1-1 and Hx Room           4.2.4.2 3-B-1   3-B-1  RHR Pump 1-1 and Hx Room                     Detection - Smoke               N   N   Y   N   Y 3-B-1   3-B-1  RHR Pump 1-1 and Hx Room                     Feature - None 3-B-1   3-B-1  RHR Pump 1-1 and Hx Room                     Suppression - Water Spray       N   N   Y   N   Y Water spray in adjacent Fire Zone 3-B-3 protects door to Fire Zone 3-B-1.
Page 66

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 806 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone     Description                      Basis               Type             S    L E R       D                Notes 3-B-2          RHR Pump 1-2 and Hx Room          4.2.4.2 3-B-2   3-B-2  RHR Pump 1-2 and Hx Room                   Detection - Smoke            N    N   Y   N   Y 3-B-2   3-B-2  RHR Pump 1-2 and Hx Room                   Feature - None 3-B-2   3-B-2  RHR Pump 1-2 and Hx Room                   Suppression - Water Spray    N    N   Y   N   Y Water spray in adjacent Fire Zone 3-B-3 protects door to Fire Zone 3-B-2.
3-BB           Containment Penetration Area      4.2.4.2 3-BB     3-BB  Containment Penetration Area               Detection - Smoke            N    Y   Y   Y   Y 3-BB85.smoke detection not credited for risk 3-BB    3-BB   Containment Penetration Area               Feature - ERFBS              N    Y   Y   Y   Y 3-BB    3-BB   Containment Penetration Area               Suppression - Wet Pipe       N    Y   Y   Y   Y 3-BB85 auto suppression not provided 3-CC           Containment Penetration Area      4.2.4.2 3-CC    3-CC   Containment Penetration Area               Detection - Smoke            N    Y   Y   Y   Y 3-CC85 smoke detection not credited for risk 3-CC    3-CC   Containment Penetration Area               Feature - ERFBS              N    Y   Y   Y   Y 3-CC    3-CC   Containment Penetration Area               Suppression - Wet Pipe       N    Y   Y   Y   Y 3-CC85 auto suppression not provided 3-D-1           RHR Pump 2-1 and Hx Room          4.2.4.2 3-D-1   3-D-1  RHR Pump 2-1 and Hx Room                   Detection - Smoke            N    N   Y   N   Y 3-D-1   3-D-1  RHR Pump 2-1 and Hx Room                   Feature - None 3-D-1   3-D-1  RHR Pump 2-1 and Hx Room                   Suppression - Water Spray    N    N   Y   N   Y Water spray in adjacent Fire Zone 3-D-3 protects door to Fire Zone 3-D-1.
Page 67

Pacific Gas and Electric Company                                                                   4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                             Regulatory                               Required?
Area     Zone     Description                                 Basis               Type          S   L E R       D              Notes 3-D-2          RHR Pump 2-2 and Hx Room                     4.2.4.2 3-D-2   3-D-2  RHR Pump 2-2 and Hx Room                              Detection - Smoke         N   N   Y   N   Y 3-D-2   3-D-2  RHR Pump 2-2 and Hx Room                              Feature - None 3-D-2   3-D-2  RHR Pump 2-2 and Hx Room                              Suppression - Water Spray N   N   Y   N   Y Water spray in adjacent Fire Zone 3-D-3 protects door to Fire Zone 3-D-2.
3-H-1          Centrifugal Charging Pumps 1-1               4.2.3.2 and 1-2 Room 3-H-1   3-H-1  Centrifugal Charging Pumps 1-1 and 1-2 Room           Detection - Smoke         N   N   Y   N   N 3-H-1   3-H-1  Centrifugal Charging Pumps 1-1 and 1-2 Room           Feature - None 3-H-1   3-H-1  Centrifugal Charging Pumps 1-1 and 1-2 Room           Suppression -Water Spray  N   N   Y   N   N 3-H-1   3-H-1  Centrifugal Charging Pumps 1-1 and 1-2 Room           Suppression -Wet Pipe     N   N   Y   N   N 3-H-2          Centrifugal Charging Pump 1-3                4.2.3.2 Room 3-H-2   3-H-2  Centrifugal Charging Pump 1-3 Room                    Detection - Smoke         N   N   Y   N   N 3-H-2   3-H-2  Centrifugal Charging Pump 1-3 Room                    Feature - None 3-H-2   3-H-2  Centrifugal Charging Pump 1-3 Room                    Suppression- Wet Pipe     N   N   Y   N   N Page 68

Pacific Gas and Electric Company                                                                   4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                             Regulatory                               Required?
Area     Zone      Description                                Basis               Type          S   L E R       D           Notes 3-1-1          Centrifugal Charging Pumps 2-1               4.2.3.2 and 2-2 Room 3-1-1   3-1-1 Centrifugal Charging Pumps 2-1 and 2-2 Room           Detection - Smoke         N   N   Y   N   N 3-1-1   3-1-1 Centrifugal Charging Pumps 2-1 and 2-2 Room           Feature - None 3-1-1   3-1-1 Centrifugal Charging Pumps 2-1 and 2-2 Room           Suppression - Water Spray N   N   Y   N   N 3-1-1   3-1-1 Centrifugal Charging Pumps 2-1 and 2-2 Room           Suppression - Wet Pipe    N   N   Y   N   N 3-1-2          Centrifugal Charging Pump 2-3                4.2.3.2 Room 3-1-2   3-1-2 Centrifugal Charging Pump 2-3 Room                    Detection - Smoke         N   N   Y   N   N 3-1-2   3-1-2 Centrifugal Charging Pump 2-3 Room                    Feature - None 3-1-2   3-1-2 Centrifugal Charging Pump 2-3 Room                    Suppression - Wet Pipe    N   N   Y   N   N 3-P-1          HVAC, Filters, Fans                          4.2.3.2 3-P-1   3-P-1  HVAC, Filters, Fans                                   Detection - Smoke         N   N   N   N   N 3-P-1   3-P-1  HVAC, Filters, Fans                                   Feature- None 3-P-1   3-P-1  HVAC, Filters, Fans                                   Suppression - None 3-P-5          HVAC, Filters, Fans                          4.2.3.2 3-P-5   3-P-5  HVAC, Filters, Fans                                   Detection - None 3-P-5   3-P-5  HVAC, Filters, Fans                                   Feature-None 3-P-5   3-P-5  HVAC, Filters, Fans                                   Suppression - None Page 69

0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone     Description                      Basis               Type             S    L E R       D           Notes 3-P-12          HVAC, Filters, Fans               4.2.3.2 3-P-12   3-P-12 HVAC, Filters, Fans                        Detection - None 3-P-12   3-P-12 HVAC, Filters, Fans                        Feature- None 3-P-12   3-P-12 HVAC, Filters, Fans                        Suppression - None 3-Q-1           Auxiliary Feedwater Pump Room     4.2.4.2 3-Q-1   3-Q-1  Auxiliary Feedwater Pump Room              Detection - Smoke            N    N   Y   N   Y 3-Q-1   3-Q-1  Auxiliary Feedwater Pump Room              Feature - None 3-Q-1   3-Q-1  Auxiliary Feedwater Pump Room              Suppression  - Wet Pipe      N    N   Y   N   Y 3-T-1          Auxiliary Feedwater Pump Room     4.2.4.2 3-T-1    3-T-1 Auxiliary Feedwater Pump Room              Detection - Smoke            N    N   Y   N   Y 3-T-1    3-T-1 Auxiliary Feedwater Pump Room              Feature - None 3-T-1    3-T-1 Auxiliary Feedwater Pump Room              Suppression - Wet Pipe       N    N   Y   N   Y 3-V-1          HVAC, Filters, Fans               4.2.3.2 3-V-1   3-V-1  HVAC, Filters, Fans                        Detection - Smoke            N    N   N   N   N 3-V-1   3-V-1  HVAC, Filters, Fans                        Feature- None 3-V-1   3-V-1  HVAC, Filters, Fans                        Suppression - None Page 70

P Pacific Gas and Electric Company 0                                                        0 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone     Description                     Basis                Type             S    L E R       D           Notes 3-V-5          HVAC, Filters, Fans              4.2.3.2 3-V-5    3-V-5 HVAC, Filters, Fans                        Detection - Smoke            N    N   N   N   N 3-V-5    3-V-5 HVAC, Filters, Fans                        Feature-None 3-V-5    3-V-5 HVAC, Filters, Fans                        Suppression  - None 3-V-12          HVAC, Filters, Fans              4.2.3.2 3-V-12   3-V-12 HVAC, Filters, Fans                        Detection - None 3-V-12   3-V-12 HVAC, Filters, Fans                        Feature- None 3-V-12   3-V-12 HVAC, Filters, Fans                        Suppression  - None 4-A-1          G Bus Compartment                4.2.4.2 4-A-1   4-A-1  G Bus Compartment                          Detection - Smoke            N    N   Y   N   Y 4-A-1   4-A-1  G Bus Compartment                          Feature - None 4-A-1   4-A-1  G Bus Compartment                          Suppression - None 4-A-2          H Bus Compartment                4.2.4.2 4-A-2   4-A-2  H Bus Compartment                          Detection - Smoke            N    N   Y   N   Y 4-A-2   4-A-2  H Bus Compartment                          Feature- None 4-A-2   4-A-2  H Bus Compartment                          Suppression - None Page 71

0                                                           0 Pacific Gas and Electric Company                                                               4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                     Required?
Area     Zone      Description                      Basis               Type                S   L E R       D           Notes 4-A (U1)         Counting and Chemical              4.2.4.2 Laboratory 4-A (Ul)  4-A   Counting and Chemical Laboratory            Detection - Smoke               N   Y   Y   Y   Y 4-A (Ul)   4-A  Counting and Chemical Laboratory            Feature - Radiant Energy Shield N   Y   Y   N   Y 4-A (Ul)  4-A   Counting and Chemical Laboratory            Feature - ERFBS                 N   Y   Y   N   Y 4-A (Ul)  4-A   Counting and Chemical Laboratory            Suppression -Wet Pipe           N   Y   Y   Y   Y 4-A (g2)         Counting and Chemical              4.2.3.2 Laboratory 4-A (U2)  4-A   Counting and Chemical Laboratory            Detection - Smoke               N   Y   Y   N   N 4-A (U2)  4-A   Counting and Chemical Laboratory            Feature - ERFBS                 N   Y   Y   N   N 4-A (U2)  4-A   Counting and Chemical Laboratory            Feature - Radiant Energy Shield N   Y   Y   N   N 4-A (U2)  4-A   Counting and Chemical Laboratory            Suppression - Wet Pipe          N   Y   Y   N   N 4-B-1          G Bus Compartment                 4.2.4.2 4-B-1  4-B-1  G Bus Compartment                           Detection - Smoke               N   N   Y   N   Y 4-B-1  4-B-1  G Bus Compartment                           Feature - None 4-B-1  4-B-1  G Bus Compartment                           Suppression - None 4-B-2          H Bus Compartment                 4.2.4.2 4-B-2  4-B-2  H Bus Compartment                           Detection - Smoke               N   N   Y   N   Y 4-B-2  4-B-2  H Bus Compartment                           Feature - None 4-B-2  4-B-2  H Bus Compartment                           Suppression - None Page 72

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                       Regulatory                               Required?
Area     Zone      Description                          Basis               Type         S    L E R       D           Notes 4-B (UI)         Showers, Lockers, and Access           4.2.4.2 Control 4-B (Ul)   4-B  Showers, Lockers, and Access Control            Detection - Smoke        N    Y   Y   Y   Y 4-B (U1)   4-B  Showers, Lockers, and Access Control            Feature - ERFBS          N    Y   Y   N   Y 4-B (U1)   4-B  Showers, Lockers, and Access Control            Suppression - Wet Pipe   N    Y   Y   Y   Y 4-B (U2)         Showers, Lockers, and Access          4.2.4.2 Control 4-B (U2)  4-B   Showers, Lockers, and Access Control            Detection - Smoke        N    Y   Y   Y   Y 4-B (U2)  4-B   Showers, Lockers, and Access Control            Feature - ERFBS          N    Y   Y   N   Y 4-B (U2)  4-B   Showers, Lockers, and Access Control            Suppression - Wet Pipe   N    Y   Y   Y   Y 5-A-1          480V Vital Switchgear, F Bus          4.2.4.2 5-A-1  5-A-1  480V Vital Switchgear, F Bus                    Detection - Smoke        N    N   Y   Y   Y 5-A-1  5-A-1  480V Vital Switchgear, F Bus                    Feature - None 5-A-1  5-A-1  480V Vital Switchgear, F Bus                    Suppression - None 5-A-2          480V Vital Switchgear, G Bus          4.2.4.2 5-A-2  5-A-2  480V Vital Switchgear, G Bus                    Detection - Smoke        N    N   Y   Y  Y 5-A-2  5-A-2  480V Vital Switchgear, G Bus                    Feature - None 5-A-2  5-A-2  480V Vital Switchgear, G Bus                    Suppression - None Page 73

0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                            Regulatory                         Required?
Area     Zone     Description                               Basis                Type   S    L E R       D            Notes 5-A-3          480V Vital Switchgear, H Bus               4.2.4.2 5-A-3   5-A-3  480V Vital Switchgear, H Bus                         Detection - Smoke  N    N   Y   Y   Y 5-A-3   5-A-3  480V Vital Switchgear, H Bus                         Feature - None 5-A-3   5-A-3  480V Vital Switchgear, H Bus                         Suppression - None 5-A-4          480V Non-vital Switchgear and              4.2.4.2 Hot Shutdown Panel 5-A-4   5-A-4  480V Nonvital Switchgear and Hot Shutdown            Detection - Smoke  N    N   Y   Y   Y Panel 5-A-4   5-A-4  480V Nonvital Switchgear and Hot Shutdown            Feature - ERFBS    N    N   Y   Y   Y Panel 5-A-4   5-A-4  480V Nonvital Switchgear and Hot Shutdown            Suppression - None Panel 5-B-1          480V Vital Switchgear, F Bus               4.2.4.2 5-B-1   5-B-1  480V Vital Switchgear, F Bus                         Detection - Smoke  N    N   Y   Y   Y 5-B-1   5-B-1  480V Vital Switchgear, F Bus                         Feature - None 5-B-1   5-B-1  480V Vital Switchgear, F Bus                         Suppression - None 5-B-2          480V Vital Switchgear, G Bus               4.2.4.2 5-B-2   5-B-2  480V Vital Switchgear, G Bus                         Detection - Smoke  N    N   Y   Y   Y 5-B-2   5-B-2  480V Vital Switchgear, G Bus                         Feature - None 5-B-2   5-B-2  480V Vital Switchgear, G Bus                         Suppression - None Page 74

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                              Regulatory                        Required?
Area     Zone      Description                                Basis                Type   S   L E R       D           Notes 5-B-3          480V Vital Switchgear, H Bus                 4.2.4.2 5-B-3   5-B-3  480V Vital Switchgear, H Bus                           Detection - Smoke  N   N   Y   Y   Y 5-B-3   5-B-3  480V Vital Switchgear, H Bus                           Feature - None 5-B-3   5-B-3  480V Vital Switchgear, H Bus                           Suppression - None 5-B-4          480V Non-vital Switchgear and                4.2.4.2 Hot Shutdown Panel 5-B-4   5-B-4  480V Nonvital Switchgear and Hot Shutdown              Detection - Smoke  N   N   Y   Y   Y Panel 5-B-4   5-B-4  480V Nonvital Switchgear and Hot Shutdown              Feature - ERFBS    N   N   Y   Y   Y Panel 5-B-4   5-B-4  480V Nonvital Switchgear and Hot Shutdown              Suppression - None Panel 6-A-1          Battery, Inverter, and DC                    4.2.4.2 Switchgear, F Bus 6-A-1   6-A-1  Battery, Inverter, and DC Switchgear, F Bus            Detection - Smoke  N   N   Y   Y   Y 6-A-1   6-A-1  Battery, Inverter, and DC Switchgear, F Bus            Feature - None 6-A-1   6-A-1  Battery, Inverter, and DC Switchgear, F Bus            Suppression - None 6-A-2          Battery, Inverter, and DC                    4.2.4.2 Switchgear, G Bus 6-A-2   6-A-2  Battery, Inverter, and DC Switchgear, G Bus            Detection - Smoke  N   N   Y   Y   Y 6-A-2   6-A-2  Battery, Inverter, and DC Switchgear, G Bus            Feature - None 6-A-2   6-A-2  Battery, Inverter, and DC Switchgear, G Bus            Suppression - None Page 75

S                                                                       S Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                               Regulatory                        Required?
Area     Zone      Description                                Basis                Type   S   L E R       D           Notes 6-A-3          Battery, Inverter, and DC                    4.2.4.2 Switchgear, H Bus 6-A-3   6-A-3  Battery, Inverter, and DC Switchgear, H Bus            Detection - Smoke  N   N   Y   Y   Y 6-A-3   6-A-3  Battery, Inverter, and DC Switchgear, H Bus            Feature - None 6-A-3   6-A-3  Battery, Inverter, and DC Switchgear, H Bus            Suppression - None 6-A-4          Reactor Trip Switchgear                      4.2.4.2 6-A-4   6-A-4  Reactor Trip Switchgear                                Detection - Smoke  N   N   Y   Y   Y 6-A-4   6-A-4  Reactor Trip Switchgear                                Feature - None 6-A-4   6-A-4  Reactor Trip Switchgear                                Suppression - None 6-A-5          Electrical Area                              4.2.4.2 6-A-5   6-A-5  Electrical Area                                        Detection - Smoke  N   N   Y   Y   Y 6-A-5   6-A-5  Electrical Area                                        Feature - None 6-A-5   6-A-5  Electrical Area                                        Suppression - None 6-B-1          Battery, Inverter, and DC                    4.2.4.2 Switchgear, F Bus 6-B-1   6-B-1  Battery, Inverter, and DC Switchgear, F Bus            Detection - Smoke  N   N   Y   Y   Y 6-B-1   6-B-1  Battery, Inverter, and DC Switchgear, F Bus            Feature - None 6-B-1   6-B-1  Battery, Inverter, and DC Switchgear, F Bus            Suppression - None Page 76

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                              Regulatory                        Required?
Area     Zone      Description                                 Basis               Type   S   L E R       D           Notes 6-B-2          Battery, Inverter, and DC                     4.2.4.2 Switchgear, G Bus 6-B-2   6-B-2  Battery, Inverter, and DC Switchgear, G Bus            Detection - Smoke  N   N   Y   Y   Y 6-B-2   6-B-2  Battery, Inverter, and DC Switchgear, G Bus            Feature - None 6-B-2   6-B-2  Battery, Inverter, and DC Switchgear, G Bus            Suppression - None 6-B-3          Battery, Inverter, and DC                    4.2.4.2 Switchgear, H Bus 6-B-3   6-B-3  Battery, Inverter, and DC Switchgear, H Bus            Detection - Smoke  N   N   Y   Y   Y 6-B-3   6-B-3  Battery, Inverter, and DC Switchgear, H Bus            Feature - None 6-B-3   6-B-3  Battery, Inverter, and DC Switchgear, H Bus            Suppression - None 6-B-4          Reactor Trip Switchgear                      4.2.4.2 6-B-4   6-B-4  Reactor Trip Switchgear                                Detection - Smoke  N   N   Y   Y   Y 6-B-4   6-B-4  Reactor Trip Switchgear                                Feature - None 6-B-4   6-B-4  Reactor Trip Switchgear                                Suppression - None 6-B-5          Electrical Area                              4.2.4.2 6-B-5   6-B-5  Electrical Area                                        Detection - Smoke  N   N   Y   Y   Y 6-B-5   6-B-5  Electrical Area                                        Feature - None 6-B-5   6-B-5  Electrical Area                                        Suppression - None Page 77

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone     Description                     Basis                Type              S   L E R       D                Notes 7-A            Cable Spreading Room             4.2.4.2 7-A     7-A   Cable Spreading Room                       Detection - Smoke             N   N   Y   Y   Y 7-A     7-A   Cable Spreading Room                       Detection - Heat              N   N   Y   Y   Y 7-A     7-A   Cable Spreading Room                       Detection - Incipient - Smoke N   N   N   Y   Y Incipient detection to be installed. See Attachment S, Table S-2, Item S-2.4.
7-A     7-A   Cable Spreading Room                       Feature - None 7-A     7-A   CableSpreading Room                        Suppression - Automatic C02   N   N   Y   Y   Y 7-B            Cable Spreading Room             4.2.4.2 7-B     7-B   Cable Spreading Room                       Detection - Heat              N   N   Y   Y   Y 7-B     7-B   Cable Spreading Room                       Detection - Smoke             N   N   Y   Y   Y 7-B     7-B   Cable Spreading Room                       Detection - Incipient - Smoke N   N   N   Y   Y Incipient detection to be installed. See Attachment S, Table S-2, Item S-2.4.
7-B     7-B   Cable Spreading Room                       Feature - None 7-B     7-B   Cable Spreading Room                       Suppression - Automatic C02   N   N   Y   Y   Y 7-C            Communications Room              4.2.3.2 7-C     7-C   Communications Room                        Detection - None 7-C     7-C   Communications Room                        Feature - None 7-C     7-C   Communications Room                        Suppression -Automatic C02    N   N   N   N   N Page 78

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone     Description                      Basis               Type             S    L   E R     D               Notes 7-D           Communications Room               4.2.3.2 7-D     7-D   Communications Room                        Detection - None 7-D     7-D   Communications Room                        Feature - None 7-D     7-D   Communications Room                        Suppression - Automatic C02  N    N   N   N   N 8-G            Safeguards Room                   4.2.4.2 8-G     8-G   Safeguards Room                            Detection - Smoke            N    N   Y   Y   Y 8-G     8-G   Safeguards Room                            Detection - Incipient- Smoke N    N   N   Y   Y Incipient detection to be installed. See Attachment S, Table S-2, Item S-2.4.
8-G     8-G   Safeguards Room                            Feature - None 8-G     8-G   Safeguards Room                            Suppression - None 8-H            Safeguards Room                   4.2.4.2 8-H     8-H   Safeguards Room                            Detection - Smoke            N    N   Y   Y   Y 8-H     8-H   Safeguards Room                            Feature - None 8-H     8-H   Safeguards Room                            Suppression - None Page 79

S Pacific Gas and Electric Company                                                                       4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                            Regulatory                                     Required?
Area     Zone     Description                              Basis                Type                S   L E R       D           Notes 9            Containment Building                      4.2.4.2 9      9-A   Containment Annulus Area                            Detection - Smoke               N   N   Y   Y   Y 9      9-A   Containment Annulus Area                            Feature - Radiant Energy Shield N   N   Y   N   Y 9      9-A   Gontainment Annulus Area                            Suppression - None 9      9-B   Reactor Steam Generator Area                        Detection - Smoke               N   Y   Y   Y   Y 9      9-B   Reactor Steam Generator Area                        Feature - None 9      9-B   Reactor Steam Generator Area                        Suppression - Wet Pipe          N   Y   Y   Y   Y 9      9-C   Reactor Cavity and Operating Deck                   Detection - Flame               N   N   Y   Y   Y Feature - None 9      9-C   Reactor Cavity and Operating Deck 9      9-C   Reactor Cavity and Operating Deck                   Suppression - None 10            12kV Switchgear Room and                  4.2.4.2 Cable Spreading Room 10       10   12kV Switchgear Room and Cable Spreading            Detection - Smoke               N   N   Y   Y   Y Room 10       10   12kV Switchgear Room and Cable Spreading            Feature - ERFBS                 N   N   Y   Y   Y Room 10       10   12kV Switchgear Room and Cable Spreading            Suppression - None Room Page 80

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                          Regulatory                            Required?
Area     Zone     Description                              Basis               Type       S   L E R       D           Notes 11-D           Corridor Outside Diesel                   4.2.3.2 Generator Rooms 11-D     11-D  Corridor Outside Diesel Generator Rooms            Detection - None 11-D     11-D  Corridor Outside Diesel Generator Rooms            Feature - ERFBS        N   N   N   N   N 11-D     11-D  Corridor Outside Diesel Generator Rooms            Suppression - Wet Pipe N   N   Y   N   N 13-D           Excitation Switchgear Room               4.2.4.2 13-D     13-D  Excitation Switchgear Room                         Detection - Smoke      N   N   Y   Y   Y 13-D     13-D  Excitation Switchgear Room                         Feature - None 13-D     13-D  Excitation Switchgear Room                         Suppression - None 13-E           Switchgear Ventilation Fan Room          4.2.3.2 13-E     13-E  Switchgear Ventilation Fan Room                    Detection - Smoke      N   N   Y   N   N 13-E     13-E  Switchgear Ventilation Fan Room                    Feature - None 13-E     13-E  Switchgear Ventilation Fan Room                    Suppression - Wet Pipe N   N   Y   N   N 13-F           Storage Room                             4.2.3.2 13-F     13-F  Storage Room                                       Detection - None 13-F     13-F  Storage Room                                       Feature - None 13-F     13-F  Storage Room                                       Suppression - None Page 81

0 Pacific Gas and Electric Company 0                                           .0 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                          Regulatory                                 Required?
Area     Zone     Description                            Basis                Type            S   L E R       D           Notes 14-B           Clean and Dirty Lube Oil                4.2.3.2 14-B     14-B  Clean and Dirty Lube Oil                          Detection - None 14-B     14-B  Clean and Dirty Lube Oil                          Feature - None 14-B     14-B  Clean and Dirty Lube Oil                          Suppression - Wet Pipe      N   N   Y   N   N 15            Turbine Lube Oil Reservoir              4.2.3.2 15      15   Turbine Lube Oil Reservoir                        Detection - Heat            N   N   Y   N   N 15      15   Turbine Lube Oil Reservoir                        Feature - None 15      15   Turbine Lube Oil Reservoir                        Suppression - Automatic CO2 N   N   Y 'N    N 17            Warehouse (Operations Work              4.2.3.2 Control and Outage OCC Room) 17      17   Warehouse (Operations Work Control and            Detection - None Outage OCC Room) 17       17   Warehouse (Operations Work Control and            Feature - None Outage OCC Room) 17       17   Warehouse (Operations Work Control and            Suppression - Wet Pipe      N   N   N   N   N Outage OCC Room) 18            Turbine Lube Oil Reservoir              4.2.3.2 18      18   Turbine Lube Oil Reservoir                        Detection - Heat            N   N   Y   N   N 18      18   Turbine Lube Oil Reservoir                        Feature - None 18       18   Turbine Lube Oil Reservoir                        Suppression - Automatic C02 N   N   Y   N   N Page 82

Pacific Gas and Electric Company                                                              4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                            Regulatory                            Required?
Area     Zone     Description                              Basis                Type       S   L E R       D            Notes 20            12kV Switchgear Room and                  4.2.4.2 Cable Spreading Room 20       20   12kV Switchgear Room and Cable Spreading            Detection - Smoke      N   N   Y   Y   Y Room 20       20   12kV Switchgear Room and Cable Spreading            Feature - ERFBS        N   N   Y   Y   Y Room 20       20   12kV Switchgear Room and Cable Spreading            Suppression - None Room 22-C           Corridor Outside Diesel                   4.2.3.2 Generator Rooms 22-C     22-C  Corridor Outside Diesel Generator Rooms             Detection - None 22-C     22-C  Corridor Outside Diesel Generator Rooms             Feature - ERFBS        N   N   N   N   N 22-C     22-C  Corridor Outside Diesel Generator Rooms             Suppression - Wet Pipe N   N   Y   N   N 24-D           Excitation Switchgear Room                4.2.4.2 24-D    24-D   Excitation Switchgear Room                          Detection - Smoke      N   N   Y   Y   Y 24-D    24-D   Excitation Switchgear Room                          Feature - None 24-D    24-D   Excitation Switchgear Room                          Suppression - None 26            Chemical and Gaseous Storage              4.2.3.2 26       26   Chemical and Gaseous Storage                        Detection - None 26       26   Chemical and Gaseous Storage                        Feature - None 26       26   Chemical and Gaseous Storage                        Suppression - None Page 83

Pacific Gas and Electric Company                                                            4.0 Compliance with NIFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone     Description                      Basis               Type             S    L E R       D            Notes 27-A           Boxed Waste Zone                  4.2.3.2 27-A     27-A  Boxed Waste Zone                           Detection - None 27-A     27-A  Boxed Waste Zone                           Feature - None 27-A     27-A  Boxed Waste Zone                           Suppression - Wet Pipe       N    N   N   N   N 27-B           Drum Storage Zone                 4.2.3.2 27-B     27-B  Drum Storage Zone                          Detection - None 27-B     27-B  Drum Storage Zone                          Feature - None 27-B     27-B  Drum Storage Zone                          Suppression - Wet Pipe       N    N   N   N   N 27-C           Contaminated Oil Storage          4.2.3.2 27-C     27-C  Contaminated Oil Storage                   Detection - None 27-C     27-C  Contaminated Oil Storage                   Feature - None 27-C     27-C  Contaminated Oil Storage                   Suppression - Wet Pipe       N    N   N   N   N 28            Main Transformer Area             4.2.4.2 28       28   Main Transformer Area                      Detection - None 28       28   Main Transformer Area                      Feature - None 28       28   Main Transformer Area                      Suppression - Water Spray    N    N   Y   Y   Y Page 84

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                     Regulatory                                Required?
Area      Zone    Description                        Basis                Type          S    L E R       D            Notes 29           Main Transformer Area               4.2.4.2 29      29   Main Transformer Area                         Detection - None 29      29   Main Transformer Area                         Feature - None 29      29   Main Transformer Area                         Suppression - Water Spray N    N   Y   Y   Y 30-A-1          Auxiliary Saltwater Pump 1-1        4.2.4.2 Vault 30-A-1  30-A-1 Auxiliary Saltwater Pump 1-1 Vault            Detection - None 30-A-1  30-A-1 Auxiliary Saltwater Pump 1-1 Vault            Feature - None 30-A-1  30-A-1 Auxiliary Saltwater Pump 1-1 Vault            Suppression - None 30-A-2          Auxiliary Saltwater Pump 1-2        4.2.4.2
*Vault 30-A-2   30-A-2 Auxiliary Saltwater Pump 1-2 Vault            Detection - None 30-A-2   30-A-2 Auxiliary Saltwater Pump 1-2 Vault            Feature - None 30-A-2   30-A-2 Auxiliary Saltwater Pump 1-2 Vault            Suppression  - None 30-A-3          Auxiliary Saltwater Pump 2-1        4.2.4.2 Vault 30-A-3   30-A-3 Auxiliary Saltwater Pump 2-1 Vault            Detection - None 30-A-3   30-A-3 Auxiliary Saltwater Pump 2-1 Vault            Feature - None 30-A-3   30-A-3 Auxiliary Saltwater Pump 2-1 Vault            Suppression - None Page 85

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                     Regulatory                                Required?
Area     Zone      Description                        Basis               Type          S    L   E R     D           Notes 30-A-4          Auxiliary Saltwater Pump 2-2         4.2.4.2 Vault 30-A-4  30-A-4 Auxiliary Saltwater Pump 2-2 Vault            Detection - None 30-A-4  30-A-4 Auxiliary Saltwater Pump 2-2 Vault            Feature - None 30-A-4  30-A-4 Auxiliary Saltwater Pump 2-2 Vault            Suppression - None 33           Security Diesel Generator Room       4.2.3.2 33      33   Security Diesel Generator Room                Detection - Smoke         N    N   N   N   N 33      33   Security Diesel Generator Room                Feature - None 33      33   Security Diesel Generator Room                Suppression - Wet Pipe    N    N   N   N   N 34 (UM)         Auxiliary Building Roof             4.2.4.2 34 (Ul)    34   Auxiliary Building Roof                       Detection - None 34 (U1)    34   Auxiliary Building Roof                       Feature - None 34 (Ul)    34   Auxiliary Building Roof                       Suppression -Wet Pipe     N    N   Y   Y   Y 34 (U2)         Auxiliary Building Roof             4.2.4.2 34 (U2)    34   Auxiliary Building Roof                       Detection - None 34 (U2)    34   Auxiliary Building Roof                       Feature - None 34 (U2)    34   Auxiliary Building Roof                       Suppression - Wet Pipe    N    N   Y   Y   Y Page 86

0                         ..                                                                                         I*
Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                           Regulatory                           Required?
Area     Zone     Description                              Basis               Type     S    L E R       D           Notes 35-A           Diesel Fuel Oil Transfer Pump 0-1         4.2.3.2 Vault 35-A    35-A   Diesel Fuel Oil Transfer Pump 0-1 Vault            Detection - None 35-A    35-A   Diesel Fuel Oil Transfer Pump 0-1 Vault            Feature - None 35-A    35-A   Diesel Fuel Oil Transfer Pump 0-1 Vault            Suppression - None 35-B           Diesel Fuel Oil Transfer Pump 0-2         4.2.3.2 Vault 35-B    35-B   Diesel Fuel Oil Transfer Pump 0-2 Vault            Detection - None 35-B    35-B   Diesel Fuel Oil Transfer Pump 0-2 Vault            Feature - None 35-B    35-B   Diesel Fuel Oil Transfer Pump 0-2 Vault            Suppression - None Page 87

0                                                                                                                                      0 Pacific Gas and Electric Company                                                                       4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                                  Regulatory                               Required?
Area     Zone      Description                                    Basis               Type          S   L E R       D                Notes AB-1 (UI)        Auxiliary Building                               4.2.4.2 AB-1 (Ul)  3-A   Liquid Holdup Tank Area                                   Detection - None AB-1 (Ul)  3-A   Liquid Holdup Tank Area                                   Feature - None AB-1 (U1) 3-A    Liquid Holdup Tank Area                                   Suppression - None AB-1 (U1) 3-AA   Auxiliary Building Elevation 115 Feet                     Detection - Smoke         N   N   Y   N   Y AB-1 (Ul) 3-AA   Auxiliary Building Elevation 115 Feet                     Feature - None AB-1 (Ul) 3-AA   Auxiliary Building Elevation 115 Feet                     Suppression-Wet Pipe      N   N   Y   N   Y AB-1 (U1) 3-B-3  Boron Injection Tank                                      Detection - None AB-1 (U1) 3-B-3  Boron Injection Tank                                      Feature- None AB-1 (U1) 3-B-3  Boron Injection Tank                                      Suppression - Water Spray N   N   Y   N   Y *Fire door exemption (3-B-1 &
3-B-2) credits water spray.
Water spray is present in Fire Zone 3-B-3.
AB-1 (U1)  3-C   Auxiliary Building Elevation 54, 64, and 73 Feet          Detection - Smoke         N   Y   Y   N   Y AB-1 (U1)  3-C   Auxiliary Building Elevation 54, 64, and 73 Feet          Feature - ERFBS           N   Y   N   N   Y AB-1 (U1)  3-C   Auxiliary Building Elevation 54, 64, and 73 Feet          Suppression - None AB-1 (U1) 3-D-3  Boron Injection Tank                                      Detection - None AB-1 (U1) 3-D-3  Boron Injection Tank                                      Feature - None AB-1 (U1) 3-D-3  Boron Injection Tank                                      Suppression - Water Spray N   N   Y   N   Y *Fire door exemption (3-D-1 &
3-D-2) credits water spray.
Water spray is present in Fire Zone 3-D-3.
Page 88

Pacific Gas and Electric Company                                                                      4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire           Fire                                    Regulatory                                     Required?
Area           Zone       Description                      Basis                Type               S   L   E R     D           Notes AB-1 (UI)               Auxiliary Building                 4.2.4.2 AB-1 (U1)         3-F   Containment Spray Pumps                     Detection - Smoke               N   N   Y   N   Y AB-1 (Ul)         3-F   Containment Spray Pumps                     Feature- None AB-1 (U1)         3-F   Containment Spray Pumps                     Suppression - None AB-1 (Ul)         3-G   Containment Spray Pumps                     Detection - Smoke               h   Y   Y   N   Y ADAI    I   I1~    I,- r-n+oi--an  Q  -rr~DH- .mn                  P=Mtin -   tinna
   -D  kI Il 3-G   Containment Spray Pumps                     Suppression - None AB-1 (UI)        3-J-1  Component Cooling Water Pump 1-1            Detection - Smoke               N   Y   Y       Y AB-1 (Ul)        3-J-1  Component Cooling Water Pump 1-1            Feature - ERFBS                 N   Y   Y       Y AB-I (Ul)        3-J-1  Component Cooling Water Pump 1-1            Suppression - Wet Pipe          N   Y   Y       Y AB-1 (U1)        3-J-2  Component Cooling Water Pump 1-2            Detection - Smoke               N   Y   Y       Y AB-I (UI)        3-J-2  Component Cooling Water Pump 1-2            Feature - Radiant Energy Shield N   Y   Y       Y AB-i (Ul)        3-J-2  Component Cooling Water Pump 1-2            Suppression - Wet Pipe          N   Y   Y       Y AB-I (Ul)        3-J-3  Component Cooling Water Pump 1-3            Detection - Smoke               N   Y   Y       Y AB-i (Ul)        3-J-3  Component Cooling Water Pump 1-3            Feature - Radiant Energy Shield N   Y   Y       Y AR-I (Ui)        3-J-3  Component Cooling Water Pump 1-3            Suppression - Wet Pipe          N   Y   Y       Y AR-i (Ul)       3-K-1   Component Cooling Water Pump 2-1            Detection - Smoke               N   Y   Y       Y AI-I kUl)       3-K-1   Component Cooling Water Pump 2-1            Feature - None AR-1 (Ul)       3-K-1   Component Cooling Water Pump 2-1            Suppression - Wet Pipe          N   Y   Y   N   Y Page 89
* S 0
Pacific Gas and Electric Company                                                                                    4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire        Fire                                                   Regulatory                                      Required?
Area         Zone     Description                                     Basis                Type                S    L E R       D           Notes AB-1 (U1)             Auxiliary Building                               4.2.4.2 AB-1 (Ul)     3-K-2  Component Cooling Water Pump 2-2                           Detection - Smoke               N    Y   Y   N   Y AB-1 (Ul)     3-K-2  Component Cooling Water Pump 2-2                           Feature - Radiant Energy Shield N    Y   Y   N   Y AB-1 (Ul)     3-K-2  Component Cooling Water Pump 2-2                           Suppression - Wet Pipe          N    Y   Y   N   Y AB-1 (Ul)     3-K-3  Component Cooling Water Pump 2-3                           Detection - Smoke               N    Y   Y   N   Y AB-1 (U1) 3-K-3      Component Cooling Water Pump 2-3                           Feature - Radiant Energy Shield N    Y   Y   N   Y AB-1 (U1)      3-K-3  Component Cooling Water Pump 2-3                           Suppression - Wet Pipe          N    Y   Y   N   Y AB-1 (Ul)       3-L   Auxiliary Building Elevation 85 and 100 Feet               Detection - Smoke               N    N   Y   N   Y AB-1 (U1)       3-L   Auxiliary Building Elevation 85 and 100 Feet               Feature - ERFBS                 N    N   N   N   Y Afl  . II 14\  **  I                                                            C.              K
/0-    I    I1   JL    AuxI a1        nIg  ev    nU0I)    U OJIH IdU VCIUl                         -- I "IWU          --
AB-1 (Ul)       3-M   Safety Injection Pumps                                     Detection - Smoke               N    N   Y   N   Y AB-1 (Ui)       3-M   Safety Injection Pumps                                     Feature - None AB-1 (U1)       3-M   Safety Injection Pumps                                     Suppression - None AB-1 (Ui)       3-N   Safety Injection Pumps                                     Detection - Smoke               N    N   Y   N   Y AB-1 (U1)       3-N   Safety Injection Pumps                                     Feature - None AB-1 (U1)       3-N   Safety Injection Pumps                                     Suppression - None AB-1 (Ui) 3-Q-2       Motor Driven Auxiliary Feedwater Pumps                     Detection - Smoke               N    N   Y   Y   Y AB-1 (U1)      3-Q-2  Motor Driven Auxiliary Feedwater Pumps                     Feature- None AB-1 (U1) 3-Q-2       Motor Driven Auxiliary Feedwater Pumps                     Suppression - Wet Pipe          N    N   Y   Y   Y Page 90

0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                         Regulatory                            Required?
Area     Zone     Description                             Basis               Type       S   L E R       D           Notes AB-1 (UI)        Auxiliary Building                       4.2.4.2 AB-1 (U1) 3-R    Spent Fuel Pool                                   Detection - Smoke      N   N   Y   N   Y AB-1 (Ul)   3-R  Spent Fuel Pool                                   Feature- None AB-1 (Ul)  3-R   Spent Fuel Pool                                   Suppression - None AB-i (Ul)   3-S  Auxiliary Building Elevation 140 Feet             Detection - Flame      N   N   N   N   Y AB-1 (Ul)   3-S  Auxiliary Building Elevation 140 Feet             Feature - None AB-1 (Ul)   3-S  Auxiliary Building Elevation 140 Feet             Suppression - None AB-I (UI) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Detection - Smoke      N   N   Y   Y   Y AB-1 (Ul) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Feature - None AB-1 (U1) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Suppression - Wet Pipe N   N   Y   Y   Y AB-1 (Ul)  3-W   Spent Fuel Pool                                   Detection - Smoke      N   N   Y   N   Y AB-1 (Ul)  3-W   Spent Fuel Pool                                   Feature- None AB-1 (Ul)  3-W   Spent Fuel Pool                                   Suppression - Wet Pipe N   N   Y   N   Y AB-1 (Ul)   3-X  Auxiliary Building Elevation 100 Feet             Detection - Smoke      N   N   Y   Y   Y AB-1 (Ul)   3-X  Auxiliary Building Elevation 100 Feet             Feature- None AB-1 (Ul)   3-X  Auxiliary Building Elevation 100 Feet             Suppression - Wet Pipe N   N   Y   Y   Y AB-1 (Ul) 8-B-1  Supply Fan Room                                   Detection - Smoke      N   N   N   N   Y AB-1 (U1) 8-B-1  Supply Fan Room                                   Feature- None AB-1 (Ul) 8-B-1  Supply Fan Room                                   Suppression - None Page 91

0 Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire       Fire                                  Regulatory                                   Required?
Area       Zone    Description                      Basis               Type             S    L   E R     D           Notes AB-1 (U1)        Auxiliary Building                 4.2.4.2 ABA- (Ul) 8-B-2  Supply Fan Room                             Detection- Smoke             N    N   N   N   Y AB-1 (U1) 8-B-2  Supply Fan Room                             Feature- None AB-1 (Ul) 8-B-2  Supply Fan Room                             Suppression - Wet Pipe       N    N   N   N   Y ABA- (U1)    S-2 Stairwell S-2                               Detection - None ABA- (Ul)    S-2 Stairwell S-2                               Feature-None AB-1 (Ul)    S-2 Stairwell S-2                               Suppression - None ABR- (Ui)    S-3 Stairwell S-3                               Detection - None ABR- (U1)    S-3 Stairwell S-3                               Feature- None AR..1 WIi1l  S3  .Stairwell S-3                              SIupnnresion - Nonn-ABR- (Ul)    S-4 Stairwell S-4                               Detection - None ABR- (Ul)    S-4 Stairwell S-4                               Feature - None ABR- (Ui)    S-4 Stairwell S-4                               Suppression - None AB-1 (Ul)    S-8 Stairwell S-8                               Detection - None ABR- (Ui)    S-8 Stairwell S-8                               Feature - None ABR- (Ul)    S-8 Stairwell S-8                               Suppression - Wet Pipe       N    N   N   N  Y ABR- (Ui)    S-9 Stairwell S-9                               Detection - None ABR- (Ui)    S-9 Stairwell S-9                               Feature - None ABR- (Ul)    S-9 Stairwell S-9                               Suppression - None Page 92

0                                                                                                                     0 4.0 Compliance with NFPA 805 Requirements Pacific Gas and Electric Company Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                    Regulatory                                   Required?
Area     Zone      Description                      Basis               Type             S    L E R       D           Notes AB-1 (UM)        Auxiliary Building                 4.2.4.2 AR-1 (Ul)  S-10  Stairwell S-10                              Detection - None AB-1 (Ul)  S-10  Stairwell S-10                              Feature- None AB-1 (U1)  S-10  Stairwell S-10                              Suppression - None AR-1 (U1)  S-11  Stairwell S-11                              Detection - None AB-1 (UM)  S-11  Stairwell S-11                              Feature- None AR-1 (U1)  S-11  Stairwell S-ll                              Suppression - None Page 93

0                                                                           0 Pacific Gas and Electric Company                                                                       4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                                 Regulatory                               Required?
Area     Zone      Description                                    Basis               Type          S   L E R       D           Notes AB-1 (U2)        Auxiliary Building                               4.2.4.2 AB-1 (U2)   3-A  Liquid Holdup Tank Area                                   Detection - None AB-1 (U2)   3-A  Liquid Holdup Tank Area                                   Feature - None AB-1 (U2)   3-A  Liquid Holdup Tank Area                                   Suppression - None AB-1 (U2)  3-AA  Auxiliary Building Elevation 115 Feet                     Detection - Smoke         N   N   Y   N   Y AB-1 (U2) 3-AA   Auxiliary Building Elevation 115 Feet                     Feature - None AB-1 (U2)  3-AA  Auxiliary Building Elevation 115 Feet                     Suppression - Wet Pipe    N   N   Y   N   Y AB-1 (U2) 3-B-3  Boron Injection Tank                                      Detection - None AB-1 (U2) 3-B-3  Boron Injection Tank                                      Feature- None AB-1 (U2) 3-B-3  Boron Injection Tank                                      Suppression - Water Spray N   N   Y   N   Y AB-1 (U2)   3-C  Auxiliary Building Elevation 54, 64, and 73 Feet          Detection - Smoke         N   Y   Y   N   Y AB-1 (U2)   3-C  Auxiliary Building Elevation 54, 64, and 73 Feet          Feature - ERFBS           N   Y   N   N   Y AB-1 (U2)   3-C  Auxiliary Building Elevation 54, 64, and 73 Feet          Suppression - None AB-1 (U2) 3-D-3  Boron Injection Tank                                      Detection - None AB-1 (U2) 3-D-3  Boron Injection Tank                                      Feature- None AB-1 (U2) 3-D-3  Boron Injection Tank                                      Suppression - Water Spray N   N   Y   N   Y AB-1 (U2)   3-F  Containment Spray Pumps                                   Detection - Smoke         N   N   Y   N   Y AB-1 (U2)   3-F  Containment Spray Pumps                                   Feature - None AB-1 (U2)   3-F  Containment Spray Pumps                                   Suppression - None Page 94

Pacific Gas and Electric Company                                                                4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                   Regulatory                                     Required?
Area      Zone     Description                      Basis               Type                S   L E R       D           Notes AB-1 (U2)         Auxiliary Building                 4.2.4.2 AR-1 (U2)     3-G Containment Spray Pumps                     Detection - Smoke               N   N   Y   N   Y A*0   IH)'  . I0 r'nn-+inmanf Q Cnr-l I-DHn-.                  Fo=Mlrot - KIvinn AR-1 (U2)     3-G Containment Spray Pumps                     Suppression   -   None AR-1 (U2)   3-J-1 Component Cooling Water Pump 1-1            Detection - Smoke               N       Y AB-i (U2)   3-J-1 Component Cooling Water Pump 1-1            Feature - ERFBS                 N       Y AR-1 (U2)   3-J-1 Component Cooling Water Pump 1-1            Suppression - Wet Pipe          N       Y AR-1 (U2)   3-J-2 Component Cooling Water Pump 1-2            Detection - Smoke               N       Y AR-1 (U2)   3-J-2 Component Cooling Water Pump 1-2            Feature - Radiant Energy Shield N       Y AR-1 (U2)   3-J-2 Component Cooling Water Pump 1-2            Suppression - Wet Pipe          N       Y AR-1 (U2)   3-J-3 Component Cooling Water Pump 1-3            Detection - Smoke               N       Y AR-1 (U2)   3-J-3 Component Cooling Water Pump 1-3            Feature - Radiant Energy Shield N       Y AR-1 (U2)   3-J-3 Component Cooling Water Pump 1-3            Suppression - Wet Pipe          N       Y AR-1 (U2)   3-K-1 Component Cooling Water Pump 2-1            Detection - Smoke               N       Y AR-1 (U2)   3-K-1 Component Cooling Water Pump 2-1            Feature - None AR-1 (U2)   3-K-1 Component Cooling Water Pump 2-1            Suppression - Wet Pipe          N   Y   Y   N   Y AR-1 (U2)   3-K-2 Component Cooling Water Pump 2-2            Detection - Smoke               N   Y   Y   N   Y AR-1 (U2)   3-K-2 Component Cooling Water Pump 2-2            Feature - Radiant Energy Shield N   Y   Y   N   Y AR-1 (U2)   3-K-2 Component Cooling Water Pump 2-2            Suppression - Wet Pipe          N   Y   Y   N   Y Page 95

0
* Pacific Gas and Electric Company                                                                           4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                                Regulatory                                     Required?
Area     Zone     Description                                  Basis                Type                S   L E R       D           Notes AB-1 (U2)        Auxiliary Building                            4.2.4.2 AB-1 (U2) 3-K-3  Component Cooling Water Pump 2-3                        Detection - Smoke               N   Y   Y   N   Y AB-1 (U2) 3-K-3  Component Cooling Water Pump 2-3                        Feature - Radiant Energy Shield N   Y   Y   N   Y AB-1 (U2) 3-K-3  Component Cooling Water Pump 2-3                        Suppression  - Wet Pipe         N   Y   Y   N   Y AB-1 (U2)  3-L   Auxiliary Building Elevation 85 and 100 Feet            Detection - Smoke               N   N   Y   N   Y AB-1 (U2)  3-L   Auxiliary Building Elevation 85 and 100 Feet            Feature - ERFBS                 N   N   N   N   Y AB-1 (U2)  3-L   Auxiliary Building Elevation 85 and 100 Feet            Suppression - None AB-1 (U2)  3-M   Safety Injection Pumps                                  Detection - Smoke               N   N   Y   N   Y AB-1 (U2)  3-M   Safety Injection Pumps                                  Feature - None AB-1 (U2)  3-M   Safety Injection Pumps                                  Suppression - None AB-1 (U2)  3-N   Safety Injection Pumps                                  Detection - Smoke               N   N   Y   N   Y AB-1 (U2)  3-N   Safety Injection Pumps                                  Feature - None AB-1 (U2)  3-N   Safety Injection Pumps                                  Suppression - None AB-1 (U2) 3-Q-2  Motor Driven Auxiliary Feedwater Pumps                  Detection - Smoke               N   N   Y   Y   Y AB-1 (U2) 3-Q-2  Motor Driven Auxiliary Feedwater Pumps                  Feature - None AB-1 (U2) 3-Q-2  Motor Driven Auxiliary Feedwater Pumps                  Suppression  - Wet Pipe         N   N   Y   Y   Y AB-1 (U2)  3-R   Spent Fuel Pool                                         Detection - Smoke               N   N   Y   N   Y AB-1 (U2)  3-R   Spent Fuel Pool                                         Feature- None AB-1 (U2)  3-R   Spent Fuel Pool                                         Suppression - None Page 96

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                         Regulatory                            Required?
Area     Zone     Description                            Basis                Type       S   L E R       D           Notes AB-1 (U2)        Auxiliary Building                      4.2.4.2 AB-1 (U2)   3-S  Auxiliary Building Elevation 140 Feet             Detection - Flame      N   N   N   N   Y AB-1 (U2)   3-S  Auxiliary Building Elevation 140 Feet             Feature - None AB-1 (U2)   3-S  Auxiliary Building Elevation 140 Feet             Suppression - None AB-i (U2) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Detection - Smoke      N   N   Y   Y   Y AB-1 (U2) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Feature - None AB-1 (U2) 3-T-2  Motor Driven Auxiliary Feedwater Pumps            Suppression - Wet Pipe N   N   Y   Y   Y AB-1 (U2)  3-W   Spent Fuel Pool                                   Detection - Smoke      N   N   Y   N   Y AB-1 (U2)  3-W   Spent Fuel Pool                                   Feature- None AB-1 (U2)  3-W   Spent Fuel Pool                                   Suppression - Wet Pipe N   N   Y   N   Y AB-1 (U2)   3-X  Auxiliary Building Elevation 100 Feet             Detection-Smoke        N   N   Y   Y   Y AB-1 (U2)   3-X  Auxiliary Building Elevation 100 Feet             Feature - None AB-1 (U2)   3-X  Auxiliary Building Elevation 100 Feet             Suppression -Wet Pipe  N   N   Y   Y   Y AB-1 (U2) 8-B-1  Supply Fan Room                                   Detection - Smoke      N   N   N   N   Y AB-1 (U2) 8-B-1  Supply Fan Room                                   Feature- None AB-1 (U2) 8-B-1  Supply Fan Room                                   Suppression - None AB-1 (U2) 8-B-2  Supply Fan Room                                   Detection - Smoke      N   N   N   N   Y AB-1 (U2) 8-B-2  Supply Fan Room                                   Feature- None AB-1 (U2) 8-B-2  Supply Fan Room                                   Suppression - Wet Pipe N   N   N   N   Y Page 97

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone      Description                    Basis                Type             S    L E R       D           Notes AB-1 (U2)        Auxiliary Building               4.2.4.2 AB-1 (U2)   S Stairwell S-2                              Detection - None AB-1 (U2)   S-2  Stairwell S-2                              Feature- None AB-I (U2)   S-2  Stairwell S-2                              Suppression - None AB-1 (U2)   S-3  Stairwell S-3                              Detection - None AB-1 (U2)   S-3  Stairwell S-3                              Feature-None AB-1 (U2)   S-3  Stairwell S-3                              Suppression - None AR-1 (U2)   S-4  Stairwell S-4                              Detection - None AB-i (U2)   S-4  Stairwell S-4                              Feature - None ABR- (U2)   S-4  Stairwell S-4                              Suppression - None AR-1 (U2)   S-8  Stairwell S-8                              Detection - None AB-1 (U2)   S-8  Stairwell S-8                              Feature- None AB-I (U2)   S-8  Stairwell S-8                              Suppression  -Wet  Pipe      N    N   N   N   Y AB-1 (U2)   S-9  Stairwell S-9                              Detection - None AB-1 (U2)   S-9  Stairwell S-9                              Feature- None AR-1 (U2)   S-9  Stairwell S-9                              Suppression - None AR-1 (U2)  S-10  Stairwell S-10                             Detection - None AR-1 (U2)  S-10  Stairwell S-10                             Feature- None AR-1 (U2)  S-10  Stairwell S-10                             Suppression - None Page 98

P Pacific Gas and Electric Company 0                                                       0q 4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                   Regulatory                                   Required?
Area     Zone      Description                      Basis               Type             S    L E R       D           Notes AB-1 (U2)        Auxiliary Building                 4.2.4.2 AB-1 (U2)  S-11  Stairwell S-11                              Detection - None AB-1 (U2)  S-11  Stairwell S-11                              Feature- None AB-1 (U2)  S-11  Stairwell S-11                              Suppression - None AB-2           Electrical AreaNentilation Room    4.2.3.2 AB-2    8-B-5  Electrical AreaNentilation Room             Detection - None AB-2    8-B-5  Electrical AreaNentilation Room             Feature - None AB-2    8-B-5  Electrical AreaNentilation Room             Suppression - None AB-2    8-B-6  Electrical AreaNentilation Room             Detection - None AB-2    8-B-6  Electrical AreaNentilation Room             Feature - None-AB-2    8-B-6  Electrical AreaNentilation Room             Suppression - None AB-2      S-5  Stairwell S-5                               Detection - None AB-2      S-5  Stairwell S-5                               Feature - None AB-2      S-5  Stairwell S-5                               Suppression - Wet Pipe       N    N   Y   N   Y Page 99

0                                                                                                                    0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone      Description                    Basis                Type             S    L E R       D           Notes AB-3           Electrical AreaNentilation Room  4.2.3.2 AB-3    8-B-7  Electrical Areafentilation Room            Detection - None AB-3    8-B-7  Electrical AreaNentilation Room            Feature - None AB-3    8-B-7  Electrical AreaNentilation Room            Suppression - None AB-3    8-8-8  Electrical AreaNentilation Room            Detection - None AB-3    8-B-8  Electrical AreaNentilation Room            Feature - None AB-3    8-B-8  Electrical AreaNentilation Room            Suppression - None AB-3     S-1   Stairwell S-1                              Detection - None AB-3     S-1   Stairwell S-1                              Feature - None AB-3     S-1   Stairwell S-1                              Suppression - None Page 100

0 Pacific Gas and Electric Company                                                                        4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire          Fire                                       Regulatory                                    Required?
Area           Zone         Description                     Basis                    Type         S     L E R       D           Notes CR-I (UI)                 Control Room Complex               4.2.4.2 CR-i (Ul)         8-A     Computer Room                                Detection-Smoke              N     N   Y   N   Y CR-i (Ul)         8-A     Computer Room                                Feature - None CR-i (Ul)         8-A     Computer Room                                Suppression - None CR-1 (U1)        8-B-3    CR Ventilation Equipment Room                Detection - Smoke            N     N   Y   N   Y CR-i (Ui) 8-B-3           CR Ventilation Equipment Room                Feature - None CR-i (Ui) 8-B-3           CR Ventilation Equipment Room                Suppression - Wet Pipe       N     N   Y   N   Y CR-1 (U1)        8-B-4    CR Ventilation Equipment Room                Detection - Smoke            N     N   Y   N   Y CR-i (Ul) 8-B-4           CR Ventilation Equipment Room                Feature - None CR-i (Ul)        8-B-4    CR Ventilation Equipment Room                Suppression - Wet Pipe       N     N   Y   N   Y CR-i (Ul)         8-C     Control Room                                 Detection - Smoke            N     N   Y   Y   Y CR-1 (Ul)         8-C     Control Room                                 Feature - None f*    .4 /I 14%   0  V' 1"-%
I     I)  O-    .  ..UI I 'pUUI II KIUI                                    1 J 1 Jte:IUII onU - Ione       --
CR-1 (Ul)         8-D     Computer Room                                Detection- Smoke             N     N   Y   N   Y CR-1 (Ul)         8-D     Computer Room                                Feature- None CR-1 (Ui)         8-D     Computer Room                                Suppression - None CR-1 (Ui)         8-E     Office                                       Detection - Smoke            N     N   Y   N   Y CR-1 (Ui)         8-E     Office                                       Feature- None CR-1 (Ui)         8-E     Office                                       Suppression      - Wet Pipe  N     N   Y   N   Y Page 101

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone      Description                    Basis               Type              S    L   E R     D           Notes CR-1 (UM)        Control Room Complex             4.2.4.2 CR-i (Ul)  8-F   Office                                     Detection- Smoke             N    N   Y   N   Y CR-i (Ul)  8-F   Office                                     Feature- None CR-1 (Ul)  8-F   Office                                     Suppression - None Page 102
* 0                                                       0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone      Description                    Basis                Type             S    L E R       D           Notes CR-I (U2)        Control Room Complex             4.2.4.2 CR-1 (U2)   8-A  Computer Room                              Detection-Smoke              N    N   Y   N   Y CR-1 (U2)   8-A  Computer Room                              Feature- None CR-1 (U2)   8-A  Computer Room                              Suppression - None CR-1 (U2) 8-1-3  CR Ventilation Equipment Room              Detection - Smoke            N    N   Y   N   Y CR-i (U2) 8-B-3  CR Ventilation Equipment Room              Feature - None CR-1 (U2) 8-8-3  CR Ventilation Equipment Room              Suppression - Wet Pipe       N    N   Y   N   Y CR-1 (U2) 8-8-4  CR Ventilation Equipment Room              Detection - Smoke            N    N   Y   N   Y CR-1 (U2) 8-B-4  CR Ventilation Equipment Room              Feature - None CR-1 (U2) 8-1-4  CR Ventilation Equipment Room              Suppression - Wet Pipe       N    N   Y   N   Y CR-1 (U2)  8-C   Control Room                               Detection - Smoke            N    N   Y   Y   Y CR-1 (U2)  8-C   Control Room                               Feature- None CR-i (U2)  8-C   Control Room                               Suppression - None CR-1 (U2)  8-D   Computer Room                              Detection - Smoke            N    N   Y   N   Y CR-1 (U2)  8-D   Computer Room                              Feature- None CR-1 (U2)  8-D   Computer Room                              Suppression - None CR-1 (U2)  8-E   Office                                     Detection - Smoke            N    N   Y   N   Y CR-1 (U2)  8-E   Office                                     Feature- None CR-1 (U2)  8-E   Office                                     Suppression - Wet Pipe       N    N   Y   N   Y Page 103

0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                      Regulatory                               Required?
Area      Zone     Description                         Basis               Type         S    L E R       D           Notes CR-I (U2)        Control Room Complex                  4.2.4.2 CR-1 (U2)   8-F  Office                                         Detection- Smoke         N    N   Y   N   Y CR-i (U2)   8-F  Office                                         Feature- None CR-1 (U2)   8-F  Office                                         Suppression - None FB-1 (UI)        Fuel Handling Building                4.2.4.2 FB-1 (Ul)  3-0  Spent Fuel Pool Heat Exchanger Room            Detection - Smoke        N    N   Y   N   Y FB-1 (Ul)  3-0  Spent Fuel Pool Heat Exchanger Room            Feature - None FB-1 (Ul)   3-0  Spent Fuel Pool Heat Exchanger Room            Suppression - None FB-1 (Ul)    31  Fuel Handling Building Corridor                Detection - None FB-A (Ul)    31  Fuel Handling Building Corridor                Feature - None FB-1 (Ul)   31   Fuel Handling Building Corridor                Suppression -Wet Pipe    N    N   Y   Y   Y FB-I (U2)        Fuel Handling Building               4.2.4.2 FB-1 (U2)   3-0  Spent Fuel Pool Heat Exchanger Room            Detection - Smoke        N    N   Y   N   Y FB-1 (U2)   3-0  Spent Fuel Pool Heat Exchanger Room            Feature - None FB-1 (U2)   3-0  Spent Fuel Pool Heat Exchanger Room            Suppression - None FB-1 (U2)   31   Fuel Handling Building Corridor                Detection - None FB-1 (U2)   31   Fuel Handling Building Corridor                Feature - None FB-1 (U2)   31   Fuel Handling Building Corridor                Suppression - Wet Pipe   N    N   Y   N  Y Page 104

0 Pacific Gas and Electric Company                                                              4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                      Regulatory                                 Required?
Area     Zone      Description                         Basis               Type            S   L E R       D           Notes FB-2           Fuel Handling Building                4.2.4.2 FB-2      3-U  Spent Fuel Pool Heat Exchanger Room            Detection - Smoke           N   N   Y   N   Y FB-2      3-U  Spent Fuel Pool Heat Exchanger Room            Feature - None FB-2      3-U  Spent Fuel Pool Heat Exchanger Room            Suppression - None FB-2       32  Fuel Handling Building Corridor                Detection - None FB-2       32  Fuel Handling Building Corridor                Feature - None FB-2       32  Fuel Handling Building Corridor                Suppression - Wet Pipe      N   N   Y   N   Y IS-I           Intake Structure                    4.2.3.3(b)
IS-1    30-A-5 Circulating Water Pump Room                    Detection - Smoke           Y   N   Y   N   N IS-1    30-A-5 Circulating Water Pump Room                    Feature - None IS-1    30-A-5 Circulating Water Pump Room                    Suppression - Automatic C02 Y   N   Y   N   N IS-1    30-A-5 Circulating Water Pump Room                    Suppression - Wet Pipe      Y   N   Y   N   N IS-1     30-B  Intake Structure Control Room                  Detection - Smoke           Y   N   N   N   N IS-1     30-B  Intake Structure Control Room                  Feature - None IS-1     30-B  Intake Structure Control Room                  Suppression - None Page 105

0 Pacific Gas and Electric Company 0
4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                             Regulatory                                 Required?
Area     Zone      Description                               Basis                Type            S   L E R       D           Notes TB-1            Emergency Diesel Generator 1-1             4.2.3.2 TB-1    11-A-1  Emergency Diesel Generator 1-1                       Detection - Heat            N   N   Y   N   N TB-i    11-A-1  Emergency Diesel Generator 1-1                       Feature - None TB-1    11-A-1  Emergency Diesel Generator 1-1                       Suppression - Automatic C02 N   N   Y   N   N TB-i    1I-A-2  Emergency Diesel Generator 1-1 Intake and            Detection - Heat            N   N   Y   N   N Exhaust Room TB-1    11 -A-2 Emergency Diesel Generator 1-1 Intake and            Feature - None Exhaust Room TB-1    11-A-2  Emergency Diesel Generator 1-1 Intake and            Suppression -Automatic C02  N   N   Y   N   N Exhaust Room TB-2            Emergency Diesel Generator 1-2             4.2.3.2 TB-2    11-B-1  Emergency Diesel Generator 1-2                       Detection - Heat            N   N   Y   N   N TB-2    11-B-1  Emergency Diesel Generator 1-2                       Feature - None TB-2    11-B-1  Emergency Diesel Generator 1-2                       Suppression - Automatic C02 N   N   Y   N   N TB-2    11--B-2 Emergency Diesel Generator 1-2 Intake and            Detection - Heat            N   N   Y   N   N Exhaust Room TB-2    11-8-2  Emergency Diesel Generator 1-2 Intake and            Feature - None Exhaust Room TB-2    11--B-2 Emergency Diesel Generator 1-2 Intake and            Suppression - Automatic C02 N   N   Y   N   N Exhaust Room Page 106

Pacific Gas and Electric Company                                                                    4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                            Regulatory                                 Required?
Area     Zone     Description                                Basis               Type            S   L E R       D            Notes TB-3           Emergency Diesel Generator 1-3              4.2.3.2 TB-3    11-C-1 Emergency Diesel Generator 1-3                       Detection - Heat            N   N   Y   N   N TB-3    11-C-1 Emergency Diesel Generator 1-3                       Feature - None TB-3    11-C-1 Emergency Diesel Generator 1-3                       Suppression - Automatic C02 N   N   Y   N   N TB-3    11-C-2 Emergency Diesel Generator 1-3 Intake and            Detection - Heat            N   N   Y   N   N Exhaust Room TB-3    11-C-2 Emergency Diesel Generator 1-3 Intake and            Feature - None Exhaust Room TB-3    11-C-2 Emergency Diesel Generator 1-3 Intake and            Suppression - Automatic C02 N   N   Y   N   N Exhaust Room TB-4           4kV Switchgear Room and Cable               4.2.4.2 Spreading Room, F Bus TB-4     12-A  4kV Cable Spreading Room, F Bus                      Detection - Smoke           N   N   Y   Y   Y TB-4     12-A  4kV Cable Spreading Room, F Bus                      Feature - None TB-4     12-A  4kV Cable Spreading Room, F Bus                      Suppression - None TB-4     13-A  4kV Switchgear Room, F Bus                           Detection - Smoke           N   N   Y   Y   Y TB-4     13-A  4kV Switchgear Room, F Bus                           Feature - None TB-4     13-A  4kV Switchgear Room, F Bus                           Suppression - None Page 107

0                                                                                                                    0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone     Description                     Basis                Type             S    L E R       D           Notes TB-5           4kV Switchgear Room and Cable    4.2.4.2 Spreading Room, G Bus TB-5     12-B  4kV Cable Spreading Room, G Bus            Detection - Smoke            N    N   Y   Y   Y TB-5     12-B  4kV Cable Spreading Room, G Bus            Feature - None TB-5     12-B  4kV Cable Spreading Room, G Bus            Suppression - None TB-5     13-B  4kV Switchgear Room, G Bus                 Detection - Smoke            N    N   Y   Y   Y TB-5     13-B  4kV Switchgear Room, G Bus                 Feature - None TB-5     13-B  4kV Switchgear Room, G Bus                 Suppression - None TB-6           4kV Switchgear Room and Cable    4.2.4.2 Spreading Room, H Bus TB-6     12-C  4kV Cable Spreading Room, H Bus            Detection - Smoke            N    N   Y   Y   Y TB-6     12-C  4kV Cable Spreading Room, H Bus            Feature - None TB-6     12-C  4kV Cable Spreading Room, H Bus            Suppression - None TB-6     13-C  4kV Switchgear Room, H Bus                 Detection - Smoke            N    N   Y   Y   Y TB-6     13-C  4kV Switchgear Room, H Bus                 Feature - None TB-6     13-C  4kV Switchgear Room, H Bus                 Suppression - None Page 108

0 Pacific Gas and Electric Company                                                                  4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                            Regulatory                               Required?
Area      Zone     Description                               Basis               Type          S   L   E R     D           Notes TB-7 (UI)        Turbine Deck and Main                       4.2.4.2 Condenser Area TB-7 (U1)   12-E Iso-Phase Bus Duct Room                              Detection - None TB-7 (U1)  12-E  Iso-Phase Bus Duct Room                              Feature- None TB-7 (U1) 12-E   Iso-Phase Bus Duct Room                              Suppression - None TB-7 (U1) 14-A   Main Condenser, Feedwater, and Condensate            Detection - None Equipment Area TB-7 (UL1) 14-A  Main Condenser, Feedwater, and Condensate            Feature- None Equipment Area TB-7 (U1) 14-A   Main Condenser, Feedwater, and Condensate            Suppression -Water Spray  N   N   Y   Y   Y Equipment Area TB-7 (U1)  14-A  Main Condenser, Feedwater, and Condensate            Suppression - Wet Pipe    N   N   Y   Y   Y Equipment Area TB-7 (U1)  14-C  Electrical Load Center                               Detection - Smoke         N   N   Y   N   Y TB-7 (U1)  14-C  Electrical Load Center                               Feature - None TB-7 (Ul)  14-C  Electrical Load Center                               Suppression - None TB-7 (Ul)  14-D  Turbine Deck                                         Detection - Heat          N   N   Y   Y   Y TB-7 (Ul)  14-D  Turbine Deck                                         Feature- None TB-7. (Ul) 14-D  Turbine Deck                                         Suppression - Wet Pipe    N   N   Y   Y   Y TB-7 (Ul)  14-D  Turbine Deck                                         Suppression-Automatic C02 N   N   Y   Y   Y TB-7 (UL1) 14-D  Turbine Deck                                         Suppression- Deluge       N   N   Y   Y   Y TB-7 (Ul)  14-E  Component Cooling Water Heat Exchanger Room          Detection - Smoke         N   N   Y   N   Y Page 109

Pacific Gas and Electric Company                                                                  4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                            Regulatory                               Required?
Area     Zone      Description                               Basis               Type          S   L E R       D           Notes TB-7 (U1)        Turbine Deck and Main                       4.2.4.2 Condenser Area TB-7 (Ul)  14-E  Component Cooling Water Heat Exchanger Room          Feature - None TB-7 (Ul)  14-E  Component Cooling Water Heat Exchanger Room          Suppression - Wet Pipe    N   N   Y   N   Y TB-7 (Ul)   16   Machine Shop                                         Detection - None TB-7 (Ul)   16   Machine Shop                                         Feature - None TB-7 (Ul)   16   Machine Shop                                         Suppression - Wet Pipe    N   N   N   N   Y TB-7 (U1) 19-A   Main Condenser, Feedwater, and Condensate            Detection - None Equipment Area TB-7 (Ul)  19-A  Main Condenser, Feedwater, and Condensate            Feature - None Equipment Area TB-7 (Ul)  19-A  Main Condenser, Feedwater, and Condensate            Suppression - Water Spray N   N   Y   Y   Y Equipment Area TB-7 (Ul)  19-A  Main Condenser, Feedwater, and Condensate            Suppression -Wet Pipe     N   N   Y   Y   Y Equipment Area TB-7 (U1)  19-B  Electrical Load Center                               Detection - Smoke         N   N   Y   N   Y TB-7 (Ul)  19-B  Electrical Load Center                               Feature - None TB-7 (U1)  19-B  Electrical Load Center                               Suppression - None TB-7 (Ul)  19-C  Oil Reclamation and Shortage Room                    Detection - None TB-7 (Ul)  19-C  Oil Reclamation and Shortage Room                    Feature- None TB-7 (Ul)  19-C  Oil Reclamation and Shortage Room                    Suppression -Wet Pipe     N   N   N   N   Y TB-7 (Ul)  19-D  Turbine Deck                                         Detection- Heat           N   N   Y   Y   Y Page 110

Pacific Gas and Electric Company                                                                4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                          Regulatory                               Required?
Area     Zone     Description                             Basis               Type          S   L   E R     D            Notes TB-7 (UI)        Turbine Deck and Main                     4.2.4.2 Condenser Area TB-7 (Ul) 19-D  Turbine Deck                                       Feature- None TB-7 (Ul) 19-D  Turbine Deck                                       Suppression-Automatic C02 N   N   Y   Y   Y TB-7 (Ul)  19-D  Turbine Deck                                       Suppression- Deluge       N   N   Y   Y   Y TB-7 (Ul)  19-E  Component Cooling Water Heat Exchanger Room        Detection - Smoke         N   N   Y   N   Y TB-7 (Ul)  19-E  Component Cooling Water Heat Exchanger Room        Feature - None TB-7 (Ul)  19-E  Component Cooling Water Heat Exchanger Room        Suppression -Wet Pipe     N   N   Y   N   Y TB-7 (Ul)  23-E  Iso-Phase Bus Duct Room                            Detection - None TB-7 (U1)  23-E  Iso-Phase Bus Duct Room                            Feature - None TB-7 (Ul)  23-E  Iso-Phase Bus Duct Room                            Suppression - None TB-7 (Ul)   S-6  Stairwell S-6                                      Detection - None TB-7 (Ul)   S-6  Stairwell S-6                                      Feature- None TB-7 (Ul)   S-6  Stairwell S-6                                      Suppression - None Page 111

0 Pacific Gas and Electric Company                                                                    4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                             Regulatory                                 Required?
Area     Zone      Description                              Basis                Type            S   L E R       D           Notes TB-7 (U2)        Turbine Deck and Main                      4.2.4.2 Condenser Area TB-7 (U2)  12-E  Iso-Phase Bus Duct Room                              Detection - None TB-7 (U2)  12-E  Iso-Phase Bus Duct Room                              Feature - None TB-7 (U2)  12-E  Iso-Phase Bus Duct Room                              Suppression - None TB-7 (U2)  14-A  Main Condenser, Feedwater, and Condensate            Detection - None Equipment Area TB-7 (U2)  14-A  Main Condenser, Feedwater, and Condensate            Feature - None Equipment Area TB-7 (U2)  14-A. Main Condenser, Feedwater, and Condensate            Suppression  - Water Spray  N   N   Y   Y   Y Equipment Area TB-7 (U2)  14-A  Main Condenser, Feedwater, and Condensate            Suppression - Wet Pipe      N   N   Y   Y   Y Equipment Area TB-7 (U2)  14-C  Electrical Load Center                               Detection - Smoke           N   N   Y   N   Y TB-7 (U2)  14-C  Electrical Load Center                               Feature - None TB-7 (U2)  14-C  Electrical Load Center                               Suppression - None TB-7 (U2)  14-D  Turbine Deck                                         Detection - Heat            N   N   Y   Y   Y TB-7 (U2)  14-D  Turbine Deck                                         Feature- None TB-7 (U2)  14-D  Turbine Deck                                         Suppression - Wet Pipe      N   N   Y   Y   Y TB-7 (U2)  14-D  Turbine Deck                                         Suppression- Deluge         N   N   Y   Y   Y TB-7 (U2)  14-D  Turbine Deck                                         Suppression - Automatic C02 N   N   Y   Y   Y TB-7 (U2)  14-E  Component Cooling Water Heat Exchanger Room          Detection - Smoke           N   N   Y   N   Y Page 112

Pacific Gas and Electric Company                                                                  4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                             Regulatory                               Required?
Area     Zone      Description                              Basis                Type          S   L   E R     D            Notes TB-7 (U2)        Turbine Deck and Main                      4.2.4.2 Condenser Area TB-7 (U2)  14-E  Component Cooling Water Heat Exchanger Room          Feature - None TB-7 (U2)  14-E  Component Cooling Water Heat Exchanger Room          Suppression  - Wet Pipe   N   N   Y   N   Y TB-7 (U2)   16   Machine Shop                                         Detection - None TB-7 (U2)   16   Machine Shop                                         Feature - None TB-7 (U2)   16   Machine Shop                                         Suppression - Wet Pipe    N   N   N   N   Y TB-7 (U2)  19-A  Main Condenser, Feedwater, and Condensate            Detection - None Equipment Area TB-7 (U2)  19-A  Main Condenser, Feedwater, and Condensate            Feature - None Equipment Area TB-7 (U2)  19-A  Main Condenser, Feedwater, and Condensate            Suppression - Water Spray N   N   Y   Y   Y Equipment Area TB-7 (U2)  19-A  Main Condenser, Feedwater, and Condensate            Suppression - Wet Pipe    N   N   Y   Y   Y Equipment Area TB-7 (U2)  19-B  Electrical Load Center                               Detection - Smoke         N   N   Y   N   Y TB-7 (U2)  19-B  Electrical Load Center                               Feature - None TB-7 (U2)  19-B  Electrical Load Center                               Suppression - None TB-7 (U2)  19-C  Oil Reclamation and Shortage Room                    Detection - None TB-7 (U2)  19-C  Oil Reclamation and Shortage Room                    Feature - None TB-7 (U2)  19-C  Oil Reclamation and Shortage Room                    Suppression -Wet Pipe     N   N   N   N   Y TB-7 (U2)  19-D  Turbine Deck                                         Detection - Heat          N   N   Y   Y   Y Page 113

Pacific Gas and Electric Company                                                                  4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                           Regulatory                                Required?
Area      Zone     Description                             Basis                 Type         S    L E R       D           Notes TB-7 (U2)        Turbine Deck and Main                     4.2.4.2 Condenser Area TB-7 (U2)   19-D Turbine Deck                                        Feature- None TB-7 (U2)   19-D Turbine Deck                                        Suppression-Automatic C02 N    N   Y   Y   Y TB-7 (U2)   19-D Turbine Deck                                        Suppression- Deluge       N    N   Y   Y   Y TB-7 (U2)   19-E Component Cooling Water Heat Exchanger Room         Detection - Smoke         N    N   Y   N   Y TB-7 (U2)   19-E Component Cooling Water Heat Exchanger Room         Feature - None TB-7 (U2)   19-E Component Cooling Water Heat Exchanger Room         Suppression - Wet Pipe    N    N   Y   N   Y TB-7 (U2)   23-E Iso-Phase Bus Duct Rnnm                             rDetectinn--     .        -nn-TB-7 (U.12) 23-  Iso-Phase Bus Duct Room                             Feature - None TB-7 (U2)   23-E Iso-Phase Bus Duct Room                             Suppression - None TB-7 (U2)   S-6  Stairwell S-6                                       Detection - None TB-7(U2)    S-6  Stairwell S-6                                       Feature - None TB-7 (U2)   S-6  Stairwell S-6                                       Suppression - None Page 114

Pacific Gas and Electric Company                                                                     4.0 Compliance with NFPA 806 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                             Regulatory                                 Required?
Area     Zone      Description                                Basis               Type            S   L E R       D           Notes TB-8            Emergency Diesel Generator 2-1              4.2.3.2 TB-8    22-A-1  Emergency Diesel Generator 2-1                       Detection - Heat            N   N   Y   N   N TB-8    22-A-1  Emergency Diesel Generator 2-1                       Feature - None TB-8    22-A-1  Emergency Diesel Generator 2-1                       Suppression - Automatic C02 N   N   Y   N   N TB-8    22-A-2  Emergency Diesel Generator 2-1 Intake and            Detection - Heat            N   N   Y   N   N Exhaust Room TB-8    22-A-2  Emergency Diesel Generator 2-1 Intake and            Feature - None Exhaust Room TB-8    22-A-2 *Emergency Diesel Generator 2-1 Intake and            Suppression - Automatic C02 N   N   Y   N   N Exhaust Room TB-9            Emergency Diesel Generator 2-2              4.2.3.2 TB-9    22-B-1  Emergency Diesel Generator 2-2                       Detection - Heat            N   N   Y   N   N TB-9    22-B-1  Emergency Diesel Generator 2-2                       Feature - None TB-9    22-B-1 Emergency Diesel Generator 2-2                        Suppression - Automatic C02 N   N   Y   N   N TB-9    22-B-2 Emergency Diesel Generator 2-2 Intake and             Detection - Heat.           N   N   Y   N   N Exhaust Room TB-9   22-B-2  Emergency Diesel Generator 2-2 Intake and             Feature - None Exhaust Room TB-9   22-B-2  Emergency Diesel Generator 2-2 Intake and             Suppression - Automatic C02 N   N   Y   N   N Exhaust Room Page 115

0                                                                                                                     10 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                  Regulatory                                   Required?
Area     Zone     Description                     Basis                Type             S    L E R       D           Notes TB-10           4kV Switchgear Room and Cable    4.2.4.2 Spreading Room, F Bus TB-10    23-A  4kV Cable Spreading Room, F Bus            Detection - Smoke            N    N   Y   Y   Y TB-10    23-A  4kV Cable Spreading Room, F Bus            Feature - None TB-10    23-A  4kV Cable Spreading Room, F Bus            Suppression - None TB-10    24-A  4kV Switchgear Room, F Bus                 Detection - Smoke            N    N   Y   Y   Y TB-10    24-A  4kV Switchgear Room, F Bus                 Feature - None TB-10    24-A  4kV Switchgear. Room, F Bus                Suppression - None TB-I1           4kV Switchgear Room and Cable    4.2.4.2 Spreading Room, G Bus TB-11    23-B  4kV Cable Spreading Room, G Bus            Detection - Smoke            N    N   Y   Y   Y TB-11    23-B  4kV Cable Spreading Room, G Bus            Feature - None TB-1i    23-B  4kV Cable Spreading Room, G Bus            Suppression - None TB-11    24-B  4kV Switchgear Room, G Bus                 Detection - Smoke            N    N   Y   Y   Y TB-1i    24-B  4kV Switchgear Room, G Bus                 Feature - None TB-lI    24-B  4kV Switchgear Room, G Bus                 Suppression - None Page 116

Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone     Description                      Basis               Type             S    L E R       D           Notes TB-12           4kV Switchgear Room and Cable     4.2.4.2 Spreading Room, H Bus TB-12    23-C  4kV Cable Spreading Room, H Bus            Detection - Smoke            N    N   Y   Y   Y TB-12    23-C  4kV Cable Spreading Room, H Bus            Feature - None TB-12   23-C   4kV Cable Spreading Room, H Bus            Suppression - None TB-12   24-C   4kV Switchgear Room, H Bus                 Detection - Smoke            N    N   Y   Y   Y TB-12   24-C   4kV Switchgear Room, H Bus                 Feature - None TB-12   24-C   4kV Switchgear Room, H Bus                 Suppression - None Page 117

Pacific Gas and Electric Company                                                                4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                            Regulatory                             Required?
Area     Zone      Description                              Basis                Type        S   L E R       D           Notes TB-13           Switchgear Ventilation Fan Room            4.2.3.2 and Operations Ready Room TB-1 3  23-C-1 Corridor Outside 4kV Cable Spreading Room            Detection - Smoke       N   N   Y   N   N TB-13   23-C-1 Corridor Outside 4kV Cable Spreading Room            Feature - None TB-13   23-C-1 Corridor Outside 4kV Cable Spreading Room            Suppression - None TB-13    24-E  Switchgear Ventilation Fan Room                      Detection - Smoke       N   N   Y   N   N TB-13    24-E  Switchgear Ventilation Fan Room                      Feature - None TB-13    24-E  Switchgear Ventilation Fan Room                      Suppression - Wet Pipe  N   N   Y   N   N TB-i3     25   Operations Ready Room                                Detection - None TB-13     25   Operations Ready Room                                Feature - None TB-13     25   Operations Ready Room                                Suppression - Wet Pipe  N   N   Y   N   N TB-13     S-7  Stairwell S-7                                        Detection - None TB-13     S-7  Stairwell S-7                                        Feature - None TB-13     S-7  Stairwell S-7                                        Suppression - None TB-14           Reverse Osmosis Area                       4.2.3.2 TB-14   TB-14  Reverse Osmosis Area TB-I5           Unit I Buttress Area                       4.2.3.2 TB-15   TB-15  Unit I Buttress Area                                 Detection - Smoke       N   N   N   N   N TB-15   TB-15  Unit 1 Buttress Area                                 Feature- None TB-15   TB-15  Unit 1 Buttress Area                                 Suppression  - Wet Pipe N   N   N   N   N Page 118

Pacific Gas and Electric Company                                                                       4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                               Regulatory                                 Required?
Area     Zone      Description                                  Basis               Type            S   L E     R   D           Notes TB-16           Unit 2 Buttress Area/Technical                 4.2.3.2 Support Center TB-16   TB-16  Unit 2 Buttress Area/Technical Support Center           Detection - Smoke           N   N   N   N   N TB-16   TB-16  Unit 2 Buttress Area/Technical Support Center           Feature - None TB-16   TB-16  Unit 2 Buttress Area/Technical Support Center           Suppression - Wet Pipe      N   N   N   N   N TB-17           Emergency Diesel Generator 2-3                 4.2.3.2 TB-17   22-C-1 Emergency Diesel Generator 2-3                          Detection - Heat            N   N   Y   N   N TB-17   22-C-1 Emergency Diesel Generator 2-3                          Feature - None TB-17   22-C-1 Emergency Diesel Generator 2-3                          Suppression - Automatic C02 N   N   Y   N   N TB-17   22-C-2 Emergency Diesel Generator 2-3 Intake and               Detection - Heat            N   N   Y   N   N Exhaust Room TB-17   22-C-2 Emergency Diesel Generator 2-3 Intake and               Feature - None Exhaust Room TB-17   22-C-2 Emergency Diesel Generator 2-3 Intake and               Suppression - Automatic C02 N   N   Y   N   N Exhaust Room Page 119

0                                                           0 Pacific Gas and Electric Company                                                            4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                   Regulatory                                   Required?
Area     Zone     Description                     Basis                Type             S    L E R       D           Notes V-1            HVAC Rooms                       4.2.3.2 V-1    3-P-2  HVAC Room                                  Detection - None V-1    3-P-2  HVAC Room                                  Feature- None V-1    3-P-2  HVAC Room                                  Suppression - None V-1    3-P-3  HVAC Room                                  Detection - Smoke            N    N   Y   N   N V-1    3-P-3  HVAC Room                                  Feature - None V-1    3-P-3  HVAC Room                                  Suppression - None V-1    3-P-4  HVAC Room                                  Detection - Smoke            N    N   N   N   N V-1    3-P-4  HVAC Room                                  Feature - None V-1    3-P-4  HVAC Room                                  Suppression - None V-1    3-P-9  HVAC Room                                  Detection - None V-1    3-P-9  HVAC Room                                  Feature - None V-1    3-P-9  HVAC Room                                  Suppression - None Page 120

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                   Regulatory                                   Required?
Area     Zone      Description                      Basis               Type             S    L E R       D           Notes V-2            HVAC Rooms                        4.2.3.2 V-2    3-P-6   HVAC Room                                  Detection - None V-2    3-P-6   HVAC Room                                  Feature - None V-2    3-P-6   HVAC Room                                  Suppression - None V-2    3-P-7   HVAC Room                                  Detection - Smoke            N    N   N   N   N V-2    3-P-7   HVAC Room                                  Feature - None V-2    3-P-7   HVAC Room                                  Suppression - None V-2    3-P-8   HVAC Room                                  Detection - Smoke            N    N   N   N   N V-2    3-P-8   HVAC Room                                  Feature - None V-2    3-P-8   HVAC Room                                  Suppression - None V-2    3-P-10  HVAC Room                                  Detection - None V-2    3-P-10  HVAC Room                                  Feature- None V-2    3-P-1 0 HVAC Room                                  Suppression - None V-2    3-P-1 1 HVAC Room                                  Detection - None V-2    3-P-1 1 HVAC Room                                  Feature- None V-2    3-P-1 1 HVAC Room                                  Suppression - None Page 121

0                                                             0 Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire     Fire                                    Regulatory                                   Required?
Area     Zone      Description                      Basis               Type             S    L E R       D           Notes V-3            HVAC Rooms                         4.2.3.2 V-3    3-V-2  HVAC Room                                   Detection - None V-3    3-V-2  HVAC Room                                   Feature - None V-3    3-V-2  HVAC Room                                   Suppression - None V-3    3-V-3  HVAC Room                                   Detection - Smoke            N    N   Y   N   Y V-3    3-V-3  HVAC Room                                   Feature - None V-3    3-V-3  HVAC Room                                   Suppression - None V-3    3-V-4  HVAC Room                                   Detection - Smoke            N    N   N   N   N V-3    3-V-4  HVAC Room                                   Feature - None V-3    3-V-4  HVAC Room                                   Suppression - None V-3    3-V-9  HVAC Room                                   Detection - None V-3    3-V-9  HVAC Room                                   Feature - None V-3    3-V-9  HVAC Room                                   Suppression - None Page 122

Pacific Gas and Electric Company                                                             4.0 Compliance with NFPA 805 Requirements Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features NFPA 805 Fire      Fire                                   Regulatory                                   Required?
Area     Zone       Description                     Basis                Type            S    L E R       D           Notes V-4            HVAC Rooms                        4.2.3.2 V-4     3-V-6  HVAC Room                                   Detection - None V-4     3-V-6  HVAC Room                                   Feature - None V-4     3-V-6  HVAC Room                                  Suppression - None V-4     3-V-7  HVAC Room                                  Detection - Smoke            N    N   N   N   N V-4     3-V-7  HVAC Room                                   Feature - None V-4     3-V-7  HVAC Room                                  Suppression - None V-4     3-V-8  HVAC Room                                  Detection - Smoke            N    N   N   N   N
   %1-A    4-\/-P WIACO-m                                    f:.inf It- MNon                   -
V-A     3-V-8  HVAC Room                                  Suppression - None V-4    3-V-10  HVAC Room                                  Detection - None V-4    3-V-10  HVAC Room                                  Feature - None V-4    3-V-10  HVAC Room
* Suppression - None V-4    3-V-1I  HVAC Room                                  Detection - None V-4    3-V-11  HVAC Room                                  Feature - None V-4    3-V-11  HVAC Room                                  Suppression - None Page 123

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==5.0           REGULATORY EVALUATION==

5.1           Introduction - 10 CFR 50.48 On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative FP requirements. Federal Regulation 10 CFR 50.48 endorses, with exceptions, NFPA 805, 2001 Edition, as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b), Appendix R, and Section (f),
Decommissioning.
The voluntary adoption of 10 CFR 50.48(c) by PG&E does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, GDC 3, Fire Protection. The NRC addressed the overall adequacy of the regulations during the promulgation of 10 CFR 50.48(c) (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086).
             "NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(f). Those regulatoryrequirements continue to apply to licensees that adopt NFPA 805. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements may be met is different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs importantto safety, NFPA 805 identifies fire protection systems and features requiredto meet the Chapter I performance criteriathrough the methodology in Chapter4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii)requirement to limit fire damage to SSCs important to safety so that the capabilityto safely shut down the plant is ensured is satisfied by meeting the performance criteriain Section 1.5.1 of NFPA 805. The Section 1.5.1 criteriainclude provisions for ensuring that reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries,and process monitoring are achieved and maintained.
This methodology specifies a process to identify the fire protection systems and features requiredto achieve the nuclearsafety performance criteria in Section 1.5 of NFPA 805. Once a determination has been made that a fire protection system or feature is required to achieve the performance criteria of Section 1.5, its design and qualificationmust meet any applicable requirementsof NFPA 805, Chapter3. Having identified the requiredfire protection systems and features, the licensee selects either a deterministic orperformance-basedapproach to demonstrate that the performance criteriaare satisfied. This process satisfies the GDC 3 requirement to design and locate SSCs important to safety to minimize the probabilityand effects of fires and explosions." (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086)
The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a),
which requires each operating nuclear power plant to have a FP Program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the FP plan required by paragraph (a) of this section to reflect the licensee's decision to comply with NFPA 805." Therefore, to the extent that the contents of the existing FP Program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the FP Program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48 (a) and GDC 3 have corresponding requirements in NFPA 805.
Page 124

Pacific Gas and Electric Comnanv                                                       5.0 Reoulatorv Evaluation A comparison of the current requirements in Appendix R with the comparable requirements in Section 3 of NFPA 805 shows that the two sets of requirements are consistent in many respects. This was further clarified in FAQ 07-0032, Clarification of 10 CFR 50.48(c),
10 CFR 50.48(a) and GDC 3 clarification (ML081300697). The following tables provide a cross reference of FP regulations associated with the post-transition DCPP FP Program and applicable industry and DCPP documents that address the topic.
10 CFR 50.48(a)
Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s)                         Applicability/Compliance Reference (1) Each holder of an operating license issued under this       See below part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of Appendix A to this part. This fire protection plan must:
(i) Describe the overall fire protection program for the   NFPA 805 Section 3.2 facility;                                                  NEI 04-02, Revision 2, Table B-1 (ii)Identify the various positions within the licensee's   NFPA 805 Section 3.2.2 organization that are responsible for the program;         NEI 04-02, Revision 2, Table B-1 (iii) State the authorities that are delegated to each of  NFPA 805 Section 3.2.2 these positions to implement those responsibilities; and   NEI 04-02, Revision 2, Table B-1 (iv) Outline the plans for fire protection, fire detection NFPA 805 Section 2.7 and Chapters 3 and 4 and suppression capability, and limitation of fire         NEI 04-02, Revision 2, B-1 and B-3 Tables damage.
(2) The plan must also describe specific features               See below necessary to implement the program described in Paragraph (a)(1) of this section such as:
(i) Administrative controls and personnel requirements     NFPA 805 Sections 3.3.1 and 3.4 for fire prevention and manual fire suppression            NEI 04-02, Revision 2, Table B-1 activities; (ii)Automatic and manually operated fire detection and     NFPA 805 Sections 3.5 through 3.10 and suppression systems; and                                   Chapter 4 NEI 04-02, Revision 2, B-1 and B-3 Tables (iii) The means to limit fire damage to structures,        NFPA 805 Section 3.3 and Chapter 4 systems, or components important to safety so that the     NEI 04-02, Revision 2, B-3 Table capability to shut down the plant safely is ensured.
(3) The licensee shall retain the fire protection plan and      NFPA 805 Section 2.7.1.1 requires that each change to the plan as a record until the              documentation (Analyses, as defined by NFPA 805 Commission terminates the reactor license. The             2.4, performed to demonstrate compliance with this licensee shall retain each superseded revision of the     standard) be maintained for the life of the plant.
procedures for 3 years from the date it was               DCPP Procedure AD10.1D1, "Storage and Control superseded.                                               of Quality Assurance Records" (Reference 6.52),
Storage and Control of Quality Assurance Records (4) Each applicant for a design approval, design               Not applicable. DCPP is licensed under certification, or manufacturing license under part 52 of  10 CFR 50.
this chapter must have a description and analysis of the fire protection design features for the standard plant necessary to demonstrate compliance with Criterion 3 of Appendix A to this part.
Page 125

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                                                  *                                             *qI*uIaL.JI a      IEVGIUGLI..UIU General Design Criterion 3 Table 5-2 GDC 3 - Applicability/Compliance Reference GDC 3, Fire Protection, Statement                         Applicability/Compliance Reference Structures, systems, and components important to               NFPA 805 Chapters 3 and 4 safety shall be designed and located to minimize,              NEI 04-02, Revision 2, B-1 and B-3 Tables consistent with other safety requirements, the probability and effect of fires and explosions.
Noncombustible and heat resistant materials shall be           NFPA 805 Sections 3.3.2, 3.3.3, 3.3.4, 3.11.4 used wherever practical throughout the Unit,                   NEI 04-02, Revision 2, B-1 Table particularly in locations such as the containment and control room.
Fire detection and fighting systems of appropriate             NFPA 805 Chapters 3 and 4 capacity and capability shall be provided and designed         NEI 04-02, Revision 2, B-1 and B-3 Tables to minimize the adverse effects of fires on structures, systems, and components important to safety.
Firefighting systems shall be designed to assure that          NFPA 805 Sections 3.4 through 3.10 and 4.2.1 their rupture or inadvertent operation does not                 NEI 04-02, Revision 2, Table B-3 significantly impair the safety capability of these structures, systems, and components.
10 CFR 50.48(c)
Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                              Applicability/Compliance Reference (1) Approval of incorporationby reference. NFPA 805 2001 Edition , which is              General Information.
referenced in this section, was approved for incorporation by reference by        NFPA 805 (2001 Edition) is the Director of the Federal Register pursuant to 5 U.S.C. 552(a) and               the edition used.
1 CFR Part 51.
(2) Exceptions, modifications, and supplementation of NFPA 805. As used in               General Information.
this section, references to NFPA 805 are to the 2001 Edition, with the             NFPA 805 (2001 Edition) is following exceptions, modifications, and supplementation:                         the edition used.
(i) Life Safety Goal, Objectives, and Criteria.The Life Safety Goal,              The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed.                           Objectives, and Criteria of Chapter 1 of NFPA 805 are not part of the LAR.
(ii)PlantDamage/Business Interruption Goal, Objectives, and Criteria.The          The Plant Damage/Business Plant Damage/Business Interruption Goal, Objectives, and Criteria of              Interruption Goal, Objectives, Chapter 1 are not endorsed.                                                       and Criteria of Chapter 1 of NFPA 805 are not part of the LAR.
(iii) Use of feed-and-bleed. In demonstrating compliance with the                 Feed and bleed is not utilized performance criteria of Sections 1.5.1(b) and (c), a high-pressure                as the sole fire-protected safe charging/injection pump coupled with the pressurizer power-operated relief        shutdown methodology.
valves (PORVs) as the sole fire-protected safe shutdown path for maintaining reactor coolant inventory, pressure control, and decay heat removal capability (i.e., feed-and-bleed) for pressurized-water reactors (PWRs) is not permitted.
(iv)Uncertainty analysis. An uncertainty analysis performed in accordance        Uncertainty analysis was not with Section 2.7.3.5 is not required to support deterministic approach            performed for deterministic calculations.                                                                     methodology.
Page 126

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Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                           Applicability/Compliance Reference (v) Existing cables. In lieu of installing cables meeting flame propagation         Electrical cable construction tests as required by Section 3.3.5.3, a flame-retardant coating may be              complies with a flame applied to the electric cables, or an automatic fixed fire suppression system       propagation test that was may be installed to provide an equivalent level of protection. In addition, the     found acceptable to the NRC italicized exception to Section 3.3.5.3 is not endorsed.                            as documented in NEI 04-02, Revision 2, Table B-I.
(vi) Water supply and distribution. The italicized exception to Section 3.6.4 is    DCPP complies with not endorsed. Licensees who wish to use the exception to Section 3.6.4              NFPA 3.6.4 (without the use must submit a request for a license amendment in accordance with                    of the exception) as paragraph (c)(2)(vii) of this section.                                              documented in NEI 04-02, Revision 2, Table B-I.
(vii) Performance-based methods. Notwithstanding the prohibition in                 The use of performance-Section 3.1 against the use of performance-based methods, the fire                  based methods for NFPA 805 protection program elements and minimum design requirements of                      Chapter 3 is requested. See Chapter 3 may be subject to the performance-based methods permitted                 Attachment L.
elsewhere inthe standard. Licensees who wish to use performance-based methods for these fire protection program elements and minimum design requirements shall submit a request in the form of an application for license amendment under &sect; 50.90. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application ifthe Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
(3) Compliance with NFPA 805.                                                              See below (i)A licensee may maintain a fire protection program that complies with             The LAR was submitted in NFPA 805 as an alternative to complying with paragraph (b) of this section          accordance with for plants licensed to operate before January 1, 1979, or the fire protection       10 CFR 50.90. The LAR license conditions for plants licensed to operate after January 1, 1979. The        included applicable license licensee shall submit a request to comply with NFPA 805 inthe form of an            conditions, orders, technical application for license amendment under &sect; 50.90. The application must               specifications/bases that identify any orders and license conditions that must be revised or                  needed to be revised and/or superseded, and contain any necessary revisions to the plant's technical            superseded.
specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.
(ii)The licensee shall complete its implementation of the methodology in           The LAR and transition report Chapter 2 of NFPA 805 (including all required evaluations and analyses)            summarize the evaluations and, upon completion, modify the fire protection plan required by paragraph        and analyses performed in (a) of this section to reflect the licensee's decision to comply with NFPA 805,    accordance with Chapter 2 of before changing its fire protection program or nuclear power plant as              NFPA 805.
permitted by NFPA 805.
Page 127

                                                                                          .* fl R*nldntnrv I*vnhntinn Evaluation Pacific Gas and Electric Co nanu                                                          A 0 Renul2f-rv Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                                ApplicabilitylCompliance Reference (4) Risk-informed or performance-based alternatives to compliance with                 No risk-informed or NFPA 805. A licensee may submit a request to use risk-informed or                 performance-based performance-based alternatives to compliance with NFPA 805. The request           alternatives to compliance must be in the form of an application for license amendment under &sect; 50.90 of      with NFPA 805 (per this chapter. The Director of the Office of Nuclear Reactor Regulation, or        10 CFR 50.48(c)(4)) were designee of the Director, may approve the application if the Director or          utilized.
designee determines that the proposed alternatives:
(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
5.2          Regulatory Topics 5.2.1        License Condition Changes The current DCPP fire protection license conditions 2.C.5 for Unit 1 and 2.C.4 for Unit 2 are being replaced with the standard license condition in Regulatory Position C.3.1 of RG 1.205, Revision 1, as shown in Attachment M.
5.2.2        Technical Specifications PG&E conducted a review of the Technical Specifications (TS) to determine which TS are required to be revised, deleted, or superseded. PG&E determined that the changes to the TS and applicable justification listed in Attachment N are adequate for the DCPP adoption of the new FP licensing basis.
5.2.3        Orders and Exemptions A review was conducted of the DCPP docketed correspondence to determine if there were any orders or exemptions that needed to be superseded or revised. A review was also performed to ensure that compliance with the physical protection requirements, security orders, and adherence to those commitments applicable to the plant are maintained. A discussion of affected orders and exemptions is included in Attachment 0.
5.3          Regulatory Evaluations 5.3.1        No Significant Hazards Consideration A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
* Involve a significant increase in the probability or consequences of an accident previously evaluated; or
* Create the possibility of a new or different kind of accident from any accident previously evaluated; or Page 128

P2r~ifir~ ~   ~nrI FI~r~tr.r~ C~nmn2nu                                    .* fl R*nHlntnrv l:vnl.ntinn Pacific Gas and Electric Cornnanv                                         5 0 Renulatoru   Evaluation
* Involve a significant reduction in a margin of safety.
This evaluation is contained in Attachment Q.
Based on the considerations discussed above; (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. PG&E has evaluated the proposed amendment and determined that it involves no significant hazards consideration.
5.3.2      Environmental Consideration Pursuant to 10 CFR 51.22(b), an evaluation of the LAR has been performed to determine whether it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c). That evaluation is discussed in Attachment R. The evaluation confirms that this LAR meets the criteria set forth in 10 CFR 51.22(c)(9) for categorical exclusion from the need for an environmental impact assessment or statement.
5.4        Revision to the UFSAR After the approval of the LAR, in accordance with 10 CFR 50.71(e), the DCPP UFSAR will be revised. The format and content will be consistent with NEI 04-02, Revision 2, FAQ 12-0062.
5.5        Transition Implementation Schedule The following schedule for transitioning DCPP to the new FP licensing basis requires NRC approval of the LAR in accordance with the following schedule:
Implementation of the new NFPA 805 FP Program to include procedure changes, process updates, and training to affected plant personnel will occur 180 days after issuance of the license amendment (see Attachment S, Table S-3).
PG&E will complete modifications necessary to support the new FP licensing basis for transitioning to NFPA 805 by the end of the Units 1 and 2 Refueling Outages, currently scheduled for April/May 2017 (1R20) and February/March 2018 (2R20), respectively. All modifications have been planned and are in the site's long term budget. Appropriate compensatory measures will be established per OM8.1D2, "Fire System Impairment," and maintained until modifications are complete (see Attachment S, Table S-2).
Page 129

6 0 References~B Pac~ifii' GasQ :1-1 Elw-fric Co nanvn

==6.0        REFERENCES==

The following references were used in the development of the TR. Additional references are in the NEI 04-02, Revision 2, Tables in the various Attachments:
6.1.       10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," U.S.
Nuclear Regulatory Commission, Washington, DC.
6.2.       NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition 6.3.       NEI 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," Revision 1, January 2005 6.4.       NEI 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," Revision 2, May 2009 6.5.       NEI 04-02, "Guidance for Implementing A Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2, April 2008 6.6.       Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2, May 2011 6.7.       Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," Revision 2, March 2009 6.8.       Regulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Revision 1, December 2009 6.9.       NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities", September 2005 6.10.      SECY-1 1-0061, "A request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," June 10, 2011 6.11.      PG&E Letter DCL-05-0153, "Letter of Intent to Adopt NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition," December 29, 2005 (ML060100480) 6.12.      NRC Letter "NRC Response to Pacific Gas and Electric Company's Letter of Intent to Adopt 10 CFR 50.48(c) (NFPA 805 Rule) For Diablo Canyon Power Plant, Units 1 and 2," March 1, 2006 (ML060600229) 6.13.      NRC Letter "Period of Enforcement Discretion During Implementation of National Fire Protection Association Standard 805, Diablo Canyon Power Plant, Units 1 and 2," April 29, 2007 (ML062020316) 6.14.      PG&E Letter DCL-08-088, "Request for Extension of Enforcement Discretion and Revised Submittal Date for 10 CFR 50.48(c) (NFPA 805) License Amendment Request," October 15, 2008 (ML082970259) 6.15.      NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Evaluation of the Request for an Extension of Enforcement Discretion in Accordance with the Interim Enforcement Policy for Fire Protection Issues During Transition to National Fire Page 130

n0  ^;S;^ 1,_-      *.4    r'M-        1.; t'%   m     ...                                a  nl Dnnrann al=I.lI G ** 11:  0   IU    - a%*I.LI %LL,   W.1J L tJ1l   y                              v.IG    G   II G.
Protection Association Standard NFPA 805 (TAC Nos. ME0075 and ME0076,"
December 19, 2008 (ML083170652) 6.16.        PG&E Letter DCL-1 1-076, "Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request,"
June 24, 2011 (ML111751786) 6.17.        NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Commitment to Submit a License Amendment Request to Transition to 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805, and Request to Extend Enforcement Discretion (TAC Nos. ME6634 and ME6635)," July 28, 2011 (ML112010657) 6.18.        Report P1890-002-001, "NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review," Revision 4, June 2013 6.19.        Report R1890-012-001, "Nuclear Safety Performance Analysis Methodology Review," Revision 4, June 2013 6.20.        Report P1890-002-003, "Engineering Evaluation Review," Revision 3, June 2013 6.21.        Report R2049-005-001, "Non-Power Operation Modes Review," Revision 2, June 2013 6.22.        Report R2165-004-001, "Nuclear Safety Capability Assessment," Revision 0, June 2013 6.23.        PG&E Calculation SAP No. 9000041465 (Legacy No. M-1176), Part 000, Version 00, "NFPA 805 Radioactive Release Review" 6.24.        Report R2165-042-001, "Recovery Action Feasibility Assessment Report," Revision 0, June 2013 6.25.        Report No.TE-PGE-1 13-ROO1, "Multiple Spurious Operation Report," Revision 0, November 3, 2010 6.26.        American Society of Mechanical Engineers (ASME) RA-Sa-2003, Addenda to ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," December 5, 2003 6.27.        Electric Power Research Institute (EPRI) Technical Report TR-1 006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features," July 2003 6.28.        ASME/ANS RA-Sa-2009, "Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications," ASME and the American Nuclear Society, February 2009 6.29.        ANSI/ANS 58.23-2007, "Fire PRA Methodology," American Nuclear Society, November 2007 6.30.        DCPP Departmental Administrative Procedure TS3.NR1, "Probabilistic Risk Assessment (PRA)"
6.31.        PRA Calculation File No. F.3.1, "Plant Boundary Definition and Partitioning" 6.32.         PRA Calculation File No. F.3.2, "Fire PRA Component Selection" 6.33.         PRA Calculation File No. F.3.2.1, "Fire PRA Containment Initial Screening" 6.34.         PRA Calculation File No. F.3.5, "Development of Fire-Induced Risk Model" Page 131

Pacific Gas and Electric Comnanv                                                    6-0 Refemrences 6.35. PRA Calculation File No. F.3.6, "Fire PRA Ignition Frequency Calculation" 6.36. PRA Calculation File No. F.3.9 (134A-DC), "Associated Ckt Analysis - Fire Protection" 6.37. PRA Calculation File No. F.3.10, "Fire PRA Circuit Failure Mode Likelihood Analysis" 6.38. PRA Calculation File No. F.3.1 1b, "Main Control Room Fire Modeling" 6.39. PRA Calculation File No. F.3.1 1c, "Fire PRA Multi-Compartment Analysis for Units 1
           & 2" 6.40. PRA Calculation File No. F.3.1 1d, "Fire-Induced Failure of Structural Steel for Units 1
           & 2" 6.41. PRA Calculation File No. F.3.12, "Post-Fire Human Reliability Analysis" 6.42. PRA Calculation File No. F.3.13, "Seismic Fire Interaction Assessment" 6.43. PRA Calculation File No. F.3.15, "Uncertainty and Sensitivity Analysis" 6.44. PRA Calculation File No. G.2, "Human Action Analysis - Failure Likelihood and Range Factor Calculation" 6.45. EPM Division Procedure EPM-DP-RSD-001, "Fire Risk Evaluation" 6.46. DCPP Departmental Administrative Procedure AD8.DC55, "Outage Safety Scheduling"
   .6.47. NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management," December 1991 6.48. PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T ), Part 000, Version 02, "NFPA 805 Transition Circuit Analysis" 6.49. DCA 9000041373-000-00 (N-315), "Liquid Effluent Release to the Unrestricted Area Boundary Due to a Fire," Part 000, Version 000, January 15, 2013 6.50. DCA 9000041374-000-00 (N-316), "Gaseous Effluent Release to the Unrestricted Area Boundary Due to Fire," Part 000, Version 000, January 15, 2013 6.51. Report R2165-007-001, "NFPA 805 Risk Informed Performance Based Fire Risk Evaluations," Revision 1, June 2013 6.52. DCPP Interdepartmental Administrative Procedure AD10.1D1, "Storage and Control of Quality Assurance Records" 6.53. NRC Inspection Manual 0609 Appendix G Attachment 2, "NRC Shutdown SDP Process," Issue February 28, 2005 6.54. American Society of Mechanical Engineers (ASME)RA-Sb-2005, Addenda to ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," December 30, 2005 6.55. PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, "Associated CKT Analysis - Fire Protection" 6.56. DCPP SAP Notification 50541381, "NFPA 805 - Gap Analysis of FAQ 07-0038" 6.57. Report R2291-004-001, "Licensing Action Review Report" Revision 2, June 2013 Page 132

0   if; r_1        .4 Cl     + ;   t-  -                                            AI Al 92faran*aa Oar          a U Uimll,    l *IGLI     . rnWnb!".,11 I                                          m C m   ifira,im 6.58.      Report R2165-008-001, "Fire Area Transition Review Report (Table B-3 Report),"
Revision 1, June 2013 6.59.      DCPP Administrative Work Procedure AWP E-028, "PRA Model Maintenance and Upgrades" 6.60.      DCPP Interdepartmental Administrative Procedure MA1.ID17, "Maintenance Rule Monitoring Program" 6.61.      DCPP Interdepartmental Administrative Procedure TS5.ID1, "System Engineering Program" 6.62.      DCPP Interdepartmental Administrative Procedure OM15.1D6, "Station Programs" 6.63.      DCPP Interdepartmental Administrative Procedure OM7.ID1, "Problem Identification and Resolution" 6.64.      DCPP Program Directive CF4, "Modification Control" 6.65.      DCPP Interdepartmental Administrative Procedure CF3.1D9, "Design Change Development" 6.66.      DCPP Interdepartmental Administrative Procedure ADl.ID2, "Procedure Process Control" 6.67.      Report P1 890-002-004, "Fire Protection Code Conformance Review" Revision 1, March 2013 6.68.       DCPP Program Directive CF3, "Design Control" 6.69.       DCPP Interdepartmental Administrative Procedure CF3.ID4, "Design Calculations" 6.70.       DCPP Interdepartmental Administrative Procedure CF3.1D17, "Design and Analysis Documents Prepared by External Contractors" 6.71.       DCPP Program Directive OM8, "Fire Protection Program" 6.72.       DCPP Program Directive TQ2, "Accredited Training Programs" 6.73.       DCPP Interdepartmental Administrative Procedure OM7.1D13, "Technical Evaluations" 6.74.       DCPP Interdepartmental Administrative Procedure OM15.1D2, "Change Management" 6.75.       DCPP Interdepartmental Administrative Procedure CF3.1D15, "Development and Independent Verification of Calculations" 6.76.       U.S. Nuclear Regulatory Commission to PG&E, "Diablo Canyon Units 1 and 2 Safety Evaluation Report," Supplement 23, SSER 23, June 1984 6.77.        U.S. Nuclear Regulatory Commission to PG&E, "Diablo Canyon Unit 2 Safety Evaluation Report, Supplement 31," SSER 31, April 1985 6.78.       U.S. Nuclear Regulatory Commission to PG&E, "Diablo Canyon Units 1 and 2 Safety Evaluation Report, Supplement 32," SSER 32, July 1985 6.79.       PG&E Letter, Diablo Canyon Power Plant Unit 1 to NRC, "Report on Deviations from Appendix R of 10 CFR 50," July 15, 1983 6.80.       PG&E Letter, Diablo Canyon Power Plant Unit 1 to NRC, "Additional Information on Appendix R Review," September 23, 1983 Page 133

Dn^M^ flne  &#xfd;nA          f-   mn                                                 Aft 0-f Dfn       -*
6.81. PG&E Letter, Diablo Canyon Power Plant Unit 2 to NRC, "Fire Protection Review for Conformance to 10 CFR 50, Appendix R," December 6, 1984.
6.82. PRA Calculation File No. C.9, "Quantification of CDF and LERF for the DCPP PRA Model," Revision 11, November 23, 2012 6.83. PRA Calculation, "DCPP Internal Flooding Report - Section 12," Revision original, November 23, 2012 6.84. Westinghouse letter LTR-RAM-II-08-019, "Pilot Application of the Fire PRA Peer Review Process for the Diablo Canyon Power Plant Fire Probabilistic Risk Assessment," October 17, 2008 6.85. Westinghouse letter LTR-RAM-11-1 1-004, "Fire PRA Peer Review Against the Fire PRA Standard Supporting Requirements From Section 4 of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications for the Diablo Canyon Plant Fire Probabilistic Risk Assessment," May 24, 2011 6.86. Westinghouse letter LTR-RAM-II-13-002, "RG 1.200 PRA Peer Review Against the ASME/ANS PRA Standard Requirements for the Diablo Canyon Nuclear Plant Probabilistic Risk Assessment," March 20, 2013 6.87. Westinghouse letter LTR-RAM-1 3-04, "Peer Review of Diablo Canyon Power Plant Probabilistic Risk Assessment Against the Seismic PRA Standard Supporting Requirements of the ASME/ANS Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessments for Nuclear Power Plant Applications,"
May 1, 2013 6.88. U.S. Nuclear Regulatory Commission to PG&E "Review of Diablo Canyon Individual Plant Examination of External Events (IPEEE) Submittal (TAC Nos. M83614 and M83615)," December 4, 1997 6.89. Report R-1 736044-1728, "Diablo Canyon Follow-On Peer Review HRA Update,"
August 10, 2007 Page 134

f;    r_-    A Cl 4- ; fl                          A H'a,-     nt +'
0%%,r     &#xfd;"   El      fnI rnwll~a             -.-             -
                                                           ..... L-kmo Attachments Page 135

Attachment A - NEI 04-02 Table B-1 Pacific Gas and Electric Company                       Transition of FPP & Design Elements A. NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements 124 Pages Page A-1

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                   Compliance Statement       Compliance Basis         Reference Document 3.1 General               This chapter contains the              N/A                  N/A - General statement; No    N/A fundamental elements of the fire                            technical requirements 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.
3.2 Fire Protection Plan  N/A                                    N/A                  N/A - Section Heading, see     N/A sub-sections for any specific compliance statements 3.2.1 Intent             A site-wide fire protection plan shall
* Complies           No Additional Clarification    OM8, "Fire Protection Program,"
be established. This plan shall                                                            Revision 4, All Sections 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.
Page A-2

0                                                                      0 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement      Comliance Basis           Reference Document 3.2.2 Management         A policy document shall be prepared       . Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Policy Direction and     that defines management authority                                                             Revision 4, Section 5 Responsibility           and responsibilities and establishes the general policy for the site fire protection program.
3.2.2.1 [Management      The policy document shall designate
* Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Policy on Senior         the senior management position with                                                           Revision 4, Section 5.1 Management]              immediate authority and responsibility for the fire protection program.
3.2.2.2 [Management      The policy document shall designate
* Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Policy on Daily          a position responsible for the daily                                                          Revision 4, Section 4.2.3 and 5.10 Administration]          administration and coordination of the fire protection program and its implementation.
3.2.2.3 [Management      The policy document shall define the      &deg; Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Policy on Interfaces]    fire protection interfaces with other                                                         Revision 4, Sections 5, 6, and 7 organizations and assign responsibilities for the coordination of                                                      OM8.1D1, "Fire Loss Prevention,"
activities. In addition, this policy                                                          Revision 24, Section 4 document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.
3.2.2.4 [Management      The policy document shall identify       - Complies            No Additional Clarification    OM8, "Fire Protection Program,"
Policy on AHJ]           the appropriate AHJ for the various                                                           Revision 4, Sections 3.2 and 3.3 areas of the fire protection program.
Page A-3
* 0 T
Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                   Compliance Statement       Comoliance Basis         Reference Document 3.2.3 Procedures         Procedures shall be established for     N/A                  N/A - General statement; No    N/A implementation of the fire protection                        technical requirements program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:
Page A-4

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement       Comoliance Basis          Reference Documnent 3.2.3(1) Procedures (1)  Inspection, testing, and maintenance     " Complies           The current program complies    0M8, "Fire Protection Program,"
for fire protection systems and          " Submit for NRC     with the requirements of this   Revision 4, Section 6 features credited by the fire           Approval              section.
protection program                                                                            Surveillance Test Procedures (STPs)
Submit for NRC Approval:        concerning fire system components:
NRC approval is requested in Attachment L for the use of     MP 1-1.18-1, Servicing & Testing Pyr-performance-based               Alarm Fire Detectors surveillance frequencies as described in Electric Power     MP 1-i 8-Li1 11, Cardox Storage Tank Research Institute (EPRI)       0-i Level Channel LI-i 1i/LS-i 11 Technical Report TR-1 006756,   Calibration "Fire Protection Surveillance Optimization and Maintenance    MP 1-i 8-1_1189, Fire Water Storage Guide for Fire Protection       Tank 0-i Level LI-i 89 Calibration Systems and Features" for the inspection, testing, and        MP 1-i18-L-38, Firewater Storage Tank maintenance of fire protection  Level Channel LT-38 Calibration systems and features credited by the fire protection program. MP 1-1 8-P258, Standby S/U Transformers i-1 and 1-2 Deluge System PS-258 Calibration MP 1-i18-P259, Standby S/U Transformer 2-i Deluge System PS-259 Calibration MP I-i18-132611, Firewater Deluge System PS-261 Calibration MP 1-i 8-SBi DET, Security Building Fire Detection System Functional MP l-EAi 5, Calibration of Pyrotronics SCU-9 Fire Detector Sensitivity Test Set MP M-1i8.i1, Fire Pump Disassembly, Page A-5

P Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Comoliance Statement      Compliance Basis          Reference Document Repair and Reassembly MP M-18.2, Service, Tagging, Charging and Hydrostatic Testing of Portable Fire Extinguishers MP M-1 8.4, Firewater System Flush Through RCP Sprinkler Headers STP I-1A, Routine Shift Checks Required by Licenses STP I-1C, Routine Weekly Checks Required By Licenses STP 1-34, Functional Test: Fire Detection System STP 1-34A, Fire Detection System Detector Functional Panel A STP 1-34B, Fire Detection System Detector Functional Panel B STP 1-34C, Fire Detection System Supervisory Functional STP 1-34D, Fire Detection System Detector Functional Panel D STP 1-34E, Plant Elevator Smoke Detector Functional Test STP 1-34G, Fire Detection System Panel Voltage Test STP 1-34H, Fire Detection System RTD Calibration Check Page A-6

P0 Ga Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                Compliance Statement      Compliance Basis           Reference Document STP 1-341, Fire Protection System Data Gathering Panel Backup Battery Test STP 1-34L, POFC Detector and Panel Functional Test STP M-1 12, Test of Backup Air Accumulator System to FCV-633 Fire Water to Containment STP M-39A1, Routine Surveillance Test of Diesel Generator 1-1 (2-1)
Room Carbon Dioxide Fire System Operation STP M-39A2, Routine Surveillance Test of Diesel Generator 1-2 (2-2)
Room Carbon Dioxide Fire System Operation STP M-39A3, Routine Surveillance Test of Diesel Generator 1-3 (2-3)
Room Carbon Dioxide Fire System Operation STP M-39B, Routine Surveillance Test of Cable Spreading -Room Carbon Dioxide Fire System Operation STP M-39C, Routine Surveillance Test of Turbine Lube Oil Room Carbon Dioxide Fire System Operation STP M-39D, Routine Surveillance Page A-7

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Comoliance Statement      Compliance Basis          Reference Document Test of Carbon Dioxide Hose Reels STP M-39E, Routine Surveillance Test of Turbine Generator Bearing No. 10 Carbon Dioxide Fire System Operation STP M-39F, Routine Surveillance Test of Circulating Water Pump High Pressure Carbon Dioxide Fire System Operation STP M-39G, Routine Surveillance Test of Circulating Water Pump High Pressure Carbon Dioxide Fire System Detector Operation STP M-39H, C02 Cylinder Periodic Weighing and Maintenance for Circulating Water Pump Motor Protection System STP M-63A, Fire Water System Flow Alarm Test STP M-63B, Fire Water Deluge System Flow Test STP M-63C, Fire Water System Functional Test of the Fuel Handling and Radwaste Buildings STP M-63D, Fire Water Main System Functional Test of the Turbine Buildings STP M-63E, Fire Water System Yard Loop Flush Page A-8

P0 Ga Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A    - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement      Compliance Basis           Reference Document STP M-63F, Yard Loop Fire Water System Hydrant Flush STP M-63G, South Site Fire Water Loop System Hydrant Flush STP M-63H, Containment Fire Water FS-25 Flow Test STP M-64, Deluge System Functional Test STP M-65, Sprinkler/Deluge System Visual Verification STP M-66A, Deluge System Nozzle Proof Test Startup Transformers STP M-66B, Deluge System Nozzle Proof Test Main and Auxiliary Transformers STP M-67B1, Containment Fire Hose Reel Station Inspection STP M-67B2, Containment Fire Hose Reel Station Inspection STP M-67B3, Containment Firewater Flow Path Valve Inspection STP M-67B4, Containment Firewater Flow Path Valve Inspection STP M-67C, Monthly Hose Reel Station Inspection Page A-9
* a                                                              0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement      Compliance Basis           Reference Document STP M-69A, Monthly Fire Extinguisher Station Inspection Inside the Protected Area STP M-69B, Monthly C02 Hose Reel and Deluge Valve Inspection STP M-69C, Monthly Fire Extinguisher Station Inspection Outside the Protected Area STP M-70A, Inspection of Fire Barrier and HELB Penetration Seals STP M-70B, Inspection and Testing of Fire Dampers STP M-70C, Inspection of ECG Doors STP M-70D, Inspection of Fire Barriers, Rated Enclosures, Credited Cable Tray Fire Stops, and Equipment Hatches STP M-71, Firewater System Flow Test STP M-71 B, South Side Firewater System Flow Test STP M-72, Exercising Valves FCV-200, 201, and 203 through 207, FWP Turbines, MN Turbine Bearings and H2 Seal Oil Deluge STP M-79, Indoor Fire Hose Inspection Page A-10

0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Comnliance Statement      Compliance Basis          Reference Document STP M-80A, Outdoor Fire Hose Operability Test STP M-80B, Indoor Fire Hose Operability Test STP M-80C, Long Term Cooling Water Pump Hose Annual Operability and Hydrostatic Test STP M-80D, Fire Hose Hydrostatic Testing STP P-24, Testing of the Portable Long Term Cooling Pumps STP P-FPP-AO1, Fire Pump 0-1 Performance Test STP P-FPP-A02, Fire Pump 0-2 Performance Test STP P-FPP-A03, Fire Pump 0-3 Performance Test STP P-FPP-A04, Fire Pump 0-4 Performance Test STP P-FPP-BO1, Fire Pump 0-1 Routine Surveillance STP P-FPP-B02, Fire Pump 0-2 Routine Surveillance STP P-FPP-B03, Fire Pump 0-3 Routine Surveillance STP P-FPP-B04, Fire Pump 0-4 Page A-11

0                                                                     S Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Elemnent        NFPA 805 Reauirement                    Compliance Statement      Comoliance Basis          Reference Document Routine Surveillance STP V-3Q1, Exercising Fire Suppression System Sectionalizing, Isolation, and Supply Valves STP V-3Q3, Exercising South Site Loop Fire Suppression System Sectionalizing, Isolation, and Supply Valve 3.2.3(2) Procedures (2)  Compensatory actions implemented
* Complies           No Additional Clarification    0M8.1D2, "Fire System Impairment,"
when fire protection systems and                                                            Revision 17, Section 5.3 other systems credited by the fire protection program and this standard                                                        ECG 18.1, "Fire Suppression cannot perform their intended                                                               Systems/Fire Suppression Water function and limits on impairment                                                           Systems," Revision 9, All Sections duration ECG 18.2, "Fire Hose Stations,"
Revision 9, All Sections ECG 18.3, "Fire Detection Instrumentation," Revision 10, All Sections ECG 18.4, "Spray and/or Sprinkler Systems," Revision 6, All Sections ECG 18.5, "C02 System," Revision 9, All Sections ECG 18.7, "Fire Rated Assemblies,"
Revision 9, All Sections Page A-12

N                                                                       S Pacific Gas and Electric Company                        Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NE3PA 805 Element              NFPA 805 Reauirement                           Comoliance Statement             Comoliance Basis         Reference Document 3.2.3(3) Procedures (3)        Reviews of fire protection program        -     - Complies, with           Complies once Implementation   TS5.DC1, "Engineering Programs,"
related performance and trends                  Required Action            Item S-3.1 is completed.       Revision 5, All Sections TS5.ID1, "System Engineering Program," Revision 18, All Sections IMPLEMENTATION ITEMS:
S-3.1    SAP Notification #50399288 was issued to track the development and implementation of the NFPA 805 monitoring program for DCPP.
3.2.3(4) Procedures (4)        Reviews of physical plant                       - Complies                No Additional Clarification     CF3.1D9, "Design Change modifications and procedure                                                                               Development," Revision 43, All changes for impact on the fire                                                                            Sections protection program CF4, "Modification Control,"
Revision 7, Section 7.1.17 AD1.ID2, "Procedure Process Control," Revision 34 CF3.1D4, "Design Calculations,"
Revision 21 TS3.1D2, "Licensing Basis Impact Evaluations," Revision 34A Page A-13

Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement      Compliance Basis          Reference Document 3.2.3(5) Procedures (5)  Long-term maintenance and                 - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
configuration of the fire protection                                                          Revision 4, All Sections program CF3.1D9, "Design Change Development," Revision 43, All Sections X13, "Licensing Basis Documents,"
Revision 4, All Sections CF3.1D4 "Design Calculations,"
Revision 21 TS5.DC1, "Engineering Programs" Revision 5, All Sections 3.2.3(6) Procedures (6)  Emergency response procedures for
* Complies           No Additional Clarification    Casualty Procedure (CP) M-6, "Fire,"
the plant industrial fire brigade                                                             Revision 33A, All Sections Pre-Fire Plans 3.3 Prevention           A fire prevention program with the
* Complies           No Additional Clarification    OM8, "Fire Protection Program,"
goal of preventing a fire from starting                                                       Revision 4 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:
Page A-14

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.3(1) Prevention (1)    Prevention of fires and fire spread by  - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
controls on operational activities                                                           Revision 4, Section 4.6 OM8.1D1, "Fire Loss Prevention,"
Revision 24, Section 5.3 OM8.1D2, "Fire System Impairment,"
Revision 17, All Sections OM8.1D4, "Control of Flammable and Combustible Materials," Revision 19, All Sections AD7.DC6, "On-Line Maintenance Risk Management," Revision 20 AD7.DC8, "Work Planning,"
Revision 42 AD7.DC11, "Program Governance for On-Line Maintenance Risk Management," Revision 1 3.3(2) Prevention (2)    Design controls that restrict the use   - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
of combustible materials.                                                                   Revision 4, Section-4.2- -..
The design control requirements                                                             OM8.1D1, "Fire Loss Prevention,"
listed in the remainder of this section                                                     Revision 24, All Sections shall be provided as described.
OM8.1D4, "Control of Flammable and Combustible Materials," Revision 19, All Sections CF3.1D9, "Design Change Development," Revision 43, Sections 5.4.1, 8.3.8, and Attachment 9 Page A-IS5

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                      Compliance Statement       Compliance Basis          Reference Document 3.3.1 Fire Prevention     The fire prevention program activities
* Complies           No Additional Clarification     OM8, "Fire Protection Program,"
for Operational           shall consist of the necessary                                                                 Revision 4, All Sections Activities                elements to address the control of ignition sources and the use of                                                                OM8.ID1, "Fire Loss Prevention,"
transient combustible materials                                                                Revision 24, All Sections during all aspects of plant operations. The fire prevention                                                                OM8.1D4, "Control of Flammable and program shall focus on the human                                                               Combustible Materials," Revision 19, and programmatic elements                                                                      All Sections 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      The fire prevention activities shall      N/A                  Plant procedures for fire       Refer to basis documentation in the Prevention Activities     include but not be limited to the                              prevention activities have been sub-sections of this element.
following program elements:                                    implemented. The procedures address, at a minimum, the FPP elements identified in this section, but are not limited to these elements. The NFPA 805 code requirements for this element are satisfied.
3.3.1.1(1) General Fire   Training on fire safety information for
* Complies           No Additional Clarification     General Employee Training (GET)
Prevention Activities (1) all employees and contractors including, as a minimum,                                                                       OM8, "Fire Protection Program,"
familiarization with plant fire                                                                Revision 4, Sections 4.2.2, 4.10, 6.2, prevention procedures, fire reporting,                                                         and 7.10 and plant emergency alarms OM8.D1, "Fire Loss Prevention,"
Revision 24, All Sections OM8.1D4, "Control of Flammable and Combustible Materials," Revision 19, All Sections Page A-16

0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis          Reference Document 3.3.1.1(2) General Fire   Documented plant inspections            - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Prevention Activities (2) including provisions for corrective                                                         Revision 4, Sections 4.12 and 7.2 actions for conditions where unanalyzed fire hazards are identified                                                      OM8.1D1, "Fire Loss Prevention,"
Revision 24, Sections 4.3.1, 4.3.4, 4.3.9, 5.7.3, and 6.4 OM7.1D1, "Problem Identification and Resolution," Revision 42, All Sections TS5.1Dl, "System Engineering Program," Revision 18 STP M-65, "Sprinkler/Deluge System Visual Verification," Revision 15 3.3.1.1(3) General Fire   Administrative controls addressing     - Complies            No Additional Clarification    OM8, "Fire Protection Program,"
Prevention Activities (3) the review of plant modifications and                                                       Revision 4, Sections 4.4, 4.7, and 7.8 maintenance to ensure that both fire hazards and the impact on plant fire                                                        OM8.1D1, "Fire Loss Prevention,"
protection systems and features are                                                         Revision 24, Section 5 minimized CF3.1D9, "Design Change Development," Revision 43, All Sections CF4, "Modification Control,"
Revision 7, Section 7.1.17 AD7.DC8, "Work Planning,"
Revision 42 Page A-17

0                                                                                        0 Pacific Gas and Electric Company                        Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element               NFPA 805 Reauirement                             Compliance Statement                Compliance Basis                     Reference Document 3.3.1.2 Control of             Procedures for the control of general             - Complies                   No Additional Clarification                AD4.ID1, "Housekeeping,"
Combustible Materials          housekeeping practices and the                                                                                             Revision 13, All Sections control of transient combustibles shall be developed and                                                                                                     OM8, "Fire Protection Program,"
implemented. These procedures                                                                                              Revision 4, Section 4.6 shall include but not be limited to the following program elements:                                                                                                OM8.1D4, "Control of Flammable and Combustible Materials," Revision 19, All Sections 3.3.1.2(1) Control of          Wood used within the power block                  - Complies, with             Complies once Implementation               OM8.1D4, "Control of Flammable and Combustible Materials          shall be listed pressure-impregnated              Required Action              Item S-3.2 is completed.                   Combustible Materials," Revision 19, (1)                            or coated with a listed fire-retardant                                                                                    Section 5.1.1 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.
IMPLEMENTATION ITEMS:
S-3.2    SAP Notification #50294777-27 was issued to track the revision of OM8.I04 to incorporate the requirements of NFPA 805, Section 3.3.1.2.(1), which discusses wood used within the power block.
3.3.1.2(2) Control of          Plastic sheeting materials used in the
* Complies, with            Complies once Implementation                OM8.1D4, "Control of Flammable and Combustible Materials          power block shall be fire-retardant               Required Action              Item S-3.3 is completed.                   Combustible Materials," Revision 19, (2)                            types that have passed NFPA 701,                                                                                          Section 5.1.1 Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.
IMPLEMENTATION ITEMS:
S-3.3   SAP Notification #50294777-3 was issued to track the revision of OM8.1D4, Section 5.1.1.f to address basis of flame retardant plastic sheeting material.
Page A-18
* 0 Pacific Gas and Electric Company                           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element               NFPA 805 Reauirement                              Compliance Statement                 Comoliance Basis                      Reference Document 3.3.1.2(3) Control of           Waste, debris, scrap, packing                     - Complies, with              Complies once Implementation                 OM8.1D4, "Control of Flammable and Combustible Materials           materials, or other combustibles shall            Required Action               tem S-3.4 is completed.                      Combustible Materials," Revision 19, (3)                             be removed from an area                                                                                                      Section 5 immediately following the completion of work or at the end of the shift, whichever comes first.
IMPLEMENTATION ITEMS:
S-3.4   SAP Notification #50294777-15 was issued to track the revision of OM8.1D4 to comply with the requirements of NFPA 805 Section 3.3.1.2(3) for removal of incident combustible materials at the end of the shift or when work is complete, whichever comes first. Also, OM8.104 will be revised to specify labeling and limits on combustible storage areas per NFPA 805 Section 3.3.1.2(4).
3.3.1.2(4) Control of           Combustible storage or staging
* Complies, with             Complies once Implementation                 OM8.1D4, "Control of Flammable and Combustible Materials           areas shall be designated, and limits             Required Action              Item S-3.4 is completed.                     Combustible Materials," Revision 19, (4)                             shall be established on the types and                                                                                       Section 5.5 quantities of stored materials.
EV2.DC4, "Hazardous Materials Management Program," Revision 9, Section 5.5 IMPLEMENTATION ITEMS:
S-3.4   SAP Notification #50294777-15 was issued to track the revision of OM8.1D4 to comply with the requirements of NFPA 805 Section 3.3.1.2(3) for removal of incident combustible materials at the end of the shift or when work is complete, whichever comes first. Also, OM8.1D4 will be revised to specify labeling and limits on combustible storage areas per NFPA 805 Section 3.3.1.2(4).
3.3.1.2(5) Control of           Controls on use and storage of
* Complies                   No Additional Clarification                  Report P1890-002-004, "Fire Combustible Materials          flammable and combustible liquids                                                                                            Protection Code Conformance (5)                             shall be in accordance with NFPA                                                                                            Review Report," Revision 1, dated 30, Flammable and Combustible                                                                                               March 2013 Liquids Code, or other applicable NFPA standards.                                                                                                             OM8.1D4, "Control of Flammable and Combustible Materials," Revision 19, Sections 5.1, 5.2, and 5.3 EV2.DC4, "Hazardous Materials Management Program," Revision 9, Section 5.5 Page A-19

Pacific Gas and Electric Company             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                 Comnliance Statement        Comrliance Basis        Reference Document 3.3.1.2(6) Control of    Controls on use and storage of       - Complies with       Plant procedures are in place  Report P1890-002-004, "Fire Combustible Materials    flammable gases shall be in          Clarification         to control the use and storage Protection Code Conformance (6)                      accordance with applicable NFPA                            of flammable gases.            Review Report," Revision 1, dated standards.                                                                                March 2013 No other NFPA standards were determined to be          OM8.1D4, "Control of Flammable and applicable based on the        Combustible Materials," Revision 19, guidance in NEI 04-02,         Sections 5 Section K.1 (FAQ 06-0020).
Commitment to additional       MA1.ID9, "Compressed Gas Cylinder applicable codes is not        Control," Revision 3, All Sections identified in the UFSAR.
EV2.DC4, "Hazardous Materials Management Program," Revision 9, Section 5.5 Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)" Revision 2 /
Section K.1 (FAQ 06-0020) 3.3.1.3 Control of       N/A                                  N/A                   N/A - Section Heading, see     N/A Ignition Sources                                                                    sub-sections for any specific compliance statements Page A-20

0                                                                                         0 Pacific Gas and Electric Company                           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                 NFPA 805 Reauirement                              Compliance Statement               Compliance Basis                     Reference Document 3.3.1.3.1 [Control of            A hot work safety procedure shall be              - Complies, with             Complies once Implemenation                OM8.1D1, "Fire Loss Prevention,"
Ignition Sources Code            developed, implemented, and                       Required Action              tems S-3.5 and S-3.6 are                   Revision 24, Sections 4.4.7, 5.5, and Requirements]                    periodically updated as necessary in                                           completed.                                 5.10 accordance with NFPA 51 B, Standard for Fire Prevention During                                                                                       MA1.ID9, "Compressed Gas Cylinder Welding, Cutting, and Other Hot                                                                                           Control," Revision 3, All Sections Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.
IMPLEMENTATION ITEMS:
S-3.5    SAP Notification #50294777-6 was issued to track the revision of Plant Procedure MA1.1D9 to include requirements that management ensure that only approved apparatus, such as torches, manifolds, regulators or pressure reducing valves, and acetylene generators, be used in accordance with NFPA 51B requirements.
IMPLEMENTATION ITEMS:
S-3.6    SAP Notification #50294777-13 was issued to track the revision of applicable procedure(s) to indicate the operational requirements for cutting/welding equipment with more than one cylinder as required by NFPA 241.
3.3.1.3.2 [Control of            Smoking and other possible sources
* Complies                  No Additional Clarification                 OM8.1D1, "Fire Loss Prevention,"
Ignition Sources                 of ignition shall be restricted to                                                                                        Revision 24, Section 5.3 Smoking Limitations]             properly designated and supervised safe areas of the plant.
3.3.1.3.3 [Control of            Open flames or combustion-
* Complies                  No Additional Clarification                 OM8.1D1, "Fire Loss Prevention,"
Ignition Sources for             generated smoke shall not be                                                                                              Revision 24, Section 5.3.6 Leak Testing]                    permitted for leak or air flow testing.
3.3.1.3.4 [Control of            Plant administrative procedure shall
* Complies                  No Additional Clarification                 OM8.ID1, "Fire Loss Prevention,"
Ignition sources on              control the use of portable electrical                                                                                    Revision 24, Section 5.3.4 Portable Heaters]                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.
Page A-21

Pacific Gas and Electric Company                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                      Compliance Statement      Compliance Basis           Reference Document 3.3.2 Structural          Walls, floors, and components             - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
required to maintain structural                                                               Revision 19, Sections 4.3.10, 4.3.11, integrity shall be of noncombustible                                                          and 4.3.12 construction, as defined in NFPA 220, Standard on Types of Building                                                            Drawings 515562 - 515580, "Fire Construction.                                                                                 Barriers, Zones, and Fixed Suppression/Detection," Various Revisions 3.3.3 Interior Finishes   Interior wall or ceiling finish           - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
classification shall be in accordance                                                         Revision 19, Section 4.3.10.b with NFPA 101, Life Safety Code, requirements for Class A materials.                                                           DCM T-32, "Containment Coatings Interior floor finishes shall be in                                                           (Class I)," Revision 7, Section 3.6.3 accordance with NFPA 101 requirements for Class I interior floor                                                       Specification 8848, "Service Level II finishes.                                                                                     and Balance of Plant Coatings,"
Revision 7N, dated May 23, 2007 Specification 8875, "Containment Field Coatings," Revision 8, dated November 16, 2001 Page A-22

A Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program &Design Elements 0
Pacific Gas and Electric Company Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                NFPA 805 Reauirement                                Comoliance Statement               Compliance Basis                     Reference Document 3.3.4 Insulation                Thermal insulation materials,                       " Complies                   Current plant configuration is in          NRC SSER No. 8 dated Materials                       radiation shielding materials,                      " Complies, with             compliance. Implementation                 November 15, 1978 ventilation duct materials, and                     Required Action              Item S-3.9 tracks revision of soundproofing materials shall be                                                 DCPP design guidance                       DCM S-18, "Fire Protection System,"
noncombustible or limited                                                        documents to ensure                        Revision 19, Section 4.3.12 combustible.                                                                     continued compliance with this requirement.                               DCM S-23B, "Auxiliary Building Ventilation System," Revision 24, Section 4.2.2, dated October 22, 2012 DCM S-23D, "Fuel Handling Building Heating and Ventilation System,"
Revision 17, Section 4.2.2 CF3.1D9, "Design Change Development," Revision 43 Specification 0728, "Building Exhaust Filters," Revision 33, dated March 28, 1979 IMPLEMENTATION ITEMS:
S-3.9   SAP Notification #50294777-16 was issued to track updates to appropriate procedures to identify that any future modifications that utilize include thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials that the materials are noncombustible or limited combustible.
3.3.5 Electrical                N/A                                                 N/A                         N/A - Section Heading, see                 N/A sub-sections for any specific compliance statements Page A-23

0                                                                                         0                                                                                           0 Pacific Gas and Electric Company                             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                 NFPA 805 Reauirement                                Comoliance Statement            Compliance Basis                       Reference Document 3.3.5.1 [Electrical              Wiring above suspended ceiling shall                - Submit for NRC         Submit for NRC Approval:                      DCM S-18, "Fire Protection System,"
Wiring Above                     be kept to a minimum. Where                         Approval                 NRC approval is requested in                  Revision 19, Section 4.3.12 Suspended Ceiling                installed, electrical wiring shall be               - Complies, with         Attachment L for the existence Limitations]                     listed for plenum use, routed in                    Required Action          of wiring above suspended                     DCM T-22, "Electrical Cable, armored cable, routed in metallic                                            ceilings.                                    Termination and Raceway,"
conduit, or routed in cable trays with                                                                                     Revision 10D, Section 4.3.3.10 solid metal top and bottom covers.                                           Complies once Implementation Item S-3.10 is completed.                    Unit 1 Cable Tray and Conduit Layout Drawings 57602, 57605, 57606, 501464, 501866, and 502106, Various Revisions Unit 2 Cable Tray and Conduit Layout Drawings 500668, 500672, 500673, 500690, and 504468, Various Revisions IMPLEMENTATION ITEMS:
S-3.10  SAP Notification #50401031 was issued to track the revision of DCPP design guidance documents associated with the implementation of NFPA 805 (2001 Edition), Section 3.3.5.1. This section requires that "Wiring above suspended ceilings shall be kept to a 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."
3.3.5.2 [Electrical              Only metal tray and metal conduits
* Submit for NRC        Submit for NRC Approval:                      DCM T-22, "Electrical Cable, Raceway Construction             shall be used for electrical raceways.              Approval                NRC approval is requested in                  Termination and Raceway,"
Limits]                          Thin wall metallic tubing shall not be                                      Attachment L for the use of                   Revision 1OD, Sections 4.3.1.1 and used for power, instrumentation, or                                         non-metallic conduit.                         4.3.1.2 control cables. Flexible metallic conduits shall only be used in short                                                                                      Drawing 050029, Sheets 8-12, lengths to connect components.                                                                                            "Electrical, Notes, Symbols, and Typical Details for Raceway &
Wires," Various Revisions Page A-24

0 Pacific Gas and Electric Company                   Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element           NFPA 805 Reauirement                      ComPliance Statement        Compliance Basis         Reference Document 3.3.5.3 [Electrical        Electric cable construction shall         - Complies with       Plant requirements comply      DCM S-18, "Fire Protection System,"
Cable Flame                comply with a flame propagation test      Clarification         with the acceptable electrical Revision 19, Section 4.3.5.4 Propagation Limits]        as acceptable to the AHJ.                                       cable construction tests acceptable to the AHJ (NRC)    DCM T-22, "Electrical Cable, Note: As stated in 10 CFR                                       as documented in FAQ 06-       Termination and Raceway,"
50.48(c)(2)(v), In lieu of installing                           0022 and as clarified below. Revision 1OD, Section 4.3.3.10 cables meeting flame propagation tests as required by Section 3.3.5.3,                           Electrical cables at DCPP      CF3.1D9, "Design Change a flame-retardant coating may be                                meet the intent of IEEE 383-   Development," Revision 43 applied to the electric cables, or an                           1974 flame test requirements automatic fixed fire suppression                                as stated in FAQ 06-0022 or    ABB Impell Corporation Document system may be installed to provide                              ABB Impell Corporation         No. 0170-219-001, "PG&E Electrical an equivalent level of protection. In                           Document No. 0170-219-001,     Cable Acceptability Analysis,"
addition, the italicized exception to                           Revision 1, (PG&E Electrical   Revision 2 Section 3.3.5.3 is not endorsed.                                Cable Acceptability Analysis).
Cables installed at DCPP fall  Specification 0702, "High Voltage nto one of four categories:    Power Cables," Revision 1 (Inactive),
dated July 22, 1994 *
(1) Cables tested to the flame test requirements of IEEE 383-  Specification 0703, "Low Voltage 1974. These cables meet the     Power Cables," Revision 1 (Inactive),
requirement without further     dated July 22, 1994
* clarification.
Drawing 663359, Sheet 91, (2) Cables tested to the flame  pages 5-7, "Flame Test Report,"
test requirements in UL 1666    Revision 1 or UL 1581. The flame tests in these UL Standards meet or exceed the requirements of IEEE 383-1974 per the guidance of NEI 02-04, Revision 1, as supplemented by FAQ 06-0022, Revision 3.
(3) Cables tested to the flame test requirements in UL 910.
The flame tests in this UL Standards meet or exceed the Page A-25

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Comnliance Basis            Reference Document requirements of IEEE 383-1974 as evaluated and documented in ABB Impell Corporation Document No.
0170-219-001, Revision 1, (PG&E Electrical Cable Acceptability Analysis).
Specifically, the UL 910 standard represents a much more severe test condition than IEEE 383 and the acceptance criteria are more conservative.
(4) Cables that were not originally required to meet the flame tests of IEEE 383 since they are used in small quantities, and/or are generally routed in conduit or used inside panels and equipment, including:
Wire and cables supplied by the vendor as part of the equipment; Specialty cables, such as communications, telephone, and instrumentation cables; Wire or cable used only within panels or equipment; Lighting and receptacle cables that are installed entirely within fully enclosed raceway (conduit, solid tray with solid covers).
Additionally, all cables installed at DCPP in analyzed fire areas Page A-26

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company                Attachment A NEt 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement       Comnliance Basis          Reference Document subsequent to June 1, 1991, meet the requirements of IEEE 383 (Category 1), UL 1666 or 1581 (Category 2), or UL 910 (Category 3). Therefore, Category 4 cables are permitted to remain as is per the exception to this section.
3.3.6 Roofs              Metal roof deck construction shall be   - Complies            No Additional Clarification    Turbine Building: Drawings 59601 -
designed and installed so the roofing                                                        50606 and 6018227 Sheets 1 - 77, system will not sustain a self-                                                              Various Revisions propagating fire on the underside of the deck when the deck is heated by                                                          Auxiliary Building: Drawings 59579, a fire inside the building. Roof                                                             59583, 59590, 59593, and 59662, coverings shall be Class A as                                                                Various Revisions determined by tests described in NFPA 256, Standard Methods of Fire                                                           Fuel Handling Building: Drawings Tests of Roof Coverings.                                                                     501252, 501253, 59581, 59582, 59591, 59607, 59608, 6013118 Sheets 1 - 5, 439505 - 439508, 443498, 4002044, and 59641, Various Revisions Containment: Drawings 57729, 57731, 438464, 438231 and 438234, Various Revisions Intake Structure: Drawings 495080   -
49586, 495476 - 49586, and 4017056, Various Revisions Buttress Building: Drawings 512471 -
512476, 6018227 Sheets 1 -77, and 663524 Sheets 1 - 12, Various Revisions Page A-27

Pacific Gas and Electric Company                         Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                NFPA 805 Reauirement                            Comnliance Statement                Compliance Basis                       Reference Document 3.3.7 Bulk Flammable            Bulk compressed or cryogenic                     - Complies                  No Additional Clarification                    DCM T-40, "Toxic and Explosive Gas Storage                     flammable gas storage shall not be                                                                                          Materials," Revision 1, Section 3.8 permitted inside structures housing systems, equipment, or components                                                                                           OM8.1D4, "Control of Flammable and important to nuclear safety.                                                                                                Combustible Materials," Revision 19, Section 5.3 MA1.ID9, "Compressed Gas Cylinder Control," Revision 3, Section 5.6.4 3.3.7.1 [Bulk                   Storage of flammable gas shall be               - Complies                   No Additional Clarification                    DCM T-40, "Toxic and Explosive Flammable Gas                   located outdoors, or in separate                                                                                            Materials," Revision 1, Section 3.8 Location                        detached buildings, so that a fire or Requirements]                   explosion will not adversely impact                                                                                         OM8.1D4, "Control of Flammable and systems, equipment, or components                                                                                           Combustible Materials," Revision 19, important to nuclear safety. NFPA                                                                                           Sections 5.2 and 5.3 50A, Standard for Gaseous Hydrogen Systems at Consumer                                                                                                MA1.ID9, "Compressed Gas Cylinder Sites, shall be followed for hydrogen                                                                                       Control," Revision 3, Section 5.6.4 storage.
Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 3.3.7.2 [Bulk                   Outdoor high-pressure flammable                 - Submit for NRC             Submit for NRC Approval:                       MA1.ID9, "Compressed Gas Cylinder Flammable Gas                   gas storage containers shall be                 Approval                     NRC approval is requested in                   Control," Revision 3, Section 5.6 Container Restrictions]         located so that the long axis is not            . Complies, with             Attachment L for the outdoor pointed at buildings.                           Required Action              high-pressure flammable gas                    DCM T-40, "Toxic and Explosive storage container configuration.               Materials," Revision 1, Section 4.4 Complies once Implementation                   UFSAR, Section 3.5.1.2, "Missiles Item S-3.11 is completed.                      Generated Outside the Containment" IMPLEMENTATION ITEMS:
S-3.11   SAP Notification #50401046 was issued to track the revision of DCPP design guidance documents associated with the implementation of NFPA 805 (2001 Edition), Section 3.3.7.2. This section requires that "Outdoor high-pressure flammable gas storage containers shall be located so that the long axis is not pointed at buildings."
Page A-28

0                                                                                                                                                                                 0 Pacific Gas and Electric Company                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                NFPA 805 Reauirement                              Compliance Statement            Compliance Basis                       Reference Document 3.3.7.3 [Bulk                   Flammable gas storage cylinders not
* Complies                No Additional Clarification                  MA1 .ID9, "Compressed Gas Cylinder Flammable Gas                   required for normal operation shall                                                                                      Control," Revision 3, Section 5.1.8 Cylinder Limitations]           be isolated from the system.
3.3.8 Bulk Storage of           Bulk storage of flammable and
* Complies                Except as identified below,                  OM8.1D4, "Control of Flammable and Flammable and                   combustible liquids shall not be
* Submit for NRC          controls on use and storage of               Combustible Materials," Revision 19 Combustible Liquids             permitted inside structures                       Approval                  flammable and combustible containing systems, equipment, or
* Complies, with          liquids are in accordance with               Report P1890-002-004, "Fire components important to nuclear                   Required Action           NFPA 30, "Flammable and                      Protection Code Conformance safety. As a minimum, storage and                                           Combustible Liquids Code," as                Review Report," Revision 1, dated use shall comply with NFPA 30,                                              identified in Report P1890-002-              March 2013 Flammable and Combustible Liquids                                           004, "Fire Protection Code Code.                                                                       Conformance Review Report."
Submit for NRC Approval:
NRC approval is requested in Attachment L for the existing fuel withdrawal connection configuration of the EDG day tanks.
Complies once Implementation Item S-3.12 is completed.
IMPLEMENTATION ITEMS:
S-3.12   SAP Notification #50294777-34 was issued to track the revision of procedure OM8.1D4 to include requirements to prohibit transfer of flammable or combustible liquids by means of air pressure on the container or portable tanks.
3.3.9 Transformers              Where provided, transformer oil
* Complies                No Additional Clarification                  EV2.DC7, "Spill Prevention Control collection basins and drain paths                                                                                        and Countermeasures (SPCC) Plan shall be periodically inspected to                                                                                       Visual Inspections," Revision 3, ensure that they are free of debris                                                                                      Sections 5.4 and 5.5 and capable of performing their design function.
Page A-29

0 Pacific Gas and Electric Company                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element               NFPA 805 Reauirement                             Comoliance Statement               Compliance Basis                    Reference Document 3.3.10 Hot Pipes and           Combustible liquids, including high               - Complies, with            Complies once Implementation              OM8, "Fire Protection Program,"
Surfaces                       flashpoint lubricating oils, shall be             Required Action             tem S-3.7 is completed.                    Revision 4 kept from coming in contact with hot pipes and surfaces, including                                                                                           OM8.ID1, "Fire Loss Prevention,"
insulated pipes and surfaces.                                                                                           Revision 24 Administrative controls shall require the prompt cleanup of oil on                                                                                            OM8.1D4, "Control of Flammable and insulation.                                                                                                             Combustible Materials," Revision 19 OP1.DC41, "Operations Housekeeping," Revision 0 IMPLEMENTATION ITEMS:
S-3.7   SAP Notification #50294777-5 was issued to track the revision of OM8.1D4 to address combustible liquid in contact with hot pipes. Combustible liquid in contact with hot pipes is not specifically addressed in procedures. DCPP will provide documentation to support compliance or revise a document to address the issue.
3,3.11 Electrical              Adequate clearance, free of
* Complies, with           Complies once Implementation               OM8.1D4, "Control of Flammable and Equipment                      combustible material, shall be                    Required Action            Item S-3.8 is completed.                   Combustible Materials," Revision 19 maintained around energized electrical equipment.
IMPLEMENTATION ITEMS:
S-3.8   SAP Notification #50294777-7 was issued to track the revision of procedure OM8,1D4 to include requirements for adequate clearance around all electrical equipment.
Page A-30

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Comoliance Statement        Comoliance Basis           Reference Document 3.3.12 Reactor           For facilities with non-inerted          " Complies            Except as identified below, the  PG&E letter, "Report on Deviations Coolant Pumps            containments, reactor coolant pumps      " Complies by         DCPP RCP oil collection          from Appendix R of 10 CFR 50,"
with an external lubrication system      Previous NRC          system is in compliance with     dated July 15, 1983 shall be provided with an oil           Approval               this section.
collection system. The oil collection                                                           NRC SSER No. 23, dated June 18, system shall be designed and                                   Complies by Previous NRC         1984 installed such that leakage from the                           Approval.
oil system is safely contained for off                         PG&E letter, "Report on          NRC SSER No. 31, dated May 1985 normal conditions such as accident                             Deviations from Appendix R of conditions or earthquakes. All of the                          10 CFR 50, dated 7/15/1983,      DCM T-13, "Appendix R Fire following shall apply.                                         states: "The above described     Protection," Revision 6, Section 4.2.4 RCP oil collection system is in compliance with Appendix R,      Independent Safety Engineering Section 111.0, and Item 2 of the Group Report #961430034, "Assess NRC staff position paper,        the installed Reactor Coolant Pump except for drainage of any       motor oil collection system to the overflow '... to a safe location requirements of Appendix R of where the lube oil will not      10 CFR 50," dated June 27, 1996 present an exposure fire hazard or otherwise endanger safety related equipment.' In the unlikely event of an overflow from a multiple RCP lube oil spill, RCP oil would be discharged from the RCP oil collection tank into the containment annulus floor at Elevation 91 feet.
Basis for Exemption Request:
: 1. The RCP lube oil collection tank overflow pipe discharges downward to a recessed trench in the Elevation 91 feet floor, along the outside of the shield wall.
This trench is sloped so an Page A-31

0a                                                               0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NIPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Comnliance Basis           Reference Document RCP lube oil overflow would flow to the containment drain sump.
: 2. The overflow pipe of the oil collection tank has pickup from 3 inches above the tank bottom. Thus, in the remote likelihood of a multiple RCP motor lube oil spill and fire propagation to the oil collection tank, such a fire would not be extended to the oil discharges to the floor trench.
: 3. The Westinghouse RCP CS VSS motor currently utilizes a high flashpoint (480 degree) lubricating oil. The fire point of this oil is 520 degrees F. Therefore, a high energy ignition source would be necessary to sustain combustion in the unlikely event a multiple RCP lube oil spill (greater than 300 gallons) occurs and oil is discharged through the overflow pipe.
: 4. Due to an oil-to-water heat exchanger serving each bearing assembly, and that the heat exchanger discharge water and bearing temperatures are monitored and alarm in the continuously manned control room, it is not deemed credible for the RCP lube oil to reach temperatures within 50% of its flash point.
: 5. There are various Page A-32

0cf                                                              0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Comeliance Basis            Reference Document components and circuits necessary for safe shutdown in the vicinity of this floor trench.
Power cable is routed in conduit. Other circuits are not considered to present high energy ignition source.
: 6. Upgrading of the RCP lube oil collection tank overflow would not enhance to a significant degree the protection provided to the existing configuration."
SSER 23 states:
                                                                                  "Evaluation The technical requirements of Section 111.0 are not met because the oil holding tanks are not large enough to hold the entire lube oil system inventory for the four RCPs.
In its original evaluation of this system in the SER, the staff expressed concern that an unmitigated fire involving lube oil could damage safety-related equipment in the vicinity. Consequently, the licensee agreed to install an oil collection system to provide a capability for collecting leakage from vulnerable components, and to provide an automatic sprinkler system to spray the areas around the pumps.
Page A-33

0                                                                0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                Compliance Statement         Compliance Basis           Reference Document The staff was also concerned that if overflowing lube oil ignited, the resulting fire would damage shutdown systems.
However, the overflow line discharges into a trench that is sloped to channel any potential oil spill to the containment.
drain sump. The oil has a flash point of 480 F and would, therefore, represent a significant hazard only if atomized or if the oil came in contact with a high-energy ignition source. Because the oil collection system is presently designed to withstand the safe shutdown earthquake and because there are no ignition sources in the anticipated flow path of the overflowing oil, the staff does not expect the oil to ignite.
If a fire were to occur at the oil collection tank, the smoke detectors in the area would activate and summon the fire brigade to extinguish the fire with portable fire-fighting equipment. However, although safe shutdown systems could be damaged, the loss of these systems would not impair the ability to achieve and maintain safe shutdown.
Page A-34

0                                                                9                                                                0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 806 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis         Reference Document Additional modifications to satisfy the requirements of Appendix R would not significantly enhance the level of fire safety.
Conclusion Based on its evaluation, the staff concludes that the licensee's fire protection configuration will achieve an acceptable level of fire protection equivalent to that provided by Section 111.0.
Therefore, the licensee's request for a deviation for the RCP oil collection system holding tanks is approved."
No significant changes have been made to the RCP oil collection system that would affect any of the inputs or assumption made in approval of this deviation. Accordingly, this previous NRC approval remains valid.
Page A-35

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                   Compliance Statement      Comnliance Basis          Reference Document 3.3.12(1) Reactor        The oil collection system for each     - Complies            No Additional Clarification    DCM T-13, "Appendix R Fire Coolant Pumps (1)        reactor coolant pump shall be                                                               Protection," Revision 6, Section 4.2.4 capable of collecting lubricating oil from all potential pressurized and                                                          Independent Safety Engineering nonpressurized leakage sites in each                                                        Group Report #961430034, "Assess reactor coolant pump oil system.                                                            the installed Reactor Coolant Pump Motor Oil Collection System to the requirements of Appendix R of 10 CFR 50," dated June 27, 1996 Drawing 504472, "Unit 1 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 7 Drawing 504473, "Unit 1 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 7 Drawing 506766, "Unit 1 Reactor Coolant Pump Fire Protection System Details," Revision 7 Drawing 502741, "Unit 2 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 5 Drawing 502742, "Unit 2 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 6 Page A-36

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Elemen          NFPA 805 Requirement                     Compliance Statement      Comnliance Basis           Reference Document 3.3.12(2) Reactor        Leakage shall be collected and           - Complies by        See Section 3.3.12 above.      See Section 3.3.12 above.
Coolant Pumps (2)        drained to a vented closed container     Previous NRC that can hold the inventory of the      Approval reactor coolant pump lubricating oil system.
3.3.12(3) Reactor        A flame arrestor is required in the
* Complies           No Additional Clarification    DCM T-13, "Appendix R Fire Coolant Pumps (3)        vent if the flash point characteristics                                                      Protection," Revision 6, Section 4.2.4 of the oil present the hazard of a fire flashback.                                                                                   Independent Safety Engineering Group Report #961430034, "Assess the Installed Reactor Coolant Pump Motor Oil Collection System to the requirements of Appendix R of 10 CFR 50," dated June 27, 1996 Page A-37

Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 80EElement          NFPA 805 Reauirement                      Compliance Statement      Compliance Basis           Reference Document I
3.3.12(4) Reactor        Leakage points on a reactor coolant       - Complies           No Additional Clarification    DCM T-13, "Appendix R Fire Coolant Pumps (4)        pump motor to be protected shall                                                              Protection," Revision 6, Section 4.2.4 include but not be limited to the lift pump and piping, overflow lines, oil                                                          Independent Safety Engineering cooler, oil fill and drain lines and                                                          Group Report #961430034, "Assess plugs, flanged connections on oil                                                             the installed Reactor Coolant Pump lines, and the oil reservoirs, where                                                          Motor Oil Collection System to the such features exist on the reactor                                                            requirements of Appendix R of coolant pumps.                                                                                10 CFR 50," dated June 27, 1996 Drawing 504472, "Unit 1 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 6 Drawing 504473, "Unit 1 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 7 Drawing 506766, "Unit 1 Reactor Coolant Pump Fire Protection System Details," Revision 7 Drawing 502741, "Unit 2 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 5 Drawing 502742, "Unit 2 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 6 Page A-38

Pacific Gas and Electric Company                   Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element           NFPA 805 Reauirement                      Compliance Statement       Compliance Basis         Reference Document 3.3.12(5) Reactor          The collection basin drain line to the    - Complies           No Additional Clarification    DCM T-13, "Appendix R Fire Coolant Pumps (5)          collection tank shall be large enough                                                         Protection," Revision 6, Section 4.2.4 to accommodate the largest potential oil leak such that oil leakage does                                                           Independent Safety Engineering not overflow the basin.                                                                       Group Report #961430034, "Assess the installed Reactor Coolant Pump Motor Oil Collection System to the requirements of Appendix R of 10 CFR 50," dated June 27, 1996 Drawing 504472, "Unit 1 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 6 Drawing 504473, "Unit 1 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 7 Drawing 506766, "Unit 1 Reactor Coolant Pump Fire Protection System Details," Revision 7 Drawing 502741, "Unit 2 Reactor Coolant Pump No. 1 & No. 2 Fire Protection, Oil Drip Pan Locations,"
Revision 5 Drawing 502742, "Unit 2 Reactor Coolant Pump No. 3 & No. 4 Fire Protection, Oil Drip Pan Locations,"
Revision 6 3.4 Industrial Fire        N/A                                       N/A                  N/A - Section Heading, see     N/A Brigade                                                                                   sub-sections for any specific compliance statements Page A-39

0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement       Compliance Basis        Reference Document 3.4.1 On-Site Fire-      All of the following requirements shall   N/A                  N/A - General statement; No   N/A Fighting Capability      apply.                                                         technical requirements 3.4.1(a) On-Site Fire-   A fully staffed, trained, and equipped
* Complies           No Additional Clarification   Casualty Procedure (CP) M-6, "Fire,"
Fighting Capability (a)  fire-fighting force shall be available at                                                    Revision 33A, Section 2.1 all times to control and extinguish all fires on site. This force shall have a                                                       OM8, "Fire Protection Program,"
minimum complement of five persons                                                           Revision 4, Section 4.1.2 on duty and shall conform with the following NFPA standards as                                                                  TQ1.DC12, "Fire Brigade and applicable:                                                                                  Emergency Response Training,"
Revision 12 3.4.1(a)(1) On-Site      NFPA 600, Standard on Industrial          &deg; Complies           No Additional Clarification   TQI.DC12, "Fire Brigade and Fire-Fighting Capability Fire Brigades (interior structural fire                                                      Emergency Response Training,"
(a)(1)                   fighting)                                                                                    Revision 12 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Page A-40

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement         Compliance Basis          Reference Document 3.4.1 (a)(2) On-Site      NFPA 1500, Standard on Fire            N/A                    NFPA 1500 is not applicable to   Nuclear Energy Institute (NEI) 04-02, Fire-Fighting Capability  Department Occupational Safety and                            DCPP per Section K.6 of NEI      "Guidance for Implementing a Risk-(a)(2)                    Health Program                                                04-02, which states, "The        Informed, Performance-Based Fire NFPA standards divide fire       Protection Program under brigades into two types, based   10 CFR 50.48(c)" Revision 2, Section on organization and duties:       K.6
                                                                                        'Industrial Fire Brigades' and
                                                                                        'Industrial Fire Departments.'
Practically, this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)."
3.4.1 (a)(3) On-Site      NFPA 1582, Standard on Medical         N/A                    NFPA 1582 is not applicable to  Nuclear Energy Institute (NEI) 04-02, Fire-Fighting Capability  Requirements for Fire Fighters and                            DCPP per Section K.6 of NEI     'Guidance for Implementing a Risk-(a)(3)                    Information for Fire Department                              04-02, which states, "The        Informed, Performance-Based Fire Physicians                                                   NFPA standards divide fire       Protection Program under brigades into two types, based    10 CFR 50.48(c)," Revision 2, on organization and duties:      Section K.6
                                                                                       'Industrial Fire Brigades' and
                                                                                       'Industrial Fire Departments.'
Practically, this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)."
Page A-41

0                                                                                        0 Pacific Gas and Electric Company                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element                NFPA 805 Reauirement                              Compliance Statement             Compliance Basis                     Reference Document 3.4.1 (b) On-Site Fire-         Industrial fire brigade members shall             - Complies                No Additional Clarification                 Casualty Procedure (CP) M-6, "Fire,"
Fighting Capability (b)        have no other assigned normal plant                                                                                      Revision 33A, Section 2.1.1 duties that would prevent immediate response to a fire or other emergency as required.
3.4.1(c) On-Site Fire-         During every shift, the brigade leader             - Complies, with          Complies with the exception of              Casualty Procedure (CP) M-6, "Fire,"
Fighting Capability (c)        and at least two brigade members                   Required Action           a statement in Casualty                     Revision 33A, Section 2.1.1 shall have sufficient training and                                           Procedure M-6, "Fire,"
knowledge of nuclear safety systems                                          Revision 33A, that allows the to understand the effects of fire and                                        Incident Commander to be an fire suppressants on nuclear safety                                          operations responder. This is performance criteria.                                                        not actual plant practice.
Therefore, Compliance Basis Exception: Sufficient training and                                           will be Complies once knowledge shall be permitted to be                                           Implementation Item S-3.13 is provided by an operations advisor                                            completed.
dedicated to industrial fire brigade support.
IMPLEMENTATION ITEMS:
S-3.13   SAP Notification #50294777-32 was issued to track the revision of Casualty Procedure M-6 to remove the phrase "unless the IC is an operations responder" from Section 2.1.1.
3.4.1(d) On-Site Fire-         The industrial fire brigade shall be
* Complies                No Additional Clarification                 Casualty Procedure (CP) M-6, "Fire,"
Fighting Capability (d)        notified immediately upon verification                                                                                   Revision 33A, Section 4.1.1 of a fire.
3.4.1(e) On-Site Fire-         Each industrial fire brigade member
* Complies                No Additional Clarification                TQ1.DC12, "Fire Brigade and Fighting Capability (e)        shall pass an annual physical                                                                                            Emergency Response Training,"
examination to determine that he or                                                                                      Revision 12 she can perform the strenuous activity required during manual firefighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.
Page A-42

0 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFEA 805 Elemen           NFPA 805 Reauirement                      Compliance Statement     Compliance Basis          Reference Document 3.4.2 Pre-Fire Plans      Current and detailed pre-fire plans
* Complies           No Additional Clarification   Casualty Procedure (CP) M-6, "Fire,"
shall be available to the industrial fire                                                    Revision 33A, Attachment 7.2 brigade for all areas in which a fire could jeopardize the ability to meet                                                         OM8.1D1, "Fire Loss Prevention,"
the performance criteria described in                                                        Revision 24, Sections 4.3.14 and 5.9 Section 1.5.
Pre-Fire Plans 3.4,2.1 [Fire Pre-Plan    The plans shall detail the fire area
* Complies           No Additional Clarification   Pre-Fire Plans Contents]                 configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.
3.4,2.2 [Fire Pre-Plan    Pre-fire plans shall be reviewed and      &deg; Complies           No Additional Clarification   OM8.1D1, "Fire Loss Prevention,"
Updates]                  updated as necessary.                                                                        Revision 24, Sections 4.3.14 and 5.9 3.4,2.3 [Fire Pre-Plan    Pre-fire plans shall be available in
* Complies           No Additional Clarification   Casualty Procedure (CP) M-6, "Fire,"
Locations]                the control room and made available                                                          Revision 33A, Attachment 7.2 to the plant industrial fire brigade.
3.4,2.4 [Fire Pre-Plan    Pre-fire plans shall address              - Complies           No Additional Clarification   Casualty Procedure (CP) M-6, "Fire,"
Coordination Needs]       coordination with other plant groups                                                         Revision 33A, Section 4.1.4 during fire emergencies.
3.4,3 Training and Drills Industrial fire brigade members and
* Complies           No Additional Clarification   OM8.ID1, "Fire Loss Prevention,"
other plant personnel who would                                                              Revision 24, Section 5.6 respond to a fire in conjunction with the brigade shall be provided with                                                           TQ1.DC12, "Fire Brigade and training commensurate with their                                                             Emergency Response Training,"
emergency responsibilities.                                                                  Revision 12, All Sections Page A-43

0
* 0 Pacific Gas and Electric Company                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Requirement                      Compliance Statement       Compliance Basis         Reference Document 3.4.3(a) Plant           All of the following requirements shall    N/A                  N/A - See sub-sections for any N/A Industrial Fire Brigade   apply.                                                         specific compliance statements Training 3.4.3(a)(1) Training      Plant industrial fire brigade members
* Complies           No Additional Clarification    Report P1890-002-004, "Fire and Drills (a)(1)         shall receive training consistent with                                                        Protection Code Conformance the requirements contained in NFPA                                                            Review Report," Revision 1, dated 600, Standard on Industrial Fire                                                              March 2013 Brigades, or NFPA 1500, Standard on Fire Department Occupational                                                               TQ1.ID4, "Training Records Safety and Health Program, as                                                                 Management," Revision 12, All appropriate.                                                                                  Sections TQ1.DC12, "Fire Brigade and Emergency Response Training,"
Revision 12, All Sections 3.4.3(a)(2) Training      Industrial fire brigade members shall
* Complies            No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (a)(2)         be given quarterly training and                                                               Emergency Response Training,"
practice in fire fighting, including                                                          Revision 12, Section 5.2.3.b.4 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.
3.4.3(a)(3) Training     A written program shall detail the
* Complies           No Additional Clarification    TQ1 .DC12, "Fire Brigade and and Drills (a)(3)         industrial fire brigade training                                                              Emergency Response Training,"
program.                                                                                      Revision 12, All Sections Page A-44

Pacific Gas and Electric Company                   Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reouirement                       ComPliance Statement       Compliance Basis         Reference Document 3.4.3(a)(4) Training      Written records that include but are       - Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (a)(4)         not limited to initial industrial fire                                                         Emergency Response Training,"
brigade classroom and hands-on                                                                 Revision 12, Section 6 training, refresher training, special training schools attended, drill                                                               TQ1.ID4, "Training Records attendance records, and leadership                                                             Management," Revision 12, All training for industrial fire brigades                                                          Sections shall be maintained for each industrial fire brigade member.
3.4.3(b) Training for     Plant personnel who respond with           - Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and Non-Industrial Fire       the industrial fire brigade shall be                                                           Emergency Response Training,"
Brigade Personnel         trained as to their responsibilities,                                                          Revision 12, Sections 5.2.3 potential hazards to be encountered, and interfacing with the industrial fire                                                       0M8.ID1, "Fire Loss Prevention,"
brigade.                                                                                       Revision 24, Sections 4.3 and 5.6 Diablo Canyon Power Plant Emergency Plan, Section 8.1, Revision 4, Change 14 Memorandum of Understanding (MOU) between CAL FIRE and DCFD (On File with Group Captain Supervisor) 3.4.3(c) Drills           All of the following requirements shall    N/A                  N/A - See sub-sections for any N/A apply.                                                          specific compliance statements 3.4.3(c)(1) Training      Drills shall be conducted quarterly for
* Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (c)(1)         each shift to test the response                                                                Emergency Response Training,"
capability of the industrial fire brigade.                                                     Revision 12, Section 5.2.3.d.8 Page A-45

00 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement      Compliance Basis          Reference Document 3.4,3(c)(2) Training      Industrial fire brigade drills shall be  - Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (c)(2)         developed to test and challenge                                                              Emergency Response Training,"
industrial fire brigade response,                                                            Revision 12, Section 5.2.3 including brigade performance as a team, proper use of equipment,                                                                OPS Policy G-2, Revision 0 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.
3.4,3(c)(3) Training      Industrial fire brigade drills shall be
* Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (c)(3)        conducted in various plant areas,                                                             Emergency Response Training,"
especially in those areas identified to                                                       Revision 12, Section 5.2.3.d.16.cl be essential to plant operation and to contain significant fire hazards.
3.4.3(c)(4) Training      Drill records shall be maintained
* Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (c)(4)        detailing the drill scenario, industrial                                                      Emergency Response Training,"
fire brigade member response, and                                                             Revision 12, Section 6 ability of the industrial fire brigade to perform as a team.                                                                           TQI1.D4, "Training Records Management," Revision 12, All Sections 3.4.3(c)(5) Training     A critique shall be held and
* Complies           No Additional Clarification    TQ1.DC12, "Fire Brigade and and Drills (c)(5)        documented after each drill.                                                                  Emergency Response Training,"
Revision 12, Section 5.2.3.d.17a Page A-46

0                                                                       0                                                                   0 Pacific Gas and Electric Company                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element           NFPA 805 Reauirement                     Compliance Statement       Comoliance Basis          Reference Document 3.4.4 Fire-Fighting        Protective clothing, respiratory         - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Equipment                  protective equipment, radiation                                                              Revision 4, Section 4.11 monitoring equipment, personal dosimeters, and fire suppression                                                             Diablo Canyon Power Plant equipment such as hoses, nozzles,                                                            Emergency Plan, Section 7, fire extinguishers, and other needed                                                         Revision 4, Change 14 equipment shall be provided for the industrial fire brigade. This                                                                Diablo Canyon "Fire Brigade equipment shall conform with the                                                             Organizational Statement," Revised applicable NFPA standards.                                                                   August 2012 Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Revision 2, Section K.1 (FAQ 06-0020) 3.4.5 Off-Site Fire        N/A                                      N/A                  N/A - Section Heading, see     N/A Department Interface                                                                     sub-sections for any specific compliance statements Page A-47

0 Pacific Gas and Electric Company                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                      Compliance Statement       Compliance Basis          Reference Document 3.4.5.1 Mutual Aid        Off-site fire authorities shall be        - Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Agreement                 offered a plan for their interface                                                            Revision 4, Section 4.9 during fires and related emergencies on site.                                                                                      Diablo Canyon Power Plant Emergency Plan, "Organization and Control of Emergencies," Revision 4, Change 12, Section 5.12.7 Casualty Procedure (CP) M-6, "Fire,"
Revision 33A, Section 4.1.5 Memorandum of Understanding (MOU) between CAL FIRE and DCFD (On File with Group Captain Supervisor) 3.4.5.2 Site-Specific     Fire fighters from the off-site fire
* Complies           No Additional Clarification    OM8, "Fire Protection Program,"
Training                  authorities who are expected to                                                               Revision 4, Section 4.9 respond to a fire at the plant shall be offered site-specific training and shall                                                      TQ1.DC12, "Fire Brigade and be invited to participate in a drill at                                                       Emergency Response Training,"
least annually.                                                                               Revision 12, Section 5.2.3.d.14 3.4.5.3 Security and      Plant security and radiation              - Complies           No Additional Clarification    Casualty Procedure (CP) M-6, "Fire,"
Radiation Protection      protection plans shall address off-site                                                       Revision 33A, Attachment 7.1 fire authority response.
3.4.6 Communications     An effective emergency
* Complies           No Additional Clarification    Calculation 335-DC, "10 CFR 50, communications capability shall be                                                            Appendix R Emergency Lighting and provided for the industrial fire brigade.                                                     Communication," Revision 7 3.5 Water Supply          N/A                                       N/A                  N/A - Section Heading, see     N/A sub-sections for any specific compliance statements Page A-48

0                                                                    l0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis          Reference Document 3.5.1 [Water Supply      A fire protection water supply of        - Complies           Complies with section (a)      DCM S-18, "Fire Protection System,"
Flow Code                adequate reliability, quantity, and                                                          Revision 19, Sections 2.1.1.1, Requirements]            duration shall be provided by one of                                                         4.3.1.1, and 4.3.2.1 the two following methods.
ECG 18.1, "Fire Suppression (a) Provide a fire protection water                                                          Systems / Fire Suppression Water supply of not less than two separate                                                         Systems," Revision 9 300,000-gal (1,135,500-L) supplies.
Drawing 102018 (series), "Unit 1 Fire (b) Calculate the fire flow rate for 2                                                       Protection Systems," Various hours. This fire flow rate shall be                                                          Revisions based on 500 gpm (1892.5 L/min) for manual hose streams plus the                                                                 Drawing 108018 (series), "Unit 2 Fire largest design demand of any                                                                 Protection Systems," Various sprinkler or fixed water spray                                                               Revisions system(s) in the power block as determined in accordance with NFPA                                                           Drawing 438148, Sheet 1, "General 13, Standard for the Installation of                                                         Layout & Utility Plan, Raw Water Sprinkler Systems, or NFPA 15,                                                               Reservoir Area," Revision 14 Standard for Water Spray Fixed Systems for Fire Protection. The fire                                                        Drawing 6003131, Sheet 13, water supply shall be capable of                                                             "Reservoirs, Safety Anchors,"
delivering this design demand with                                                           Revision 1 the hydraulically least demanding portion of fire main loop out of service.
Page A-49

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement        Compliance Basis            Reference Document 3.5.2 [Water Supply      The tanks shall be interconnected
* Complies by        Complies with Previous NRC         NRC SSER No. 8, dated Tank Code                such that fire pumps can take suction    Previous NRC         Approval                           November 15, 1978 Requirements]            from either or both. A failure in one    Approval             PG&E letter, "Supplementary tank or its piping shall not allow both                       nformation for Fire Protection     NRC SSER No. 9, dated June 1980 tanks to drain. The tanks shall be                            Review," dated 11/13/1978, designed in accordance with NFPA                              states: "The primary water         DCM S-18, "Fire Protection System,"
22, Standard for Water Tanks for                              supply for this system is a 4.5-   Revision 19, Sections 2.1.1.1, Private Fire Protection.                                      million gallon reservoir, divided  4.3.1.1, and 4.3.2.1 n two isolable compartments.
Exception No. 1: Water storage tanks                          This reservoir supplies and        DCM T-6, "Seismic Analysis of shall not be required when fire                               pressurizes the fire water         Structures," Revision 8A pumps are able to take suction from                           system, and meets system a large body of water (such as a                              pressure and flow                  ECG 18.1, "Fire Suppression lake), provided each fire pump has                            requirements. As a backup to      -Systems / Fire Suppression Water its own suction and both suctions                             he reservoir, two 1500 gpm         Systems," Revision 9 and pumps are adequately                                      fire pumps provide water from separated.                                                    a 300,000 gallon fire water        SQE-007.1, "Fire Pumps Seismic storage tank. These pumps          Qualification," Revision 10, dated Exception No. 2: Cooling tower                                would not normally be required     December 23, 2009 (Superseded basins shall be an acceptable water                           o supply the fire main system. Calculation M-143) source for fire pumps when the                                The pumps are powered from volume is sufficient for both purposes                        *edundant480 volt vital circuits   Report P1890-002-004, "Fire and water quality is consistent with                          and start automatically (in        Protection Code Conformance the demands of the fire service.                              sequence) if fire system           Review Report," Revision 1, dated pressure drops-below 75            March 2013 psig... Fire pump installation conforms to NFPA 20."              DCPP letter to NRC, "Answers to NRC Staff Questions Relating to SSER 8 states: "The water fire     Diablo Canyon Fire Protection protection system is common        Review," dated February 6, 1978 n both units, and consists of a 4.5-million gallon reservoir, a    PG&E letter, "Supplementary 300,000 gallon fire water tank,    Information for Fire Protection a yard loop with sectionalizing    Review," dated November 13, 1978 solation valves, and two electric motor-driven pumps        Drawing 102018 (series), "Unit 1 Fire having a design capacity of        Protection Systems," Various 1500 gpm and 290-foot head         Revisions Page A-50

0                                                                     0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reouirement                Compliance Statement        Compliance Basis          Reference Document that automatically start in sequence when the pressure       Drawing 108018 (series), "Unit 2 Fire in the fire water system drops   Protection Systems," Various to 75 psig. The 4.5-million      Revisions gallon reservoir is the primary means of pressurizing the fire water system by hydrostatic pressure. The two electric fire pumps, which are seismic Category I, and powered from Class 1E buses, provide the backup capability for pressurizing the fire water system.
Based on our review, and on the applicant's commitments to install sprinkler systems in areas identified above, we conclude that water extinguishing systems, including automatic sprinklers, and manual hose stations are acceptable."
In summary, Diablo Canyon has two credited sources providing fire water supply for the fire protection system with one source not dependent upon any type of fire pump and the second source depends on fire pumps 0-1 and 0-2, which are not 100% redundant pumps and for a compliance position are treated as a single source. Of note, actual capacity of the raw water Page A-51

Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                      Compliance Statement        Compliance Basis          Reference Document storage reservoirs is 5 million gallons, which is greater than the 4.5 million gallons cited in PG&E letter dated 11/13/1978 and SSER 8. No significant changes have been made to the firewater system that would affect any of the inputs or assumptions made in approval of this deviation. Accordingly, this previous NRC approval remains valid.
3.5.3 [Water Supply       Fire pumps, designed and installed
* Complies by        See Section 3.5.2 above.         See Section 3.5.2 above.
Pump Code                 in accordance with NFPA 20,               Previous NRC Requirements]             Standard for the Installation of          Approval 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.
3.5.4 [Water Supply      At least one diesel engine-driven fire
* Complies by        See Section 3.5.2 above.         See Section 3.5.2 above.
Pump Diversity and        pump or two more seismic Category I       Previous NRC Redundancy]               Class IE electric motor-driven fire       Approval pumps connected to redundant Class IE emergency power buses
                         -capable of providing 100 percent of the required flow rate and pressure shall be provided.
3.5.5 [Water Supply       Each pump and its driver and              - Complies by        See Section 3.5.2 above.         See Section 3.5.2 above.
Pump Separation          controls shall be separated from the       Previous NRC Requirements]             remaining fire pumps and from the         Approval rest of the plant by rated fire barriers.
Page A-52

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.5.6 [Water Supply      Fire pumps shall be provided with       - Complies           No Additional Clarification    Report P1890-002-004, "Fire Pump Start/Stop          automatic start and manual stop only.                                                       Protection Code Conformance Requirements]                                                                                                        Review Report," Revision 1, dated March 2013 Drawing 437630, "Unit 1 & 2, Schematic Diagram, Fire Pumps,"
Revision 10 3.5.7 [Water Supply      Individual fire pump connections to
* Complies by        See Section 3.5.2 above.       See Section 3.5.2 above.
Pump Connection          the yard fire main loop shall be        Previous NRC Requirements]            provided and separated with            Approval sectionalizing valves between connections.
3.5.8 [Water Supply      A method of automatic pressure
* Complies            No Additional Clarification    DCM S-18, "Fire Protection System,"
Pressure Maintenance     maintenance of the fire protection                                                          Revision 19, Sections 2.1.1.1, Limitations]             water system shall be provided                                                              4.3.1.1, and 4.3.2.1 independent of the fire pumps.
Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 438148, Sheet 1, "Unit 1 &
2, General Layout & Utility Plan, Raw Water Reservoir Area," Revision 14 Drawing 060831 (series), "Fire Water Hose Reel RO Specifications,"
Revision 5 Page A-53

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company               Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                    ComPliance Statement      Compliance Basis          Reference Document 3.5.9 [Water Supply      Means shall be provided to              - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Pump Operation           immediately notify the control room,                                                        Revision 19, Section 5.3.2 Notification]            or other suitable constantly attended location, of operation of fire pumps.                                                       Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 &2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Drawing 437630, "Schematic Diagram, Fire Pumps," Revision 10 Page A-54

Pacific Gas and Electric Company                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element              NFPA 805 Reauirement                             Comoliance Statement               Compliance Basis                      Reference Document 3.5.10 [Water Supply          An underground yard fire main loop,               " Complies                  Except as identified below,                  DCM S-18, "Fire Protection System,"
Yard Main Code                 designed and installed in accordance             " Complies, with            DCPP complies with the                       Revision 19, Section 4.3.3.1 Requirements]                 with NFPA 24, Standard for the                    Required Action              equirements of NFPA 24.
Installation of Private Fire Service                                                                                      Report P1890-002-004, "Fire Mains and Their Appurtenances,                                               Complies once                               Protection Code Conformance shall be installed to furnish                                                 mplementation Item S-3.14 is                Review Report," Revision 1, dated anticipated water requirements.                                              completed.                                   March 2013 Drawing 438145, "Unit 1 &2, Civil Plan, Fire Water System, Power Block Perimeter," Revision 35 Drawing 102018 (series), "Unit 1 Fire Protection Systems," Various Revisions Drawing 108018 (series), "Unit 2 Fire Protection Systems," Various Revisions IMPLEMENTATION ITEMS:
S-3.14  SAP Notification #50294777-20 was issued to track plant procedures to ensure that a minimum level in the reservoir will be maintained to support a dedicated capacity capable of supply maximum fire protection demand per NFPA 805 Section 3.5.16. Plant procedures will also be revised to require evaluation of prohibiting non-FP use of fire water (FV) when lined up to the FW storage tank.
Page A-55

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company                Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Comoliance Statement        Comnliance Basis            Reference Document 3.5.11 [Water Supply     Means shall be provided to isolate       " Complies            Except as identified below,       NRC SSER No. 8, dated Yard Main                portions of the yard fire main loop for  " Complies by         means are provided to isolate     November 15, 1978 Maintenance Issues]      maintenance or repair without            Previous NRC          portions of the yard fire main simultaneously shutting off the          Approval              oop for maintenance or repair     DCPP letter to NRC, "Answers to supply to both fixed fire suppression                          without simultaneously shutting   NRC Staff Questions Relating to systems and fire hose stations                                 off the supply to both fixed fire Diablo Canyon Fire Protection provided for manual backup.                                    suppression systems and fire      Review," dated February 6, 1978 Sprinkler systems and manual hose                              hose stations provided for station standpipes shall be                                    manual backup.                    DCM S-18, "Fire Protection System,"
connected to the plant fire protection                                                           Revision 19, Sections 4.3.2.1.c, and water main so that a single active                             Complies with Previous NRC        4.3.3.1.b failure or a crack to the water supply                         Approval piping to these systems can be                                 Reference PG&E letter to          Drawing 102018 (series), "Unit 1 Fire isolated so as not to impair both the                          NRC, "Answers to NRC Staff        Protection Systems," Various primary and backup fire suppression                            Questions Relating to Diablo      Revisions systems.                                                       Canyon Fire Protection Review," dated February 6,        Drawing 108018 (series), "Unit 2 Fire 1978, NRC Question 47 of the      Protection Systems," Various 58 Questions: "Describe the       Revisions means by which a fire will be detected and suppressed           Report P1890-002-004, "Fire when maintenance or repair on     Protection Code Conformance he single fire protection line to Review Report," Revision 1, dated containment is being done."       March 2013 PG&E Response: "When maintenance or repair on the single fire protection line to the containment is being done, backup fire hoses can be bought into containment. In addition, portable fire extinguishing equipment is available."
SSER 8 accepted PG&E response as follows: "Based on our review, and on the Page A-56

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reouirement                Compliance Statement        Comoliance Basis         Reference Document applicant's commitments to install sprinkler systems in areas identified above
[omitted], we conclude that extinguishing systems, including automatic sprinklers, and manual hose stations are acceptable."
No significant changes have been made to fire protection systems that would affect any of the inputs or assumptions made in this SSER.
Accordingly, this previous NRC approval remains valid.
Page A-57

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.5.12 [Water Supply     Threads compatible with those used      - Complies           No Additional Clarification     DCM S-18, "Fire Protection System,"
Compatible Thread        by local fire departments shall be                                                           Revision 19, Section 4.3.3.1.c Connections]             provided on all hydrants, hose couplings, and standpipe risers.                                                             Report P1890-002-004, "Fire Protection Code Conformance Exception: Fire departments shall be                                                         Review Report," Revision 1, dated permitted to be provided with                                                               March 2013 adapters that allow interconnection between plant equipment and the fire                                                        Drawing 060831 (series), "Fire Water department equipment if adequate                                                            Hose Reel RO Specifications,"
training and procedures are provided.                                                       Revision 5 Drawing 064358 (series), "Unit 1 & 2, Details of Fire Water Hose Reel Station Types I and IA," Various Revisions Drawing 064359, Sheet 1, "Unit 1 &
2, Details of Fire Water Hose Reel Station Types 2, 2A, 3, 3A, 4, and 4A," Various Revisions Replacement Part Evaluation (RPE) 80000004705, "Fire Hose (with Aluminum or Brass Fittings),"
Revision original, dated November 26, 2012 Page A-58

0                                                                     0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.5.13 [Water Supply     Headers fed from each end shall be       - Complies           No Additional Clarification     DCM S-18, "Fire Protection System,"
Header Options]          permitted inside buildings to supply                                                          Revision 19, Sections 4.3.3.1.j and both sprinkler and standpipe                                                                 4.3.3.1.k systems, provided steel piping and fittings meeting the requirements of                                                          Drawing 438145, "Civil Plan ANSI B31.1, Code for Power Piping,                                                            Firewater System," Revision 34 are used for the headers (up to and including the first valve) supplying                                                          Drawing 047225, "Mechanical the sprinkler systems where such                                                              Design Standard Piping Specification headers are part of the seismically                                                          'K'," Sheet 1 Revision 22, Sheet 2 analyzed hose standpipe system.                                                               Revision 25, and Where provided, such headers shall                                                           Sheet 3 Revision 22 be considered an extension of the yard main system. Each sprinkler                                                              Drawing 102018 (series), "Unit 1 Fire and standpipe system shall be                                                                Protection Systems," Various equipped with an outside screw and                                                           Revisions yoke (OS&Y) gate valve or other approved shutoff valve.                                                                      Drawing 108018 (series), "Unit 2 Fire Protection Systems," Various Revisions PG&E Document "Classification of Structures, Systems, and Components for Diablo Canyon Power Plant Units 1 and 2 (Q-list),"
Revision 28, dated November 28, 2011 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Page A-59

0
* 0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Comoliance Statement      Compliance Basis           Reference Document 3.5.14 [Water Supply     All fire protection water supply and     - Complies           Complies with section (a)      DCM S-18, "Fire Protection System,"
Control Valve            fire suppression system control                                                              Revision 19, Sections 4.3.3.1.b and Supervision]             valves shall be under a periodic                                                             4.3.3.1.k inspection program and shall be supervised by one of the following                                                           STP's (from 3.2.3(1)): M-112, methods.                                                                                     M-39A1-3, M-39B-H, M-63A-H, M-64, M-65, M-66A, M-66B, (a) Electrical supervision with audible                                                      M-67B3, M-67B4, M-69A-C, M-71, and visual signals in the main control                                                       M-71B, M-72, V-3Q1, and V-3Q3 room or other suitable constantly attended location.                                                                           Report P1890-002-004, "Fire Protection Code Conformance (b) Locking valves in their normal                                                           Review Report," Revision 1, dated position. Keys shall be made                                                                 March 2013 available only to authorized personnel.                                                                                   Drawing 502091, "Unit I &2, Schematic Diagram, Firewater Valve, (c) Sealing valves in their normal                                                           Supervision Fire Pumps, Firewater positions. This option shall be utilized                                                     System," Revision 15 only where valves are located within fenced areas or under the direct                                                             Drawing 501129, "Unit 1, Schematic control of the owner/operator.                                                               Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-60

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.5.15 [Water Supply     Hydrants shall be installed             - Complies            No Additional Clarification    DCM S-18, "Fire Protection System,"
Hydrant Code             approximately every 250 ft (76 m)                                                            Revision 19, Section 4.3.2.1.a Requirements]            apart on the yard main system. A hose house equipped with hose and                                                            Report P1890-002-004, "Fire combination nozzle and other                                                                 Protection Code Conformance auxiliary equipment specified in                                                             Review Report," Revision 1, dated NFPA 24, Standard for the                                                                    March 2013 Installation of Private Fire Service Mains and Their Appurtenances,                                                               Drawing 438145, "Unit 1 & 2, Civil shall be provided at intervals of not                                                        Plan, Fire Water System, Power more than 1000 ft (305 m) along the                                                          Block Perimeter," Revision 35 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.
Page A-61

0 Pacific Gas and Electric Company                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element               NFPA 805 Reauirement                             Compliance Statement               Compliance Basis                     Reference Document 3.5.16 [Water Supply           The fire protection water supply                 - Complies with            Complies with Clarification:                 DCM S-18, "Fire Protection System,"
Dedicated Limits]              system shall be dedicated for fire               Clarification              Primary fire protection water                Revision 19, Sections 2.3.2 and protection use only.                             - Complies, with           storage is provided by the Raw               4.3.3.1 a Required Action            Water Reservoir. DCM S-16 Exception No. 1: Fire protection                                            Section 4.1.4 states, "The Raw               DCM S-16 "Make Up Water System,"
water supply systems shall be                                               Water Reservoir ... consists of              Revision 17A, Sections 2.2.2 and permitted to be used to provide                                             two kidney shaped parts, each                4.1.4 backup to nuclear safety systems,                                           of 2.5 million gallons storage provided the fire protection water                                          capacity." Section 2.2.2                     ECG 18.1 "Fire Suppression supply systems are designed and                                             states, "For all Modes of plant              Systems/Fire Suppression Water maintained to deliver the combined                                          operation, the Raw Water                     Systems," Revision 9, Surveillance fire and nuclear safety flow demands                                        Reservoirs are required to be                Requirement 18.1.1 for the duration specified by the                                           lined up to gravity feed the fire applicable analysis.                                                        suppression headers and have                 Drawing 102018 (series), "Unit 1 Fire a minimum usable volume of                   Protection Systems," Various Exception No. 2: Fire protection                                            360,000 gallons." ECG 18.1,                  Revisions water storage can be provided by                                            SR 18.1.1 requires: "Verify that plant systems serving other                                                 Raw Water Reservoir supply                   Drawing 108018 (series), "Unit 2 Fire functions, provided the storage has a                                       containing a minimum usable                  Protection Systems," Various dedicated capacity capable of                                               volume of 360,000 gallons."                  Revisions providing the maximum fire                                                  Due to the significant excess protection demand for the specified                                         capacity of the Raw Water                    Drawing 438148, Sheet 1, "Unit 1 &
duration as determined in this                                              Reservoirs (total capacity of 5              2, General Layout & Utility Plan, Raw million gallons) and the                     Water Reservoir Area," Revision 14 procedural requirement to maintain the volume required                 Drawing 6003131, Sheet 13, to ensure sufficient water is                "Reservoirs, Safety Anchors,"
available for fire protection,               Revision 1 exception 2 is satisfied and DCPP complies with this requirement.
Complies once Implementation Item S-3.14 is completed.
IMPLEMENTATION ITEMS:
S-3.14  SAP Notification #50294777-20 was issued to track plant procedures to ensure that a minimum level in the reservoir will be maintained to support a dedicated capacity capable of supply maximum fire protection demand per NFPA 805 Section 3.5.16. Plant procedures will also be revised to require evaluation of prohibiting non-FP use of fire water (FW) when lined up to the FW storage tank.
Page A-62

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement       Compliance Basis         Reference Document 3.6 Standpipe and        N/A                                 N/A                  N/A - Section Heading, see     N/A Hose Stations                                                                     sub-sections for any specific compliance statements Page A-63

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company               Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement        Compliance Basis          Reference Document 3.6.1 [Standpipe and     For all power block buildings, Class    - Complies by        Complies by Previous NRC         NRC SSER No. 8, dated Hose Station Code        III standpipe and hose systems shall    Previous NRC         Approval.                        November 15, 1978 Requirements]            be installed in accordance with NFPA    Approval             PG&E letter, "Supplementary 14, Standard for the Installation of                         Information for Fire Protection  DCM S-18, "Fire Protection System,"
Standpipe, Private Hydrant, and                              Review," dated November 13,      Revision 19, Section 4.3.3.1.j Hose Systems.                                                1978 states, "Interior manual hose stations are located so     Report P1890-002-004, "Fire that all locations can be        Protection Code Conformance reached with at least one        Review Report," Revision 1, dated effective hose stream.           March 2013 Exceptions to this criterion are as follows:                      PG&E letter, "Supplementary Information for Fire Protection Location, Area Coverage,         Review," dated November 13, 1978 Alternate Capability, FHA Sec U1 Battery Rm, 30%, C02 Hose, Manual, 4.1.6.1 U2 Battery Rm, 30%, C02 Hose, Manual, 4.1.6.2 U1 480V Swgr, 80%, C02 Hose, Manual, 4.1.5.1 U2 480V Swgr, 80%, C02 Hose, Manual, 4.1.5.2 U1 12kV Swgr, 10%, C02 Hose, Manual, 4.1.10 U2 12kV Swgr, 10%, C02 Hose, Manual, 4.1.20 U1 4.16kV Swgr, 10%, C02 Hose, Manual, 4.1.13 U2 4.16kV Swgr, 10%, C02 Hose, Manual, 4.1.24 U1 4.16kV CSR, 70%, C02, Manual, 4.1.12 U2 4.16kV CSR, 70%, C02, Manual, 4.1.23 Doc Storage Area, 50%,
Sprinkler, Manual, 4.1.21 Traveling Crew Quarters, 40%,
Page A-64

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Comnliance Basis           Reference Document Manual, 4.1.25 In addition, total area coverage is provided in the cable spreading room (Section 4.1.7) from existing hose reels, but not all hose reels are easily accessible.
Based on results of the fire hazards analysis, additional fire detection/suppression capabilities have been recommended in those areas where it is deemed appropriate."
SSER 8 accepted DCPP condition as follows: "Manual hose stations are located throughout the plant to ensure that an effective hose stream can be directed to any safety-related area in the plant.
These systems are consistent with the requirements of NFPA Standard No. 14, "Standpipe and Hose System for Sizing, Spacing, and Piping Support Requirements." The fire water tank, pumps and associated piping were initially classified as seismic Category I and will be qualified for the Hosgri event. The manual hose stations and their associated piping, which were not initially classified, will also be analyzed Page A-65

S Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Comoliance Statement        Compliance Basis          Reference Document and qualified for the Hosgri event as previously noted.
Based on our review, and on the applicant's commitments to install sprinkler systems in areas identified above, we conclude that water extinguishing systems, including automatic sprinklers, and manual hose stations are acceptable."
No significant changes have been made to the standpipes and hose reels that would affect any of the inputs or assumptions made in approval of this deviation. Accordingly, this previous NRC approval remains valid.
3.6.2 [Standpipe and      A capability shall be provided to       - Complies            No Additional Clarification     DCM S-18, "Fire Protection System,"
Hose Station              ensure an adequate water flow rate                                                            Revision 19, Section 4.3.1.1.f Capability Limitations]   and nozzle pressure for all hose stations. This capability includes the                                                        Calculation M-99, 'Hose Reel provision of hose station pressure                                                            Calculation," Revision 1, dated reducers where necessary for the                                                              October 1,2009 safety of plant industrial fire brigade members and off-site fire department                                                          Calculation M-1 01, "Pressure personnel.                                                                                    reducing Orifices," Revision 1, dated November 8, 1988 Drawing 060831 (series), "Fire Water Hose Reel RO Specifications,"
Revision 5 Page A-66

0                                                                     0                                                                    S Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis          Reference Document 3.6.3 [Standpipe and     The proper type of hose nozzle to be     - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Hose Station Nozzle      supplied to each power block area                                                            Revision 19, Section 4.3.3.1.j Restrictions]            shall be based on the area fire hazards. The usual combination                                                               Drawing 064358 (series), "Unit 1 &2, spray/straight stream nozzle shall not                                                       Details of Fire Water Hose Reel be used in areas where the straight                                                          Station Types I and IA," Various stream can cause unacceptable                                                                Revisions damage or present an electrical hazard to fire-fighting personnel.                                                           Drawing 064359, Sheet 1, "Unit 1 &
Listed electrically safe fixed fog                                                           2, Details of Fire Water Hose Reel nozzles shall be provided at                                                                 Station Types 2, 2A, 3, 3A, 4, and locations where high-voltage shock                                                           4A," Various Revisions hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed.
3.6.4 [Standpipe and     Provisions shall be made to supply       - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Hose Station             water at least to standpipes and                                                             Revision 19, Section 4.1.1 Earthquake Provisions]   hose stations for manual fire suppression in all areas containing                                                          Drawing 064358 (series), "Unit 1 &2, systems and components needed to                                                             Details of Fire Water Hose Reel perform the nuclear safety functions                                                         Station Types I and IA," Various in the event of a safe shutdown                                                              Revisions earthquake (SSE).
Drawing 064359, Sheet 1, "Unit 1 &
2, Details of Fire Water Hose Reel Station Types 2, 2A, 3, 3A, 4, and 4A," Various Revisions PG&E Document "Classification of Structures, Systems, and Components for Diablo Canyon Power Plant Units 1 and 2 (Q-list),"
Revision 28, dated November 28, 2011 Page A-67
* 0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement       Comoliance Basis         Reference Document 3.6.5 [Standpipe and     Where the seismic required hose         - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Hose Station Seismic     stations are cross-connected to                                                             Revision 19, Section 2.3.2 Connection Limitations]  essential seismic non-fire protection water supply systems, the fire flow                                                         Drawing 102018 (series), "Unit 1 Fire shall not degrade the essential water                                                       Protection Systems," Various system requirement.                                                                         Revisions Drawing 108018 (series), "Unit 2 Fire Protection Systems," Various Revisions 3.7 Fire Extinguishers   Where provided, fire extinguishers of   - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
the appropriate number, size, and                                                           Revision 19, Section 4.3.3.3 type shall be provided in accordance with NFPA 10, Standard for Portable                                                         Report P1890-002-004, "Fire Fire Extinguishers. Extinguishers                                                           Protection Code Conformance shall be permitted to be positioned                                                         Review Report," Revision 1, dated outside of fire areas due to                                                                March 2013 radiological conditions.
Drawing 059629 (series), "Unit 1 Schedule of Fire Extinguisher Locations,' Various Revisions Drawing 061958 (series), "Unit 2 Schedule of Fire Extinguisher Locations," Various Revisions Drawing 111906 (series) "Fire Protection," Various Revisions 3.8 Fire Alarm and       N/A                                     N/A                  N/A - Section Heading, see     N/A Detection systems                                                                     sub-sections for any specific compliance statements Page A-68

0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement         Compliance Basis        Reference Document 3.8.1 Fire Alarm         Alarm initiating devices shall be        - Complies with      Alarm annunciation is          DCM S-18, "Fire Protection System,"
installed in accordance with             Use of EEEEs         compliant. See Section 3.8.2   Revision 19, Section 4.3.5 NFPA 72, National Fire Alarm                                  below for discussion of alarm Code. Alarm annunciation shall                               initiating devices and         PG&E letter, "Supplementary allow the proprietary alarm system to                         associated EEEEs.              Information for Fire Protection transmit fire-related alarms,                                                                Review," dated November 13, 1978 supervisory signals, and trouble signals to the control room or other                                                         Report P1890-002-004, "Fire constantly attended location from                                                            Protection Code Conformance which required notifications and                                                             Review Report," Revision 1, dated response can be initiated. Personnel                                                         March 2013 assigned to the proprietary alarm station shall be permitted to have                                                           Drawing 502091, "Unit 1 & 2, other duties. The following fire-                                                            Schematic Diagram, Firewater Valve, related signals shall be transmitted:                                                        Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-69

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Comnoliance Basis          Reference Document 3.8.1(1) Fire Alarm (1)  Actuation of any fire detection device  - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Revision 19, Section 4.3.5.3 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 & 2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-70

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Requirement                   Compliance Statement      Compliance Basis          Reference Document 3.8.1(2) Fire Alarm (2)   Actuation of any fixed fire           - Complies            No Additional Clarification    DCM S-18, "Fire Protection System,"
suppression system                                                                         Revision 19, Sections 4.3.5.1 and 4.3.5.2 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 &2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, 'Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1 008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1 008," Revision 33 Drawing 333358, "Unit 1, Schematic Diagram, Cardox System,"
Revision 9 Drawing 338208, "Unit 2, Schematic Diagram, Cardox System,"
Revision 8 Drawing 338216, "Unit 1, Schematic Diagram, Deluge System Annunciator," Revision 13 Drawing 338217, "Unit 2, Schematic Diagram, Deluge System Annunciator," Revision 14 Page A-71

Pacific Gas and Electric Company             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                 Compliance Statement       Compliance Basis           Reference Document 3.8.1(3) Fire Alarm (3)  Actuation of any manual fire alarm   - Complies           No Additional Clarification     DCM S-18, "Fire Protection System,"
station                                                                                   Revision 19, Section 4.3.5 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 & 2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-72

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement      Comoliance Basis           Reference Document 3.8.1(4) Fire Alarm (4)  Starting of any fire pump                - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Revision 19, Section 4.3.5.1 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 & 2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-73

0                                                                    S Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.8.1(5) Fire Alarm (5)  Actuation of any fire protection        - Complies           No Additional Clarification. DCM S-18, "Fire Protection System,"
supervisory device                                                                           Revision 19, Sections 4.3.5.1 and 4.3.5.2 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 &2, Schematic Diagram, Firewater Valve, Supervision-Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 Page A-74

0                                                                     S Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement      Compliance Basis           Reference Document 3.8.1(6) Fire Alarm (6)   Indication of alarm system trouble      - Complies           No Additional Clarification. DCM S-18, "Fire Protection System,"
condition                                                                                    Revision 19, Section 4.3.5.3 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 502091, "Unit 1 & 2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 3.8.1.1 [Fire Alarm      Means shall be provided to allow a
* Complies            No Additional Clarification    Report P1890-002-004, "Fire Communications           person observing a fire at any                                                               Protection Code Conformance Requirements]            location in the plant to quickly and                                                         Review Report," Revision 1, dated reliably communicate to the control                                                          March 2013 room or other suitable constantly attended location.                                                                           Casualty Procedure (CP) M-6, "Fire,"
Revision 33A 0M8.ID1, "Fire Loss Prevention,"
Revision 24 Calculation 9000032684 (Legacy
                                                                                                                      #355-DC), "Emergency Lighting and Communications," Revision 008/00, Section 6 and Appendix D Page A-75

0                                                                     0 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Comoliance Statement       Comoliance Basis          Reference Document 3.8.1.2 [Fire Alarm       Means shall be provided to promptly      N/A                  N/A - General statement; No    N/A Prompt Notification       notify the following of any fire                              technical requirements Limits]                   emergency in such a way as to allow them to determine an appropriate course of action:
3.8.1.2(1) [Fire Alarm    General site population in all
* Complies           No Additional Clarification    Casualty Procedure (CP) M-6, "Fire,"
Prompt Notification       occupied areas                                                                               Revision 33A, Section 4.1 Limits] (1)
Drawing 458860, "Unit 1, Schematic Diagram, Fire Alarm System,"
Revision 18 Drawing 458593, "Units 1 & 2, Schematic Diagram, Fire Alarm System," Revision 6 3.8.1.2(2) [Fire Alarm    Members of the industrial fire brigade   &deg; Complies           No Additional Clarification    Casualty Procedure (CP) M-6, "Fire,"
Prompt Notification       and other groups supporting fire                                                             Revision 33A, Section 4.1 Limits] (2)               emergency response Page A-76

Pacific Gas and Electric Company 0                                                                    1 Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement      Compliance Basis          Reference Document 3.8.1.2(3) [Fire Alarm    Off-site fire emergency response         - Complies           No Additional Clarification    OP K-9, "Instructions for Operation of Prompt Notification       agencies. Two independent means                                                              DCPP Radio Systems,"
Limits] (3)               shall be available (e.g., telephone                                                          Revision 12 and radio) for notification of off-site emergency services.                                                                          STP 1-29, "Emergency Signals and Communication Systems Functional Test," Revision 41, Section 4 Casualty Procedure (CP) M-6, "Fire,"
Revision 33A, Section 4.1 Memorandum of Understanding between CAL FIRE / San Luis Obispo County Fire and Diablo Canyon Fire Department, dated January 1, 2012 Calculation 9000032684 (Legacy
                                                                                                                       #335-DC), "Emergency Lighting and Communications," Revision 008/00, Section 6.2 and Appendix D Page A-77

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company                Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program &Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement        Compliance Basis           Reference Document 3.8.2 Detection          If automatic fire detection is required  - Complies by         Complies by Previous NRC         NRC SSER No. 23, dated to meet the performance or               Previous NRC          Approval:                        June 18, 1984 deterministic requirements of            Approval              Previous NRC approval is Chapter 4, then these devices shall
* Complies with       credited for partial fire        NRC SSER No. 31, dated April 1985 be installed in accordance with NFPA     Use of EEEEs          detection in Fire Areas 3-BB 72, National Fire Alarm Code, and its                          (Unit 1), 3-CC (Unit 2), 4-A     PG&E letter, "Report on Deviations applicable appendixes.                                         (both units), and AB-1 (both     from Appendix R of 10 CFR 50,"
units) as follows:               dated July 15, 1983 PG&E letter, "Report on           PG&E letter, "Report on Deviations Deviations from Appendix R of     from Appendix R of 10 CFR 50 10 CFR 50 [Unit 1]," dated July   [Unit 2]," dated December 6, 1984 15, 1983, states: "Fire area 3-BB does not meet the            DCM S-18, "Fire Protection System,"
requirements of Appendix R,       Revision 19, Section 4.3.6.3.a Section III.G.2 in that only partial area detection and        Report P1890-002-004, "Fire suppression is provided... At     Protection Code Conformance Elevation 85 feet, smoke          Review Report," Revision 1, dated detection only is provided, and   March 2013 it is used for early notification of a fire in the post LOCA        FHARE No. 21, "Evaluation of Partial sampling room. On Elevations      Smoke Detector Coverage,"
100 and 115 feet, complete        Revision 2, dated April 5, 1990 automatic suppression is provided with ionization smoke    FHARE No. 47, "Partial Detection &
detectors located in the vicinity Suppression Protection," Revision 2, of the in-situ combustibles       dated April 5, 1990 (cable trays) on both elevations."                      FHARE No. 51, "Lack of Area-Wide And                               Fire Suppression and Detection,"
                                                                                       "Fire area 4-A does not meet      Revision 2, dated April 5, 1990 the requirements of Appendix R, Section IIl.G.2(c) in that     FHARE No. 78, "Smoke Detection in 1-hour rated fire barriers are    the False Ceiling Area," Revision 2, not provided around redundant     dated April 11, 1990 trains of safe shutdown systems located above the         FHARE No. 93, "Smoke Detectors Page A-78

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Comnliance Statement        Compliance Basis           Reference Document 1-hour rated drop ceiling."       Not in All Control Room Cabinets,"
Revision 0, dated August 30, 1991 PG&E letter, "Report on Deviations from Appendix R of     FHARE No. 116, "Testing and 10 CFR 50 [Unit 2]," dated        Maintenance of Ionization Smoke December 6, 1984, states: "Fire   Detectors," Revision 2, dated Area 3-CC does not meet the      September 15, 2004 requirements of Appendix R, Section III.G.2 in that only      FHARE No. 157, "Unprotected Fire partial area detection and        Rated Assemblies and Lack of Area-suppression is provided... At     wide Detection/Suppression," dated Elevation 85 feet, in the post-   May 16, 2013 LOCA sampling room, smoke detection is provided and it is used for early notification of a fire. At Elevations 100 and 115 feet, complete automatic suppression is provided with partial area ionization smoke detectors located in the vicinity of the in-situ combustibles (cable trays) on both elevations."
SSER 23 states:
                                                                                  "9.6.1.4 Penetration Area (Fire Area 3-BB)
A fire on any elevation might damage redundant shutdown systems. However, the amount of combustible material on all three levels is limited and widely dispersed...
The partial smoke detection systems in the area would activate after some time delay and would alert the plant fire Page A-79

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis             Reference Document brigade.., the absence of area-wide smoke detection and fire suppression systems on this level [85 feet] would not prevent the ability to achieve and maintain safe shutdown...
the staff concludes that the existing fire protection, provides an acceptable level of fire safety ... the licensee's request for a deviation in the penetration area (Fire Area 3-BB) is approved.
9.6.1.5 Chemical Laboratory and Offices (Fire Area 4-A)
Although the smoke detection system does not cover the entire fire area, the rooms that are unprotected are a small fraction of the total floor area...
Thus, if a fire were to occur within an unprotected room, a detector in an adjoining room would activate after a short delay... the staff concludes that the existing fire protection,
                                                                                  ... provides an acceptable level of fire safety ... the licensee's request for a deviation in chemical laboratory and offices (Fire Area 4-A) is approved."
SSER 31 states:
                                                                                  "9.6.1.4 Penetration Area Based on its evaluation, the Page A-80

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis          Reference Document staff concludes that the existing fire protection, provides an acceptable level of fire safety ... the licensee's request for a deviation in the penetration area (Fire Area 3-CC) is approved.
9.6.1.5 Chemical Laboratory and Offices These areas are common to both units. The staff evaluation in SSER 23 applies to both units."
Complies with Use of EEEEs:
Automatic detection systems credited to meet the requirements of Chapter 4 are identified in Section 4.8 of the Transition Report. For the credited systems, DCPP complies with NFPA 72A-1967, Standard for the Installation, Maintenance and Use of Local Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service, and NFPA 72D-1975, Standard for the Installation, Maintenance and use of Proprietary Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service, as documented in Report P1890-002-004, "Fire Protection Code Conformance Review Report,"
Page A-81

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement       Comoliance Basis          Reference Document Revision 1, dated March 2013.
Engineering evaluations (FHAREs) were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents."
3.9 Automatic and        N/A                                     N/A                  N/A - Section Heading, see     N/A Manual Water-Based                                                                    sub-sections for any specific Fire Suppression                                                                      compliance statements Systems 3.9.1 [Fire              If an automatic or manual water-        N/A                  N/A                            N/A Suppression System       based fire suppression system is Code Requirements]       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:
Page A-82

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Elemeint        NFPA 805 Reauirement                     Compliance Statement        Compliance Basis           Reference Document 3.9.1(1) [Fire           NFPA 13, Standard for the                - Complies by         Complies by Previous NRC         NRC SSER No. 23, dated Suppression System       Installation of Sprinkler Systems        Previous NRC          Approval:                        June 18, 1984 Code Requirements]                                                Approval              Previous NRC approval is (1)                                                               - Complies with       credited for partial suppression NRC SSER No. 31, dated April 1985 Use of EEEEs          n Fire Areas 3-BB (Unit 1),
3-CC (Unit 2), 4-A (both units), PG&E letter, "Report on Deviations and AB-1 (both units) as         from Appendix R of 10 CFR 50,',
follows:                         dated July 15, 1983 PG&E letter, "Report on           PG&E letter, "Report on Deviations Deviations from Appendix R of     from Appendix R of 10 CFR 50 10 CFR 50 [Unit 1], dated        [Unit 2]," dated December 6, 1984 July 15, 1983, states: "Fire Area 3-BB does not meet the       DCM S-18, 'Fire Protection System,"
requirements of Appendix R,       Revision 19, Section 4.3.3.1.k Section III.G.2 in that only partial area detection and        FHARE No. 47, "Partial Detection &
suppression is provided... At     Suppression Protection," Revision 2, Elevation 85 feet, smoke          dated April 5, 1990 detection only is provided, and it is used for early notification FHARE No. 51, 'Lack of Area-Wide of a fire in the post LOCA        Fire Suppression and Detection,"
sampling room. On Elevations      Revision 2, dated April 5, 1990 100 and 115 feet, complete automatic suppression is          FHARE No. 157, "Unprotected Fire provided with ionization smoke    Rated Assemblies and Lack of Area-detectors located in the vicinity wide Detection/S uppress ion,"' dated of the in-situ combustibles       May 16, 2013 (cable trays) on both elevations."                      FHARE No. 160, "Lack of Return And                               Bends in Fire Sprinkler Piping," dated "Fire Area 4-A does not meet      March 21, 2013 the requirements of Appendix R, Section IIl.G.2(c) in that     Report P1890-002-004, "Fire 1-hour rated fire barriers are    Protection Code Conformance not provided around redundant     Review Report," Revision 1, dated trains of safe shutdown           March 2013 systems located above the Page A-83

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis            Reference Document 1-hour rated drop ceiling."
PG&E letter, "Report on Deviations from Appendix R of 10 CFR 50 [Unit 2]," dated December 6, 1984, states: "Fire Area 3-CC does not meet the requirements of Appendix R, Section II.G.2 in that only partial area detection and suppression is provided...
At Elevation 85 feet, in the post-LOCA sampling room, smoke detection is provided and it is used for early notification of a fire. At Elevations 100 and 115 feet, complete automatic suppression is provided with partial area ionization smoke detectors located in the vicinity of the in-situ combustibles (cable trays) on both elevations."
SSER 23 states:
                                                                                  "9.6.1.4 Penetration Area (Fire Area 3-BB)
A fire on any elevation might damage redundant shutdown systems. However, the amount of combustible material on all three levels is limited and widely dispersed...
the absence of area-wide smoke detection and fire suppression systems on this level [85 feet] would not Page A-84

       *0                                                                                                                                0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis           Reference Document prevent the ability to achieve and maintain safe shutdown...
the staff concludes that the existing fire protection, ...
provides an acceptable level of fire safety ... the licensee's request for a deviation in the penetration area (Fire Area 3-BB) is approved.
9.6.1.5 Chemical Laboratory and Offices (Fire Area 4-A)
If the fire propagates rapidly and room temperatures rise, the automatic sprinkler system will activate automatically to suppress the fire and limit damage. During the time between the start of the fire and the arrival of the fire brigade or the activation of the sprinkler system, the membrane ceiling will provide sufficient passive protection to prevent cables above the ceiling from sustaining damage. There is no significant quantity of ignitable materials above the ceiling because all cables are enclosed in conduit... the staff concludes that the existing fire protection, ... provides an acceptable level of fire safety
                                                                                  ... the licensee's request for a deviation in chemical laboratory and offices (Fire Area 4-A) is approved."
Page A-85

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                Compliance Statement        Compliance Basis          Reference Document SSER 31 states:
                                                                                  "9.6.1.4 Penetration Area Based on its evaluation, the staff concludes that the existing fire protection, provides an acceptable level of fire safety ... the licensee's request for a deviation in the penetration area (Fire Area 3-CC) is approved.
9.6.1.5 Chemical Laboratory and Offices These areas are common to both units. The staff evaluation in SSER 23 applies to both units."
Complies with Use of EEEEs:
Automatic or manual water based suppression systems credited to meet the requirements of Chapter 4 are identified in Section 4.8 of the Transition Report. For the credited systems, DCPP complies with NFPA 13-1969 and 1983, Standard for the Installation of Sprinkler Systems, as documented in Report P1890-002-004, "Fire Protection Code Conformance Review Report, Revision 1, dated March 2013.
Page A-86

S Pacific Gas and Electric Company             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                  Compliance Statement       Compliance Basis           Reference Document Engineering evaluations (FHAREs) were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents."
3.9.1(2) [Fire           NFPA 15, Standard for Water Spray     - Complies with      Complies with Use of EEEEs:      DCM S-18, "Fire Protection System,"
Suppression System       Fixed Systems for Fire Protection     Use of EEEEs         Automatic or manual water        Revision 19, Section 4.3.3.1.k Code Requirements]                                                                  based suppression systems (2)                                                                                 credited to meet the             Report P1890-002-004, "Fire requirements of Chapter 4 are    Protection Code Conformance identified in Section 4.8 of the Review Report," Revision 1, dated Transition Report. For the       March 2013 credited systems, DCPP complies with NFPA 15-1969 and 1990, Water Spray Fixed Systems for Fire Protection, as documented in Report P1890-002-004, "Fire Protection Code Conformance Review Report, Revision 1, dated March 2013.
Engineering evaluations (FHAREs) were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents."
Page A-87

0Ga Pacific Gas and Electric Company              Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                   Compliance Statement       Comoliance Basis          Reference Document 3.9.1(3) [Fire           NFPA 750, Standard on Water Mist       N/A                  NFPA 750 does not apply, as     N/A Suppression System       Fire Protection Systems                                     there are no water mist Code Requirements]                                                                   extinguishing systems installed (3)                                                                                  at DCPP.
3.9.1(4) [Fire           NFPA 16, Standard for the              N/A                  NFPA 16 does not apply, as      N/A Suppression System       Installation of Foam-Water Sprinkler                        there are no foam water Code Requirements]       and Foam-Water Spray Systems                                sprinkler and foam-water spray (4)                                                                                  extinguishing systems installed at DCPP.
3.9.2 [Fire              Each system shall be equipped with     - Complies           No Additional Clarification     DCM S-18, "Fire Protection System,"
Suppression System       a water flow alarm.                                                                         Revision 19, Section 4.3.3.1.k Flow Alarm]
Drawing 338216, "Unit 1, Schematic Diagram, Deluge System Annunciator," Revision 13 Drawing 338217, "Unit 2, Schematic Diagram, Deluge System Annunciator," Revision 14 Page A-88

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Comoliance Statement        Compliance Basis        Reference Document 3.9.3 [Fire              All alarms from fire suppression        - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression system       systems shall annunciate in the                                                             Revision 19, Section 4.3.3.1.k Alarm Locations]         control room or other suitable constantly attended location.                                                               Drawing 102034, Sheet 16, "Unit 1, Piping & Instrumentation Drawing, Deluge System," Revision 90 Drawing 108034, Sheet 16A, "Unit 2, Piping & Instrumentation Drawing, Deluge System," Revision 61 Drawing 501130, "Unit 1, Schematic Diagram, Main Annunciator,"
Revision 46 Drawing 500780, "Unit 2, Schematic Diagram, Main Annunciator,"
Revision 44 3.9.4 [Fire              Diesel-driven fire pumps shall be       N/A                  There are no permanently       N/A Suppression System       protected by automatic sprinklers,                           installed diesel-driven fire Diesel Pump Sprinkler                                                                 pumps at DCPP.
Protection]
Page A-89

0 Pacific Gas and Electric Company             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                  Compliance Statement      Comoliance Basis           Reference Document 3.9.5 [Fire              Each system shall be equipped with   - Complies            No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       an OS&Y gate valve or other                                                               Revision 19, Section 4.3.3.1.k Shutoff Controls]        approved shutoff valve.
Drawing 102018 (series), "Unit 1 Fire Protection Systems," Various Revisions Drawing 108018 (series), "Unit 2 Fire Protection Systems," Various Revisions Drawing 049020, Sheet 29, "Valve Specification Mark No. G-0219,"
Revision 16 Page A-90

0                                                                                                                                         S Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Comoliance Statement       Comoliance Basis          Reference Document 3.9.6 [Fire              All valves controlling water-based fire - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       suppression systems required to                                                             Revision 19, Section 4.3.3.1.k Valve Supervision]       meet the performance or deterministic requirements of                                                               STP M-67A, "Fire Valve Inspection,"
Chapter 4 shall be supervised as                                                            Revision 48, All Sections described in 3.5.14.
STP's (from 3.2.3(1)): M-112, M-39A1-3, M-39B-H, M-63A-H, M-64, M-65, M-66A, M-66B, M-67B3, M-67B4, M-69A-C, M-71, M-71B, M-72, V-3Q1, and V-3Q3 Drawing 502091, "Unit 1 & 2, Schematic Diagram, Firewater Valve, Supervision Fire Pumps, Firewater System," Revision 15 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator, PK0914 thru PK1008," Revision 33 3.10 Gaseous Fire        N/A                                     N/A                  N/A - Section Heading, see     N/A Suppression Systems                                                                   sub-sections for any specific compliance statements Page A-91

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company                Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 80&sect; Element         NFPA 805 Reauirement                     Compliance Statement       Compliance Basis          Reference Document 3.10.1 [Gaseous          If an automatic total flooding and       N/A                  N/A - General statement; No     N/A Suppression System       local application gaseous fire                                technical requirements Code Requirements]       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:
3.10.1(1) [Gaseous       NFPA 12, Standard on Carbon
* Complies            No Additional Clarification     DCM S-18, "Fire Protection System,"
Suppression System       Dioxide Extinguishing Systems                                                                 Revision 19, Section 4.3.1.2.c Code Requirements]
(1)                                                                                                                    Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 3.10.1(2) [Gaseous       NFPA 12A, Standard on Halon 1301         N/A                  NFPA 12A does not apply, as     N/A Suppression System       Fire Extinguishing Systems                                    there are no Halon Code Requirements]                                                                     extinguishing systems installed (2)                                                                                    in the DCPP Power Block.
3.10.1(3) [Gaseous       NFPA 2001, Standard on Clean            N/A                   NFPA 2001 does not apply, as    N/A Suppression System       Agent Fire Extinguishing Systems                              there are no clean agent fire Code Requirements]                                                                     extinguishing systems installed (3)                                                                                    in the DCPP Power Block.
Page A-92

Pacific Gas and Electric Company              Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                   Comoliance Statement      Comoliance Basis           Reference Document 3.10.2 [Gaseous          Operation of gaseous fire              - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       suppression systems shall                                                                  Revision 19, Sections 4.3.8.2.a and Alarm Location]          annunciate and alarm in the control                                                        4.3.8.2.b room or other constantly attended location identified.                                                                       Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 501129, "Unit 1, Schematic Diagram, Main Annunciator,"
Revision 46 Drawing 500779, "Unit 2, Schematic Diagram, Main Annunciator,"
Revision 33 Page A-93

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                   Compliance Statement      Compliance Basis          Reference Document 3.10.3 [Gaseous           Ventilation system design shall take   - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System        into account prevention from over-                                                         Revision 19, Sections 4.3.2.2, Ventilation Limitations]  pressurization during agent injection,                                                     4.3.3.2.a and 4.3.3.4.b adequate sealing to prevent loss of agent, and confinement of                                                                  Report P1890-002-004, "Fire radioactive contaminants.                                                                  Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 494387, "Unit 1, Schematic and Diagram of Connections, Cardox System, Diesel Generator Rooms 1-1, 1-2, and 1-3," Revision 1 Drawing 494400, "Unit 2, Schematic and Diagram of Connections, Cardox System, Diesel Generator Rooms 2-1, 2-2, and 2-3," Revision 4 Drawing 102023, Sheet 18, "Unit 1, Piping Schematic, Ventilation and Air Conditioning System, Diesel/Generator," Revision 94 Drawing 108023, Sheet 18, "Unit 2, Piping Schematic, Ventilation and Air Conditioning System, Diesel/Generator Ventilation,"
Revision 64 Drawing 102023, Sheet 20, "Unit 1 Piping Schematic, Ventilation and Air Conditioning System, Common (Ul and U2) Intake Structure,"
Revision 100 Drawing 102023, Sheet 18C, "Unit 1 Piping Schematic, Ventilation and Air Page A-94

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement      Compliance Basis          Reference Document Conditioning System, Areas 'B, C &
D', Turbine Building Ventilation Systems," Revision 98 Drawing 108023, Sheet 18B, "Unit 2 Piping Schematic, Ventilation and Air Conditioning System, Areas 'B, C &
D', Turbine Building Ventilation Systems," Revision 47 Drawing 102023, Sheet 13, "Unit 1 Piping Schematic, Ventilation and Air Conditioning System, Aux. Building:
Condenser Unit Room, Cable Spreading Room, 480V Switchgear Room Supply & Exhaust,"
Revision 104 Drawing 108023, Sheet 13, "Unit 2 Piping Schematic, Ventilation and Air Conditioning System, Aux. Building:
Condenser Unit Room, Cable Spreading Room, 480V Switchgear Room Supply & Exhaust,"
Revision 73 Drawing 338213, "Unit 1 & 2, Electrical Schematic, Cardox System," Revision 16 Drawing 494416, "Unit 1 & 2, Schematic Diagram, Ventilation System, Cable Spreading Room,"
Revision 6 Page A-95

0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                     Compliance Statement      ComPliance Basis          Reference Document 3.10.4 [Gaseous          In any area required to be protected     N/A                  Not Applicable. DCPP does      N/A Suppression System       by both primary and backup gaseous                            not have areas protected by Single Failure Limits]   fire suppression systems, a single                            both primary and backup active failure or a crack in any pipe in                      gaseous suppression systems.
the fire suppression system shall not impair both the primary and backup fire suppression capability.
3.10.5 [Gaseous          Provisions for locally disarming
* Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       automatic gaseous suppression                                                                Revision 19, Sections 4.3.4.2.b Disarming Controls]      systems shall be secured and under strict administrative control.                                                               ECG 18.5, "C02 System," Revision 9 OP2.1D1, "Clearances," Revision 29, Section 5 Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 3.10.6 [Gaseous          Total flooding carbon dioxide            &deg; Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       systems shall not be used in                                                                 Revision 19, Section 4.3.2.2.a C02 Limitations]         normally occupied areas.
Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Page A-96

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company               Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Comoliance Statement      Compliance Basis           Reference Document 3.10.7 [Gaseous          Automatic total flooding carbon         - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression system       dioxide systems shall be equipped                                                           Revision 19, Section 4.3.2.2 C02 Warnings]            with an audible pre-discharge alarm and discharge delay sufficient to                                                           Report P1890-002-004, "Fire permit egress of personnel. The                                                             Protection Code Conformance carbon dioxide system shall be                                                              Review Report," Revision 1, dated provided with an odorizer.                                                                  March 2013 Drawing 338213, "Unit 1 & 2, Schematic Diagram, Cardox System," Revision 16 Drawing 102018, Sheet 6, "Unit 1, Fire Protection Systems, Carbon Dioxide Fire Protection System Hazard Spray Heads," Revision 74 Drawing 102018, Sheet 6A, "Unit 1, Fire Protection Systems, Carbon Dioxide Fire Protection System Hosereels," Revision 72 Drawing 108018, Sheet 6, "Unit 2, Fire Protection Systems, Carbon Dioxide Fire Protection System Hazard Spray Heads," Revision 37 Drawing 108018, Sheet 6A, "Unit 2, Fire Protection Systems, Carbon Dioxide Fire Protection System Hosereels," Revision 35 Drawing 102018, Sheet 8 "Unit 1, Fire Protection Systems, C02 Protection for Intake Structure,"
Revision 38 Page A-97

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement      Compliance Basis          Reference Document 3.10.8 [Gaseous          Positive mechanical means shall be      - Complies           No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       provided to lock out total flooding                                                         Revision 19, Sections 4.3.3.2 and C02 Required             carbon dioxide systems during work                                                          4.3.4.2.b Disarming]               in the protected space.
Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013 Drawing 102018, Sheet 6, "Unit 1, Fire Protection Systems, Carbon Dioxide Fire Protection System Hazard Spray Heads," Revision 74 ECG 18.5, "C02 System," Revision 9 I&C Maintenance Procedure MP 1-2.35-1, "Cable Spreading Room Cardox System Removal / Return to Service," Revision 2 Page A-98

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement       Compliance Basis          Reference Document 3.10.9 [Gaseous          The possibility of secondary thermal   - Complies            No Additional Clarification    DCM S-18, "Fire Protection System,"
Suppression System       shock (cooling) damage shall be                                                             Revision 19, Section 4.3.2.2 Cooling                  considered during the design of any Considerations]          gaseous fire suppression system, but                                                        Report P1890-002-004, "Fire particularly with carbon dioxide.                                                           Protection Code Conformance Review Report," Revision 1, dated March 2013 Operating Procedure OP K-2B, "Low Pressure Cardox Fire Fighting System," Revision 9, Section 5.3 Specification 8724, "Auto Sprinkler System / Carbon Dioxide Fire Protection System," Revision 12, dated March 14, 1985 TQ1.DC12, "Fire Brigade and Emergency Response Training,"
Revision 12 3.10.10 [Gaseous         Particular attention shall be given to N/A                   DCPP uses no extinguishing     N/A Suppression System       corrosive characteristics of agent                           agents that could leave Decomposition Issues]    decomposition products on safety                             corrosive decomposition systems.                                                     products Page A-99

0 Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                   Compliance Statement       Compliance Basis         Reference Document 3.11 Passive fire        This section shall be used to           N/A                  N/A - General statement; No    N/A Protection Features      determine the design and installation                        technical requirements 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.
Page A-100

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement         Compliance Basis           Reference Document 3.11.1 Building          Each major building within the power    - Complies with       Plant general design and          DCM S-18, "Fire Protection System,"
Separation               block shall be separated from the       Use of EEEEs          ayout plays a significant role in Revision 19, Section 4.3.10.a others by barriers having a                                   fire protection by providing the designated fire resistance rating of                          needed physical separation        FHARE No. 5, "Main Steam Line 3 hours or by open space of at least                          between safety-related            Penetration Turbine/Containment 50 ft (15.2 m) or space that meets                            systems and unacceptable fire     Penetration Areas," Revision 3, the requirements of NFPA 80A,                                 hazards [Reference Appendix       dated April 11, 1990 Recommended Practice for                                      Ato Branch Technical Position Protection of Buildings from Exterior                         (BTP) APCSB 9.5-1, and NEIL       FHARE No. 12, "Winch Cable Fire Exposures.                                               Property Loss Prevention          Penetrations for Post-LOCA Standards]. Generally, when       Sampling Room Shield Wall,"
Exception: Where a performance-                               physical separation (via          Revision 2, dated April 4, 1990 based analysis determines the                                 distance) cannot be achieved, adequacy of building separation, the                          fire barriers are provided to     FHARE No. 13, "Unique Blockout requirements of 3.11.1 shall not                              ensure protection of a single     Penetration seal through barrier apply.                                                        safety division from fire         between the Unit 2 hazards, and to separate          Turbine/Containment Penetration redundant divisions or trains of  Areas," Revision 3, dated safety-related systems from       March 10, 1998 each other so that both are not subject to damage from a          FHARE No. 38, "Undampered single fire.                      Ventilation Duct and Unrated Door in 1-Hour Rated Barrier," Revision 2, The major buildings for each       dated April 6, 1990 unit are the Turbine Building, Auxiliary Building, Fuel           FHARE No. 58, "Undampered Duct Handling Building, Intake          Penetrations 4B, 19E, TB-7/19-A,"
Structure and Containment          Revision 3, dated June 26, 1998 and the separation of these structures is evaluated in         FHARE No. 60, "Undampered Appendix 9.5A. Based on the        Ventilation Duct Penetration,"
analysis performed as describe     Revision 2, dated March 24, 1990 above and the greater than 50 feet separation of the major       FHARE No. 91, "Non-rated Barrier power block buildings from         Between Fire Area/Zone 3-BB major buildings, compliance        (3-CC) and 3-P-2 (3-V-2),"
with use of the existing           Revision 0, dated May 11, 1992 engineering equivalency Page A-101

0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement       Compliance Basis         Reference Documnent evaluation is achieved.        FHARE No. 97, "Containment Electrical Penetrations," Revision 0, Engineering evaluations        dated October 7, 1991 (FHAREs) were developed to analyze the acceptability of   FHARE No. 100, "Block Walls various configurations at      Structurally Modified with Columns, DCPP. A list of applicable     Beams, and Steel Plates,"
engineering evaluations is     Revision 0, dated March 17, 1992 provided under "Reference Documents."                    FHARE No. 109, "Acceptance Criteria For Penetration Seals In Selected Barriers," Revision 2, dated October 6, 2004 EHARE No. 118, "Appendix R Fire Area Boundary Plaster Barriers,"
Revision 0, dated June 3, 1999 FHARE No. 121, "Pipe Penetration Seals through Plaster Walls in the Unit -1 AFW Pump Rooms Flammastic & Marinite Boards in Plaster Walls," Revision 0, dated May 12,1998 FHARE No. 123, "Unsealed Penetrations With Fusible Link Chain Penetrants Through Fire Barriers,"
Revision 0, dated March 11, 1998 FHARE No. 125, "Lesser Rated Plaster Blockouts and Penetration Seal Configurations," Revision 0, dated March 11, 1998 FHARE No. 128, "Non-rated Pipe Penetrations in Ceiling of Unit 1 Page A-1 02

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reouirement               Compliance Statement       Compliance Basis           Reference Document Turbine Driven Auxiliary Feedwater Pump Room," Revision 0, dated April 3, 1998 FHARE No. 130, "Inaccessible Jumbo Duct Penetrants," Revision 0, dated May 22, 1998 FHARE No. 133, "Seismic /
Construction Gaps in the 12 kV Switchgear Rooms," Revision 1, dated October 26, 1999 FHARE No. 157, "Unprotected Fire Rated Assemblies and Lack of Area-wide Detection/Suppression," dated May 16, 2013 Drawings 515562 - 515580, "Fire Barriers, Zones, and Fixed Suppression/Detection," Various Revisions Page A-103

Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company                 Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                      Compliance Statement       Compliance Basis           Reference Document 3.11.2 Fire Barriers     Fire barriers required by Chapter 4       - Complies with      Complies with Clarification:     DCM S-18, "Fire Protection System,"
shall include a specific fire-resistance  Clarification        Fire barriers required by        Revision 19, Section 4.3.10.b rating. Fire barriers shall be designed   - Complies with      Chapter 4 will be identified in  through 4.3.10O.d and installed to meet the specific fire   Use of EEEEs         the Fire Safety Analyses (FSA) resistance rating using assemblies                             completed for each fire area. DCM S-98, "Penetration Seals,"
qualified by fire tests. The                                   The FSAs will be developed       Revision 6, All Sections qualification fire tests shall be in                           based on M-657 which accordance with NFPA 251,                                      currently documents fire barrier Calculation M-657, 'Document the Standard Methods of Tests of Fire                              requirements. A specific fire-   Change in Inspection Requirements Endurance of Building Construction                             resistance rating for all fire   for Fire Barriers," Part 001, and Materials, or ASTM E 119,                                  barriers is included (see        Version 00 Standard Test Methods for Fire Tests                           Implementation Item S-3.15).
of Building Construction and                                                                    Calculation M-670, "Fire Barrier Materials.                                                     All walls, floors, and ceilings  Penetration Seal Documentation,"
separating fire areas are either Revision 15 reinforced concrete construction which meet or       Calculation M-997, "Qualification of exceed a 3-hour fire rating, or  Penetration Seal Typical Seal are of concrete block            Details," Revision 12 construction with a 3-hour fire resistance rating or have been   FHARE No. 3, "Valve Operator evaluated as equivalent or       Shafts Through Barrier 5001,"
adequate for the hazard. The     Revision 3, dated April 29, 1999 design and installation of fire barriers meets the               FHARE No. 11, 'Non-rated Barrier requirements of ASTM E 119.      Features," Revision 2, dated All openings for cable, pipe,    April 11, 1990 and ductwork in walls, floor, and ceilings separating fire     FHARE No. 30, "Unrated Gaps in areas have been sealed with      Appendix R Barriers in the Turbine foamed in place silicone which   Building," Revision 5, dated was tested for up to three       October 15, 1999 hours fire exposure in an ASTM E 119 wall fire test.       FHARE No. 37, "Rating of Barriers Cable tray openings have been    Between CCW Pump Rooms,"
sealed and verified by ASTM E    Revision 3, dated March 1,1998 119 tests.
FHARE No. 91, 'Non-rated Barrier Page A-1 04

9                                                                      0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement       Compliance Basis          Reference Document Complies with use of EEEEs:     Between Fire Area/ Zone 3-BB (3-Each barrier which contained a  CC) and 3-P-2 (3-V-2)," Revision 0, feature with an unrated         dated May 11, 1992 component was analyzed with respect to its fire suppression FHARE No. 103, "Fire Barrier and detection systems,          Configurations in the Emergency proximity to safe-shutdown      Diesel Generator Rooms,"
equipment, and the impact that  Revision 4, dated October 10, 1999 the unrated portion of the fire barrier could have oh safe-     EHARE No. 117, "Safe Shutdown shutdown capability. These      Analysis for Modifying Fire Area 4A barriers which contained        and 4B Boundary Barriers,"
unrated components have         Revision 1, dated March 30, 2005 been evaluated as equivalent or adequate for the hazards. EHARE No. 119, "Plaster Barriers Credited for Appendix A to BTP (APCSB) 9.5-1," Revision 0, dated May 14, 1999 EHARE No. 134, "Non-rated Structural Gap Seals in Fire Barriers," Revision 1, dated October 6, 2004 FHARE No. 146, "Gaps in Unistruts and Support Members Through Pyrocrete Barriers," Revision 0, dated September 28, 2001 FHARE No. 157, "Unprotected Fire Rated Assemblies and Lack of Area-wide Detection/Suppression," dated May 16, 2013 Drawing 066689 (series),
                                                                                                                  "Penetrating Seal, Typical Design Details," Various Revisions Page A-105

Pi G                                                                                      B Pacific Gas and Electric Company                       Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element             NFPA 805 Reauirement                              Compliance Statement              Compliance Basis              Reference Document Drawings 515562 - 515580, "Fire Barriers, Zones, and Fixed Suppression/Detection," Various Revisions IMPLEMENTATION ITEMS:
S-3.15  SAP Notification #50399545 was issued to track the development of the FP basis document in the form of the Fire Safety Analysis (FSA).
Page A-106
* 0 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                     Compliance Statement        Compliance Basis            Reference Document 3.11.3 Fire Barrier       Penetrations in fire barriers shall be   - Complies with      Complies with use of EEEEs:        Calculation M-997, "Qualification of Penetrations              provided with listed fire-rated door     Use of EEEEs         In general, fire-rated door        Penetration Seal Typical Seal assemblies or listed rated fire                               assemblies or listed rated fire    Details," Revision 12 dampers having a fire resistance                              dampers having the fire rating consistent with the designated                         resistance rating consistent       Basis documentation for Engineering fire resistance rating of the barrier as                      with the fire resistance rating of Equivalency Evaluations is listed in determined by the performance                                 the fire barrier are provided. 3.11.3(1) through 3.11.3(3).
requirements established by                                   Where fire-rated door Chapter 4. (See 3.11.3.4 for                                  assemblies or listed rated fire penetration seals for through                                 dampers are not provided with penetration fire stops). Passive fire                         the fire resistance rating protection devices such as doors and                          consistent with the fire dampers shall conform with NFPA                               resistance rating of the fire 80, 90A, and 101 as identified below.                         barrier (e.g., hatches, water curtains, manways, etc.), the Exception: Where fire area                                    assemblies have been boundaries are not wall-to-wall, floor-                       evaluated to be equivalent or to-ceiling boundaries with all                                 adequate for the hazard.
penetrations sealed to the fire rating                        DCPP complies with the use of required of the boundaries, a                                 EEEE's (FHARE) for fire rated performance-based analysis shall be                           door assemblies and rated fire required to assess the adequacy of                            dampers as evaluated in fire barrier forming the fire boundary                         EEEEs identified.
to determine if the barrier will withstand the fire effects of the                              The fire-rated door assemblies hazards in the area. Openings in fire                         and fire-rated dampers comply barriers shall be permitted to be                             with NFPA 80 and NFPA 90A protected by other means as                                   as documented in Report acceptable to the AHJ.                                        P1 890-002-004, "Fire Protection Code Conformance Review Report, Revision 1, dated March 2013.
Page A-107

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                    Compliance Statement        Compliance Basis          Reference Document 3.11.3(1) [NFPA 80 -     Passive fire protection devices such    - Complies by        Complies by Previous NRC         DCM S-18, "Fire Protection System,"
Fire Door and Window     as doors and dampers shall conform      Previous NRC         Approval:                        Revision 19, Section 4.3.10 Requirements] (1)        with the following NFPA standards,      Approval as applicable:                          - Complies with      PG&E letter, Responses to        DCPP letter to NRC, "Answers to Use of EEEEs         NRC Questions, dated             NRC Staff Questions Relating to (1) NFPA 80, Standard for Fire Doors                         February 6, 1978 states in the   Diablo Canyon Fire Protection and Fire Windows                                             response to Question 5, "Fire    Review," dated February 6, 1978 doors are U.L. labeled or certified by the vendor to be    Report P1890-002-004, "Fire constructed in accordance with   Protection Code Conformance U.L. labeled specifications, or  Review Report," Revision 1, dated an equivalent."                  March 2013 In the response to Question 41   Specification 2078, "Power Block, of the 58 Questions, "Three      New and Replacement Hollow Metal hour rated walls which define    Doors," Revision 0, dated fire zones or fire areas as      July 6, 1990 specified in the Fire Protection Review (Amendment 41) have       FHARE No. 70, "Lesser Rated (or will have) three-hour rated  Doors," Revision 2, dated doors or an equivalent.          April 7, 1990 Situations where doors felt to be equivalent to three-hour      FHARE No. 90, "Lockset Protectors doors are:                       on Fire Doors," Revision 1, dated December 14, 1990 (1) Steel rolling doors that are unlabeled due to their size, but FHARE No. 94, "Containment were manufactured to "A" label   Personnel Airlock Doors,"
specifications.                  Revision 0, dated May 24,1991 (2) The missile barrier door that separates the diesel        FHARE No. 95, "Justification of generators from the main         Excessive Gaps on Fire Doors turbine area. The door is of     Maximum Allowable Door Gaps,"
heavier construction than a "A"  Revision 0, dated September 11, labeled door.                    1990 (3) Blow out panels between the turbine building and the     FHARE No. 157, "Unprotected Fire penetration area. The panels     Rated Assemblies and Lack of Area-Page A-108

Pacific Gas and Electric Company            Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company            Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                 Compliance Statement        Comnliance Basis           Reference Document are of three-hour construction    wide Detection/Suppression," dated but "A" labeled latching          May 16, 2013 requirements would interfere with their blowout function. A    FHARE No. 159, "Unrated doors means will be provided to         Protected by Local Automatic ensure the panels are normally    Sprinklers," dated March 21, 2013 closed.
(4) In some areas monorails       Drawings 515562 - 515580, "Fire for equipment removal             Barriers, Zones, and Fixed penetrate fire doors. Doors       Suppression/Detection," Various built to "A"label specifications  Revisions are (or will be) provided, but due to the monorail               Drawings 515220 - 515226 (series),
penetration, are unlabeled.       "Unit 1 & 2, Door Schedule," Various Revisions No three-hour rated fire doors at Diablo Canyon contain glass windows."
In the response to various questions, commitments were made to upgrade specific doors.
Per Section 9.6.1, "Fire Barriers," of NRC SSER No. 8, dated November 15, 1978, "Fire Doors and Fire Dampers We reviewed the placement of the fire doors to ensure that fire doors of proper fire rating are provided. The applicant's fire hazard analysis identified a number of fire areas where the fire rating of the door was less than the rating of the fire Page A-109

0                                                                0                                                                 0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement         Compliance Basis           Reference Document barrier in which the door was installed. The applicant committed to upgrade the fire doors rating or install fire doors of appropriate rating for these areas. We require that the applicant comply with this commitment prior to plant operation. Based on our evaluation and the applicant's commitment, we conclude that fire doors of the proper rating are or will be installed in fire barriers throughout the plant."
No significant changes have been made that would affect any of the inputs or assumption made in approval of this deviation. Accordingly, this previous NRC approval remains valid.
Complies with use of EEEEs:
Where fire-rated door assemblies or listed rated fire dampers are not provided with the fire resistance rating consistent with the fire resistance rating of the fire barrier (e.g., hatches, water curtains, manways, etc.), the assemblies have been evaluated to be equivalent or adequate for the hazard.
DCPP complies with the use of EEEE's for fire-rated door assemblies and fire-rated Page A-1 10

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement       Compliance Basis         Reference Document dampers as evaluated in FHARES identified.
The fire-rated door assemblies and rated fire dampers comply with NFPA 80 and NFPA 90A as documented in Report P1890-002-004, "Fire Protection Code Conformance Review Report," Revision 1, dated March 2013.
Page A-1Il

Pacific Gas and Electric Company               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                    Compliance Statement       Compliance Basis          Reference Documnent 3.11.3(2) [NFPA 90A -    Passive fire protection devices such    - Complies with      Complies with use of EEEEs:     DCM S-18, "Fire Protection System,"
Fire Damper              as doors and dampers shall conform      Use of EEEEs         Where fire-rated door           Revision 19, Section 4.3.10 Requirements] (2)        with the following NFPA standards,                           assemblies or listed rated fire as applicable:                                               dampers are not provided with   Report P1890-002-004, "Fire the fire resistance rating      Protection Code Conformance (2) NFPA 90A, Standard for the                               consistent with the fire        Review Report," Revision 1,dated Installation of Air-Conditioning and                         resistance rating of the fire   March 2013 Ventilating Systems                                          barrier (e.g., hatches, water curtains, manways, etc.), the   Specification 101 27-M-NPG, "Fire assemblies have been            Dampers in HVAC System,"
evaluated to be equivalent or   Revision 1, dated adequate for the hazard.        September 17, 2011 DCPP complies with the use of EEEE's for fire rated door      FHARE No. 9, "Ventilation Opening assemblies and fire-rated       Above Unit 1 and 2 AFW Pumps,"
dampers as evaluated in         Revision 3, dated May 15,1998 FHARES identified.
FHARE No. 15, "HVAC Ducts The fire-rated door assemblies  Wrapped With Pyrocrete 102 (Units and rated fire dampers comply   1 &2)," Revision 2, dated with NFPA 80 and NFPA 90A       April 11, 1990 as documented in Report P1890-002-004, "Fire            FHARE No. 25, "Non-Rated Features Protection Code Conformance     in the Unit 1 and 2 Centrifugal Review Report," Revision 1,     Charging Pump Rooms Undampered dated March 2013.               Duct Penetrations, Revision 3," dated May 22, 1998 FHARE No. 27, "Undampered Duct Penetrations in Concrete Lined Shafts," Revision 3, dated October 6, 2004 FHARE No. 31, "Undampered Duct Penetrations From the Fan Room,"
Revision 2, dated April 6, 1990 FHARE No. 33, "Undampered Page A-1 12

0                                                                0                                                                      0 Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Elemen          NFPA 805 Reauirement                Compliance Statement      Compliance Basis          Reference Document Ventilation Duct Penetrations,"
Revision 3, dated March 31, 1999 FHARE No. 38, "Undampered Ventilation Duct and Unrated Door in 1-Hour Rated Barrier," Revision 2, dated April 6, 1990 FHARE No. 40, "Undampered Ventilation. Ducts," Revision 3, dated November 2, 2001 FHARE No. 42, "Fire Damper Installation for Fire Areas 5-A-4 and 5-B-4," Revision 1, dated March 18, 1990 FHARE No. 56, "Undampered Ventilation Duct Penetration,"
Revision 2, dated April 5, 1990 FHARE No. 58, "Undampered Duct Penetrations 4B, 19E, TB-7/19-A,"
Revision 3, dated June 26, 1998 FHARE No. 60, "Undampered Ventilation Duct Penetration,"
Revision 2, dated March 24, 1990 FHARE No. 67, "Undampered Duct Penetrations," Revision 2, dated March 20, 1990 FHARE No. 73, "Undampered Ducts," Revision 3, dated October 6, 2004 FHARE No. 77, "Fiberglass Fume Page A-113

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement      Compliance Basis          Reference Document Hood Exhaust Ducts," Revision 2, dated April 11, 1990 FHARE No. 80, "Fire Dampers Installed At Variance with Manufacturer's Instructions,"
Revision 3, dated March 16, 1998 FHARE No. 126, "HVAC Ducts through Modified Unrated Hatches,"
Revision 0, dated July 7, 1998 FHARE No. 129, "Duct Penetrations Through Common Walls Associated with Fire Zones 8-A, 8-D, 8-E, 8-F, 8-G and 8-H," Revision 1, dated July 9, 2012 FHARE No. 130, "Inaccessible Jumbo Duct Penetrants," Revision 0, dated May 22, 1998 FHARE No. 136, "Unrated HVAC Duct Penetrations," Revision 1, dated May 13, 1999 FHARE No. 139, "Unrated HVAC Duct Seal Penetrant in Cable Spreading Room," Revision 0, dated June 3, 1999 FHARE No. 149, "Non-rated Fire Damper Installations In Fire Area AB-1, Zone 3-C, Tool Room,"
Revision 0, dated June 11, 2007 Drawings 515562 - 515580, "Fire Barriers, Zones, and Fixed Page A-114

0 Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Reauirement                    Compliance Statement        Comoliance Basis         Reference Document Suppression/Detection," Various Revisions 3.11.3(3) [NFPA 101 -     Passive fire protection devices such    - Complies with      DCPP complies with             Basis documentation for this section Life Safety Code         as doors and dampers shall conform       Clarification        clarification with regards to  is listed in 3.11.3(1) and 3.11.3(2)
Requirements] (3)        with the following NFPA standards,                            NFPA 101, 2000 Edition.        above.
as applicable:                                                NFPA 101 compliance is achieved through NFPA 80 (3) NFPA 101, Life Safety Code                                and NFPA 90A. NFPA 101, 2000 Edition, Section 8.2.3.2.1(a) with regards to rated fire door assemblies refers to NFPA 80. NFPA 101, 2000 Edition, Section 9.2.1 with regards to rated fire dampers refers to NFPA 90A.
Table B-i, Section 3.11.3(1) and 3.11.3(2) discuss compliance of NFPA 80 and NFPA 90A.
3.11.4 Through           Through penetration fire stops for       N/A                  N/A - Section Heading, see     N/A Penetration Fire Stops   penetrations such as pipes, conduits,                         sub-sections for any specific bus ducts, cables, wires, pneumatic                           compliance statements tubes and ducts, and similar building service equipment that pass through fire barriers shall be protected as follows.
Page A-115

0 Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                      Compliance Statement        Compliance Basis           Reference Document 3.11.4(a) Through        (a) The annular space between the        - Complies with       Complies with Clarification:      Calculation M-997, "Qualification of Penetration Fire Stops   penetrating item and the through         Clarification                                           Penetration Seal Typical Seal opening in the fire barrier shall be     - Complies with       Except as identified below,       Details," Revision 12 filled with a qualified fire-resistive   Use of EEEEs          DCPP complies with the penetration seal assembly capable of                           requirements of this section. Calculation M-670, "Fire Barrier maintaining the fire resistance of the                                                           Penetration Seal Documentation,"
fire barrier. The assembly shall be                            Calculation M-670, "Fire          Revision 15 qualified by tests in accordance with                          Barrier Penetration Seal a fire test protocol acceptable to the                         Documentation" identifies and     FHARE No. 3, "Valve Operator AHJ or be protected by a listed fire-                          documents penetrations            Shafts Through Barrier 5001,"
rated device for the specified fire-                           through fire barriers.            Revision 3, dated April 29, 1999 resistive period.
Calculation M-997,                FHARE No. 4, "Stairwell Ceiling for Fire Area 10 and Fire Area 20,"
                                                                                        "Qualification of Penetration     Revision 2, dated April 4, 1990 Seal Typical Seal Details," has the following purpose: "The       FHARE No. 5, "Main Steam Line purpose of this calculation is to Penetration Turbine/Containment establish the criteria and the    Penetration Areas," Revision 3, design of penetration seals for   dated April 11, 1990 use in fire barriers at DCPP, in a manner consistent with          FHARE No. 6, "Structural Gap at licensing commitments, NRC        Concrete Block Walls," Revision 4, guidance, and procedural          dated September 9, 1999 requirements. The resulting criteria and penetration seal     FHARE No. 11, "Non-rated Barrier designs will be used to satisfy   Features," Revision 2, dated fire barrier requirements,        April 11, 1990 assuring that a level of protection commensurate with      FHARE No. 12, "Winch Cable the hazards present and/or        Penetrations for Post-LOCA equal to the rating of the        Sampling Room Shield Wall,"
barrier is maintained."           Revision 2, dated April 4, 1990 Calculation M-997,                FHARE No. 14, "Concrete Appendix 1, has the following     Equipment Hatches," Revision 4, purpose and scope: "The           dated January 30, 1999 purpose of this evaluation is to Page A-1 16

0 Pacific Gas and Electric Company            Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                 Compliance Statement        Compliance Basis            Reference Document establish the criteria that will EHARE No. 20, "Bus Duct be used for the review of        Penetrations," Revision 2, dated April penetration seal fire test       5,1990 reports. It is necessary to ensure that installed             FHARE No. 26, "Non-rated Barriers,"
penetration seal designs will    Revision 3, dated October 6, 2004 provide an adequate level of fire protection and support the   FHARE No. 29, "Fire Traps for Diesel Diablo Canyon Power Plant        Generator Rooms," Revision 2, (DCPP) commitments.[13]          dated April 5,1990 Thus, fire test reviews are used to verify that fire test    EHARE No. 30, "Unrated Gaps in methods support PG&E              Appendix R Barriers in the Turbine licensing commitments and        Building," Revision 5, dated NRC guidance for the fire        November 15, 1999 testing of penetration seal assemblies. This evaluation       FHARE No. 37, "Rating of Barriers reviews NRC guidance, Diablo      Between CCW Pump Rooms,"
Canyon Power Plant (DCPP)         Revision 3, dated March 1, 1998 commitments, and the major industry fire testing standards,  FHARE No. 50, "Plaster Blockout and establishes the fire test     Panels in 3-Hour Barriers,"
review criteria and               Revision 4, dated May 13, 1999 methodology used by DCPP."
FHARE No. 75, "1-Hour Barrier,"
: 1. Electrical Penetrations        Revision 3, dated August 21, 1996
                                                                                   -Electrical penetrations through fire barriers for cables, cable   FHARE No. 91, "Non-rated Barrier trays, conduit, and bus ducts     Between Fire Area! Zone 3-BB are sealed to provide a fire      (3-CC) and 3-P-2 (3-V-2),"
resistance rating at least equal  Revision 0, dated May 11, 1992 to the fire resistance rating of the fire barrier penetrated       FHARE No. 100, "Block Walls
[Reference Appendix A to BTP      Structurally Modified with Columns, APCSB 9.5-1]. Otherwise an        Beams, and Steel Plates,"
engineering evaluation is         Revision 0, dated March 17, 1992 provided, to the guidelines of Generic Letter                    FHARE No. 103, "Fire Barrier Page A-1 17

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Pacific Gas and Electric Company           Attachment A NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                Compliance Statement        Compliance Basis           Reference Documnent 86-10, to justify the adequacy    Configurations in the Emergency of the penetration assembly to    Diesel Generator Rooms,"
ensure safe shutdown              Revision 4, dated functions are not affected.       November 10, 1999 Where required, open space inside conduit is also sealed to  FHARE No. 104, "Fire Proofing on prevent the transmission of       Structural Steel For Block Walls,"
fire, smoke, and hot gasses.      Revision 1, dated October 6, 2004
                                                                                  -Electrical penetration fire seal designs use materials which       FHARE No. 106, "Block Walls have been tested in               Modified in the 4kV Switchgear accordance with ASTM E-1 19       Area," Revision 2, dated fire and hose stream tests        September 21, 1993
[Reference Calculation M-674].
FHARE No. 107, "Block Walls
: 2. Piping Penetrations            Modified in the Counting and
                                                                                  -Fire barrier piping              Chemical Lab Area," Revision 0, penetrations are sealed to an     dated July 16, 1993 equivalent fire resistance rating of the fire barrier [Reference    FHARE No. 111, "Glass Pipe Appendix A to BTP APCSB 9.5-      Penetrants," Revision 0, dated 1], or otherwise, an              June 12, 1998 engineering evaluation is provided to justify the           FHARE No. 117, "Safe Shutdown adequacy of the penetration       Analysis for Modifying Fire Area 4A assembly to ensure safe           and 4B Boundary Barriers,"
shutdown functions are not        Revision 1, dated March 30, 2005 affected. This evaluation is performed to the guidelines of    FHARE No. 118, "Appendix R Fire Generic Letter 86-10.             Area Boundary Plaster Barriers,"
                                                                                  -There are two categories of      Revision 0, dated June 3, 1999 pipe penetration seal designs, seal designs for cold pipes and   FHARE No. 119, "Plaster Barriers seal designs for pipes with       Credited for Appendix A to BTP thermal movement. Seal            (APCSB) 9.5-1 ," Revision 0, dated design for cold pipes is similar  May 14, 1999 to seal design for rigid electrical conduit. Seal design   FHARE No. 122, "Staircases S-7 and Page A-1 1

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Compliance Basis           Reference Document for pipes with thermal            S-6 Fire Area Boundary," Revision 1, movement utilizes materials       dated October 26, 1999 and configurations which do not restrict the thermal          FHARE No. 123, "Unsealed movement (expansion and           Penetrations With Fusible Link Chain contraction) of the pipe.         Penetrants Through Fire Barriers,"
                                                                                  -Piping penetration fire seal     Revision 0, dated designs use materials which       March 11, 1998 have been tested in accordance with ASTM E-1 19       FHARE No. 125, "Lesser Rated fire and hose stream tests        Plaster Blockouts and Penetration
[Reference Calculation M-674]. Seal Configurations," Revision 0, dated March 11, 1998
: 3. Ventilation Penetrations
                                                                                  -Ventilation duct penetrations    FHARE No. 128, "Non-rated Pipe through fire barriers are         Penetrations in Ceiling-of-Unit 1 sealed, internally and            Turbine Driven Auxiliary Feedwater externally, [Reference            Pump Room," Revision 0, dated Appendix A to BTP APCSB           April 3, 1998 9.5-1] or otherwise, have an engineering evaluation to         FHARE No. 131, "Non-Rated Pipe justify their acceptability. This Penetration in the Clean and Dirty evaluation is performed to the    Lube Oil Room and Unit 1 & Unit 2 guidelines of GL 86-10.           Turbine Lube Oil Reservoirs,"
Design bases for fire dampers     Revision 0, dated May 7, 1999 (providing internal duct sealing) are discussed in         FHARE No. 133, "Seismic /
Section 4.3.3.5.                  Construction Gaps in the 12kV
                                                                                  -The design of external seals     Switchgear Rooms," Revision 1, for ventilation ducts allows for  dated October 26, 1999 a small clearance between ducts and their barriers, in      FHARE No. 134, "Non-rated accordance with damper            Structural Gap Seals in Fire manufacturer                      Barriers," Revision 1, dated recommendations, for proper       October 6, 2004 operation of internal fire dampers.                          FHARE No. 135, "Gaps and Potentially Degraded Penetration Page A-1 1

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Reauirement                Compliance Statement        Comoliance Basis          Reference Document DCPP fire seals are designed     Seals in Appendix-A Fire Rated to have a fire rating            Barriers," Revision 1, dated commensurate with the hazard     January 13, 2000 present on either side of the barrier and/or equal to the fire FHARE No. 137, "Unrated rating of the barrier in which   Penetrations through the Unit 1 they are installed [barrier fire Control Room Floor (Barrier 458),"
ratings are shown in drawings    Revision 0, dated August 20, 1999 515562 through 515580],
except as follows (Reference     FHARE No. 140, "Unrated GL 86-10):                       Penetrations through Unit 2 Control
                                                                                  -Seals which are accepted (in    Room Floor (Barrier 458),"
writing) by the NRC and          Revision 0, dated July 28, 1999
                                                                                  -Seals which are evaluated in accordance with Procedure for    FHARE No. 141, "Fireproofing On Fire Hazards Appendix R          Unistruts Attached To Structural Evaluations (FHARE) and their    Steel Members," Revision 0, dated associated 10 CFR 50.59          April 28, 2000 Safety Evaluation.
The fire ratings of DCPP         FHARE No. 146, "Gaps in Unistruts penetration seals are based on   and Support Members Through fire tests performed in          Pyrocrete Barriers," Revision 0, accordance with ASTM E-1 19      dated September 28, 2001
[SSER Supplements 8 and 9]
or similar standard test         FHARE No. 147, "Evaluation of methods (ASTM E-814, IEEE        Lesser Rated Unistrut Configurations 634 or ANI/MAERP Test            in 128 foot Cable Spreading Room, Standard. These test methods     Revision 0, dated March 13, 2002 involve:
                                                                                  -High temperature exposure       Drawing 066689 (series),
for the fire endurance period,   "Penetrating Seal, Typical Design followed by                      Details," Various Revisions
                                                                                  -Application of a hose stream.
Key elements of the acceptance criteria for the tests are [GL 86-10]:
                                                                                  -No passage of flame or hot gases, Page A-120

Pacific Gas and Electric Company           Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                Comoliance Statement        Compliance Basis         Reference Document
                                                                                  -Limited unexposed side temperature rise, and
                                                                                  -No passage of water during the hose stream exposure.
[Designs for installed penetrations seals and fire tests that support those seal designs are provided in Drawing 066689 of Design Change Notice (DCN) DCO-SM-049282 and Mechanical Calculation M-997. The DCN was the vehicle for issuing all penetration seal typical detail designs, and M-997 contains the detailed evaluations which establish the typical details through analysis and review of fire testing]. DCPP penetration seal designs are installed by qualified personnel working for a specialty seal vendor or by trained PG&E personnel.
Thus, installed penetration seals are based on testing performed in accordance with industry standard test methods.
Complies with Use of EEEEs:
Engineering evaluations (FHAREs) were developed to analyze the acceptability of various configurations at DCPP. A list of applicable engineering evaluations is provided under "Reference Documents."
Page A-121

Pacific Gas and Electric Company                 Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Requirement                     Comoliance Statement      Compliance Basis           Reference Document 3.11.4(b) Through        (b) Conduits shall be provided with       - Complies           No Additional Clarification    Calculation M-997, "Qualification of Penetration Fire Stops   an internal fire seal that has an                                                             Penetration Seal Typical Seal equivalent fire-resistive rating to that                                                      Details," Revision 12 of the fire barrier through opening fire stop and shall be permitted to be                                                             Calculation M-670, "Fire Barrier installed on either side of the barrier                                                       Penetration Seal Documentation,"
in a location that is as close to the                                                         Revision 15 barrier as possible.
Drawing 066689 (series),
Exception: Openings inside conduit                                                            "Penetrating Seal, Typical Design 4 in. (10.2 cm) or less in diameter                                                           Details," Various Revisions 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.
Page A-122

Pacific Gas and Electric Company                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element          NFPA 805 Requirement                    Compliance Statement       Compliance Basis         Reference Document 3.11.5 Electrical        ERFBS required by Chapter 4 shall        - Complies with      Complies with Use of EEEEs:    FHARE No. 138, "Drain Holes in Raceway Fire Barrier     be capable of resisting the fire effects Use of EEEEs         Engineering evaluations        Pyrocrete Panels in Fire Areas 10 Systems (ERFBS)          of the hazards in the area. ERFBS                             (FHAREs) were developed to     and 20," Revision 0, dated shall be tested in accordance with                            analyze the acceptability of   November 4, 1998 and shall meet the acceptance                                 various configurations at criteria of NRC GL 86-10,                                     DCPP. A list of applicable     FHARE No. 145, "Pyrocrete Supplement 1, "Fire Endurance Test                            engineering evaluations is     Enclosure Thickness," Revision 1, Acceptance Criteria for Fire Barrier                          provided under "Reference      dated May 9, 2001 Systems Used to Separate Safe                                 Documents."
Shutdown Trains Within the Same                                                              MIP C-10.0, "Pyrocrete Installation Fire Area." The ERFBS needs to                                                               (DCP-207)," Revision 4 adequately address the design requirements and limitations of                                                              MIP C-13.0, "3M Interam Fire supports and intervening items and                                                           Protection System (DCP-212),"
their impact on the fire barrier system                                                      Revision 3 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 GL 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 Page A-123

Pacific Gas and Electric Company              Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Element         NFPA 805 Requirement                   Compliance Statement      Comoliance Basis           Reference Document GL 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 GL 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.
Page A-124

Attachment B - NEI 04-02 Table B-2 Pacific Gas and Electric Company                                NSCA Methodoloav Review B. NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review 141 Pages Page B-1

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Tnhla R-1 M"mpga2r _Qfaihi ('!a      kiih,  A aapam~nn+0-0 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.0 Deterministic                 This section discusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe shutdown analysis to Methodology                       address regulatory requirements. For a complete understanding of the deterministic requirements, work this section in combination with the information in Appendix C, High/Low Pressure Interfaces, Appendix D, Alternative and Dedicated Shutdown Requirements, Appendix E, Acceptance Criteria for Operator Manual Actions and repairs, and Appendix H, Hot Shutdown versus Important to Safe Shutdown Components. To resolve the industry issue related to multiple spurious operations (MSOs), refer to Section 4, Appendix B, Appendix F, and Appendix G. The plant specific analysis approved by NRC is reflected in the plant's licensing basis. The methodology described in this section is an acceptable method of performing a post-fire safe shutdown analysis. This methodology is depicted in Figure 3-1. Other methods acceptable to NRC may also be used.
Regardless of the method selected by an individual licensee, the criteria and assumptions provided in this guidance document may apply. The methodology described in Section 3 is based on a computer database oriented approach, which is utilized by several licensees to model Appendix R data relationships. This guidance document, however, does not require the use of a computer database oriented approach.
The requirements of Appendix R, Sections III.G.1, III.G.2, and III.G.3 apply to equipment and cables required for achieving and maintaining safe shutdown in any fire area. Although equipment and cables for fire detection and suppression systems, communications systems and 8-hour emergency lighting systems are important features, this guidance document does not address them. The requirements of Appendix R, Section III.G.2, do not apply to the circuits for fire detection and suppression systems, communications systems and 8-hour emergency lighting systems.
Additional information is provided in Appendix B to this document related to the circuit failure criteria to be applied in assessing impacts to post-fire safe shutdown, including MSOs. The criteria in Appendix B developed for MSOs has also been included in Section 3.5.1.1 for assessing the potential affects of fire-induced impacts to individual components on the required safe shutdown path for a particular III.G.1 and 2 fire area.
Section 4 provides the Resolution Methodology for determining the Plant Specific List of MSOs to be evaluated. Section 5 provides a focused-scope Fire Probabilistic Risk Assessment (PRA) risk methodology for assessing, on an individual basis, the risk significance of any MSOs determined to be impacted within a common plant fire area. The appropriate use of these tools for mitigating the effects of fire-induced circuit failures for this section and for the MSOs addressed in Section 4 and Appendix G are discussed in Appendix H.
Applicability                     Comments Applicable                        None Alionment Statement Aligns Alignment Basis A deterministic methodology was used to assess conformance with the NSPC from Section 1.5.1 of NFPA 805 for Diablo Canyon Power Plant.
The DCPP NFPA 805 Nuclear Safety Capability Assessment (NSCA) deterministic methodology has been reviewed in detail against the guidance, criteria, and assumptions contained within NEI 00-01, Chapter 3, as documented in the subsequent sections of this table (i.e., Table B-2 from NEI 04-02). The results of this review conclude that the DCPP NSCA has been performed consistent with (i.e., aligns with) the deterministic methodology guidance, criteria, and assumptions from Chapter 3 of NEI 00-01.
With the exception of a few specific paragraphs, all other information contained herein from DCPP plant documentation is paraphrased. Unless otherwise noted, all statements are applicable to DCPP as a whole (i.e., DCPP Units 1 and 2).
Page B-2

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Canabilitv Assessment Methodoloav Revie Attachment B - NEI                Table B-2 Nuclear Safety    04-02Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Note that NEI 00-01, Revision 2, identifies a distinction between components and cables that are "Important to Safe Shutdown" and "Required for Hot Shutdown." This distinction is not applicable to a licensing basis that complies with the requirements of NFPA 805. Furthermore, all components that are identified to support the NFPA 805 NSCA definition of "safe and stable" plant conditions are consistent with the NEI 00-01, Appendix H, definition of "Required for Hot Shutdown." Cables that are required for the proper operation of such components are also understood to be "Required for Hot Shutdown."
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        None PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                     None Circuit Analysis Page B-3

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                                          &#xfd;X Attac~hmpnt B    -  NEI 04-02l Tphcin R..9 Kmuipa~r q~fh      1'2 2huilhi A cahacmgnt Rfnhkll 1+/-                                   UY_
PouinuAg Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1 Safe Shutdown               This section discusses the identification of systems necessary to perform the required safe shutdown functions. It also provides information on the Systems and Path                process for combining these systems into safe shutdown paths. Appendix R, Section IIl.G.l.a, requires that the capability to achieve and maintain Development                     hot shutdown be free of fire damage. Appendix R, Section IIl.G.l.b, requires that repairs to systems and equipment necessary to achieve and maintain cold shutdown be completed within 72 hours. This section provides some guidance on classifying components as either required or important to safe shutdown (SSD) circuit components. It also provides some guidance on the tools available for mitigating the effects of fire-induced circuit failures to each of these classes of equipment. For a more detailed discussion of the topic of required and important to SSD components refer to Appendix H.
The goal of post-fire safe shutdown is to assure that a one train of shutdown systems, structures, and components remains free of fire damage for a single fire in any single plant fire area. This goal is accomplished by determining those functions required to achieve and maintain hot shutdown.
Safe shutdown systems are selected so that the capability to perform these required functions is a part of each safe shutdown path. The functions required for post-fire safe shutdown generally include, but are not limited to the following:
                                - Reactivity control
                                - Pressure control systems
                                - Inventory control systems
                                - Decay heat removal systems
                                - Process monitoring (as defined in NRC Information Notice 84-09)
                                - Support systems
                                   - Electrical power and control systems
                                   - Component Cooling systems
                                   - Component Lubrication systems These functions are of importance because they have a direct bearing on the safe shutdown goal of being able to achieve and maintain hot shutdown, which ensures the integrity of the fuel, the reactor pressure vessel and the primary containment. Ifthese functions are preserved, then the plant will be safe because the fuel, the reactor and the primary containment will not be damaged. By assuring that this equipment is not damaged and remains functional, the protection of the health and safety of the public is assured.
The components required to perform these functions are classified as required for hot shutdown components. These components are necessary and sufficient to perform the required safe shutdown functions assuming that fire-induced impacts to other plant equipment/cables do not occur.
Since fire-induced impacts to other plant equipment/cables can occur in the fire condition, these impacts must also be addressed. The components not necessary to complete the required safe shutdown functions, but which could be impacted by the fire and cause a subsequent impact to the required safe shutdown components are classified as either required for hot shutdown or important to SSD components. Depending on the classification of the components, the tools available for mitigating the affects of fire-induced damage vary. The available tools are generally discussed in this section and in detail in Appendix H. The classification of a component or its power or control circuits may vary from fire area to fire area. Therefore, the required safe shutdown path for any given fire area is comprised of required for hot shutdown components and important to SSD components. The distinction and classification for each required safe shutdown path for each fire area should be discernible in the post-fire safe shutdown analysis.
Generic Letter 81-12 specifies consideration of associated circuits of concern with the potential for spurious equipment operation and/or loss of power source, and the common enclosure failures. As described above, spurious operations/actuations can affect the accomplishment of the required safe shutdown functions listed above. Typical examples of the effects of the spurious operations of concern are the following:
Page B-4

Pacific Gas and Electric Comoanv                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Caoabilitv Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection
                                - A loss of reactor pressure vessel/reactor coolant inventory in excess of the safe shutdown makeup capability
                                - A flow loss or blockage in the inventory makeup or decay heat removal systems being used for the required safe shutdown path.
Spurious operations are of concern because they have the potential to directly affect the ability to achieve and maintain hot shutdown, which could affect the fuel and cause damage to the reactor pressure vessel or the primary containment. To address the issue of multiple spurious operations, Section 4 provides a Resolution Methodology for developing a Plant Specific List of MSOs for evaluation. Appendix B provides the circuit failure criteria applicable to the evaluation of the Plant Specific list of MSOs.
Common power source and common enclosure concerns could also affect the safe shutdown path and must be addressed.
In addition to the tools described for components classified as required for hot shutdown, fire-induced impacts to cables and components classified as important to SSD may be mitigated using some additional tools. For important to SSD component failures, operator manual actions, fire modeling and/or a focused-scope fire PRA may be used to mitigate the impact. (If the use of a Focused-Scope Fire PRAs is not permitted in the Plants Current License Basis, then, a License Amendment Request (LAR) will be necessary to use the Focused-Scope Fire PRA).
ApDlicabilit                    Comments Applicable                       None Alignment Statement Aligns Alignment gasis DCPP systems / functions / components required to achieve and maintain "safe and stable" plant conditions post-fire per the NSPC of NFPA 805 are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection. The identification and analysis of these systems / functions / components includes addressing associated circuit issues for spurious operations, common power supplies, and common enclosures. These associated circuit issues are discussed in Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
The DCPP definition for "safe and stable" plant operation post-fire per the Nuclear Safety Performance Criteria (NSPC) of NFPA 805 is provided in Section 8.6, Definition of"Safe and Stable" Plant Conditions for DCPP, of Report R2165-004-001.
A computer database tool, System Assurance & Fire Protection Engineering Software (SAFE), is utilized to demonstrate that the NSPC of NFPA 805 are met for each fire area of the plant. The computer database tool is identified as the "NSCA database" in the remainder of this table, and is described in Section 12.0, Description of SAFE, of Report R2165-004-001.
Comments None Reference Documents                                                                                                        Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Sections 8.0 (Subsection 8.6), 10.0, and 12.0 Page B-5

SG                                                                    0 Pacific Gas and Electric Company                           Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated Circuit (CKT) None Analysis - Fire Protection Page B-6

Pacific Gas and Electric Company                                 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.1.1 Criteria/Assumptions     The following criteria and assumptions should be considered, as applicable, when identifying systems available and necessary to perform the required safe shutdown functions and combining these systems into safe shutdown paths. This list provides recognized examples of criteria/assumptions but should not be considered an all-inclusive list. The final set of criteria/assumptions should be based on regulatory requirements and the performance criteria for post-fire safe shutdown for each plant.
Aoolicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                              Not Applicable Page B-7

Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2,4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.1.1 Criteria/Assumptions    [BWR] GE Report GE-NE-T43-00002-00-01-RO1 entitled "Original Safe Shutdown Paths For The BWR" addresses the systems and equipment originally designed into the GE boiling water reactors (BWRs) in the 1960s and 1970s, that can be used to achieve and maintain safe shutdown per Section lII.G. 1 of 10 CFR 50, Appendix R. Any of the shutdown paths (methods) described in this report are considered to be acceptable methods for achieving redundant safe shutdown.
Applicability                   Comments Not Applicable.                 DCPP is a PWR; BWR guidance is not applicable.
Alignment Statement Not Applicable Alianment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                     Document Details Not Applicable                                                                                                          Not Applicable Page B-8

0    M. t1-      nA Cla&#xfd;fr;&#xfd;  frm      nn                           Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.1.2 Criteria/Assumptions      [BWR] GE Report GE-NE-T43-00002-00-03-RO1 provides a discussion on the     BWR Owners' Group (BWROG) position regarding the use of Safety Relief Valves (SRVs) and low pressure systems (LPCI/CS) for safe shutdown. The BWROG position is that the use of SRVs and low pressure systems is an acceptable methodology for achieving redundant safe shutdown in accordance with the requirements of 10 CFR 50 Appendix R Sections II.G.1 and 1II.G.2. The NRC has accepted the BWROG position and   issued a Safety Evaluation Report (SER) dated December 12, 2000.
AeDlicability                     Comments Not Applicable                    DCPP is a PWR; BWR guidance is not applicable.
Alignment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                   Document Details Not Applicable                                                                                                        Not Applicable Page B-9

A 01      1. t,                                   Affnpkm~nn     1  - Ml~i fA.n.fl Tnkla Q.,5 MhiAn~r Q~fan     fr&#xfd;  nki.4; Aa  aaemtan+   MakAI          OatfianAl Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                      NEI 00-01 Guidance 3.1.1.3 Criteria/Assumptions       [PWR] Generic Letter 86-10, Enclosure 2, Section 5.3.5 specifies that hot shutdown can be maintained without the use of pressurizer heaters (i.e.,
pressure control is provided by controlling the makeup/charging pumps). Hot shutdown conditions can be maintained via natural circulation of the Reactor Coolant System (RCS) through the steam generators. The cooldown rate must be controlled to prevent the formation of a bubble inthe reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled.
Aoolicability                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis RCS pressure control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model includes pressurizer heater capability for RCS pressure control for defense-in-depth (DID). The vital pressurizer heater groups are analyzed to remain available from the Main Control Room (MCR) (or locally) for RCS pressure control. The non-vital pressurizer heater groups are only analyzed for loss of MCR trip capability.
The DCPP NSCA model also allows for RCS pressure control to be achieved utilizing the Chemical and Volume Control System (CVCS) to add RCS inventory (and increase RCS pressure) and the Auxiliary Feedwater (AFW) System (to remove decay heat, and decrease RCS pressure).
RCS inventory is supplied with the CVCS utilizing one of three centrifugal charging pumps, with pump suction taken from the borated Refueling Water Storage Tank (RWST) or Boric Acid Storage Tanks (BASTs), and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths.
The noncredited charging pump(s) are analyzed for loss of MCR trip capability.
Feedwater for decay heat removal is supplied from either the Turbine Driven Auxiliary Feedwater (TDAFW) Pump (supplies steam generators (SGs) 1-2 (2-2) and 1-3 (2-3)) or the two Motor Driven Auxiliary Feedwater Pumps (MDAFW). AFW-1(2)-AFWP1-RUN supplies SGs 1-1 (2-1) and 1-2 (2-2), AFW-1(2)-AFWP2-RUN supplies SGs 1-3 (2-3) and 1-4 (2-4). 10 percent atmospheric steam dump valves (ASDVs) are modeled to be operable as required for the credited SG (1 of 4). The noncredited AFW pump(s) are analyzed for loss of MCR trip capability.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Section 10.0 Page B-10

Pacific Gas and Electric Comnanv                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Capabilitv Assessment Methodoloqv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                      NEI 00-01 Guidance 3.1.1.4 Criteria/Assumptions       The classification of shutdown capability as alternative/dedicated shutdown is made independent of the selection of systems used for shutdown.
Alternative/dedicated shutdown capability is determined based on an inability to assure the availability of a redundant safe shutdown path.
Compliance to the separation requirements of Sections Ill.G.1 and II.G.2 may be supplemented by the use of operator manual actions to the extent allowed by the regulations and the licensing basis of the plant (see Appendix E), repairs (cold shutdown only), exemptions, deviations, GL 86-10 fire hazards analyses or fire protection design change evaluations permitted by GL 86-10, as appropriate. These may also be used in conjunction with alternative/dedicated shutdown capability. A discussion of time zero for the fire condition, as it relates to operator manual actions and repairs, is contained in Appendix E.
Applicability                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis Unlike 10 CFR 50, Appendix R, NFPA 805 makes no distinction for alternative / dedicated shutdown.
The Hot Shutdown Panel (HSDP) is the primary control station for implementation of the 10 CFR 50, Appendix R, Alternate Shutdown Strategy in the event of a fire that requires the evacuation of the MCR.
Based on the definition provided in RG 1.205, and the additional guidance provided in FAQ 07-0030 Revision 5 (ML110070485), the HSDP is also considered to be the Primary Control Station (PCS) for NFPA 805.
Enabling of the HSDP involves the transfer of control from the MCR to HSDP through an operator action to manually position isolation transfer switches, which are located on the HSDP and locally at the 4kV and 480V switchgears. Following activation of the HSDP, the plant operator is provided with the capability to control and monitor secondary side decay heat removal capability utilizing the AFW System, the capability to control RCS pressure, and the capability to monitor critical RCS process parameters, which are necessary to verify that natural circulation has been established in the RCS and that it is being successfully maintained thereafter.
The HSDP has been transitioned to NFPA 805 as the PCS for meeting the NSPC in the event of a fire that requires evacuation of the MCR.
Comments None Reference Documents                                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                             Section 3.0 Report R2165-042-001, Recovery Action Feasibility Assessment Report, Revision 0, June 2013                                    Section 7.1.1 Page B-1l1

rl~~~~~~~    -. I: ,   t,*'.
q^         n  n                            Aff&#xfd;&#xfd;hmnn4 Q - kIg:I flA-fl'  Tnhla Q-     MmmpIldar nftohi e    n~kilidh  Aceneamnnt   Mfnfhf~rlvfI%1^    pniE.ag r-allill{,,;         . lur anJd       %".t.                                     IIUGas'lS                                            i. Iy       F   t   V f/l COi OO*  1Y     .. ,111t11        v Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                          NEI 00-01 Guidance 3.1.1.5 Criteria/Assumptions           At the onset of the postulated fire, all safe shutdown systems (including applicable redundant trains) are assumed operable and available for post-fire safe shutdown. Systems are assumed to be operational with no repairs, maintenance, testing, Limiting Conditions for Operation (LCO), etc. in progress. The units are assumed to be operating at full power under normal conditions and normal lineups.
Applicability                          Comments Applicable                             None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria/
assumption listed in Section 3.1.1.5 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
Comments None Reference Documents                                                                                                              Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                Sections 3.0 and 10.0 Page B-12

SG                                                                              0 Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.1.6 Criteria/Assumptions    No Final Safety Analysis Report accidents or other design basis events (e.g. loss of coolant accident (LOCA), earthquake), single failures or non-fire-induced transients need be considered in conjunction with the fire.
Applicabiity                    Comments Applicable                      None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.1.1.6 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        Sections 3.0 and 10.0 Page B-13

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B'- NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.1.7 Criteria/Assumptions    For the case of redundant shutdown, offsite power may be credited if demonstrated to be free of fire damage. Offsite power should be assumed to remain available for those cases where its availability may adversely impact safety (i.e., reliance cannot be placed on fire causing a loss of offsite power if the consequences of offsite power availability are more severe than its presumed loss). No credit should be taken for a fire causing a loss of offsite power. For areas where train separation cannot be achieved and alternative shutdown capability is necessary, shutdown must be demonstrated both where offsite power is available and where offsite power is not available for 72 hours.
Applicability                   Comments Applicable                      None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria I assumption listed in Section 3.1.1.7 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
Report R2165-004-001, Sections 10.5.5 (Performance Goal and System Logics: Vital Auxiliaries - Unit 1) and 10.5.10 (Performance Goal and System Logics: Vital Auxiliaries -
Unit 2), describe how the NSCA models offsite power, as well as onsite power from the emergency diesel generators (EDGs). As part of the NSCA model (through equipment-to-equipment logic success path in the NSCA database tool), offsite power is only credited in fire areas where it can be demonstrated to be free of fire damage.
Comments None Reference Documents                                                                                                        Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Sections 3.0 and 10.0 (Subsections 10.5.5 and 10.5.10)
Page B-14

SG                                                                             0 Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.1.8 Criteria/Assumptions    Post-fire safe shutdown systems and components are not required to be safety-related.
Aoolicabilitv                   Comments Applicable                      None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.1.1.8 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model includes nonsafety-related plant systems / functions / components. For example, nonsafety-related offsite power capability is included in the NSCA model as described in Report R2165-004-001, Sections 10.5.5 (Performance Goal and System Logics: Vital Auxiliaries - Unit 1) and 10.5.10 (Performance Goal and System Logics:
Vital Auxiliaries - Unit 2).
Comments None Reference Documents                                                                                                     Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                       Sections 3.0 and 10.0 (Subsections 10.5.5 and 10.5.10)
Page B-15

0 Pacific Gas and Electric Company 9
Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.1.9 Criteria/Assumptions      The post-fire safe shutdown analysis assumes a 72-hour coping period starting with a reactor scram/trip. Fire-induced impacts that provide no adverse consequences to hot shutdown within this 72-hour period need not be included in the post-fire safe shutdown analysis. At least one train can be repaired or made operable within 72 hours using onsite capability to achieve cold shutdown.
Applicability                     Comments Applicable                        None Alignment Statement Aligns with Intent Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria/
assumption listed in Section 3.1.1.9 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
From Section 3.0 of Report R2165-004-001:
The NFPA 805 NSPC requires the licensee to demonstrate that the plant can achieve and maintain a "safe and stable" condition, but it does not explicitly require the licensee to demonstrate that cold shutdown can be achieved within 72 hours and maintained indefinitely thereafter. The DCPP NFPA 805 NSPC analysis has defined the "safe and stable" condition as being able to achieve and maintain Hot Standby until such time as the plant can either transition to Cold Shutdown, or can safely return to power operation.
"Safe and stable" for DCPP is defined in Section 8.6, Definition of "Safe and Stable" Plant Conditions for DCPP, of Report R2165-004-001.
From Section 8.6 of Report R2165-004-001:
The objective of the NFPA 805 NSCA as documented in [Report R2165-004-001] is to demonstrate that DCPP can achieve and maintain Hot Standby conditions following a significant and challenging fire event using either deterministic or performance based methods of NFPA 805. The NSCA, including supporting calculations, documents this assessment of fire impact on DCPP plant systems and features required to achieve and maintain Hot Standby from at power conditions. The NSCA replaces the post-fire safe shutdown compliance assessment for each area that was previously assessed to determine compliance with 10 CFR 50, Appendix R, Section III.G.
From Section 10.0 of Report R2165-004-001:
The transition from Hot Standby to Cold Shutdown and plant operation in Cold Shutdown is not required to demonstrate that the NSPC "safe and stable" plant conditions defined for DCPP have been met. OMAs [operator manual actions] and/or repair activities associated with these capabilities are not identified as Variances from Deterministic Requirements (VFDRs) of NFPA 805, and are not implemented into the plant operations fire response procedures.
From Section 13.2.1 of Report R2165-004-001:
The capability to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown has been analyzed in the DCPP NSCA. OMAs and repair activities necessary to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown have been identified in [Report R2165-004-001], and have been qualitatively assessed to ensure their Page B-16

0                                                                                 0 0 0% 1.f.%t,,If%-00a "11..
A Cl     f ;
U.Ott I. %,
f, WJ,,UNN,                 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection feasibility in consideration of the "safe and stable" conditions for the plant; however, these operator actions and repair activities are not required to demonstrate that the NSPC "safe and stable" plant conditions defined for the DCPP have been met, are not identified as VFDRs, and are not implemented into the plant operations fire response procedures).
The 72-hour requirement from NEI 00-01 is only applicable to the 10 CFR 50, Appendix R, licensing basis. The DCPP NSCA model does include plant systems /functions /
components required for the transition from Hot Standby to Cold Shutdown, and the achievement and maintenance of Cold Shutdown. However, these plant systems / functions /
components are not required for the NSCA, and are not credited in the plant operations fire response procedures.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0, 8.0 (Subsection 8.6), 10.0, and 13.0 (Subsection 13.2.1)
Page B-17

0     1.r. t1_     A C1    * ;  f^&#xfd;      &#xfd;n                           Aft2rhment B - NEI 04-02 Table B-2 N"r-lapr qnfatl ro              2hilifu Accoacmant Rfinfh^rJr%1r%       PalligWU Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                       NEI 00-01 Guidance 3.1.1.10                            Manual initiation from the main control room or emergency control stations of systems required to achieve and maintain safe shutdown is Criteria/Assumptions                acceptable where permitted by current regulations or approved by NRC (See Appendix E); automatic initiation of systems selected for safe shutdown is not required but may be included as an option, if the additional cables and equipment are also included in the analysis. Spurious actuation of automatic systems (Safety Injection (SI), Auxiliary Feedwater, High Pressure Coolant Injection, Reactor Core Isolation Cooling, etc.)
due to fire damage, however, should be evaluated.
Aoolicability                       Comments Applicable                          None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.1.1.10 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
From Section 3.0 of Report R2165-004-001:
The DCPP NSCA credits Main Control Room operator action to align NSCA systems / functions / components. The DCPP NSCA does not credit automatic initiation of NSCA systems / functions / components unless specifically modeled and analyzed.
The effects of fires on the Reactor Protection System (RPS), Reactor Trip Breakers, Reactor Trip Bypass Breakers, and Control Rod Drive Mechanisms (CRDMs) are not considered to preclude the initiation of an automatic or manual reactor trip and control rod insertion due to the RPS fail-safe design. The RPS channels are designed to fail in the trip condition on loss of power. The reactor trip breakers and reactor trip bypass breakers are designed to trip on loss of DC control power. Similarly, the control rod drive clutch mechanisms are designed to release the control rods on loss of power. This is based on GL 86-10, Enclosure 2, Section 3.8.4.
Section 10.8 of Report R2165-004-001 provides a discussion for the treatment of a valid and/or spurious actuation of the Engineered Safety Features Actuation System (ESFAS) in the DCPP Plant NSCA.
Circuits that may result in spurious actuation of automatic systems are evaluated in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T).
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0 and 10.0 (Subsection 10.8)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                         Section 5.0 Circuit Analysis Page B-18

PG                                                                                 0 Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.1.11                        Where a single fire can impact more than one unit of a multi-unit plant, the ability to achieve and maintain safe shutdown for each affected unit must Criteria/Assumptions            be demonstrated.
Applicability                   Comments Applicable                      None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.1.1.11 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0 and 10.0 Page B-19

Pacific Gas and Electric Company                                Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.1.2 Shutdown Functions       The following discussion on each of these shutdown functions provides guidance for selecting the systems and equipment required for hot shutdown. For additional information on BWR system selection, refer to GE Report GE-NE-T43-00002-00-01-RO0 entitled "Original Safe Shutdown Paths for the BWR."
Aonlicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                   Document Details Not Applicable                                                                                                        Not Applicable Page B-20

Pacific Gas and Electric Company                                 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                 NEI 00-01 Guidance 3.1.2.1 Reactivity Control    [BWR] Control Rod Drive System The safe shutdown performance and design requirements for the reactivity control function can be met without automatic scram/trip capability.
Manual scram/reactor trip is credited. The post-fire safe shutdown analysis must only provide the capability to manually scram/trip the reactor.
Each licensee should have an operator manual action to either vent the instrument air header or to remove RPS power in their post-fire safe shutdown procedures. The presence of this action precludes the need to perform circuit analysis for the reactivity control function and is an acceptable way to accomplish this function. If this action is a "time critical" action, the timing must be justified.
Aoolicabilitv                 Comments Not Applicable                DCPP is a PWR; BWR guidance is not applicable.
Alignment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                          Document Details Not Applicable                                                                                                               Not Applicable Page B-21

0                                                                                  0                                                                               0 Pacific Gas and Electric Company                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.2.1 Reactivity Control        [PWR] Makeup/Charging There must be a method for ensuring that adequate shutdown margin is maintained from initial reactor scram to cold shutdown conditions, by controlling Reactor Coolant System temperature and ensuring borated water is utilized for RCS makeup/charging.
Applicability                     Comments Applicable                        None Alignment Statement Aligns Alicinment Basis Reactivity control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires short term reactivity control to be provided through automatic or manual reactor trip and the subsequent insertion of the control rods.
The effects of fires on the RPS, Reactor Trip Breakers, Reactor Trip Bypass Breakers, and CRDMs are not considered to preclude the initiation of an automatic or manual reactor trip and control rod insertion due to the RPS fail-safe design. The RPS channels are designed to fail inthe trip condition on loss of power. The reactor trip breakers and reactor trip bypass breakers are designed to trip on loss of DC control power. Similarly, the control rod drive clutch mechanisms are designed to release the control rods on loss of power.
This is based on GL 86-10, Enclosure 2, Section 3.8.4.
The DCPP NSCA model requires long term reactivity control to be provided utilizing the CVCS to add borated RCS inventory.
Borated RCS inventory is supplied with the CVCS utilizing one of three centrifugal charging pumps (CCPs), with pump suction taken from the borated RWST or BASTs, and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths.
The credited source of borated water is the RWST or the BASTs, and the Volume Control Tank (VCT) is isolated to prevent dilution of borated water and inadvertent reduction of the shutdown margin.
Comments None Reference Documents                                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                             Section 10.0 Page B-22

0 Pacific Gas and Electric Company                                 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref               NEI 00-01 Guidance 3.1.2.2 Pressure Control    The systems discussed in this section are examples of systems that can be used for pressure control. This does not restrict the use of other Systems                     systems for this purpose.
[BWR] Safety Relief Valves (SRVs)
Initial pressure control may be provided by the SRVs mechanically cycling at their setpoints (electrically cycling for Electro-Mechanical Relief Valves (EMRVs)). Mechanically-actuated SRVs require no electrical analysis to perform their overpressure protection function. The SRVs may also be opened to maintain hot shutdown conditions or to depressurize the vessel to allow injection using low pressure systems. These are operated manually. Automatic initiation of the Automatic Depressurization System (ADS) is not a required function. Automatic initiation of the ADS may be credited, if available. If automatic ADS is not available and use of ADS is desired, an alternative means of initiation of ADS separate from the automatic initiation logic for accomplishing the pressure control function should be provided.
Applicability               Comments Not Applicable              DCPP is a PWR; BWR guidance is not applicable.
Alignment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                    Document Details Not Applicable                                                                                                         Not Applicable Page B-23

Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.2.2 Pressure Control        [PWR] Makeup/Charging Systems RCS pressure is controlled by controlling the rate of charging/makeup to the RCS. Although utilization of the pressurizer heaters and/or auxiliary spray reduces operator burden, neither component is required to provide adequate pressure control. Pressure reductions are made by allowing the RCS to cool/shrink, thus reducing pressurizer level/pressure. Pressure increases are made by initiating charging/makeup to maintain pressurizer level/pressure. Manual control of the related pumps is acceptable.
Aeolicabililt                   Comments Applicable                      None Alignment Statement Aligns Alignment Basis RCS pressure control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model includes pressurizer heater capability for RCS pressure control for DID. The vital pressurizer heater groups are analyzed to remain available from the MCR (or locally) for RCS pressure control. The non-vital pressurizer heater groups are only analyzed for loss of MCR trip capability.
The DCPP NSCA model also allows for RCS pressure control to be achieved utilizing the CVCS to add RCS inventory (and increase RCS pressure) and the AFW System (to remove decay heat, and decrease RCS pressure).
Addition of RCS inventory is accomplished with the CVCS utilizing one of three CCPs, with pump suction taken from the borated RWST or BASTs, and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths. The noncredited charging pump(s) are analyzed for loss of MCR trip capability.
Feedwater for decay heat removal is supplied from either the TDAFW Pump (supplies SGs 1-2 (2-2) and 1-3 (2-3)) or the two MDAFW. AFW-1(2)-AFWP1-RUN supplies SGs 1-1 (2-1) and 1-2 (2-2), AFW-1(2)-AFWP2-RUN supplies SGs 1-3 (2-3) and 1-4 (2-4). 10 percent ASDVs are modeled to be operable as required for the credited SG (1 of 4). The noncredited AFW pump(s) are analyzed for loss of MCR trip capability.
Comments None Reference Documents                                                                                                        Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Section 10.0 Page B-24

0 Pacific Gas and Electric Company                               Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqy Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                NEI 00-01 Guidance 3.1.2.3 Inventory Control    [BWR]: Systems selected for the inventory control function should be capable of supplying sufficient reactor coolant to achieve and maintain hot shutdown. Manual initiation of these systems is acceptable. Automatic initiation functions are not required. Spurious actuation of automatic systems, however, should be evaluated (High Pressure Coolant Injection, High Pressure Core Spray, Reactor Core Isolation Cooling, etc.).
Apolicabilitv                Comments Not Applicable               DCPP is a PWR; BWR guidance is not applicable.
Alianment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                   Document Details Not Applicable                                                                                                        Not Applicable Page B-25

0 I--       ,
A '           ,*     **n                             Affphm~nn 0     - Ki=1 fAAft") Tnkhei C1. Mu,,-Ir Qnf      fn    nhii4~ Acea&#xfd;c-cn+tn  Rf-h-41           Oafi rdtI    ct     n~ a"~    Wc,tu %t, flJ,.I~a V                                     naa'         a                             .Lt                 Mm**y F~                       .~..~ts     ,YU Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                         NEI 00-01 Guidance 3.1.2.3 Inventory Control             [PWR]: Systems selected for the inventory control function should be capable of maintaining level to achieve and maintain hot shutdown. Typically, the same components providing inventory control are capable of providing pressure control. Manual initiation of these systems is acceptable.
Automatic initiation functions are not required. Spurious actuation of automatic systems, however, should be evaluated (Safety Injection, High Pressure Injection, Auxiliary Feedwater, Emergency Feedwater, etc.).
Applicabilitv                         Comments Applicable                            None Alianment Statement Aligns Alignment Basis RCS inventory control capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires the CVCS to be utilized for RCS inventory control.
Addition of RCS inventory is accomplished with the CVCS utilizing one of three CCPs, with pump suction taken from the borated RWST or BASTs, and pump discharge injected into the RCS through the normal charging, alternate charging, RCP seal injection, or charging injection flowpaths. The noncredited charging pump(s) are analyzed for loss of MCR trip capability.
Section 10.8 of Report R2165-004-001 provides a discussion for the treatment of a valid and/or spurious actuation of the ESFAS in the DCPP Plant NSCA.
Comments None Reference Documents                                                                                                            Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                              Section 10.0 (Subsection 10.8)
Page B-26

Pacific Gas and Electric Company                                Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref               NEI 00-01 Guidance 3.1.2.4 Decay Heat Removal  [BWRj Systems selected for the decay heat removal function(s) should be capable of:
                            - Removing sufficient decay heat from primary containment, to prevent containment over-pressurization and failure.
                            - Satisfying the net positive suction head requirements of any safe shutdown systems taking suction from the containment (suppression pool).
                            - Removing sufficient decay heat from the reactor to achieve cold shutdown. (This is not a hot shutdown requirement.)
This does not restrict the use of other systems.
Applicability               Comments Not Applicable              DCPP is a PWR; BWR guidance is not applicable.
Alignment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                  Document Details Not Applicable                                                                                                       Not Applicable Page B-27

0Ga Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.2.4 Decay Heat Removal        [PWR] Systems selected for the decay heat removal function(s) should be capable of:
                                  - Removing sufficient decay heat from the reactor to reach hot shutdown conditions. Typically, this entails utilizing natural circulation inlieu of forced circulation via the reactor coolant pumps and controlling steam release via the Atmospheric Dump valves.
                                  - Removing sufficient decay heat from the reactor to reach cold shutdown conditions. (This is not a hot shutdown requirement.)
This does not restrict the use of other systems.
Anplicability                     Comments Applicable                        None Alignment Statement Aligns Alianment Basis RCS decay heat removal capabilities required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires the AFW System to be utilized for RCS decay heat removal.
Decay heat removal is achieved by initially tripping the Reactor Coolant Pumps (RCPs) and establishing natural circulation through at least 1 of the 4 SGs. The SG 10 percent ASDVs are credited to release steam.
"Safe and stable" for DCPP is defined in Section 8.6, Definition of "Safe and Stable" Plant Conditions for DCPP, of Report R2165-004-001.
From Section 8.6 of Report R2165-004-001:
The objective of the NFPA 805 NSCA as documented in [Report R2165-004-001] is to demonstrate that DCPP can achieve and maintain Hot Standby conditions following a significant and challenging fire event using either deterministic or performance based methods of NFPA 805. The NSCA, including supporting calculations, documents this assessment of fire impact on DCPP plant systems and features required to achieve and maintain Hot Standby from at power conditions. The NSCA replaces the post-fire safe shutdown compliance assessment for each area that was previously assessed to determine compliance with 10 CFR 50, Appendix R, Section Mll.G.
From Section 10.0 of Report R2165-004-001:
The transition from Hot Standby to Cold Shutdown and plant operation in Cold Shutdown is not required to demonstrate that the NSPC "safe and stable" plant conditions defined for DCPP have been met. OMAs and/or repair activities associated with these capabilities are not identified as VFDRs, and are not implemented into the plant operations fire response procedures.
From Section 13.2.1 of Report R2165-004-001:
Page B-28

Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Pacific Gas and Electric Comoanv                                           aE                        Tl Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection The capability to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown has been analyzed in the DCPP NSCA. OMAs and repair activities necessary to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown have been identified in [Report R2165-004-001], and have been qualitatively assessed to ensure their feasibility in consideration of the "safe and stable" conditions for the plant; however, these operator actions and repair activities are not required to demonstrate that the NSPC "safe and stable" plant conditions defined for the DCPP have been met, are not identified as VFDRs, and are not implemented into the plant operations fire response procedures).
The 72-hour requirement from NEI 00-01 is only applicable to the 10 CFR 50, Appendix R, licensing basis. The DCPP NSCA model does include plant systems / functions /
components required for the transition from Hot Standby to Cold Shutdown, and the achievement and maintenance of Cold Shutdown. However, these plant systems / functions /
components are not required for the NSCA, and are not credited in the plant operations fire response procedures.
Comments None Reference Documents                                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 8.0 (Subsection 8.6), 10.0, and 13.0 (Subsection 13.2.1)
Page B-29

Pacific Gas and Electric Comoanv                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capabilily Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                 NEI 00-01 Guidance 3.1.2.5 Process Monitoring    The process monitoring function is provided for all safe shutdown paths. Information Notice (IN) 84-09, Attachment 1, Section IX "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50 Appendix R)" provides guidance on the instrumentation acceptable to and preferred by the NRC for meeting the process monitoring function. This instrumentation is that which monitors the process variables necessary to perform and control the functions specified in Appendix R Section III.L.1. Such instrumentation must be demonstrated to remain unaffected by the fire. The IN 84-09 list of process monitoring is applied to alternative/dedicated shutdown (III.G.3). The use of this same list for III.G.2 redundant Post-Fire Safe Shutdown is acceptable, but the analyst needs to review the specific license basis for the plant under evaluation. In general, process monitoring instruments similar to those listed below are needed to successfully use existing operating procedures (including Abnormal Operating Procedures).
BWR:
                              - Reactor coolant level and pressure
                              - Suppression pool level and temperature
                              - Emergency or isolation condenser level
                              - Diagnostic instrumentation for safe shutdown systems
                              - Level indication for tanks needed for safe shutdown The specific instruments required may be based on operator preference, safe shutdown procedural guidance strategy (symptomatic vs.
prescriptive), and systems and paths selected for safe shutdown.
ApplicabilitY                 Comments Not Applicable                DCPP is a PWR; BWR guidance is not applicable.
Alionment Statement Not Applicable Alignment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                                       Document Details Not Applicable                                                                                                            Not Applicable Page B-30

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodolog y Re view                       i Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.2.5 Process Monitoring        The process monitoring function is provided for all safe shutdown paths. IN 84-09, Attachment 1, Section IX "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10 CFR 50 Appendix R)" provides guidance on the instrumentation acceptable to and preferred by the NRC for meeting the process monitoring function. This instrumentation is that which monitors the process variables necessary to perform and control the functions specified in Appendix R Section Ill.L1. Such instrumentation must be demonstrated to remain unaffected by the fire. The IN 84-09 list of process monitoring is applied to alternative/dedicated shutdown (III.G.3). The use of this same list for Ill.G.2 redundant Post-Fire Safe Shutdown is acceptable, but the analyst needs to review the specific license basis for the plant under evaluation. In general, process monitoring instruments similar to those listed below are needed to successfully use existing operating procedures (including Abnormal Operating Procedures).
PWR:
                                  - Reactor coolant temperature (hot leg / cold leg)
                                  - Pressurizer pressure and level
                                  - Neutron flux monitoring (source range)
                                  - Level indication for tanks needed for safe shutdown
                                  - Steam generator level and pressure
                                  - Diagnostic instrumentation for safe shutdown systems The specific instruments required may be based on operator preference, safe shutdown procedural guidance strategy (symptomatic vs.
prescriptive), and systems and paths selected for safe shutdown.
Aanlicabilitv Applicable                        None Alignment Statement Aligns Alignment Basis Process monitoring instrumentation required to achieve and maintain a "safe and stable" plant condition post-fire is identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires the following instrumentation to be utilized for process monitoring. This instrumentation is consistent with minimum process monitoring instrumentation expectations identified in USNRC IN 84-09, and as previously approved by the USNRC in the 10 CFR 50, Appendix R, licensing basis for DCPP.
* Reactor coolant temperature (T-hot / T-cold): These instruments are modeled in support of the Decay Heat Removal Performance Goal.
* Pressurizer pressure and level: These instruments are modeled in support of the Inventory and Pressure Control Performance Goal.
* Neutron flux monitoring (source range): These instruments are modeled in support of the Reactivity Control Performance Goal.
* Level indication for various tanks: These instruments are included in the system logics for which the tank is required.
Page B-31

0                                                                            0                                                          0 Pacific Gas and Electric Company                              Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection
- SG level and pressure: These instruments are modeled in support of the Decay Heat Removal Performance Goal.
Comments None Reference Documents                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                             Section 10.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition          Section 5.0 Circuit Analysis Page B-32

Pacific Gas and Electric Comnanv                               Attachment B - NEI 04-02 Table B-2 Nuclear Safety Canabilitv Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                 NEI 00-01 Guidance 3.1.2.6 Support Systems       [Blank Heading - No specific guidance]
Applicabilitv                 Comments Applicable                    None Alignment Statement Not Required Alignment Basis Blank heading. Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                        Document Details Not Applicable                                                                                             Not Applicable Page B-33

0                                                                                     0 Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.1.2.6.1 Electrical Systems      AC Distribution System Power for the Appendix R safe shutdown equipment is typically provided by a medium voltage system such as 4.16KV Class 1E busses either directly from the busses or through step down transformers/load centers/distribution panels for 600, 480 or 120 VAC loads. For redundant safe shutdown performed in accordance with the requirements of Appendix R Section III.G.1 and 2, power may be supplied from either offsite power sources or the emergency diesel generator depending on which has been demonstrated to be free of fire damage. No credit should be taken for any beneficial effects of a fire causing a loss of offsite power. Refer to Section 3.1.1.7.
DC Distribution System Typically, the 125VDC distribution system supplies DC control power to various 125VDC control panels including switchgear breaker controls. The 125VDC distribution panels may also supply power to the 120VAC distribution panels via static inverters. These distribution panels may supply power for instrumentation necessary to complete the process monitoring functions.
For fire events that result in an interruption of power to the AC electrical bus, the station batteries are necessary to supply any required control power during the interim time period required for the diesel generators to become operational. Once the diesels are operational, the 125VDC distribution system can be powered from sources feed from the diesels through the battery chargers.
[BWR] Certain plants are also designed with a 250VDC Distribution System that supplies power to Reactor Core Isolation Cooling and/or High Pressure Coolant Injection equipment.
The DC control centers may also supply power to various small horsepower Appendix R safe shutdown system valves and pumps. If the DC system is relied upon to support safe shutdown without battery chargers being available, it must be verified that sufficient battery capacity exists to support the necessary loads for sufficient time (either until power is restored, or the loads are no longer required to operate).
APlicabilitY                      Comments Applicable                        None Alianment Statement Aligns Alignment Basis Electrical distribution systems required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Sections 10.5.5 (Performance Goal and System Logics: Vital Auxiliaries - Unit 1) and 10.5.10 (Performance Goal and System Logics: Vital Auxiliaries - Unit 2).
The DCPP NSCA model includes diverse Class 1E and non-Class 1E electrical distribution system capabilities to provide the vital support function of electrical power for the mechanical systems / functions / components of the NSCA model.
AC power may be supplied by offsite power through the switchyard, or AC power may be supplied by onsite power from the emergency diesel generators.
The AC power supplies provide power to 4kV buses, which inturn supply 480VAC buses. The 480VAC buses are the normal supply for 120VAC buses.
Page B-34

SG                                                                               0 Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Battery backed 125VDC supplies power to 120VAC distribution panels via inverters and static transfer switches. The static transfer switches are used as a backup to automatically supply 120VAC from a 480VAC source through a constant voltage transformer.
Electrical power circuits required to achieve and maintain a "safe and stable" plant condition are evaluated in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T).
Comments None Reference Documents                                                                                                        Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Section 10.0 (Subsections 10.5.5 and 10.5.10)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                       Section 5.0 Circuit Analysis Page B-35

P                                                                                04 Pacific Gas and Electric Company                                Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B        - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.1.2.6.2 Cooling Systems      Various cooling water systems are required to support safe shutdown system operation, based on plant specific considerations. Typical uses include:
                               - Residual Heat Removal (RHR)/Shutdown Cooling (SDC)/Decay Heat (DH) Heat Exchanger cooling water
                               - Safe shutdown pump cooling (seal coolers, oil coolers)
                               - Diesel generator cooling Aoniocabilitv                  Comments Applicable                     None Alignment Statement Aligns Alignment Basis Cooling water systems required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires the Component Cooling Water system (CCW) and the Auxiliary Salt Water (ASW) system to provide the vital support function of cooling water for the other mechanical systems / functions / components of the NSCA model.
The CCW system is cooled by the ASW system. There are three CCW trains; the CCW system is credited to provide cooling water to the following:
* RHR Heat Exchangers
* RHR Pump Seal Coolers
* CCP Pump Oil Cooler
* Seal Return Heat Exchanger
* RCP Thermal Barrier Heat Exchanger The two ASW trains are credited to cool the following:
- CCW Heat Exchangers Comments None Reference Documents                                                                                                       Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                         Section 10.0 Page B-36

         *0 Pacific Gas and Electric Company 0
Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                NEI 00-01 Guidance 3.1.2.6.3 HVAC Systems       Heating, Ventilation and Air Conditioning (HVAC) Systems may be required to assure that safe shutdown equipment remains within its operating temperature range, as specified in manufacturer's literature or demonstrated by suitable test methods, and to assure protection for plant operations staff from the effects of fire (smoke, heat, toxic gases, and gaseous fire suppression agents).
HVAC systems, however, are not required to support post-fire safe shutdown in all cases. The need for HVAC system operation is based on plant specific configurations and plant specific heat loads. Typical potential uses include:
                             - Main control room, cable spreading room, relay room
                             - Emergency Core Cooling System (ECCS) pump compartments
                             - Diesel generator rooms
                             - Switchgear rooms Plant specific evaluations are necessary to determine which HVAC systems could be required or useful in supporting post-fire safe shutdown.
Transient temperature response analyses are often utilized to demonstrate that specific HVAC systems would or would not be required. If HVAC systems are credited, the potential for adverse fire effects to the HVAC system must also be considered, including:
                             - Dampers closing due to direct fire exposure or due to hot gases flowing through ventilation ducts from the fire area to an area not directly affected by the fire. Where provided, smoke dampers should consider similar effects from smoke.
                             - Recirculation or migration of toxic conditions (e.g., smoke from the fire, suppressants such as Carbon Dioxide).
In certain situations, adequate time exists to open doors to provide adequate cooling to allow continued equipment operation. Therefore, the list of required safe shutdown components as it relates to HVAC Systems may be determined based on transient temperature analysis. Should this analysis demonstrate that adequate time exists to open doors to provide the necessary cooling, this is an acceptable approach to achieving HVAC Cooling. The temperature analysis must demonstrate the adequacy of the cooling effect from opening the door within the specified time. Only those components whose operation is required to provide HVAC Cooling for required safe shutdown components in a time frame that cannot be justified for operator manual actions are considered themselves to be required safe shutdown components. This latter set of HVAC Cooling Components are required to meet the criteria for required safe shutdown components with regard to the available mitigating tools.
Applicability                Comments Applicable                   None Alignment Statement Aligns Alianment Basis HVAC systems required to achieve and maintain a "safe and stable" plant condition post-fire are identified in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection.
The DCPP NSCA model requires HVAC to provide the vital support function of air cooling for plant equipment operability (of other mechanical systems / functions / components in the NSCA model).
Page B-37

Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection HVAC systems are required for the following plant areas:
* ASW Pump Rooms
* 4kV Switchgear Rooms
* DC and 480V Switchgear Rooms In the event of fire induced failure of required HVAC systems, portable ventilation is utilized, as identified inAttachment 14 of Report R2165-004-001.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Section 10.0; Attachment 14 Page B-38

P0 Ga Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.1.3 Methodology for          Refer to Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe shutdown systems and developing the shutdown paths.
Shutdown System Selection The following methodology may be used to define the safe shutdown systems and paths for an Appendix R analysis:
Aoplicabilitv                  Comments Applicable                     None Alignment Statement Not Required Aliqnment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                              Not Applicable Page B.39

0                                                                              0                                                                               0 Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                    NEI 00-01 Guidance 3.1.3.1 Identify Safe            Review available documentation to obtain an understanding of the available plant systems and the functions required to achieve and maintain safe Shutdown Functions               shutdown. Documents such as the following may be reviewed:
                                 - Operating Procedures (Normal, Emergency, Abnormal)
                                 - System descriptions
                                 - Fire Hazard Analysis
                                 - Single-line electrical diagrams
                                 - Piping and Instrumentation Diagrams (P&IDs)
                                 - [BWR] GE Report GE-NE-T43-00002-00-01-R02 entitled "Original Shutdown Paths for the BWR" AoDlicabilitv                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Section 4.0, NSCA Design Inputs, of Report R2165-004-001 identifies the following types of documents and databases as sources of design input utilized for the development of the NSCA model:
* National Fire Protection Association Standard 805
* Nuclear Energy Institute NEI 00-01
* Nuclear Energy Institute NEI 04-02
* DCPP Technical Specifications
* DCPP Design Calculations
* DCPP Piping and Instrumentation Diagrams
* DCPP Instrument Schematic Diagrams
* DCPP Electrical One-line Diagrams (electrical drawings)
* DCPP Electrical Three-line Diagrams (electrical drawings)
* DCPP Electrical Schematic Diagrams (electrical drawings)
* DCPP Instrument Loop Diagrams (electrical drawings)
* DCPP Raceway Plan Drawings (electrical drawings)
* DCPP Exposed Conduit Drawings (electrical drawings)
* Plant Operating Procedures
* DCPP USNRC Safety Evaluation Reports and Supplements
* USNRC INs and GLs
* Plant Fire Zone Boundary Partitioning Drawings
* The SAFE database tool.*
*The SAFE cable and raceway database tool is populated with information from DCPP's FIREPROT (DCPP Drawing 065126, Unit 1 Electrical Fire Protection Information and 065127, Unit 2 Electrical Fire Protection Information) database.
Page B-40

Pacific Gas and Electric Company                                Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection The SAFE database tool is described in Section 12.0, Description of SAFE, of Report R2165-004-001.
The FIREPROT database is described in Section 17.0, Definitions, of Report R2165-004-001.
Comments None Reference Documents                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                           Sections 4.0, 12.0, and 17.0 Page B-41

0                                                                               0 Pacific Gas and Electric Companv                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.3.2 Identify                Given the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of achieving the safe shutdown Combinations of Systems         functions of reactivity control, pressure control, inventory control, decay heat removal, process monitoring and support systems such as electrical That Satisfy Each Safe          and cooling systems (refer to Section 3.1.2). This selection process does not restrict the use of other systems. In addition to achieving the Shutdown Function               required safe shutdown functions, consider other equipment whose mal-operation or spurious operation could impact the required safe shutdown function. The components in this latter set are classified as either required for hot shutdown or as important to SSD as explained in Appendix H.
Applicability                   Comments Applicable                      None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant systems that satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
From Section 10.0 of Report R2165-004-001:
The purpose of NSCA model development and component selection activity is to create an accurate plant model that represents the NSPC requirements from NFPA 805, Section 1.5.1. The NSCA model must identify and include plant systems/ functions / components that are required to actively function in order satisfy the NSPC requirements. The NSCA model also must identify include plant systems / functions / components that are not required to actively function, but whose mal-operation (i.e., spurious operation), alone or in combination, could be adverse to meeting the NSPC requirements. The plant model should, within constraints of complexity and cost, maximize the diversity and number of potential success paths that are available to satisfy the NSPC requirements.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Section 10.0 Page B-42

0 Pacific Gas and Electric Companv                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Caoabilitv Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                   NEI 00-01 Guidance 3.1.3.3 Define Combination      Select combinations of systems with the capability of performing all of the required safe shutdown functions and designate this set of systems as a of Systems for Each Safe        safe shutdown path. In many cases, paths may be defined on a divisional basis since the availability of electrical power and other support systems Shutdown Path                   must be demonstrated for each path. During the equipment selection phase, identify any additional support systems and list them for the appropriate path.
Applicability                   Comments Applicable                      None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to determine the combinations of plant systems that satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Report R2165-004-001, Section 10.0, also identifies the overall process utilized to logically relate individual systems in support of each performance goal. Success paths for each performance goal are specified (i.e., performance goal-to-system logic success paths in the NSCA database tool). Each success path represents the minimum system combinations required to achieve a specific performance goal.
Certain support systems / functions, such as electrical power and cooling water, are modeled to directly support specific components and systems rather than to directly support performance goals. These relationships are illustrated by equipment-to-equipment logic success paths in the DCPP NSCA model.
These relationships are maintained electronically in the NSCA database.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Section 10.0 Page B-43

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                                                                                                                                                         **    ~     *J*~t On.IffhAI Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                        NEI 00-01 Guidance 3.1.3.4 Assign Shutdown              Assign a path designation to each combination of systems. The path will serve to document the combination of systems relied upon for safe Paths to Each Combination            shutdown in each fire area. Refer to Attachment 1 to this document for an example of a table illustrating how to document the various combinations of Systems                           of systems for selected shutdown paths.
Applicability                        Comments Applicable                           None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to determine the combinations of plant systems that satisfy each of the NSPC fromSection 1.5.1 of NFPA 805.
Report R2165-004-001, Section 10.0, identifies that each performance goal may have multiple success paths representing a different combination of systems / functions (i.e.,
performance goal-to-system logic success paths in the NSCA database tool). Each combination of systems that represents a unique success path for a given performance goal is assigned a path number in the NSCA database tool. The path number is automatically assigned by the NSCA database tool.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Section 10.0 Page B-44

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                                                                                                                                                                                                       ,P l u Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                                   NEI 00-01 Guidance 3.2 Safe Shutdown                               The previous section described the methodology for selecting the systems and paths necessary to achieve and maintain safe shutdown for an Equipment Selection                             exposure fire event (see Section 5.0 DEFINITIONS for "Exposure Fire"). This section describes the criteria/assumptions and selection methodology for identifying the specific safe shutdown equipment necessary for the systems to perform their Appendix R functions. The selected equipment should be related back to the safe shutdown systems that they support and be assigned to the same safe shutdown path as that system. The list of safe shutdown equipment will then form the basis for identifying the cables necessary for the operation or that can cause the mal-operation of the safe shutdown systems. For each path it will be important to understand which components are classified as required safe shutdown components and which are classified as important to safe shutdown components. When evaluating the fire-induced impact to each affected cable/component in each fire area, this classification dictates the tools available for mitigation the affects.
Applicability                                   Comments Applicable                                      None Alignment Statement Not Required Alianment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                                          Document Details Not Applicable                                                                                                                               Not Applicable Page B-45

Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.2.1 Criteria/Assumptions     Consider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:
Aoolicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                   Document Details Not Applicable                                                                                                        Not Applicable Page B-46

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                                                                                                                                                           !JvX "oVoo      ll   t,*aSlt4!F  ?d I Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                                 NEI 00-01 Guidance 3.2.1.1 Criteria/Assumptions                  Safe shutdown equipment can be divided into two categories. Equipment may be categorized as (1) primary components or (2) secondary components. Typically, the following types of equipment are considered to be primary components:
                                              - Pumps, motor operated valves, solenoid valves, fans, gas bottles, dampers, unit coolers, etc.
                                              - All necessary process indicators and recorders (i.e., flow indicator, temperature indicator, turbine speed indicator, pressure indicator, level recorder)
                                              - Power supplies or other electrical components that support operation of primary components (i.e., diesel generators, switchgear, motor control centers, load centers, power supplies, distribution panels, etc.).
Secondary components are typically items found within the circuitry for a primary component. These provide a supporting role to the overall circuit function. Some secondary components may provide an isolation function or a signal to a primary component via either an interlock or input signal processor. Examples of secondary components include flow switches, pressure switches, temperature switches, level switches, temperature elements, speed elements, transmitters, converters, controllers, transducers, signal conditioners, hand switches, relays, fuses and various instrumentation devices.
Applicability                                 Comments Applicable                                    None Alignment Statement Aligns Aliqinment Basis Report R2165-004-001, Section 3.0, NSCA Criteria I Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria!
assumption listed in Section 3.2.1.1 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis (component selection is also performed during the circuit identification and analysis activity).
There is no explicit distinction made in the DCPP NSCA between primary and secondary equipment; however, a similar approach is maintained through the system-to-equipment logic success paths and the equipment-to-equipment logic success paths in the NSCA database tool.
- Mechanical and electrical system components such as pumps, air operated valves, motor operated valves, and solenoid operated valves, fans, heaters, electrically controlled circuit breakers, transformers, switchgear, motor control centers, batteries, battery chargers, inverters, distribution panels, automatic transfer switches, diesel generators and engines, strainers, instrumentation, and dampers, etc. which have an active function in achieving safe shutdown are included in the NSCA.
- Mechanical and electrical system components such as pumps, air operated valves, motor operated valves, and solenoid operated valves, fans, heaters, electrically controlled circuit breakers, instrumentation, and dampers, etc. that are not credited to operate (i.e., that have a passive function) are included in the NSCA if they maintain a system boundary or if the spurious operation(s) of the passive component(s) has an adverse impact on NSCA capabilities.
Page B-47

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                      .4 01   4  ;  f' 0%, 1 %1 %J FO"Y                         Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqy Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection
" Mechanical system passive components such as tanks, vessels, and heat exchangers which have no spurious failure mode are included in the NSCA for completeness.
"Control panels and discrete electrical and instrumentation components such as hand switches, relays, starters, fuses, indicating lights, molded case and other nonelectrically operated circuit breakers, electrical disconnects, pull boxes, junction boxes, terminal boxes, signal converters, amplifiers, bistables, relay cards, instrument power supplies, etc.
(excluding the transmitting devices and indicating devices) are not explicitly identified or included in the NFPA 805 NSPC Equipment List. These secondary components or sub-components are represented in the NSCA by virtue of the circuit conductors and cables that interconnect them to the primary component.
- Manual valves that are repositioned for credited NFPA 805 Recovery Actions are included in the NFPA 805 NSPC Equipment List.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0 and 10.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                         None Circuit Analysis Page B-48

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                    NEI 00-01 Guidance 3.2.1.2 Criteria/Assumptions     Assume that exposure fire damage to manual valves and piping does not adversely impact their ability to perform their pressure boundary or safe shutdown function (heat sensitive piping materials, including tubing with brazed or soldered joints, are not included in this assumption). Fire damage should be evaluated with respect to the ability to manually open or close the valve should this be necessary as a part of the post-fire safe shutdown scenario. For example, post-fire coefficients of friction for rising stem valves cannot be readily determined. Handwheel sizes and rim pulls are based on well lubricated stems. Any post-fire operation of a rising stem valve should be well justified using an engineering evaluation.
Avnlicability                    Comments Applicable                       None Alignment Statement Aligns Alionment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.2.1.2 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Section 13.0, Deterministic Fire Area Assessment and Results.
Consideration of the fluid boundary isolation provided by a normally closed manual valve is applicable to, and included in the development of the NSCA model and component selection, and the deterministic fire area assessment.
Consideration of the flowpath alignment provided by a normally open manual valve is applicable to, and included in the development of the NSCA model and component selection, and the deterministic fire area assessment.
- Manual valves that are repositioned for credited NFPA 805 Recovery Actions are included in the NFPA 805 NSPC Equipment List, and are subject to assessment of feasibility per Report R2165-042-001.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Sections 3.0, 10.0, and 13.0 Report R2165-042-001, Recovery Action Feasibility Assessment Report, Revision 0, June 2013                                  None Page B-49
: 0.                                                                                                                                                              .O Pacific Gas and Electric Company                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                    NEI 00-01 Guidance 3.2.1.3 Criteria/Assumptions     Assume that all components, including manual valves, are in their normal position as shown on P&IDs or in the plant operating procedures, that there are no LCOs ineffect, that the Unit is operating at 100% power and that no equipment has been taken out of service for maintenance.
APPlicabilitY                    Comments Applicable                       None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.2.1.3 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Section 13.0, Deterministic Fire Area Assessment and Results.
Consideration of the fluid boundary isolation provided by a normally closed manual valve is applicable to, and included in the development of the NSCA model and component selection, and the deterministic fire area assessment.
Consideration of the flowpath alignment provided by a normally open manual valve is applicable to, and included inthe development of the NSCA model and component selection, and the deterministic fire area assessment.
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        Sections 3.0, 10.0, and 13.0 Page B-50

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* 1. f,                                   Aff2rhmant R     - K11:1 flA.fl9 T2hla R-9~ MEbia-lr -q2faftI (~n    2hilith Acaaccmant Mgnthn,4en~n          Paia Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                      NEI 00-01 Guidance 3.2.1.4 Criteria/Assumptions       Assume that a check valve closes in the direction of potential flow diversion and seats properly with sufficient leak tightness to prevent flow diversion. Therefore, check valves do not adversely affect the flow rate capability of the safe shutdown systems being used for inventory control, decay heat removal, equipment cooling or other related safe shutdown functions.
Aoolicabilitv                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria/
assumption listed in Section 3.2.1.4 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Section 13.0, Deterministic Fire Area Assessment and Results.
Consideration of the fluid boundary isolation provided by a check valve is applicable to, and included in the development of the NSCA model and component selection, and the deterministic fire area assessment.
Comments None Reference Documents                                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                             Sections 3.0, 10.0, and 13.0 Page B-51

0                                                                                     0                                                                               0 Pacific Gas and Electric Company                                        Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                       NEI 00-01 Guidance 3.2.1.5 Criteria/Assumptions        Instruments (e.g., resistance temperature detectors, thermocouples, pressure transmitters, and flow transmitters) are assumed to fail upscale, midscale, or downscale as a result of fire damage, whichever is worse. An instrument performing a control function is assumed to provide an undesired signal to the control circuit.
Aoolicabilitv                       Comments Applicable                          None Alignment Statement Aligns with Intent Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. This criteria /
assumption listed in Section 3.2.1.5 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, Section 13.0, Deterministic Fire Area Assessment and Results, and Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis (component selection is also performed during the circuit identification and analysis activity).
Consideration of these instrumentation failure modes is applicable to, and included inthe development of the NSCA model and component selection, the circuit identification and analysis, and the deterministic fire area assessment.
Comments Note: Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) does not consider the following failure mode to be credible:
From Section 5.1.2.4 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T):
Fire-induced'insulation damage to shielded instrument cables on the output were not considered for hot shorts that could drive the instrument loop output high because:
: 1. The shielded instrument cable is far more likely to have an internal short shunting current from the end device causing it to fail low
: 2. A hot short, if it did penetrate the shield, would blow the output fuse of the rack and fail the output low
: 3. A hot short, to drive the output high, would have to be of the same polarity, from the same power source, and of the correct low signal strength (a smart short) that is considered highly unlikely to occur in a fire. See DCM T-19 Section 4.3.1.
: 4. These instrument cables are twisted and shielded and most probably will have an internal hot short. Once the shielded instrument cable has an internal hot short, the instrument loop output will be low with or without an external hot short. In summary, for instrument rack shielded output cables, hot shorts were considered but determined to disable the instrument loop failing the circuit low. Smart hot shorts that penetrate shielded cables driving output circuits high were not considered due to the reasons explained above. This is consistent with DCM T-1 9 Section 4.3.1.
Reference Documents                                                                                                         Document Details Page B-52

0                                                                            0                                                          9 Pacific Gas and Electric Company                              Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                         Sections 3.0, 10.0, and 13.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition      None Circuit Analysis Design Criteria Memorandum (DCM) T-19, "Electrical Separation and Isolation," Revision 11                 Section 4.0 (Subsection 4.3.1)
Page B-53

Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table 8-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                  NEI 00-01 Guidance 3.2.2 Methodology for          Refer to Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown equipment.
Equipment Selection Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:
Aonlicabilitv                  Comments Applicable                     None Alianment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                              Not Applicable Page B-54

0 Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.2.2.1 Identify the System       Mark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path. Refer to Attachment 2 for an Flow Path for Each                example of an annotated P&ID illustrating this concept. When developing the SSEL, determine which equipment should be included on the Safe Shutdown Path                     Shutdown Equipment List (SSEL). As an option, include secondary components with a primary component(s) that would be affected by fire damage to the secondary component. By doing this, the SSEL can be kept to a manageable size and the equipment included on the SSEL can be readily related to required post-fire safe shutdown systems and functions.
Applicability                     Comments Applicable                        None Alignment Statement Aligns with Intent Alianment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
A review of P&IDs, electrical drawings, instrument loop diagrams, etc. is performed to identify the NSCA systems, and to identify and develop the NSCA system-to-equipment logic relationships (i.e., Boolean logic / success paths) and the NSCA equipment-to-equipment logic success path relationships (i.e., success paths).
Comments None Reference Documents                                                                                                       Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                         Section 10.0 Page B-55

0 Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                      NEI 00-01 Guidance 3.2.2.2 Identify the               Review the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all equipment in each system's flow Equipment in Each Safe            path has been identified. Assure that any equipment that could spuriously operate and adversely affect the desired system function(s) is also Shutdown System Flow               identified. Additionally, refer to Section 4 for the Resolution Methodology for determining the Plant Specific List of MSOs requiring evaluation.
Path Including Equipment          Criteria for making the determination as to which of these components are to be classified as required for hot shutdown or as important to SSD is That May Spuriously               contained in Appendix H. If additional systems are identified which are necessary for the operation of the safe shutdown system under review, Operate and Affect System          include these as required for hot shutdown systems. Designate these new systems with the same safe shutdown path as the primary safe Operation                         shutdown system under review (Refer to Figure 3-1).
APPlicabilitY                     Comments Applicable                        None Alianment Statement Aligns Alianment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
A review of P&IDs, electrical drawings, instrument loop diagrams, etc. is performed to identify the NSCA systems, and to identify and develop the NSCA system-to-equipment logic relationships (i.e., Boolean logic / success paths) and the NSCA equipment-to-equipment logic success path relationships (i.e., success paths).
This is an iterative process.
* Mechanical and electrical system components such as pumps, air operated valves, motor operated valves, and solenoid operated valves, fans, heaters, electrically controlled circuit breakers, transformers, switchgear, motor control centers, batteries, battery chargers, inverters, distribution panels, automatic transfer switches, diesel generators and engines, strainers, instrumentation, and dampers, etc. which have an active function in achieving safe shutdown are included in the NSCA.
- Mechanical and electrical system components such as pumps, air operated valves, motor operated valves, and solenoid operated valves, fans, heaters, electrically controlled circuit breakers, instrumentation, and dampers, etc. that are not credited to operate (i.e., that have a passive function) are included in the NSCA if they maintain a system boundary or if the spurious operation(s) of the passive component(s) has an adverse impact on NSCA capabilities.
"Mechanical system passive components such as tanks, vessels, and heat exchangers which have no spurious failure mode are included in the NSCA for completeness.
"Control panels and discrete electrical and instrumentation components such as hand switches, relays, starters, fuses, indicating lights, molded case and other nonelectrically operated circuit breakers, electrical disconnects, pull boxes, junction boxes, terminal boxes, signal converters, amplifiers, bistables, relay cards, instrument power supplies, etc.
(excluding the transmitting devices and indicating devices) are not explicitly identified or included in the NFPA 805 NSPC Equipment List. These secondary components or sub-components are represented in the NSCA by virtue of the circuit conductors and cables that interconnect them to the primary component.
- Manual valves that are repositioned for credited NFPA 805 Recovery Actions are included in the NFPA 805 NSPC Equipment List.
Comments Page B-56

0                                                                          0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection None Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Section 10.0 Page B-57

S Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                    NEI 00-01 Guidance 3.2.2.3 Develop a List of        Prepare a table listing the equipment identified for each system and the shutdown path that it supports. Identify any valves or other equipment that Safe Shutdown Equipment          could spuriously operate and impact the operation of that safe shutdown system. Criteria for making the determination as to which of these and Assign the                   components are to be classified as required for hot shutdown or as important to SSD is contained in Appendix H. Assign the safe shutdown path corresponding System and         for the affected system to this equipment. During the cable selection phase, identify additional equipment required to support the safe shutdown Safe Shutdown Path(s)            function of the path (e.g., electrical distribution system equipment). Include this additional equipment in the safe shutdown equipment list.
Designation to Each              Attachment 3 to this document provides an example of a (SSEL). The SSEL identifies the list of equipment within the plant considered for post-fire safe shutdown and it documents various equipment-related attributes used in the analysis.
Identify instrument tubing that may cause subsequent effects on instrument readings or signals as a result of fire. Determine and consider the fire area location of the instrument tubing when evaluating the effects of fire damage to circuits and equipment in the fire area.
Agolicability                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NFPA 805 NSPC Equipment List is maintained as Attachment 8 to Report R2165-004-001. Other attachments of Report R2165-004-001 include data such as NSCA component association to system logic success path (i.e., system-to-equipment logic), NSCA system association to performance goal logic success path (i.e., performance goal-to-system logic), etc. This data is also contained within the NSCA database. The NSCA database also contains NSCA component drawing references.
From Section 10.6 of Report R2165-004-001:
Calculation SAP No. 9000039969 (Legacy No. M-1126), 10 CFR 50 Appendix R - Instrument Sensing Line Analysis, documents the evaluation of fire impacts on instrument sense lines. The evaluation of instrument sense lines in Calculation SAP No. 9000039969 (Legacy No. M-1 126) is based on Calculation SAP No. 9000039526 (Legacy No. M-680),
10 CFR 50 Appendix R Safe Shutdown Equipment, Revision 17, and was developed in support for the 10 CFR 50, Appendix R, licensing basis.
Calculation SAP No. 9000039969 (Legacy No. M-1126) was reviewed to ensure that its methodology and results demonstrate the achievement of the NSPC of NFPA 805 with respect to instrument sensing tubing lines per the requirements/guidance of NFPA 805, 2001 Edition, Section B.2.1.(e) and NEI 00-02, Revision 2, Sections 3.2.1.2, 3.2.2.3, and 3.4.1.9. The calculation was found to be bounding with regard to the instrumentation credited to achieve the NFPA 805 NSPC for Process Monitoring.
From Section 13.2.1 of Report R2165-004-001:
* When resolving component and cable failures the analyst is required to consider, and address as necessary, the potential impact resulting from the following:
* heating of instrument tubing sensing lines resulting in erroneous or unreliable signals from NSCA analyzed instrumentation (refer to Section 10.6 of [Report R2165-004-001])
Page B-58

Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Comments None Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 10.0 (Subsection 10.6) and 13.0 (Subsection 13.2.1); Attachment 8 PG&E Calculation SAP No. 9000039969 (Legacy No. M-1126), Part 000, Version 00, 10 CFR 50 Appendix R-     None Instrument Sensing Line Analysis Page B-59

Pacific Gas and Electric Comoanv                                        Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                     NEI 00-01 Guidance 3.2.2.4 Identify Equipment        Collect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for the equipment. In order to Information Required for the      facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer to Attachment 3 to this document for an example of a Safe Shutdown Analysis            SSEL. Examples of related equipment data should include the equipment type, equipment description, safe shutdown system, safe shutdown path, drawing reference, fire area, fire zone, and room location of equipment. Other information such as the following may be useful in performing the safe shutdown analysis: normal position, hot shutdown position, cold shutdown position, failed air position, failed electrical position, high/low pressure interface concern, and spurious operation concern. Criteria for making the determination as to which of these components are to be classified as required for hot shutdown or as important to SSD is contained in Appendix H.
Applicability                     Comments Applicable                         None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NFPA 805 NSPC Equipment List is maintained as Attachment 8 to Report R2165-004-001. Attachment 8 includes the following data associated with each NSCA Equipment ID:
" Unit ("0" designates common, or non-unit specific)
" System ID
" Fire Zone Location
" High/Low Pressure Interface
" Normal Position (normal component position with the plant operating at power)
* Hot Position (required hot standby/shutdown position)
" Cold Position (required cold shutdown position)
" Failed Power Position (resulting position due to loss of power)
" Failed Air Position (resulting position due to loss of air)
" Remarks (additional amplifying notes and comments)
Other attachments of Report R2165-004-001 include data such as NSCA component association to system logic success path (i.e., system-to-equipment logic), NSCA system association to performance goal logic success path (i.e., performance goal-to-system logic), etc. This data is also contained within the NSCA database. The NSCA database also contains NSCA component drawing references.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Section 10.0; Attachment 8 Page B-60

Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ret                    NEI 00-01 Guidance 3.2.2.5 Identify                 In the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as electrical power and Dependencies Between             interlocked equipment. As an aid in assessing identified impacts to safe shutdown, consider modeling the dependency between equipment within Equipment, Supporting            each safe shutdown path either in a relational database or in the form of a Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an Equipment, Safe Shutdown         example of a SSLD that may be developed to document these relationships.
Systems and Safe Shutdown Paths Aoolicabilitv                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Supporting equipment is tied to supported components through the use of equipment-to-equipment logic success path relationships in the NSCA database tool. The NSCA includes these equipment-to-equipment logic success path relationships when determining the effect of the a postulated fire event.
NSCA equipment-to-equipment logic success path relationships are tabulated in Attachment 7 to Report R2165-004-001. These relationships are maintained electronically in the NSCA database.
Comments None Reference Documents                                                                                                       Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                         Section 10. 0; Attachment 7 Page B-61

0    ".S". t1-   A01    4. t%                                     Aftni-hmann    rz - 1jFii flA..fr Tzhhis Q-1 kmIrInr -QfalhiI'm     uiltfu AaaagiemtanG     M~nfh,~rl1Irr,^    Pallial Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.3 Safe Shutdown Cable        This section provides industry guidance on one acceptable approach for selecting safe shutdown cables and determining their potential impact on Selection and Location         equipment required for achieving and maintaining safe shutdown of an operating nuclear power plant for the condition of an exposure fire. The Appendix R safe shutdown cable selection criteria are developed to ensure that all cables that could affect the proper operation or that could cause the mal-operation of safe shutdown equipment are identified and that these cables are properly related to the safe shutdown equipment whose functionality they could affect. Through this cable-to-equipment relationship, cables become part of the safe shutdown path assigned to the equipment affected by the cable. The classification of a cable as either an important to SSD circuit cable or a required safe shutdown cable is also derived from the classification applied to the component that it supports. This classification can vary from one fire area to another depending on the approach used to accomplish post-fire safe shutdown in the area. Refer to Appendix H for the criteria to be used for classifying required and important to SSD components.
Applicability                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                        Document Details Not Applicable                                                                                                             Not Applicable Page B-62

DP~r-fit tr2    2ndflorfri  rnmfl2nl r    x Attachment B     - NEI 04d..02 TablIB- NucleaI~i~r q42faht I'm V-2hIili Aeac~maemnf    Mtafhtk,,~rn~n UY-Paw~ignm Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.3.1 Criteria/Assumptions     To identify an impact to safe shutdown equipment based on cable routing, the equipment must have cables that affect it identified. Carefully consider how cables are related to safe shutdown equipment so that impacts from these cables can be properly assessed in terms of their ultimate impact on safe shutdown components, systems and functions.
Consider the following criteria when selecting cables that impact safe shutdown equipment:
Aoolicabilitv                  Comments Applicable                     None Aliqnment Statement Not Required Alionment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                   Document Details Not Applicable                                                                                                        Not Applicable Page B-63

Pacific Gas and Electric Companv                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                      NEI 00-01 Guidance 3.3.1.1.1                          The list of cables whose failure could impact the operation of a piece of safe shutdown equipment includes more than those cables connected to Criteria/Assumptions               the equipment. The relationship between cable and affected equipment is based on a review of the electrical or elementary wiring diagrams. To assure that all cables that could affect the operation of the safe shutdown equipment are identified, investigate the power, control, instrumentation, interlock, and equipment status indication cables related to the equipment. Review additional schematic diagrams to identify additional cables for interlocked circuits that also need to be considered for their impact on the ability of the equipment to operate as required in support of post-fire safe shutdown. As an option, consider applying the screening criteria from Section 3.5 as a part of this section.
APolicabilitY                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria /
assumptions listed in Section 3.3.1.1.1 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The methodology utilized to analyze circuits includes consideration of the following:
" Shorts to Ground (grounded and ungrounded circuits
" Hot shorts - internal (wire to wire within same cable)
" Hot shorts - external (cable to cable)
" Open circuits (fire-induced conductor break)
" Low level instrument cables (including shielded cables)
" Spurious signals (including interlock and permissive circuits)
This is an iterative process which may result in the addition of new NSCA components to the NFPA 805 NSPC Equipment List, and the addition of new equipment-to-equipment logic success path relationships to the NSCA model. The new NSCA components added to the NFPA 805 NSPC Equipment List are also subject to the circuit identification and analysis process described above.
The final set of NSCA cables identified to support the required function of each NSCA component are maintained utilizing an equipment-to-cable logic success path relationship in the NSCA database.
Comments None Page B-64

P0 Ga Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Section 3.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Section 5.0 Circuit Analysis Page B-65

Pacific Gas and Electric Company                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                   NEI 00-01 Guidance 3.3.1.1.2                       In cases where the failure (including spurious operations) of a single cable could impact more than one piece of safe shutdown equipment, Criteria/Assumptions            associate the cable with each piece of safe shutdown equipment.
Aoolicability                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria assumptions listed in Section 3.3.1.1.2 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
This is an iterative process which may result in the addition of new NSCA components to the NFPA 805 NSPC Equipment List, and the addition of new equipment-to-equipment logic success path relationships to the NSCA model. The new NSCA components added the to NFPA 805 NSPC Equipment List are also subject to the circuit identification and analysis process described above.
A single cable, if determined to be required for more than one NSCA component, may be associated to each unique NSCA equipment ID utilizing the component-to-cable logic success path relationship in the NSCA database. Typically in the case of power cables, one cable may be associated to a single NSCA support equipment ID, and that NSCA support equipment ID may be associated to one or more other NSCA supported equipment IDs utilizing the equipment-to-equipment logic success path relationship in the NSCA database.
The final set of NSCA cables identified to support the required function of each NSCA component are maintained utilizing a equipment-to-cable logic success path relationship in the NSCA database.
The final set of NSCA support components identified to support the required function of each NSCA supported component are maintained utilizing a equipment-to-equipment logic success path relationship in the NSCA database. The NSCA equipment-to-equipment logic success path relationship is also provided in Report R2165-004-001, Attachment 7.
Comments None.
Reference Documents                                                                                                        Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Section 3.0; Attachment 7 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                       Section 5.0 Circuit Analysis Page B-66

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                                     . f-,m      ~  t
: 01.       %,   00019        0%,  a   %I    %J111pa"Y                            Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                                  NEI 00-01 Guidance 3.3.1.1.2.1                                    Electrical devices such as relays, switches and signal resistor units are considered to be acceptable isolation devices. In the case of instrument Criteria/Assumptions                           loops and electrical metering circuits, review the isolation capabilities of the devices in the loop to determine that an acceptable isolation device has been installed at each point where the loop must be isolated so that a fault would not impact the performance of the safe shutdown instrument function. Refer to Section 3.5 for the types of faults that should be considered when evaluating the acceptability of the isolation device being credited.
Aonlicabilitv                                 Comments Applicable                                     None Alianment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria /
assumptions listed in Section 3.3.1.1.2.1 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Acceptable isolation devices are described in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.4 as being electrical contacts, fuses, blocking diodes, other protective devices, or circuits powered from a separate power source. Isolation devices for instrumentation loops are not specifically addressed, but may be implied under the category of "other protective devices."
Note that selective coordination of breakers / fuses is initially assumed during the circuit identification and analysis for each unique NSCA component. Selective coordination of breakers / fuses is subsequently confirmed for the electrical distribution systems, electrical distribution components, and electrical distribution alignments included in the NSCA as part of the associated circuits assessment provided in Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Associated CKT Analysis - Fire Protection.
Comments None Reference Documents                                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                            Section 3.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                                         Section 5.0 (Subsection 5.1.2.4)
Circuit Analysis PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                                             None Analysis - Fire Protection Page B-67

0                                                                                0 Pacific Gas and Electric Companv                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                    NEI 00-01 Guidance 3.3.1.1.3                        Screen out cables for circuits that do not impact the safe shutdown function of a component (i.e., annunciator circuits, space heater circuits and Criteria/Assumptions             computer input circuits) unless some reliance on these circuits is necessary. To be properly screened out, however, the circuits associated with these devices must be isolated from the component's control scheme in such a way that a cable fault would not impact the performance of the circuit. Refer to Section 3.5 for the types of faults that should be considered when evaluating the acceptability of the isolation device being credited.
Comments Applicable                       None Alianment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria/
assumptions listed in Section 3.3.1.1.3 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.4, defines the methodology for circuit analysis. This section provides examples of SSD (required) circuits and Non-SSD (not required) circuits. Acceptable isolation devices described in this section are electrical contacts, fuses, blocking diodes, other protective devices, or circuits powered from a separate power source. Isolation devices for instrumentation loops are not specifically addressed, but may be implied under the category of "other protective devices." Annunciator circuits, space heater circuits, and computer input circuits are not specifically addressed, but may be implied under the category of"circuits powered from a separate power source."
Not required cables are generally only identified in the NSCA database for primary scheme (i.e., "on-scheme") cables that are determined not to be required for the NSCA. These cables are identified in the NSCA database at the discretion of the preparer and reviewer of the circuit identification and analysis for each NSCA component to document that the primary scheme cables were indeed included and addressed in the circuit identification and analysis activity.
The final set of NSCA cables identified as not being required to support the required function of each NSCA component are maintained utilizing an equipment-to-cable logic success path relationship in the NSCA database.
Comments None Reference Documents                                                                                                         Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Section 3.0 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                        Section 5.0 (Subsection 5.1.2.4)
Circuit Analysis Page B-68

0                                                                                0 Pacific Gas and Electric ComnanY                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                     NEI 00-01 Guidance 3.3.1.1.4                         For each circuit requiring power to perform its safe shutdown function, identify the cable supplying power to each safe shutdown and/or required Criteria/Assumptions              interlock component. Initially, identify only the power cables from the immediate upstream power source for these interlocked circuits and components (i.e., the closest power supply, load center or motor control center). Review further the electrical distribution system to capture the remaining equipment from the electrical power distribution system necessary to support delivery of power from either the offsite power source or the emergency diesel generators (i.e., onsite power source) to the safe shutdown equipment. Add this equipment to the safe shutdown equipment list.
The set of cables described above are classified as required safe shutdown cables. Evaluate the power cables for breaker coordination concerns.
The non-safe shutdown cables off of the safe shutdown buses are classified as required for hot shutdown or as important to SSD based on the criteria contained in Appendix H.
Applicability                     Comments Applicable                        None Alignment Statement Aligns Alionment Basis Report R2165-004-001, Section 3.0, NSCA.Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria /
assumptions listed in Section 3.3.1.1.4 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Transition Circuit Analysis (component selection is also performed during the circuit identification and analysis activity).
Report R2165-004-001, Section 10.0, identifies the overall process utilized to develop the NSCA model and select components required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NSCA model development and component selection process includes consideration for the following:
- With respect to the convention for identifying and associating electrical distribution equipment to NSCA components, the NSCA model development and component selection should utilize a "building block" approach consistent with NEI 00-01 Criteria / Assumption 3.3.1.1.4. The boundary for NSCA model development and component selection (for each NSCA component) should include only, as applicable, the upstream electrical power source for each NSCA component.
Application of NEI 00-01 Criteria / Assumption 3.3.1.1.4 for the DCPP NSCA is reflected in the final set of NSCA support components identified to support the required function of each NSCA supported component. These relationships are maintained utilizing an equipment-to-equipment logic success path relationship in the NSCA database. The NSCA equipment-to-equipment logic success path relationship is also provided in Report R2165-004-001, Attachment 7.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0 and 10.0; Attachment 7 Page B-69

0                                                                                     0                                                                               0 Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                     NEI 00-01 Guidance 3.3.1.1.4.1                       The automatic initiation logics for the credited post-fire safe shutdown systems are generally not required to support safe shutdown. Typically, each Criteria/Assumptions             system can be controlled manually by operator actuation in the main control room or emergency control station. The emergency control station includes those plant locations where control devices, such as switches, are installed for the purpose of operating the equipment. If operator actions to manually manipulate equipment at locations outside the MCR or the emergency control station are necessary, those actions must conform to the regulatory requirements on operator manual actions (See Appendix E). If not protected from the effects of fire, the fire-induced failure of automatic initiation logic circuits should be considered for their potential to adversely affect any post-fire safe shutdown system function.
ApDlicability                    Comments Applicable                        None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria /
assumptions listed in Section 3.3.1.1.4.1 of NEI 00-01 are explicitly stated inthe report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), NFPA 805 Circuit Analysis (component selection is also performed during the circuit identification and analysis activity).
Report R2165-004-001, Section 10.0, identifies the overall process utilized to develop the NSCA model and select components required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NSCA model development and component selection process includes consideration for the following:
* Unless specifically included in the NFPA 805 NSPC Equipment List and modeled inthe NSCA, credit is not taken inthe NSCA model development and component selection for the actuation of any automatic safety features to assist in the operation of components to achieve the NFPA 805 NSPC. With respect to automatic signals, the model development and component selection for the NSCA ensures that components functional requirements are included in the NFPA 805 NSPC Equipment List and the NSCA database, as applicable, to identify NSCA components where the circuit identification and analysis will need to include the capability for the plant operator to reposition the NSCA component from the MCR in the event that an ESFAS actuation had occurred, following manual reset of the ESFAS signal.
Section 10.8 of Report R2165-004-001 provides a discussion for the treatment of a valid and/or spurious actuation of the ESFAS in the DCPP Plant NSCA.
Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Unless specifically included in the NFPA 805 NSPC Equipment List and modeled in the NSCA, credit is not taken in the circuit identification and analysis for the actuation of any automatic safety features to assist in the operation of components to achieve the NFPA 805 NSPC. With respect to automatic signals, based on component functional requirements identified in the NFPA 805 NSPC Equipment List and the NSCA database, the circuit identification and analysis for NSCA components ensures that circuits are included in the NSCA model, as applicable, that allow the plant operator to reposition the NSCA component from the MCR in the event that an ESFAS actuation had occurred, Page B-70

Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis following manual reset of the ESFAS actuation signal.
Comments None Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 3.0 and 10.0 (Subsection 10.8)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Section 5.0 Circuit Analysis Page B-71

0                                                                                 S Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                     NEI 00-01 Guidance 3.3.1.1.5                        Cabling for the electrical distribution system is a concern for those breakers that feed circuits and are not fully coordinated with upstream breakers.
Criteria/Assumptions             With respect to electrical distribution cabling, two types of cable associations exist. For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component and classified as a required safe shutdown cable. For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to a motor control center (MCC) supports the MCC. However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center. Additionally, the non-safe shutdown circuits off of each of the required safe shutdown components in the electrical distribution system can impact safe shutdown if not properly coordinated. These cables are classified as required for hot shutdown based on the criteria contained in Appendix H.
Applicabilitv                     Comments Applicable                        None Aliunment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria /
assumptions listed in Section 3.3.1.1.5 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Associated CKT Analysis - Fire Protection.
Selective coordination of breakers / fuses has been confirmed for the electrical distribution systems, electrical distribution components, and electrical distribution alignments included in the NSCA as part of the associated circuits assessment provided in Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
From Section 1 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T):
The purpose of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] is to evaluate common power supply and common enclosure associated circuits as applied to the DCPP Fire Protection Program Nuclear Safety Capability Assessment (NSCA) and Fire PRA. It is not the intent of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to duplicate existing electrical coordination and protection information contained in other DCPP calculations and/or analyses. Rather, the fire protection associated circuits analysis is most effective when it provides a clear description of the coordination credited by the NSCA and Fire PRA circuit analysis, and then points to the applicable electrical design calculations that contain the time-current plots and supporting data that demonstrate electrical coordination/protection. In this way the calculation serves as a "roadmap" between the NSCA and Fire PRA criteria and the applicable electrical design calculations, but does not duplicate information that is contained in the other calculations.
The objectives of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] are:
"Identify electrical power supplies credited by the NSCA and Fire PRA, and document the electrical coordination requirements applicable to these power supplies.
"For credited electrical power supplies, assess electrical coordination - as documented in controlled calculations or studies - to determine if any vulnerabilities exist with respect to Page B-72
* S 0
Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis common power supply associated circuits.
- Assess electrical circuit protection - as documented in controlled calculations, analyses, or design criteria - to determine ifany vulnerabilities exist with respect to common power supply associated circuits.
* Provide a "road map" for electrical coordination and protection calculations that facilitates easy correlation between the associated circuit requirements specified in [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to the specific design calculations that demonstrate acceptability.
- Identify for existing electrical coordination and protection calculations/studies any weaknesses in the objectives, methodology, criteria, or results that do not fully support the criteria for associated circuits.
Section 8, Results, of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) identifies concerns regarding proper circuit coordination or impacts of associated circuits. The identification of corrective strategies for identified concerns are documented within the evaluation of associated circuits in Section 7 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
Comments None Reference Documents                                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                             Section 3.0 PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                              Sections 1.0, 7.0, and 8.0 Analysis - Fire Protection Page B-73

DnrfM    f%-, ndEanrr        flnm nn,                              AHf2Ikmant R - K11= fA..flO T2hlg%R-9 Km-loo~r Qnfahi~ ('n        &#xfd;hilift Aea  aam~nn  Mahril          D&#xfd; Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                    NEI 00-01 Guidance 3.3.1.1.6                        Exclusion analysis may be used to demonstrate a lack of potential for any impacts to post-fire safe shutdown from a component or group of Criteria/Assumptions             components regardless of the cable routing. For these cases, rigorous cable searching and cable to component associations may not be required.
Annlicability                    Comments Applicable                       None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection. The criteria/
assumptions listed in Section 3.3.1.1.6 of NEI 00-01 are explicitly stated in the report.
Exclusion analysis was not utilized in the development of the NSCA model and component selection activities.
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        Section 3.0 Page B-74

D&#xfd;&#xfd;M^ t--na mnA Plao-frie- I'em     on                             Att~achment B   - NEI 04-02l Table B-2~ NIdrIonr      nfcahtIn~n~hilifu    Acccicmanf M~afkhrnfietn,        Diakinrigu Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.3.2 Associated Circuit of    Appendix R, through the guidance provided in NRC Generic Letter 81-12, requires that separation features be provided for associated nonsafety Concern Cables                 circuits that could prevent operation or cause mal-operation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve hot shutdown. The three types of associated circuits were identified in Reference 7.1.5 and further clarified in a NRC memorandum dated March 22, 1982 from R. Mattson to D. Eisenhut, Reference 7.1.6. They are as follows:
                               - Spurious actuations (4)
                               - Common power source
                               - Common enclosure.
Each of these cables is classified as an associated circuit of concern cable.
(4) As explained in NRC RIS 2005-30 and in Appendix H, components whose spurious operations could directly prevent the required safe shutdown path in any fire area from performing its required hot shutdown function are classified as required for hot shutdown components.
Components whose spurious operation could affect important to safe shutdown components might be associated circuits of concern for spurious actuation.
Aoplicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                      Document Details Not Applicable                                                                                                           Not Applicable Page B-75

Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                      NEI 00-01 Guidance 3.3.2 Associated Circuit of        Cables Whose Failure May Cause Spurious Operations Concern Cables - Cable Whose Failure May Cause            Safe shutdown system spurious operation concerns can result from fire damage to a cable whose failure could cause the spurious operation/mal-Spurious Actuations                operation of equipment whose operation could affect safe shutdown. These cables are identified in Section 3.3.3 together with the remaining safe shutdown cables required to support control and operation of the equipment.
Apolicabilitv                      Comments Applicable                         None Alignment Statement Aligns Alionment Basis Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Section 5.1.1 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) describes that the circuit identification and analysis for each NSCA component is defined from the functional requirements identified inthe NFPA 805 NSPC Equipment List and the NSCA database. These functional requirements include: (1) normal position (at-power), (2) required position, and (3) failed position.
Plant components whose spurious operation alone, or in combination with other components, could adversely affect NSCA capabilities are included inthe NFPA 805 NSPC Equipment List (as NSCA components).
One or more cable is identified by the circuit identification and analysis as being required for an NSCA component if its failure alone (or their failure in combination) could adversely affect the desired position(s) / function(s) for the NSCA component, as applicable, based on consideration of the effects of open circuits, short circuits, and/or grounds.
Multiple simultaneous circuit failures are postulated inthe circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type circuit failures that are postulated to occur except as modified by the following:
- Spurious operation, when resulting only from properly sequenced three-phase to three-phase external hot shorts is only postulated in the circuit identification and analysis for high/low pressure interface valves.
&deg;Spurious operation, when only resulting from positive to positive (+ to +) and negative to negative (- to -) external DC hot shorts in ungrounded DC circuits is only postulated in the circuit identification and analysis for high/low pressure interface valves.
" No credit is taken for self-healing of electrical failures.
"The circuit identification and analysis does not screen out cables on the basis of jacket material, insulation material, shielding, and/or the cable being routed in a dedicated conduit.
The final set of NSCA cables identified to support the required function of each NSCA component are maintained utilizing an equipment-to-cable logic success path relationship in Page B-76

Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis the NSCA database. The NSCA database identifies the spurious cables together with other NSCA cables required to support control and operation of the NSCA components.
Comments None Reference Documents                                                                                               Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition              Section 5.0 (Subsection 5.1.1)
Circuit Analysis Page B-77

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                     NEI 00-01 Guidance 3.3.2 Associated Circuit of       Common Power Source Cables Concern Cables - Common Power Source Cable                The concern for the common power source associated circuits of concern is the loss of a safe shutdown power source due to inadequate breaker/fuse coordination. In the case of a fire-induced cable failure on a non-safe shutdown load circuit supplied from the safe shutdown power source, a lack of coordination between the upstream supply breaker/fuse feeding the safe shutdown power source and the load breaker/fuse supplying the non-safe shutdown faulted circuit can result in loss of the safe shutdown bus. This would result in the loss of power to the safe shutdown equipment supplied from that power source preventing the safe shutdown equipment from performing its required safe shutdown function. Identify these cables together with the remaining safe shutdown cables required to support control and operation of the equipment. Refer to Section 3.5.2.4 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
APPlicabil                         Comments Applicable                         None Alignment Statement Aligns Alignment Basis DCPP has performed electrical design calculations which establish protective device setpoints and coordination. Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T),
Section 7.1, Evaluation of Electrical Coordination for Required Power Supplies, confirms that selective coordination of breakers / fuses is maintained the electrical distribution systems, electrical distribution components, and electrical distribution alignments included in the NSCA. Selective coordination of breakers / fuses has been confirmed for the electrical distribution systems, electrical distribution components, and electrical distribution alignments included in the NSCA as part of the associated circuits assessment provided in Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
From Section 1 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T):
The purpose of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] is to evaluate common power supply and common enclosure associated circuits as applied to the DCPP Fire Protection Program Nuclear Safety Capability Assessment (NSCA) and Fire PRA. It is not the intent of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to duplicate existing electrical coordination and protection information contained in other DCPP calculations and/or analyses. Rather, the fire protection associated circuits analysis is most effective when it provides a clear description of the coordination credited by the NSCA and Fire PRA circuit analysis, and then points to the applicable electrical design calculations that contain the time-current plots and supporting data that demonstrate electrical coordination/protection. In this way the calculation serves as a "roadmap" between the NSCA and Fire PRA criteria and the applicable electrical design calculations, but does not duplicate information that is contained in the other calculations.
The objectives of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] are:
"Identify electrical power supplies credited by the NSCA and Fire PRA, and document the electrical coordination requirements applicable to these power supplies.
"For credited electrical power supplies, assess electrical coordination - as documented in controlled calculations or studies - to determine if any vulnerabilities exist with respect to common power supply associated circuits.
- Assess electrical circuit protection - as documented in controlled calculations, analyses, or design criteria - to determine if any vulnerabilities exist with respect to common power supply associated circuits.
Page B-78

Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety CapabilitV Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
- Provide a "road map" for electrical coordination and protection calculations that facilitates easy correlation between the associated circuit requirements specified in [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to the specific design calculations that demonstrate acceptability.
- Identify for existing electrical coordination and protection calculations/studies any weaknesses in the objectives, methodology, criteria, or results that do not fully support the criteria for associated circuits.
Section 8, Results, of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) identifies concerns regarding proper circuit coordination or impacts of associated circuits. The identification of corrective strategies for identified concerns are documented within the evaluation of associated circuits in Section 7 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
Comments None Reference Documents                                                                                                           Document Details PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                              Sections 1.0, 7.0 (Subsection 7.1), and 8.0 Analysis - Fire Protection Page B-79

Pacific Gas and Electric Company                                         Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                      NEI 00-01 Guidance 3.3.2 Associated Circuit of        Common Enclosure Cables Concern Cables - Common Enclosure Cables                   The concern with common enclosure associated circuits of concern is fire damage to a cable whose failure could propagate to other safe shutdown cables in the same enclosure either because the circuit is not properly protected by an isolation device (breaker/fuse) such that a fire-induced fault could result in ignition along its length, or by the fire propagating along the cable and into an adjacent fire area. This fire spread to an adjacent fire area could impact safe shutdown equipment in that fire area, thereby resulting in a condition that exceeds the criteria and assumptions of this methodology (i.e., multiple fires). Refer to Section 3.5.2.5 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
AnDlicabilitv                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Section 7.3, Evaluation of Common Enclosure Associated Circuits, Section 7.4, Evaluation of Loss of Control Power to Power Circuit Breakers, and Section 7.5, Evaluation of Current Transformer Open Circuits, address common enclosure concerns, inclusive of an assessment for the open circuiting of current transformer (CT) secondaries.
From Section 1 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T):
The purpose of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] is to evaluate common power supply and common enclosure associated circuits as applied to the DCPP Fire Protection Program Nuclear Safety Capability Assessment (NSCA) and Fire PRA. It is not the intent of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to duplicate existing electrical coordination and protection information contained in other DCPP calculations and/or analyses. Rather, the fire protection associated circuits analysis is most effective when it provides a clear description of the coordination credited by the NSCA and Fire PRA circuit analysis, and then points to the applicable electrical design calculations that contain the time-current plots and supporting data that demonstrate electrical coordination/protection. In this way the calculation serves as a "roadmap" between the NSCA and Fire PRA criteria and the applicable electrical design calculations, but does not duplicate information that is contained in the other calculations.
The objectives of [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] are:
" Identify electrical power supplies credited by the NSCA and Fire PRA, and document the electrical coordination requirements applicable to these power supplies.
" For credited electrical power supplies, assess electrical coordination - as documented in controlled calculations or studies - to determine if any vulnerabilities exist with respect to common power supply associated circuits.
- Assess electrical circuit protection - as documented in controlled calculations, analyses, or design criteria - to determine if any vulnerabilities exist with respect to common power supply associated circuits.
- Provide a "road map" for electrical coordination and protection calculations that facilitates easy correlation between the associated circuit requirements specified in [Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)] to the specific design calculations that demonstrate acceptability.
Page B-80

0 D&#xfd;^Prv^ fl&#xfd;a     nnri Clexi-frid- I'tm F
nn                            Af*nrhmant R -    NEFI flA..fl Tnhlg R-.9 hitirlIa~r 4'2fa~hi ('n nhkii$1
                                                                                                                                  .r ~       .V-Aeetacamanf     Mafk,-rninin, W
Dowawc Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
- Identify for existing electrical coordination and protection calculations/studies any weaknesses in the objectives, methodology, criteria, or results that do not fully support the criteria for associated circuits.
Section 8, Results, of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) identifies concerns regarding proper circuit coordination or impacts of associated circuits. The identification of corrective strategies for identified concerns are documented within the evaluation of associated circuits in Section 7 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T).
Comments None Reference Documents                                                                                                           Document Details PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                              Sections 1.0, 7.0 (Subsections 7.2, 7.3, and 7.5), and 8.0 Analysis - Fire Protection Page B-81

PG                                                                                   0 Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.3.3 Methodology for          Refer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for performing a post-fire safe shutdown Cable Selection and            analysis.
Location Use the following methodology to define the cables required for safe shutdown including cables that may cause associated circuits concerns for a post-fire safe shutdown analysis:
Aoolicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alicnment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                               Not Applicable Page B-82

0 Pacific Gas and Electric Company                                        Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                      NEI 00-01 Guidance 3.3.3.1 Identify Circuits          For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including the following documentation Necessary for the Operation        to identify the circuits (power, control, instrumentation) required for operation or whose failure may impact the operation of each piece of equipment:
of the Safe Shutdown Equipment                          - Single-line electrical diagrams
                                   - Elementary wiring diagrams
                                   - Electrical connection diagrams
                                   - Instrument loop diagrams.
For electrical power distribution equipment such as power supplies, identify any circuits whose failure may cause a coordination concern for the bus under evaluation.
If power is required for the equipment, include the closest upstream power distribution source on the safe shutdown equipment list. Through the iterative process described in Figures 3-2 and 3-3, include the additional upstream power sources up to either the offsite or the emergency power source.
AoDlicability                      Comments Applicable                         None Alignment Statement Aligns Alionment Basis Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, Circuit Identification and Analysis, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Section 5.1.1 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) describes that the circuit identification and analysis for each NSCA component is defined from the functional requirements identified in the NFPA 805 NSPC Equipment List and the NSCA database. These functional requirements include: (1) normal position (at-power), (2) required position, and (3) failed position.
One or more cable is identified by the circuit identification and analysis as being required for an NSCA component if its failure alone (or their failure in combination) could adversely affect the desired position(s) / function(s) for the NSCA component, as applicable, based on consideration of the effects of open circuits, short circuits, and/or grounds.
Multiple simultaneous circuit failures are postulated in the circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type circuit failures that are postulated to occur except as modified by the following:
- Spurious operation, when resulting only from properly sequenced three-phase to three-phase external hot shorts is only postulated in the circuit identification and analysis for high/low pressure interface valves.
- Spurious operation, when only resulting from positive to positive (+ to +) and negative to negative (- to -) external DC hot shorts in ungrounded DC circuits is only postulated in the circuit identification and analysis for high/low pressure interface valves.
Page B-83

0                                                                                 0
* Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
" No credit is taken for self-healing of electrical failures.
"The circuit identification and analysis does not screen out cables on the basis of jacket material, insulation material, shielding, and/or the cable being routed in a dedicated conduit.
The final set of NSCA cables identified to support the required function of each NSCA component are maintained utilizing an equipment-to-cable logic success path relationship in the NSCA database. The NSCA database identifies the spurious cables together with other NSCA cables required to support control and operation of the NSCA components.
Comments None Reference Documents                                                                                                          Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                         Section 5.0 (Subsection 5.1.1)
Circuit Analysis Page B-84

0 OIL. 1.61.%, t1_ 012 all A U1 VVU L,
t%
V    Folly                           Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                                NEI 00-01 Guidance 3.3.3.2 Identify Interlocked                 In reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and equipment. Assign to the equipment Circuits and Cables Whose                    any cables for interlocked circuits that can affect the equipment.
Spurious Operation or Mal-operation Could Affect                       While investigating the interlocked circuits, additional equipment or power sources may be discovered. Include these interlocked equipment or Shutdown                                     power sources in the safe shutdown equipment list (refer to Figure 3-3) if they can impact the operation of the equipment under consideration in an undesirable manner that impacts post-fire safe shutdown.
Applicability                                Comments Applicable                                   None Alianment Statement Aligns Alignment Basis Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, Circuit Identification and Analysis, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Section 5.1.1 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) describes that the circuit identification and analysis for each NSCA component is defined from the functional requirements identified in the NFPA 805 NSPC Equipment List and the NSCA database. These functional requirements include: (1) normal position (at-power), (2) required position, and (3) failed position.
One or more cable is identified by the circuit identification and analysis as being required for an NSCA component if its failure alone (or their failure in combination) could adversely affect the desired position(s) / function(s) for the NSCA component, as applicable, based on consideration of the effects of open circuits, short circuits, and/or grounds.
Multiple simultaneous circuit failures are postulated in the circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type circuit failures that are postulated to occur except as modified by the following:
- Spurious operation, when resulting only from properly sequenced three-phase to three-phase external hot shorts is only postulated in the circuit identification and analysis for high/low pressure interface valves.
- Spurious operation, when only resulting from positive to positive (+ to +) and negative to negative (- to -) external DC hot shorts in ungrounded DC circuits is only postulated in the circuit identification and analysis for high/low pressure interface valves.
* No credit is taken for self-healing of electrical failures.
* The circuit identification and analysis does not screen out cables on the basis of jacket material, insulation material, shielding, and/or the cable being routed in a dedicated conduit.
Comments None Page B-85

PG                                                                        0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Reference Documents                                                                                      Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Section 5.0 (Subsection 5.1.1)
Circuit Analysis Page B-86

Pacific Gas and Electric Comnanv                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                      NEI 00-01 Guidance 3.3.3.3 Assign Cables to           Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in mal-operation of each piece of the Safe Shutdown                  safe shutdown equipment. Cables are classified as either required for hot shutdown or important to SSD based on the classification of the Equipment                          component to which they are associated and the function of that component in supporting post-fire safe shutdown in each particular fire area.
Refer to Appendix H for additional guidance.
Tabulate the list of cables potentially affecting each piece of equipment in a relational database including the respective drawing numbers, their revision and any interlocks that are investigated to determine their impact on the operation of the equipment. In certain cases, the same cable may support multiple pieces of equipment. Relate the cables to each piece of equipment, but not necessarily to each supporting secondary component.
If adequate coordination does not exist for a particular circuit, relate the power cable to the power source. This will ensure that the power source is identified as affected equipment in the fire areas where the cable may be damaged. Criteria for making the determination as to which cables are to be classified as required for hot shutdown or as important to SSD is contained in Appendix H.
Applicability                      Comments Applicable                         None Alignment Statement Aligns Aliqnment Basis Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.0, Circuit Identification and Analysis, identifies the overall process utilized to identify and analyze circuits for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Section 5.1.1 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) describes that the circuit identification and analysis for each NSCA component is defined from the functional requirements identified in the NFPA 805 NSPC Equipment List and the NSCA database. These functional requirements include: (1) normal position (at-power), (2) required position, and (3) failed position.
One or more cable is identified by the circuit identification and analysis as being required for an NSCA component if its failure alone (or their failure in combination) could adversely affect the desired position(s) / function(s) for the NSCA component, as applicable, based on consideration of the effects of open circuits, short circuits, and/or grounds.
Multiple simultaneous circuit failures are postulated in the circuit identification and analysis (affecting multiple cables, affecting multiple conductors within cables). No limit is prescribed to the number or type circuit failures that are postulated to occur except as modified by the following:
- Spurious operation, when resulting only from properly sequenced three-phase to three-phase external hot shorts is only postulated in the circuit identification and analysis for high/low pressure interface valves.
- Spurious operation, when only resulting from positive to positive (+ to +) and negative to negative (- to -) external DC hot shorts in ungrounded DC circuits is only postulated in the circuit identification and analysis for high/low pressure interface valves.
- No credit is taken for self-healing of electrical failures.
Page B-87

Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Pacific Gas and Electric Co            anvA02
                                         -                                                                                              a           AR Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
- The circuit identification and analysis does not screen out cables on the basis of jacket material, insulation material, shielding, and/or the cable being routed in a dedicated conduit.
The final set of NSCA cables identified to support the required function of each NSCA component are maintained utilizing an equipment-to-cable logic success path relationship in the NSCA database. The NSCA database identifies the spurious cables together with other NSCA cables required to support control and operation of the NSCA components.
In addition, per Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Attachment 1, a "Cable Data Worksheet" is prepared for each SSD component being reviewed. The required fields of the datasheet include:
"Component ID
* Component Name/Function "System "SSD Category (i.e., HSB, HSB-S, CSD, and/or CSD-S)
"Fire Area Location "Normal Position "Desired Position "Failed Position "Cable ID "Cable Type (i.e., Power, Control, or Instrument)
"Fault Type (i.e., OC, SC, HS, VWV, and SG)
* Fault Consequence (i.e., LOP, SPUR, CONT, IND, and/or NA)
"Safe Shutdown (Y or N)
"Drawing Reference "Additional Notes The datasheets are maintained in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Attachments 4 through 13. The above data associated with SSD equipment and their associated cables is also maintained in the FIREPROT database.
The FIREPROT database is described in Section 17.0, Definitions, of Report R2165-004-001.
Comments None Reference Documents                                                                                                           Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                          Sections 5.0 (Subsection 5.1.1) and 11.0; Attachments 1, Circuit Analysis                                                                                                              4, 5, 6, 7, 8, 9, 10, 11, 12, and 13 Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                             Section 17.0 Page B-88

0                                                                                  0                                                                                    0 Pacific Gas and Electric Companv                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location NEI 00-01 Ref                   NEI 00-01 Guidance 3.3.3.4 Identify Routing of     Identify the routing for each cable including all raceway and cable endpoints. Typically, this information is obtained from joining the list of safe Cables                          shutdown cables with an existing cable and raceway database.
Applicability                   Comments Applicable                      None Alignment Statement Aligns Alignment Basis Sections 5.1.3 and 5.1.4 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) describe the overall process for assigning fire zone locations to NSCA components and NSCA cable via raceways. This includes assigning fire zone locations to NSCA cable to/from equipment.
Comments None Reference Documents                                                                                                        Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                       Section 5.0 (Subsections 5.1.3 and 5.1.4)
Circuit Analysis Page B-89

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                                                                                                                                                                                                &#xfd; Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location NEI 00-01 Ref                         NEI 00-01 Guidance 3.3.3.5 Identify Location of          Identify the fire area location of each raceway and cable endpoint identified in the previous step and join this information with the cable routing Raceway and Cables by                 data. For raceway and cable endpoints in multiple fire areas, each fire area where the raceway or cable endpoint exists must be included. In Fire Area                             addition, identify the location of field-routed cable by fire area. This produces a database containing all of the cables requiring fire area analysis, their locations by fire area, and their raceway.
APPlicabilitY                         Comments Applicable                            None Alignment Statement Aligns Alionment Basis The methodology for identification of SSD equipment and cable fire area locations is described in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.3. This methodology includes identification of fire area locations for SSD equipment, SSD cable to/from equipment and SSD raceways.
The fire area locations for SSD equipment, SSD cable to/from equipment and SSD raceways are identified based on review of the DCPP Electrical Raceway Drawings and Fire Barrier Drawings.
The fire area locations for SSD equipment, SSD cable to/from equipment and SSD raceways are maintained in Calculation SAP No. 9000041072 (Legacy No. 134-DC-T),
Attachments 4 through 13. Fire area location data associated with SSD equipment and their associated cables is also maintained in the FIREPROT database.
The FIREPROT database is described in Section 17.0, Definitions, of Report R2165-004-001.
Comments None Reference Documents                                                                                                                Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                               Sections 5.0 (Subsection 5.1.3) and 11.0; Attachments 4, Circuit Analysis                                                                                                                   5,6,7,8,9, 10, 11,12, and 13 Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                  Section 17.0 Page B-90

Pacific Gas and Electric Company                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqy Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                  NEI 00-01 Guidance 3.4 Fire Area Assessment        By determining the location of each component and cable by fire area and using the cable to equipment relationships described above, the affected and Compliance Strategies      safe shutdown equipment in each fire area can be determined. Using the list of affected equipment in each fire area, the impacts to safe shutdown systems, paths and functions can be determined. Based on an assessment of the number and types of these impacts, the required safe shutdown path for each fire area can be determined. The specific impacts to the selected safe shutdown path can be evaluated using the circuit analysis and evaluation criteria contained in Section 3.5 of this document. Knowing which components and systems are performing which safe shutdown functions, the required and important to SSD components can be classified. Once these component classifications have been made the tools available for mitigating the affects of fire induced damage can be selected. Refer to Appendix H for additional guidance on classifying components as either required for hot shutdown or important to safe shutdown. For MSOs the Resolution Methodology outlined in Section 4, Section 5, Appendix B and Appendix G should be applied. Components in each MSO are classified as either required for hot shutdown or important to safe shutdown components using the criteria from Appendix H. Similarly, this classification determines the available tools for mitigating the affects of fire-induced damage to the circuits for these components.
Having identified all impacts to the required safe shutdown path in a particular fire area, this section provides guidance on the techniques available for individually mitigating the effects of each of the potential impacts.
Applicabilit                   Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                              Not Applicable Page B-91

Ppii     Qpam   an  El*wmvlectric Co    na n                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capabili              Assessment Methodology Review Attachment B - NEI 0.4-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                        NEI 00-01 Guidance 3.4.1 Criteria/Assumptions           The following criteria and assumptions apply when performing fire area compliance assessment to mitigate the consequences of the circuit failures identified in the previous sections for the required safe shutdown path in each fire area.
Aoolicabilitv                        Comments Applicable                           None Alignment Statement Not Required Alicnment Basi Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                             Document Details Not Applicable                                                                                                                  Not Applicable Page B-92

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fsl.~         V*~VE Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                        NEI 00-01 Guidance 3.4.1.1 Criteria/Assumptions         Assume only one fire in any single fire area at a time.
Aoolicabilitv                        Comments Applicable                           None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.4.1.1 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
A deterministic NSCA is performed for each fire area of the plant utilizing the SAFE database tool to determine the final NSCA compliance strategy assuming one all consuming fire in a single fire area at a time. The objective is to recover at least one NSCA success path for each SAFE performance goal-to-system logic based on identification of the least impacted train of plant equipment.
Comments None Reference Documents                                                                                                            Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                              Sections 3.0 and 13.0 (Subsection 13.2)
Page B-93

Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Pacific Gas and Electric Com               -anv                       A                                                         a     C           AR Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                      NEI 00-01 Guidance 3.4.1.2 Criteria/Assumptions       Assume that the fire may affect all unprotected cables and equipment within the fire area. This assumes that neither the fire size nor the fire intensity is known. This is conservative and bounds the exposure fire that is postulated in the regulation.
Applicability                      Comments Applicable                         None Alionment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.4.1.2 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
- An initial deterministic analysis is run with the SAFE database tool for each fire area (or analysis area). The initial fire area analysis assumes that all NSCA equipment and NSCA cables physically located in the fire area fail to their worst case condition or state.
Comments None Reference Documents                                                                                                             Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                               Sections 3.0 and 13.0 (Subsection 13.2)
Page B-94

(Illl nnA  pollg  i I  Cln~   ni D*    i Attachment B      -  NEI 04-02 Table B-2 Nuclear Safety Canabilitv Assessment Methodoloov Review In-ft Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                       NEI 00-01 Guidance 3.4.1.3 Criteria/Assumptions        Address all cable and equipment impacts affecting the required safe shutdown path in the fire area. All potential impacts within the fire area must be addressed. The focus of this section is to determine and assess the potential impacts to the required safe shutdown path selected for achieving post-fire safe shutdown and to assure that the required safe shutdown path for a given fire area is properly protected.
Applicability                       Comments Applicable                          None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.4.1.3 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- The NSCA compliance strategy for these "resolved" fire areas in SAFE typically credits the least affected success path. This strategy for "resolution" generally involves the resolution of supporting functions first (i.e., electrical distribution, cooling water, etc.), followed by resolution of the supported front line systems / functions / components (i.e.,
Reactivity Control, Inventory Control, etc.).
- The deterministic NSCA for each "resolved" fire area in SAFE may rely on SAFE equipment and/or cable resolutions. Additional details regarding SAFE equipment and cables resolution is provided in this section of [Report R2165-004-001].
- SAFE equipment resolutions identify and provide a traceable link for each component failure on a fire area basis that requires further engineering justification to be determined acceptable as-is (i.e., not having any adverse impact to the NSCA), or that requires further engineering review to identify and PROPOSE a plant change such as an OMA, or a physical plant modification. Each equipment resolution includes descriptive text fields in SAFE to document the engineering review basis.
- SAFE cable resolutions identify and provide a traceable link for protected cables in the fire area (i.e., protected by ERFBS [Electrical Raceway Fire Barrier System], embedded with evaluation, routed in buried ductbanks through one or more manhole). Each cable resolution includes descriptive text fields in SAFE to document the engineering review basis.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage.
Page B-95

0Ga Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment  to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Comments None Reference Documents                                                                                           Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                             Sections 3.0, 8.0 (Subsection 8.5), and 13.0 (Subsection 13.2)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition          Attachment 3 Circuit Analysis Page B-96

0 Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                    NEI 00-01 Guidance 3.4.1.4 Criteria/Assumptions     Use the criteria from Appendix H to classify each impacted cable/component as either a required or important to SSD cable/component.
Applicability                    Comments Applicable                       None Alignment Statement Aligns with Intent Alianment Basis DCPP conservatively treats all plant equipment required to achieve and maintain safe and stable plant conditions as "Required for Hot Shutdown." The "important to SSD cable/component" classification is not utilized.
Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NFPA 805 NSPC Equipment List is maintained as Attachment 8 to Report R2165-004-001. This data is also contained within the NSCA database. The NFPA 805 NSPC Equipment List identifies the required hot standby position and cold shutdown position for each component. In accordance with Appendix H of NEI 00-01, a component in the NFPA 805 NSPC Equipment List that has a listed position for hot standby is defined to be "Required for Hot Shutdown." Cables that are required for the proper operation of such components are also understood to be "Required for Hot Shutdown." If affected in a fire area analysis, resolutions to equipment failures are addressed in Attachment 14 to Report R2165-004-001.
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        Section 10.0; Attachments 8 and 14 Page B-97

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodolocgv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                      NEI 00-01 Guidance 3.4.1.5 Criteria/Assumptions       Use operator manual actions where appropriate, for cable/component impacts classified as important to SSD cable/components, to achieve and maintain post-fire safe shutdown conditions in accordance with NRC requirements (refer to Appendix E). For additional criteria to be used when determining whether an operator manual action may be used for a flow diversion off of the primary flow path, refer to Appendix H.
Aoelicability                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis
,Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.4.1.5 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 3.0 of Report R2165-004-001:
For NFPA 805, OMAs to achieve and maintain "safe and stable" plant conditions are not allowed by the separation requirements of NFPA 805, Section 4.2.3, with respect to demonstrating the NSPC of NFPA 805 Section 1.5.1 are met. Recovery actions (RA) may be credited to achieve and maintain "safe and stable" plant conditions provided that they are evaluated per the risk-informed, performance based (RI-PB) requirements of NFPA 805 Section 4.2.4, and determined to be feasible and reliable.
From Section 13.2 of Report R2165-004-001:
- The deterministic NSCA for each "resolved" fire area in SAFE may rely on SAFE equipment and/or cable resolutions. Additional details regarding SAFE equipment and cables resolution is provided in this section of [Report R2165-004-001].
- SAFE equipment resolutions identify and provide a traceable link for each component failure on a fire area basis that requires further engineering justification to be determined acceptable as-is (i.e., not having any adverse impact to the NSCA), or that requires further engineering review to identify and PROPOSE a plant change such as an OMA, or a physical plant modification. Each equipment resolution includes descriptive text fields in SAFE to document the engineering review basis.
- SAFE cable resolutions identify and provide a traceable link for protected cables in the fire area (i.e., protected by ERFBS, embedded with evaluation, routed in buried ductbanks through one or more manhole). Each cable resolution includes descriptive text fields in SAFE to document the engineering review basis.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Page B-98
* 0                                                               0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Comments None Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 3.0 and 13.0 (Subsection 13.2)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Attachment 3 Circuit Analysis Page B-99

Pacific Gas and Electric Company                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                   NEI 00-01 Guidance 3.4.1.6 Criteria/Assumptions   Where appropriate to achieve and maintain cold shutdown within 72 hours, use repairs to equipment required in support of post-fire shutdown.
Applicability                  Comments Not Applicable                  PG&E Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment.
This criteria / assumption listed in Section 3.4.1.6 of NEI 00-01 is explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2.1 of Report R2165-004-001:
                               - The NFPA 805 NSPC requires the licensee to demonstrate that the plant can achieve and maintain a "safe and stable" condition, but it does not explicitly require the licensee to demonstrate that cold shutdown can be achieved within 72 hours and maintained indefinitely thereafter. The DCPP NFPA 805 NSPC analysis has defined the "safe and stable" condition as being able to achieve and maintain Hot Standby until such time as the plant can either transition to Cold Shutdown, or can safely return to power operation.
                               "Safe and stable" for DCPP is defined in Section 8.6, Definition of "Safe and Stable" Plant Conditions for DCPP, of Report R2165-004-001.
From Section 8.6 of Report R2165-004-001:
The objective of the NFPA 805 NSCA as documented in [Report R2165-004-001] is to demonstrate that DCPP can achieve and maintain Hot Standby conditions following a significant and challenging fire event using either deterministic or performance based methods of NFPA 805. The NSCA, including supporting calculations, documents this assessment of fire impact on DCPP plant systems and features required to achieve and maintain Hot Standby from at power conditions. The NSCA replaces the post-fire safe shutdown compliance assessment for each area that was previously assessed to determine compliance with 10 CFR 50, Appendix R, Section Ili.G.
From Section 13.2.1 of Report R2165-004-001:
The capability to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown has been analyzed in the DCPP NSCA. OMAs and repair activities necessary to transition to Cold Shutdown, and to achieve and maintain Cold Shutdown have been identified in [Report R2165-004-001], and have been qualitatively assessed to ensure their feasibility in consideration of the "safe and stable" conditions for the plant; however, these operator actions and repair activities are not required to demonstrate that the NSPC "safe and stable" plant conditions defined for the DCPP have been met, are not identified as VFDRs, and are not implemented into the plant operations fire response procedures).
The 72-hour requirement from NEI 00-01 is only applicable to the 10 CFR 50 Appendix R licensing basis. The DCPP NSCA model does include plant systems / functions / components required for the transition from Hot Standby to Cold Shutdown, and the achievement and maintenance of Cold Shutdown. However, these plant systems / functions / components are not required for the NSCA, and are not credited in the plant operations fire response procedures.
Alignment Statement Not Applicable Page B-100

0                                                                           0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Alianment Basis Not Applicable Comments Not Applicable Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 3.0, 8.0 (Subsection 8.6), and 13.0 (Subsection 13.2.1)
Page B-101

0Ga Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                   NEI 00-01 Guidance 3.4.1.7 Criteria/Assumptions    For the components on the required safe shutdown path classified as required hot shutdown components as defined in Appendix H, Appendix R compliance requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage (llI.G.l.a). When cables or equipment are within the same fire area outside primary containment and separation does not already exist, provide one of the following means of separation for the required safe shutdown components impacted circuit(s):
                                - Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area by a fire barrier having a 3-hour rating (lIl.G.2.a)
                                - Separation of cables and equipment and associated nonsafety circuits of redundant trains within the same fire area by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (lll.G.2.b).
                                - Enclosure of cable and equipment and associated nonsafety circuits of one redundant train within a fire area in a fire barrier having a one-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (IIl.G.2.c).
For fire areas inside non-inerted containments, the following additional options are also available:
                                - Separation of cables and equipment and associated nonsafety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards (Ill.G.2.d);
                                - Installation of fire detectors and an automatic fire suppression system in the fire area (Ill.G.2.e); or
                                - Separation of cables and equipment and associated nonsafety circuits of redundant trains by a noncombustible radiant energy shield (llI.G.2.f).
Use exemptions, deviations, LARs and licensing change processes to satisfy the requirements mentioned above and to demonstrate equivalency depending upon the plant's license requirements.
Apolicabilitv                   Comments Applicable                      None Alianment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.4.1.7 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
Page B-1 02

0 Pacific Gas and Electric Companv                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Caoabilitv Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA.805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0, 8.0 (Subsection 8.5), and 13.0 (Subsection 13.2)
Page B-103

9 Comnanv                                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Revie Pacific Gas and ElectricAttachment                 - NEI 04-02 Table B-2 Nuclear        B Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                    NEI 00-01 Guidance 3.4.1.8 Criteria/Assumptions     Consider selecting other equipment that can perform the same safe shutdown function as the impacted equipment. In addressing this situation, each equipment impact, including spurious operation, is to be addressed in accordance with regulatory requirements and the NPP's current licensing basis. With respect to MSOs, the criteria in Section 4, Appendix B, Appendix G and Appendix H should be used.
Aoolicabilitv                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection and fire area assessment. The criteria / assumptions listed in Section 3.4.1.8 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, and Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 10.0 of Report R2165-004-001:
The purpose of NSCA model development and component selection activity is to create an accurate plant model that represents the NSPC requirements from NFPA 805, Section 1.5.1. The NSCA model must identify and include plant systems / functions / components that are required to actively function in order satisfy the NSPC requirements. The NSCA model also must identify include plant systems / functions / components that are not required to actively function, but whose mal-operation (i.e., spurious operation), alone or in combination, could be adverse to meeting the NSPC requirements. The plant model should, within constraints of complexity and cost, maximize the diversity and number of potential success paths that are available to satisfy the NSPC requirements.
From Section 13.2 of Report R2165-004-001:
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- The NSCA compliance strategy for these "resolved" fire areas in SAFE typically credits the least affected success path. This strategy for "resolution" generally involves the resolution of supporting functions first (i.e., electrical distribution, cooling water, etc.), followed by resolution of the supported front line systems / functions / components (i.e.,
Reactivity Control, Inventory Control, etc.).
Comments None Reference Documents                                                                                                                Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                 Sections 3.0, 8.0 (Subsection 8.5), 10.0, and 13.0 Page B-1 04

Pacific Gas and Electric Company                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment (Subsection 13.2)
Page B-105

Pacific Gas and Electric Comoanv                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safetv CaDability Assessment Methodolociv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                    NEI 00-01 Guidance 3.4.1.9 Criteria/Assumptions     Consider the effects of the fire on the density of the fluid in instrument tubing and any subsequent effects on instrument readings or signals associated with the protected safe shutdown path in evaluating post-fire safe shutdown capability. This can be done systematically or via procedures such as Emergency Operating Procedures (EOP).
Applicability                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA model development and component selection and fire area assessment. This criteria / assumption listed in Section 3.4.1.9 of NEI 00-01 is explicitly stated in the report.
From Section 10.6 of Report R2165-004-001:
Calculation SAP No. 9000039969 (Legacy No. M-1 126), 10 CFR 50 Appendix R - Instrument Sensing Line Analysis, Revision 0, documents the evaluation of fire impacts on instrument sense lines. The evaluation of instrument sense lines in Calculation SAP No. 9000039969 (Legacy No. M-1 126) is based on Calculation SAP No. 9000039526 (Legacy No. M-680), 10 CFR 50 Appendix R Safe Shutdown Equipment, Revision 17, and was developed in support for the 10 CFR 50, Appendix R licensing basis.
Calculation SAP No. 9000039969 (Legacy No. M-1 126) was reviewed to ensure that its methodology and results demonstrate the achievement of the NSPC of NFPA 805 with respect to instrument sensing tubing lines per the requirements/guidance of NFPA 805, 2001 Edition, Section B.2.1.(e) and NEI 00-02, Revision 2, Sections 3.2.1.2, 3.2.2.3, and 3.4.1.9. The calculation was found to be bounding with regard to the instrumentation credited to achieve the NFPA 805 NSPC for Process Monitoring.
From Section 13.2.1 of Report R2165-004-001:
"When resolving component and cable failures the analyst is required to consider, and address as necessary, the potential impact resulting from the following:
" Heating of instrument tubing sensing lines resulting in erroneous or unreliable signals from NSCA analyzed instrumentation (refer to Section 10.6 of [Report R2165-004-001])
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Sections 3.0, 10.0 (Subsection 10.6), and 13.0 (Subsection 13.2.1)
PG&E Calculation SAP No. 9000039969 (Legacy No. M-1 126), Part 000, Version 00, 10 CFR 50 Appendix R -                       None Instrument Sensing Line Analysis Page B-106

SG                                                                               0 Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                  NEI 00-01 Guidance 3.4.2 Methodology for Fire     Refer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.
Area Assessment Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:
Applicabilite                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                          Document Details Not Applicable                                                                                                               Not Applicable Page B-107

iG                                                                                    0 Pacific Gas and Electric Company                                       Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                     NEI 00-01 Guidance 3.4.2.1 Identify the Affected     Identify the safe shutdown cables, equipment and systems located in each fire area that may be potentially damaged by the fire. Provide this Equipment by Fire Area            information in a report format. The report may be sorted by fire area and by system in order to understand the impact to each safe shutdown path within each fire area (see Attachment 5 for an example of an Affected Equipment Report).
ApDlicabilitv                      Comments Applicable                         None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results, identifies the overall process utilized to perform deterministic fire area assessment and the fire area assessment results for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
From Section 13.2 of Report R2165-004-001:
- An initial deterministic analysis is run with the SAFE database tool for each fire area (or analysis area). The initial fire area analysis assumes that all NSCA equipment and NSCA cables physically located inthe fire area fail to their worst case condition or state.
- The SAFE analysis structure and results for each fire area are displayed on the computer screen as a tree structure beginning with performance goals on the left leading to system logic. The system logic display shows all equipment inevery success path. This tree structure diagram of the SAFE model shows the results of the analysis in the following way:
"Failed equipment, cables, systems, and performance goals (displayed in red text)
"Resolved equipment, cables, systems (displayed in blue text, with check mark)
"Design Change logics, if applicable (displayed in bold text)
* All items that show with black text are unaffected by the initial failures used inthis analysis "The following hardcopy reports are available in SAFE for each deterministic analysis area:
" Status of Goals - a list of all NSCA performance goals, identifies each NSCA performance goal as useable or failed "Status of Systems by Goals - identifies the NSCA systems associated with each NSCA performance goal as useable or failed, identifies each NSCA performance goal as useable or failed "Status of Systems - a list of all NSCA systems, identifies each NSCA system as useable or failed "Status of Safe Shutdown Equipment - a list of all NSCA components, identifies each component as useable, failed, or resolved; for each failed NSCA component, identifies the Page B-108

0Ga Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment failed equipment-to-equipment logic success path (i.e., support component) and failed equipment-to-cable logic success path (i.e., required cable), as applicable; for each resolved NSCA component, identifies the equipment resolution
- Status of Safe Shutdown Equipment by System - identifies the NSCA components associated with each NSCA system as useable, failed, or resolved, identifies each NSCA system as useable or failed; for each failed NSCA component, identifies the failed equipment-to-equipment logic success path (i.e., support component) and failed equipment-to-cable logic success path (i.e., required cable), as applicable; for each resolved NSCA component, identifies the equipment resolution "Failed Safe Shutdown Cables - a list of all NSCA cables in the fire area, identifies each cable as useable, failed, or recovered "Failed Safe Shutdown Cables, Fire Zone Location inthis Analysis - a list of all NSCA cables in the fire area, identifies the fire zone(s) each cable is contained within, inside the fire area "Analysis Cables status for this analysis - identifies the NSCA cables in the fire area as useable, failed, or resolved; for each resolved NSCA cable, identifies the cable resolution "Resolutions used inthis analysis - a list of all resolved NSCA components followed by a list of all resolved NSCA cables (for cables inthe fire area); for each resolved NSCA component, identifies the equipment resolution; for each resolved NSCA cable, identifies the cable resolution Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Section 13.0 (Subsection 13.2)
Page B-109

0 Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                   NEI 00-01 Guidance 3.4.2.2 Determine the           Based on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are either unaffected or least Shutdown Paths Least            impacted by a postulated fire within the fire area. Typically, the safe shutdown path with the least number of cables and equipment in the fire area Impacted By a Fire in Each      would be selected as the required safe shutdown path. Consider the circuit failure criteria and the possible mitigating strategies, however, in Fire Area                       selecting the required safe shutdown path in a particular fire area. Review support systems as a part of this assessment since their availability will be important to the ability to achieve and maintain safe shutdown. For example, impacts to the electric power distribution system for a particular safe shutdown path could present a major impediment to using a particular path for safe shutdown. By identifying this early in the assessment process, an unnecessary amount of time is not spent assessing impacts to the frontline systems that will require this power to support their operation. Determine which components are required hot shutdown components and which components are important to SSD components using the guidance in Appendix H.
Based on an assessment as described above, designate the required safe shutdown path(s) for the fire area. Classify the components on the required safe shutdown path necessary to perform the required safe shutdown functions as required safe shutdown components. Identify all equipment not in the safe shutdown path whose spurious operation or mal-operation could affect the shutdown function. Criteria for classifying these components as required for hot shutdown or as important to SSD is contained in Appendix H. Include the affected cables in the shutdown function list. For each of the safe shutdown cables (located in the fire area) that are part of the required safe shutdown path in the fire area, perform an evaluation to determine the impact of a fire-induced cable failure on the corresponding safe shutdown equipment and, ultimately, on the required safe shutdown path.
When evaluating the safe shutdown mode for a particular piece of equipment, it is important to consider the equipment's position for the specific safe shutdown scenario for the full duration of the shutdown scenario. It is possible for a piece of equipment to be in two different states depending on the shutdown scenario or the stage of shutdown within a particular shutdown scenario. Document information related to the normal and shutdown positions of equipment on the safe shutdown equipment list.
ADolicabilitv                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results, identifies the overall process utilized to perform deterministic fire area assessment and the fire area assessment results for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
From Section 13.2 of Report R2165-004-001:
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- The NSCA compliance strategy for these "resolved" fire areas in SAFE typically credits the least affected success path. This strategy for "resolution" generally involves the Page B-110

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W W!dy Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment resolution of supporting functions first (i.e., electrical distribution, cooling water, etc.), followed by resolution of the supported front line systems / functions I components (i.e.,
Reactivity Control, Inventory Control, etc.).
- The deterministic NSCA for each "resolved" fire area in SAFE may rely on SAFE equipment and/or cable resolutions. Additional details regarding SAFE equipment and cables resolution is provided in this section of [Report R2165-004-001].
- SAFE equipment resolutions identify and provide a traceable link for each component failure on a fire area basis that requires further engineering justification to be determined acceptable as-is (i.e., not having any adverse impact to the NSCA), or that requires further engineering review to identify and PROPOSE a plant change such as an OMA, or a physical plant modification. Each equipment resolution includes descriptive text fields in SAFE to document the engineering review basis.
- SAFE cable resolutions identify and provide a traceable link for protected cables in the fire area (i.e., protected by ERFBS, embedded with evaluation, routed in buried ductbanks through one or more manhole). Each cable resolution includes descriptive text fields in SAFE to document the engineering review basis.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
The NSCA database generated hardcopy reports and other supplemental reports created to document the final "resolved" assessment for each fire area are included in 4 of Report R2165-004-001. These reports identify the credited success path for each NSPC performance goal.
NSCA component position information is identified in the NFPA 805 NSPC Equipment List (Attachment 8 of Report R2165-004-001), and in the NSCA database.
Comments None Reference Documents                                                                                                                Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                  Sections 8.0 (Subsection 8.5), 10.0, and 13.0 (Subsection 13.2); Attachments 8 and 14 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                               Attachment 3 Circuit Analysis Page B-1Il

S                                                                                        0                                                                                 0 Pacific Gas and Electric Company                                         Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                    NEI 00-01 Guidance 3.4.2.3 Determine Safe           Using the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment that can impact safe shutdown Shutdown Equipment               and that can potentially be impacted by a fire in the fire area, and what those possible impacts are.
Impacts AoDlicabilitv                     Comments Applicable                        None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results, identifies the overall process utilized to perform deterministic fire area assessment and the fire area assessment results for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
From Section 13.2 of Report R2165-004-001:
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC ina given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- The NSCA compliance strategy for these "resolved" fire areas in SAFE typically credits the least affected success path. This strategy for "resolution" generally involves the resolution of supporting functions first (i.e., electrical distribution, cooling water, etc.), followed by resolution of the supported front line systems / functions / components (i.e.,
Reactivity Control, Inventory Control, etc.).
- The deterministic NSCA for each "resolved" fire area in SAFE may rely on SAFE equipment and/or cable resolutions. Additional details regarding SAFE equipment and cables resolution is provided in this section of [Report R2165-004-001].
- SAFE equipment resolutions identify and provide a traceable link for each component failure on a fire area basis that requires further engineering justification to be determined acceptable as-is (i.e., not having any adverse impact to the NSCA), or that requires further engineering review to identify and PROPOSE a plant change such as an OMA, or a physical plant modification. Each equipment resolution includes descriptive text fields in SAFE to document the engineering review basis.
- SAFE cable resolutions identify and provide a traceable link for protected cables inthe fire area (i.e., protected by ERFBS, embedded with evaluation, routed in buried ductbanks through one or more manhole). Each cable resolution includes descriptive text fields in SAFE to document the engineering review basis.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Page B-112

iGs a0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Comments None Reference Documents                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 3.0, 8.0 (Subsection 8.5), 11.0, and 13.0 (Subsection 13.2)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Attachment 3 Circuit Analysis Page B-113

Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                  NEI 00-01 Guidance 3.4.2.4 Develop a              The available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Figure 1-1):
Compliance Strategy or Disposition to Mitigate the    Required for Hot Shutdown Components:
Effects Due to Fire Damage to Each Required               - Re-design the circuit or component to eliminate the concern. This option will require a revision to the post-fire safe shutdown analysis.
Component or Cable
                               - Re-route the cable of concern. This option will require a revision to the post-fire safe shutdown analysis.
                               - Protect the cable in accordance with III.G.2.
                               - Provide a qualified 3-fire rated barrier.
                               - Provide a 1-hour fire rated barrier with automatic suppression and detection.
                               - Provide separation of 20 feet or greater with automatic suppression and detection and demonstrate that there are no intervening combustibles within the 20 foot separation distance.
                               - Perform a cold shutdown repair in accordance with regulatory requirements.
                               - Identify other equipment not affected by the fire capable of performing the same safe shutdown function.
                               - Develop exemptions, deviations, LARs, Generic Letter 86-10 evaluation or fire protection design change evaluations with a licensing change process.
Important to Safe Shutdown Components:
                               - Any of the options provided for required for hot shutdown components.
                               - Perform and operator manual action in accordance with Appendix E.
                               - Address using fire modeling or a focused-scope fire PRA using the methods of Section 5 for MSO impacts. [Note: The use of fire modeling will require a review by the Expert Panel and the use of a focused-scope fire PRA will require a LAR.]
Additional options are available for non-inerted containments as described in 10 CFR 50 Appendix R section III.G.2.d, e and f.
Aoolicabilitv                  Comments Applicable                     None Alignment Statement Aligns Alionment Basis Page B-114

Pacific Gas and Electric Company                                          Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results, identifies the overall process utilized to perform deterministic fire area assessment and the fire area assessment results for the NSCA components identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
From Section 13.2 of Report R2165-004-001:
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- The NSCA compliance strategy for these "resolved" fire areas in SAFE typically credits the least affected success path. This strategy for "resolution" generally involves the resolution of supporting functions first (i.e., electrical distribution, cooling water, etc.), followed by resolution of the supported front line systems / functions / components (i.e.,
Reactivity Control, Inventory Control, etc.).
- The deterministic NSCA for each "resolved" fire area in SAFE may rely on SAFE equipment and/or cable resolutions. Additional details regarding SAFE equipment and cables resolution is provided in this section of [Report R2165-004-001].
- SAFE equipment resolutions identify and provide a traceable link for each component failure on a fire area basis that requires further engineering justification to be determined acceptable as-is (i.e., not having any adverse impact to the NSCA), or that requires further engineering review to identify and PROPOSE a plant change such as an OMA, or a physical plant modification. Each equipment resolution includes descriptive text fields in SAFE to document the engineering review basis.
- SAFE cable resolutions identify and provide a traceable link for protected cables in the fire area (i.e., protected by ERFBS, embedded with evaluation, routed in buried ductbanks through one or more manhole). Each cable resolution includes descriptive text fields in SAFE to document the engineering review basis.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage.
- SAFE equipment resolutions that propose OMAs are identified as "separation issues," and VFDRs. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
The NSCA database generated hardcopy reports and other supplemental reports created to document the final "resolved" assessment for each fire area are included in 4 of Report R2165-004-001. These reports identify the credited success path for each NSPC performance goal.
Comments None Reference Documents                                                                                                                Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                                  Sections 8.0 (Subsection 8.5) and 13.0 Subsection 13.2);
Attachment 14 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                              Attachment 3 Page B-1IS

P                                                              04 Pacific Gas and Electric Company                    Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment Circuit Analysis Page B-116

0 Pacific Gas and Electric Companv                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Caoabilitv Assessment Methodoloov Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                   NEI 00-01 Guidance 3.4.2.5 Document the            Assign compliance strategy statements or codes to components or cables to identify the justification or mitigating actions proposed for achieving Compliance Strategy or          safe shutdown. The justification should address the cumulative effect of the actions relied upon by the licensee to mitigate a fire in the area.
Disposition Determined to       Provide each piece of safe shutdown equipment, equipment not in the path whose spurious operation or mal-operation could affect safe shutdown, Mitigate the Effects Due to     and/or cable for the required safe shutdown path with a specific compliance strategy or disposition. Refer to Attachment 6 for an example of a Fire Fire Damage to Each             Area Assessment Report documenting each cable disposition.
Required Component or Cable At)olicability                  Comments Applicable                      None Alignment Statement Aligns Alianment Basis The methodology for assigning compliance strategies (i.e., creating equipment and cable resolutions in the NSCA database) is consistent with the prescribed method (see the Alignment Basis for Item 3.4.2.2).
Comments None Reference Documents                                                                                                       Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                         Sections 8.0 (Subsection 8.5), 10.0, and 13.0 (Subsection 13.2); Attachments 8 and 14 Page B-117

0 Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqy Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.5 Circuit Analysis and       This section on circuit analysis provides information on the potential impact of fire on circuits used to monitor, control and power required for hot Evaluation                     shutdown and important to safe shutdown equipment. Applying the circuit analysis criteria will lead to an understanding of how fire damage to the cables may affect the ability to achieve and maintain post-fire safe shutdown in a particular fire area. This section should be used in conjunction with Section 3.4, to evaluate the potential fire-induced impacts that require mitigation. Additionally, when assessing fire-induced damage to circuits that could potentially result in MSOs, the circuit failure criteria in Appendix B should be used.
Appendix R Section II.G.2 identifies the fire-induced circuit failure types that are to be evaluated for impact from exposure fires on safe shutdown equipment. Section II.G.2 of Appendix R requires consideration of hot shorts, shorts-to-ground and open circuits.
Applicability                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                         Document Details Not Applicable                                                                                                              Not Applicable Page B-118

O Pacific Gas and Electric Company                                  Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Capabilitv Assessment Methodoloov Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.5.1 Criteria/Assumptions     Apply the following criteria/assumptions when performing fire-induced circuit failure evaluations. Refer to the assessment of the NEI/EPRI and CAROLFIRE Cable Test Results in Appendix B to this document for the basis for these criteria and for further elaboration on the application of the criteria.
Aoolicabilitv                  Comments Applicable                     None Alianment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                       Document Details Not Applicable                                                                                                            Not Applicable Page B-119

S                                                                                    9                                                                                  0 Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                   NEI 00-01 Guidance 3.5.1.1 Circuit Failure         Circuit Failure Criteria: The criteria provided below addresses the effects of multiple fire-induced circuit failures impacting circuits for components Criteria                        classified as either "required for hot shutdown" or "important to safe shutdown". Consider the following circuit failure types on each conductor of each unprotected cable. Criteria differences, however, do apply depending on whether the component is classified as required for hot shutdown or important to safe shutdown.
                                - A hot short may result from a fire-induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage or signal on a specific conductor. A hot short may cause a spurious operation of safe shutdown equipment.
                                - A hot short inthe control circuitry for a motor operated valve (MOV) can bypass the MOV protective devices, i.e. torque and limit switches. This is the condition described in NRC Information Notice 92-18. In this condition, the potential exists to damage the MOV motor and/or valve. Damage to the MOV could result in an inability to operate the MOV either remotely, using separate controls with separate control power, or manually using the MOV hand wheel. This condition could be a concern intwo instances: (1) For fires requiring Control Room evacuation and remote operation from the Remote Shutdown Panel, the Auxiliary Control Panel or Auxiliary Shutdown Panel; (2) For fires where the selected means of addressing the effects of fire induced damage is the use of an operator manual action. In each case, analysis must be performed to demonstrate that the MOV can be subsequently operated electrically or manually, as required by the safe shutdown analysis.
                                - An open circuit may result from a fire-induced break ina conductor resulting in the loss of circuit continuity. An open circuit may prevent the ability to control or power the affected equipment. An open circuit may also result in a change of state for normally energized equipment. (e.g. [for BWRs]
loss of power to the Main Steam Isolation Valve (MSIV) solenoid valves due to an open circuit will result in the closure of the MSIVs). [Note: Open circuits as a result of conductor melting have not occurred in any of the recent cable fire testing and they are not considered to be a viable form of cable failure.]
                                - A short-to-ground may result from a fire-induced breakdown of a cable insulation system, resulting in the potential on the conductor being applied to ground potential. A short-to-ground may have all of the same effects as an open circuit and, inaddition, a short-to-ground may also cause an impact to the control circuit or power train of which it is a part. A short-to-ground may also result in a change of state for normally energized equipment.
Applicabilitv                   Comments Applicable                      None Alianment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.1 of NEI 00-01 are explicitly stated inthe report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
Page B-120

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Caoability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions), Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Report R2165-004-001, Section 10.9, USNRC Information Notice (IN) 92-18, addresses concerns of MOV inoperability that result from energization of an MOV with the valve limit /
torque switches bypassed due to fire damage to the MOV control cable(s).
Comments None Reference Documents                                                                                                      Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                        Sections 3.0, 10.0 (Subsection 10.9), 11.0, and 13.0 (Subsection 13.2)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                     Attachment 3 Circuit Analysis Page B-121

Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                    NEI 00-01 Guidance 3.5.1.1 Circuit Failure          Circuits for "required for hot shutdown" components: Because Appendix R Section III.G.1 requires that the hot shutdown capability remain "free of Criteria                         fire damage", there is no limit on the number of concurrent/simultaneous fire-induced circuit failures that must be considered for circuits for components "required for hot shutdown: located within the same fire area. For components classified as "required for hot shutdown", there is no limit on the duration of the hot short. It must be assumed to exist until an action is taken to mitigate its effects. Circuits required for the operation of or that can cause the mal-operation of "required for hot shutdown" components that are impacted by a fire are considered to render the component unavailable for performing its hot shutdown function unless these circuits are properly protected as described in the next sentence. The required circuits for any "required for hot shutdown" component, if located within the same fire area where they are credited for achieving hot shutdown, must be protected in accordance with one of the requirements of Appendix R Section III.G.2 or plant specific license conditions.
Applicability                     Comments Applicable                         None Alignment Statement Aligns Alianment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.1 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
- SAFE documents the final NSCA compliance strategy for each fire area of the plant by demonstrating that at least one success path is "free of fire damage" and available to meet the NSPC of NFPA 805 (for the DCPP "safe and stable" definition as provided in Section 8.6 of [Report R2165-004-001]). The term "free of fire damage" represents that the separation requirements of NFPA 805, Section 4.2.3, have been met.
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
Page B-122

0 Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capabilitv Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis The NFPA 805 NSPC Equipment List is maintained as Attachment 8 to Report R2165-004-001. This data is also contained within the NSCA database. The NFPA 805 NSPC Equipment List identifies the required hot standby position and cold shutdown position for each component. In accordance with Appendix H of NEI 00-01, a component in the NFPA 805 NSPC Equipment List that has a listed position for hot standby is defined to be "Required for Hot Shutdown." Cables that are required for the proper operation of such components are also understood to be "Required for Hot Shutdown."
DCPP conservatively treats all plant equipment required to achieve and maintain safe and stable plant conditions as "Required for Hot Shutdown." The "important to SSD cable/component" classification is not utilized.
Comments None Reference Documents                                                                                                    Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                      Sections 3.0, 8.0 (Subsections 8.5 and 8.6), 10.0, 11.0, and 13.0 (Subsection 13.2); Attachment 8 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                   Attachment 3 Circuit Analysis Page B-123

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Vnn X                            Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.5.1.1 Circuit Failure        Circuits for "important to safe shutdown" components: Circuits for components classified as "important to safe shutdown" are not specifically Criteria                       governed by the requirements of Appendix R Section III.G. 1, III.G.2 or III.G.3. To address fire-induced impacts on these circuits, consider the three types of circuit failures identified above to occur individually on each conductor with the potential to impact any "important to safe shutdown" component with the potential to impact components "required for hot shutdown". In addition, consider the following additional circuit failure criteria for circuits for "important to safe shutdown" components located within the same fire area with the potential to impact components "required for hot shutdown":
                              - As explained in Figure 3.5.2-3, multiple shorts-to-ground are to be evaluated for their impact on ungrounded circuits.
                              - As explained in Figure 3.5.2-5, for ungrounded DC circuits, a single hot short from the same source is assumed to occur unless it can be demonstrated that the occurrence of a same source short is not possible in the affected fire area. If this approach is used, a means to configuration control this condition must be developed and maintained.
                              - For the double DC break solenoid circuit design discussed in the NRC Memo from Gary Holahan, Deputy Director Division of Systems Technology, dated December 4, 1990 and filed under ML062300013, the effect of two hot shorts of the proper polarity in the same multi-conductor cable should be analyzed for non-high low pressure interface components. [Reference Figure B.3.3 (f) of NFPA 805-2001.]
                              - Multiple spurious operations resulting from a fire-induced circuit failure affecting a single conductor must be included in the post-fire safe shutdown analysis.
                              - Multiple fire-induced circuit failures affecting multiple conductors within the same multi-conductor cable with the potential to cause a spurious operation of an "important to safe shutdown" component must be assumed to exist concurrently.
                              - Multiple fire-induced circuit failures affecting separate conductors in separate cables with the potential to cause a spurious operation of an "important to safe shutdown" component must be assumed to exist concurrently when the effect of the fire-induced circuit failure is sealed-in or latched.
                              - Conversely, multiple fire-induced circuit failures affecting separate conductors in separate cables with the potential to cause a spurious operation of an "important to safe shutdown" component need not be assumed to exist concurrently when the effect of the fire-induced circuit failure is not sealed-in or latched. This criterion applies to consideration of concurrent hot shorts in secondary circuits and to their effect on a components primary control circuit. It is not to be applied to concurrent single hot shorts in primary control circuit for separate components in an MSO combination.
                              - For components classified as "important to safe shutdown", the duration of a hot short may be limited to 20 minutes. (If the effect of the spurious actuation involves a "sealing in" or "latching" mechanism, that is addressed separately from the duration of the spurious actuation, as discussed above.)
                              - For any impacted circuits for "important to safe shutdown" components that are located within the same fire area, protection in accordance with the requirements of Appendix R Section III.G.2 or plant specific license conditions may be used. In addition, consideration may be given to the use of fire modeling or operator manual actions, as an alternative to the requirements of Appendix R Section III.G.2. (Other resolution options may also be acceptable, if accepted by the Authority Having Jurisdiction.)
Apolicabilitv                 Comments Page B-124

0     1.r. I--  mnrJ =]&#xfd;&#xfd;fri&#xfd; Ptm      an                             Afttachment B - NEFI 04A..02 Tahbgi B-29 Nuuphe2r     2foh, C~2 2h.ilhi Acanaamanf RAnthneinin,          PAL19U Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Applicable                        None Alignment Statement Aligns Aliqnment Basis Report R2165-004-001, Section 3.0, NSCA Criteria / Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.1 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
- SAFE documents the final NSCA compliance strategy for each fire area of the plant by demonstrating that at least one success path is "free of fire damage" and available to meet the NSPC of NFPA 805 (for the DCPP "safe and stable" definition as provided in Section 8.6 of [Report R2165-004-001]). The term "free of fire damage" represents that the separation requirements of NFPA 805, Section 4.2.3, have been met.
- Where the initial SAFE analysis run identifies that there is no success path available to satisfy the NSPC in a given fire area, then subsequent iterations of the SAFE analysis is required, as necessary, to recover ("resolve") at least one success path to satisfy the NSPC in the given fire area. Separation requirements for the deterministic approach to demonstrate the NSPC are identified from NFPA 805, Section 4.2.3, and are provided in Section 8.5 of [Report R2165-004-001]. These requirements must be satisfied for the fire area to be deterministically compliant.
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
Report R2165-004-001, Section 10.0, NSCA Model Development and Component Selection, identifies the overall process utilized to identify the combinations of plant components for each plant system that is identified as being required to satisfy each of the NSPC from Section 1.5.1 of NFPA 805.
The NFPA 805 NSPC Equipment List is maintained as Attachment 8 to Report R2165-004-001. This data is also contained within the NSCA database. The NFPA 805 NSPC Equipment List identifies the required hot standby position and cold shutdown position for each component. In accordance with Appendix H of NEI 00-01, a component in the NFPA 805 NSPC Equipment List that has a listed position for hot standby is defined to be "Required for Hot Shutdown." Cables that are required for the proper operation of such components are also understood to be "Required for Hot Shutdown."
DCPP conservatively treats all plant equipment required to achieve and maintain safe and stable plant conditions as "Required for Hot Shutdown." The "important to SSD cable/component" classification is not utilized.
Comments None Reference Documents                                                                                                          Document Details Page B-125

Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Sections 3.0, 8.0 (Subsections 8.5 and 8.6), 10.0, 11.0, Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013 and 13.0 (Subsection 13.2); Attachment 8 PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Attachment 3 Circuit Analysis Page B-126

Comnanv                                Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Pacific Gas and ElectricAttachment             B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                    NEI 00-01 Guidance 3.5.1.2 Spurious Operation       Spurious Operation Criteria: The following criteria address the effect of multiple spurious operations of components classified as either "required Criteria                         for hot shutdown" or "important to safe shutdown" on post-fire safe shutdown. These criteria are to be applied to the population of components whose spurious operation has been determined to be possible based on an application of the circuit failure criteria described above when assessing impacts to post-fire safe shutdown capability in any fire area.
                                 - The set of concurrent combinations of spurious operations provided through the MSO Process outlined in Section 4 and the list of MSO contained in Appendix G must be included in the analysis of MSOs.
                                 - MSOs do not need to be combined, except as explained in Section 4.4.3.4 of this document.
Section 4.4.3.4 states that the expert panel should review the plant specific list of MSOs to determine whether any of the individual MSOs should be combined due to the combined MSO resulting in a condition significantly worse than either MSO individually.
                                 - In this review, consideration of key aspects of the MSOs should be factored in, such as the overall number of spurious operations in the combined MSOs, the circuit attributes in Appendix B, and other physical attributes of the scenarios.
                                 - Specifically, if the combined MSOs involve more than a total of four components or if the MSO scenario requires consideration of sequentially selected cable faults of a prescribed type, at a prescribed time, in a prescribed sequence in order for the postulated MSO combination to occur, then this is considered to be beyond the required design basis for MSOs.
Aoplicability                    Comments Applicable                       None Alignment Statement Aligns Alignment Basis Report R2165-004-001, Section 10.7, Multiple Spurious Operation, references the overall process utilized to identify and evaluate multiple spurious operations concerns that potentially impact each of the NSPC from Section 1.5.1 of NFPA 805.
The treatment of multiple spurious operations for the NFPA 805 NSCA is documented in Attachment 11 to Report R2165-004-001.
Subsequent to the completion of the review and evaluation of fire-induced multiple spurious operations at DCPP, FAQ 07-0038, Revision 3 (ML110140242) was issued. The results of the review and evaluation process were reviewed against FAQ 07-0038, Revision 3, and it was determined that no revision to the results were required.
Comments None Reference Documents                                                                                                          Document Details Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                            Section 10.0 (Subsection 10.7); Attachment 11 Page B-127

Pacific Gas and Electric Company PAttachment                                             B - NEI 04-02 Table B-2 Nuclear Safety Capabilitv Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                     NEI 00-01 Guidance 3.5.1.3 Criteria/Assumptions      Assume that circuit contacts are initially positioned (i.e., open or closed) consistent with the normal mode/position of the "required for hot shutdown" or "important to safe shutdown" equipment as shown on the schematic drawings. The analyst must consider the position of the "required for hot shutdown" and "important to safe shutdown" equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the "required for hot shutdown" and "important to safe shutdown equipment".
Applicability                     Comments Applicable                        None Alianment Statement Aligns Alignment Basis Report R2165-004-001, Section 3.0, NSCA Criteria /Assumptions, lists criteria / assumptions pertaining to the NSCA fire area assessment. The criteria / assumptions listed in Section 3.5.1.3 of NEI 00-01 are explicitly stated in the report.
Report R2165-004-001, Section 3.0, identifies the criteria / assumptions utilized in Report R2165-004-001, Section 13.0, Deterministic Fire Area Assessment and Results.
From Section 13.2 of Report R2165-004-001:
- Circuit analysis may be utilized to assess and disposition specific circuit failures modes (as documented in the SAFE equipment resolutions). Circuit analysis conforms to the criteria / assumptions identified in Section 3.0 and Section 11.0 of [Report R2165-004-001]. The circuit analysis may discount spurious operation based on a fire affected cable being routed in a dedicated conduit, and therefore being protected from external sources of voltage. to Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Appendix R Blocked Conduits, documents cables that are routed in dedicated conduits, and are therefore protected from external sources of voltage.
The following are related criteria/assumptions in the DCPP Licensing Basis Documents that together, meet the intent of this specific criteria/assumption:
- Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1, provide circuit analysis criteria with respect to consideration of the normal position and required function of each SSD component for which circuit analysis/cable selection will be performed.
- Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.4, provides circuit analysis criteria with respect to taking credit for circuit isolation devices (i.e., open contacts, fuses, blocking diodes, etc.).
- Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.4, provides circuit analysis criteria with respect to considering the impact of circuit interlocks and permissives on the required SSD function of the associated component.
Comments None Reference Documents                                                                                                             Document Details Page B-128
* 0                                                                       0 Pacific Gas and Electric Company                             Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                        Sections 3.0, 11.0, and 13.0 (Subsection 13.2)
PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition     Section 5.0 (Subsections 5.1 and 5.1.2.4); Attachment 3 Circuit Analysis Page B-129

Pacific Gas and Electric Comoanv                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloqv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                  NEI 00-01 Guidance 3.5.2 Types of Circuit         Appendix R requires that nuclear power plants must be designed to prevent exposure fires from defeating the ability to achieve and maintain post-Failures                       fire safe shutdown. Fire damage to circuits that provide control and power to equipment required for hot shutdown and important to safe shutdown in each fire area must be evaluated for the effects of a fire in that fire area. Only one fire at a time is assumed to occur. The extent of fire damage is assumed to be limited by the boundaries of the fire area. Given this set of conditions, it must be assured that one redundant train of equipment necessary to achieve and maintain hot shutdown is free of fire damage for fires in every plant location. To provide this assurance, Appendix R requires that equipment and circuits required for hot shutdown be free of fire damage and that these circuits be designed for the fire-induced effects of a hot short, short-to-ground, or an open circuit. With respect to the electrical distribution system, the issue of breaker coordination must also be addressed. Criteria for making the determination as to which breakers are to be classified as required for hot shutdown is contained in Appendix H.
This section will discuss specific examples of each of the following types of circuit failures:
                               - Open circuit
                               - Short-to-ground
                               - Hot short Also, refer to Appendix B for the circuit failure criteria to be applied in assessing the impact of the Plant Specific List of MSOs on post-fire safe shutdown.
ApDlicabilitv                  Comments Applicable                     None Alignment Statement Not Required Alignment Basis Detailed alignment discussed in subsequent reference paragraphs.
Comments Not Applicable Reference Documents                                                                                                          Document Details Not Applicable                                                                                                               Not Applicable Page B-130

0                                                                                  0                                                                                     4P Pacific Gas and Electric Company Attachment B - NEI 04-02 Table B-2 Nuclear Safetv Canabilitv Assessment Methodoloov Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                   NEI 00-01 Guidance 3.5.2.1 Circuit Failures Due    This section provides guidance for addressing the effects of an open circuit for required for hot shutdown and important to safe shutdown to an Open Circuit              equipment. An open circuit is a fire-induced break in a conductor resulting in the loss of circuit continuity. An open circuit will typically prevent the ability to control or power the affected equipment. An open circuit can also result in a change of state for normally energized equipment. For example, a loss of power to the main steam isolation valve (MSIV) solenoid valves [for BWRs] due to an open circuit will result in the closure of the MSIV.
                                - Loss of electrical continuity may occur within a conductor resulting in de-energizing the circuit and causing a loss of power to, or control of, the required for hot shutdown and important to safe shutdown equipment.
                                - In selected cases, a loss of electrical continuity may result in loss of power to an interlocked relay or other device. This loss of power may change the state of the equipment. Evaluate this to determine if equipment fails safe.
                                - Open circuit on a high voltage (e.g., 4.16 kV) ammeter current transformer (CT) circuit may result in secondary damage, possibly resulting in the occurrence of an additional fire in the location of the CT itself.
Figure 3.5.2-1 shows an open circuit on a grounded control circuit.
Open circuit No. 1:
An open circuit at location No. 1 will prevent operation of the subject equipment.
Open circuit No. 2:
An open circuit at location No. 2 will prevent opening/starting of the subject equipment, but will not impact the ability to close/stop the equipment.
Atnlicabilitv                   Comments Applicable                      None Alianment Statement Aligns Alianment Basis The following DCPP Documents address NFPA 805 NSPC circuit analysis criteria with respect to Circuit Failures Due to an Open Circuit.
* Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.3
* Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Section 7.5
* Report R2165-004-001, Section 3.0
* Report R2165-004-001, Attachment 15: Procedure P1890-004-002 The above documents require that open circuits be assumed in the circuit analysis for AC and DC power cables, control and indication cables, and instrumentation cables.
Page B-131

0                                                                                 0
* Pacific Gas and Electric Company                                 Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Section 7.5, also provides a qualitative assessment of the impact of fire induced open circuits on the secondary windings of current transformers with respect to adverse impact upon SSD.
The DCPP methodology for analysis of circuit failures due to an open circuit is in alignment with NEI 00-01 guidance.
Comments None Reference Documents                                                                                                   Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                  Section 5.0 (Subsection 5.1.2.3)
Circuit Analysis Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                     Section 3.0; Attachment 15 PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                      Section 7.0 (Subsection 7.5)
Analysis - Fire Protection Page B-132

0                                                                                                                                                                        wa Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                   NEI 00-01 Guidance 3.5.2.2 Circuit Failures Due    This section provides guidance for addressing the effects of a short-to-ground on circuits for required for hot shutdown and important to safe to a Short-to-Ground            shutdown equipment. A short-to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential. A short-to-ground can cause a loss of power to or control of required safe shutdown equipment. In addition, a short-to-ground may affect other equipment in the electrical power distribution system inthe cases where proper coordination does not exist.
There is no limit to the number of shorts-to-ground that could be caused by the fire.
Consider the following consequences in the post-fire safe shutdown analysis when determining the effects of circuit failures related to shorts-to-ground:
                                - A short to ground in a power or a control circuit may result in tripping one or more isolation devices (i.e. breaker/fuse) and causing a loss of power to or control of required safe shutdown equipment.
                                - In the case of certain energized equipment such as HVAC dampers, a loss of control power may result in loss of power to an interlocked relay or other device that may cause one or more spurious operations.
Short-to-Ground on Grounded Circuits:
Typically, inthe case of a grounded circuit, a short-to-ground on any part of the circuit would present a concern for tripping the circuit isolation device thereby causing a loss of control power.
Figure 3.5.2-2 illustrates how a short-to-ground fault may impact a grounded circuit.
Short-to-ground No. 1:
A short-to-ground at location No. 1 will result in the control power fuse blowing and a loss of power to the control circuit. This will result in an inability to operate the equipment using the control switch. Depending on the coordination characteristics between the protective device on this circuit and upstream circuits, the power supply to other circuits could be affected.
Short-to-ground No. 2:
A short-to-ground at location No. 2 will have no effect on the circuit until the close/stop control switch is closed. Should this occur, the effect would be identical to that for the short-to-ground at location No. 1 described above. Should the open/start control switch be closed prior to closing the close/stop control switch, the equipment will still be able to be opened/started.
Short-to-Ground on Ungrounded Circuits:
In the case of an ungrounded circuit, postulating only a single short-to-ground on any part of the circuit may not result in tripping the circuit isolation device. Another short-to-ground on the circuit or another circuit from the same source would need to exist to cause a loss of control power to the circuit.
Figure 3.5.2-3 illustrates how a short to ground fault may impact an ungrounded circuit.
Page B-133

0Ga Pacific Gas and Electric Company                                   Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Short-to-ground No. 1:
A short-to-ground at location No. 1 will result in the control power fuse blowing and a loss of power to the control circuit ifshort-to-ground No. 3 also exists either within the same circuit or on any other circuit fed from the same power source. This will result in an inability to operate the equipment using the control switch. Depending on the coordination characteristics between the protective device on this circuit and upstream circuits, the power supply to other circuits could be affected. If multiple grounds can occur in a single fire area, they should be assumed to occur simultaneously unless justification to the contrary is provided.
Short-to-ground No. 2:
A short-to-ground at location No. 2 will have no effect on the circuit until the close/stop control switch is closed. Should this occur, the effect would be identical to that for the short-to-ground at location No. 1 described above. Should the open/start control switch be closed prior to closing the close/stop control switch, the equipment will still be able to be opened/started. If multiple grounds can occur ina single fire area, they should be assumed to occur simultaneously unless justification to the contrary is provided. Note that a simultaneous short-to-ground at locations No. 1 and No. 2 could result in a spurious close/stop. This condition is identical to that portrayed in Figure 3.5.2-5 should a hot short occur on the ungrounded circuit shown in Figure 3.5.2-5 at location No. 1.
Applicability                Comments Applicable                    None Alianment Statement Aligns Alianment Basis The following DCPP Documents address NFPA 805 NSPC circuit analysis criteria with respect to Circuit Failures Due to a Short-to-Ground.
"Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Section 5.1.2.1 "Report R2165-004-001, Section 3.0 "Report R2165-004-001, Attachment 15: Procedure P1890-004-002 The above documents require that shorts to ground be assumed inthe circuit analysis for AC power cables, control and indication cables, and instrumentation cables.
The DCPP methodology for analysis of circuit failures due to an open circuit is in alignment with NEI 00-01 guidance.
Comments None Reference Documents                                                                                                        Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                       Section 5.0 (Subsection 5.1.2.1)
Circuit Analysis Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                          Section 3.0; Attachment 15 Page B-134

Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis NEI 00-01 Ref                   NEI 00-01 Guidance 3.5.2.3 Circuit Failures Due    This section provides guidance for analyzing the effects of a hot short on circuits for required for required for hot shutdown and important to safe to a Hot Short                  shutdown equipment. A hot short is defined as a fire-induced insulation breakdown between conductors of the same cable, a different cable or some other external source resulting in an undesired impressed voltage on a specific conductor. The potential effect of the undesired impressed voltage would be to cause equipment to operate or fail to operate in an undesired manner.
Consider the following specific circuit failures related to hot shorts as part of the post-fire safe shutdown analysis:
                                - A hot short between an energized conductor and a de-energized conductor within the same cable may cause a spurious operation of equipment.
The spuriously operated device (e.g., relay) may be interlocked with another circuit that causes the spurious operation of other equipment. This type of hot short is called an intra-cable hot short (also known as conductor-to-conductor hot short or an internal hot short).
                                - A hot short between any external energized source such as an energized conductor from another cable and a de-energized conductor may also cause a spurious operation of equipment. This is called an inter-cable hot short (also known as cable-to-cable hot short/external hot short).
                                - A hot short in the control circuitry for an MOV can bypass the MOV protective devices, i.e. torque and limit switches. This is the condition described in NRC Information Notice 92-18. In this condition, MOV motor damage can occur. Damage to the MOV motor could result in an inability to operate the MOV either remotely, using separate controls with separate control power, or manually using the MOV hand wheel. This condition could be a concern in two instances: (1) For fires requiring Control Room evacuation and remote operation from the Remote Shutdown Panel; (2) For fires where the selected means of addressing the effects of fire induced damage is the use of an operator manual action. In this latter case, analysis must be performed to demonstrate that the MOV thrust at motor failure does not exceed the capacity of the MOV hand wheel. For either case, analysis must demonstrate the MOV thrust at motor failure does not damage the MOV pressure boundary.
A Hot Short on Grounded Circuits:
A short-to-ground is another failure mode for a grounded control circuit. A short-to-ground as described above would result in de-energizing the circuit. This would further reduce the likelihood for the circuit to change the state of the equipment either from a control switch or due to a hot short. Nevertheless, a hot short still needs to be considered. Figure 3.5.2-4 shows a typical grounded control circuit that mightbe used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted, since these devices are not required to understand the concepts being explained in this section. In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot shorts depicted.
The following discussion describes the impact of these individual cable faults on the operation of the equipment controlled by this circuit.
Hot short No. 1:
A hot short at this location would energize the close relay and result in the undesired closure of a motor-operated valve.
Hot short No. 2:
A hot short at this location would energize the open relay and result in the undesired opening of a motor-operated valve.
A Hot Short on Ungrounded Circuits:
Page B-135

Pacific Gas and Electric Company                                     Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis In the case of an ungrounded circuit, a single hot short may be sufficient to cause a spurious operation. A single hot short can cause a spurious operation ifthe hot short comes from a circuit from the positive leg of the same ungrounded source as the affected circuit.
In reviewing each of these cases, the common denominator is that in every case, the conductor inthe circuit between the control switch and the start/stop coil must be involved.
Figure 3.5.2-5 depicted below shows a typical ungrounded control circuit that might be used for a motor-operated valve. However, the protective devices and position indication lights that would normally be included in the control circuit for a motor-operated valve have been omitted, since these devices are not required to understand the concepts being explained in this section.
In the discussion provided below, it is assumed that a single fire in a given fire area could cause any one of the hot shorts depicted. The discussion provided below describes the impact of these cable faults on the operation of the equipment controlled by this circuit.
Hot short No. 1:
A hot short at this location from the same control power source would energize the close relay and result inthe undesired closure of a motor operated valve.
Hot short No. 2 A hot short at this location from the same control power source would energize the open relay and result inthe undesired opening of a motor operated valve.
Applicabilitv                    Comments Applicable                        None Alianment Statement Aligns Alignment Basis The following DCPP documents address NFPA 805 NSPC circuit analysis criteria with respect to Circuit Failures Due to a Hot Short.
* Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Sections 5.1.2.2 and 5.1.2.4
* Report R2165-004-001, Section 3.0
* Report R2165-004-001, Attachment 15: Procedure P1890-004-002 The above documents require that hot shorts (originating from energized sources external to the affected cable) and wire-to-wire shorts (between conductors inthe same cable) be assumed in the circuit analysis for 120VAC and 125VDC power cables, control and indication cables, and instrumentation cables.
Consistent with past NRC guidelines for circuit failure modes as identified in NRC Generic Letter 86-10, dated April 24, 1986, Enclosure 2, Question/Answer 5.3.1., circuit failure modes are defined as hot shorts, open circuits, and shorts to ground. Proper phase 3-phase AC hot shorts only require to be postulated for high/low pressure interface valves, and proper polarity "+ to +" and "-to -"DC hot shorts only require to be postulated for high/low pressure interface valves.
Page B-136

PG                                                                                      0 Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Report R2165-004-001, Section 10.9, USNRC Information Notice (IN)92-18, addresses concerns of MOV inoperability that result from energization of an MOV with the valve limit /
torque switches bypassed due to fire damage to the MOV control cable(s).
The DCPP methodology for analysis of circuit failures due to an open circuit is in alignment with NEI 00-01 guidance.
Comments Note: Calculation SAP No. 9000041072 (Legacy No. 134-DC-T) does not consider the following failure mode to be credible.
From Section 5.1.2.4 of Calculation SAP No. 9000041072 (Legacy No. 134-DC-T):
Fire-induced insulation damage to shielded instrument cables on the output were not considered for hot shorts that could drive the instrument loop output high because:
: 1. The shielded instrument cable is far more likely to have an internal short shunting current from the end device causing it to fail low
: 2. A hot short, if it did penetrate the shield, would blow the output fuse of the rack and fail the output low
: 3. A hot short, to drive the output high, would have to be of the same polarity, from the same power source, and of the correct low signal strength (a smart short) that is considered highly unlikely to occur in a fire. See DCM T-19 Section 4.3.1.
: 4. These instrument cables are twisted and shielded and most probably will have an internal hot short. Once the shielded instrument cable has an internal hot short, the instrument loop output will be low with or without an external hot short. In summary, for instrument rack shielded output cables, hot shorts were considered but determined to disable the instrument loop failing the circuit low. Smart hot shorts that penetrate shielded cables driving output circuits high were not considered due to the reasons explained above. This is consistent with DCM T-1 9 Section 4.3.1.
Reference Documents                                                                                                         Document Details PG&E Calculation SAP No. 9000041072 (Legacy No. 134-DC-T), Part 000, Version 02, NFPA 805 Transition                        Section 5.0 (Subsections 5.1.2.2 and 5.1.2.4)
Circuit Analysis Report R2165-004-001, Nuclear Safety Capability Assessment, Revision 0, June 2013                                           Sections 3.0 and 10.0 (Subsection 10.9); Attachment 15 Design Criteria Memorandum (DCM) T-19, "Electrical Separation and Isolation," Revision 11                                   Section 4.0 (Subsection 4.3.1)
Page B-137

0 CLUI.C. %. t1_01,01 all A C1 0%,
4 *. 11 1 %,   WAINVally                            Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodologv Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location NEI 00-01 Ref                               NEI 00-01 Guidance 3.5.2.4 Circuit Failures Due                The evaluation of circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load to Inadequate Circuit                       breakers/fuses for power sources that are required for hot shutdown. The concern is that, for fire damage to a single power cable, lack of Coordination                                coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.
To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.
A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus. Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.
The methodology for identifying potential circuits of a common power source and evaluating circuit coordination cases on a single circuit fault basis is as follows:
                                           - Identify the power sources required to supply power to safe shutdown equipment.
                                           - For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.
                                           - For each power source, demonstrate proper circuit coordination using acceptable industry methods. For example, for breakers that have internal breaker tripping devices and do not require control power to trip the breaker, assure that the time-current characteristic curve for any affected load breaker is to the left of the time-current characteristic curve for the bus feeder breaker and that the available short circuit current for each affected breaker is to the right of the time-current characteristic curve for the bus feeder breaker or that the bus feeder breaker has a longer time delay in the breaker instantaneous range than the load breaker. For breakers requiring control power for the breaker to trip, the availability of the required control power must be demonstrated in addition to the proper alignment of the time-current characteristic curves described above. The requirement for the availability of control power would apply to load breakers fed from each safe shutdown bus where a fire-induced circuit failure brings into questions the availability of coordination for a required for hot shutdown component.
                                           - For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the circuit of concern are routed and the power source is required for hot shutdown. Prepare a list of the following information for each fire area:
                                           - Cables of concern.
                                           - Affected common power source and its path.
                                           - Raceway in which the cable is enclosed.
Page B-138

P0 Ga Pacific Gas and Electric Company                                      Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B         - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location
                                   - Sequence of the raceway inthe cable route.
                                   - Fire zone/area in which the raceway is located.
For fire zones/areas inwhich the power source is disabled, the effects are mitigated by appropriate methods.
                                   - Develop analyzed safe shutdown circuit dispositions for the circuit of concern cables routed in an area of the same path as required by the power source. Evaluate adequate separation and other mitigation measures based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.
Apolicability                      Comments Applicable                          None Alignment Statement Aligns Alignment Basis Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) assesses coordination including DC control power for all switchgear credited for safe shutdown including NPO equipment.
Sections 7.1.1 and 7.1.2 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) provides coordination for 12kV, 4kV, 480V, 125VDC, 120VAC power supplies for DCPP Unit 1 and Unit 2.
This assessment is supported by the following site Electrical Design Calculations:
"154C-DC, 154D-DC and 154G-DC (12kV)
"114-DC, 115-DC, 160-DC, 170-DC and 181A-DC (4kV)
"93C-DC, 101C-DC, 195A-DC, 195B-DC, 195C-DC, 195D-DC, 202-DC, 207A-DC, 207B-DC, 387A-DC and 387B-DC (480V)
"93C-DC, 101C-DC, 333-DC (Sec 0 to IV), 333A-DC, 333B-DC and 334-DC (120VAC)
"234A-DC, 234B-DC, 234C-DC, 234D-DC, 234E-DC, 234F-DC, 333-DC (Sec 0 to IV), 334-DC, 334A-DC, 3348-DC (125VDC)
It is further noted that as part this review, over-current trip concerns were also reviewed and addressed by including the DC control power cables and individual load cables for all switchgear credited for safe shutdown in SAFE. This allows the model to recognize ifDC control tripping capability exists should a fire-induced short to ground occur on the associated cables. Therefore, a loss of DC control power results ina loss of that switchgear. The analyst further recognizes that the protective relaying may not be available.
Section 8 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) indicates satisfactory coordination except for three cases, two of which were identified as common power supply associated circuits of concern for MCC 12J and MCC 22N.
The DCPP methodology is in alignment with NEI 00-01 guidance.
Comments None Reference Documents                                                                                                          Document Details Page B-139

0                                                                        0                                                                     0 Pacific Gas and Electric Company                          Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT      Sections 7.0 (Subsections 7.1.1 and 7.1.2) and 8.0 Analysis - Fire Protection Page B-140

0 Pnt-ifie-III I-Z&#xfd;a gO nnA
                *llg Plot-trie-bl*Ll   I*
(nm VVIIIUglIV nn                            Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodoloav Review Attachment B - NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location NEI 00-01 Ref                       NEI 00-01 Guidance 3.5.2.5 Circuit Failures Due        The common enclosure concern deals with the possibility of causing secondary failures due to fire damage to a circuit either whose isolation device to Common Enclosure                 fails to isolate the cable fault or protect the faulted cable from reaching its ignition temperature, or the fire somehow propagates along the cable into Concerns                            adjoining fire areas.
The electrical circuit design for most plants provides proper circuit protection in the form of circuit breakers, fuses and other devices that are designed to isolate cable faults before ignition temperature is reached. Adequate electrical circuit protection and cable sizing are included as part of the original plant electrical design maintained as part of the design change process. Proper protection can be verified by review of as-built drawings and change documentation. Review the fire rated barrier and penetration designs that preclude the propagation of fire from one fire area to the next to demonstrate that adequate measures are in place to alleviate fire propagation concerns.
Applicability                       Comments Applicable                          None Alignment Statement Aligns Alignment Basis Section 7.3 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) evaluates Common Enclosure Associated Circuits including sizing of cable and protective devices.
Section 7.3 of Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T) provides a qualitative assessment of the Common Enclosure concern for DCPP Units 1 and 2. The overall conclusion of this assessment is that the design criteria, DCM T-19, Electrical Separation and Isolation, effectively precludes Circuit Failures Due to Common Enclosure Concerns (with two exceptions that are analyzed in Attachment G to Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T)).
Overall, the DCPP methodology for analysis of Circuit failures Due to Common Enclosure Concerns is in alignment with NEI 00-01, Section 3.5.
The DCPP methodology is in alignment with NEI 00-01 guidance.
Comments None Reference Documents                                                                                                                Document Details PG&E Calculation SAP No. 9000041048 (Legacy No. 134A-DC-T), Part 000, Version 00, Associated CKT                                   Section 7.0 (Subsection 7.3)
Analysis - Fire Protection Design Criteria Memorandum (DCM) T-1 9, Electrical Separation and Isolation, Revision 11                                           None Page B-141

Pacific Gas and Electric Company                 Attachment E - Radioactive Release Transition E. NEI 04-02 Radioactive Release Transition 161 Pages Page E-1

Pacific God    Electric Company                                                S                                    Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire       Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description     Plan   Rev. In?           Water                          Smoke               Plan Review Results               Conclusions 1      1    1-A    Containment   RA-26   05/03    Yes   During Plant Operation:      Containment ventilation      Training materials reinforce Based on the availability of Annulus Area  RA-27   05/03          Floor drains are routed to   systems include              use of PFPs and Casualty     engineering controls for RA-28   05/03          the monitored Liquid         Containment fan coolers,     Procedure CP M-6, "Fire"     both smoke and fire Radwaste System (LRS).       Iodine removal units, and    for containment and          suppression water runoff Units 1 and 2 share a        Containment Purge Supply     monitoring of potential      and use of revised PFPs common LRS, except for       and Exhaust System. All      radioactive effluents. PFP   and training materials, equipment located inside     radioactive atmospheres      revisions will identify      DCPP's approach will be containment. The wastes      are monitored for            potentially contaminated     considered acceptable to are collected in the         radioactivity concentration  areas, provide instruction   meet NFPA 805 Containment sump and         during normal operations,    for communication with       radioactive release are released to the          anticipated transients, and  Radiation Protection and     performance criteria.
environment at either of     accident conditions by the   describe precautions to be the units circulating water  Radiation Monitoring         undertaken for the           The results documenting system discharge             System (RMS). High           containment and safe         conformance to NFPA 805 structures via the Auxiliary radiation in any of these    removal of contaminated      radioactive release criteria Saltwater (ASW) System.      areas in monitored in the    smoke and water runoff in    will be maintained as part The ASW System and           Control Room. Accidental     these potentially            of DCPP's Configuration Main Circulating Water       releases from Containment    contaminated areas.          Control Program. This System dilute the            are monitored by the         Training material and PFP    program will ensure that collected waste. The         Process and Effluent         revisions will describe the  the radioactive release effluents are continuously   Radiological Monitoring      presence and potential use   goals, objective and monitored and require        System. For all conditions,  of monitored ventilation     performance criteria will positive operator action to  the RMS is capable of        and drainage systems, if     continue to be satisfied be released into the         isolating or diverting lines such systems are deemed      when considering the environment.                 containing gaseous activity  operational and capable of   possibility that areas that when activity levels reach a supporting manual removal    were not contaminated at During Non Power             preset limit.                efforts. The level of detail the time of NFPA 805 Operations (NPO): Floor                                   provided in the revised      transition, and were drains as described above During Normal Operation: training materials and              consequently screened-remain present.              Five fan cooler units are    PFPs will meet NFPA 805      out, may become provided in Containment to radioactive release            contaminated fin the future Provisions are in place to recirculate and cool the       performance criteria.        due to plant operational commence                     containment atmosphere                                    events.
communication between        during normal operation      Implementation Item S-the Fire Brigade and         and following a design       3.19 - PFPs and training     Implementation Item S-Radiation Protection and basis accident (DBA).            materials will be revised to 3.20 - The NFPA 805 to contain/monitor liquid                                 address radioactive          radioactive release review effluents prior to safe      Each Containment building release requirements of         will be incorporated into removal.                     is provided with two Iodine NFPA 805. See NFPA 805        DCPP's Configuration removal units consisting of Transition Report             Control Program. See a recirculation fan          Attachment S, Table S-3. NFPA 805 Transition complete with roughing                                    Report Attachment 5, filter, HEPA filter, and                                  Table S-3.
charcoal filter on the fan suction. These units are Page E-2

Pacific G   nd Electric Company                                       0                                    Attachment E - Radioactive Release   nsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened            Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?        Water                     Smoke               Plan Review Results        Conclusions operated as required during normal operation to control airborne iodine and particulate concentrations in the containment atmosphere.
During NPO: The Containment Purge Supply and exhaust system includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header in the Containment and exhausts it to the plant vent where it is released to the atmosphere at the top of the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it is reasonable to anticipate that any fire condition Page E-3

Pacific Go   d Electric Company                                                                          Attachment E - Radioactive Release4    sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened            Engineering Controls                   Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?        Water                    Smoke              Plan Review Results        Conclusions would be quickly detected and reported to the Control Room using the plant communication system. In addition, the Reactor Coolant Pumps (RCPs) and associated oil supply are considered the largest potential fire contributor, however, due to the fact that these pumps and motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment, which results inradiological consequences, are considered negligible.
Furthermore, it is expected that the volume of Containment is sufficiently large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8.DC54.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation Page E-4

Pacific God     Electric Company                                               a                                   Attachment E - Radioactive Releaseasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                        Smoke                 Plan Review Results              Conclusions techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1    1-B     Reactor       RA-26  05/03    Yes   During Plant Operation:     Containment ventilation      Training materials reinforce Based on the availability of Steam         RA-27  05/03          Floor drains are routed to  systems include              use of PFPs and Casualty     engineering controls for Generator     RA-28  05/03          the monitored LRS. Units    Containment fan coolers,     Procedure CP M-6, "Fire"     both smoke and fire Area                                1 and 2 share a common      Iodine removal units, and    for containment and          suppression water runoff LRS, except for             Containment Purge Supply     monitoring of potential      and use of revised PFPs equipment located inside    and Exhaust System. All      radioactive effluents. PFP   and training materials, containment. The wastes     radioactive atmospheres      revisions will identify      DCPP's approach will be are collected in the        are monitored for            potentially contaminated     considered acceptable to Containment sump and        radioactivity concentration  areas, provide instruction   meet NFPA 805 are released to the         during normal operations,    for communication with       radioactive release environment at either of    anticipated transients, and  Radiation Protection and     performance criteria.
the units circulating water accident conditions by the   describe precautions to be system discharge            RMS. High radiation in any   undertaken for the           The results documenting structures via the ASW      of these areas in monitored  containment and safe         conformance to NFPA 805 System. The ASW System      in the Control Room.         removal of contaminated      radioactive release criteria and Main Circulating        Accidental releases from     smoke and water runoff in    will be maintained as part Water System dilute the     Containment are monitored    these potentially            of DCPP's Configuration collected waste. The        by the process and effluent  contaminated areas.          Control Program. This effluents are continuously  radiological monitoring      Training material and PFP    program will ensure that monitored and require       system. For all conditions,  revisions will describe the  the radioactive release positive operator action to the RMS is capable of        presence and potential use   goals, objective and be released into the        isolating or diverting lines of monitored ventilation     performance criteria will environment.                containing gaseous activity  and drainage systems, if     continue to be satisfied when activity levels reach a such systems are deemed      when considering the During NPO: Floor drains    preset limit.                operational and capable of   possibility that areas that as described above                                       supporting manual removal    were not contaminated at remain present.             During Normal Operation: efforts. The level of detail     the time of NFPA 805 Five fan cooler units are    provided in the revised      transition, and were Provisions are in place to  provided in Containment to training materials and         consequently screened-Page E-5

Pacific Gad    Electric Companv                                             0                                    Attachment E - Radioactive Releaseensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire    Fire Zone   Pre-Fire      Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?          Water                        Smoke                Plan Review Results               Conclusions commence                   recirculate and cool the      PFPs will meet NFPA 805      out, may become communication between      containment atmosphere        radioactive release          contaminated in the future the Fire Brigade and       during normal operation       performance criteria.        due to plant operational Radiation Protection and   and following a DBA.                                       events.
to contain/monitor liquid                                Implementation Item S-effluents prior to safe    Each Containment building     3.19 - PFPs and training     Implementation Item S-removal.                   is provided with two Iodine   materials will be revised to 3.20 - The NFPA 805 removal units consisting of   address radioactive          radioactive release review a recirculation fan           release requirements of      will be incorporated into complete with roughing        NFPA 805. See NFPA 805       DCPP's Configuration filter, HEPA filter, and      Transition Report            Control Program. See charcoal filter on the fan    Attachment S, Table S-3. NFPA 805 Transition suction. These units are                                   Report Attachment S, operated as required                                       Table S-3.
during normal operation to control airborne iodine and particulate concentrations in the containment atmosphere.
During NPO: The Containment Purge Supply and exhaust system includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header in the Containment and exhausts it to the plant vent where it is released to the atmosphere at the top of the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, Page E-6

Pacific Gold Electric Company                                                                          Attachment E - Radioactive Releaseonsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire   Fire Zone  Pre-Fire      Screened            Engineering Controls                   Training and Pre-Fire Unit Area Zone   Description   Plan   Rev. In?        Water                    Smoke              Plan Review Results        Conclusions the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it is reasonable to anticipate that any fire condition would be quickly detected and reported to the Control Room using the plant communication system. In addition, the RCPs and associated oil supply are considered the largest potential fire contributor; however, due to the fact that these pumps and motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment which results in radiological consequences, are considered negligible.
Furthermore, it is expected that the volume of Containment is sufficiently large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment Page E-7

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                        Smoke                Plan Review Results               Conclusions hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8.DC54.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1-C    Reactor       RA-29  05/03    Yes   During Plant Operation:     Containment ventilation      Training materials reinforce Based on the availability of Cavity and    RA-30  05/03          Floor drains are routed to  systems include              use of PFPs and Casualty     engineering controls for Operating                           the monitored LRS. Units    Containment fan coolers,     Procedure CP M-6, "Fire"     both smoke and fire Deck                                1 and 2 share a common      Iodine removal units, and    for containment and          suppression water runoff LRS, except for             Containment Purge Supply monitoring of potential          and use of revised PFPs equipment located inside    and Exhaust System. All      radioactive effluents. PFP   and training materials, containment. The wastes     radioactive atmospheres      revisions will identify      DCPP's approach will be are collected in the        are monitored for            potentially contaminated     considered acceptable to Containment sump and        radioactivity concentration .areas, provide instruction   meet NFPA 805 are released to the         during normal operations, for communication with          radioactive release environment at either of    anticipated transients, and Radiation Protection and      performance criteria.
the units circulating water accident conditions by the describe precautions to be system discharge            RMS. High radiation in any undertaken for the             The results documenting structures via the ASW      of these areas in monitored containment and safe          conformance to NFPA 805 System. The ASW System      in the Control Room.         removal of contaminated      radioactive release criteria and Main Circulating        Accidental releases from     smoke and water runoff in    will be maintained as part Water System dilute the     Containment are monitored these potentially               of DCPP's Configuration Page E-8

Pacific Ged    Electric Company                                                                                   Attachment E - Radioactive Releaseonsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                         Smoke                 Plan Review Results              Conclusions collected waste. The        by the process and effluent   contaminated areas.          Control Program. This effluents are continuously radiological monitoring        Training material and PFP    program will ensure that monitored and require       system. For all conditions,   revisions will describe the  the radioactive release positive operator action to the RMS is capable of         presence and potential use goals, objective and be released into the        isolating or diverting lines  of monitored ventilation     performance criteria will environment.                containing gaseous activity   and drainage systems, if     continue to be satisfied when activity levels reach a  such systems are deemed when considering the During NPO: Floor drains preset limit.                    operational and capable of possibility that areas that as described above                                        supporting manual removal were not contaminated at remain present.             During Normal Operation:      efforts. The level of detail the time of NFPA 805 Five fan cooler units are     provided in the revised      transition, and were Provisions are in place to provided in Containment to     training materials and       consequently screened-commence                    recirculate and cool the      PFPs will meet NFPA 805      out, may become communication between       containment atmosphere        radioactive release          contaminated in the future the Fire Brigade and        during normal operation       performance criteria.        due to plant operational Radiation Protection and and following a DBA.                                          events.
to contain/monitor liquid                                 Implementation Item S-effluents prior to safe     Each Containment building     3.19 - PFPs and training     Implementation Item S-removal.                    is provided with two Iodine   materials will be revised to 3.20 - The NFPA 805 removal units consisting of   address radioactive          radioactive release review a recirculation fan           release requirements of      will be incorporated into complete with roughing        NFPA 805. See NFPA 805 DCPP's Configuration filter, HEPA filter, and      Transition Report            Control Program. See charcoal filter on the fan    Attachment S, Table S-3. NFPA 805 Transition suction. These units are                                   Report Attachment S, operated as required                                       Table S-3.
during normal operation to control airborne iodine and particulate concentrations in the containment atmosphere.
During NPO: The.
Containment Purge Supply and exhaust system includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header in the Containment and exhausts it to the plant vent where it Page E-9

Pacific Go   d Electric Company                                                                           Attachment E - Radioactive Releasee sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened           Engineering Controls                    Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?        Water                    Smoke               Plan Review Results        Conclusions is released to the atmosphere at the top of the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it is reasonable to anticipate that any fire condition would be quickly detected and reported to the Control Room using the plant communication system. In addition, the RCPs and associated oil supply are considered the largest potential fire contributor; however, due to the fact that these pumps and motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment which results in radiological consequences, are considered negligible.
Furthermore, it is expected Page E-1O

Pacific Go   d Electric Company                                              0                                  Attachment E - Radioactive Release~ sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                        Smoke               Plan Review Results             Conclusions that the volume of Containment is sufficiently large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8.DC54.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     2     Auxiliary     RA-5   05/03    Yes   Floor drains are routed to Each unit is served by a    Training materials reinforce Based on the availability of Boiler        RA-6   03/08         the monitored LRS. Each     similar but separate        use of PFPs and Casualty     engineering controls for floor drain flows into the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"     both smoke and fire Auxiliary Building (AB)     operate in either of two    for containment and          suppression water runoff sump. The collected         configurations, a normal    monitoring of potential      and use of revised PFPs Page E-11

Pacific God    Electric Company                                                                                    Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  PFre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan    Rev. In?          Water                         Smoke                 Plan Review Results              Conclusions wastes are released to the  configuration or an iodine    radioactive effluents. PFP   and training materials, environment at either of    removal configuration. The    revisions will identify      DCPP's approach will be the units circulating water difference between the        potentially contaminated     considered acceptable to system discharge            configurations is the         areas, provide instruction   meet NFPA 805 structures via the ASW      treatment of exhaust air. for communication with       radioactive release System. The ASW System      Each FHBVS contains two       Radiation Protection and     performance criteria.
and Main Circulating        full-capacity supply fans     describe precautions to be Water System dilute the     that collect air from along   undertaken for the           The results documenting collected waste. The        one side of the fuel pool,    containment and safe         conformance to NFPA 805 effluents are continuously  and discharge into duct       removal of contaminated      radioactive release criteria monitored and require       work in the corridors and     smoke and water runoff in    will be maintained as part positive operator action to equipment compartments        these potentially            of DCPP's Configuration be released into the        below the Spent Fuel Pool     contaminated areas.          Control Program. This environment.                (SFP).                        Training material and PFP    program will ensure that revisions will describe the  the radioactive release During NPO: Floor drains    During normal operation,      presence and potential use   goals, objective and as described above          one non-vital exhaust fan     of monitored ventilation     performance criteria will remain present.             is in operation and the air and drainage systems, if       continue to be satisfied is passed through a           such systems are deemed      when considering the Provisions are in place to  roughing and HEPA filter      operational and capable of   possibility that areas that commence                    before being discharged to supporting manual removal       were not contaminated at communication between       the plant vent. In the iodine efforts. The level of detail the time of NFPA 805 the Fire Brigade and        removal configuration,        provided in the revised      transition, and were Radiation Protection and    exhaust air passes through training materials and          consequently screened-to contain/monitor liquid   charcoal adsorbers in         PFPs will meet NFPA 805      out, may become effluents prior to safe     addition to roughing and      radioactive release          contaminated in the future removal.                    HEPA filters. Automatic       performance criteria.        due to plant operational initiation of the iodine                                   events.
removal configuration         Implementation Item S-occurs in response to high 3.19 - PFPs and training        Implementation Item S-radiation, as measured by materials will be revised to     3.20 - The NFPA 805 radiation monitors in the     address radioactive          radioactive release review Fuel Handling Building        release requirements of      will be incorporated into (FHB), or upon failure of     NFPA 805. See NFPA 805       DCPP's Configuration the normal operating          Transition Report            Control Program. See exhaust fan. Ventilation air Attachment S, Table S-3.      NFPA 805 Transition from areas containing                                      Report Attachment S, radioactive materials is                                   Table S-3.
exhausted through HEPA and/or charcoal filters.
During NPO: The ventilation and monitoring systems as described above remain present.
Page E-12

Pacific Gad     Electric Company                                              0                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                         Smoke               Plan Review Results              Conclusions If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     3-B-1 3-B-1   RHR Pump 1-   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system    Training materials reinforce Based on the availability of 1 and HX      RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Room                                AB is divided into several  supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere          for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the RHR sumps    building and to the          potentially contaminated     considered acceptable to that are normally           engineered safety feature    areas, provide instruction   meet NFPA 805 discharged to the floor     (ESF) pump compartments      for communication with       radioactive release drain receivers. The        whenever they are in         Radiation Protection and     performance criteria.
collected wastes are        operation. During normal     describe precautions to be released to the             operating conditions,        undertaken for the           The results documenting environment at either of    exhaust air is passed        containment and safe         conformance to NFPA 805 the units circulating water through a roughing filter    removal of contaminated      radioactive release criteria system discharge            and HEPA filter before       smoke and water runoff in    will be maintained as part structures via the ASW      entering the vent.           these potentially            of DCPP's Configuration System. The ASW System                                   contaminated areas.          Control Program. This and Main Circulating        Under accident conditions, Training material and PFP      program will ensure that Water System dilute the     the air is exhausted from    revisions will describe the  the radioactive release collected waste. The        the ESF pump                 presence and potential use   goals, objective and effluents are continuously  compartments and is          of monitored ventilation     performance criteria will monitored and require -     passed through a charcoal and drainage systems, if        continue to be satisfied positive operator action to filter in addition to the    such systems are deemed      when considering the Page E-13

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Releasessition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                       Smoke                  Plan Review Results              Conclusions be released into the        roughing and HEPA filters. operational and capable of   possibility that areas that environment.                Exhaust air from other       supporting manual removal    were not contaminated at portions of the building will efforts. The level of detail the time of NFPA 805 During NPO: Floor drains   continue to be passed         provided in the revised      transition, and were as described above         through roughing and          training materials and       consequently screened-remain present.            HEPA filters only. If only    PFPs will meet NFPA 805      out, may become one supply/exhaust fan set    radioactive release          contaminated in the future Provisions are in place to is available under accident   performance criteria.        due to plant operational commence                   conditions, exhaust air                                    events.
communication between      from areas other than the     Implementation Item S-the Fire Brigade and       ESF pump compartments         3.19 - PFPs and training     Implementation Item S-Radiation Protection and   will be isolated.             materials will be revised to 3.20 - The NFPA 805 to contain/monitor liquid                                address radioactive          radioactive release review effluents prior to safe    During NPO: The               release requirements of      will be incorporated into removal.                   ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible Page E-14

Pacific Gad     Electric Company                                                                                    Attachment E - Radioactive Releaselasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     3-B-2 3-B-2   RHR Pump 1-   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Bas.ed on the availability of 2 and HX      RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Room                                AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the RHR sumps    building and to the ESF       potentially contaminated     considered acceptable to that are normally           pump compartments             areas, provide instruction   meet NFPA 805 discharged to the floor     whenever they are in          for communication with       radioactive release drain receivers. The        operation. During normal      Radiation Protection and     performance criteria.
collected wastes are        operating conditions,         describe precautions to be released to the             exhaust air is passed         undertaken for the           The results documenting environment at either of    through a roughing filter     containment and safe         conformance to NFPA 805 the units circulating water and HEPA filter before        removal of contaminated      radioactive release criteria system discharge            entering the vent.            smoke and water runoff in    will be maintained as part structures via the ASW                                    these potentially            of DCPP's Configuration System. The ASW System      Under accident conditions, contaminated areas.             Control Program. This and Main Circulating        the air is exhausted from     Training material and PFP    program will ensure that Water System dilute the     the ESF pump                  revisions will describe the  the radioactive release collected waste. The        compartments and is           presence and potential use   goals, objective and effluents are continuously  passed through a charcoal of monitored ventilation         performance criteria will monitored and require       filter in addition to the     and drainage systems, if     continue to be satisfied positive operator action to roughing and HEPA filters. such systems are deemed         when considering the be released into the        Exhaust air from other        operational and capable of   possibility that areas that environment.                portions of the building will supporting manual removal    were not contaminated at continue to be passed         efforts. The level of detail the time of NFPA 805 During NPO: Floor drains    through roughing and          provided in the revised      transition, and were as described above          HEPA filters only. If only    training materials and       consequently screened-remain present.             one supply/exhaust fan set PFPs will meet NFPA 805         out, may become is available under accident radioactive release            contaminated inthe future Page E-1 5

Pacific Gad    glectric Company                                                                                 Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                        Smoke               Plan Review Results               Conclusions Provisions are in place to conditions, exhaust air      performance criteria.        due to plant operational commence                   from areas other than the                                 events.
communication between      ESF pump compartments        Implementation Item S-the Fire Brigade and       will be isolated.            3.19 - PFPs and training     Implementation Item S-Radiation Protection and                                materials will be revised to 3.20 - The NFPA 805 to contain/monitor liquid  During NPO: The              address radioactive          radioactive release review effluents prior to safe    ventilation and monitoring   release requirements of      will be incorporated into removal.                   systems as described         NFPA 805. See NFPA 805       DCPP's Configuration above remain present.        Transition Report            Control Program. See Attachment S, Table S-3. NFPA 805 Transition All radioactive                                           Report Attachment S, atmospheres are                                           Table S3.
monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade Page E-16

Pacific God     Electric Company                                                                                   Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                         Smoke                Plan Review Results              Conclusions and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     3-BB  3-BB    Containment   RA-9   05/03    Yes   Floor drains are routed to  The Containment              Training materials reinforce Based on the results of Penetration  RA-1 0  03/08          the monitored LRS. The      Penetration Area             use of PFPs and Casualty     DCPP Calculation Area                                AB is divided into several  ventilation system           Procedure CP M-6, "Fire"     9000041374 regarding drainage zones and each     (GE/GW - east and west of    for containment and          gaseous radioactive area within a zone is       column line "N",             monitoring of potential      release, the potential drained by several screen   respectively) contains two   radioactive effluents. PFP   availability of engineering outlets. Each floor drain   full capacity exhaust fans. revisions will identify      controls for both smoke flows into the AB sump. One of the two fans runs to  potentially contaminated     and fire suppression water The collected wastes are    exhaust air from the         areas, provide instruction   runoff, and use of revised released to the             GE/GW areas. The running     for communication with       PFPs and training environment at either of    fan maintains the GE/GW      Radiation Protection and     materials, DCPP's the units circulating water areas at a slight negative   describe precautions to be   approach will be system discharge
* pressure relative to the     undertaken for the           considered acceptable to structures via the ASW      outdoors to maintain         containment and safe         meet NEPA 805 System. The ASW System      smoke in the area of         removal of contaminated      radioactive release and Main Circulating        greater contamination        smoke and water runoff in    performance criteria.
Water System dilute the     potential. The other full    these potentially collected waste. The        capacity fan is provided so  contaminated areas.          The results documenting effluents are continuously  that failure of one fan will Training material and PFP    conformance to NFPA 805 monitored and require       not result in loss of        revisions will describe the  radioactive release criteria positive operator action to ventilation during normal    presence and potential use   will be maintained as part be released into-the        plant operation. The         of monitored ventilation     of DCPP's Configuration environment.                ventilation flow consists of and drainage systems, if     Control Program. This 100 percent outside air      such systems are deemed      program will ensure that During NPO: Floor drains    drawn through the intake     operational and capable of   the radioactive release as described above          louvers. Recirculation fans  supporting manual removal    goals, objective and remain present.             move the entrained air to    efforts. The level of detail performance criteria will the areas farthest from the  provided in the revised      continue to be satisfied Provisions are in place to  intake louver. The           training materials and       when considering the commence                    ventilation air flows to the PFPs will meet NFPA 805      possibility that areas that communication between       enclosed annular gap, into   radioactive release          were not contaminated at the Fire Brigade and        the duct connected to the    performance criteria.        the time of NFPA 805 Radiation Protection and    exhaust fan and is                                        transition, and were to contain/monitor liquid   discharged into the plant    Implementation Item S-       consequently screened-effluents prior to safe     vent, where it is monitored. 3.19 - PFPs and training     out, may become removal.                                                 materials will be revised to contaminated inthe future During NPO: The              address radioactive          due to plant operational ventilation and monitoring   release requirements of      events..
systems as described         NFPA 805. See NFPA 805 Page E-17

Pacific God    Electric Company                                       a                                    Attachment E - Radioactive Release           sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened           Engineering Controls                    Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?        Water                     Smoke               Plan Review Results           Conclusions above remain present.        Transition Report        Implementation Item S-Attachment S, Table S-3. 3.20 - The NFPA 805 If normal ventilation is                              radioactive release review unavailable, smoke has the                            will be incorporated into potential to exhaust to the                           DCPP's Configuration environment via ventilation                           Control Program. See louvers. However, DCPP                                NFPA 805 Transition Calculation 9000041374                                Report Attachment S, demonstrates that the                                 Table S-3.
gaseous effluent radioactive dose limits of 10 CFR 20 and plant TS will not be exceeded due to the effects of complete combustion of the worst-case "bounding" single dry active waste container, and subsequent fire suppression activities within the Owner Protected Area. As such, this calculation is "bounding" for this location and can be applied to demonstrate that any potential contaminated gaseous effluent release from this location is expected to be below 10 CFR 20 and plant technical specification limits. In addition, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide Page E-18

Pacific Gad     Electric Company                                               0                                   Attachment E - Radioactive Releasensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?            Water                        Smoke                Plan Review Results              Conclusions precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-CC  3-CC    Containment   RA-13  05/03    Yes   Floor drains are routed to  The Containment              Training materials reinforce Based on the results of Penetration   RA-14  03/08          the monitored LRS. The      Penetration Area             use of PFPs and Casualty     DCPP Calculation Area                                AB is divided into several  ventilation system           Procedure CP M-6, "Fire"     9000041374 regarding drainage zones and each     (GE/GW - east and west of    for containment and          gaseous radioactive area within a zone is       column line "N",             monitoring of potential      release, the potential drained by several screen   respectively) contains two   radioactive effluents. PFP   availability of engineering outlets. Each floor drain   full capacity exhaust fans. revisions will identify      controls for both smoke flows into the AB sump. One of the two fans runs to  potentially contaminated     and fire suppression water The collected wastes are    exhaust air from the         areas, provide instruction   runoff, and use of revised released to the             GE/GW areas. The running     for communication with       PFPs and training environment at either of    fan maintains the GE/GW      Radiation Protection and     materials, DCPP's the units circulating water areas at a slight negative   describe precautions to be   approach will be system discharge            pressure relative to the     undertaken for the           considered acceptable to structures via the ASW      outdoors to maintain         containment and safe         meet NFPA 805 System. The ASW System      smoke in the area of         removal of contaminated      radioactive release and Main Circulating        greater contamination        smoke and water runoff in    performance criteria.
Water System dilute the     potential. The other full    these potentially collected waste. The        capacity fan is provided so  contaminated areas.          The results documenting effluents are continuously  that failure of one fan will Training material and PFP    conformance to NFPA 805 monitored and require       not result in loss of        revisions will describe the  radioactive release criteria positive operator action to ventilation during normal    presence and potential use   will be maintained as part be released into the        plant operation. The         of monitored ventilation     of DCPP's Configuration environment.                ventilation flow consists of and drainage systems, if     Control Program. This 100 percent outside air      such systems are deemed      program will ensure that During NPO: Floor drains    drawn through the intake     operational and capable of   the radioactive release as described above          louvers. Recirculation fans  supporting manual removal    goals, objective and remain present.             move the entrained air to    efforts. The level of detail performance criteria will the areas farthest from the  provided in the revised      continue to be satisfied Provisions are in place to  intake louver. The           training materials and       when considering the commence                    ventilation air flows to the PFPs will meet NFPA 805      possibility that areas that communication between       enclosed annular gap, into   radioactive release          were not contaminated at the Fire Brigade and        the duct connected to the    performance criteria.        the time of NFPA 805 Radiation Protection and    exhaust fan and is                                        transition, and were to contain/monitor liquid   discharged into the plant    Implementation Item S-       consequently screened-effluents prior to safe     vent, where it is monitored. 3.19 - PFPs and training     out, may become removal.                                                 materials will be revised to contaminated in the future During NPO: The              address radioactive          due to plant operational ventilation and monitoring   release requirements of      events.
systems as described         NFPA 805. See NFPA 805 above remain present.        Transition Report            Implementation Item S-Attachment S, Table S-3. 3.20 - The NFPA 805 Page E-19

Pacific God     Electric Company                                                                           Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire      Screened            Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?        Water                     Smoke              Plan Review Results          Conclusions If normal ventilation is                            radioactive release review unavailable, smoke has the                          will be incorporated into potential to exhaust to the                         DCPP's Configuration environment via ventilation                         Control Program. See louvers. However, DCPP                              NFPA 805 Transition Calculation 9000041374                              Report Attachment S, demonstrates that the                               Table S-3.
gaseous effluent radioactive dose limits of 10 CFR 20 and plant TS will not be exceeded due to the effects of complete combustion of the worst-case "bounding" single dry active waste container, and subsequent fire suppression activities within the Owner Protected Area. As such, this calculation is "bounding" for this location and can be applied to demonstrate that any potential contaminated gaseous effluent release from this location is expected to be below 10 CFR 20 and plant technical specification limits. In addition, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely Page E-20

Pacific Ged    Electric Company                                                                                    Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions releasing contaminated gaseous effluents.
2    3-D-1 3-D-1   RHR Pump 2-   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of 1 and HX      RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Room                                AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 -The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
Page E-21

Pacific Go   d Electric Company                                                                                  Attachment E - Radioactive Releaseo             sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire    Fire Zone   Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                        Smoke                Plan Review Results             Conclusions atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation inany of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2    3-D-2 3-D-2   RHR Pump 2-   RA-3   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of 2 and HX      RA-4   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty     engineering controls for Room                                AB is divided into several supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each    from the atmosphere          for containment and          suppression water runoff area within a zone is      above the AB and then        monitoring of potential      and use of revised PFPs Page E-22

Pacific Ged    Electric Company                                              a                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                         Smoke                Plan Review Results              Conclusions drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is Page E-23

Pacific Go    d Electric Company                                                o                                   Attachment E - Radioactive Release~ sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone      Description    Plan   Rev. In?            Water                       Smoke                 Plan Review Results             Conclusions monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
3-H-1 3-H-1   Centrifugal    RA-3   05/03    Yes   Floor drains are routed to The AB ventilation system     Training materials reinforce Based on the availability of Charging       RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Pumps 1-1                            AB is divided into several supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire and 1-2 Room                         drainage zones and each from the atmosphere              for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen discharge it to the            radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are engineered safety feature       areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be Page E-24

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Releaseasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                         Smoke                Plan Review Results              Conclusions system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material-and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains   roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of Page E-25

Pacific God     Electric Company                                              0                                    Attachment E - Radioactive Release~sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                        Smoke                Plan Review Results              Conclusions higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
3-H-2 3-H-2   Centrifugal   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system    Training materials reinforce Based on the availability of Charging      RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Pump 1-3                            AB is divided into several  supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire Room                                drainage zones and each     from the atmosphere          for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature    areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be system discharge            operating conditions,        undertaken for the           The results documenting structures via the ASW      exhaust air is passed        containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter    removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before       smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.           these potentially            of DCPP's Configuration collected waste. The                                     contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,   Training material and PFP    program will ensure that Page E-26

Pacific Ged    Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                         Smoke                Plan Review Results              Conclusions monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed when considering the During NPO: Floor drains   roughing and HEPA filters. operational and capable of possibility that areas that as described above          Exhaust air from other        supporting manual removal were not contaminated at remain present.            portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805 DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is Page E-27

Pacific GOd      Electric Company                                                S                                  Attachment E - Radioactive Releasessition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire       Fire Zone   Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone       Description    Plan   Rev. In?           Water                          Smoke              Plan Review Results              Conclusions unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-1-1 3-1-1    Centrifugal    RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system   Training materials reinforce Based on the availability of Charging       RA-4   03/08          the monitored LRS. The      contains two full-capacity  use of PFPs and Casualty     engineering controls for Pumps 2-1                            AB is divided into several  supply fans that draw air   Procedure CP M-6, "Fire"     both smoke and fire and 2-2 Room                         drainage zones and each     from the atmosphere         for containment and          suppression water runoff area within a zone is       above the AB and then       monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the         radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the       revisions will identify      DCPP's approach will be flows into the AB sump. building and to the         potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature   areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments     for communication with       radioactive release environment at either of    whenever they are in        Radiation Protection and     performance criteria.
the units circulating water operation. During normal    describe precautions to be system discharge            operating conditions,       undertaken for the           The results documenting structures via the ASW      exhaust air is passed       containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter   removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before      smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.          these potentially            of DCPP's Configuration collected waste. The                                    contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP     program will ensure that monitored and require       the air is exhausted from   revisions will describe the  the radioactive release positive operator action to the ESF pump                presence and potential use   goals, objective and be released into the        compartments and is         of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if       continue to be satisfied filter in addition to the   such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of    possibility that areas that as described above          Exhaust air from other      supporting manual removal    were not contaminated at Page E-28

Pacific Gad    Electric Companv                                             0                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                       Smoke                  Plan Review Results              Conclusions remain present.            portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                   HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between      one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and       is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events.
to contain/monitor liquid  from areas other than the     Implementation Item S-effluents prior to safe    ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal Page E-29

Pacific God     Electric Company                                                                                    Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-1-2 3-1-2   Centrifugal   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of Charging      RA-4   03/08          themonitored LRS. The       contains two full-capacity    use of PFPs and Casualty     engineering controls for Pump 2-3                            AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire Room                                drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
Page E-30

Pacific Gad     Electric Company                                                                                  Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire      Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?          Water                       Smoke                 Plan Review Results               Conclusions to contain/monitor liquid  from areas other than the     Implementation Item S-effluents prior to safe    ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection Page E-31

Pacific God     Electric Company                                                                                      Attachment E - Radioactive Releasissition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description     Plan Rev.       In?            Water                        Smoke                 Plan Review Results              Conclusions personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     3-P-1 3-P-1   HVAC,           RA-5   05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce Based on the availability of Filters, Fans   RA-6   03/08          the monitored LRS. Each     similar but separate Fuel     use of PFPs and Casualty     engineering controls for RA-7   05/03          floor drain flows into the  Handling Building             Procedure CP M-6, "Fire"     both smoke and fire RA-8   03/08          AB sump. The collected      Ventilation System            for containment and          suppression water runoff wastes are released to the  (FHBVS). The FHBVS can        monitoring of potential      and use of revised PFPs environment at either of    operate in either of two      radioactive effluents. PFP   and training materials, the units circulating water configurations, a normal      revisions will identify      DCPP's approach will be system discharge            configuration or an iodine    potentially contaminated     considered acceptable to structures via the ASW      removal configuration. The    areas, provide instruction   meet NFPA 805 System. The ASW System      difference between the        for communication with       radioactive release and Main Circulating        configurations is the         Radiation Protection and     performance criteria.
Water System dilute the     treatment of exhaust air. describe precautions to be collected waste. The        Each FHBVS contains two       undertaken for the           The results documenting effluents are continuously  full-capacity supply fans     containment and safe         conformance to NFPA 805 monitored and require       that collect air from along   removal of contaminated      radioactive release criteria positive operator action to one side of the fuel pool,    smoke and water runoff in    will be maintained as part be released into the        and discharge into duct       these potentially            of DCPP's Configuration environment.                work in the corridors and     contaminated areas.          Control Program. This equipment compartments        Training material and PFP    program will ensure that During NPO: Floor drains    below the SFP.                revisions will describe the  the radioactive release as described above                                        presence and potential use   goals, objective and remain present.             During normal operation,      of monitored ventilation     performance criteria will one non-vital exhaust fan     and drainage systems, if     continue to be satisfied Provisions are in place to  is in operation and the air such systems are deemed        when considering the commence                    is passed through a           operational and capable of   possibility that areas that communication between       roughing and HEPA filter      supporting manual removal    were not contaminated at the Fire Brigade and        before being discharged to efforts. The level of detail    the time of NFPA 805 Radiation Protection and    the plant vent. In the iodine provided in the revised      transition, and were to contain/monitor liquid   removal configuration,        training materials and       consequently screened-effluents prior to safe     exhaust air passes through PFPs will meet NFPA 805         out, may become removal.                    charcoal adsorbers in         radioactive release          contaminated inthe future addition to roughing and      performance criteria.        due to plant operational HEPA filters. Automatic                                    events.
initiation of the iodine      Implementation Item S-removal configuration         3.19 - PFPs and training     Implementation Item 5-occurs in response to high materials will be revised to    3.20 - The NFPA 805 radiation, as measured by address radioactive              radioactive release review radiation monitors in the     release requirements of      will be incorporated into FHB, or upon failure of the NFPA 805. See NFPA 805         DCPP's Configuration normal operating exhaust Transition Report                 Control Program. See Page E-32

Pacific God     Electric Company                                                                                    Attachment E - Radioactive Releasissition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description      Plan   Rev. In?            Water                       Smoke               Plan Review Results              Conclusions fan. Ventilation air from   Attachment S, Table S-3. NFPA 805 Transition areas containing                                         Report Attachment S, radioactive materials is                                 Table S-3.
exhausted through HEPA and/or charcoal filters.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
3-P-5 3-P-5   HVAC,           RA-9   05/03    Yes   Floor drains are routed to  Each unit is served by a    Training materials reinforce Based on the availability of Filters, Fans  RA-10   03/08          the monitored LRS. Each     similar but separate        use of PFPs and Casualty     engineering controls for floor drain flows into the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two    for containment and          suppression water runoff wastes are released to the  configurations, a normal    monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine  radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The  revisions will identify      DCPP's approach will be system discharge            difference between the      potentially contaminated     considered acceptable to structures via the ASW      configurations is the       areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two     Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans   describe precautions to be collected waste. The        that collect air from along undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,  containment and safe         conformance to NFPA 805 Page E-33

Pacific God    Electric Company                                               0                                    Attachment E - Radioactive Release~sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                         Smoke                 Plan Review Results              Conclusions monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air of monitored ventilation       performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events. --..
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust release requirements of           will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any Page E-34

Pacific Gad      Electric Company                                                0                                     Attachment E - Radioactive Releaseasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire       Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description      Plan   Rev. In?           Water                         Smoke                 Plan Review Results              Conclusions release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
3-P-12 3-P-12   HVAC,           RA-5   05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce Based on the availability of Filters, Fans   RA-6   03/08          the monitored LRS. Each     similar but separate          use of PFPs and Casualty     engineering controls for floor drain flows into the  FHBVS. The FHBVS can          Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two      for containment and          suppression water runoff wastes are released to the  configurations, a normal      monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify      DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment,                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air of monitored ventilation       performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are inplace to   roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided inthe revised          transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated inthe future initiation of the iodine      performance criteria,        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-Page E-35

Pacific Gad    Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                        Smoke                Plan Review Results               Conclusions radiation monitors in the   -materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the  address radioactive          radioactive release review normal operating exhaust     release requirements of      will be incorporated into fan. Ventilation air from    NFPA 805. See NFPA 805       DCPP's Configuration areas containing             Transition Report            Control Program. See radioactive materials is     Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                    Report Attachment S, and/or charcoal filters.                                  Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
3-Q-1 3-Q-1   Auxiliary     RA-7   05/03    Yes   Floor drains are routed to  Each unit is served by a     Training materials reinforce Based on the availability of Feedwater     RA-8   03/08          the monitored LRS. Each     similar but separate         use of PFPs and Casualty     engineering controls for Pump Room                           floor drain flows into the  FHBVS. The FHBVS can         Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two     for containment and          suppression water runoff wastes are released to the  configurations, a normal     monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine   radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The   revisions will identify      DCPP's approach will be system discharge            difference between the       potentially contaminated     considered acceptable to structures via the ASW      configurations is the        areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two      Radiation Protection and     performance criteria.
Page E-36

Pacific God     Electric Company                                              0                                    Attachment E - Radioactive Releasensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?          Water                         Smoke                 Plan Review Results              Conclusions Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20- The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust release requirements of           will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to Page E-37

Pacific God     Electric Company                                              0                                     Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                         Smoke                 Plan Review Results              Conclusions an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-T-1 3-T-1   Auxiliary    RA-15   05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce Based on the availability of Feedwater    RA-16   03/08          the monitored LRS. Each     similar but separate          use of PFPs and Casualty     engineering controls for Pump Room                           floor drain flows into the  FHBVS. The FHBVS can          Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two      for containment and          suppression water runoff wastes are released to the  configurations, a normal      monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify      DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational E-38 Page Page E-38

Pacific God     Electric Company                                                                                    Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description      Plan   Rev. In?           Water                        Smoke               Plan Review Results               Conclusions removal configuration                                    events.
occurs in response to high  Implementation Item S-radiation, as measured by   3.19 - PFPs and training     Implementation Item S-radiation monitors in the   materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive          radioactive release review normal operating exhaust    release requirements of      will be incorporated into fan. Ventilation air from   NFPA 805. See NFPA 805       DCPP's Configuration areas containing            Transition Report            Control Program. See radioactive materials is    Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                   Report Attachment S, and/or charcoal filters.                                 Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-V-1 3-V-1   HVAC,           RA-1 3 05/03    Yes   Floor drains are routed to  Each unit is served by a    Training materials reinforce Based on the availability of Filters, Fans   RA-14  03/08          the monitored LRS. Each     similar but separate        use of PFPs and Casualty     engineering controls for floor drain flows int6 the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate ineither of two     for containment and          suppression water runoff wastes are released to the  configurations, a normal    monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine  radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The  revisions will identify      DCPP's approach will be system discharge            difference between the      potentially contaminated     considered acceptable to Page E-39

Pacific Gad    Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan Rev.       In?           Water                        Smoke                 Plan Review Results              Conclusions structures via the ASW     configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System     treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require      and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the       equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains   During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.            is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and   exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust      release requirements of      will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation Page E-40

Pacific God       Electric Company                                                                                      Attachment E - Radioactive Releaseasition Paii vdEeti           Co*n                                                                                        Atahen                 adociv        eesesto Table E NEI 04-02 Radioactive Release Transition Review Fire Fire        Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone       Description      Plan   Rev. In?           Water                        Smoke                  Plan Review Results              Conclusions techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely.
releasing contaminated gaseous effluents.
2    3-V-5  3-V-5     HVAC,           RA-1 7 05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce Based on the availability of Filters, Fans   RA-18  05/03          the monitored LRS. Each     similar but separate          use of PFPs and Casualty     engineering controls for floor drain flows into the  FHBVS. The FHBVS can          Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two      for containment and          suppression water runoff wastes are released to the  configurations, a normal      monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify      DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment,                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan presence and potential use       goals, objective and remain present.             is in operation and the air of monitored ventilation       performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter such systems are deemed           when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-Page E-41

Pacific Ged       Electric Company                                                                                    Attachment E - Radioactive Releaseoisition Paifc     -~   Elcti      Copn                                                                                     Atahet                aiacieRlas                  sto Table E NEI 04-02 Radioactive Release Transition Review Fire Fire       Fire Zone    Pre-Fire       Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone         Description     Plan   Rev. In?           Water                        Smoke               Plan Review Results                Conclusions effluents prior to safe    addition to roughing and    PFPs will meet NFPA 805        out, may become removal.                   HEPA filters. Automatic     radioactive release            contaminated in the future initiation of the iodine    performance criteria.          due to plant operational removal configuration                                      events.
occurs in response to high  Implementation Item S-radiation, as measured by   3.19 - PFPs and training       Implementation Item S-radiation monitors in the   materials will be revised to   3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust    release requirements of        will be incorporated into fan. Ventilation air from   NFPA 805. See NFPA 805         DCPP's Configuration areas containing            Transition Report              Control Program. See radioactive materials is    Attachment S, Table S-3.       NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     3-V-12 3-V-12    HVAC,           RA-13  05/03    Yes   Floor drains are routed to Each unit is served by a    Training materials reinforce   Based on the availability of Filters, Fans   RA-14  03/08         the monitored LRS. Each similar but separate            use of PFPs and Casualty       engineering controls for floor drain flows into the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"       both smoke and fire AB sump. The collected      operate in either of two    for containment and            suppression water runoff wastes are released to the configurations, a normal     monitoring of potential        and use of revised PFPs Page E-42

Pacific Gad    Electric Company                                              a                                     Attachment E - Radioactive Releaselsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                         Smoke                 Plan Review Results              Conclusions environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify      DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust release requirements of           will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is Page E-43

Pacific Ged     Electric Company                                                                                   Attachment E - Radioactive Releasasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?            Water                         Smoke             Plan Review Results               Conclusions unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
o   4-A (Ul) 4-A    Counting and   RA-5   05/03    Yes   Floor drains are routed to  The AB ventilation system   Training materials reinforce Based on the availability of 4-A (U2)        Chemical       RA-6   03/08          the monitored LRS. The      contains two full-capacity  use of PFPs and Casualty     engineering controls for Laboratory                           AB is divided into several  supply fans that draw air   Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere         for containment and          suppression water runoff area within a zone is       above the AB and then       monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the         radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the       revisions will identify      DCPP's approach will be flows into the AB sump. building and to the         potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature   areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments     for communication with       radioactive release environment at either of    whenever they are in        Radiation Protection and     performance criteria.
the units circulating water operation. During normal    describe precautions to be system discharge            operating conditions,       undertaken for the           The results documenting structures via the ASW      exhaust air is passed       containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter   removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before      smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.          these potentially            of DCPP's Configuration collected waste. The                                    contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP     program will ensure that monitored and require       the air is exhausted from   revisions will describe the  the radioactive release positive operator action to the ESF pump                presence and potential use   goals, objective and be released into the        compartments and is         of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if       continue to be satisfied filter in addition to the   such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of    possibility that areas that as described above          Exhaust air from other      supporting manual removal    were not contaminated at Page E-44

Pacific G&d Electric Company                                                                                  Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone   Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone  Description   Plan   Rev. In?          Water                       Smoke                  Plan Review Results              Conclusions remain present.            portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                   HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between      one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and       is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events:.
to contain/monitor liquid  from areas other than the     Implementation Item S-effluents prior to safe    ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal Page E-45

Pacific Ged    Electric Company                                                                                     Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                        Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                          Smoke                Plan Review Results               Conclusions ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
I    4-A-1 4-A-1   G Bus         RA-5   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of Compartment   RA-6   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the t imre of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
Page E-46

Pacific God    Electric Company                                             0                                   Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                       Smoke                Plan Review Results               Conclusions to contain/monitor liquid  from areas other than the    Implementation Item S-effluents prior to safe    ESF pump compartments        3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.            materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The              release requirements of      will be incorporated into ventilation and monitoring   NFPA 805. See NFPA 805       DCPP's Configuration systems as described         Transition Report            Control Program. See above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                           Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection Page E-47

Pacific Gad     Electric Company                                                                                    Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results               Conclusions personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     4-A-2 4-A-2   H Bus         RA-5   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of Compartment   RA-6   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NEPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NEPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will1 be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See Page E-48

Pacific G&d Electric Company                                                                                   Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone   Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone   Description   Plan   Rev. In?           Water                        Smoke               Plan Review Results              Conclusions above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                           Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1   4-B (UW) 4-B Showers,      RA-5   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of 4-B (U2)     Lockers and   RA-6   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty engineering controls for Page E-49

Pacific G*id   Electric Company                                               a                                    Attachment E - Radioactive Releaseasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions Access                              AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire Control                             drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated inthe future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating Page E-50

Pacific Go    d Electric Company                                             0                                    Attachment E - Radioactive Release            nsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                       Smoke                Plan Review Results              Conclusions conditions and accident conditions. High radiation in any of these areas is monitored inthe Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     4-B-1 4-B-1   G Bus         RA-5   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of Compartment   RA-6   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty     engineering controls for AB is divided into several supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each    from the atmosphere          for containment and          suppression water runoff area within a zone is      above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen  discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain  occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are   engineered safety feature    areas, provide instruction   meet NFPA 805 Page E-51

Pacific Ged    Electric Company                                                                                    Attachment E - Radioactive Releaseltsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.   ---
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed Page E-52

Pacific Gnd     Electric Company                                              0                                    Attachment E - Radioactive Releas             nsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?            Water                       Smoke                 Plan Review Results              Conclusions so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2     4-B-2 4-B-2   H Bus         RA-5   05/03    Yes   Floor drains are routed to  The AB ventilation system    Training materials reinforce Based on the availability of Compartment   RA-6   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere          for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature    areas, provide instruction   meet NEPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be system discharge            operating conditions,        undertaken for the           The results documenting structures via the ASW      exhaust air is passed        containment and safe         conformance to NEPA 805 System. The ASW System      through a roughing filter    removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before       smoke and water runoff in    will be maintained as part.
Page E-53

Pacific Gad    Electric Company                                                                                    Attachment E - Radioactive Releaseasition Pacific. Gvn   Electri  Co*al                                                                                      Atahmn            -Rdoatv         Rlanst Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                        Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions Water System dilute the      entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously   Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                 passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and         is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid    from areas other than the     Implementation Item S-effluents prior to safe      ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a Page E-54

Pacific God     Electric Company                                        0                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened           Engineering Controls                   Training and Pre-Fire Unit Area Zone      Description     Plan   Rev. In?        Water                    Smoke               Plan Review Results         Conclusions slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1     5-A-1 5-A-1   480V Vital      RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear, F Bus 1     5-A-2 5-A-2   480V Vital      RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear, G Bus 1     5-A-3 5-A-3   480V Vital      RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear, H Bus 1     5-A-4 5-A-4   480V Non-       RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out vital Switchgear and Hot Shutdown Panel 2     5-B-1 5-B-1   480V Vital      RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear, F Bus 2     5-B-2 5-B-2   480V Vital      RA-8   03/08     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear, Page E-55

Pacific God     Electric Company                                                                      Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened           Engineering Controls            Training and Pre-Fire Unit Area Zone      Description     Plan   Rev. In?        Water                 Smoke           Plan Review Results         Conclusions G Bus 2     5-B-3 5-B-3   480V Vital      RA-8   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Switchgear, H Bus 2     5-B-4 5-B-4   480V Non-       RA-8   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out vital Switchgear and Hot Shutdown 6-A-1 6-A-1   Battery,       RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and DC Switchgear, F Bus 6-A-2 6-A-2   Battery,       RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and DC Switchgear, G Bus 6-A-3 6-A-3   Battery,       RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and DC Switchgear, H Bus 1     6-A-4 6-A-4   Reactor Trip   RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Switchgear 1     6-A-5 6-A-5   Electrical     RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Area 2     6-B-1 6-B-1   Battery,       RA-i0   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and DC Switchgear, F Bus 2     6-B-2 6-B-2   Battery,       RA'-10  03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and DC Switchgear, G Bus 2     6-B-3 6-B-3   Battery,       RA-10   03/08     No   N/A                  N/A                  N/A                     N/A - Screened Out Inverter and Page E-56

Pacific G    nd Electric Company                                               0                                   Attachment E - Radioactive Releasensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?           Water                        Smoke               Plan Review Results               Conclusions DC Switchgear, H Bus 2     6-B-4  6-B-4  Reactor Trip  RA-10   03/08     No   N/A                         N/A                         N/A                          N/A - Screened Out Switchgear 2     6-B-5  6-B-5  Electrical    RA-10   03/08     No   N/A                         N/A                         N/A                          N/A - Screened Out Area 1      7-A    7-A   Cable         RA-22   05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out Spreading Room 2      7-B    7-B   Cable         RA-22   05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out Spreading Room 1      7-C    7-C   Communi-      RA-22   05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out cations Room 2      7-D    7-D   Communi-      RA-22   05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out cations Room 1      8-G    8-G   Safeguards    RA-12   03/08     No   N/A                         N/A                         N/A                          N/A - Screened Out Room 2      8-H    8-H   Safeguards    RA-12   03/08     No   N/A                         N/A                         N/A                          N/A - Screened Out Room 2       9     9-A   Containment   RA-31   05/03    Yes   During Plant Operation:     Containment ventilation     Training materials reinforce Based on the availability of Annulus Area  RA-32   05/03          Floor drains are routed to  systems include             use of PFPs and Casualty     engineering controls for RA-33   05/03          the monitored LRS. Units    Containment fan coolers,    Procedure CP M-6, "Fire"     both smoke and fire 1 and 2 share a common      Iodine removal units, and   for containment and          suppression water runoff LRS, except for             Containment Purge Supply    monitoring of potential      and use of revised PFPs equipment located inside    and Exhaust System. All     radioactive effluents. PFP   and training materials, containment. The wastes     radioactive atmospheres     revisions will identify      DCPP's approach will be are collected in the        are monitored for           potentially contaminated     considered acceptable to Containment sump and        radioactivity concentration areas, provide instruction   meet NFPA 805 are released to the         during normal operations,   for communication with       radioactive release environment at either of    anticipated transients, and Radiation Protection and     performance criteria.
the units circulating water accident conditions by the  describe precautions to be system discharge            RMS. High radiation in any  undertaken for the           The results documenting structures via the ASW      of these areas in monitored containment and safe         conformance to NFPA 805 System. The ASW System      in the Control Room.        removal of contaminated      radioactive release criteria and Main Circulating        Accidental releases from    smoke and water runoff in    will be maintained as part Water System dilute the      Containment are monitored   these potentially            of DCPP's Configuration collected waste. The        by the process and effluent contaminated areas.          Control Program. This effluents are continuously  radiological monitoring     Training material and PFP    program will ensure that Page E-57

Pacific Gad    Electric Comnpany                                             0                                     Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire      Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description     Plan   Rev. In?          Water                         Smoke                 Plan Review Results              Conclusions monitored and require       system. For all conditions,   revisions will describe the  the radioactive release positive operator action to the RMS is capable of         presence and potential use   goals, objective and be released into the        isolating or diverting lines  of monitored ventilation     performance criteria will environment.                containing gaseous activity   and drainage systems, if     continue to be satisfied when activity levels reach a  such systems are deemed      when considering the During NPO: Floor drains preset limit.                   operational and capable of   possibility that areas that as described above                                        supporting manual removal    were not contaminated at remain present.             During Normal Operation:      efforts. The level of detail the time of NFPA 805 Five fan cooler units are     provided in the revised      transition, and were Provisions are in place to provided in Containment to     training materials and       consequently screened-commence                    recirculate and cool the      PFPs will meet NFPA 805      out, may become communication between       containment atmosphere        radioactive release          contaminated in the future the Fire Brigade and        during normal operation       performance criteria.        due to plant operational Radiation Protection and and following a DBA.                                         events.
to contain/monitor liquid                                 Implementation Item S-effluents prior to safe     Each Containment building     3.19 - PFPs and training     Implementation Item S-removal.                    is provided with two Iodine   materials will be revised to 3.20 - The NFPA 805 removal units consisting of   address radioactive          radioactive release review a recirculation fan           release requirements of      will be incorporated into complete with roughing        NFPA 805. See NFPA 805       DCPP's Configuration filter, HEPA filter, and      Transition Report            Control Program. See charcoal filter on the fan    Attachment S, Table S-3. NFPA 805 Transition suction. These units are                                   Report Attachment S, operated as required                                       Table S-3.
during normal operation to control airborne iodine and particulate concentrations in the containment atmosphere.
During NPO: The Containment Purge Supply and exhaust system includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header in the Containment and exhausts it to the plant vent where it is released to the atmosphere at the top of Page E-58

Pacific Go   d Electric Company                                       9                                   Attachment E - Radioactive Releaselsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened           Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?        Water                    Smoke               Plan Review Results        Conclusions the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it is reasonable to anticipate that any fire condition would be quickly detected and reported to the Control Room using the plant communication system. In addition, the RCPs and associated oil supply are considered the largest potential fire contributor; however, due to the fact that these pumps and motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment which results in radiological consequences, are considered negligible.
Furthermore, it is expected that the volume of Containment is sufficiently Page E-59

Pacific Go   d Electric Company                                             0                                   Attachment E - Radioactive Releasensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                        Smoke               Plan Review Results             Conclusions large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8. DC54.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2      9    9-B    Reactor      RA-31   05/03    Yes   During Plant Operation:    Containment ventilation     Training materials reinforce Based on the availability of Steam        RA-32   05/03          Floor drains are routed to systems include             use of PFPs and Casualty     engineering controls for Generator    RA-33   05/03          the monitored LRS. Units   Containment fan coolers,    Procedure CP M-6, "Fire"     both smoke and fire Area                                1 and 2 share a common     Iodine removal units, and   for containment and          suppression water runoff LRS, except for            Containment Purge Supply    monitoring of potential      and use of revised PFPs equipment located inside   and Exhaust System. All     radioactive effluents. PFP   and training materials, containment. The wastes    radioactive atmospheres     revisions will identify      DCPP's approach will be Page E-60

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                        Smoke                Plan Review Results               Conclusions are collected in the        are monitored for            potentially contaminated     considered acceptable to Containment sump and        radioactivity concentration  areas, provide instruction   meet NFPA 805 are released to the         during normal operations,    for communication with       radioactive release environment at either of    anticipated transients, and  Radiation Protection and     performance criteria.
the units circulating water accident conditions by the   describe precautions to be system discharge            RMS. High radiation in any   undertaken for the           The results documenting structures via the ASW      of these areas in monitored  containment and safe         conformance to NFPA 805 System. The ASW System      in the Control Room.         removal of contaminated      radioactive release criteria and Main Circulating        Accidental releases from     smoke and water runoff in    will be maintained as part Water System dilute the     Containment are monitored    these potentially            of DCPP's Configuration collected waste. The        by the process and effluent  contaminated areas.          Control Program. This effluents are continuously  radiological monitoring      Training material and PFP    program will ensure that monitored and require       system. For all conditions,  revisions will describe the  the radioactive release positive operator action to the RMS is capable of        presence and potential use   goals, objective and be released into the        isolating or diverting lines of monitored ventilation     performance criteria will environment.                containing gaseous activity  and drainage systems, if     continue to be satisfied when activity levels reach a such systems are deemed      when considering the During NPO: Floor drains    preset limit.                operational and capable of   possibility that areas that as described above                                       supporting manual removal    were not contaminated at remain present.             During Normal Operation:     efforts. The level of detail the time of NFPA 805 Five fan cooler units are    provided in the revised      transition, and were Provisions are in place to  provided in Containment to training materials and         consequently screened-commence                    recirculate and cool the     PFPs will meet NFPA 805      out, may become communication between       containment atmosphere       radioactive release          contaminated in the future the Fire Brigade and        during normal operation      performance criteria.        due to plant operational Radiation Protection and    and following a DBA.                                      events.
to contain/monitor liquid                                Implementation Item S-effluents prior to safe     Each Containment building 3.19 - PFPs and training        Implementation Item S-removal.                    is provided with two Iodine materials will be revised to  3.20 - The NFPA 805 removal units consisting of address radioactive           radioactive release review a recirculation fan          release requirements of      will be incorporated into complete with roughing       NFPA 805. See NFPA 805       DCPP's Configuration filter, HEPA filter, and     Transition Report            Control Program. See charcoal filter on the fan   Attachment S, Table S-3. NFPA 805 Transition suction. These units are                                  Report Attachment S, operated as required                                      Table S-3.
during normal operation to control airborne iodine and particulate concentrations in the containment atmosphere.
During NPO: The Containment Purge Supply and exhaust system Page E-61

Pacific Go   d Electric Company                                       O                                    Attachment E - Radioactive Releaseo sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened            Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?        Water                     Smoke               Plan Review Results        Conclusions includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header inthe Containment and exhausts it to the plant vent where it is released to the atmosphere at the top of the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it is reasonable to anticipate that any fire condition would be quickly detected and reported to the Control Room using the plant communication system. In addition, the RCPs and associated oil supply are considered the largest potential fire contributor; however, due to the fact that these pumps and Page E-62

Pacific GO d Electric Company                                                                          Attachment E - Radioactive Release   ksition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone   Pre-Fire       Screened           Engineering Controls                   Training and Pre-Fire Unit Area Zone   Description    Plan   Rev. In?        Water                     Smoke             Plan Review Results        Conclusions motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment which results in radiological consequences, are considered negligible.
Furthermore, it is expected that the volume of Containment is sufficiently large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8.DC54.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection Page E-63

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Relea .see             sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water.                        Smoke                Plan Review Results              Conclusions personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2      9    9-C    Reactor       RA-34  05/03    Yes   During Plant Operation:     Containment ventilation      Training materials reinforce Based on the availability of Cavity and    RA-35  05/03          Floor drains are routed to  systems include              use of PFPs and Casualty     engineering controls for Operating                           the monitored LRS. Units    Containment fan coolers,     Procedure CP M-6, "Fire"     both smoke and fire Deck                                1 and 2 share a common      Iodine removal units, and    for containment and          suppression water runoff LRS, except for             Containment Purge Supply     monitoring of potential      and use of revised PFPs equipment located inside    and Exhaust System. All      radioactive effluents. PFP   and training materials, containment. The wastes     radioactive atmospheres      revisions will identify      DCPP's approach will be are collected in the        are monitored for            potentially contaminated     considered acceptable to Containment sump and        radioactivity concentration  areas, provide instruction   meet NFPA 805 are released to the         during normal operations,    for communication with       radioactive release environment at either of    anticipated transients, and  Radiation Protection and     performance criteria.
the units circulating water accident conditions by the   describe precautions to be system discharge            RMS. High radiation inany    undertaken for the           The results documenting structures via the ASW      of these areas in monitored  containment and safe         conformance to NFPA 805 System. The ASW System      in the Control Room.         removal of contaminated      radioactive release criteria and Main Circulating        Accidental releases from     smoke and water runoff in    will be maintained as part Water System dilute the     Containment are monitored    these potentially            of DCPP's Configuration collected waste. The        by the process and effluent  contaminated areas.          Control Program. This effluents are continuously  radiological monitoring      Training material and PFP    program will ensure that monitored and require       system. For all conditions,  revisions will describe the  the radioactive release positive operator action to the RMS is capable of        presence and potential use   goals, objective and be released into the        isolating or diverting lines of monitored ventilation     performance criteria will environment.                containing gaseous activity  and drainage systems, if     continue to be satisfied when activity levels reach a such systems are deemed      when considering the During NPO: Floor drains    preset limit.                operational and capable of   possibility that areas that as described above                                       supporting manual removal    were not contaminated at remain present.             During Normal Operation: efforts. The level of detail     the time of NFPA 805 Five fan cooler units are    provided in the revised      transition, and were Provisions are in place to  provided in Containment to training materials and         consequently screened-commence                    recirculate and cool the     PFPs will meet NFPA 805      out, may become communication between       containment atmosphere       radioactive release          contaminated in the future the Fire Brigade and        during normal operation      performance criteria.        due to plant operational Radiation Protection and    and following a DBA.                                      events.
to contain/monitor liquid                                Implementation Item S-effluents prior to safe     Each Containment building    3.19 - PFPs and training     Implementation Item S-removal.                    is provided with two Iodine  materials will be revised to 3.20 - The NFPA 805 removal units consisting of  address radioactive          radioactive release review a recirculation fan          release requirements of      will be incorporated into complete with roughing       NFPA 805. See NFPA 805       DCPP's Configuration filter, HEPA filter, and     Transition Report            Control Program. See Page E-64

Pacific God    Electric Company                                                                            Attachment E - Radioactive Releaselasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened            Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?        Water                     Smoke                Plan Review Results          Conclusions charcoal filter on the fan    Attachment S, Table S-3. NFPA 805 Transition suction. These units are                               Report Attachment S, operated as required                                   Table S-3.
during normal operation to control airborne iodine and particulate concentrations inthe containment atmosphere.
During NPO: The Containment Purge Supply and exhaust system includes a single supply fan and a single exhaust fan. Supply air is drawn from the atmosphere through a roughing filter.
The purge exhaust fan draws air from the main ventilation header inthe Containment and exhausts
                                                                            *it to the plant vent where it is released to the atmosphere at the top of the containment. This system is not in continuous operation during power operation, but is provided for use on a periodic basis as required prior to personnel entry.
Although the purge exhaust air is not filtered, the release of radioactive materials due to smoke migration is not expected as plant personnel have a heightened sense of awareness and monitor the Containment structure during NPO. Plant workers trained in plant communications are present in Containment; it Page E-65

Pacific Go d Electric Company                                                                         Attachment E - Radioactive Releasel    sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone   Pre-Fire      Screened           Engineering Controls                   Training and Pre-Fire Unit Area Zone    Description   Plan   Rev. In?        Water                   Smoke              Plan Review Results        Conclusions is reasonable to anticipate that any fire condition would be quickly detected and reported to the Control Room using the plant communication system. In addition, the RCPs and associated oil supply are considered the largest potential fire contributor; however, due to the fact that these pumps and motors are not operating during NPO, ignition sources and subsequent risk of a credible fire scenario within Containment which results in radiological consequences, are considered negligible.
Furthermore, it is expected that the volume of Containment is sufficiently large enough to ensure that smoke from a radiological fire scenario (considered unlikely) would be contained within the structure. During NPO, containment openings are internal to the plant with the exception of the Containment equipment hatch. Closure of the equipment hatch for containment integrity can also established via a detailed Containment Closure Plant Procedure, AD8.DC54.
If normal ventilation is unavailable, smoke will be removed using standard Page E-66

Pacific God     Electric Company                                                                              Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone     Pre-Fire       Screened           Engineering Controls                   Training and Pre-Fire Unit Area Zone     Description       Plan   Rev. In?        Water                     Smoke              Plan Review Results         Conclusions industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
10    10     12kV             TB-5   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear Room and Cable Spreading Room 11-D  11-D    Corridor         TB-5   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Outside Diesel Generator Rooms 1     13-D  13-D    Excitation       TB-9   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Switchgear Room 1     13-E  13-E    Switchgear       TB-7   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Ventilation Fan Room 1     13-F  13-F    Storage          TB-9   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Room I     14-B  14-B    Clean and        TB-5   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Dirty Lube Oil 1      15    15     Turbine Lube     TB-7   05/03     No   N/A                  N/A                         N/A                     N/A - Screened Out Oil Reservoir Page E-67

Pacific God     Electric Company                                                                                      Attachment E - Radioactive Releaselosition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description     Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions 0      17    17     Warehouse       TB-9   05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out 2      18    18     Turbine Lube    TB-18  05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Oil Reservoir 2      20    20      12kV           TB-5   05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Switchgear Room and Cable Spreading Room 2     22-C  22-C    Corridor        TB-16  05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Outside Diesel Generator Rooms 2     24-D  24-D    Excitation      TB-20  05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Switchgear Room 0      26    26     Building        RA-23  05/03    Yes   DCPP Calculation No.         DCPP Calculation No.         Training materials reinforce Based on the results of 117B           RA-24   05/03          9000041373                   9000041374 demonstrates      use of PFPs and Casualty     DCPP Calculation No's.
Radwaste       RA-25   05/03          demonstrates that the        that the gaseous effluent    Procedure CP M-6, "Fire"     9000041373 and Laundry and                           liquid effluent radioactive  radioactive dose limits of   for containment and          9000041374 regarding Storage                               dose limits of 10 CFR 20     10 CFR 20 and plant TS       monitoring of potential      liquid and gaseous Building                              and plant TS will not be     will not be exceeded due to  radioactive effluents. PFP   radioactive release, and exceeded due to the          the effects of complete      revisions will identify      the use of revised PFPs effects of complete          combustion of the worst-     potentially contaminated     and training materials, combustion of the worst-     case "bounding" single dry   areas, provide instruction   DCPP's approach will be case "bounding" single dry   active waste container, and  for communication with       considered acceptable to active waste container,      subsequent fire              Radiation Protection and     meet NFPA 805 and subsequent fire          suppression activities       describe precautions to be   radioactive release suppression activities       within the Owner Protected   undertaken for the           performance criteria.
within the Owner             Area. As such, this          containment and safe Protected Area. As such,     calculation is "bounding"    removal of contaminated      The results documenting this calculation is          for this location and can be smoke and water runoff in    conformance to NFPA 805 "bounding" for this location applied to demonstrate that  these potentially            radioactive release criteria and can be applied to        any potential contaminated   contaminated areas.          will be maintained as part demonstrate that any         gaseous effluent release     Training material and PFP    of DCPP's Configuration potential contaminated       resulting from complete      revisions will describe the  Control Program. This liquid effluent release      combustion of the single     presence and potential use   program will ensure that resulting from complete      "worst-case" radioactive     of monitored ventilation     the radioactive release combustion of the single     source container and         and drainage systems, if     goals, objective and "worst-case" radioactive     subsequent fire              such systems are deemed      performance criteria will source container and         suppression activities in    operational and capable of   continue to be satisfied Page E-68

Pacific Gad     Electric Company                                                                                    Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions subsequent fire              this building is expected to supporting manual removal    when considering the suppression activities in    be below 10 CFR 20 and       efforts. The level of detail possibility that areas that this building is expected to plant technical              provided in the revised      were not contaminated at be below 10 CFR 20 and       specification limits,        training materials and       the time of NFPA 805 plant technical                                           PFPs will meet NFPA 805      transition, and were specification limits.        Provisions are in place to radioactive release            consequently screened-commence communication performance criteria,              out, may become Provisions are in place to   between the Fire Brigade                                  contaminated in the future commence                     and Radiation Protection     Implementation Item S-       due to plant operational communication between        and provide precautions for 3.19 - PFPs and training      events.
the Fire Brigade and         containing, monitoring, and materials will be revised to Radiation Protection and     safely releasing             address radioactive          Implementation Item S-to contain/monitor liquid    contaminated gaseous         release requirements of      3.20 - The NFPA 805 effluents prior to safe      effluents.                   NFPA 805. See NFPA 805       radioactive release review removal.                                                  Transition Report            will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3.
0     27-A  27-A    Boxed Waste  RA-21   05/03    Yes   DCPP Calculation No.         DCPP Calculation No.         Training materials reinforce Based on the results of Zone          RA-22  05/03          9000041373                   9000041374 demonstrates      use of PFPs and Casualty     DCPP Calculation No's.
demonstrates that the        that the gaseous effluent    Procedure CP M-6, "Fire"     9000041373 and liquid effluent radioactive  radioactive dose limits of   for containment and          9000041374 regarding dose limits of 10 CFR 20     10 CFR 20 and plant TS       monitoring of potential      liquid and gaseous and plant TS will not be     will not be exceeded due to  radioactive effluents. PFP   radioactive release, and exceeded due to the          the effects of complete      revisions will identify      the use of revised PFPs effects of complete          combustion of the worst-     potentially contaminated     and training materials, combustion of the worst-     case "bounding" single dry   areas, provide instruction   DCPP's approach will be case "bounding" single dry   active waste container, and  for communication with       considered acceptable to active waste container,      subsequent fire.             Radiation Protection and     meet NFPA 805 and subsequent fire          suppression activities       describe precautions to be   radioactive release suppression activities       within the Owner Protected   undertaken for the           performance criteria.
within the Owner             Area. As such, this          containment and safe Protected Area. As such,     calculation is "bounding"    removal of contaminated      The results documenting this calculation is          for this location and can be smoke and water runoff in    conformance to NFPA 805 "bounding" for this location applied to demonstrate that  these potentially            radioactive release criteria and can be applied to        any potential contaminated   contaminated areas,          will be maintained as part demonstrate that any         gaseous effluent release     Training material and PFP    of DCPP's Configuration potential contaminated       resulting from complete      revisions will describe the  Control Program. This liquid effluent release      combustion of the single     presence and potential use   program will ensure that resulting from complete      "worst-case" radioactive     of monitored ventilation     the radioactive release combustion of the single     source container and         and drainage systems, if     goals, objective and "worst-case" radioactive     subsequent fire              such systems are deemed      performance criteria will source container and         suppression activities in    operational and capable of   continue to be satisfied Page E-69

Pacific Gaod Electric Company                                                                                     Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone   Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions subsequent fire              this building is expected to supporting manual removal    when considering the suppression activities in    be below 10 CFR 20 and       efforts. The level of detail possibility that areas that this building is expected to plant technical              provided in the revised      were not contaminated at be below 10 CFR 20 and       specification limits,        training materials and       the time of NFPA 805 plant technical                                           PFPs will meet NFPA 805      transition, and were specification limits.        Provisions are in place to radioactive release            consequently screened-commence communication performance criteria,              out, may become Provisions are in place to   between the Fire Brigade                                  contaminated in the future commence                     and Radiation Protection     Implementation Item S-       due to plant operational communication between        and provide precautions for 3.19 - PFPs and training      events.
the Fire Brigade and         containing, monitoring, and materials will be revised to Radiation Protection and     safely releasing             address radioactive          Implementation Item S-to contain/monitor liquid    contaminated gaseous         release requirements of      3.20 - The NFPA 805 effluents prior to safe      effluents.                   NFPA 805. See NFPA 805       radioactive release review removal.                                                  Transition Report            will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3.
0     27-8  27-B Drum           RA-21  05/03    Yes   DCPP Calculation No.         DCPP Calculation No.         Training materials reinforce Based on the results of Storage Zone   RA-22  05/03          9000041373                   9000041374 demonstrates      use of PFPs and Casualty     DCPP Calculation No's.
demonstrates that the        that the gaseous effluent    Procedure CP M-6, "Fire"     9000041373 and liquid effluent radioactive  radioactive dose limits of   for containment and          9000041374 regarding dose limits of 10 CFR 20     10 CFR 20 and plant TS       monitoring of potential      liquid and gaseous and plant TS will not be     will not be exceeded due to  radioactive effluents. PFP   radioactive release, and exceeded due to the          the effects of complete      revisions will identify      the use of revised PFPs effects of complete          combustion of the worst-     potentially contaminated     and training materials, combustion of the worst-     case "bounding" single dry   areas, provide instruction   DCPP's approach will be case "bounding" single dry   active waste container, and  for communication with       considered acceptable to active waste container,      subsequent fire              Radiation Protection and     meet NFPA 805 and subsequent fire          suppression activities       describe precautions to be   radioactive release suppression activities       within the Owner Protected   undertaken for the           performance criteria.
within the Owner             Area. As such, this          containment and safe Protected Area. As such,     calculation is "bounding"    removal of contaminated      The results documenting this calculation is          for this location and can be smoke and water runoff in    conformance to NFPA 805 "bounding" for this location applied to demonstrate that  these potentially            radioactive release criteria and can be applied to        any potential contaminated   contaminated areas,          will be maintained as part demonstrate that any         gaseous effluent release     Training material and PFP    of DCPP's Configuration potential contaminated       resulting from complete      revisions will describe the  Control Program. This liquid effluent release      combustion of the single     presence and potential use   program will ensure that resulting from complete      "worst-case" radioactive     of monitored ventilation     the radioactive release combustion of the single     source container and         and drainage systems, if     goals, objective and "worst-case" radioactive     subsequent fire              such systems are deemed      performance criteria will source container and         suppression activities in    operational and capable of   continue to be satisfied Page E-70

Pacific Gend Electric Company                                                1                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire   Fire Zone   Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone   Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions subsequent fire              this building is expected to supporting manual removal    when considering the suppression activities in    be below 10 CFR 20 and       efforts. The level of detail possibility that areas that this building is expected to plant technical              provided in the revised      were not contaminated at be below 10 CFR 20 and       specification limits,        training materials and       the time of NFPA 805 plant technical                                           PFPs will meet NFPA 805      transition, and were specification limits.        Provisions are in place to radioactive release            consequently screened-commence communication performance criteria,              out, may become Provisions are in place to   between the Fire Brigade                                  contaminated in the future commence                     and Radiation Protection     Implementation Item S-       due to plant operational communication between        and provide precautions for 3.19 - PFPs and training      events.
the Fire Brigade and         containing, monitoring, and materials will be revised to Radiation Protection and     safely releasing             address radioactive          Implementation Item S-to contain/monitor liquid    contaminated gaseous         release requirements of      3.20 - The NFPA 805 effluents prior to safe      effluents.                   NFPA 805. See NFPA 805       radioactive release review removal.                                                  Transition Report            will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3.
0     27-C  27-C Contaminated  RA-21   05/03    Yes   DCPP Calculation No.         DCPP Calculation No.         Training materials reinforce Based on the results of Oil Storage  RA-22   05/03          9000041373                   9000041374 demonstrates      use of PFPs and Casualty     DCPP Calculation No's.
demonstrates that the        that the gaseous effluent    Procedure CP M-6, "Fire"     9000041373 and liquid effluent radioactive  radioactive dose limits of   for containment and          9000041374 regarding dose limits of 10 CFR 20     10 CFR 20 and plant TS       monitoring of potential      liquid and gaseous and plant TS will not be     will not be exceeded due to  radioactive effluents. PFP   radioactive release, and exceeded due to the          the effects of complete      revisions will identify      the use of revised PFPs effects of complete          combustion of the worst-     potentially contaminated     and training materials, combustion of the worst-     case "bounding" single dry   areas, provide instruction   DCPP's approach will be case "bounding" single dry   active waste container, and  for communication with       considered acceptable to active waste container,      subsequent fire              Radiation Protection and     meet NFPA 805 and subsequent fire          suppression activities       describe precautions to be   radioactive release suppression activities       within the Owner Protected   undertaken for the           performance criteria.
within the Owner             Area. As such, this          containment and safe Protected Area. As such,     calculation is "bounding"    removal of contaminated      The results documenting this calculation is          for this location and can be smoke and water runoff in    conformance to NFPA 805 "bounding" for this location applied to demonstrate that  these potentially            radioactive release criteria and can be applied to        any potential contaminated   contaminated areas.          will be maintained as part demonstrate that any         gaseous effluent release     Training material and PFP    of DCPP's Configuration potential contaminated       resulting from complete      revisions will describe the  Control Program. This liquid effluent release      combustion of the single     presence and potential use   program will ensure that resulting from complete      "worst-case" radioactive     of monitored ventilation     the radioactive release combustion of the single     source container and         and drainage systems, if     goals, objective and "worst-case" radioactive     subsequent fire              such systems are deemed      performance criteria will source container and         suppression activities in    operational and capable of   continue to be satisfied Page E-71

Pacific God      Electric Company                                               0                                    Attachment E - Radioactive Release~sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description    Plan   Rev. In?            Water                        Smoke                 Plan Review Results              Conclusions subsequent fire              this building is expected to supporting manual removal    when considering the suppression activities in    be below 10 CFR 20 and       efforts. The level of detail possibility that areas that this building is expected to plant technical              provided in the revised      were not contaminated at be below 10 CFR 20 and       specification limits,        training materials and       the time of NFPA 805 plant technical                                           PFPs will meet NFPA 805      transition, and were specification limits.        Provisions are in place to radioactive release            consequently screened-commence communication performance criteria,              out, may become Provisions are in place to   between the Fire Brigade                                  contaminated in the future commence                     and Radiation Protection     Implementation Item S-       due to plant operational communication between        and provide precautions for 3.19 - PFPs and training      events.
the Fire Brigade and         containing, monitoring, and materials will be revised to Radiation Protection and     safely releasing             address radioactive          Implementation Item S-to contain/monitor liquid    contaminated gaseous         release requirements of      3.20 - The NFPA 805 effluents prior to safe      effluents.                   NFPA 805. See NFPA 805       radioactive release review removal.                                                  Transition Report            will be incorporated into Attachment S, Table S-3. DCPP's Configuration Control Program. See NFPA 805 Transition Report Attachment S, Table S-3.
1      28     28     Main          TB-24  05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Transformer Area 2      29     29     Main          TB-24  05/03     No   N/A                          N/A                          N/A                          N/A - Screened Out Transformer Area 1    30-A-1 30-A-1   Auxiliary     PA-2   03/08     No   N/A                          N/A                          N/A                          N/A - Screened Out Saltwater Pump 1-1 Vault I    30-A-2 30-A-2   Auxiliary     PA-2   03/08     No   N/A                          N/A                          N/A                          N/A - Screened Out Saltwater Pump 1-2 Vault 2    30-A-3 30-A-3   Auxiliary     PA-2   03/08     No   N/A                          N/A                          N/A                          N/A - Screened Out Saltwater Pump 2-1 Vault 2    30-A-4 30-A-4   Auxiliary     PA-2   03/08     No   N/A                          N/A                          N/A                          N/A - Screened Out Saltwater Pump 2-2 Vault Page E-72

Pacific Gad    Electric Company                                                                                    Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions 2      33    33    Security      RA-13  05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of Diesel        RA-14  03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Generator                           AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire Room                                drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of-revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          trainingmaterials and        consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment 5, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity Page E-73

Pacific Go    d Electric Company                                                O                                     Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                Engineering Controls                        Training and Pre-Fire Unit Area Zone      Description     Plan   Rev. In?           Water                         Smoke                Plan Review Results               Conclusions concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
0    34 (UM) 34     Auxiliary      RA-1 1  05/03     Yes  This location is the roof of DCPP Calculation No.         Training materials reinforce Based on the results of 34 (U2)        Building Roof  RA-12   03/08          the RCA in the AB.           9000041374 demonstrates      use of PFPs and Casualty     DCPP Calculation No's.
Typical roof drainage        that the gaseous effluent    Procedure CP M-6, "Fire"     9000041373 and systems are present under    radioactive dose limits of   for containment and          9000041374 regarding normal conditions,           10 CFR 20 and plant TS       monitoring of potential      liquid and gaseous however if contamination     will not be exceeded due to  radioactive effluents. PFP   radioactive release, and is detected, roof drains     the effects of complete      revisions will identify      the use of revised PFPs Page E-74

Pacific Gad     Electric Company                                                                                   Attachment E - Radioactive Release4&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?           Water                        Smoke                Plan Review Results              Conclusions discharge to the            combustion of the worst-    potentially contaminated     and training materials, monitored LRS. The AB is    case "bounding" single dry  areas, provide instruction   DCPP's approach will be divided into several        active waste container, and for communication with       considered acceptable to drainage zones and each     subsequent fire             Radiation Protection and     meet NFPA 805 area within a zone is       suppression activities      describe precautions to be   radioactive release drained by several screen   within the Owner Protected  undertaken for the           performance criteria.
outlets. Each floor drain   Area. As such, this         containment and safe flows into the AB sump. calculation is "bounding"   removal of contaminated      The results documenting The collected wastes are    for the roof area and can   smoke and water runoff in    conformance to NFPA 805 released to the             be applied to demonstrate   these potentially            radioactive release criteria environment at either of    that any potential          contaminated areas.          will be maintained as part the units circulating water contaminated gaseous        Training material and PFP    of DCPP's Configuration system discharge            effluent release from the   revisions will describe the  Control Program. This structures via the ASW      roof is expected to be      presence and potential use   program will ensure that System. The ASW System      below 10 CFR 20 and plant   of monitored ventilation     the radioactive release and Main Circulating        technical specification     and drainage systems, if     goals, objective and Water System dilute the     limits.                     such systems are deemed      performance criteria will collected waste. The                                    operational and capable of   continue t6be satisfied effluents are continuously                              supporting manual removal    when considering the monitored and require                                   efforts. The level of detail possibility that areas that positive operator action to                             provided in the revised      were not contaminated at be released into the                                    training materials and       the time of NFPA 805 environment.                                            PFPs will meet NFPA 805      transition, and were radioactive release          consequently screened-During NPO: Floor drains                                performance criteria.        out, may become as described above                                                                   contaminated in the future remain present.                                         Implementation Item S-       due to plant operational 3.19 - PFPs and training     events.
Provisions are in place to                              materials will be revised to commence                                                address radioactive          Implementation Item S-communication between                                   release requirements of      3.20 - The NFPA 805 the Fire Brigade and                                    NFPA 805. See NFPA 805       radioactive release review Radiation Protection and                                Transition Report            will be incorporated into to contain/monitor liquid                               Attachment S, Table S-3. DCPP's Configuration effluents prior to safe                                                              Control Program. See removal.                                                                             NFPA 805 Transition Report Attachment S, Table S-3 0     35-A  35-A    Diesel Fuel    TB-2   05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out Oil Transfer Pump 0-1 Vault 0     35-B  35-B    Diesel Fuel    TB-12  05/03     No   N/A                         N/A                         N/A                          N/A - Screened Out Oil Transfer Page E-75

Pacific Glad    Electric Company                                                                                      Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description     Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions Pump 0-2 Vault 0 AB-1 (Ul)  3-A    Liquid Holdup   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Tank Area       RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
Page E-76

Pacific Ge    d Electric Company                                                                                    Attachment E - Radioactive Release~ sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone    Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description      Plan   Rev. In?           Water                        Smoke               Plan Review Results              Conclusions atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release,'PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
0 AB-1 (UM)3-AA     Auxiliary       RA-9   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)        Building       RA-10   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty     engineering controls for Elevation 115                         AB is divided into several supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire Feet -                                drainage zones and each    from the atmosphere          for containment and          suppression water runoff Appendix R                            area within a zone is      above the AB and then        monitoring of potential      and use of revised PFPs
                                                                                                                                                               .Page E-77

Pacific God    Electric Company                                              0                                     Attachment E - Radioactive Releasensition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                        Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions Area                               drained by several screen    discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump.      building and to the           potentially contaminated     considered acceptable to The collected wastes are     engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of     whenever they are in          Radiation Protection and     performance criteria.
the units circulating water  operation. During normal      describe precautions to be system discharge             operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the      entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                       contaminated areas.          Control Program. This effluents are continuously   Under accident conditions,    Training material and PFP    program will ensure that~
monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                 passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above           Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                     HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between        one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and         is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid    from areas other than the     Implementation Item S-effluents prior to safe      ESF pump compartments         3.19 - PFPs and training     Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is Page E-78

Pacific Ga    d Electric Company                                                  0                                   Attachment E - Radioactive Release              nsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone     Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone      Description      Plan   Rev. in?            Water                        Smoke                Plan Review Results              Conclusions monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (UM)3-B-3    Boron            RA-3   05/03    Yes   Floor drains are routed to The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Injection Tank   RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for AB is divided into several supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each from the atmosphere              for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen discharge it to the            radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are engineered safety feature       areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be Page E-79

Pacific Go   d Electric Company                                              a                                    Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire    Fire Zone   Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of possibility that areas that as described above          Exhaust air from other        supporting manual removal were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805 DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3..
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of Page E-80

Pacific GAL Electric Company                                                                                      Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire   Fire Zone    Pre-Fire       Screened                Engineering Controls                       Training and Pre-Fire Unit Area Zone   Description     Plan   Rev. In?           Water                        Smoke                Plan Review Results               Conclusions higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
o  AB-1 (Ul) 3-C Auxiliary       RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)     Building        RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Elevation 54,                         AB is divided into several  supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire 64 and 73                             drainage zones and each     from the atmosphere          for containment and          suppression water runoff Feet                                  area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature    areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be system discharge            operating conditions,        undertaken for the           The results documenting structures via the ASW      exhaust air is passed        containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter    removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before       smoke and water runoff in    will be maintained as part Water System dilute the      entering the vent.           these potentially            of DCPP's Configuration collected waste. The                                     contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP      program will ensure that Page E-81

Pacific God    Electric Company                                              0                                    Attachment E - Radioactive Releaseosition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains roughing and HEPA filters.       operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and           training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20'- The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is Page E-82

Pacific God      Electric Company                                                  a                                  Attachment E - Radioactive Release~sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire       Fire Zone     Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone       Description      Plan   Rev. In?            Water                         Smoke              Plan Review Results              Conclusions unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2  AB-1 (Ul) 3-D-3   Boron            RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system   Training materials reinforce Based on the availability of AB-1 (U2)         Injection Tank   RA-4   03/08          the monitored LRS. The      contains two full-capacity  use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air   Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere         for containment and          suppression water runoff area within a zone is       above the AB and then       monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the         radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the       revisions will identify      DCPP's approach will be flows into the AB sump. building and to the         potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature   areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments     for communication with       radioactive release environment at either of    whenever they are in        Radiation Protection and     performance criteria.
the units circulating water operation. During normal    describe precautions to be system discharge            operating conditions,       undertaken for the           The results documenting structures via the ASW      exhaust air is passed       containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter   removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before      smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.          these potentially            of DCPP's Configuration collected waste. The                                    contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP     program will ensure that monitored and require       the air is exhausted from   revisions will describe the  the radioactive release positive operator action to the ESF pump                presence and potential use   goals, objective and be released into the        compartments and is         of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if       continue to be satisfied filter in addition to the   such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of    possibility that areas that as described above          Exhaust air from other      supporting manual removal    were not contaminated at Page E-83

Pacific God    Electric Company                                              0                                   Attachment E - Radioactive Releasedsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                        Smoke                 Plan Review Results              Conclusions remain present.            portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                   HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between      one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and       is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events.
to contain/monitor liquid  from areas other than the     Implementation Item S-effluents prior to safe    ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal Page E-84

Pacific God     Electric Company                                                                                    Attachment E - Radioactive Releasessition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (Ul)  3-F    Containment   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of AB-i (U2)        Spray Pumps   RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated inthe future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
Page E-85

Pacific God    Electric Company                                              a                                  Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                       Smoke                Plan Review Results               Conclusions to contain/monitor liquid  from areas other than the    Implementation Item S-effluents prior to safe    ESF pump compartments        3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.            materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The              release requirements of      will be incorporated into ventilation and monitoring   NFPA 805. See NFPA 805       DCPP's Con'figuration systems as described         Transition Report            Control Program. See above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                           Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection Page E-86

Pacific G*d      Electric Company                                                                                        Attachment E - Radioactive Releasessition Paii-~     leti       opn                                                                                        AtahetE-               aiatv       Rlaesto Table E NEI 04-02 Radioactive Release Transition Review Fire Fire         Fire Zone  Pre-Fire       Screened                 Engineering Controls                         Training and Pre-Fire Unit Area Zone         Description   Plan   Rev. In?            Water                         Smoke                  Plan Review Results               Conclusions personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB- (Ul)    3-G      Containment   RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system       Training materials reinforce  Based on the availability of AB-1 (U2)           Spray Pumps   RA-4   03/08          the monitored LRS. The      contains two full-capacity      use of PFPs and Casualty      engineering controls for AB is divided into several  supply fans that draw air       Procedure CP M-6, "Fire"      both smoke and fire drainage zones and each     from the atmosphere             for containment and           suppression water runoff area within a zone is       above the AB and then           monitoring of potential       and use of revised PFPs drained by several screen   discharge it to the           'radioactive effluents. PFP     and training materials, outlets. Each floor drain   occupied areas of the           revisions will identify       DCPP's approach will be flows into the AB sump. building and to the             potentially contaminated      considered acceptable to The collected wastes are    engineered safety feature       areas, provide instruction    meet NFPA 805 released to the             (ESF) pump compartments         for communication with        radioactive release environment at either of    whenever they are in            Radiation Protection and      performance criteria.
the units circulating water operation. During normal        describe precautions to be system discharge            operating conditions,           undertaken for the            The results documenting structures via the ASW      exhaust air is passed           containment and safe          conformance to NFPA 805 System. The ASW System      through a roughing filter       removal of contaminated       radioactive release criteria and Main Circulating        and HEPA filter before          smoke and water runoff in     will be maintained as part Water System dilute the     entering the vent.              these potentially             of DCPP's Configuration collected waste. The                                        contaminated areas.           Control Program. This effluents are continuously  Under accident conditions,      Training material and PFP     program will ensure that monitored and require       the air is exhausted from       revisions will describe the   the radioactive release positive operator action to the ESF pump                    presence and potential use    goals, objective and be released into the        compartments and is             of monitored ventilation      performance criteria will environment.                passed through a charcoal       and drainage systems, if      continue to be satisfied filter in addition to the       such systems are deemed       when considering the During NPO: Floor drains    roughing and HEPA filters.      operational and capable of    possibility that areas that as described above          Exhaust air from other          supporting manual removal     were not contaminated at remain present.             portions of the building will   efforts. The level of detail  the time of NFPA 805 continue to be passed           provided in the revised       transition, and were Provisions are in place to  through roughing and            training materials and        consequently screened-commence                    HEPA filters only. If only      PFPs will meet NFPA 805       out, may become communication between       one supply/exhaust fan set      radioactive release           contaminated in the future the Fire Brigade and        is available under accident     performance criteria.         due to plant operational Radiation Protection and    conditions, exhaust air                                       events.
to contain/monitor liquid   from areas other than the       Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training                Implementation Item S-removal.                    will be isolated.               materials will be revised to  3.20 - The NFPA 805 address radioactive           radioactive release review During NPO: The                 release requirements of       will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805             DCPP's Configuration systems as described            Transition Report             Control Program. See Page E-87

Pacific Gnd      Electric Company                                             0                                    Attachment E - Radioactive Releasessition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                Engineering Controls                     Training and Pre-Fire Unit Area Zone      Description    Plan   Rev. In?           Water                       Smoke                Plan Review Results              Conclusions above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                           Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (U1) 3-J-1    Component     RA-3   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)         Cooling       RA-4   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty engineering controls for Page E-88

Pacific God    Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                         Smoke                Plan Review Results              Conclusions Water Pump                         AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"      both smoke and fire 1-1                                drainage zones and each     from the atmosphere           for containment and           suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify       DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the            (ESF) pump compartments       for communication with        radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent,            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition
                                                                                                                                              *Report Attachment 5, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating Page E-89

Pacific G~    d Electric Company                                                                                  Attachment E - Radioactive ReleaseS sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?           Water                        Smoke                Plan Review Results             Conclusions conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (UW)3-J-2     Component    RA-3   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)         Cooling      RA-4   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty     engineering controls for Water Pump                          AB is divided into several supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire 1-2                                drainage zones and each    from the atmosphere          for containment and          suppression water runoff area within a zone is      above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen  discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain  occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are   engineered safety feature    areas, provide instruction   meet NFPA 805 Page E-90

Pacific Gad     Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone   Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of possibility that areas that as described above          Exhaust air from other        supporting manual removal were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805 DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed Page E-91

Pacific God     Electric Company                                              S                                    Attachment E - Radioactive Releasedsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?            Water                        Smoke               Plan Review Results               Conclusions so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (Ul) 3-J-3   Component     RA-3   05/03     Yes  Floor drains are routed to  The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)        Cooling       RA-4   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Water Pump                          AB is divided into several  supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire 1-3                                 drainage zones and each     from the atmosphere          for containment and          suppression water runoff area within a zone is       above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the          radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will1 be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature    areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be system discharge            operating conditions,        undertaken for the           The results documenting structures via the ASW      exhaust air is passed        containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter    removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before       smoke and water runoff in    will be maintained as part Page E-92

Pacific Gad    Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of possibility that areas that as described above          Exhaust air from other        supporting manual removal were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805 DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a Page E-93

Pacific Glad    Electric Company                                                                                  Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                         Smoke              Plan Review Results               Conclusions slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-1 (Ul) 3-K-1   Component     RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system   Training materials reinforce Based on the availability of AB-1 (U2)        Cooling       RA-4   03/08          the monitored LRS. The      contains two full-capacity  use of PFPs and Casualty     engineering controls for Water Pump                          AB is divided into several  supply fans that draw air   Procedure CP M-6, "Fire"     both smoke and fire 2-1                                 drainage zones and each     from the atmosphere         for containment and          suppression water runoff area within a zone is       above the AB and then       monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the         radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the       revisions will identify      DCPP's approach will be flows into the AB sump. building and to the         potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature   areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments     for communication with       radioactive release environment at either of    whenever they are in        Radiation Protection and     performance criteria.
the units circulating water operation. During normal    describe precautions to be system discharge            operating conditions,       undertaken for the           The results documenting structures via the ASW      exhaust air is passed       containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter   removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before      smoke and water runoff in    will be maintained as part Water System dilute the      entering the vent.          these potentially            of DCPP's Configuration collected waste. The                                    contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP     program will ensure that monitored and require       the air is exhausted from   revisions will describe the  the radioactive release positive operator action to the ESF pump                presence and potential use   goals, objective and be released into the        compartments and is         of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if       continue to be satisfied Page E-94

Pacific Ge   d Electric Company                                             0                                    Attachment E - Radioactive Releaselnsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?          Water                         Smoke                Plan Review Results              Conclusions filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains   roughing and HEPA filters. operational and capable of   possibility that areas that as described above         Exhaust air from other        supporting manual removal    were not contaminated at remain present.            portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to through roughing and          training materials and       consequently screened-commence                   HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between      one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and       is available under accident   performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                    events.
to contain/monitor liquid  from areas other than the     Implementation Item S-effluents prior to safe    ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable Page E-95

Pacific Gid     Electric Company                                              0                                     Attachment E - Radioactive Releaselnsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-1 (Ul) 3-K-2   Component     RA-3   05/03     Yes  Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Cooling       RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Water Pump                          AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire 2-2                                 drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become Page E-96

Pacific God    Electric Company                                                                                  Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                       Smoke                Plan Review Results               Conclusions communication between      one supply/exhaust fan set   radioactive release          contaminated in the future the Fire Brigade and       is available under accident  performance criteria.        due to plant operational Radiation Protection and   conditions, exhaust air                                   events.
to contain/monitor liquid  from areas other than the    Implementation Item S-effluents prior to safe    ESF pump compartments        3.19 - PFPs and training     Implementation Item S-removal.                   will be isolated.            materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The              release requirements of      will be incorporated into ventilation and monitoring   NFPA 805. See NFPA 805       DCPP's Configuration systems as described         Transition Report            Control Program. See above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                           Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish Page E-97

Pacific God     Electric Company                                                                                    Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone      Description   Plan   Rev. In?            Water                         Smoke                Plan Review Results              Conclusions direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-1 (Ul) 3-K-3   Component     RA-3   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Cooling       RA-4   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Water Pump                          AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire 2-3                                 drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated in the future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review Page E-98

Pacific G&d Electric Company                                                                            Attachment E - Radioactive Releaselasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire Fire Zone   Pre-Fire      Screened            Engineering Controls                    Training and Pre-Fire Unit Area Zone  Description   Plan   Rev. In?        Water                    Smoke                Plan Review Results           Conclusions During NPO: The              release requirements of  will be incorporated into ventilation and monitoring   NFPA 805. See NFPA 805   DCPP's Configuration systems as described         Transition Report        Control Program. See above remain present.        Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                       Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated Page E-99

Pacific God     Electric Company                                                                                     Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions gaseous effluents.
o  AR-1 (Ul) 3-L    Auxiliary      RA-5   05/03    Yes   Floor drains are routed to  The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Building       RA-6   03/08          the monitored LRS. The      contains two full-capacity    use of PFPs and Casualty     engineering controls for Elevation 85                         AB is divided into several  supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire and 100 Feet                         drainage zones and each     from the atmosphere           for containment and          suppression water runoff area within a zone is       above the AB and then         monitoring of potential      and use of revised PFPs drained by several screen   discharge it to the           radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP    program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of   possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805       DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are Page E-100

Ah Pacific Gid    Electric Company                                                 .                                Attachment E - Radioactive Releasew              siston Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?           Water                       Smoke                 Plan Review Results             Conclusions monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (UM) 3-M    Safety        RA-5   05/03    Yes   Floor drains are routed to The AB ventilation system    Training materials reinforce Based on the availability of AB-1 (U2)       Injection     RA-6   03/08          the monitored LRS. The     contains two full-capacity   use of PFPs and Casualty     engineering controls for Pumps                               AB is divided into several supply fans that draw air    Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each    from the atmosphere          for containment and          suppression water runoff area within a zone is      above the AB and then        monitoring of potential      and use of revised PFPs drained by several screen  discharge it to the          radioactive effluents. PFP   and training materials, Page E-101

Pacific Gad    Electric Company                                             0                                     Attachment E - Radioactive Releaseisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions outlets. Each floor drain   occupied areas of the         revisions will identify      DCPP's approach will be flows into the AB sump. building and to the           potentially contaminated     considered acceptable to The collected wastes are    engineered safety feature     areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments       for communication with       radioactive release environment at either of    whenever they are in          Radiation Protection and     performance criteria.
the units circulating water operation. During normal      describe precautions to be system discharge            operating conditions,         undertaken for the           The results documenting structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in    will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions, Training material and PFP       program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use   goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal and drainage systems, if         continue to be satisfied filter in addition to the     such systems are deemed      when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of      possibility that areas that as described above          Exhaust air from other        supporting manual removal    were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set radioactive release             contaminated inthe future the Fire Brigade and        is available under accident performance criteria.          due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments 3.19 - PFPs and training             Implementation Item 5-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring NFPA 805. See NFPA 805          DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NEPA 805 Transition Report Attachment 5, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Page E-102

Pacific Go    d Electric Company                                               0                                   Attachment E - Radioactive Releasee sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?           Water                         Smoke               Plan Review Results              Conclusions Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-A (UM) 3-N     Safety        RA-5   05/03    Yes   Floor drains are routed to The AB ventilation system     Training materials reinforce Based on the availability of AB-1 (U2)        Injection     RA-6   03/08          the monitored LRS. The      contains two full-capacity   use of PFPs and Casualty     engineering controls for Pumps                               AB is divided into several supply fans that draw air     Procedure CP M-6, "Fire"     both smoke and fire drainage zones and each from the atmosphere              for containment and          suppression water runoff area within a zone is       abovethe AB and then         monitoring of potential      and use of revised PFPs drained by several screen discharge it to the            radioactive effluents. PFP   and training materials, outlets. Each floor drain   occupied areas of the        revisions will identify      DCPP's approach will be flows into the AB sump. building and to the          potentially contaminated     considered acceptable to The collected wastes are engineered safety feature       areas, provide instruction   meet NFPA 805 released to the             (ESF) pump compartments      for communication with       radioactive release environment at either of    whenever they are in         Radiation Protection and     performance criteria.
the units circulating water operation. During normal     describe precautions to be system discharge            operating conditions,        undertaken for the           The results documenting Page E-103

Pacific G&d Electric Company                                                                                   Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone  Pre-Fire      Screened                 Engineering Controls                       Training and Pre-Fire Unit Area Zone  Description   Plan   Rev. In?          Water                          Smoke                Plan Review Results              Conclusions structures via the ASW      exhaust air is passed         containment and safe         conformance to NFPA 805 System. The ASW System      through a roughing filter     removal of contaminated      radioactive release criteria and Main Circulating        and HEPA filter before        smoke and water runoff in will be maintained as part Water System dilute the     entering the vent.            these potentially            of DCPP's Configuration collected waste. The                                      contaminated areas.          Control Program. This effluents are continuously  Under accident conditions,    Training material and PFP program will ensure that monitored and require       the air is exhausted from     revisions will describe the  the radioactive release positive operator action to the ESF pump                  presence and potential use goals, objective and be released into the        compartments and is           of monitored ventilation     performance criteria will environment.                passed through a charcoal     and drainage systems, if     continue to be satisfied filter in addition to the     such systems are deemed when considering the During NPO: Floor drains    roughing and HEPA filters. operational and capable of possibility that areas that as described above          Exhaust air from other        supporting manual removal were not contaminated at remain present.             portions of the building will efforts. The level of detail the time of NFPA 805 continue to be passed         provided in the revised      transition, and were Provisions are in place to  through roughing and          training materials and       consequently screened-commence                    HEPA filters only. If only    PFPs will meet NFPA 805      out, may become communication between       one supply/exhaust fan set    radioactive release          contaminated in the future the Fire Brigade and        is available under accident   performance criteria.        due to plant operational Radiation Protection and    conditions, exhaust air                                    events.
to contain/monitor liquid   from areas other than the     Implementation Item S-effluents prior to safe     ESF pump compartments         3.19 - PFPs and training     Implementation Item S-removal.                    will be isolated.             materials will be revised to 3.20 - The NFPA 805 address radioactive          radioactive release review During NPO: The               release requirements of      will be incorporated into ventilation and monitoring    NFPA 805. See NFPA 805 DCPP's Configuration systems as described          Transition Report            Control Program. See above remain present.         Attachment S, Table S-3. NFPA 805 Transition Report Attachment S, All radioactive                                            Table S-3.
atmospheres are monitored for radioactivity concentration during normal operating conditions and accident conditions. High radiation in any of these areas is monitored in the Control Room. In all modes of operation, the ventilation flow patterns are designed so that the air flows from areas of lower potential contamination to areas of higher potential Page E-104

Pacific GdOd Electric Company                                                                                     Attachment E - Radioactive Releaseesition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire    Fire Zone   Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone    Description    Plan   Rev. In?           Water                        Smoke                Plan Review Results              Conclusions contamination. The system is balanced so that the building is normally under a slight negative pressure.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (UL1)3-Q-2 Motor Driven   RA-7   05/03    Yes   Floor drains are routed to  Each unit is served by a     Training materials reinforce Based on the availability of AB-1 (U2)      Auxiliary      RA-8   03/08          the monitored LRS. Each     similar but separate         use of PFPs and Casualty engineering controls for Feedwater                            floor drain flows into the  FHBVS. The FHBVS can         Procedure CP M-6, "Fire"     both smoke and fire Pumps                                AB sump. The collected      operate in either of two     for containment and          suppression water runoff wastes are released to the  configurations, a normal     monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine   radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The revisions will identify        DCPP's approach will be system discharge            difference between the       potentially contaminated     considered acceptable to structures via the ASW      configurations is the        areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two Radiation Protection and          performance criteria.
Water System dilute the     full-capacity supply fans    describe precautions to be collected waste. The        that collect air from along  undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,   containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct      removal of contaminated      radioactive release criteria positive operator action to work in the corridors and    smoke and water runoff in will be maintained as part be released into the        equipment compartments       these potentially            of DCPP's Configuration environment.                below the SFP.               contaminated areas.          Control Program. This Training material and PFP program will ensure that During NPO: Floor drains    During normal operation,     revisions will describe the  the radioactive release Page E-105

Pacific G&d Electric Company                                                                                   Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire  Fire Zone  Pre-Fire      Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone  Description   Plan   Rev. In?          Water                         Smoke                 Plan Review Results              Conclusions as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to    operational and capable of   possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through    provided in the revised      transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high    Implementation Item S-radiation, as measured by     3.19 - PFPs and training     Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the   address radioactive          radioactive release review normal operating exhaust      release requirements of      will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide Page E-106

Pacific GAd     Electric Company                                               0                                    Attachment E - Radioactive Releaseasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone  Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?            Water                        Smoke                 Plan Review Results              Conclusions precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
1 AB-1 (Ul)  3-R    Spent Fuel    RA-11  05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce  Based on the availability of AB-1 (U2)        Pool          RA-12  03/08          the monitored LRS. Each     similar but separate          use of PFPs and Casualty     engineering controls for floor drain flows into the  FHBVS. The FHBVS can          Procedure CP M-6, "Fire"     both smoke and fire AB sump. The collected      operate in either of two      for containment and          suppression water runoff wastes are released to the  configurations, a normal      monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify       DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    .program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters: Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item 5-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust release requirements of           will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition Page E-107

Pacific G~d    Electric Company                                                 0                                  Attachment E - Radioactive Releaseoisition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened                 Engineering Controls                    Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?            Water                        Smoke               Plan Review Results              Conclusions exhausted through HEPA                                   Report Attachment S, and/or charcoal filters.                                 Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
0 AB-1 (UW) 3-S    Auxiliary      RA-1 1  05/03    Yes   Floor drains are routed to  Each unit is served by a    Training materials reinforce Based on the availability of AB-1 (U2)       Building       RA-12   03/08          the monitored LRS. Each     similar but separate        use of PFPs and Casualty     engineering controls for Elevation 140                         floor drain flows into the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"     both smoke and fire Feet                                  AB sump. The collected      operate ineither of two     for containment and          suppression water runoff wastes are released to the  configurations, a normal    monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine  radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The  revisions will identify      DCPP's approach will be system discharge            difference between the      potentially contaminated     considered acceptable to structures via the ASW      configurations is the       areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two     Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans   describe precautions to be collected waste. The        that collect air from along undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,  containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct     removal of contaminated      radioactive release criteria positive operator action to work inthe corridors and    smoke and water runoff in    will be maintained as part be released into the        equipment compartments      these potentially            of DCPP's Configuration Page E-108

Pacific Gad     Electric Company                                                                                  Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      FireZone   Pre-Fire      Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description    Plan   Rev. In?          Water                        Smoke                 Plan Review Results              Conclusions environment.               below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains   During normal operation,      revisions will describe the  the radioactive release as described above         one non-vital exhaust fan     presence and potential use   goals, objective and remain present.            is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to roughing and HEPA filter      such systems are deemed      when considering the commence                   before being discharged to operational and capable of      possibility that areas that communication between      the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and       removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and   exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid  charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe    addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                   HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust      release requirements of      will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805       DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication Page E.109

Pacific Gad     Electric Company                                                                                     Attachment E - Radioactive R leaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire      Fire Zone   Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?            Water                        Smoke                 Plan Review Results              Conclusions between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-1 (Ul) 3-T-2   Motor Driven  RA-15   05/03    Yes   Floor drains are routed to  Each unit is served by a      Training materials reinforce Based on the availability of AB-1 (U2)        Auxiliary     RA-16   03/08          the monitored LRS. Each     similar but separate          use of PFPs and Casualty     engineering controls for Feedwater                            floor drain flows into the  FHBVS. The FHBVS can          Procedure CP M-6, "Fire"     both smoke and fire Pumps                                AB sump. The collected      operate in either of two      for containment and          suppression water runoff wastes are released to the  configurations, a normal      monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine    radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The    revisions will identify      DCPP's approach will be system discharge            difference between the        potentially contaminated     considered acceptable to structures via the ASW      configurations is the         areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two       Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans     describe precautions to be collected waste. The        that collect air from along   undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,    containment and safe         conformance to NFPA 805 monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action to work in the corridors and     smoke and water runoff in    will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above          one non-vital exhaust fan     presence and potential use   goals, objective and remain present.             is in operation and the air of monitored ventilation       performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed      when considering the commence                    before being discharged to operational and capable of      possibility that areas that communication between       the plant vent. In the iodine supporting manual removal    were not contaminated at the Fire Brigade and        removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid   charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe     addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust release requirements of           will be incorporated into Page E-110

Pacific Gad    Electric Company                                                0                                 Attachment E - Radioactive ReleaseSsition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire       Screened                 Engineering Controls                     Training and Pre-Fire Unit Area Zone     Description   Plan   Rev. In?            Water                        Smoke               Plan Review Results             Conclusions fan. Ventilation air from   NFPA 805. See NFPA 805       DCPP's Configuration areas containing            Transition Report            Control Program. See radioactive materials is    Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                   Report Attachment S, and/or charcoal filters.                                 Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any release, PFPs provide instructions to establish direct communication between the Fire Brigade and Radiation Protection personnel and provide precautions for containing, monitoring, and safely releasing contaminated gaseous effluents.
2 AB-1 (U1) 3-W    Spent Fuel   RA-17   05/03    Yes   Floor drains are routed to  Each unit is served by a    Training materials reinforce Based on the availability of AB-1 (U2)       Pool         RA-18   05/03          the monitored LRS. Each     similar but separate        use of PFPs and Casualty     engineering controls for RA-19   05/03          floor drain flows into the  FHBVS. The FHBVS can        Procedure CP M-6, "Fire"     both smoke and fire RA-20   05/03          AB sump. The collected      operate ineither of two     for containment and          suppression water runoff wastes are released to the  configurations, a normal    monitoring of potential      and use of revised PFPs environment at either of    configuration or an iodine  radioactive effluents. PFP   and training materials, the units circulating water removal configuration. The  revisions will identify      DCPP's approach will be system discharge            difference between the      potentially contaminated     considered acceptable to structures via the ASW      configurations is the       areas, provide instruction   meet NFPA 805 System. The ASW System      treatment of exhaust air. for communication with       radioactive release and Main Circulating        Each FHBVS contains two     Radiation Protection and     performance criteria.
Water System dilute the     full-capacity supply fans   describe precautions to be collected waste. The        that collect air from along undertaken for the           The results documenting effluents are continuously  one side of the fuel pool,  containment and safe         conformance to NFPA 805 Page E-1 11

Pacific Gad    Electric Company                                                                                    Attachment E - Radioactive Releasiasition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone  Pre-Fire      Screened                 Engineering Controls                        Training and Pre-Fire Unit Area Zone     Description   Plan Rev.       In?           Water                         Smoke                 Plan Review Results              Conclusions monitored and require       and discharge into duct       removal of contaminated      radioactive release criteria positive operator action-to work in the corridors and     smoke and water runoff in will be maintained as part be released into the        equipment compartments        these potentially            of DCPP's Configuration environment.                 below the SFP.                contaminated areas.          Control Program. This Training material and PFP    program will ensure that During NPO: Floor drains    During normal operation,      revisions will describe the  the radioactive release as described above           one non-vital exhaust fan     presence and potential use goals, objective and remain present.             is in operation and the air   of monitored ventilation     performance criteria will is passed through a           and drainage systems, if     continue to be satisfied Provisions are in place to  roughing and HEPA filter      such systems are deemed when considering the commence                     before being discharged to operational and capable of possibility that areas that communication between        the plant vent. In the iodine supporting manual removal were not contaminated at the Fire Brigade and         removal configuration,        efforts. The level of detail the time of NFPA 805 Radiation Protection and    exhaust air passes through provided in the revised         transition, and were to contain/monitor liquid    charcoal adsorbers in         training materials and       consequently screened-effluents prior to safe      addition to roughing and      PFPs will meet NFPA 805      out, may become removal.                    HEPA filters. Automatic       radioactive release          contaminated in the future initiation of the iodine      performance criteria.        due to plant operational removal configuration                                      events.
occurs in response to high Implementation Item S-radiation, as measured by 3.19 - PFPs and training         Implementation Item S-radiation monitors in the     materials will be revised to 3.20 - The NFPA 805 FHB, or upon failure of the address radioactive            radioactive release review normal operating exhaust      release requirements of      will be incorporated into fan. Ventilation air from     NFPA 805. See NFPA 805 DCPP's Configuration areas containing              Transition Report            Control Program. See radioactive materials is      Attachment S, Table S-3. NFPA 805 Transition exhausted through HEPA                                     Report Attachment S, and/or charcoal filters.                                   Table S-3.
During NPO: The ventilation and monitoring systems as described above remain present.
If normal ventilation is unavailable, smoke will be removed using standard industry manual ventilation techniques (i.e., portable smoke ejectors and flexible ducts) to the outside or to an area where normal ventilation will remove the smoke. Prior to any Page E-112

Pacific God    Electric Company                                                                                      Attachment E - Radioactive Release&sition Table E NEI 04-02 Radioactive Release Transition Review Fire Fire     Fire Zone    Pre-Fire       Screened                 Engineering Controls                      Training and Pre-Fire Unit Area Zone     Description     Plan   Rev. In?           Water                          Smoke                Plan Review Results              Conclusions}}