View source for NRC 2013-0028, License Amendment Request 271 - Transition to 10 CFR 50.48(c) - NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. Part 1 of 3

{{Adams
| number = ML13182A353
| issue date = 06/26/2013
| title = License Amendment Request 271 - Transition to 10 CFR 50.48(c) - NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. Part 1 of 3
| author name = Meyer L
| author affiliation = NextEra Energy Point Beach, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person = 
| case reference number = NRC 2013-0028
| document type = Letter type:NRC, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 404
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:NExTera ENERGY PPITB EACH June 26, 2013 NRC 2013-0028 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Request 271 Transition to 10 CFR 50.48(c) - NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition

==References:==
: 1. Nuclear Management Company, LLC, letter to NRC dated November 30, 2005, "Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805. Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition." (ML053460342)
: 2. NextEra Energy letter to NRC dated June 23, 2011, "Request for Extension of Enforcement Discretion and Commitment to Submittal Dates for 10 CFR 50.48(c)
License Amendment Request" (ML11178A237)
: 3. NRC Letter to NextEra Energy Point Beach, LLC, dated July 29, 2011, "Point Beach Nuclear Plant, Units 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. ME6646 and ME6647)"
(ML112000214)
In accordance with the commitment in Reference 1, with the revised schedule requested in Reference 2 and granted in Reference 3, and pursuant to 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests to amend Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively. Implementation of the regulatory requirements in the proposed license amendment request (LAR) would enable PBNP to adopt a new fire protection licensing basis, which complies with the requirements of 10 CFR 50.48(a) (fire protection plan) and (c) (National Fire Protection Association Standard NFPA 805) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants."
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390:
Attachments C, D, G, S, and W of the Enclosure to this letter contain security-related information. Upon removal of Attachments C, D, G, S, and W of the Enclosure, this letter is uncontrolled.                                                                                  4 00(o

Document Control Desk Page 2 As documented in this request, NextEra PBNP has met the regulatory requirements for the transition of its fire protection licensing basis. This license amendment does not present a significant hazards consideration and the criteria have been met for categorical exclusion from the need for an environmental assessment.
Information associated with NextEra PBNP's fire protection transition is provided in the enclosed Transition Report, including the technical and regulatory justifications required to support this LAR, Major topics in this Transition Report are presented as Attachments A through W, summarized as follows:
* Attachment A - NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements
* Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment -
Methodology Review
* Attachment C - NEI 04-02 Table B Fire Area Transition (Security Related Information)
* Attachment D - Non-Power Operational Modes Transition (Security Related Information)
* Attachment E - NEI 04-02 Radioactive Release Transition
* Attachment F - Fire-Induced Multiple Spurious Operations Resolution
    " Attachment G - Recovery Actions Transition (Security Related Information)
* Attachment H - NFPA 805 Frequently Asked Questions Summary Table
    " Attachment I - Definition of Power Block
* Attachment J - Fire Modeling V&V
* Attachment K - Existing Licensing Action Transition
* Attachment L - NFPA 805 Chapter 3 Requirements for Approval
* Attachment M - License Condition Changes
* Attachment N - Technical Specification Changes
* Attachment 0 - Orders and Exemptions
* Attachment P - RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4)
* Attachment Q - No Significant Hazards Evaluations
* Attachment R - Environmental Considerations Evaluation
* Attachment S - Modifications and Implementation Items (Security Related Information)
* Attachment T - Clarification of Prior NRC Approvals
* Attachment U - Internal Events PRA Quality
* Attachment V - Fire PRA Quality
* Attachment W - Fire PRA Insights (Security Related Information)
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390:
Attachments C, D, G, S, and W of the Enclosure to this letter contain security-related information. Upon removal of Attachments C, D, G, S, and W of the Enclosure, this letter is uncontrolled.

Document Control Desk Page 3 The proposed License changes (Attachment M to the Enclosure) and Technical Specification changes (Attachment N to the Enclosure) have been reviewed by the Plant Operations Review Committee.
In accordance with the guidance in Regulatory Position C.2.2.4.2 of Regulatory Guide 1.205, Revision 1, the total risk change associated with the implementation of NFPA 805 for the overall plant was evaluated. Upon completion of the proposed modifications and implementation items, as referenced in the enclosed Transition Report, Section 4.8.2 and Attachment S, the total change in risk associated with NextEra PBNP's transition to NFPA 805 will be consistent with the acceptance guidelines in 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.
NextEra has determined that a number of fire zones represent a higher contribution to the risk of PBNP core damage frequency (CDF) as a result of a fire than other fire zones. These risk contributions will be addressed by plant modifications identified for implementation of NFPA 805, as described in Attachment S of the Enclosure to this letter. These higher fire risk contribution fire zones will be subject to interim compensatory measures until NRC approval of the NFPA 805 license amendment request and PBNP installation of the modifications associated with each specific fire zone. This risk determination is based on the results of the fire probabilistic risk assessment (PRA) of PBNP as an NFPA 805 "compliant plant," as defined in Attachment W of the Enclosure to this letter. The interim compensatory measures for each higher risk fire zone will apply until the modifications associated with each of those fire zones are installed. The additional interim compensatory measures are identified as regulatory commitments in an attachment to this letter.
There are five new regulatory commitments in this submittal as identified in the attachment to this letter and no revision of existing regulatory commitments.
The enclosed Transition Report, Section 5.5, contains NextEra PBNP's proposed implementation schedule for transitioning to the new fire protection licensing basis. The plant modifications and implementation items identified in Tables S-2 and S-3, respectively, of Attachment S of the enclosed Transition Report, are proposed to support approval of the LAR and may change during the NRC review period.
NextEra PBNP requests that Attachments C, D, G, S, and W to the Enclosure, which contain sensitive security-related information, be withheld from public disclosure in accordance with 10 CFR 2.390.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, Wl 54241 Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390:
Attachments C, D, G, S, and W of the Enclosure to this letter contain security-related information. Upon removal of Attachments C, D, G, S, and W of the Enclosure, this letter is uncontrolled.

Document Control Desk Page 4 In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.
If you have any questions regarding this LAR, please contact Mike Millen at (920) 755-7845.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 26, 2013.
Very truly yours, NextEra Energy Point Beach, LLC Larry       f:
Site Vice President Attachment (Regulatory Commitments for Interim Compensatory Actions)
Enclosure (Transition Report) cc:     Administrator, Region III, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241 Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390:
Attachments C, D, G, S, and W of the Enclosure to this letter contain security-related information. Upon removal of Attachments C, D, G, S, and W of the Enclosure, this letter is uncontrolled.

ATTACHMENT NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 271 Transition to 10 CFR 50.48(c) - NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition REGULATORY COMMITMENTS FOR INTERIM COMPENSATORY ACTIONS Two Pages Follow
: 1. NextEra will maintain the existing hourly fire watch inspections for the identified higher risk fire zones at PBNP (see table below), until the plant modifications for a specific fire zone described in Attachment S of the enclosure to this letter are installed. The requirements for these inspections are specified in existing site procedures. The purpose of these inspections includes inspecting for combustible materials not normally located in the fire zone, work activities that will introduce potential ignition sources in the fire zone, and any other abnormal activity that could raise the likelihood of a fire starting in the fire zone.
: 2. NextEra will implement by August 30, 2013, stricter control of transient combustibles for the PBNP higher risk fire zones (see table below), until the plant modifications for a specific fire zone described in Attachment S of the enclosure to this letter are installed. These fire zones will be designated in the appropriate site procedure to require specific approvals beyond standard. These stricter controls include verification that appropriate fire detection and suppression are in service and that no hot work activity is allowed in the fire zone without prior approval.
: 3. NextEra will implement by August 30, 2013, stricter controls of hot work activities (e.g.,
welding, cutting, grinding) in the higher risk fire zones (see table below), until the plant modifications for a specific fire zone described in Attachment S of the enclosure to this letter are installed. These activities will be treated as high risk activities requiring stricter controls including developing a risk management plan and conducting a risk classification challenge board.
: 4. NextEra will continue the monthly thermography scans for Appendix R equipment in the PBNP higher risk fire zones (see table below), until the plant modifications for a specific fire zone described in Attachment S of the enclosure to this letter are installed. The purpose of these scans is to determine equipment condition through infrared thermal imaging and diagnosis by detecting electrical and mechanical equipment deterioration and taking preventive action prior to failure.
: 5. NextEra will continue the compensatory actions for a Halon fire suppression system out of service for the higher risk fire zones (see table below), until the plant modifications for a specific fire zone described in Attachment S of the enclosure to this letter are installed.
These actions include providing backup fire suppression capability.
1

PBNP Higher Risk Fire Zones for NFPA 805 Transition Item  Fire Zone                           Description 1       166    MCC Room- 2B32 (Primary Auxiliary Building 8' Elevation) 2       187    Monitor Tank Room (Primary Auxiliary Building 26' Elevation) 3       237    CC HX & Boric Acid Tank Room (Primary Auxiliary Building 46' E4evation) 4     304N     AFW Pump Room - North (Control Building 8' Elevation) 5    304S    AFW Pump Room - South (Control Building 8' Elevation) 6       305    4160 V Vital Switchgear Room (Control Building 8' Elevation) 7       318    Cable Spreading Room (Control Building 26' Elevation) 2

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 271 Transition to 10 CFR 50.48(c) - NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition TRANSITION REPORT Page 1 of 1581 Security-Related Information - Withhold from Public Disclosure Under 10 CFR 2.390:
Attachments C, D, G, S, and W of the Enclosure to this letter contain security-related information. Upon removal of Attachments C, D, G, S, and W of the enclosure, this letter is uncontrolled.

NextEra Energy Point Beach, LLC Point Beach Nuclear Plant, Units I and 2 Docket Numbers 50-266 and 50-301 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition NEXTeFa" ENERGYc Transition Report Revision 0 June 2013

NextEra PBNP                                                                                             NFPA 805 Transition Report TABLE OF CONTENTS Executive Summary .............................................................................................................          iv Acronym List ........................................................................................................................ vi 1.0   IN TR O D UC TIO N............................................................................................................       1 1.1   Background .....................................................................................................               1 1.1.1  NFPA 805- Requirements and Guidance ............................................                                        1 1.1.2  Transition to 10 CFR 50.48(c) ................................................................                          2 1.2   P urpose .........................................................................................................             4 2.0  OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM ...................................                                                      5 2.1    Current Fire Protection Licensing Basis ................................................................                       5 2.2    NRC Acceptance of the Fire Protection Licensing Basis ......................................                                   5 3.0  TRANSITION PROCESS ..........................................................................................                         8 3.1    Background .....................................................................................................               8 3.2    NFPA805 Process .............................................................................................                  8 3.3    NEI 04 NFPA 805 Transition Process .......................................................                                9 3.4    NFPA 805 Frequently Asked Questions (FAQs) ..............................................                                    11 4.0   COMPLIANCE WITH NFPA 805 REQUIREMENTS ..............................................                                               12 4.1    Fundamental Fire Protection Program and Design Elements .........................                                            12 4.1.1  Overview of Evaluation Process ............................................................                           12 4.1.2  Results of the Evaluation Process ......................................................                              14 4.1.3  Definition of Power Block and Plant .....................................................                             15 4.2    Nuclear Safety Performance Criteria ................................................................                         15 4.2.1  Nuclear Safety Capability Assessment Methodology ............................                                         16 4.2.2  Existing Engineering Equivalency Evaluation Transition .....................                                          24 4.2.3  Licensing Action Transition ..................................................................                        25 4.2.4  Fire Area Transition .............................................................................                    28 4.3    Non-Power Operational Modes ......................................................................                           31 4.3.1  Overview of Evaluation Process ..........................................................                             31 4.3.2  Results of the Evaluation Process ......................................................                              34 4.4    Radioactive Release Performance Criteria ....................................................                                35 4.4.1  Overview of Evaluation Process ............................................................                           35 4.4.2  Results of the Evaluation Process ......................................................                              36 4.5    Fire PRA and Performance-Based Approaches ..............................................                                     36 4.5.1  Fire PRA Development and Assessment ............................................                                      36 Revision 0                                                                                                                            Page i

NextEra PBNP                                                                                               NFPA 805 Transition Report 4.5.2     Performance-Based Approaches .........................................................                              39 4.6   Monitoring Program ........................................................................................                   43 4.6.1     Overview of NFPA 805 Requirements and NEI 04-02 Guidance on the NFPA 805 Fire Protection System and Feature Monitoring Program ...... 43 4.6.2     Overview of Post-Transition NFPA 805 Monitoring Program ............... 44 4.7   Program Documentation, Configuration Control, and Quality Assurance .....                                                     50 4.7.1     Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 .............................................................................................              50 4.7.2     Compliance with Configuration Control Requirements in Sections 2.7.2 and 2.2.9 of NFPA 805 .........................................................................                     52 4.7.3     Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 .... 55 4.8   Summary of Results ........................................................................................                   58 4.8.1     Results of the Fire Area Review ..........................................................                          58 4.8.2     Plant Modifications and Items to be Completed During the Implementation Phase .........................................................................                      58 4.8.3     Supplemental Information - Other Licensee Specific Issues ............... 59

==5.0   REGULATORY EVALUATION==
 .................................................................................                          123 5.1   Introduction - 10 CFR 50.48 .............................................................................                   123 5.2   R egulatory 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 UFSA R ......................................................................................               129 5.5   Transition Implementation Schedule .................................................................                        129 6.0   R EFER EN C ES ...........................................................................................................       130 ATTA C HMENTS ................................................................................................................         137 A. NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program &
Design Elements .................................................................................................                A-1 B. NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review ....................................................................................................................... B -1 C. NEI 04-02 Table B 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 F. Fire-Induced Multiple Spurious Operations Resolution ..................................                                           F-1 Revision 0                                                                                                                           Page ii

NextEra PBNP                                                                                       NFPA 805 Transition Report G. Recovery Actions Transition ..................................................................................            G-1 H. NFPA 805 Frequently Asked Question Summary Table .................................. H-1 I. Definition of Power 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 Condition Changes ................................................................................                M-1 N. Technical Specification Changes .......................................................................                    N-1
: 0. Orders and Exemptions ......................................................................................               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 PRA Quality ...............................................................................                U-1 V. Fire PRA Q uality .................................................................................................... V-1 W. Fire PRA Insights .................................................................................................      W -1 Page iii Revision 00                                                                                                                  Page iii

NextEra PB3NP                                                          Executive Summary Executive Summary NextEra Energy Point Beach, LLC (NextEra) will transition the Point Beach Nuclear Plant Units 1 and 2 (PBNP) fire protection program to a new Risk-Informed, Performance-Based (RI-PB) alternative per 10 CFR 50.48(c) which incorporates by reference NFPA 805. The fire protection licensing basis per 10 CFR 50.48(b) and 10 CFR 50, Appendix R, which has been in place since the early 1980s will be superseded. The voluntary adoption of 10 CFR 50.48(c) by PBNP does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, GDC 3, Fire Protection. However, compliance with the new rule establishes compliance with these sections.
Nuclear Management Company (NMC) was the licensee for PBNP when the decision was made to transition the fire protection license basis. NMC submitted a letter of intent to the NRC on November 30, 2005 and submitted a revised and supplemented letter of intent on March 14, 2006 for PBNP to adopt NFPA 805 in accordance with 10 CFR 50.48(c). By letter dated September 7, 2006, the NRC granted a three-year enforcement discretion period. By letter dated September 11, 2008, and in accordance with Federal Register Notice 73 FR 52705, FPL Energy Point Beach LLC requested that enforcement discretion be extended for PBNP until six months after the safety evaluation is issued for the second pilot plant. The NRC granted the enforcement discretion extension on November 20, 2008. By letter dated June 23, 2011, and in accordance with SECY-1 1-0061, NextEra Energy Point Beach, LLC requested that the due date for the 10 CFR 50.48(c) license amendment request be extended to June 30, 2013. The NRC granted the enforcement discretion extension on July 29, 2011. The enforcement discretion period will continue until the NRC issues a License Amendment.
This submittal incorporates lessons learned from the Requests for Additional Information for the pilot plants, and the generic NFPA 805 License Amendment Request template developed by the Nuclear Energy Institute NFPA 805 Task Force.
The transition process consists of a review and update of PBNP documentation, including the development of a Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850 as guidance. This Transition Report summarizes the transition process and results. This Transition Report 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 Transition Report provides a summary of compliance with the following NFPA 805 requirements:
    " Fundamental Fire Protection Program Elements and Minimum Design Requirements
    " Nuclear Safety Performance Criteria, including:
Revision 0                                                                         Page iv

NextEra PBNP                                                            Executive Summary o   Non-Power Operational Modes o   Fire Risk Evaluations
    " Radioactive Release Performance Criteria
    " Monitoring Program
    " Program Documentation, Configuration Control, and Quality Assurance Section 5 of the Transition Report provides regulatory evaluations and associated attachments, including:
    " Changes to License Condition
    " Changes to Technical Specifications, Orders, and Exemptions,
    " Determination of No Significant Hazards and evaluation of Environmental Considerations.
The attachments to the Transition Report include detail to support the transition process and results.
Attachment H contains the approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in Regulatory Guide (RG) 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this License Amendment Request.
Page v Revision 00                                                                         Page v

NextEra PBNP                                                    Acronym List Acronym List ac    Alternating Current ACP   Auxiliary Control Panel ADAMS Agency-wide Document Access and Management System ADS   Automatic Depressurization System ADV   Atmospheric Steam Dump Valves AFW   Auxiliary Feedwater AHJ   Authority Having Jurisdiction AM    Administrative Manual ANS   American Nuclear Society ANSI  American National Standards Institute AOV   Air Operated Valve APCSB Auxiliary Power Conversion Systems Branch AR    Action Request ARB   Alarm Response Book ARP   Auxiliary Relay Panel ASD   Alternative Shutdown ASME  American Society of Mechanical Engineers ASTM  American Society for Testing and Materials BE    Basic Event(s)
BOP   Balance Of Plant BTP   Branch Technical Position Btu   British Thermal Unit BWR   Boiling Water Reactor BWROG Boiling Water Reactor Owners Group CC    Capability Category CCDP  Conditional Core Damage Probability CCW   Component Cooling Water CDF   Core Damage Frequency CFAST Consolidated Model of Fire Growth and Smoke Transport Revision 0                                                           Page vi

NextEra PBNP                                              Acronym List CFR   Code of FederalRegulations CLB   Current Licensing Basis CLERP Conditional Large Early Release Probability CRD   Control Rod Drive CRS   Control Room Supervisor CS    Condensate System CST   Condensate Storage Tank CT    Current Transformer dc    Direct Current DCCP  DC Control Power DG    Design Guideline / Diesel Generator DGB   Diesel Generator Building DID   Defense-In-Depth DCCP  dc Control Power EA    Engineering Analysis EC    Engineering Change ECCS  Emergency Core Coolant System EDG   Emergency Diesel Generator EEEE  Existing Engineering Equivalency Evaluations EP    Emergency Plan EPM   Engineering Planning and Management, Inc.
EPRI  Electric Power Research Institute ER    Equipment Reliability ERFBS Electrical Raceway Fire Barrier System F&Os  Facts and Observations FO    Fuel Oil FACP  Fire Alarm Control Panel FAP   Fire Attack Plan FAQs  Frequently Asked Questions FDS   Fire Dynamics Simulator FEP   Fire Emergency Plan Page vii Revision 00                                                    Page vii

NextEra PBNP                                                   Acronym List NextEra PBNP                                                   Acronym List FFD   Fitness For Duty FHAR  Fire Hazards Analysis Report FIRM  Fire Induced Risk Model FOP   Fire Organization Plan FP    Fire Protection FPEE  Fire Protection Engineering Evaluation FPER  Fire Protection Evaluation Report FPL   Florida Power & Light Company FPP   Fire Protection Program FPRA  Fire Probabilistic Risk Assessment FPTE  Fire Protection Technical Evaluation Fr    Fire Froude Number FR    Federal Register FRE   Fire Risk Evaluation FSA   Fire Safety Analyses FSAR  Final Safety Analysis Report FW    Feedwater GDC   General Design Criterion/Criteria GET   General Employee Training GL    Generic Letter gpm   Gallons Per Minute HEAF  High Energy Arcing Fault HEP   Human Error Probability HFE   Human Failure Event HGL   Hot Gas Layer HP    Health Physics HRE   Higher Risk Evolution HRR   Heat Release Rate HVAC  Heating, Ventilation, and Air Conditioning HW    Handwheel (valve)
IEEE  Institute of Electrical and Electronics Engineers Page viii Revision 00 Revision                                                            Page viii

NextEra PBNP                                                    Acronym List NextEra PBNP                                                    Acronym List IMC    Inspection Manual Chapter IMP    Implementation Item IN     Information Notice INPO   Institute of Nuclear Power Operations IPCEA  Insulated Power Cable Engineer's Association IT&M   Inspection, Testing, and Maintenance kg      Kilogram kJ      Kilo Joule KSF     Key Safety Function kV      Kilovolt LAR     License Amendment Request LERF    Large Early Release Frequency LTAM    Long-Term Asset Management MCA     Multi-Compartment Analysis MCB     Main Control Board MCC     Motor Control Center MCR     Main Control Room MOV     Motor Operated Valve MR      Modification Request MSIV    Main Steam Isolation Valve MSO     Multiple Spurious Operation MSPI    Mitigating Systems Performance Index (Indicator)
N/A     Not Applicable NAMS    Nuclear Asset Management System NANTeL  National Academy for Nuclear Training eLearning NEI     Nuclear Energy Institute NFPA    National Fire Protection Association NextEra NextEra Energy Point Beach, LLC NMC     Nuclear Management Company, LLC NP      Nuclear Procedure NPC     Nuclear Plant Correspondence Page ix Revision 00                                                          Page ix

NextEra PBNP                                               Acronym List NextEra PBNP                                               Acronym List NPL   Nuclear Plant Letter NPO   Non-Power Operation NRC   U.S. Nuclear Regulatory Commission NSB   North Service Building NSCA  Nuclear Safety Capability Assessment NUC   Nuclear OCA   Owner-Controlled Area OE    Operating Experience OM    Operations Manual OMA   Operator Manual Action PA    Protected Area PAB   Primary Auxiliary Building PAT   Plant Access Training PAU   Physical Analysis Unit PB    Performance-Based / Point Beach PBNP  Point Beach Nuclear Plant PBSAP Point Beach Security Administrative Procedure PC    Periodic Check / Primary Containment PCB   Polychlorinated Biphenyl PCS   Primary Control Station PIC   Process Instrumentation Cabinet PMG   Performance Monitoring Group POS   Plant Operational State PRA   Probabilistic Risk Assessment PSA   Probabilistic Safety Assessment PT    Periodic Testing PWR   Pressurized Water Reactor QA    Quality Assurance RA    Recovery Action RAI   Request for Additional Information RAW   Risk Achievement Worth Page x Revision 00                                                      Page x

NextEra PBNP                                                       Acronym List NextEra PBNP                                                       Acronym List RB       Reactor Building RCA      Radiologically Controlled Area RCP      Reactor Coolant Pump RCPLOCS  Reactor Coolant Pump Lube Oil Collection System REC      Reactor Equipment Cooling RG       Regulatory Guide RHR      Residual Heat Removal RI       Risk-Informed RI-PB    Risk-Informed Performance-Based RIS      Regulatory Issue/Information Summary RMP      Routine Maintenance Procedure RPS      Reactor Protection System RPV      Reactor Pressure Vessel RWST     Refueling Water Storage Tank scf      Standard Cubic Feet SDC      Shutdown Cooling SER      Safety Evaluation Report SFPE     Society of Fire Protection Engineers SM       Shift Manager SR       Supporting Requirement(s)
SRP      Standard Review Plan SRV      Safety Relief Valve SSB      South Service Building SSC      Systems, Structures, and Components SSEL     Safe Shutdown Equipment List / NSCA Equipment List SSPS     Solid State Protection System SW (SWS) Service Water (System)
TBC      Thermal Barrier Cooling TCVFD    Two Creeks Volunteer Fire Department TE       Technical Evaluation TER      Technical Evaluation Report Page xi Revision 0 Revision 0                                                              Page xi

NextEra PBNP                                          Acronym List NextEra PBNP                                          Acronym List T-H   Thermal-Hydraulic TR    Transition Report TRM   Technical Requirements Manual TS    Technical Specifications UFSAR Updated Final Safety Analysis Report UL    Underwriters Laboratory V&V   Verification and Validation VAC   Volts Alternating Current VFDR  Variance From Deterministic Requirements WE    Wisconsin Electric Power Company WO    Work Order yr    Year ZOl   Zone Of Influence Page xii Revision 00                                                Page xii

NextEra PB3NP                                                                           1.0 Introduction

==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 (NFPA 805). NextEra 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)" (NEI 04-02)1 to transition PBNP 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 PBNP 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 requirements. 10 CFR 50.48(c) incorporates by reference, with exceptions, the National Fire Protection Association's NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants- 2001 Edition, as a voluntary alternative to 10 CFR 50.48 Section (b), 10 CFR 50 Appendix R, and 10 CFR 50.48 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 shut down 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:
1 Where  referred to in this document NEI 04-02 is Revision 2 and RG 1.205 is Revision 1.
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NextEra PBNP                                                                       1.0 Introduction NextEra PBNP                                                                       1.0 IntroductIon o   dnf*D Incorporation by                "       '"
Reference                 50.48(c) 0*
National Fire Protection Association Standard NFPA 805 E
NEI 04-02                                  RG 1.205 Endorsement                 ...
k
       .5 GUIDANCE FOR                  IRI-PB PP FOR            UISTING IMPLEMENTING A RI.PS                       LIGHT-WATER NUCLEAR FP PROGRAM UNDER 10                            POWER PLANTS CFR 60.48(c)
Figure 1-1 NFPA 805 Transition - Implementation Requirements/Guidance 1.1.2 Transition to 10 CFR 50.48(c) 1.1.2.1     Start of Transition NMC was the licensee for PBNP when the decision was made to transition the fire protection licensing basis. NMC submitted a letter of intent to the NRC on November 30, 2005 (ML053460342) and submitted a revised and supplemented letter of intent on March 14, 2006 (ML060730265) for PBNP to adopt NFPA 805 in accordance with 10 CFR 50.48(c).
On April 18, 2006, the NRC published in the FederalRegister (Notice 71 FR 19905) a revision to its enforcement policy extending the NFPA 805 transition discretion period from 24 to 36 months.
By letter dated September 7, 2006 (ML061500035), the NRC granted a three-year enforcement discretion period. Therefore, the NRC considered the discretion period for PBNP, which began on November 30, 2005, to expire on November 30, 2008.
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NextEra P13NP                                                                  1.0 Introduction 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 fire protection issues, allowing licensees the option to request an extended enforcement discretion period for submittal of a license amendment request (LAR) if they are pursuing transition to 10 CFR 50.48(c). This revision states that an additional period of enforcement discretion may be granted on a case-by-case basis, if a licensee has made substantial progress in its transition effort. This additional period of enforcement discretion, if granted, would end six months after the date of the safety evaluation approving the second pilot plant LAR review. Following submittal of the LAR, the enforcement discretion would continue in place, without interruption, until NRC approval of the LAR to transition to 10 CFR 50.48(c).
By letter dated September 11, 2008, and in accordance with Federal Register Notice 73 FR 52705, FPL Energy Point Beach LLC requested that enforcement discretion be extended for PBNP until six months after the safety evaluation is issued for the second pilot plant (ML082600482).
By letter dated November 20, 2008, the NRC staff reviewed FPL Energy Point Beach LLC'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 6 months after the date of the safety evaluation approving the second pilot plant LAR (ML083110860).
On December 29, 2010, the NRC issued a safety evaluation for the second pilot plant (ML103630612). Based on this document, the period of enforcement discretion for PBNP was extended to June 29, 2011.
By letter dated June 23, 2011, and in accordance with SECY-1 1-0061, NextEra Energy Point Beach, LLC requested that the due date for the 10 CFR 50.48(c) license amendment request be extended to June 30, 2013 (ML11178A237).
By letter dated July 29, 2011, the NRC staff reviewed NextEra Energy Point Beach LLC's request and granted the enforcement discretion extension to June 30, 2013 (ML112000214).
In addition, in accordance with NRC Enforcement Policy, the enforcement discretion period will continue until the NRC approval of the PBNP license amendment request (LAR) is completed.
1.1.2.2      Transition Process The transition to NFPA 805 includes the following high level activities:
     " A new fire safe shutdown analysis
     " A new Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, as guidance and a revision to the Internal Events PRAs
     " Completion of activities required to transition the pre-transition Licensing Basis to 10 CFR 50.48(c) as specified in NEI 04-02 and RG 1.205 Revision 0                                                                               Page 3

NextEra PBNP                                                                1.0 Introduction 1.2     Purpose The purpose of the Transition Report is as follows:
: 1) Describe the process implemented to transition the current fire protection 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 fire protection program complies with 10 CFR 50.48(c) requirements.
: 4) Describe the new fire protection licensing basis.
: 5) Describe the configuration management processes used to manage post-transition changes to the station and the fire protection program, and resulting impact on the licensing basis.
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NextEra P13NP                                 2.0 Overview of Existing Fire Protection Program 2.0     OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1     Current Fire Protection Licensing Basis Point Beach Nuclear Plant was licensed to operate on October 5, 1970 (Unit 1) and March 8, 1973 (Unit 2). As a result, the Point Beach Nuclear Plant fire protection program is based on compliance with 10 CFR 50.48(a), 10 CFR 50.48(b), and the following License Conditions:
NextEra Energy Point Beach Nuclear Plant Unit 1 license condition 4.F states:
F. NextEra Energy Point Beach shall implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR for the facility and as approved in the Safety Evaluation Report dated August 2, 1979 (and Supplements dated October 21, 1980, January22, 1981, and July 27, 1988) and the safety evaluation issued January8, 1997, for Technical Specification Amendment No. 170, subject to the following provision: NextEra Energy Point Beach may make changes to the approved fire protectionprogram without priorapprovalof the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
NextEra Energy Point Beach Nuclear Plant Unit 2 license condition 4.F states:
F. NextEra Energy Point Beach shall implement and maintain in effect all provisions of the approved fire protection program as described in the FSAR for the facility and as approved in the Safety Evaluation Report dated August 2, 1979 (andSupplements dated October 21, 1980, January22, 1981, and July 27, 1988) and the safety evaluation issued January8, 1997, for Technical Specifications Amendment No. 174, subject to the following provision: NextEra Energy Point Beach may make changes to the approved fire protection program without priorapprovalof the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
2.2     NRC Acceptance of the Fire Protection Licensing Basis In response to the NRC's request, Wisconsin Electric (PBNP licensee at the time) performed a fire hazards analysis which analyzed the PBNP fire protection program against the guidance of Appendix A to BTP APCSB 9.5-1. The results of the analysis, in addition to proposed modifications and additions to the fire protection system, were communicated to the NRC by letter dated June 20, 1977, and served as the basis for the Appendix A to BTP APCSB 9.5-1 safety evaluation, dated August 2, 1979, which was supplemented by safety evaluations dated October 21, 1980, January 22, 1981, May 4, 1981, and July 27, 1988.
In support of compliance with 10 CFR 50 Appendix R, Sections Ill.G, and Ill.J, the NRC granted the following exemptions from the rule:
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NextEra PBNP                                   2.0 Overview of Existinq Fire Protection Proqrarn
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.3, for lack of an automatic fire suppression system in an area in which alternate shutdown is provided (control room) in a safety evaluation dated April 28, 1983.
   "   An exemption from 10 CFR 50 Appendix R, Section Ill.G.2.b, for lack of 20-foot separation and lack of an automatic fire suppression system in an area with redundant trains of cables and equipment (1 B32 MCC area) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section Ill.G.2.b, for lack of 20-foot separation and lack of an automatic fire suppression system in an area with redundant trains of cables and equipment (component cooling water pump room) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.2.b, for lack of 20-foot separation and lack of a full-area automatic fire suppression system in an area with redundant trains of cables and equipment (2B32 MCC area) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.3, for lack of an automatic fire suppression system in an alternate shutdown area (containment spray additive tank and monitor area) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.2.b, for lack of 20-foot separation and lack of a full-area automatic fire suppression system in an area with redundant trains of cables and equipment (safety injection and containment spray pump room) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section Ill.G.2.b, for lack of 20-foot separation without intervening combustibles in an area with redundant trains of cables and equipment (auxiliary feed water pump room) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.2.b, for lack of 20-foot separation without intervening combustibles in an area with redundant trains of cables and equipment (cable spreading room) in a safety evaluation dated July 3, 1985.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.2.b, for lack of 20-foot separation without intervening combustibles in an area with redundant trains of cables and equipment (service water pump room) in a safety evaluation dated December 31, 1986.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.2.b, for lack of an automatic suppression system in an area with redundant trains of cables and equipment (residual heat removal pump zone) in a safety evaluation dated December 31, 1986.
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.2.b, for lack of an automatic suppression system in an area with redundant trains of cables and equipment (entire auxiliary building) in a safety evaluation dated December 31, 1986.
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NextEra PBNP                                    2.0 Overview of Existing Fire Protection Program
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.2.a, for lack of a 3-hour-rated barrier separating redundant trains of cables and equipment (entire auxiliary building) in a safety evaluation dated December 31, 1986.
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.3, for lack of an automatic fire suppression system in an area in which alternate shutdown is provided (CCW heat exchanger and boric acid tank room) in a safety evaluation dated May 23, 1988.
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.3, for lack of an automatic fire suppression system in an area in which alternate shutdown is provided (computer and instrument rack room) in a safety evaluation dated May 23, 1988.
   "   An exemption from 10 CFR 50 Appendix R, Section III.G.2.b, for lack of 20-foot separation without intervening combustibles in an area with redundant trains of cables and equipment (auxiliary feedwater pump room) in a safety evaluation dated July 18, 1995.
   "   An exemption from 10 CFR 50 Appendix R, Section Ill.J, for lack of 8-hour battery power supply for outdoor access and egress routes to buildings containing safe shutdown equipment in a safety evaluation dated May 7, 1998.
   "   An exemption from 10 CFR 50 Appendix R, Section IIl.G.l.a, for hot shutdown repair actions in a safety evaluation dated June 2, 2005.
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NextEra PBNP                                                           3.0 Transition Process 3.0    TRANSITION PROCESS 3.1    Background Section 4.0 of NEI 04-02 describes the process for transitioning from compliance with the current fire protection licensing basis to the new requirements of 10 CFR 50.48(c).
NEI 04-02 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 fire protection 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 a Safety Evaluation; 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 fire protection 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, NextEra has implemented the NFPA 805 Section 2.2 process by first determining the extent to which its current fire protection 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.
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NextEra PBNP                                                                                    3.0 Transition Process NextEra PBNP                                                                                    3.0 TransItion Process xMphO-hexihazardsOoanswysi N        pdAy     -611V I 5GOIn inwt8WVU EstetbiU*1    program NFPA805 Section 2 2(I)
Figure 3-1 NFPA 805 Process [NEI 04-02 Figure 3-1 based on Figure 2-2 of NFPA 805]2 3.3      NEI 04 NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a RI-PB fire protection program. NEI 04-02 was developed to provide guidance on the overall process 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.
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NextEra PBNP                                                                          3.0 Transition Process (programmatic, technical, and licensing) for transitioning from a traditional fire protection licensing basis to a new RI-PB method based upon NFPA 805, as shown in Figure 3-2.
Section 4.0 of NEI 04-02 describes the detailed process for assessing a fire protection program for compliance with NFPA 805, as shown in Figure 3-2.
Transition Report                                                 Transition Report Sect 4.1                                                           Sect 4.2 rA                                                        f r N                                          Use PB Approach if           Transition for NRC II     I                              Needed (Fire Modeling or        TrReport n ito Fire Risk Evaluations)          Sect 4.5 If needed Transition Verify / Establish Monitoring   . Report Program                   Sect. 4.6 Transition Confirm I Establish Adequate        TasReport Documentation I Quality and           Ret.
Sect. 4.7, Configuration Control Regulatory Submittal a            Transition Approval               . Report sect. 4.8, Figure 3-2 Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]
Page 10 Revision 00 Revision                                                                                              Page 10

NextEra PBNP                                                           3.0 Transition Process 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, NEI 04-02, and the requirements of NFPA 805. The NFPA 805 FAQ process was jointly developed by NEI and 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, 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 Safety Evaluations.
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, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this LAR.
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements 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 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 fire protection program changes that would be necessary for compliance with NFPA 805. NEI 04-02 Appendix B-1 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 PBNP Fire Protection Program to the requirements of NFPA 805 Chapter 3 was performed and documented in an engineering analysis entitled "NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review."
The engineering analysis used the guidance contained in NEI 04-02, Section 4.3.1 and Appendix B-1 (See Figure 4-1).
Each section and subsection of NFPA 805 Chapter 3 was reviewed against the current fire protection 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 Existing Engineering Equivalency Evaluations (EEEEs) -
For those sections/subsections determined to be equivalent to the NFPA 805 Chapter 3 requirements as documented by engineering analysis.
     " 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).
     " 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).
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 requirement of NFPA 805 Chapter 3.
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[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.
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NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements 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 the NEI 04-02 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 fire protection program at PBNP 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. Implementation items are identified for those sections and/or subsections determined to meet the specific requirements of NFPA 805 after the completion of a modification or other action, such as a procedure change or a work request. (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. NextEra requests that the NRC concur with their finding of prior approval for the following sections of NFPA 805 Chapter 3:
* 3.3.8 - Clarification of the approval that the location of the fuel oil storage tanks for the heating boiler is acceptable, as the APCSB 9-5.1 Appendix A SER did not identify the proper location of these tanks.
The discussion of the prior approval, including appropriate reference documents, is provided in Attachment T.
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:
* 3.2.3(1) - Approval is requested for the use of performance-based methods to establish the appropriate inspection, testing, and maintenance frequencies for required fire protection systems and features.
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NextEra PBNP                                          4.0 Compliance with NFPA 805 Requirements H   3.3.3 - Approval is requested for the interior finishes applied to walls, ceilings, and floors.
a 3.3.5.1 - Approval is requested for instances of unprotected wiring above suspended ceilings.
E 3.3.5.2 - Approval is requested for the use of electrical metallic tubing (EMT).
0 3.3.7.1 - Approval is requested for maintaining the existing separation distance between the exterior hydrogen storage system and the Turbine Building.
0 3.5.3 and 3.5.6 - Approval is requested for the electric motor-driven fire pump, which cannot hold stalled rotor current indefinitely and can be stopped automatically.
0 3.5.13 and 3.6.1 - Approval is requested for the use of containment hose reel station control valves that are not listed or approved for fire protection service due to the fact that the reels are fed by the service water system.
a 3.5.16 - Approval is requested for the temporary "off-normal" use of the fire protection water supply.
The specific deviation and a discussion of how the alternative satisfies 10 CFR 50.48(c)(2)(vii) requirements are provided in Attachment L. NextEra 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.
PBNP 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 of NFPA 805. These structures are listed in Attachment I and define the "power block" and "plant" for PBNP.
4.2     Nuclear Safety Performance Criteria The Nuclear Safety Performance Criteria are established in Section 1.5 of NFPA 805.
Chapter 4 of NFPA 805 provides the methodology to determine the fire protection systems and features required to achieve the performance criteria outlined in Section 1.5. Section 4.3.2 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis meets these criteria and for identifying any necessary fire protection program changes. NEI 04-02, Appendix B-2 provides guidance on documenting the transition of Nuclear Safety Capability Assessment Methodology and the Fire Area compliance strategies.
Page 15 Revision 00 Revision                                                                                Page 15

NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements 4.2.1 Nuclear Safety Capability Assessment Methodology The Nuclear Safety Capability Assessment (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 non-power operational (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 criteriain Chapter 1 (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 criteria given a fire in each fire area" The NSCA methodology review evaluated the NSCA methodology against the guidance provided in NEI 00-01, Revision 2 (ML091770265) Chapter 3, "Deterministic Methodology," as discussed in Appendix B-2 of NEI 04-02. 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 and one of the following alignment statements and its associated basis were assigned to each section:
o Aligns o Aligns with intent Revision 0                                                                             Page 16

NextEra PBNP                                            4.0 Compliance with NFPA 805 Requirements o  Not in Alignment o  Not in Alignment, but Prior NRC Approval o  Not in Alignment, but no adverse consequences
            " For those sections that do not align, an assessment was made to determine if the failure to maintain strict alignment with the guidance in NEI 00-01 could have adverse consequences. Since NEI 00-01 is a guidance document, portions of its text could be interpreted as 'good practice' or intended as an example of an efficient means of performing the analyses. If the section has no adverse consequences, these sections of NEI 00-01 can be dispositioned without further review.
The comparison of the PBNP NSCA methodology to NEI 00-01 Chapter 3 (NEI 04-02 Table B-2) was performed and documented in Report R1 918-0041-001, Nuclear Safety Performance Analysis Methodology Review.
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.
Step I Step 2 Stop 3 4
Istop Figure 4 Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039)
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements 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, 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 pressurized water reactor.For all 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 "...reasonableassurancethat a fire during any operationalmode and plant configurationwill 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 may not be 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 plant operating state for the event.
Results Demonstration of the Nuclear Safety Performance Criteria for safe and stable conditions was performed in two analyses:
     " At-Power analysis, Modes 1-3. This analysis is discussed in Section 4.2.4.
     " Non-Power analysis, which includes Mode 4 and below. This analysis is discussed in Section 4.3.
Background Discussion The Operating Modes for PBNP are defined in Table 1.1-1 of the Technical Specifications. The minimum mode required for safe and stable is hot standby (Mode 3). Although not required to achieve it, the plant should also be capable of maintaining safe and stable conditions while in hot shutdown (Mode 4). It is not necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R.
PBNP has design features and procedures to assure long-term decay heat removal indefinitely in sustained Mode 3 and Mode 4 conditions. Auxiliary Feedwater (AFW) is initially supplied from the Condensate Storage Tanks (CSTs), but has an essentially Revision 0                                                                           Page 18

NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements indefinite supply of cooling water from Lake Michigan via the Service Water System. A minimum number of service water pumps needed to provide AFW suction have been demonstrated to be operable for all fire scenarios.
PBNP has design features and procedures to assure Reactor Coolant System (RCS) inventory control and reactivity control in sustained Mode 3 or 4 conditions. The minimum refueling water storage tank (RWST) inventory required by Technical Specifications (TS) is capable of providing injection of borated water well in excess of 72 hours considering the make-up needs for a maximum postulated RCP seal leakage plus the maximum TS allowable leakage from the RCS. Consideration of the worst-case spurious operation of equipment that can divert some of the RWST inventory still allows injection of borated water for at least 45 hours. This should provide sufficient time to provide for make-up inventory to the RWST from onsite or offsite sources.
PBNP has design features and procedures to maintain RCS pressure control without use of pressurizer heaters (i.e., charging to maintain pressurizer level and/or establish water-solid conditions) in sustained Mode 3 or 4 conditions. The operators are instructed to secure the reactor coolant pumps to help prevent excess depressurization that can result in a loss of subcooling margin. They are also instructed to use the charging pumps to help maintain subcooling margin, including allowing the pressurizers to go solid. The use of pressurizer heaters is therefore not required.
The plant design and operating procedures will maintain a safe and stable condition such that sufficient time is available for Technical Support Center (TSC) personnel and additional resources to muster and assess the extent of fire damage, and design &
implement actions and/or repairs required to transition to and establish long term cooling.
Methods to Maintain "Safe and Stable" and Extend Hot Standby Conditions The following describes methods to maintain the "Safe and Stable" condition and related support actions:
: 1. PBNP has design features and procedures to ensure that an adequate source of inventory is provided for decay heat removal in sustained Mode 3 (Hot Standby) conditions. If the CST inventory is depleted the AFW pump(s) suction will automatically transfer to the Service Water supply. Transfer can be automatic or manual from the Main Control Room.
: 2. RCS Pressure control is maintained by a combination of charging pump operation, Pressurizer PORVs or Reactor Pressure Vessel Head Vent valves, and steam generator ADVs.
: 3. Core decay heat in Mode 3 (Hot Standby) is rejected to the secondary plant through one or more of the Steam Generators, and then to atmosphere through the ADVs.
: 4. The PBNP reactor core design ensures that Keff is maintained <0.99 while the plant is in sustained Mode 3 (Hot Standby). Gravity insertion of the control rods into the reactor core will ensure reactivity control is achieved for Mode 3 (Hot Revision 0                                                                            Page 19

NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements Standby) for the first 24 hours. Subsequently, maintaining Keff <0.99 for "Safe and Stable" conditions will require boration of the RCS as described in FSAR Chapter 3.2 (Reactor Design).
: 5. Inventory makeup to the RCS may be required to account for expected RCS leakage and minimal RCS shrinkage as well as RCP seal injection. PBNP has design features and procedures to ensure that an adequate source of borated inventory (RWST) is provided for RCS inventory control in sustained Mode 3 (Hot Standby) utilizing the CVCS system and the Reactor Pressure Vessel Head Vent valves. In addition, the station has determined that Westinghouse SHIELDTM low-leakage RCP seals will be installed to reduce or eliminate RCP seal leakage in event of loss of seal cooling (See Table S-2).
: 6. Instrument Air supports selected safety-related equipment required to achieve a safe and stable condition. Critical loads (Pressurizer PORVs, AFW AOVs) will be provided with accumulators sized for 24 hours of expected usage (See Table S-2).
: 7. Fuel for the EDGs is provided by a combination of Fuel Oil (FO) Day Tanks and FO Storage Tanks. Sufficient fuel is normally maintained between the two (2) FO Storage Tanks to allow one diesel to operate continuously at the required load for 7 days. At the minimum required level, which is 11,000 gallons in each EDG FO Storage Tank, one tank could provide enough fuel for an EDG to operate for over 48 hours (FSAR Section 8.8). The maximum load demand is calculated based on the fuel consumption by one EDG for operation at continuous rating for 7 days. This onsite fuel oil capacity is sufficient to operate the EDGs for longer than the time to replenish the onsite supply from outside sources.
Assessment of Risk The fire brigade will respond to fire events within the Protected Area boundary in accordance with the guidance of NP 1.9.14, "Fire Protection Organization." In the event of an Alert declaration or higher the On-Shift Emergency Response Organization (ERO) will be supplemented by the On-Site ERO within 60 minutes. The On-Site ERO will assist the Control Room personnel with implementation of the longer term actions necessary to maintain the fuel in a "Safe and Stable" configuration. Following stabilization at Hot Standby, assessment and repair activities would commence to restore plant equipment needed to support RCS cool down in a safe and controlled manner. ERO resources will be available to assist the MCR in fire damage assessment and restoration of multiple success paths.
The ERO provides sufficient resources for assessment of fire damage and completion of repairs to equipment necessary to maintain hot standby for an extended period, transition to cold shutdown, or return to power operations as dictated by the plant fire event.
For the most limiting fire scenarios, it is anticipated that the end state of the cool down would be an RCS temperature of approximately 350 F with a long term strategy for reactivity, decay heat removal, and inventory control. Long term subcooled natural Revision 0                                                                              Page 20

NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements circulation decay heat removal is provided by supplying service water to the Steam Generators and steaming to atmosphere. The extended coping period at these conditions is based on the significant volume of water available for decay heat removal and reduced need for primary make up to match the RCS system losses.
Based on the initial achievement of safe and stable conditions in conjunction with the availability of procedural actions, repair of equipment, and initial coping period, recovery of NSCA equipment that may be required beyond 24 hours has been qualitatively evaluated and determined to have no significant measurable contribution to risk based on the following factors:
    " The actions required to maintain "Safe and Stable" conditions are limited.
    " Procedures are in place for the "Safe and Stable" actions identified above.
    " The staff will be trained in the use of the post-fire operating and long-term restoration procedures.
    " The lengthy coping period provides reasonable assurance that adequate time is provided for the ERO to be available to augment the minimum plant staffing to support the longer term "Safe and Stable" actions.
Conclusion The initial coping time is sufficient to allow the ERO to activate. Limited actions are required and procedures are in place for those actions to maintain extended hot standby conditions. The ERO provides adequate capability to extend initial Hot Standby conditions, to transition to cold shutdown, or return to power operations as dictated by the plant fire event. The approach described above has demonstrated the capability to achieve and maintain the reactor fuel in a "Safe and Stable" condition for an indefinite period following a fire.
4.2.1.3     Establishing Recovery Actions Overview of Process NEI 04-02 and RG 1.205 suggest that a licensee submit a summary of its approach for addressing the transition of operator manual actions (OMAs) as recovery actions in the LAR (Regulatory Position 2.21 and NEI-04-02, Section 4.6). As a minimum, NEI 04-02 suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensee's methodology.
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 (MLl 10070485) 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.
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NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements
    "   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).
    " 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 Results The review results are documented in the following documents:
    " P2091-2910-01, Point Beach Post-Fire Human Reliability Analysis (HRA)
Notebook
    " Fire Risk Evaluations
    " R2168-1012-01, Manual Actions Feasibility Report
    " R2167-1012-02, Recovery Actions Transition Report 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 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 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 PBNP is summarized below.
As part of the NFPA 805 transition project, a review and evaluation of PBNP susceptibility to fire-induced MSOs was performed. The process was conducted in accordance with NEI 04-02 and RG 1.205, as supplemented by FAQ 07-0038 Revision 3 (MLl 10140242). The PWR Generic MSO list dated 3/5/2008 was utilized for the Expert Panel review. A delta review was performed in June 2010 using the PWR Generic MSO dated May 2009 to evaluate any changes that occurred since the Expert Panel was concluded.
The approach outlined in Figure 4-3 (based on Figure 4-8 from FAQ 07-0038) is one acceptable method to address fire-induced MSOs. This method used insights from the Fire PRA 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, Rev. 2 Section F.4.1).
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NextEra PBNP                                                            4.0 Compliance with NFPA 805 Requirements
    "   Updating the Fire PRA model and existing post-fire 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).
Identify Potential MSOs of Concern
* SSA Step 1
* Generic List of MSOs 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 ComolanceNo Step 4                                                         Pursue other resolution options Compliant with NFPA 805?
I~YesI Step 5                      Document Results Figure 4 Multiple Spurious Operations - Transition Resolution Process (Based on FAQ 07-0038)
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements 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 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 reviewed using the methodology contained in NEI 04-02. The methodology for performing the EEEE review includes the following determinations:
    " The EEEE is not based solely on quantitative risk evaluations,
    " The EEEE is an appropriate use of an engineering equivalency evaluation,
    " 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, Regulatory Position 2.3.2 and NEI 04-02, as clarified by FAQ 07-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs that demonstrate that a fire protection 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 R2014-004-002, Engineering Evaluation Review.
In accordance with the guidance provided in RG 1.205, Regulatory Position 2.3.2, NEI 04-02, as clarified by FAQ 07-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs used to demonstrate compliance with Chapters 3 and 4 of NFPA 805 are referenced in the Attachments A and C as appropriate.
None of the transitioning EEEEs require NRC approval.
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NextEra PB3NP                                     4.0 Compliance with NFPA 805 Requirements 4.2.3 Licensing Action Transition Overview of Evaluation Process The existing licensing actions (exemptions / deviations / safety evaluations) review was performed in accordance with NEI 04-02. 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, Report R2014-004-003.
There are no licensing actions that will be transitioned into the NFPA 805 fire protection program as previously approved (NFPA 805 Section 2.2.7).
The following licensing actions are no longer necessary and will not be transitioned into the NFPA 805 fire protection program:
    " Appendix R Exemption for the lack of a fixed suppression system in fire zone 326, Control Room. (NRC SER dated April 28, 1983) (Attachment K, Item 1)
This exemption is no longer required for transition since the Control Room is transitioning with NFPA 805 Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation. Lack of a fixed fire suppression system is addressed through Fire Risk Evaluations.
    " Appendix R Exemption for the lack of 20-foot separation and full coverage automatic suppression in fire zone 156, Unit 1 Motor Control Center Room. (NRC SER dated July 3, 1985) (Attachment K, Item 2)
This exemption is no longer required for transition since the fire area is transitioning with NFPA 805 Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation. Separation and lack of full area automatic suppression are addressed through Fire Risk Evaluations.
    " Appendix R Exemption for the lack of 20-foot separation and full coverage automatic suppression in fire zone 142, Component Cooling Water Pump Room.
(NRC SER dated July 3, 1985) (Attachment K, Item 3)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. Separation and lack of full area automatic suppression are addressed through Fire Risk Evaluations.
    " Appendix R Exemption for the lack of 20-foot separation and automatic suppression in fire zone 166, Unit 2 Motor Control Center Room. (NRC SER dated July 3, 1985) (Attachment K, Item 4)
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NextEra PB3NP                                     4.0 Compliance with NFPA 805 Requirements This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. Separation and lack of full area automatic suppression are addressed through Fire Risk Evaluations.
Appendix R Exemption for the lack of a fixed suppression system in fire zone 187, Containment Spray Additive Tank and Monitor Area. (NRC SER dated July 3, 1985) (Attachment K, Item 5)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. The lack of a fixed fire suppression system is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of 20-foot separation and automatic suppression in fire zone 151, Safety Injection and Containment Spray Pump Room. (NRC SER dated July 3,1985) (Attachment K, Item 6)
This exemption is no longer required for transition because an automatic sprinkler system has been provided for complete area coverage and the area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. Separation is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of 20-foot separation without intervening combustibles in fire zones 304N and 304S, Auxiliary Feedwater Pump Room.
(NRC SER dated July 3, 1985) (Attachment K, Item 7)
This exemption is no longer required for transition because the room now consists of two analysis areas separated by a 3-hour gypsum wall. Therefore, the exemption granted against the requirements of IIl.G.2.b for intervening combustibles within 20-ft separation is no longer required.
   " Appendix R Exemption for the lack of 20-foot separation without intervening combustibles in fire zone 318, Cable Spreading Room. (NRC SER dated July 3, 1985) (Attachment K, Item 8)
This exemption is no longer required for transition because modifications have been performed which are acceptable in the compliance strategy for NFPA 805 Section 4.2.4.2 Performance-Based Approach - Fire Risk Evaluation.
   " Appendix R Exemption for the lack of 20-foot separation without intervening combustibles in fire zone 552, Service Water Pump Room. (NRC SER dated December 31, 1986) (Attachment K, Item 9)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. Separation is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of an automatic suppression system in fire zone 104, Residual Heat Removal Pump Room. (NRC SER dated December 31, 1986) (Attachment K, Item 10)
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NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. The lack of automatic suppression is addressed through Fire Risk Evaluations.
Appendix R Exemption for the lack of an automatic suppression system in the Auxiliary Building. (NRC SER dated December 31, 1986) (Attachment K, Item 11)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. The lack of automatic suppression is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of a three (3) hour fire barrier in fire zone 238, Auxiliary Building central area 46' elevation. (NRC SER dated December 31, 1986) (Attachment K, Item 12)
This exemption is no longer required for transition because the Auxiliary Building now consists of multiple fire areas. Therefore, the exemption granted against the requirements of III.G.2, for separation within a fire area, is no longer required.
   " Appendix R Exemption for the lack of a fixed suppression system in fire zone 237, CCW Heat Exchanger and BAT Room. (NRC SER dated May 23, 1988)
(Attachment K, Item 13)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. The lack of fixed fire suppression is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of fixed suppression in fire zone 336, Computer and Instrument Rack Room. (NRC SER dated May 23, 1988)
(Attachment K, Item 14)
This exemption is no longer required for transition since the fire area is transitioning under NFPA 805 Section 4.2.4.2 Performance-Based Approach -
Fire Risk Evaluation. The lack of fixed suppression is addressed through Fire Risk Evaluations.
   " Appendix R Exemption for the lack of 20-foot separation without intervening combustibles in fire zones 304N and 304S, Auxiliary Feedwater Pump Room.
(NRC SER dated July 18, 1995) (Attachment K, Item 15)
This exemption is no longer required for transition because the room now consists of two analysis areas separated by a 3-hour gypsum wall. Therefore, the exemption granted against the requirements of IIl.G.2.b for intervening combustibles within 20-ft separation is no longer required.
   " Appendix R Exemption from the requirements of Section Ill.J, Emergency Lighting. (NRC SER dated May 7,1998) (Attachment K, Item 16)
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NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements This exemption is no longer required since there is no 8-hour emergency lighting requirement per NFPA 805.
* Appendix R Exemption from the hot shutdown requirements of Appendix R Section III.G.1. (NRC SER dated June 2, 2005) (Attachment K, Item 17)
This exemption is no longer required since instrument air support is no longer utilized for the charging pumps.
Since the exemptions are either compliant with 10 CFR 50.48(c) or no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), NextEra requests that the exemptions listed in Attachment K be rescinded as part of the LAR process. It is NextEra's understanding that implicit in the superseding of the current license condition, all prior fire protection program Safety Evaluation Reports (SER)s and commitments will be superseded in their entirety. See Attachment 0, Orders and Exemptions.
4.2.4 Fire Area Transition Overview of Evaluation Process The Fire Area Transition (NEI 04-02 Table B-3) was performed using the methodology contained in NEI 04-02 and FAQ 07-0054. 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 fire protection system or feature. Developed VFDR problem statements to support resolution.
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NextEra PB3NP                                     4.0 Compliance with NFPA 805 Requirements 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 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, then alternate means of compliance was considered.
    " Document the post transition NFPA 805 Chapter 4 compliance basis.
Step 6 - Documented required fire protection 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 fire protection systems and features 'required' by NFPA 805 Chapter 4. The 'required' fire protection systems and features are subject to the applicable requirements of NFPA 805 Chapter 3.
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NextEra PBNP                         4.0 Compliance with NFPA 805 Requirements NextEra PBNP                         4.0 Compliance with NFPA 805 Requirements Figure 4 Summary of Fire Area Review
[Based on FAQ 07-0054 Revision 1]
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements Results of the Evaluation Process Attachment C contains the results of the Fire Area Transition review (NEI 04-02 Table B-3). On a fire area basis, Attachment C summarizes compliance with Chapter 4 of NFPA 805.
NEI 04-02 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 Nuclear Safety Capability Assessment Documents are provided.
     " Fire Suppression Activities Effect on Nuclear Safety Performance Criteria - A summary of the method of accomplishment is provided.
     " Licensing Actions - Specific references to exemption requests / deviations I safety evaluations 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 should be provided. Attachment T contains items for which PBNP is requesting concurrence of prior approval.
     " 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 should be 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.
4.3     Non-Power Operational Modes 4.3.1 Overview of Evaluation Process PBNP implemented the process outlined in NEI 04-02 and FAQ 07-0040, Clarification on Non-Power Operations. The goal (as depicted in Figure 4-5) is to ensure that contingency plans are established when the plant is in a 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:
     " Review the existing Outage Management Processes
     " Identify Equipment/Cables:
o   Review plant systems to determine success paths that support each of the defense-in-depth Key Safety Functions (KSFs), and Page 31 Revision 00                                                                             Page 31

NextEra PBNP                                        4.0 Compliance with NFPA 805 Requirements o    Identify cables required for the selected components and determine their routing.
    " Perform Fire Area Assessments (identify pinch-points - plant locations where a single fire may damage all success paths of a KSF).
    " Manage 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.
Figure 4-5 Review POSs, KSFs, Equipment, and Cables, and Identify Pinch Points Revision 0                                                                              Page 32

NextEra P13NP                                                 4.0 Compliance with NFPA 805 Requirements NextEra PBNP                                                  4.0 Compliance with NFPA 805 Requirements Higher Risk Evolution as Defined by Plant Specific Outage Risk Criteria for example
: 1) Time to Boil
: 2) Reactor Coolant System and Fuel Pool Inventory
: 3) Decay Heat Removal Figure 4-6 Manage Pinch Points Page 33 Revision 0 0                                                                                    Page 33

NextEra PB3NP                                      4.0 Compliance with NFPA 805 Requirements 4.3.2 Results of the Evaluation Process Based on FAQ 07-0040, the following Plant Operating States (POS) considered for equipment and cable selection are defined in report R2092-1500-001, Non-Power Operation Modes Transition Review.
PBNP procedure NP 10.3.6, "Shutdown Safety Review and Safety Assessment" implements the PBNP philosophy for risk assessment and risk management of outages.
In addition to providing guidance on shutdown risk principles, and performance of risk assessments, this procedure identifies the KSFs that need to be maintained as well as providing guidelines for maintaining them.
PBNP Form PBF-1 562 "PBNP Shutdown Safety Assessment and Fire Condition Checklist" provides the checklist for determining system availability for Modes 4 through
: 6. These checklists are used to determine the equipment requirements for each of the associated modes and serve as the starting point for identifying those systems needing to be addressed in the NFPA 805 NPO review. The explanations of the KSFs provided in NP 10.3.6 combined with the system/ train/ equipment identified on the checklists, the inventory and reactivity flow path diagrams, and the power supply load lists are utilized in developing a NPO component list.
A fire separation analysis (pinch point analysis) was performed as documented in Report R2092-1500-001. Equipment and cable failures were evaluated for the impact to KSF success paths. "Pinch points" were conservatively assigned in areas where recovery action(s) or main control room action was required to establish a success path for any KSFs.
Per NP 10.3.6 safety reviews include assessment of the vulnerabilities and areas of concern for KSFs based on fire protection features. During periods of elevated risk, safety reviews will focus on identifying methods to maintain defense in depth in the KSF either by revising the planned sequence of outage activities or through the use of appropriate contingency plans. At all times fire risk will be minimized through the control of ignition sources, control of combustibles, compensatory actions for fire protection system impairments and housekeeping. During periods of risk such as orange and red conditions, High Risk Evolutions (HREs), or when directed by plant management, the following additional controls will be considered:
    " 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 lineup modifications (e.g., removing power from equipment once it is placed in its desired position)
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    "   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 defense-in-depth (DID).
    " Other PBNP specific fire prevention or mitigation strategies proposed in R2092-1500-001.
For fire areas containing pinch points, safety reviews should consider any equipment which may be out of service and develop appropriate mitigation strategies. See Attachment D for more complete details. Based on incorporation of the recommendations from the pinch point evaluations into appropriate plant procedures, prior to implementation of NFPA 805, the performance goals for NPOs are fulfilled and the requirements of NFPA 805 are met.
4.4     Radioactive Release Performance Criteria 4.4.1 Overview of Evaluation Process The review of the fire protection program against NFPA 805 requirements for fire suppression related radioactive release was performed using the methodology contained in NEI 04-02 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 PBNP pre-fire plans. The evaluation focused on radioactive release to any unrestricted area due to fire fighting activities only; radioactive release due to potential fuel cladding damage is 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 fire protection 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 that demonstrates that the limitations for instantaneous release of radioactive effluents specified in NFPA 805, Section 1.5.2 or PBNP's Technical Specifications are met, was provided.
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NextEra PB3NP                                       4.0 Compliance with NFPA 805 Requirements 4.4.2 Results of the Evaluation Process The radioactive release review determined the fire protection program will be compliant with the requirements of NFPA 805 and the guidance in NEI 04-02 and RG 1.205 upon completion of the implementation items identified in Attachment E.
The site specific review of the direct effects of fire suppression activities on radioactive release is summarized in Attachment E.
PBNP Report Number R2014-003-001, "Radioactive Release Review," details the results of the screening process and review of pre-fire plans, fire brigade training materials, and engineering controls.
4.5     Fire PRA and Performance-Based Approaches RI-PB evaluations are an integral element of an NFPA 805 fire protection 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 Approaches (discussed in Section 4.5.2).
4.5.1   Fire PRA Development and Assessment In accordance with the guidance in RG 1.205, a Fire PRA (FPRA) model was developed for PBNP 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," (hereafter referred to as Fire PRA Standard). NextEra conducted a peer review by independent industry analysts in accordance with RG 1.200 prior to a risk-informed submittal. The resulting fire risk assessment model is used as the analytical tool to perform Fire Risk Evaluations during the transition process.
Section 4.5.1.1 describes the Internal Events PRA model. Section 4.5.1.2 describes the Fire PRA model. Section 4.5.1.3 describes the results and resolution of the peer review of the Fire PRA, and Section 4.5.1.4 describes insights gained from the Fire PRA.
4.5.1.1     Internal Events PRA The PBNP base internal events PRA (Point Beach Model 5.01) was the starting point for the Fire PRA. Attachment U provides a discussion of the Internal Events PRA and the results and disposition of the most recent peer review. No changes have been made to the Internal Events PRA model since completion of the peer review in October 2011 that would constitute an upgrade. Thus, no additional focused scope peer review is required to support this LAR.
4.5.1.2     Fire PRA A Fire PRA model was developed for PBNP using the guidance provided in NUREG/CR-6850/EPRI TR-1011989 (including supplement 1), EPRI TR-1016735, and Revision 0                                                                             Page 36

NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements NUREG-1921. Attachment H provides a listing of the approved FAQs that affect the overall license transition process for PBNP. The resulting fire risk assessment model is used to support Fire Risk Evaluations during the transition process and to develop estimates of the potential change in fire related risk.
The Fire PRA was developed using the Internal Events PRA as a starting point. The Internal Events PRA was modified to model the effects of fire, both as an initiator and the subsequent potential failure modes for affected circuits or targets. The Fire PRA has been quantified using the CAFTA PRA software. The PBNP Fire PRA is documented in a series of reports and calculations associated with each NUREG/CR-6850 Fire PRA task.
An independent peer review was conducted in June 2011 that included a review of the PRA model, data, and documentation in accordance with ASME Standard ASME/ANS RA-Sa-2009, Capability Category II requirements, as well as RG 1.200, Revision 2.
Focused-scope peer reviews were conducted in May 2013 and June 2013 to specifically address Fire Scenario Selection and Analysis (FSS) and Fire Risk Quantification (FQ).
The FSS F&Os from the 2011 full peer review were reviewed during the focused-scope peer review and the peer review determined that they could be closed. The few items that were not completely addressed from the 2011 full peer review were captured under new findings.
No changes have been made to the Fire PRA model since completion of the May and June 2013 focused-scope peer reviews that would constitute an upgrade (based on the definition provided in ASME/ANS RA-Sa-2009). Thus, no additional focused scope peer review is required to support this LAR.
Fire PRA quality and insights are discussed in subsequent sections and in Attachments V and W, respectively.
Fire Model Utilization in the Application Fire modeling was performed as part of the Fire PRA development (NFPA 805 Section 4.2.4.2). RG 1.205, Regulatory Position 4.2 and Section 5.1.2 of NEI 04-02, provide guidance to identify fire models that are acceptable to the NRC for plants implementing a risk-informed, performance-based licensing basis.
The following fire models were used:
    " Flame Height (Method of Heskestad)
    " Plume Centerline Temperature (Method of Heskestad)
    " Radiant Heat Flux (Point Source Method)
    " Plume Radius (Method of Heskestad)
    " Hot Gas Layer (Method of McCaffrey, Quintiere, and Harkleroad)
    " Hot Gas Layer (Method of Beyler)
    " Hot Gas Layer (Method of Foote, Pagni, and Alvares)
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    "   Ceiling Jet Temperature (Method of Alpert)
    " Hot Gas Layer Calculations using Fire Dynamics Simulator (FDS)
    " Plume Temperature Calculations using Fire Dynamics Simulator (FDS)
    " Smoke Concentrations Calculation using Fire Dynamics Simulator (FDS) for Main Control Room Abandonment
    " Hot Gas Layer Calculations using Consolidated Model of Fire Growth and Smoke Transport (CFAST)
    " Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios)
    " Sprinkler Activation Correlation
    " Control Room Abandonment using Fire Dynamics Simulator (FDS)
    " Temperature Sensitive Equipment Hot Gas Layer Study using CFAST
    " Temperature Sensitive Equipment Zone of Influence Study using FDS
    " Plume/Hot Gas Layer Interaction Study using FDS
    " Correlation for Heat Release Rates of Cables (Method of Lee)
    " Corner and Wall Heat Release Rate (HRR)
    " Correlation for Flame Spread over Horizontal Cable Trays (FLASH-CAT)
    " Pyrosim used to create FDS input files
    " Fire Modeling Workbook (FMWB) used to calculate zones of influence The acceptability of the use of these fire models is included in Attachment J. Many of these correlations have been built into a Fire Modeling Workbook (FMWB) utilized for the Fire PRA fire modeling. The Fire Modeling Workbook was verified, by "black box" testing, to ensure that the results were identical to the verified and validated models.
"Black box" testing (also called functional testing) is testing that ignores the internal mechanism of a system or component and focuses solely on the outputs generated in response to selected inputs and execution conditions.
The process compared results from the Fire Modeling Workbook to those produced by the NUREG-1805 Fire Dynamic Tools and Fire-Induced Vulnerability Evaluation when identical inputs were entered into both. Since the correlations from NUREG-1805 Fire Dynamic Tools and Fire-Induced Vulnerability Evaluation, Revision 1, were verified and validated in NUREG-1824, and the results match the results produced by the Fire Modeling Workbook, by the transitive property, the Fire Modeling Workbook is verified and validated with respect to NUREG-1824.
The results of this verification are documented in R2168-1003B-0001, "Verification and Validation of Fire Modeling Tools and Approaches for Use in NFPA 805 and Fire PRA Applications."
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements 4.5.1.3     Results of Fire PRA Peer Review The PBNP Fire PRA (Point Beach Fire PRA 2011) was peer reviewed against the requirements of ASME/ANS RA-Sa-2009, Part 4.
The results (i.e., Supporting Requirement capability assessments and Facts &
Observations (F&Os)) documented in the June 2011 Fire PRA peer review reports were used to support the Fire PRA for the NFPA 805 application.
The Fire PRA update included an upgrade requiring subsequent focused-scope peer reviews on Fire Scenario Selection and Analysis (FSS) and Fire Risk Quantification (FQ). These focused peer reviews were performed in May and June of 2013. The Fire PRA has been updated to address the Supporting Requirement assessed deficiencies (i.e., Not Met or Capability Category I (CC I)). Some items are not completed at this time and are deferred. These items have been dispositioned for the potential impact on the Fire PRA and the application. All F&Os that were defined as suggestions have been dispositioned but not included in Table V-I, however, they will be available for NRC review. The results of these peer review reports are summarized in Attachment V.
4.5.1.4     Risk Insights Risk insights were documented as part of the development of the Fire PRA. The total plant fire CDF/LERF was derived using the NUREG/CR-6850 methodology for fire PRA development and is useful in identifying the areas of the plant where fire risk is greatest.
A review of the dominant fire initiating events is included in 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 Fire Risk Evaluations were completed as part of the PBNP NFPA 805 transition.
These Fire Risk Evaluations were developed using the process described below. This methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, and RG 1.205. These requirements are summarized in Table 4-1.
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NextEra PBNP                                                  4.0 Compliance with NFPA 805 Requirements Table 4-1 Fire Risk Evaluation Guidance Summary Table Document                          Section(s)                                     Topic NFPA 805                 2.2(h), 4.2.4, A.2.2(h), A.2.4.4, D.5      Change Evaluation (2.2(h), 2.2.9, 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 2     4.4, 5.3, Appendix B, Appendix I,          Change Evaluation, Change Evaluation Appendix J                                 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 a Fire Risk Evaluation per Section 4.2.4.2 of NFPA 805. A Fire Risk Evaluation was performed for each fire area containing variances from the deterministic requirements of Section 4.2.3 of NFPA 805 (VFDRs).
If the Fire Risk Evaluation 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 Fire Risk Evaluation process consists of the following steps (Figure 4-7 depicts the Fire Risk Evaluation process used during transition). This is generally based on FAQ 07-0054 Revision 1:
Step 1 - Preparation for the Fire Risk Evaluation
     " 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 fire protection 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 B-3 Table and the Fire PRA, a team review of the VFDR was performed. Depending on the scope and complexity of the VFDR, the team included the Safe Shutdown/NSCA Engineer, the Fire Protection Engineer, and the Fire PRA Engineer. The purpose and objective of this team review was to address the following:
o   Review Fire PRA modeling treatment of VFDR, and o   Ensure discrepancies were captured and resolved Step 2 - Performed the Fire Risk Evaluation
* The Evaluator coordinated as necessary with the Safe Shutdown/NSCA Engineer, Fire Protection Engineer and Fire PRA Engineer to assess the VFDR using the Fire Risk Evaluation process to perform the following:
o   Change in Risk Calculation with consideration for additional risk of recovery actions and required fire protection systems and features due to fire risk, and Revision 0                                                                                                Page 40

NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements o    Fire area change in risk summary Step 3 - Reviewed the Acceptance Criteria The acceptance criteria for the Fire Risk Evaluation 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 defense-in-depth 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, as clarified in RG 1.205 Regulatory Position 2.2.4. In some cases epsilon (E)is used to represent a negligible nonzero number.
o    Defense-in-Depth. A review of the impact of the change on defense-in-depth was performed, using the guidance NEI 04-02. 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, and
            - Providing adequate level of fire protection for structures, systems and components 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 defense-in-depth 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 defense-in-depth was qualitative and addressed each of the elements with respect to the proposed change. Defense-in-depth reviews were performed on a fire area basis.
Fire protection features and systems relied upon to ensure defense-in-depth were identified as a result of the assessment of defense-in-depth.
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
            - Safety analysis acceptance criteria in the licensing basis 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.
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NextEra PBNP                                            4.0 Compliance with NFPA 805 Requirements Prepare for Fire Risk Evaluation Determine How to Model              Discuss and Document in the VFDR in the Fire PRA              EvFire PRA and Fire Risk Evaluation Documentation Perform Fire Risk Evaluation Review of Acceptance Criteria Figure 4 Fire Risk Evaluation Process (NFPA 805 Transition)
[Based on FAQ 07-0054 Revision 1]
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements Results of Evaluation Process Disposition of VFDRs The PBNP 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 a Fire Risk Evaluation was assessed against the Fire Risk Evaluation acceptance criteria of ACDF and ALERF; and maintenance of defense-in-depth and safety margin criteria from Section 5.3.5 of NEI 04-02 and RG 1.205. 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, Section C.2.2.4, Risk Evaluations, risk increases or decreases for each fire area using Fire Risk Evaluations 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 Section C.2.2.4.2 states in part "The total increase or decreasein risk associatedwith the implementation of NFPA 805 for the overall plant should be calculatedby summing the risk increasesand decreases for each fire area (includingany risk increasesresulting from previously approved recovery actions). The total risk increase should be consistent with the acceptance guidelines in Regulatory Guide 1.174. Note that the acceptance guidelines 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 additional risk 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 proposed alternativesto the deterministic criteriain NFPA 805, Chapter4 (other than the previously approved recovery actions), should be risk neutral or representa 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.
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NextEra PBNP                                          4.0 Compliance with NFPA 805 Requirements 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 fire protection 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 risk-informed, performance-based licensing basis.
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 safety evaluation issuance as part of the fire protection program transition to NFPA 805.
See Implementation item IMP-139 in Attachment S. The monitoring process is comprised of four phases.
    " Phase 1 - Scoping,
    " Phase 2 - Screening Using Risk Criteria,
    " Phase 3 - Risk Target Value Determination, and
    " Phase 4 - Monitoring Implementation.
Figure 4-8 provides detail on the Phase 1 and 2 processes.
The results of these phases will be documented in the PBNP NFPA 805 Monitoring Program Engineering Evaluation 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:
* Structures, Systems, and Components required to comply with NFPA 805, specifically:
o   Fire protection systems and features
             -   Required by the Nuclear Safety Capability Assessment,
             -   Modeled in the Fire PRA, and
             -   Required by Chapter 3 of NFPA 805.
o Nuclear Safety Capability Assessment equipment4
             -   Nuclear safety equipment,
             -   Fire PRA equipment, and 4 For the purposes of the NFPA 805 Monitoring, "NSCA equipment" is intended to include Nuclear Safety Equipment, Fire PRA equipment, and NPO equipment.
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             -    NPO equipment.
o Structures, systems and components 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/or 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/or system/program health program activities and will be documented in the PBNP NFPA 805 Monitoring Program Engineering Evaluation.
: 1. Fire Protection Systems and Features Those fire protection 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 fire protection SSCs). If compartments smaller than fire areas are used, the basis will be documented in the NFPA 805 Monitoring Program Engineering Evaluation.
The Fire PRA 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) >: 1.0E-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 the monitoring program contained in the site Maintenance Rule Program described in AM 3-4 Implementation of the Maintenance Rule at PBNP. The remaining required fire Revision 0                                                                                 Page 45

NextEra PBNP                                     4.0 Compliance with NFPA 805 Requirements protection systems and features will be monitored via the existing inspection and test program and/or in the existing system / program health program as described in DG-F01, Fire Protection Conformance Guidance, ER-AA-201-2001 System and Program Health Reporting, and ER-AA-201-2002 System Performance Monitoring.
: 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 Fire PRA 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 NPO 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/or 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 amenable to quantitative risk measurement. Additionally, since 10 CFR Part 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 fire protection 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, and
    " 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.
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NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements Therefore, monitoring is conducted using the existing system and program health programs. Fire protection health reports, self-assessments, and regulator and insurance company reports provide inputs to the monitoring program.
Phase 3 - Risk Target Value Determination Phase 3 establishes the target values for reliability and availability for the fire protection 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 fire protection 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 (-2-3 operating cycles). In addition, the EPRI Technical Report (TR) 1006756, "Fire Protection Equipment Surveillance Optimization and Maintenance Guide," will be used as input for establishing reliability targets, action levels, and monitoring frequency. See Implementation Item IMP-122 in Table S-3 of Attachment S.
Since the HSS NSCA equipment have 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 Fire PRA assumptions.
When establishing the action level threshold for reliability and availability, the action level will be no lower than the fire PRA 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 PBNP NFPA 805 Monitoring Program Engineering Evaluation.
Note that fire protection systems and features, NSCA equipment, SSCs required to meet the radioactive release criteria, and fire protection 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 a timely manner to assure that appropriate action is taken. The corrective action process will be used to address performance of fire protection and nuclear safety SSCs that do not meet performance criteria.
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NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements For fire protection 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 PI-AA-205, Condition Evaluation and Corrective Action, 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 fire PRA results to help prioritize corrective actions, if the 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 fire protection and NSCA systems?
    " Have the supporting analyses been revised such that the performance criteria are no longer applicable or new fire protection 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?
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NextEra PBNP                                         4.0 Compliance with NFPA 805 Requirements Figure 4 NFPA 805 Monitoring - Scoping and Screening Since the HSS SSCs have been identified using the Maintenance Rule guidelines, the associated SSC specific performance criteria will be established as in the Maintenance Rule, provided the criteria are consistent with Fire PRA assumptions. The actual action level is determined based on the number of component, program or functional failures within a sufficiently bounding time period (-2-3 operating cycles). 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.
Page 49 Revision 00                                                                             Page 49

NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements 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, PBNP has documented analyses to support compliance with 10 CFR 50.48(c). The analyses are being performed in accordance with NextEra's processes for ensuring assumptions are clearly defined, that results are easily understood, that results are clearly and consistently described, and that sufficient detail are 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 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 safety evaluation. Appropriate cross references will be established to supporting documents as required by NextEra processes. See IMP-135 in Attachment S.
Page 50 Revision 00                                                                          Page 50

NextEra PBNP                                                     4.0 Compliance with NFPA 805 Requirements WPA ISN DOCUMENTS NCa t      beles i---
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COM* &Cable         FA Asesan NSCA SUPPORTING INFO Revised UFSAR T-H CaIculmIons                  ActoFnlil FIRE SAFETY ANALYSIS (DOD)
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                                                          &deg; On a FiArsera Sau
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                                                            *Nuclr -a       Perfonnencae Crtlatle Corlance Summey (NW 0442 B4 Table
                                                  ..... D
                                                            .Ncn.Power Evalhaton Remlft Suamary MonPower Mode NSCA Treatment                          Raedoat Realem, Sumnwy
                                                          " On a Generic Basis 11- Table ReUita Man-PoweropersM onaCudctam                          *Radoem,#" Rol"" (rralkig)
                                                            *Monliorkv Pmgre NFPA MO4    FIRE RISK EVALUATIONS Fie Rit" Evaluatlon C            (")
                                    -lcJltlo N,      Fire PRA FHA DATABASE DATA I llow" aor.s            FP syiares an4 a scnal               FealuresDe lnwvemo f               914 Table Hazard              Detailed Dole FHA SUPPORT DOCUMENTATION Ev-aludions FPP                   Drawkeg                                         SoM text indicates now NFPA anS documents Fesn            ]B~ EquValency
   ;F-Fk*ePre-Pians Reelms Review calcualo Figure 4 NFPA 805 Planned Post-Transition Documents and Relationships Page 51 Revision 00                                                                                                            Page 51

NextEra PBNP                                                 4.0 Compliance with NFPA 805 Requirements 4.7.2 Compliance with Configuration Control Requirements in Sections 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 NextEra 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 fire protection program are reviewed appropriately. The RI-PB post transition change process methodology is based upon the requirements of NFPA 805, and industry guidance in NEI 04-02, and RG 1.205. These requirements are summarized in Table 4-2.
Table 4-2 Change Evaluation Guidance Summary Table Document                        Section(s)                                      Topic NFPA 805        2.2(h), 2.2.9, 2.4.4, A.2.2(h), A.2.4.4,    Change Evaluation D.5 NEI 04-02       5.3, Appendix B, Appendix I,                Change Evaluation, Change Evaluation Appendix J                                  Forms (Appendix I)
RG 1.205       C.2.2.4, C.3.1, C.3.2, C.4.3                Risk Evaluation, Standard License Condition, Change Evaluation Process, Fire PRA 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 Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
: 1. The baseline is defined as that plant condition or configuration that is consistent with the Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
: 2. The changed or altered condition or configuration that is not consistent with the Design Basis and 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 fire protection program. This screening is consistent with fire protection regulatory review processes in place at nuclear plants Revision 0                                                                                            Page 52

NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements 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:
    " 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 to 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 defense-in-depth 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 defense-in-depth philosophy and that sufficient safety margins were maintained.
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NextEra PBNP                                               4.0 Compliance with NFPA 805 Requirements NextEra PBNP                                               4.0 Compliance with NFPA 805 Requirements Defining the Change (5.3.2)
Licns   N            Cmpie      Yee AmendwnertRequeth             NhoT r       s ReqtReapproed Ucense Preliminary Risk Screening (5.3.3)
Risk Evaluation (5.3.4)
PRA Capability Category Assessment
                               -        .6-   -
Fite PRA1 Assessment Acceptance Criteria (5.3.5)
No Figure 4-10 Plant Change Evaluation [NEI 04-02 Figure 5-1]
Note references in Figure refer to NEI 04-02 Sections Page 54 Revision 00                                                                                   Page 54

NextEra PB3NP                                     4.0 Compliance with NFPA 805 Requirements The PBNP 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 License Basis Reviews will be utilized to maintain configuration control of the Fire Protection program documents. The configuration control procedures which govern the various PBNP documents and databases that currently exist will be revised to reflect the new NFPA 805 licensing bases requirements. See IMP-135 in Attachment S.
Several NFPA 805 document types such as: NSCA Supporting Information, Non-Power Mode NSCA Treatment, etc., generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be modeled after the existing processes for similar types of documents and databases. System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play. See IMP-135 in Attachment S.
The process for capturing the impact of proposed changes to the plant on the Fire Protection 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 Fire Protection 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 Fire Protection program impacts will be sent to qualified individuals (Fire Protection, Safe Shutdown/NSCA, and/or Fire PRA) to ascertain the program impacts, if any. If Fire Protection 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 4.2.3 requirements, or
    " Performance-Based Approach: Utilize the NFPA 805 change process developed in accordance with NEI 04-02, RG 1.205, and the PBNP NFPA 805 fire protection 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 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 PBNP will maintain the existing Fire Protection Quality Assurance program.
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NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements During the transition to 10 CFR 50.48(c), PBNP performed work in accordance with the quality requirements of Section 2.7.3 of NFPA 805.
Future NFPA 805 analyses will be conducted in accordance with the requirements of NFPA 805 Section 2.7.3.
Fire PRA Quality Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the internal events PRA model. This process complies with Section 1-5 of the ASME PRA Standard and ensures that NextEra maintains an as-built, as-operated PRA model of the plant. The process has been peer reviewed. Quality assurance of the Fire PRA is assured via the same processes applied to the internal events model.
This process follows the guidance outlined in RG 1.174 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. For instance, the procedure which addresses independent review of calculations for 10 CFR 50 Appendix B is applied to the PRA model calculations, as well.
With respect to Quality Assurance Program requirements for independent reviews of calculations and evaluations, those existing requirements for Fire Protection Program documents will remain unchanged. NextEra specifically requires that the calculations and evaluations in support of the NFPA 805 LAR, exclusive of the Fire PRA, be performed within the scope of the QA program which requires independent review as defined by NextEra procedures. As recommended by NUREG/CR-6850, the sources of uncertainty in the Fire PRA were identified and specific parameters were analyzed for sensitivity in support of the NFPA 805 Fire Risk Evaluation process.
Specifically with regard to uncertainty, an uncertainty and sensitivity matrix was developed and included with the PBNP Fire PRA Report, Uncertainty and Sensitivity Analysis Notebook, P2091-2900-03. In addition, sensitivity to uncertainty associated with specific Fire PRA parameters was quantitatively addressed in this report.
While the removal of conservatism inherent in the Fire PRA is a long-term goal, the Fire PRA results were deemed sufficient for evaluating the risk associated with this application. While NextEra 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 Fire Risk Evaluation process, the uncertainty and sensitivity associated with specific Fire PRA parameters were considerations in the evaluation of the change in risk relative to the applicable acceptance thresholds.
Page 56 Revision 00                                                                         Page 56

NextEra PBNP                                      4.0 Compliance with NFPA 805 Requirements Specific Requirements of NFPA 805 Section 2.7.3 The following discusses how the requirements of NFPA 805 Section 2.7.3 were met during the transition process. Post-transition, NextEra will perform work in accordance with NFPA 805 Section 2.7.3 requirements.
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 NextEra procedures that require independent review.
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.
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) are used and were applied appropriately as required by Section 2.7.3.3 of NFPA 805.
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 performed in accordance with the quality requirements of Section 2.7.3 of NFPA 805. Personnel who used and applied 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 Fire PRA development and evaluation, NextEra 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 IMP-135 in Attachment S.
NFPA 805 Section 2.7.3.5 - Uncertainty Analysis Uncertainty analyses were performed as required by 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 Fire PRA 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.
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NextEra PB3NP                                    4.0 Compliance with NFPA 805 Requirements 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 fire protection systems and features is provided in Table 4-3. The table provides the following information from the NEI 04-02 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 Fire Protection 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 (ERFBS), fire barriers, etc. The documentation of required fire protection 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 Table B-1 process. The information is provided on a fire zone basis. The basis for the requirement of the fire protection system / feature is designated as follows:
o   S - Separation Criteria: Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3 o   L - LA Criteria: Systems/Features required for acceptability of NRC approved Licensing Actions (i.e., Exemptions/Deviation/Safety Evaluations) (Section 2.2.7) o   E - EEEE Criteria: Systems/Features required for acceptability of Existing Engineering Equivalency Evaluations (Section 2.2.7) o   R - Risk Criteria: Systems/Features required to meet the Risk Criteria for the Performance-Based Approach (Section 4.2.4) o   D - Defense-in-depth Criteria: Systems/Features required to maintain adequate balance of Defense-in-Depth for a Performance-Based Approach (Section 4.2.4)
Attachment W contains the results of the Fire Risk Evaluations, additional risk of recovery actions, and the change in risk on a fire area basis.
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.
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NextEra PBNP                                       4.0 Compliance with NFPA 805 Requirements The Fire PRA 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 Fire PRA model includes credit for modifications completed as result of the NFPA 805 transition effort as identified in Table S-1 of Attachment S and the planned implementation of the modifications identified in Table S-2 of Attachment S. Following installation of modifications and the as-built installation details, additional refinements surrounding the modifications may need to be incorporated into the Fire PRA model (see IMP-142 in Attachment S). However, these changes are not expected to be significant.
4.8.3 Supplemental Information - Other Licensee Specific Issues None.
Page 59 Revision 00                                                                          Page 59

NextEra PBNP                                                                           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                                          Required?     Required Fire Protection Fire Area Fire Zone      Description     Regulatory  Category     ID        Type        S   L E R D        Feature and System Basis                                                                   Details AOl-A            General Plant         4.2.4.2*
Area - 8' Elevation and Below A01-A      101     Valve Pit/Sump                 Suppression None         N/A Pump Room AO-A        101    Valve Pit/Sump                  Detection  D-401    Photoelectric  Y N Y Y       N Pump Room A01-A       101    Valve Pit/Sump                   Feature   None         N/A Pump Room A01-A      104     RHR Pump Room -                Suppression None         N/A 1P10A A01-A      104     RHR Pump Room -                 Detection  D-401    Photoelectric  Y N N Y       N 1P10A A01-A      104     RHR Pump Room -                  Feature   None         N/A 1P10A A01-A      105     RHR Pump Room -                Suppression None         N/A 1P10B A01-A      105     RHR Pump Room -                 Detection  D-401    Photoelectric  Y N N Y       N 1P10B A01-A      105     RHR Pump Room -                  Feature   None         N/A 1P10B A01-A      106     Pipe Way                       Suppression None         N/A A01-A      106     Pipe Way                        Detection  None         N/A A01-A      106     Pipe Way                         Feature   None         N/A A01-A      107     Pipe Way                       Suppression None         N/A A01-A      107     Pipe Way                        Detection  None         N/A A01-A      107     Pipe Way                         Feature   None         N/A A01-A      108     RHR Pump Room -                Suppression None         N/A 2P10A A01-A      108     RHR Pump Room -                 Detection  D-401    Photoelectric  Y N Y Y       N 2P110A A01-A      108     RHR Pump Room -                  Feature   None         N/A 2P10A Revision 0                                                                                                                 Page 60

NextEra PBNP                                                                            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                                           Required?     Required Fire Protection Fire Area Fire Zone      Description     Regulatory  Category     ID        Type        S   L E R     D     Feature and System Basis                                                                   Details A01-A       109    RHR Pump Room -                Suppression None         N/A 2P1OB A01-A       109    RHR Pump Room -                 Detection  D-401    Photoelectric  Y N Y Y       N 2P1OB AO-A        109    RHR Pump Room -                  Feature   None         N/A 2P1OB A01-A       110    Pipe Way                       Suppression None         N/A A01-A       110    Pipe Way                        Detection  None         N/A A01-A       110    Pipe Way                         Feature   None         N/A A01-A       111    Pipe Way                       Suppression None         N/A A01-A       111    Pipe Way                        Detection  None         N/A A01-A       111    Pipe Way                         Feature   None         N/A A01-A       113    RHR HX Corridor                Suppression None         N/A A01-A       113    RHR HX Corridor                 Detection  D-401    Photoelectric  Y N Y N       N A01-A       113    RHR HX Corridor                  Feature   None         N/A A01-A       114    Reactor Coolant                Suppression None         N/A Drain Tank - Unit 1 A01-A       114    Reactor Coolant                 Detection  None         N/A Drain Tank - Unit 1 A01-A       114    Reactor Coolant                  Feature   None         N/A Drain Tank - Unit 1 A01-A       115    RHR Heat                       Suppression None         N/A Exchanger Room -
Unit 1 A01-A       115    RHR Heat                        Detection  None         N/A Exchanger Room -
Unit 1 A01-A       115    RHR Heat                         Feature   None         N/A Exchanger Room -
Unit 1 A01-A       117    Sump Tank &                    Suppression None         N/A Pump Room Revision 0                                                                                                                  Page 61

NextEra PBNP                                                                           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                                          Required?     Required Fire Protection Fire Area Fire Zone     Description      Regulatory  Category    ID        Type        S    L E R    D     Feature and System Basis                                                                  Details A01-A      117    Sump Tank &                      Detection  None        N/A Pump Room A01-A      117    Sump Tank &                       Feature   None        N/A Pump Room A01-A      118    Reactor Coolant                 Suppression None        N/A Drain Tank - Unit 2 A01-A      118    Reactor Coolant                  Detection  None        N/A Drain Tank - Unit 2 A01-A      118    Reactor Coolant                   Feature   None        N/A Drain Tank - Unit 2 A01-A      119    RHR Heat                        Suppression None        N/A Exchanger Room -
Unit 2 A01-A      119    RHR Heat                         Detection  None        N/A Exchanger Room -
Unit 2 A01-A      119    RHR Heat                          Feature   None        N/A Exchanger Room -
Unit 2 A01-A      131    Holdup Tank Pump                Suppression None        N/A Room A01-A      131    Holdup Tank Pump                 Detection  D-401   Photoelectric  Y N     Y N N Room A01-A      131    Holdup Tank Pump                  Feature   None        N/A Room A01-A      137    Valve Gallery - Unit            Suppression None        N/A 2
A01-A      137    Valve Gallery - Unit             Detection  D-401   Photoelectric  Y N     N N N 2
A01-A      137    Valve Gallery - Unit              Feature   None        N/A 2
A01-A      138    Boric Acid                      Suppression None        N/A Evaporator Room-North Page 62 Revision 0 0                                                                                                                 Page 62

NextEra PBNP                                                                          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                                         Required?     Required Fire Protection Fire Area Fire Zone     Description      Regulatory  Category      ID      Type        S   L E R D         Feature and System Basis                                                                  Details A01-A      138    Boric Acid                       Detection    D-401 Photoelectric  Y   N N Y     N Evaporator Room-North A01-A      138    Boric Acid                        Feature     None      N/A Evaporator Room-North A01-A      139    Boric Acid                      Suppression   None      N/A Evaporator Room-South A01-A      139    Boric Acid                       Detection    D-401 Photoelectric  Y N    N Y    N Evaporator Room-South A01-A      139    Boric Acid                        Feature     None      N/A Evaporator Room-South A01-A      140    Valve Gallery - Unit            Suppression   None      N/A 1
A01-A      140    Valve Gallery - Unit             Detection    D-401 Photoelectric  Y N    N N    N 1
A01-A      140    Valve Gallery - Unit              Feature     None      N/A 1
A01-A      141    Corridor - North                Suppression   None      N/A A01-A      141    Corridor - North                 Detection    D-401 Photoelectric  Y   N  N   Y  N A01-A      141    Corridor - North                  Feature     None      N/A AOl-A      142    CCW Pump Room                   Suppression  FP-253  Wet Pipe      N   N  Y   Y  N AOl-A      142    CCW Pump Room                   Suppression  FP-267  Wet Pipe      N   N  Y   Y  N A01-A      142    CCW Pump Room                    Detection    D-401 Photoelectric  N   N  Y   Y  N A01-A      142    CCW Pump Room                     Feature    D03-12   ERFBS        Y   N  N   Y  N Protects Raceway D03-12 A01-A      142    CCW Pump Room                     Feature   2NP2C1    ERFBS        N   N  N   Y  N Protects Raceway 2NP2C1 A01-A      142    CCW Pump Room                     Feature   2-2020D   ERFBS        N   N  N   Y  N Protects Raceway 2-2020D A01-A      142    CCW Pump Room                     Feature   2-2019D   ERFBS        Y   N  N   Y  N Protects Raceway 2-2019D A01-A      142    CCW Pump Room                     Feature    D04-11   ERFBS        Y   N  N   Y  N Protects Raceway D04-1 1 Page 63 Revision 0 0                                                                                                                 Page 63

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory   Category       ID       Type        S   L E R D        Feature and System Basis                                                                     Details A01-A       142    CCW Pump Room                   Feature    D31-11      ERFBS       Y   N  N   Y  N Protects Raceway D31-11 A01-A       142    CCW Pump Room                   Feature     FV07       ERFBS       N   N  N   Y  N Protects Raceway FV07 A01-A       142    CCW Pump Room                   Feature     D04-7      ERFBS       Y   N  N   Y  N Protects Raceway D04-7 A01-A       142    CCW Pump Room                   Feature    2P2C1       ERFBS       N   N  N   Y  N Protects Raceway 2P2C1 A01-A      142A    Condensate Return            Suppression    None        N/A Pump Room A01-A      142A    Condensate Return              Detection    D-401   Photoelectric  Y   N  Y   Y  N Pump Room A01-A      142A    Condensate Return               Feature     None        N/A Pump Room A01-A       143    Corridor - South             Suppression    None        N/A A01-A       143    Corridor - South               Detection    D-401   Photoelectric  Y   N  Y   Y  N A01-A       143    Corridor - South                Feature     None        N/A A01-A       144    Seal Water HX                Suppression    None        N/A Room - North A01-A       144    Seal Water HX                  Detection    None        N/A Room - North A01-A       144    Seal Water HX                   Feature     None        N/A Room - North A01-A       145    Non-Regen HX                 Suppression    None        N/A Room - North A01-A       145    Non-Regen HX                   Detection    None        N/A Room - North Aol-A       145    Non-Regen HX                    Feature     None        N/A Room - North A01-A       146    Non-Regen HX                 Suppression    None        N/A Room - South Aol-A       146    Non-Regen HX                   Detection    None        N/A Room - South A01-A       146    Non-Regen HX                    Feature     None        N/A Room - South At..A       1A7      o1 \A/nfor WIY             *.Qnnnr        K*inn        MI/A Mirn0 Room - South Revision 0                                                                                                                  Page 64

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A01-A       147    Seal Water HX                 Detection     None        N/A Room - South A01-A       147    Seal Water HX                  Feature      None        N/A Room - South A01-A       148    Waste Holdup                 Suppression    None        N/A Tank Room A01-A       148    Waste Holdup                  Detection     None        N/A Tank Room A01-A       148    Waste Holdup                   Feature      None        N/A Tank Room A01-A       149    Waste Evaporator             Suppression    None        N/A Pump Room A01-A       149    Waste Evaporator              Detection     None        N/A Pump Room A01-A       149    Waste Evaporator               Feature      None        N/A Pump Room A01-A       150    Waste Evaporator             Suppression    None        N/A Cond. Tank Room A01-A       150    Waste Evaporator              Detection     None        N/A Cond. Tank Room A01-A       150    Waste Evaporator               Feature      None        N/A Cond. Tank Room Page 65 Revision 00                                                                                                                Page 65

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S   L E R     D    Feature and System Basis                                                                     Details AO-B             Monitor Tank Area   4.2.4.2*
A01-B      128    Holdup Tank                  Suppression    None        N/A Room - T8A A01-B      128    Holdup Tank                   Detection     None        N/A Room - T8A A01-B      128    Holdup Tank                    Feature      None        N/A Room - T8A A01-B      129    Holdup Tank                  Suppression    None        N/A Room - T8B Aol-B      129    Holdup Tank                   Detection     None        N/A Room - T8B A01-B      129    Holdup Tank                    Feature      None        N/A Room - T8B A01-B      130    Holdup Tank                  Suppression    None        N/A Room - T8C A01-B      130    Holdup Tank                   Detection     None        N/A Room - T8C A01-B      130    Holdup Tank                    Feature      None        N/A Room - T8C A01-B      187    Monitor Tank Room             Detection    D-403    Photoelectric  Y N Y Y       N A01-B      187    Monitor Tank Room              Feature    2S394-1      ERFBS       Y N N Y       N Protects Raceway 2S394-1 A01-B      187    Monitor Tank Room              Feature     D04-11      ERFBS       Y N N Y       N Protects Raceway D04-1 1 A01-B      187    Monitor Tank Room              Feature    1S394-1      ERFBS       Y N N Y       N Protects Raceway 1S394-1 A01-B      187    Monitor Tank Room              Feature    2-2019D      ERFBS       Y N N Y       N Protects Raceway 2-2019D AO-B       187    Monitor Tank Room              Feature    1-2020D      ERFBS       Y N N Y       N Protects Raceway 1-2020D AO-B       187    Monitor Tank Room              Feature     D03-12      ERFBS       Y N N Y       N Protects Raceway D03-12 A01-B      187    Monitor Tank Room              Feature    2-2020D      ERFBS       Y N N Y       N Protects Raceway 2-2020D A01-B      188    Demineralizer                Suppression    None        N/A Room A01-B      188    Demineralizer                 Detection     None        N/A Room Revision 0                                                                                                                  Page 66

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description   Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A01-B      188    Demineralizer                  Feature     None         N/A Room A01-B      189    Demineralizer                Suppression   None         N/A Room A01-B      189    Demineralizer                 Detection    None         N/A Room A01-B      189    Demineralizer                  Feature     None         N/A Room A01-B      190    Gas Stripper                 Suppression   None         N/A Equipment Room A01-B      190    Gas Stripper                  Detection    None         N/A Equipment Room A01-B      190    Gas Stripper                   Feature     None         N/A Equipment Room A01-B      191    Gas Stripper                 Suppression   None         N/A Equipment Room A01-B      191    Gas Stripper                  Detection    None         N/A Equipment Room A01-B      191    Gas Stripper                   Feature     None         N/A Equipment Room A01-B      192    Valve Gallery                Suppression   None         N/A A01-B      192    Valve Gallery                 Detection    None         N/A A01-B      192    Valve Gallery                  Feature     None         N/A A01-B      193    Demineralizer                Suppression   None         N/A Room A01-B      193    Demineralizer                 Detection    None         N/A Room A01-B      193    Demineralizer                  Feature     None         N/A Room A01-B      194    Demineralizer                Suppression   None         N/A Room A01-B      194    Demineralizer                 Detection    None         N/A Room Revision 0                                                                                                                Page 67

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone      Description  Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A01-B       194    Demineralizer                  Feature     None         N/A Room A01-B       195    Ion-Exchanger                Suppression   None         N/A Room - North A01-B       195    Ion-Exchanger                 Detection    None         N/A Room - North A01-B       195    Ion-Exchanger                  Feature     None         N/A Room - North A01-B       196    Boric Acid                   Suppression   None         N/A Equipment Room A01-B       196    Boric Acid                    Detection    D-403    Photoelectric  N N N N N Equipment Room A01-B       196    Boric Acid                     Feature     None         N/A Equipment Room A01-B       197    Ion-Exchanger                Suppression   None         N/A Room - South A01-B       197    Ion-Exchanger                 Detection    None         N/A Room - South A01-B       197    Ion-Exchanger                  Feature     None         N/A Room - South A01-B       198    Reactor Coolant              Suppression   None         N/A Filter Room A01-B       198    Reactor Coolant               Detection    None         N/A Filter Room A01-B       198    Reactor Coolant                Feature     None         N/A Filter Room A01-B       199    Reactor Coolant              Suppression   None         N/A Filter Room A01-B       199    Reactor Coolant               Detection    None         N/A Filter Room A01-B       199    Reactor Coolant                Feature     None         N/A Filter Room Revision 0                                                                                                                 Page 68

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description  Regulatory   Category       ID         Type       S   L E R     D    Feature and System Basis                                                                     Details AOI-B/46          CCW Heat            4.2.4.2*
Exchanger Boric Acid Tank Area A01-B/46    237    CCW HX &Boric                Suppression    None         N/A Acid Tank Room A01-B/46    237    CCW HX &Boric                 Detection    D-403    Photoelectric  N N    Y Y N Acid Tank Room A01-B/46    237    CCW HX &Boric                  Feature    1S394-1      ERFBS       Y N    N Y N Protects Raceway 1S394-1 Acid Tank Room A01-B/46    237    CCW HX &Boric                  Feature    2S394-1      ERFBS       Y N    N Y N Protects Raceway 2S394-1 Acid Tank Room Page 69 Revision 00                                                                                                               Page 69

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description    Regulatory  Category       ID        Type        S    L E R    D     Feature and System Basis                                                                     Details A01-CN           General Plant       4.2.4.2*
Area - PAB 26' Elevation (North)
A01-CN      212    Volume Control               Suppression   None         N/A Tank Room - 2T4 A01-CN      212    Volume Control                Detection    None         N/A Tank Room - 2T4 A01-CN      212    Volume Control                 Feature     None         N/A Tank Room - 2T4 A01-CN      213    Concentrates                 Suppression   None         N/A Holding Tank Pump Room A01-CN      213    Concentrates                  Detection    None         N/A Holding Tank Pump Room A01-CN      213    Concentrates                   Feature     None         N/A Holding Tank Pump Room A01-CN      214    Sample Room                  Suppression   None         N/A A01-CN      214    Sample Room                   Detection    None         N/A A01-CN      214    Sample Room                    Feature     None         N/A A01-CN      215    Concentrates                 Suppression   None         N/A Holding Tank Pump Room A01-CN      215    Concentrates                  Detection    D-403    Photoelectric  N N     Y N N Holding Tank Pump Room A01-CN      215    Concentrates                   Feature     D03-12      ERFBS       Y N     N Y N Protects Raceway D03-12 Holding Tank Pump Room AOI-CN      216    Valve Gallery                Suppression   None         N/A A01-CN      216    Valve Gallery                 Detection    None         N/A AOI-CN      216    Valve Gallery                  Feature     None         N/A Revision 0                                                                                                                 Page 70

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description   Regulatory   Category       ID         Type       S   L E R D         Feature and System Basis                                                                     Details A01-CN      217    Corridor                     Suppression    None         N/A A01-CN      217    Corridor                      Detection     None         N/A A01-CN      217    Corridor                       Feature     D04-11      ERFBS       Y   N N Y N Protects Raceway D04-11 Page 71 Revision 00                                                                                                                Page 71

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category       ID        Type        S   L E R D         Feature and System Basis                                                                     Details A01-CS            General Plant       4.2.4.2*
Area - PAB 26' Elevation (South)
A01-CS       181    Gas Decay Tank               Suppression    None        N/A Room A01-CS       181    Gas Decay Tank                Detection     None        N/A Room A01-CS       181    Gas Decay Tank                 Feature      None        N/A Room A01-CS       182    Sample Room                  Suppression    None        N/A A01-CS       182    Sample Room                   Detection     None        N/A A01-CS       182    Sample Room                    Feature      None        N/A A01-CS       183    Valve Gallery                Suppression    None        N/A A01-CS       183    Valve Gallery                 Detection     None        N/A A01-CS       183    Valve Gallery                  Feature      None        N/A A01-CS       184    Corridor                     Suppression    None        N/A A01-CS       184    Corridor                      Detection   FACP-7    Photoelectric  N N     Y   N N A01-CS       184    Corridor                       Feature      None        N/A A01-CS       185    Chemical Mixing              Suppression    None        N/A Tank Room N   N   N Y   N A01-CS       185    Chemical Mixing               Detection   FACP-7    Photoelectric  N N N       N N Tank Room A01-CS       185    Chemical Mixing                Feature      None        N/A Tank Room A01-CS       186    Volume Control               Suppression    None        N/A Tank Room - 1T4 A01-CS       186    Volume Control                Detection     None        N/A Tank Room - 1T4 A01-CS       186    Volume Control                 Feature      None        N/A Tank Room - 1T4 Page 72 Revision 00                                                                                                                 Page 72

NextEra PBNP                                                                           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                                         Required?     Required Fire Protection Fire Area Fire Zone      Description      Regulatory  Category    ID        Type        S   L E R D        Feature and System Basis                                                                  Details A01-D            General Plant          4.2.4.2*
Area - PAB 44' and 66' Elevation A01-D       203    Transfer Canal                  Suppression None        N/A A01-D       203    Transfer Canal                   Detection  None        N/A A01-D       203    Transfer Canal                    Feature   None        N/A A01-D       204    Transfer Canal                  Suppression None        N/A A01-D       204    Transfer Canal                   Detection  None        N/A AO1-D       204    Transfer Canal                    Feature   None        N/A A01-D       205    Spent Fuel Pool                 Suppression None        N/A A01-D       205    Spent Fuel Pool                  Detection  None        N/A A01-D       205    Spent Fuel Pool                   Feature   None        N/A AOI-D       206    Spent Fuel Pool                 Suppression None        N/A A01-D       206    Spent Fuel Pool                  Detection  None        N/A A01-D       206    Spent Fuel Pool                   Feature   None        N/A A01-D       207    Drum Storage                    Suppression None        N/A Room A01-D       207    Drum Storage                     Detection  None        N/A Room A01-D       207    Drum Storage                      Feature   None        N/A Room A01-D       208    Radiological Waste              Suppression None        N/A Solidification A01-D       208    Radiological Waste               Detection  D-404   Photoelectric  N N N N N Solidification A01-D       208    Radiological Waste                Feature   None        N/A Solidification A01-D      208A    Radwaste                        Suppression None        N/A Solidification Waste Tank Equipment Room Revision 0                                                                                                                 Page 73

NextEra PBNP                                                                            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                                          Required?     Required Fire Protection Fire Area Fire Zone       Description     Regulatory  Category    ID        Type        S    L E R    D     Feature and System Basis                                                                  Details A01-D      208A    Radwaste                         Detection  None        N/A Solidification Waste Tank Equipment Room A01-D      208A    Radwaste                          Feature   None        N/A Solidification Waste Tank Equipment Room AOI-D       209    Truck Access Area               Suppression None        N/A A01-D       209    Truck Access Area                Detection  None        N/A A01-D       209    Truck Access Area                 Feature   None        N/A A01-D       238    Gas Stripper                    Suppression None        N/A Equipment Room A01-D       238    Gas Stripper                     Detection  D-403   Photoelectric  N N     N N N Equipment Room A01-D       238    Gas Stripper                      Feature   None        N/A Equipment Room A01-D       239    Ion-Exchanger                   Suppression None        N/A Filter Room A01-D       239    Ion-Exchanger                    Detection  None        N/A Filter Room A01-D       239    Ion-Exchanger                     Feature   None        N/A Filter Room A01-D       240    Waste Gas                       Suppression None        N/A Equipment Room A01-D       240    Waste Gas                        Detection  None        N/A Equipment Room A01-D       240    Waste Gas                         Feature   None        N/A Equipment Room A01-D       241    New Fuel Storage                Suppression None        N/A A01-D       241    New Fuel Storage                 Detection  None        N/A A01-D       241    New Fuel Storage                  Feature   None        N/A A01-D       243    Equipment Gallery               Suppression None        N/A Revision 0                                                                                                                  Page 74

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S    L E R D        Feature and System Basis                                                                     Details A01-D      243    Equipment Gallery             Detection     None        N/A A01-D      243    Equipment Gallery              Feature      None        N/A A01-D      244    Drum Preparation             Suppression    None        N/A Area A01-D      244    Drum Preparation              Detection     None        N/A Area A01-D      244    Drum Preparation               Feature      None        N/A Area A01-D      271    Service Area                 Suppression    None        N/A A01-D      271    Service Area                  Detection     None        N/A A01-D      271    Service Area                   Feature      None        N/A AO1-D      274    Fuel Handling                Suppression   None         N/A Platform AO1-D      274    Fuel Handling                 Detection    None         N/A Platform A01-D      274    Fuel Handling                  Feature     None         N/A Platform Revision 0                                                                                                                 Page 75

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone      Description   Regulatory  Category       ID        Type        S   L E R D         Feature and System Basis                                                                     Details A01-E            General Plant       4.2.4.2*
Area - Turbine Building AO1-E       122    Water Treating               Suppression    None        N/A Equipment Area A01-E       122    Water Treating                Detection     None        N/A Equipment Area A01-E       122    Water Treating                 Feature      None        N/A Equipment Area A01-E       123    Water Treatment              Suppression    None        N/A Acid Tank Room A01-E       123    Water Treatment               Detection     None        N/A Acid Tank Room A01-E       123    Water Treatment                Feature      None        N/A Acid Tank Room A01-E       124    Water Treatment              Suppression    None        N/A Caustic Tank Room A01-E       124    Water Treatment               Detection     None        N/A Caustic Tank Room A01-E       124    Water Treatment                Feature     None         N/A Caustic Tank Room A01-E       126    Cation                       Suppression   None         N/A Demineralizer Assembly Area A01-E       126    Cation                        Detection    None         N/A Demineralizer Assembly Area A01-E       126    Cation                         Feature     None         N/A Demineralizer Assembly Area A01-E       180    Pipe Shaft                   Suppression   None         N/A A01-E       180    Pipe Shaft                    Detection    None         N/A A01-E       180    Pipe Shaft                     Feature     None         N/A A01-E      218     Pipe Shaft                   Suppression   None         N/A Revision 0                                                                                                                  Page 76

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID        Type        S    L E R    D     Feature and System Basis                                                                    Details A01-E      218    Pipe Shaft                     Detection    None        N/A A01-E      218    Pipe Shaft                      Feature     None        N/A A01-E      222    Chemical Storage              Suppression   None        N/A Area A01-E      222    Chemical Storage               Detection    None        N/A Area A01-E      222    Chemical Storage                Feature     None        N/A Area A01-E      223    Hopper Area                   Suppression   None        N/A A01-E      223    Hopper Area                    Detection    None        N/A A01-E      223    Hopper Area                     Feature     None        N/A A01-E      224    Alternate Shutdown            Suppression   None        N/A Panel Zone A01-E      224    Alternate Shutdown             Detection    None        N/A Panel Zone A01-E      224    Alternate Shutdown              Feature     None        N/A Panel Zone A01-E      231    General Ops Office            Suppression  FP-325     Wet Pipe     N N     N N N Area A01-E      231    General Ops Office             Detection    None        N/A Area A01-E      231    General Ops Office              Feature     None        N/A Area A01-E      245    Electrical                    Suppression   None        N/A Equipment Room -
Unit 1 A01-E      245    Electrical                     Detection   D-407    Photoelectric  N N     N Y   N Equipment Room -
Unit 1 A01-E      245    Electrical                      Feature     None        N/A Equipment Room -
Unit 1 Revision 0                                                                                                                 Page 77

NextEra PBNP                                                                          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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A01-E      246    Electrical                    Suppression   None        N/A Equipment Room -
Unit 2 A01-E      246    Electrical                     Detection   D-408    Photoelectric  N N N Y N Equipment Room -
Unit 2 A01-E      246    Electrical                      Feature     None        N/A Equipment Room -
Unit 2 A01-E      250    HVAC Equipment                Suppression   None        N/A Room - Unit 1 A01-E      250    HVAC Equipment                 Detection    None        N/A Room - Unit 1 A01-E      250    HVAC Equipment                  Feature     None        N/A Room - Unit 1 A01-E      251    HVAC Equipment                Suppression   None        N/A Room - Unit 2 AO1-E      251    HVAC Equipment                 Detection    None        N/A Room - Unit 2 A01-E      251    HVAC Equipment                  Feature     None        N/A Room - Unit 2 A01-E      272    HVAC Fan    Room -            Suppression   None        N/A Unit 1 A01-E      272    HVAC Fan    Room -             Detection    None        N/A Unit 1 A01-E      272    HVAC Fan    Room -              Feature     None        N/A Unit 1 A01-E      273    HVAC Fan    Room -            Suppression   None        N/A Unit 2 A01-E      273    HVAC Fan    Room -             Detection   None         N/A Unit 2 A01-E      273    HVAC Fan    Room -              Feature    None         N/A Unit 2 A01-E      300    Lube Oil                      Suppression  FP-70    Water Spray    N   N N N N Turbine Oil Reservoir Unit Reservoir - Unit 1 Revision 0                                                                                                                Page 78

NextEra PBNP                                                                            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                                          Required?     Required Fire Protection Fire Area Fire Zone     Description       Regulatory  Category      ID       Type       S   L E R D         Feature and System Basis                                                                  Details A01-E      300    Lube Oil                          Detection   C-139   Photoelectric N N    N N N Reservoir - Unit 1 A01-E      300    Lube Oil                           Feature     None       N/A Reservoir - Unit 1 A01-E      301    Ul Turbine Building              Suppression   FP-60  Water Spray   N N    N N N Hydrogen Seal Oil Unit General Area - 8 Ft.
A01-E      301    Ul Turbine Building              Suppression  FP-154   Wet Pipe     N N    N N N General Area - 8 Ft.
A01-E      301    Ul Turbine Building               Detection  FACP-10  Photoelectric N   N N N N General Area - 8 Ft.
A01-E      301    Ul Turbine Building                Feature     None       N/A General Area - 8 Ft.
A01-E      301    Ul Turbine Building                Feature     None       N/A General Area - 8 Ft.
A01-E      302    Electrical Shop                  Suppression   None       N/A A01-E      302    Electrical Shop                   Detection    None       N/A A01-E      302    Electrical Shop                    Feature     None       N/A A01-E      303    Condenser Pit                    Suppression  FP-157   Wet Pipe     N   N  N   N  N Condenser Pit A01-E      303    Condenser Pit                     Detection    None       N/A A01-E      303    Condenser Pit                      Feature     None       N/A A01-E      311    AFP Tunnel                       Suppression   None       N/A A01-E      311    AFP Tunnel                        Detection    None       N/A A01-E      311    AFP Tunnel                         Feature     None       N/A A01-E      316    Ul Turbine Building              Suppression  FP-159   Wet Pipe     N   N  Y   N  N General Area - 26 ft.
A01-E      316    Ul Turbine Building               Detection  FACP-1 0 Photoelectric N   N  N   N  N General Area - 26 ft.
A01-E      316    Ul Turbine Building                Feature     None       N/A General Area - 26 ft.
A01-E      317    Instrument Shop                  Suppression  FP-159   Wet Pipe     N   N  N   N  N A01-E      317    Instrument Shop                   Detection    None       N/A Page 79 Revision 0 0                                                                                                                  Page 79

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description     Regulatory  Category       ID       Type        S   L E R D         Feature and System Basis                                                                    Details A01-E      317    Instrument Shop                 Feature     None        N/A A01-E      319    Non-Vital                     Suppression   None        N/A Switchgear Room A01-E      319    Non-Vital                      Detection   D-406    Photoelectric                N Switchgear Room A01-E      319    Non-Vital                       Feature     None        N/A Switchgear Room A01-E      320    Condensate                    Suppression   None        N/A Storage Tank Area A01-E      320    Condensate                     Detection    None        N/A Storage Tank Area A01-E      320    Condensate                      Feature     None        N/A Storage Tank Area A01-E      322    Turbine Building              Suppression Dry Chem Dry Chemical                  N Operating Floor -
Unit 1 A01-E      322    Turbine Building               Detection  FACP-10   Photoelectric                N Operating Floor -
Unit 1 A01-E      322    Turbine Building               Detection    None      Thermal                    N Turbine Bearing Detection Operating Floor -
Unit 1 A01-E      322    Turbine Building                Feature     None        N/A Operating Floor -
Unit 1 A01-E      324    Non-Safety Related            Suppression   None        N/A Battery Room -
D205 A01-E      324    Non-Safety Related             Detection   D-406      Thermal      N   N  N   N  N Battery Room -
D205 A01-E      324    Non-Safety Related              Feature     None        N/A Battery Room -
D205 A01-E      325    Telephone                     Suppression   None        N/A Equipment Room Revision 0                                                                                                                   Page 80

NextEra PBNP                                                                           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                                          Required?     Required Fire Protection Fire Area Fire Zone     Description      Regulatory  Category       ID       Type      S   L E R D         Feature and System Basis                                                                   Details A01-E      325    Telephone                        Detection    None        N/A Equipment Room A01-E      325    Telephone                         Feature     None        N/A Equipment Room A01-E      338    Elevator Machine                Suppression   None        N/A Room A01-E      338    Elevator Machine                 Detection    None        N/A Room A01-E      338    Elevator Machine                  Feature     None        N/A Room A01-E      360    South Service                   Suppression   FP-52    Wet Pipe    N N     Y N   N Building A01-E      360    South Service                    Detection   FACP-7  Photoelectric N N     N N N Building A01-E      360    South Service                     Feature     None        N/A Building A01-E      542    Lube Oil                        Suppression  FP-168  Water Spray   N N     N N   N Turbine Oil Reservoir Unit Reservoir - Unit 2 A01-E      542    Lube Oil                         Detection    C-139  Photoelectric N N     N N   N Reservoir - Unit 2 A01-E      542    Lube Oil                          Feature     None        N/A Reservoir - Unit 2 A01-E      547    Turbine Building                Suppression Dry Chem Dry Chemical  N N Y N       N Operating Floor -
Unit 2 A01-E      547    Turbine Building                 Detection    None     Thermal     N N Y N       N Turbine Bearing Detection Operating Floor -
Unit 2 A01-E      547    Turbine Building                  Feature     None        N/A Operating Floor -
Unit 2 AO1-E      583    U2 Turbine Building             Suppression  FP-108  Water Spray   N Y N N       N Hydrogen Seal Oil Unit General Area - 8 ft.
A01-E      583    U2 Turbine Building             Suppression  FP-166    Wet Pipe    N Y Y N       N General Area - 8 ft.
Revision 0                                                                                                                    Page 81

NextEra PBNP                                                                          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                                        Required?     Required Fire Protection Fire Area Fire Zone     Description       Regulatory  Category     ID      Type        S   L E R D        Feature and System Basis                                                                 Details A01-E      583    U2 Turbine Building               Detection   None      N/A General Area - 8 ft.
A01-E      583    U2 Turbine Building                Feature    None      N/A General Area - 8 ft.
A01-E      583    U2 Turbine Building                Feature    None      N/A General Area - 8 ft.
A01-E      584    U2 Condenser Pit                 Suppression FP-169  Wet Pipe      N N N N N Condenser Pit Area A01-E      584    U2 Condenser Pit                  Detection   None      N/A Area A01-E      584    U2 Condenser Pit                   Feature    None      N/A Area A01-E      587    Toilet                           Suppression  None      N/A A01-E      587    Toilet                            Detection   None      N/A A01-E      587    Toilet                             Feature    None      N/A A01-E      588    U2 Turbine Building              Suppression FP-123  Wet Pipe      N Y N N N General Area - 26 ft.
A01-E      588    U2 Turbine Building               Detection   None      N/A General Area - 26 ft.
A01-E      588    U2 Turbine Building                Feature    None      N/A General Area - 26 ft.
Revision 0                                                                                                                Page 82

NextEra PBNP                                                                          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                                         Required?      Required Fire Protection Fire Area Fire Zone     Description      Regulatory  Category     ID       Type        S   L E R      D    Feature and System Basis                                                                   Details A01 -F          General Plant          4.2.4.2*
Area - YARD A01-F      556    Main                            Suppression FP-43   Water Spray    N   Y  N   N   N lX01B Main Transformer Transformers  - Unit 1
A01-F      556    Main                            Suppression FP-41   Water Spray    N   Y  N   N   N 1X02 Aux Transformer Transformers  - Unit 1
A01-F      556    Main                            Suppression FP-44   Water Spray    N   Y  N   N   N 1X01A Main Transformer Transformers  - Unit 1
A01-F      556    Main                            Suppression FP-135  Water Spray    N   Y  N   N   N Ul Turbine Bldg Wall Spray Transformers  - Unit 1
A01-F      556    Main                            Suppression FP-42   Water Spray    N   Y  N   N   N lX01C Main Transformer Transformers  - Unit 1
A01-F      556    Main                             Detection   C01      Thermal      N   Y  N   N   N Transformers  - Unit 1
A01-F      556    Main                              Feature    None       N/A Transformers  - Unit 1
A01-F      557    Manhole B                       Suppression  None       N/A A01-F      557    Manhole B                        Detection   None       N/A A01-F      557    Manhole B                         Feature    None       N/A A01-F      576    Fuel Oil Storage                Suppression  None       N/A Tanks N   N A01-F      576    Fuel Oil Storage                 Detection  D-41 1    Thermal      N   N  N N N Tanks A01-F      576    Fuel Oil Storage                  Feature    None       N/A Tanks A01-F      577    Manhole No.11                   Suppression  None       N/A A01-F      577    Manhole No.11                    Detection   None       N/A Page 83 Revision 00                                                                                                                  Page 83

NextEra PBNP                                                                          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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A01-F      577    Manhole No.11                   Feature    None         N/A A01-F      666    Manhole No.10                 Suppression  None         N/A A01-F      666    Manhole No.10                  Detection   None         N/A A01-F      666    Manhole No.10                   Feature    None         N/A A01-F      671    Manhole No.7                  Suppression  None         N/A A01-F      671    Manhole No.7                   Detection   None         N/A A01-F      671    Manhole No.7                    Feature    None         N/A A01-F      672    Manhole No.8                  Suppression  None         N/A A01-F      672    Manhole No.8                   Detection   None         N/A A01-F      672    Manhole No.8                    Feature    None         N/A A01-F      673    Switchyard Control            Suppression  None         N/A House A01-F      673    Switchyard Control             Detection   None         N/A House AO-F       673    Switchyard Control              Feature    None         N/A House A01-F      674    Manhole No.6                  Suppression  None         N/A A01-F      674    Manhole No.6                   Detection   None         N/A A01-F      674    Manhole No.6                    Feature    None         N/A AO-F       675    13.8KV Switchgear             Suppression  None         N/A Big - North (H03)
A01-F      675    13.8KV Switchgear              Detection   D-411    Photoelectric  N N    N Y    N Big - North (H03)
A01-F      675    13.8KV Switchgear               Feature    None         N/A Big - North (H03)
A01-F      676    13.8KV Switchgear             Suppression  None         N/A Big - Center (HO1)
A01-F      676    13.8KV Switchgear              Detection   D-411    Photoelectric  N   N  N   Y  N Big - Center (HO1)
A01-F      676    13.8KV Switchgear               Feature    None         N/A Big - Center (HO1)
Revision 0                                                                                                                Page 84

NextEra PBNP                                                                              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                                               Required?     Required Fire Protection Fire Area Fire Zone      Description   Regulatory   Category          ID        Type      S   L E R     D     Feature and System Basis                                                                      Details A01-F      677     13.8KV Switchgear            Suppression        None        N/A Big - South (H02)
A01-F      677     13.8KV Switchgear               Detection      D-411   Photoelectric N N N Y       N Big - South (H02)
A01-F      677     13.8KV Switchgear                Feature        None        N/A Bg - South (H02)
A01-F      680    Station Auxiliary             Suppression       FP-41    Pre-action   N N N       N N Transformers A01-F      680    Station Auxiliary                Detection      D-411     Thermal     N N N N       N Transformers A01-F      680    Station Auxiliary                 Feature        None        N/A Transformers A01-F      681    Gas Turbine - G05             Suppression       FP-398   Pre-action   N N N       N N A01-F      681    Gas Turbine - G05             Suppression       D-41 1  Dry Chemical  N N N N N A01-F      681    Gas Turbine - G05                Detection      D-41 1  Photoelectric N N N N N A01-F      681    Gas Turbine - G05                 Feature        None        N/A A01-F      681    Gas Turbine - G05                 Feature        None        N/A A01-F      682    Manhole No.3                  Suppression        None        N/A A01-F      682    Manhole No.3                     Detection       None        N/A A01-F      682    Manhole No.3                      Feature        None        N/A A01-F      683    Manhole No.4                  Suppression        None        N/A A01-F      683    Manhole No.4                     Detection       None        N/A A01-F      683    Manhole No.4                      Feature        None        N/A Af04C                                                                         KIIA
  /U   -     UU     IVlO II VIUI IU.                 .JU 1 PIVI UOOIUI   INIJI                -   -    A01-F      684    Manhole No.5                     Detection       None        N/A A01-F      684    Manhole No.5                      Feature        None        N/A A01-F      685    Manhole No.9                  Suppression        None        N/A A01-F      685    Manhole No.9                     Detection       None        N/A A01-F      685    Manhole No.9                      Feature        None        N/A Revision 0                                                                                                                    Page 85

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description     Regulatory  Category      ID        Type        S   L E R D         Feature and System Basis                                                                    Details A01-F      693    Manhole No. 12                Suppression  None         N/A A01-F      693    Manhole No.12                  Detection   None         N/A A01-F      693    Manhole No. 12                  Feature    None         N/A A01-F      694    Manhole No.13                 Suppression  None         N/A A01-F      694    Manhole No.13                  Detection   None         N/A A01-F      694    Manhole No.13                   Feature    None         N/A A01-F      698    Main Transformer -            Suppression  FP-87    Water Spray    N Y    N N N 2XOIA Main Transformer Unit 2 A01-F      698    Main Transformer-             Suppression  FP-88    Water Spray    N Y    N N N 2XO1B Main Transformer Unit 2 A01-F      698    Main Transformer -            Suppression  FP-89    Water Spray    N   Y  N   N  N 2XOIC Main Transformer Unit 2 A01-F      698    Main Transformer -            Suppression  FP-90    Water Spray    N   Y  N   N  N 2X02 Aux Transformer Unit 2 AO-F       698    Main Transformer -             Detection    Col       Thermal      N   Y  N   N  N Unit 2 A01-F      698    Main Transformer -              Feature    None         N/A Unit 2 A01-F      755    Warehouse #4                  Suppression  None         N/A A01-F      755    Warehouse #4                   Detection   None         N/A A01-F      755    Warehouse #4                    Feature    None         N/A A01-F     YARD    Yard Area                     Suppression  None         N/A A01-F     YARD    Yard Area                      Detection   None         N/A A01-F     YARD    Yard Area                       Feature    None         N/A Page 86 Revision 0 0                                                                                                                  Page 86

NextEra PBNP                                                                           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                                             Required?      Required Fire Protection Fire Area Fire Zone     Description  Regulatory   Category       ID        Type        S    L E R    D      Feature and System Basis                                                                      Details AOI-G           Unit I Fagade       4.2.4.2*
A01-G      524    Containment                  Suppression    None        N/A Facade - Unit 1 A01-G      524    Containment                   Detection   LHP-1,     Line-Type     N N     Y N N Protectowire installed on cable Fagade - Unit 1                           FACP-7                                    trays A01-G      524    Containment                    Feature      None        N/A Fagade - Unit 1 A01-G      525    Unit 1 Fagade                Suppression    None        N/A Pump Room A01-G      525    Unit 1 Fagade                 Detection     None        N/A Pump Room A01-G      525    Unit 1 Fagade                  Feature      None        N/A Pump Room A01-G      531    Unit 1 Fagade                Suppression    None        N/A Passage A01-G      531    Unit 1 Fagade                 Detection     None        N/A Passage A01-G      531    Unit 1 Fagade                  Feature      None        N/A Passage A01-G      536    Elevator Machine             Suppression    None        N/A Room A01-G      536    Elevator Machine              Detection     None        N/A Room A01-G      536    Elevator Machine               Feature      None        N/A Room Revision 0                                                                                                                  Page 87

NextEra PBNP                                                                            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                                             Required?      Required Fire Protection Fire Area Fire Zone      Description  Regulatory   Category       ID        Type        S    L E R D         Feature and System Basis                                                                        Details A01-H            Unit 2 Fagade       4.2.4.2*
A01-H       596    Containment                  Suppression    None        N/A Fagade - Unit 2 A01-H       596    Containment                   Detection   LHP-2,     Line-Type     N N     Y N N Protectowire installed on cable Fagade - Unit 2                           FACP-8                                    trays A01-H       596    Containment                    Feature      None        N/A Fagade - Unit 2 A01-H      597A    Unit 2 Fagade                Suppression    None        N/A Pump Room A01-H      597A    Unit 2 Fagade                 Detection     None        N/A Pump Room A01-H      597A    Unit 2 Fagade                  Feature      None        N/A Pump Room A01-H       600    Unit 2 Fagade                Suppression    None        N/A Passage A01-H       600    Unit 2 Fagade                 Detection     None        N/A Passage A01-H       600    Unit 2 Fagade                  Feature      None        N/A Passage A02             Containment         4.2.4.2*
Spray/Safety Injection Pump Room A02        151    Safety Injection             Suppression   FP-253    Wet Pipe      N N Y Y       N Area and doorway water Pump Room                                                                           curtain protection A02        151    Safety Injection              Detection    D-401    Photoelectric  N N Y Y       N Pump Room A02        151    Safety Injection               Feature      None        N/A Pump Room Revision 0                                                                                                                    Page 88

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone      Description  Regulatory   Category       ID         Type       S   L E R D          Feature and System Basis                                                                        Details A03             IP2C Charging       4.2.4.2*
Pump Room A03        152    Charging Pump                Suppression   FP-253   Water Spray    N N     N N N Doorway Water Curtain Room - 1P2C A03        152    Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room - 1P2C A03        152    Charging Pump                  Feature      None         N/A Room - 1 P2C A04             IP2B Charging       4.2.4.2*
Pump Room A04       153     Charging Pump                Suppression   FP-253   Water Spray    N N     N N N Doorway Water Curtain Room - 1P2B A04       153     Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room - 1P2B A04       153     Charging Pump                  Feature      None         N/A Room - 1P2B A05             1P2A Charging       4.2.4.2*
Pump Room A05       154     Charging Pump                Suppression   FP-253   Water Spray    N N     N N N Doorway Water Curtain Room - 1P2A A05       154     Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room - 1P2A A05       154     Charging Pump                  Feature      None         N/A Room - 1P2A A06             1 B32 MCC Area      4.2.4.2*
A06       156     MCC Room - 1B32              Suppression   FP-253     Wet Pipe     N N     N Y    N Partial area and doorway curtain protection A06       156     MCC Room - 1B32               Detection    D-401    Photoelectric  N N     N Y    N A06       156     MCC Room - 1B32                Feature      None   Intra-Fire Area Y N     N Y    N Barrier A06       156A    MCC Room - 1B32               Detection    D-401    Photoelectric  N N     N Y    N Extension Page 89 Revision 0 0                                                                                                                     Page 89

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A07            Chemical Drain,     4.2.4.2*
Laundry Tank and RCP Seal Filter Area A07       157    RCP Seal Water               Suppression    None        N/A Filter Room A07       157    RCP Seal Water                Detection     None        N/A Filter Room A07       157    RCP Seal Water                 Feature      None        N/A Filter Room A07       158    Laundry Tank Room            Suppression   FP-253    Wet Pipe      N N N N N Doorway water curtains A07       158    Laundry Tank Room             Detection     None        N/A A07       158    Laundry Tank Room              Feature      None        N/A A08            HVAC Equip. Rm      4.2.4.2*
Pipeway I Valve Gallery Area A08       155    Valve Gallery -              Suppression    None        N/A Pipe Way 1 A08       155    Valve Gallery -               Detection    D-401    Photoelectric  N   N N N N Pipe Way 1 A08       155    Valve Gallery -                Feature      None        N/A Pipe Way 1 A08       159    HVAC Equipment               Suppression   FP-253    Wet Pipe      N   N N N N Doorway water curtains Room A08       159    HVAC Equipment                Detection    D-401    Photoelectric  N   N Y N N Room A08       159    HVAC Equipment                 Feature      None        N/A Room Revision 0                                                                                                                Page 90

NextEra PBNP                                                                            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                                            Required?     Required Fire Protection Fire Area Fire Zone       Description   Regulatory  Category      ID        Type        S   L E R D         Feature and System Basis                                                                    Details A09             Exhaust Fan Room     4.2.4.2*
A09        160    Stack Exhaust Fan             Suppression  None         N/A Room A09        160    Stack Exhaust Fan              Detection   None         N/A Room A09        160    Stack Exhaust Fan               Feature    None         N/A Room A09        161    Filter Exhaust Fan            Suppression  None         N/A Room A09        161    Filter Exhaust Fan             Detection   D-401      Thermal      N N N N N Room A09        161    Filter Exhaust Fan              Feature    None         N/A Room AIO             Radioactive Gas      4.2.4.2*
Treatment Area A10        167    Cryogenic Room                Suppression FP-267     Wet Pipe      N N N N N Water Curtain A10        167    Cryogenic Room                 Detection   D-401    Photoelectric  N N N N N A10        167    Cryogenic Room                  Feature    None         N/A A10        168    Decay Tank Room               Suppression  None         N/A A10        168    Decay Tank Room                Detection   None         N/A A10        168    Decay Tank Room                 Feature    None         N/A All             Pipe Way 4 - Valve   4.2.4.2*
Gallery Area All        162    Valve Gallery -               Suppression  None         N/A Pipe Way 4 All        162    Valve Gallery -                Detection   D-401    Photoelectric  N   N N N N Pipe Way 4 All        162    Valve Gallery -                 Feature    None         N/A Pipe Way 4 Revision 0                                                                                                                  Page 91

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory   Category       ID        Type        S    L E R D         Feature and System Basis                                                                        Details A12             2P2C Charging      4.2.4.2*
Pump Room A12        163    Charging Pump                Suppression   FP-267   Water Spray    N N     N N N Doorway Water Curtain Room 2P2C A12        163    Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room 2P2C A12        163    Charging Pump                  Feature      None        N/A Room 2P2C A13             2P2B Charging      4.2.4.2*
Pump Room A13        164    Charging Pump                Suppression   FP-267   Water Spray    N N     N N N Doorway Water Curtain Room 2P2B A13        164    Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room 2P2B A13        164    Charging Pump                  Feature      None        N/A Room 2P2B A14             2P2A Charging      4.2.4.2*
Pump Room A14        165    Charging Pump                Suppression   FP-267   Water Spray    N N     N N N Doorway Water Curtain Room 2P2A A14       165     Charging Pump                 Detection    D-401    Photoelectric  N N     N N N Room 2P2A A14       165     Charging Pump                  Feature      None        N/A Room 2P2A A15             2B32 MCC Area      4.2.4.2*
A15       166     MCC Room - 2B32              Suppression   FP-267    Wet Pipe      N N N       Y N Area and doorway water curtain protection A15       166     MCC Room - 2632               Detection    D-401    Photoelectric  N N N Y N A15       166     MCC Room - 2B32                Feature      None        N/A Page 92 Revision 0 Revision 0                                                                                                                    Page 92

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S    L E R D        Feature and System Basis                                                                     Details A16            D106 - Battery      4.2.4.2*
Room A16       225    Battery Room -               Suppression   None         N/A D106 A16       225    Battery Room -                Detection    D-403    Photoelectric  N N     N N N D106 A16       225    Battery Room -                 Feature     None         N/A D106 A17            D04 Electrical      4.2.4.2*
Equipment Room A17       226    125VDC Electrical            Suppression   None         N/A Equipment Room -
D04 A17       226    125VDC Electrical             Detection    D-403    Photoelectric  N N     N Y N Equipment Room -
D04 A17       226    125VDC Electrical              Feature     None         N/A Equipment Room -
D04 A18            D03 Electrical      4.2.4.2*
Equipment Room A18       227    125VDC Electrical            Suppression   None         N/A Equipment Room -
D03 A18       227    125VDC Electrical             Detection    D-403    Photoelectric  N N     N N N Equipment Room -
D03 A18       227    125VDC Electrical              Feature     None         N/A Equipment Room -
D03 Page 93 Revision 00                                                                                                                Page 93

NextEra PBNP                                                                          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                                           Required?     Required Fire Protection Fire Area Fire Zone    Description     Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A19            D105 - Battery       4.2.4.2*
Room A19       228    Battery Room -                Suppression   None        N/A D105 A19       228    Battery Room -                 Detection    D-403   Photoelectric  N   N N N N D105 A19       228    Battery Room -                  Feature     None        N/A D105 A20            Heating Boiler       4.2.4.2*
Room A20       221    Heating Boiler                Suppression  FP-113     Wet Pipe     N   N Y Y N Room A20       221    Heating Boiler                 Detection    D-412   Photoelectric  N   N Y N N Room A20       221    Heating Boiler                  Feature     None        N/A Room A21            Heating Boiler Day   4.2.4.2*
Tank No.1 Room A21       252    Day Tank Room                 Suppression  FP-1 14    Wet Pipe     N   Y Y N N No.1 A21       252    Day Tank Room                  Detection    D-408   Photoelectric  N   Y Y N N No.1 A21       252    Day Tank Room                   Feature     None        N/A No.1 A22            Heating Boiler Day   4.2.4.2*
Tank No.2 Room A22       253    Day Tank Room                 Suppression  FP-1 14   Wet Pipe      N   Y Y N N No.2 A22       253    Day Tank Room                  Detection    D-408   Photoelectric  N   Y Y N N No.2 A22       253    Day Tank Room                   Feature     None        N/A No.2 Revision 0                                                                                                                Page 94

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone    Description      Regulatory  Category      ID       Type        S   L E R D         Feature and System Basis                                                                   Details A23N            Auxiliary             4.2.4.2*
Feedwater Pump Room (North)
A23N       304N   Auxiliary Feedwater            Suppression C928, D-    Halon       Y N Y Y N Pump Room (North)                            407 A23N       304N   Auxiliary Feedwater             Detection   D-407     Thermal                    N Pump Room (North)
A23N       304N   Auxiliary Feedwater             Detection   D-407   Photoelectric                N Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature    D04-7     ERFBS                      N Protects Raceway D04-7 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature    A973      ERFBS                      N Protects Raceway A973 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature   JB4178     ERFBS                      N Protects Raceway JB4178 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature    2S079     ERFBS                      N Protects Raceway 2S079 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature    A969      ERFBS                      N Protects Raceway A969 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature   D301-1     ERFBS                      N Protects Raceway D301-1 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature     FK-1     ERFBS                      N Protects Raceway FK-1 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature     FP-3     ERFBS                      N Protects Raceway FP-3 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature   2P2B-4     ERFBS                      N Protects Raceway 2P2B-4 Pump Room (North)
A23N       304N   Auxiliary Feedwater              Feature   2P2A-4     ERFBS                      N Protects Raceway 2P2A-4 Pump Room (North)
Page 95 Revision 00                                                                                                                Page 95

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone    Description      Regulatory  Category      ID       Type        S    L E R D        Feature and System Basis                                                                   Details A23S            Auxiliary             4.2.4.2*
Feedwater Pump Room (South)
A23S       304S   Auxiliary Feedwater            Suppression C928, D-    Halon       Y N     Y Y N Pump Room                                    407 (South)
A23S       304S   Auxiliary Feedwater             Detection   D-407     Thermal      Y N     Y Y N Pump Room (South)
A23S       304S   Auxiliary Feedwater             Detection   D-407   Photoelectric  Y N     Y Y N Pump Room (South)
A23S       304S   Auxiliary Feedwater              Feature   D31-11     ERFBS        Y N     N Y N Protects Raceway D31-11 Pump Room (South)
A23S       304S   Auxiliary Feedwater              Feature    N02-3     ERFBS        Y N     N Y N Protects Raceway N02-3 Pump Room (South)
A23S       304S   Auxiliary Feedwater              Feature    1S077     ERFBS        Y N     N Y N Protects Raceway 1S077 Pump Room (South)
A23S       304S   Auxiliary Feedwater              Feature    IS079     ERFBS        Y N     N Y N Protects Raceway 1S079 Pump Room (South)
Page 96 Revision 00                                                                                                                Page 96

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description     Regulatory  Category       ID       Type        S   L E R D         Feature and System Basis                                                                    Details A24             4KV Vital            4.2.4.2*
Switchgear Room A24        305    4160 V Vital                  Suppression C929, D-      Halon                    N Switchgear Room                              405 A24        305    4160 V Vital                   Detection    D-405     Thermal                    N Switchgear Room A24        305    4160 V Vital                   Detection    D-405   Photoelectric                N Switchgear Room A24        305    4160 V Vital                    Feature    JB1017      ERFBS                     N Protects Raceway JB1017 Switchgear Room A24        305    4160 V Vital                    Feature     S1032      ERFBS                     N Protects Raceway S1032 Switchgear Room A24        305    4160 V Vital                    Feature     S1030      ERFBS                     N Protects Raceway S1030 Switchgear Room A24        305    4160 V Vital                    Feature   PBNO.1B      ERFBS                     N Protects Raceway PBNO.1B Switchgear Room A24        305    4160 V Vital                    Feature     A 135      ERFBS                     N Protects Raceway Al 35 Switchgear Room A24        305    4160 V Vital                    Feature     Al 34      ERFBS                     N Protects Raceway Al 34 Switchgear Room A24        305    4160 V Vital                    Feature     A131       ERFBS                     N Protects Raceway A131 Switchgear Room A24        305    4160 V Vital                    Feature     Al 30      ERFBS                     N Protects Raceway Al 30 Switchgear Room A24        305    4160 V Vital                    Feature   PBNO.2A      ERFBS                     N Protects Raceway PBNO.2A Switchgear Room A25             D06 - Battery        4.2.4.2*
Room A25        306    Battery Room - D06            Suppression C929, D-      Halon      N   N  Y   N  N 405 A25        306    Battery Room - D06             Detection    D-405   Photoelectric  N   N  Y   N  N A25        306    Battery Room - D06              Feature    D301-1      ERFBS       N   N  N   Y  N Protects Raceway D30 1-1 Revision 0                                                                                                                   Page 97

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID         Type       S   L E R D         Feature and System Basis                                                                    Details A26            D05 - Battery        4.2.4.2*
Room A26       307    Battery Room - D05            Suppression C929, D-      Halon      N N Y Y        N 405 A26       307    Battery Room - D05             Detection   D-405    Photoelectric  N N Y Y N A26       307    Battery Room - D05              Feature    D301-1      ERFBS       N N N Y N Protects Raceway D301-1 A27            GOI - Diesel         4.2.4.2*
Generator Room A27       308    Diesel Room - G01             Suppression FP-3742     Wet Pipe     N N Y Y N A27       308    Diesel Room - G01              Detection   D-405    Photoelectric  N N Y Y N A27       308    Diesel Room - G01               Feature     None         N/A A28            G02 - Diesel         4.2.4.2*
Generator Room A28       309    Diesel Room - G02             Suppression FP-3741     Wet Pipe     N N Y Y N A28       309    Diesel Room - G02              Detection   D-405    Photoelectric  N N Y Y N A28       309    Diesel Room - G02               Feature     None         N/A A29            Air Compressor       4.2.4.2*
Room A29       310    Air Compressor                Suppression   None         N/A Room A29       310    Air Compressor                 Detection   D-405    Ultraviolet/   N N Y N N Room                                                  Infrared A29       310    Air Compressor                  Feature     None         N/A Room Revision 0                                                                                                                 Page 98

NextEra PBNP                                                                            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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description   Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details i      A30            Cable Spreading     4.2.4.2*
Room A30       318    Cable Spreading              Suppression  C927, D-     Halon       N N Y Y N Room                                        406 A30       318    Cable Spreading               Detection    D-406      Thermal      N N Y Y N Room A30       318    Cable Spreading               Detection    D-406    Photoelectric  N N Y Y N Room A30       318    Cable Spreading                Feature      None        N/A Room Page 99 Revision 00                                                                                                                 Page 99

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S    L E R D        Feature and System Basis                                                                     Details A31            Control Room        4.2.4.2*
A31       326    Control Room                 Suppression    None        N/A A31       326    Control Room                  Detection    D-408    Photoelectric  N N     Y N N A31       326    Control Room                   Feature      None        N/A A31       328    Snack Bar in                 Suppression    None        N/A Control Room A31       328    Snack Bar in                  Detection     None        N/A Control Room A31       328    Snack Bar in                   Feature      None        N/A Control Room A31       329    Toilet in Control            Suppression    None        N/A Room A31       329    Toilet in Control             Detection     None        N/A Room A31       329    Toilet in Control              Feature      None        N/A Room A31       330    HVAC Passage in              Suppression    None        N/A Control Room A31       330    HVAC Passage in               Detection     None        N/A Control Room A31       330    HVAC Passage in                Feature      None        N/A Control Room A31       331    Cable Passage in             Suppression    None        N/A Control Room A31       331    Cable Passage in              Detection     None        N/A Control Room A31       331    Cable Passage in               Feature      None        N/A Control Room Revision 0                                                                                                                Page 100

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone      Description  Regulatory   Category       ID        Type        S    L E R D        Feature and System Basis                                                                     Details A32             Computer Room      4.2.4.2*
A32       333     North Office in              Suppression    None        N/A Computer Room A32       333     North Office in               Detection     None        N/A Computer Room A32       333     North Office in                Feature      None        N/A Computer Room A32       334     South Office in              Suppression    None        N/A Computer Room A32       334     South Office in               Detection     None        N/A Computer Room A32       334     South Office in                Feature      None        N/A Computer Room A32       335     Computer Room                Suppression    None        N/A A32       335     Computer Room                 Detection    D-407    Photoelectric  N    N N Y    N A32       335     Computer Room                  Feature      None        N/A A32       336     Instrument Rack              Suppression    None        N/A Room A32       336     Instrument Rack               Detection    D-407    Photoelectric  N    N N Y N Room A32       336     Instrument Rack                Feature      None        N/A Room A33             Control Bldg.       4.2.4.2*
HVAC Equip.
Room A33       337     HVAC   Equipment             Suppression   FP-29    Water Spray    N N Y N N Room A33       337     HVAC   Equipment              Detection    D-407      Thermal      N N Y N N Room A33       337     HVAC   Equipment              Detection    D-407    Photoelectric  N N Y N N Room A33        337    HVAC   Equipment               Feature      None        N/A Room Page 101 Revision 00                                                                                                                Page 101

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S   L E R     D    Feature and System Basis                                                                     Details A34            Technical Support   4.2.4.2*
Center A34       450    Technical Support            Suppression   FP-271     Wet Pipe     N N    N N N Center A34       450    Technical Support            Suppression   FP-272  Manual Spray    N N    N N N Center A34       450    Technical Support             Detection    D-413    Photoelectric  N N    N N N Center A34       450    Technical Support              Feature       N/A        N/A Center A35            Maintenance         4.2.4.2*
Building A35       430    Maintenance                  Suppression     N/A        N/A Building A35       430    Maintenance                   Detection     None        N/A Building A35       430    Maintenance                    Feature       N/A        N/A Building Page 102 Revision 0 Revision 0                                                                                                                Page 102

NextEra PBNP                                                                          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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A36            Unit 1               4.2.4.2*
Containment Area A36       501    Unit 1 Reactor                Suppression   None         N/A Vessel A36       501    Unit 1 Reactor                 Detection    None         N/A Vessel A36       501    Unit 1 Reactor                  Feature     None         N/A Vessel A36       505    Containment - Unit            Suppression   None         N/A 1 - 8 ft.
A36       505    Containment - Unit             Detection  FACP-7    Photoelectric  N N N Y N 1 - 8 ft.
A36       505    Containment - Unit              Feature     None   Radiant Energy  N N N N N 1 - 8 ft.                                              Shield A36       511    Containment - Unit            Suppression   None         N/A 1 -21 ft.
A36       511    Containment - Unit             Detection  FACP-7    Photoelectric  N N N Y N 1 -21 ft.
A36       511    Containment - Unit              Feature     None   Radiant Energy  N N N N N 1 - 21 ft.                                             Shield A36       516    Containment - Unit            Suppression   None        N/A 1 - 46 ft.
A36       516    Containment- Unit              Detection  FACP-7    Photoelectric  N N N Y N 1 - 46 ft.
A36       516    Containment - Unit              Feature     None        N/A 1 - 46 ft.
A36       520    Containment - Unit            Suppression   None        N/A 1 - 66 ft.
A36       520    Containment - Unit             Detection    None        N/A 1 - 66 ft.
A36       520    Containment - Unit              Feature     None        N/A 1 - 66 ft.
Revision 0                                                                                                                Page 103

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone      Description   Regulatory  Category       ID        Type        S    L E R D        Feature and System Basis                                                                     Details A37             Unit I Farade       4.2.4.2*
Stairway/Elevator Area A37        526    Unit I Fagade                Suppression    None        N/A Stairway 1 A37        526    Unit 1 Fagade                 Detection     None        N/A Stairway 1 A37        526    Unit 1 Fagade                  Feature      None        N/A Stairway 1 A37       526A    Unit 1 Fagade                Suppression    None        N/A Elevator A37       526A    Unit 1 Fagade                 Detection     None        N/A Elevator A37       526A    Unit 1 Fagade                  Feature      None        N/A Elevator Page 104 Revision 00                                                                                                                Page 104

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description    Regulatory  Category       ID        Type        S   L E R D          Feature and System Basis                                                                      Details A38            Circulating Water   4.2.4.2*
Service Water Pumphouse A38       550    Manhole No.1                 Suppression    None        N/A A38       550    Manhole No. 1                 Detection     None        N/A A38       550    Manhole No.1                   Feature      None        N/A A38       551    Manhole No.2                 Suppression    None        N/A A38       551    Manhole No.2                  Detection     None        N/A A38       551    Manhole No.2                   Feature      None        N/A A38       552    Service Water                Suppression  FP-269,    Wet Pipe      Y N N Y       N Credited for NFPA 805 Section Pump Room                                  FP-270                                   3.9.4 Compliance A38       552    Service Water                 Detection    D-409    Photoelectric  Y N N Y       N Pump Room A38       552    Service Water                  Feature      None        N/A Pump Room A38       553    Circulating Water            Suppression    None        N/A Pump Room A38       553    Circulating Water             Detection    D-409    Photoelectric  N N N Y       N Pump Room A38       553    Circulating Water              Feature      None        N/A Pump Room A38       554    Circulating Water            Suppression    None        N/A Pump House Corridor A38       554    Circulating Water             Detection     None        N/A Pump House Corridor A38       554    Circulating Water              Feature      None        N/A Pump House Corridor A38       555    Circulating Water            Suppression    None        N/A Pump House Valve Gallery Revision 0                                                                                                                 Page 105

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone     Description   Regulatory  Category       ID        Type        S   L E R     D     Feature and System Basis                                                                     Details A38       555    Circulating Water             Detection    None         N/A Pump House Valve Gallery A38       555    Circulating Water              Feature     None         N/A Pump House Valve Gallery A39            South Gatehouse     4.2.4.2*
A39       558    South Gatehouse              Suppression   None         N/A A39       558    South Gatehouse               Detection    None         N/A A39       558    South Gatehouse                Feature     None         N/A Page 106 Revision 0 0                                                                                                                Page 106

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description    Regulatory  Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A40            Fuel Oil            4.2.4.2*
Pumphouse A40      578    Fuel Oil                     Suppression   FP-204    Wet Pipe      N N N N N Pumphouse Vestibule A40      578    Fuel Oil                      Detection     D-410   Photoelectric  N N N N N Pumphouse Vestibule A40      578    Fuel Oil                       Feature      None        N/A Pumphouse Vestibule A40      579    Fuel Oil Transfer            Suppression   FP-204     Wet Pipe     N N N N N Pump Room A40      579    Fuel Oil Transfer             Detection     D-410   Photoelectric  N N N N N Pump Room A40      579    Fuel Oil Transfer              Feature      None        N/A Pump Room A40      580    Fuel Oil                     Suppression    None        N/A Pumphouse Electrical Equipment Closet A40      580    Fuel Oil                      Detection     None        N/A Pumphouse Electrical Equipment Closet A40      580    Fuel Oil                       Feature      None        N/A Pumphouse Electrical Equipment Closet Page 107 Revision 00                                                                                                               Page 107

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone    Description      Regulatory  Category     ID        Type        S    L E R D        Feature and System Basis                                                                   Details A41            Flammable             4.2.4.2*
Liquids Storage Room A41       581    Flammable Liquids              Suppression FP-120     Wet Pipe     N   N   Y   N N Storage Room A41       581    Flammable Liquids               Detection   None        N/A Storage Room A41       581    Flammable Liquids                Feature    None        N/A Storage Room A42            Lubricating Oil       4.2.4.2*
Storage Room A42       582    Lubricating Oil                Suppression FP-120     Wet Pipe     N   N   Y   N N Storage Room A42       582    Lubricating Oil                 Detection   None        N/A Storage Room A42       582    Lubricating Oil                  Feature    None        N/A Storage Room A43            Blowdown              4.2.4.2*
Evaporator Building A43       591    Blowdown                       Suppression  None        N/A Evaporator Building A43       591    Blowdown                        Detection   None        N/A Evaporator Building A43       591    Blowdown                         Feature    None        N/A Evaporator Building Page 108 Revision 00                                                                                                               Page 108

NextEra PBNP                                                                           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                                            Required?     Required Fire Protection Fire Area Fire Zone      Description  Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A44             Gas Stripper        4.2.4.2*
Building A44        592    Gas Stripper                 Suppression   None         N/A Building A44        592    Gas Stripper                  Detection    None         N/A Building A44        592    Gas Stripper                   Feature     None         N/A Building A45             Unit 2 Fagade       4.2.4.2*
Stairway Area A45        597    Unit 2 Facade                Suppression   None         N/A Stairway 57 A45        597    Unit 2 Fagade                 Detection    None         N/A Stairway 57 A45        597    Unit 2 Fagade                  Feature     None         N/A Stairway 57 Revision 0                                                                                                                 Page 109

NextEra PBNP                                                                          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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description    Regulatory  Category      ID         Type       S   L E R     D    Feature and System Basis                                                                    Details A46            Unit 2               4.2.4.2*
Containment Area A46       606    Unit 2 Reactor                Suppression  None          N/A Vessel A46       606    Unit 2 Reactor                 Detection   None          N/A Vessel A46       606    Unit 2 Reactor                  Feature    None          N/A Vessel A46       608    Containment - Unit            Suppression  None          N/A 2 - 8 ft.
A46       608    Containment - Unit             Detection  FACP-8    Photoelectric  N N    N Y    N 2 - 8 ft.
A46       608    Containment - Unit              Feature    None          N/A 2 - 8 ft.
A46       611    Containment - Unit            Suppression  None          N/A 2-21 ft.
A46       611    Containment - Unit             Detection  FACP-8    Photoelectric  N N    N Y    N 2-21 ft.
A46       611    Containment - Unit              Feature    None          N/A 2-21 ft.
A46       615    Containment - Unit            Suppression  None          N/A 2-46 ft.
A46       615    Containment - Unit             Detection  FACP-8    Photoelectric  N N N Y       N 2-46 ft.
A46       615    Containment- Unit               Feature    None    Radiant Energy  N N N N       N 2 - 46 ft.                                             Shield A46       618    Containment - Unit            Suppression  None          N/A 2-66 ft.
A46       618    Containment - Unit             Detection   None          N/A 2- 66 ft.
A46       618    Containment - Unit              Feature    None          N/A 2- 66 ft.
Page 110 Revision 0 0                                                                                                                Page 110

NextEra PBNP                                                                            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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description     Regulatory  Category      ID         Type        S   L E R D         Feature and System Basis                                                                    Details A47            Extension Building   4.2.4.2*
A47       620    Extension Building            Suppression   None         N/A A47       620    Extension Building             Detection   D-415   Photoelectric/Th N   N N N N ermal A47       620    Extension Building              Feature     None         N/A A48            Warehouse #1         4.2.4.2*
A48       667    Warehouse #1                  Suppression   FP-76     Wet Pipe      N   N N N N A48       667    Warehouse #1                   Detection    None         N/A A48       667    Warehouse #1                    Feature     None         N/A A48       668    Garage                        Suppression   None         N/A A48       668    Garage                         Detection    None         N/A A48       668    Garage                          Feature     None         N/A A49            Well Water           4.2.4.2*
Pumphouse A49       669    Well Water                    Suppression   None         N/A Pumphouse A49       669    Well Water                     Detection    None         N/A Pumphouse A49       669    Well Water                      Feature     None         N/A Pumphouse A50            Warehouse #2         4.2.4.2*
A50       691    Warehouse #2                  Suppression  FP-190     Dry Pipe      N   N N N N A50       691    Warehouse #2                   Detection    None         N/A A50       691    Warehouse #2                    Feature     None         N/A Page 111 Revision 00                                                                                                               Page Ill

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description  Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A51            Warehouse #3        4.2.4.2*
A51       692    Warehouse #3                 Suppression   FP-283     Wet Pipe     N N N N       N A51       692    Warehouse #3                  Detection     None        N/A A51       692    Warehouse #3                   Feature      None        N/A A52            North Service       4.2.4.2*
Building A52       700    North Service                Suppression   FP-92      Wet Pipe     N N N N       N Building A52       700    North Service                 Detection    D-414    Photoelectric  N N N N       N Building A52       700    North Service                 Detection    D-414    Photoelectric  N N N N       N Building A52       700    North Service                 Detection    D-414    Photoelectric  N N N N       N Building A52       700    North Service                  Feature      None        N/A Building A53            Sewage              4.2.4.2*
Treatment Plant A53       575    Sewage Treatment             Suppression    None        N/A Plant A53       575    Sewage Treatment              Detection     None        N/A Plant A53       575    Sewage Treatment               Feature      None        N/A Plant Page 112 Revision 00                                                                                                               Page 112

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description   Regulatory   Category       ID        Type        S   L E R     D     Feature and System Basis                                                                     Details A54            D305 - Swing        4.2.4.2*
Battery D301 Charger Rooms A54       321    Swing Battery                Suppression   None         N/A Room - D305 A54       321    Swing Battery                 Detection    D-406      Thermal      N N N N       N Room - D305 A54       321    Swing Battery                  Feature     None         N/A Room - D305 A54       323    Charger Room -               Suppression   None         N/A D301 A54       323    Charger Room -                Detection    D-406      Thermal      N N N N       N D301 A54       323    Charger Room -                 Feature     None         N/A D301 A58            T-175A Fuel Tank    4.2.4.2*
Room A58       761    T-175A Fuel Tank             Suppression   None         N/A Room A58       761    T-175A Fuel Tank              Detection    None         N/A Room A58       761    T-175A Fuel Tank               Feature     None         N/A Room A59            T-175B Fuel Tank    4.2.4.2*
Room A59       762    T-175B Fuel Tank             Suppression   None         N/A Room A59       762    T-175B Fuel Tank              Detection    None         N/A Room A59       762    T-175B Fuel Tank               Feature     None         N/A Room Revision 0                                                                                                                Page 113

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone     Description  Regulatory   Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A61            P-206A P207A       4.2.4.2*
Fuel Pump Room A61       771    P-206A &P207A                Suppression   FP-461    Wet Pipe      N N Y N N Fuel Oil Pump Room A61       771    P-206A &P207A                 Detection     D418    Photoelectric  N N Y N N Fuel Oil Pump Room A61       771    P-206A &P207A                  Feature      None        N/A Fuel Oil Pump Room Page 114 Revision 0 0                                                                                                                Page 114

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description    Regulatory  Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A68            Train B East Duct   4.2.4.2*
Bank Manholes A68       791    Manhole Z-067D               Suppression   None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       791    Manhole Z-067D                Detection    None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       791    Manhole Z-067D                 Feature     None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       793    Manhole Z-067C               Suppression   None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       793    Manhole Z-067C                Detection    None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       793    Manhole Z-067C                 Feature     None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       795    Manhole Z-067B               Suppression   None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       795    Manhole Z-067B                Detection    None         N/A East Diesel Generator Duct Bank (E1937.83)
Page 115 Revision 00                                                                                                               Page 115

NextEra PBNP                                                                          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                                          Required?     Required Fire Protection Fire Area Fire Zone    Description      Regulatory  Category     ID        Type        S   L E R D        Feature and System Basis                                                                   Details A68      795    Manhole Z-067B                   Feature   None         N/A East Diesel Generator Duct Bank (E1937.83)
A68      799    Manhole Z-067A                 Suppression None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       799    Manhole Z-067A                  Detection  None         N/A East Diesel Generator Duct Bank (E1937.83)
A68       799    Manhole Z-067A                   Feature   None         N/A East Diesel Generator Duct Bank (E1937.83)
A69            Manhole Z-068         4.2.4.2*
West of DGB A69       790    Manhole Z-068                  Suppression None         N/A Outside DG Building A69       790    Manhole Z-068                   Detection  None         N/A Outside DG Building A69       790    Manhole Z-068                    Feature   None         N/A Outside DG Building Page 116 Revision 0 Revision 0                                                                                                                Page 116

NextEra PBNP                                                                          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                                            Required?     Required Fire Protection Fire Area Fire Zone    Description    Regulatory  Category       ID        Type        S   L E R D        Feature and System Basis                                                                     Details A70            Train A West Duct   4.2.4.2*
Bank Manholes A70       792    Manhole Z-066D               Suppression   None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       792    Manhole Z-066D                Detection    None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       792    Manhole Z-066D                 Feature     None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       794    Manhole Z-066C               Suppression   None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       794    Manhole Z-066C                Detection    None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       794    Manhole Z-066C                 Feature     None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       796    Manhole Z-066B               Suppression   None         N/A West Diesel Generator Duct Bank (E1931.33)
A70       796    Manhole Z-066B                Detection    None         N/A West Diesel Generator Duct Bank (E1931.33)
Page 117 Revision 00                                                                                                               Page 117

NextEra PBNP                                                                           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                                             Required?     Required Fire Protection Fire Area Fire Zone    Description   Regulatory   Category       ID        Type        S   L E R D         Feature and System Basis                                                                     Details A70       796    Manhole Z-066B                 Feature      None        N/A West Diesel Generator Duct Bank (E1931.33)
A70       800    Manhole Z-066A               Suppression    None        N/A West Diesel Generator Duct Bank (E1931.33)
A70       800    Manhole Z-066A                Detection     None        N/A West Diesel Generator Duct Bank (E1931.33)
A70       800    Manhole Z-066A                 Feature      None        N/A West Diesel Generator Duct Bank (E1931.33)
Page 118 Revision 00                                                                                                               Page 118

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone      Description    Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A71             Combined DG          4.2.4.2*
Building, Train B Areas A71        763    P-213A Sump                   Suppression   None        N/A Pump Room A71        763    P-213A Sump                    Detection    None        N/A Pump Room A71        763    P-213A Sump                     Feature     None        N/A Pump Room A71        764    P-213B Sump                   Suppression   None        N/A Pump Room A71        764    P-213B Sump                    Detection    None        N/A Pump Room A71        764    P-213B Sump                     Feature     None        N/A Pump Room A71        770    Diesel Room - G-03            Suppression FP-469      Wet Pipe     N N    Y N N A71        770    Diesel Room - G-03             Detection   D-418      Thermal      N N    Y N N A71        770    Diesel Room - G-03              Feature     None        N/A A71        772    T-176A Day Tank               Suppression FP-469      Wet Pipe     N N    N Y N Room A71        772    T-176A Day Tank                Detection   D-418    Photoelectric  N N    N N N Room A71        772    T-176A Day Tank                 Feature     None        N/A Room A71        773    G-03 Switchgear               Suppression   None        N/A Room A71        773    G-03 Switchgear                Detection   D-418    Photoelectric  N N    N Y N Room A71        773    G-03 Switchgear                 Feature     None        N/A Room A71       773A    G-03 Switchgear               Suppression   None        N/A Room Exhaust Plenum Page 119 Revision 00                                                                                                                Page 119

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone     Description     Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A71       773A    G-03 Switchgear                Detection    None        N/A Room Exhaust Plenum A71       773A    G-03 Switchgear                 Feature     None        N/A Room Exhaust Plenum A71        774    Mechanical                    Suppression  FP-478     Wet Pipe     N N N N N Equipment Room A71        774    Mechanical                     Detection    D-418   Photoelectric  N N N N N Equipment Room A71        774    Mechanical                      Feature     None        N/A Equipment Room A71        775    Diesel Room - G-04            Suppression  FP-460     Wet Pipe     N N N Y N A71        775    Diesel Room - G-04             Detection    D-418     Thermal      N N Y N N A71        775    Diesel Room - G-04              Feature     None        N/A A71        776    P-206B &P-207B                Suppression  FP-460     Wet Pipe     N N N N N Fuel Oil Pump Room A71        776    P-206B &P-207B                 Detection    D-418   Photoelectric  N N N N N Fuel Oil Pump Room A71        776    P-206B &P-207B                  Feature     None        N/A Fuel Oil Pump Room A71        777    G-04 Switchgear               Suppression   None        N/A Room A71        777    G-04 Switchgear                Detection    D-418   Photoelectric  N N N Y N Room A71        777    G-04 Switchgear                 Feature     None        N/A Room A71       777A    G-04 Switchgear               Suppression   None        N/A Room Exhaust Plenum Page 120 Revision 0 0                                                                                                                 Page 120

NextEra PBNP                                                                           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                                           Required?     Required Fire Protection Fire Area Fire Zone      Description    Regulatory  Category      ID        Type        S   L E R D        Feature and System Basis                                                                    Details A71       777A    G-04 Switchgear                Detection    None        N/A Room Exhaust Plenum A71       777A    G-04 Switchgear                 Feature     None        N/A Room Exhaust Plenum A71        778    NW                            Suppression   None        N/A Stairwell/Enclosed Stairway A71        778    NW                             Detection    None        N/A Stairwell/Enclosed Stairway A71        778    NW                              Feature     None        N/A Stairwell/Enclosed Stairway A71        780    G-03 Radiator                 Suppression   None        N/A Room A71        780    G-03 Radiator                  Detection   D-418    Photoelectric  N N N N N Room A71        780    G-03 Radiator                   Feature     None        N/A Room A71        781    G-03 Diesel                   Suppression   None        N/A Silencer Shaft A71        781    G-03 Diesel                    Detection    None        N/A Silencer Shaft A71        781    G-03 Diesel                     Feature     None        N/A Silencer Shaft A71        782    G-04 Diesel                   Suppression   None        N/A Silencer Shaft A71        782    G-04 Diesel                    Detection    None        N/A Silencer Shaft A71        782    G-04 Diesel                     Feature     None        N/A Silencer Shaft A71        783    G-04 Radiator                 Suppression   None        N/A Room Revision 0                                                                                                                 Page 121

NextEra PBNP                                                                                             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                                                         Required?     Required Fire Protection Fire Area Fire Zone     Description        Regulatory          Category            ID         Type       S   L E R D          Feature and System Basis                                                                                 Details A71       783    G-04 Radiator                              Detection          D-418    Photoelectric N N N N N Room A71       783    G-04 Radiator                                Feature          None         N/A Room A71       784    G-04 Exhaust Fan                          Suppression         None         N/A Room A71       784    G-04 Exhaust Fan                           Detection          None         N/A Room A71       784    G-04 Exhaust Fan                             Feature          None         N/A Room A71       785    G-03 Exhaust Fan                          Suppression         None         N/A Room A71       785    G-03 Exhaust Fan                           Detection          None         N/A Room A71       785    G-03 Exhaust Fan                             Feature          None         N/A Room A71       786    Enclosed Walkway                          Suppression         None         N/A A71       786    Enclosed Walkway                           Detection          None         N/A A71       786    Enclosed Walkway                             Feature          None         N/A A71       787    Roof Between Fan                          Suppression         None         N/A Rooms A71       787    Roof Between Fan                           Detection          None         N/A Rooms A71       787    Roof Between Fan                             Feature          None         N/A Rooms Legend:                                                                      Required?
S  - Required for Chapter 4 Separation Criteria L  - Required for NRC-Approved Licensing Action E  - Required for Existing Engineering Equivalency Evaluation R  - Required for Risk Significance D  - Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation
                    *Compliance includes reliance on simplifying deterministic assumptions Revision 0                                                                                                                                   Page 122

NextEra PB3NP                                                       5.0 Regulatory Evaluation

==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 fire protection requirements.
10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition (NFPA 805), 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 PBNP 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(0. 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 important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter I performance criteria through the methodology in Chapter4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirementto 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, andprocess 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 applicablerequirements of NFPA 805, Chapter3. Having identified the required fire protection systems and features, the licensee selects either a deterministic or performance-basedapproach to demonstrate that the performance criteriaare satisfied. This process satisfies the GDC 3 requirementto 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 fire protection 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 Revision 0                                                                          Page 123

NextEra PBNP                                                                           5.0 Regulatory Evaluation things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 805." Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the fire protection 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.
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, 10 CFR 50.48(a) and GDC 3 clarification (ML081400292). The following tables provide a cross reference of fire protection regulations associated with the post-transition PBNP fire protection program and applicable industry and PBNP 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 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 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 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 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 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 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 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                See RM-AA-100, Records Management Program.
superseded.
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NextEra PBNP                                                                           5.0 Reaulatorv Evaluation Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s)                          Applicability/Compliance Reference (4) Each applicant for a design approval, design                 Not applicable. PBNP 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.
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 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 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 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 Table B-3 significantly impair the safety capability of these structures, systems, and components Page 125 Revision 0                                                                                                  Page 125

NextEra PBNP                                                                           5.0 Regulatory Evaluation 10 CFR 50.48(c)
Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                                ApplicabilitylCompliance Reference (1) Approval of incorporationby reference. National Fire Protection Association      General Information. NFPA (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for        805 (2001 edition) is the Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805),       edition used.
which is referenced in this section, was approved for incorporation by reference by the Director of the Federal Register pursuant to 5 U.S.C. 552(a) and 1 CFR part 51.
(2) Exceptions, modifications, and supplementation of NFPA 805. As used in           General Information. NFPA this section, references to NFPA 805 are to the 2001 Edition, with the           805 (2001 edition) is the following exceptions, modifications, and supplementation:                        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 I of NFPA 805 are not part of the LAR.
(ii) Plant Damage/BusinessInterruption 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.
(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 Table B-I.
(vi) Water supply and distribution. The italicized exception to Section 3.6.4 is PBNP Complies by Previous not endorsed. Licensees who wish to use the exception to Section 3.6.4           NRC Approval. See NEI 04-must submit a request for a license amendment in accordance with                 02 Table B-1.
paragraph (c)(2)(vii) of this section.
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NextEra PBNP                                                                            5.0 Regulatory Evaluation Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                                Applicability/Compliance Reference (vii) Performance-based methods. Notwithstanding the prohibition in Section      The use of performance-3.1 against the use of performance-based methods, the fire protection            based methods for NFPA 805 program elements and minimum design requirements of Chapter 3 may be             Chapter 3 is requested. See subject to the performance-based methods permitted elsewhere in the              Attachment L.
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 if the 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 in the 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.
(4) Risk-informed or performance-based alternatives to compliance with NFPA           No risk-informed or 805. A licensee may submit a request to use risk-informed or performance-         performance-based based alternatives to compliance with NFPA 805. The request must be in           alternatives to compliance the form of an application for license amendment under &sect; 50.90 of this            with NFPA 805 (per 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. See Attachment P.
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).
Page 127 Revision 00                                                                                                  Page 127

NextEra PBNP                                                         5.0 Regulatory Evaluation 5.2     Regulatory Topics 5.2.1   License Condition Changes The current PBNP fire protection license condition 4.F is being replaced with the standard license condition based upon Regulatory Position 3.1 of RG 1.205, as shown in Attachment M.
5.2.2 Technical Specifications NextEra conducted a review of the Technical Specifications to determine which Technical Specifications are required to be revised, deleted, or superseded. NextEra determined that the changes to the Technical Specifications and applicable justification listed in Attachment N are adequate for the PBNP adoption of the new FP licensing basis.
5.2.3 Orders and Exemptions A review was conducted of the PBNP 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 .
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
     " 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. NextEra has evaluated the proposed amendment and determined that it involves no significant hazards consideration.
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NextEra PBNP                                                        5.0 Requlatorv Evaluation 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 PBNP UFSAR will be revised. The format and content will be consistent with NEI 04-02 FAQ 12-0062.
5.5     Transition Implementation Schedule The following schedule for transitioning PBNP to the new FP licensing basis requires NRC approval of the LAR in accordance with the following schedule:
Implementation of new NFPA 805 FP program to include procedure changes, process updates, and training to affected plant personnel. This will occur 180 days after NRC approval unless that falls within a scheduled outage window.
Then this will occur 60 days after startup from that scheduled outage. See Attachment S Table S-3. Implementation Item IMP-142 is associated with modifications in Table S-2 and will be completed in accordance with the modification process.
     " Modifications will be completed by the startup of the second refueling outage (for each unit) after the issuance of the SE. Appropriate compensatory measures will be maintained until modifications are complete. See Attachment S Table S-2.
Page 129 Revision 00                                                                         Page 129

NextEra PBNP                                                                6.0 References

==6.0     REFERENCES==

The following references were used in the development of the TR. Additional references are in the NEI 04-02 Tables in the various Attachments.
6.1. NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition 6.2. NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009 6.3. NEI 00-02, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009 6.4. NEI 04-02, Guidance for Implementing A Risk-Informed, Performance-Based Fire protection Program Under 10 CFR 50.48(c), Revision 2 6.5. Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 1 - November 2002.
6.6. Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 2 - March 2009 6.7. Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, Revision 1, December 2009 6.8. NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, April 2005 6.9. Letter from NRC to NEI, "Process for Frequently Asked Questions for Title 10 of The Code of Federal Regulations, Part 50.48(c) Transitions," July 12, 2006 6.10. NRC Regulatory Issue Summary 2007-19, "Communicating Clarifications of Staff Positions in RG 1.205 Concerning Issues Identified During Pilot Application of NFPA Standard 805" (ML071590227), August 20, 2007 6.11. Federal Register Notice 69 FR 33536, June 16, 2004 6.12. Federal Register Notice 71 FR 19905, April 18, 2006 6.13. Federal Register Notice 73 FR 52705, September 10, 2008 6.14. NRC 10 CFR 50.92, Issuance of Amendment 6.15. NRC 10 CFR 51.22(b) and (c), Criterion for Categorical Exclusion 6.16. EPRI Technical Report (TR) 1006756, Fire Protection Equipment Surveillance Optimization and Maintenance Guide 6.17. ASME/ANS RA-Sa-2009, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications Revision 0                                                                        Page 130

NextEra PBNP                                                                6.0 References 6.18. Letter from Wisconsin Electric to NRC, "Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Fire Protection Provisions,"(ML1219A295),
dated June 20, 1977 6.19. NRC Safety Evaluation, NUREG-75/087 Section 9.5.1 and Appendix A to BTP APCSB 9.5-1 (Appendix A Fire Protection SER) for Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, August 2, 1979 6.20. NRC Safety Evaluation, Supplement to 8/2/79 Appendix A Fire Protection SER for Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, October 21, 1980 6.21. NRC Safety Evaluation, Supplement to 8/2/79 Appendix A Fire Protection SER for Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, January 22, 1981 6.22. NRC Safety Evaluation, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, May 4, 1981 6.23. NRC Safety Evaluation, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, July 27, 1988 6.24. NRC Exemption Approval/Safety Evaluation, R.A. Clark (NRC) to C.W. Fay (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Section Ill.G, Point Beach Nuclear Plant Unit Nos.
1 and 2, Docket Nos. 50-266 and 50-301, April 28, 1983 6.25. NRC Exemption Approval/Safety Evaluation [page 1], E.J. Butcher (NRC) to C.W. Fay (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Section Ill.G, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, July 3, 1985 6.26. NRC Exemption Approval, [page 1], T.M. Novak (NRC) to C.W. Fay (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Section Ill.G, Point Beach Nuclear Plant Unit Nos.
1 and 2, Docket Nos. 50-266 and 50-301, dated December 31, 1986 6.27. NRC Exemption Approval/Safety Evaluation Related to Exemptions From Appendix R to 10 CFR Part 50, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, December 31, 1986 6.28.      NRC Exemption Approval, D.H. Wagner (NRC) to C.W. Fay (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Section Ill.G, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, May 23, 1988 6.29.      NRC Exemption Approval/Safety Evaluation [page 1] Related to Exemptions From Appendix R to 10 CFR Part 50, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, May 23, 1988 Page 131 Revision 00                                                                       Page 131

NextEra PBNP                                                                  6.0 References 6.30. NRC Exemption Approval [page 1], A.G. Hansen (NRC) to R.E. Link (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, July 18, 1995 6.31. NRC Exemption Approval [page 2-5 of attachment], L.L. Gundrum (NRC) to M.B. Sellman (Wisconsin Electric), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, May 7, 1998 6.32. NRC Exemption Approval [page 2-5 of attachment], H.K. Chernoff (NRC) to D. Koehl (NMC), Approval of Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Point Beach Nuclear Plant Unit Nos. 1 and 2, Docket Nos. 50-266 and 50-301, June 2, 2005 6.33. Letter from NMC (D. Malone) to NRC (Document Control Desk), "Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (L-HU-05-023)
(ML053460342), dated November 30, 2005 6.34. Letter from NMC (D. Malone) to NRC (Document Control Desk), "Revision of and Supplement to Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (L-HU-06-012) (ML060730265), dated March 14, 2006 6.35. Letter from NRC (C. Haney) to NMC (M. Reddermann), "Point Beach Nuclear Plant, Units 1 & 2 - Response to Letter of Intent to Transition to National Fire Protection Association Standard NFPA 805" (TAC No. MC9291 and MC9292)
(ML061500035), dated September 7, 2006 6.36. Letter from FPL Energy Point Beach LLC to NRC, "Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 Request for Extension of Enforcement Discretion and Revised Submittal Schedule for 10 CFR 50.48(c)
License Amendment Request," (L-2008-179) (ML082600482), dated September 11, 2008 6.37. Letter from NRC to FPL Energy Point Beach LLC, "Point Beach Nuclear Plant, Units 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 Protection Standard NFPA 805" (ML083110860), dated November 20, 2008 6.38. NRC Letter "Oconee Nuclear Station, Units 1, 2, and 3, Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)"
(ML103630612), dated December 29, 2010 6.39. NextEra Energy Letter to NRC, "Request for Extension of Enforcement Discretion and Commitment to Submittal Dates for 10 CFR 50.48(c) License Amendment Request" (L-2011-235) (ML111778A237), dated June 23, 2011 Revision 0                                                                          Page 132

NextEra PB3NP                                                                6.0 References 6.40. NRC Letter to NextEra Energy Point Beach, LLC, "Point Beach Nuclear Plant, Units 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.
ME6646 and ME6647) (ML112000214), dated July 29, 2011 6.41. PBNP Unit 1 Renewed Facility Operating License incorporating Technical Specifications through Amendment 248 6.42. PBNP Unit 2 Renewed Facility Operating License incorporating Technical Specifications through Amendment 252 6.43. Report R2014-001-001, NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review, Revision 3 6.44. Report R1918-0041-001, Nuclear Safety Performance Analysis Methodology Review, Revision 1 6.45. Report R2014-003-001, Radioactive Release Review, Revision 0 6.46. Report R2014-004-002, Engineering Evaluation Review, Revision 2 6.47. Report R2014-004-003, Licensing Action Review, Revision 0 6.48. Report R2092-1500-001, Non-Power Operational Modes Analysis, Revision 2 6.49. Report R2168-1003B-0001, Verification and Validation of Fire Modeling Tools and Approaches for Use in NFPA 805 and Fire PRA Applications, Revision 2 6.50. Report P2091-2910-01, Post-Fire Human Reliability Analysis (HRA)
Notebook, Revision 1 6.51. Report P2091-2500-01, Fire Induced Risk Model (FIRM) Notebook, Revision 1
6.52. Report R2168-1012-01, Manual Actions Feasibility, Revision 1 6.53. Report R2167-1012-02, Recovery Actions Transition, Revision 0 6.54. Report P2091-2900-03, Uncertainty and Sensitivity Analysis (UNC) Notebook, Revision 1 6.55. Report R2167-1019-01, Nuclear Safety Capability Assessment, Revision 1 6.56. Procedure NP 10.3.6, Shutdown Safety Review and Safety Assessment 6.57. Form PBF-1562, PBNP Shutdown Safety Assessment and Fire Condition Checklist 6.58. Procedure AM 3-4 Implementation to the Maintenance Rule 6.59. Procedure DG-F01, Fire Protection Conformance Guidance, ER-AA-201-2001, System and Program Health Reporting 6.60. Procedure DG-F01, Fire Protection Conformance Guidance, ER-AA-201-2002, System Performance Monitoring 6.61. Procedure PI-AA-205, Condition Evaluation and Corrective Action Revision 0                                                                         Page 133

NextEra PBNP                                                               6.0 References 6.62. NP 1.9.14, Fire Protection Organization 6.63. RM-AA-100, Records Management Program 6.64. R2168-1002-AO1-B, Fire Risk Evaluation for Fire Area A01-B, Revision 0 6.65. R2168-1002-AO1-B/46, Fire Risk Evaluation for Fire Area A01-B1/46, Revision 0
6.66. R2168-1002-AO1-CN, Fire Risk Evaluation for Fire Area A01-CN, Revision 0 6.67. R2168-1002-AO1-CS, Fire Risk Evaluation for Fire Area A01-CS, Revision 0 6.68. R2168-1002-AO1-D, Fire Risk Evaluation for Fire Area A01-D, Revision 0 6.69. R2168-1002-AO1-E, Fire Risk Evaluation for Fire Area A01-E, Revision 0 6.70. R2168-1002-AO1-F, Fire Risk Evaluation for Fire Area A01-F, Revision 0 6.71. R2168-1002-AO1-G, Fire Risk Evaluation for Fire Area A01-G, Revision 0 6.72. R2168-1002-AO1-H, Fire Risk Evaluation for Fire Area A01-H, Revision 0 6.73. R2168-1002-A02, Fire Risk Evaluation for Fire Area A02, Revision 0 6.74. R2168-1002-A03, Fire Risk Evaluation for Fire Area A03, Revision 0 6.75. R2168-1002-A04, Fire Risk Evaluation for Fire Area A04, Revision 0 6.76. R2168-1002-A05, Fire Risk Evaluation for Fire Area A05, Revision 0 6.77. R2168-1002-A06, Fire Risk Evaluation for Fire Area A06, Revision 0 6.78. R2168-1002-A07, Fire Risk Evaluation for Fire Area A07, Revision 0 6.79. R2168-1002-A08, Fire Risk Evaluation for Fire Area A08, Revision 0 6.80. R2168-1002-A09, Fire Risk Evaluation for Fire Area A09, Revision 0 6.81. R2168-1002-Al 0, Fire Risk Evaluation for Fire Area A10, Revision 0 6.82. R2168-1002-Al1, Fire Risk Evaluation for Fire Area All, Revision 0 6.83. R2168-1002-A12, Fire Risk Evaluation for Fire Area A12, Revision 0 6.84. R2168-1002-Al 3, Fire Risk Evaluation for Fire Area A13, Revision 0 6.85. R2168-1002-A14, Fire Risk Evaluation for Fire Area A14, Revision 0 6.86. R2168-1002-Al 5, Fire Risk Evaluation for Fire Area Al5, Revision 0 6.87. R2168-1002-A16, Fire Risk Evaluation for Fire Area A16, Revision 0 6.88. R2168-1002-Al 7, Fire Risk Evaluation for Fire Area A17, Revision 0 6.89. R2168-1002-Al 8, Fire Risk Evaluation for Fire Area A18, Revision 0 6.90. R2168-1002-Al 9, Fire Risk Evaluation for Fire Area A19, Revision 0 6.91. R2168-1002-A20, Fire Risk Evaluation for Fire Area A20, Revision 0 6.92. R2168-1002-A21, Fire Risk Evaluation for Fire Area A21, Revision 0 6.93. R2168-1002-A22, Fire Risk Evaluation for Fire Area A22, Revision 0 Revision 0                                                                      Page 134

NextEra PBNP                                                               6.0 References NextEra PBNP                                                               6.0 References 6.94. R2168-1002-A23N, Fire Risk Evaluation for Fire Area A23N, Revision 0 6.95. R2168-1002-A23S, Fire Risk Evaluation for Fire Area A23S, Revision 0 6.96. R2168-1002-A24, Fire Risk Evaluation for Fire Area A24, Revision 0 6.97. R2168-1002-A25, Fire Risk Evaluation for Fire Area A25, Revision 0 6.98. R2168-1002-A26, Fire Risk Evaluation for Fire Area A26, Revision 0 6.99. R2168-1002-A27, Fire Risk Evaluation for Fire Area A27, Revision 0 6.100. R2168-1002-A28, Fire Risk Evaluation for Fire Area A28, Revision 0 6.101. R2168-1002-A29, Fire Risk Evaluation for Fire Area A29, Revision 0 6.102. R2168-1002-A30, Fire Risk Evaluation for Fire Area A30, Revision 0 6.103. R2168-1002-A31, Fire Risk Evaluation for Fire Area A31, Revision 0 6.104. R2168-1002-A32, Fire Risk Evaluation for Fire Area A32, Revision 0 6.105. R2168-1002-A33, Fire Risk Evaluation for Fire Area A33, Revision 0 6.106.      R2168-1002-A34, Fire Risk Evaluation for Fire Area A34, Revision 0 6.107.      R2168-1002-A35, Fire Risk Evaluation for Fire Area A35, Revision 0 6.108.      R2168-1002-A36, Fire Risk Evaluation for Fire Area A36, Revision 0 6.109.      R2168-1002-A37, Fire Risk Evaluation for Fire Area A37, Revision 0 6.110.      R2168-1002-A38, Fire Risk Evaluation for Fire Area A38, Revision 0 6.111.      R2168-1002-A39, Fire Risk Evaluation for Fire Area A39, Revision 0 6.112.      R2168-1002-A40, Fire Risk Evaluation for Fire Area A40, Revision 0 6.113.      R2168-1002-A41, Fire Risk Evaluation for Fire Area A41, Revision 0 6.114.      R2168-1002-A42, Fire Risk Evaluation for Fire Area A42, Revision 0 6.115.      R2168-1002-A43, Fire Risk Evaluation for Fire Area A43, Revision 0 6.116.      R2168-1002-A44, Fire Risk Evaluation for Fire Area A44, Revision 0 6.117.      R2168-1002-A45, Fire Risk Evaluation for Fire Area A45, Revision 0 6.118.      R2168-1002-A46, Fire Risk Evaluation for Fire Area A46, Revision 0 6.119.      R2168-1002-A47, Fire Risk Evaluation for Fire Area A47, Revision 0 6.120.      R2168-1002-A48, Fire Risk Evaluation for Fire Area A48, Revision 0 6.121.      R2168-1002-A49, Fire Risk Evaluation for Fire Area A49, Revision 0 6.122.      R2168-1002-A50, Fire Risk Evaluation for Fire Area A50, Revision 0 6.123.      R2168-1002-A51, Fire Risk Evaluation for Fire Area A51, Revision 0 6.124.      R2168-1002-A52, Fire Risk Evaluation for Fire Area A52, Revision 0 6.125.      R2168-1002-A53, Fire Risk Evaluation for Fire Area A53, Revision 0 6.126.      R2168-1002-A54, Fire Risk Evaluation for Fire Area A54, Revision 0 Page 135 Revision 00                                                                      Page 135

NextEra PBNP                                                              6.0 References NextEra PBNP                                                              6.0 References 6.127. R2168-1002-A58, Fire Risk Evaluation for Fire Area A58, Revision 0 6.128. R2168-1002-A59, Fire Risk Evaluation for Fire Area A59, Revision 0 6.129. R2168-1002-A61, Fire Risk Evaluation for Fire Area A61, Revision 0 6.130. R2168-1002-A68, Fire Risk Evaluation for Fire Area A68, Revision 0 6.131. R2168-1002-A69, Fire Risk Evaluation for Fire Area A69, Revision 0 6.132. R2168-1002-A70, Fire Risk Evaluation for Fire Area A70, Revision 0 6.133. R2168-1002-A71, Fire Risk Evaluation for Fire Area A71, Revision 0 Page 136 Revision 0 Revision 0                                                                      Page 136

NextEra PBNP             Attachments NextEra PBNP             Attachments ATTACHMENTS Page 137 Revision 0 Revision 0                   Page 137

NextEra PBNP      Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements A.       NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements 140 Pages Attached Page A-I Revision 00                                                                          Page A-1

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      Requirements/Guidance         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                              Technical Requirements fire protection program and specifies the minimum design requirements for fire protection systems and features. These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard.
Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.
3.2 Fire Protection Plan                               N/A                        N/A - General Statement; No N/A Technical Requirements Page A-2 Revision 00                                                                                                                      Page A-2

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement      Compliance Basis            Reference Document 3.2.1 Intent         A site-wide fire protection     Complies                  No Additional Clarification Procedure NP 1.9.14, "Fire plan shall be established.                                                            Protection Organization," Rev. 13 This plan shall document                                                              All 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.
3.2.2 Management     A policy document shall be      Complies                  No Additional Clarification Procedure NP 1.9.14, "Fire Policy Direction and prepared that defines                                                                 Protection Organization," Rev. 13 Responsibility       management authority and                                                              Section 2.0 responsibilities and establishes the general policy for the site fire protection program.
3.2.2.1              The policy document shall       Complies                  No Additional Clarification Procedure NP 1.9.14, "Fire designate the senior                                                                  Protection Organization," Rev. 13 management position with                                                              Section 2.1 immediate authority and responsibility for the fire protection program.
Page A-3 Revision 00                                                                                                                         Page A-3

NextEra PBNP                     Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      Requirements/Guidance             Compliance Statement              Compliance Basis                     Reference Document 3.2.2.2                  The policy document shall         Complies                          No Additional Clarification          Procedure NP 1.9.14, "Fire designate a position                                                                                     Protection Organization," Rev. 13 /
responsible for the daily                                                                                Section 2.8 administration and coordination of the fire protection program and its implementation.
3.2.2.3                  The policy document shall         Complies                          No Additional Clarification          Procedure NP 1.9.14, "Fire define the fire protection                                                                               Protection Organization," Rev. 13 /
interfaces with other                                                                                   All organizations and assign responsibilities for the coordination of activities. In addition, this policy document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.
3.2.2.4                  The policy document shall         Complies, with Required           See implementation item              NAMS Action Request 1839217, identify the appropriate AHJ      Action                            identified below.                    "NP 1.9.14 - Fire Protection for the various areas of the                                                                             Organization," dated January 14, fire protection program.                                                                                 2013 Procedure NP 1.9.14, "Fire Protection Organization," Rev. 13/
All IMPLEMENTATION ITEMS:
IMP-8:   Procedure NP 1.9.14, "Fire Protection Organization," is being revised to identify the authorities having jurisdiction for the various aspects of the fire protection program. This procedure change is being tracked by NAMS Action Request 1839217.
Page A-4 Revision 0 0                                                                                                                                                  Page A-4

NextEra PBNP                     Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      Requirements/Guidance              Compliance Statement           Compliance Basis                     Reference Document 3.2.3 Procedures         Procedures shall be                Complies                       No Additional Clarification          Fire Protection Evaluation Report established for                                                                                        (FPER), Rev. 13 / Section 4.2 implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:
3.2.3(1)                 Inspection, testing, and           Complies, with Required        See implementation item              Procedure OM 3.27, "Control of maintenance for fire               Action                         identified below.                    Fire Protection & Appendix R Safe protection systems and                                                                                 Shutdown Equipment," Rev. 47 /
features credited by the fire                                                                          Section 5.2 protection program NAMS Action Request 1789890, "NFPA 805 Performance Based Surveillance Frequencies Per EPRI," dated August 1,2012 IMPLEMENTATION ITEMS:
IMP-122:   Performance-based surveillance frequencies will be established as necessary as described in Electric Power Research Institute (EPRI) Technical Report TR-1006756, "Fire Protection Equipment Surveillance Optimization and Maintenance Guide." This is being tracked by NAMS Action Request 1789890. Where used, methodologies will be implemented in their entirety as they pertain to the fire protection systems or features being evaluated.
Submit for NRC Approval        NRC approval of the use of           None performance-based methods to establish the appropriate inspection, testing, and maintenance frequencies for required fire protection systems and features is being requested in Attachment L, Approval Request 1.
Page A-S Revision 0 0                                                                                                                                             Page A-5

NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis            Reference Document 3.2.3(2)            Compensatory actions          Complies                  No Additional Clarification Procedure OM 3.27, "Control of implemented when fire                                                               Fire Protection & Appendix R Safe protection systems and other                                                        Shutdown Equipment," Rev. 47 /
systems credited by the fire                                                        Section 4.2 protection program and this standard cannot perform their intended function and limits on impairment duration 3.2.3(3)            Reviews of fire protection    Complies                  No Additional Clarification Fire Protection Evaluation Report program - related                                                                   (FPER), Rev. 13 / Section 4.0 performance and trends ER-AA-201-2001, "System and Program Health Reporting," Rev. 6
                                                                                                        / All 3.2.3(4)            Reviews of physical plant     Complies                  No Additional Clarification Procedure DG-FO1, "Fire modifications and procedure                                                         Protection Conformance changes for impact on the                                                           Guidance," Rev. 2 / Section 5.2 fire protection program 3.2.3(5)            Long-term maintenance and     Complies                  No Additional Clarification Procedure DG-FO1, "Fire configuration of the fire                                                           Protection Conformance protection program                                                                  Guidance," Rev. 2 / All Fire Protection Evaluation Report (FPER), Rev. 13 / Section 2.5 Page A-6 Revision 0 0                                                                                                                        Page A-6

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement      Compliance Basis            Reference Document 3.2.3(6)            Emergency response            Complies                  No Additional Clarification Procedure FAP 3.0, "Fire Attack procedures for the plant                                                            Plans," Rev. 9 / All industrial fire brigade Procedure FEP 4.0, "Fire Emergency Plan," Rev. 5 1All Procedure NP 1.9.14, "Fire Protection Organization," Rev. 13 /
Sections 4.4, 4.5, and 4.6 3.3 Prevention      A fire prevention program     Complies                  No Additional Clarification Fire Protection Evaluation Report with the goal of preventing a                                                       (FPER), Rev. 13 / Section 2.2, fire from starting shall be                                                         Paragraph 5 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:
3.3(1)              Prevention of fires and fire  Complies                  No Additional Clarification Procedure NP 1.9.9, "Transient spread by controls on                                                               Combustible Control," Rev. 22 / All operational activities Procedure NP 1.9.13, "Ignition Control Procedure," Rev. 18 / All Page A-7 Revision 0 0                                                                                                                      Page A-7

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement        Compliance Basis            Reference Document 3.3(2)                Design controls that restrict   Complies with Clarification Creation of design          Procedure NP 9.8.1, "Specification the use of combustible                                      specifications accounts for Preparation, Review and Approval materials                                                   impacts on fire protection. Process," Rev. 8 / All The design control requirements listed in the remainder of this section shall be provided as described.
3.3.1 Fire Prevention The fire prevention program     Complies                    No Additional Clarification Fire Protection Evaluation Report for Operational       activities shall consist of the                                                         (FPER), Rev. 13 / Section 3.1.2 Activities            necessary elements to address the control of                                                                  Procedure NP 1.9.9, "Transient ignition sources and the use                                                            Combustible Control," Rev. 22 / All of transient combustible materials during all aspects                                                            Procedure NP 1.9.13, "Ignition of plant operations. The fire                                                           Control Procedure," Rev. 18/All prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.
Page A-8 Revision 00                                                                                                                             Page A-8

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance           Compliance Statement        Compliance Basis                 Reference Document 3.3.1.1 General Fire  General Fire Prevention         Complies with Clarification Plant procedures for general     Procedure NP 1.9.6, "Plant Prevention Activities Activities. The fire prevention                             fire prevention activities have  Cleanliness and Storage," Rev. 45 /
activities shall include but                                been developed and               All not be limited to the following                             implemented. The procedures program elements:                                           address, at a minimum, the       Procedure NP 1.9.9, "Transient fire protection program          Combustible Control," Rev. 22 / All elements identified in the sections below, but are not      Procedure NP 1.9.13, "Ignition limited to these elements.       Control Program," Rev. 18 / All Based on these procedures, the NFPA 805 code                Procedure NP 1.9.14, "Fire requirements in the following    Protection Organization," Rev. 13/
subsections are satisfied.       All 3.3.1.1(1)            Training on fire safety         Complies with Clarification In accordance with the           Fire Protection Evaluation Report information for all employees                               guidance in Section K.3 of       (FPER), Rev. 13 / Section 3.1.3.1 and contractors including, as                               NEI 04-02, the referenced a minimum, familiarization                                  documents comply with the        NANTeL NUC GET PAT 003 (FPL with plant fire prevention                                  interpreted meaning of           Plant Access Generic - FFD, BOP, procedures, fire reporting,                                 "familiarization with plant fire and Generic Training) / All and plant emergency alarms                                  prevention procedures, fire reporting, and plant             NANTeL NUC GET PAT 004 (FPL emergency alarms."               Plant Access Site Specific Training)
                                                                                                                   / All Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Rev. 2 /
Section K.3 Page A-9 Revision 00                                                                                                                                  Page A-9

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis             Reference Document 3.3.1.1(2)          Documented plant              Complies                   No Additional Clarification Fire Protection Evaluation Report inspections including                                                                (FPER), Rev. 13 / Sections 4.4, provisions for corrective                                                            4.4.f, 4.4.g, and 4.9.a actions for conditions where unanalyzed fire hazards are                                                          Procedure PC 71 PART 1, "Weekly identified                                                                           Safe Shutdown Area Tour," Rev.
18 / All Procedure PC 71 PART 2, "Non-Safe Shutdown Area Tour," Rev.
10/All 3.3.1.1(3)          Administrative controls       Complies                   No Additional Clarification Procedure DG-F01, "Fire addressing the review of                                                             Protection Conformance plant modifications and                                                              Guidance," Rev. 2 / Sections 1.2 maintenance to ensure that                                                           and 5.1.2 both fire hazards and the impact on plant fire                                                                 Procedure FP-E-MOD-02, protection systems and                                                               "Engineering Change Control,"
features are minimized                                                               Rev. 14 / All Procedure FP-E-MOD-05, "Modification Plant Impact," Rev. 9
                                                                                                         / All Procedure NP 1.9.6, "Plant Cleanliness and Storage," Rev. 45 /
All Procedure NP 1.9.14, "Fire Protection Organization," Rev. 13 /
Section 2.10 Page A-lU Revision 00                                                                                                                      Page A-1 0

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement        Compliance Basis               Reference Document 3.3.1.2 Control of    Procedures for the control of   Complies with Clarification Plant procedures for the       Procedure NP 1.9.6, "Plant Combustible Materials general housekeeping                                        control of general             Cleanliness and Storage," Rev. 45 /
practices and the control of                                housekeeping practices and     All transient combustibles shall                                the control of transient be developed and                                            combustibles have been         Procedure NP 1.9.9, "Transient implemented. These                                          developed and implemented. Combustible Control," Rev. 22 / All procedures shall include but                                The procedures address, at a not be limited to the following                             minimum, the fire protection program elements:                                           program elements identified in the sections below, but are not limited to these elements.
Based on these procedures, the NFPA 805 code requirements in the following subsections are satisfied.
3.3.1.2(1)            Wood used within the power      Complies                    No Additional Clarification    Procedure NP 1.9.9, "Transient block shall be listed                                                                      Combustible Control," Rev. 22 /
pressure-impregnated or                                                                    Section 4.1.12 coated with a listed fire-retardant application.
Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.
3.3.1.2(2)            Plastic sheeting materials      Complies                    No Additional Clarification    Procedure NP 1.9.9, "Transient used in the power block shall                                                              Combustible Control," Rev. 22 /
be fire-retardant types that                                                               Section 4.1.13 have passed NFPA 701, "Standard Methods of Fire                                                                  NFPA 701, "Standard Methods of Tests for Flame Propagation                                                                Fire Tests for Flame Propagation of of Textiles and Films," large-                                                             Textiles and Films," 1999 Edition /
scale tests, or equivalent.                                                                All Page A-lI Revision 0 0                                                                                                                             Page A-11I

NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance        Compliance Statement        Compliance Basis                 Reference Document 3.3.1.2(3)          Waste, debris, scrap,        Complies                    No Additional Clarification      Procedure NP 1.9.6, "Plant packing materials, or other                                                               Cleanliness and Storage," Rev. 45 /
combustibles shall be                                                                     Sections 4.2.2 and 4.2.9 removed from an area immediately following the                                                                 Procedure NP 1.9.9, "Transient completion of work or at the                                                              Combustible Control," Rev. 22 /
end of the shift, whichever                                                               Section 4.1.1 comes first.
3.3.1.2(4)          Combustible storage or       Complies                    No Additional Clarification      Procedure NP 1.9.6, "Plant staging areas shall be                                                                    Cleanliness and Storage," Rev. 45 /
designated, and limits shall                                                              Sections 4.4.2, 4.4.3, 4.5.1, and be established on the types                                                               4.5.2 and quantities of stored materials.
3.3.1.2(5)          Controls on use and storage  Complies with Clarification No NFPA standards, other         Nuclear Energy Institute (NEI) of flammable and                                         than those listed in the         04-02, "Guidance for Implementing combustible liquids shall be                             Reference Document column        a Risk-Informed, Performance-in accordance with NFPA 30,                              for this section, are applicable Based Fire Protection Program "Flammable and                                           to controls on use and storage   under 10 CFR 50.48(c)," Rev. 2/
Combustible Liquids Code,"                               of flammable and combustible     Section K.1 or other applicable NFPA                                 liquids at Point Beach Nuclear standards.                                               Plant, based on the guidance in Section K.1 of NEI 04-02.
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NextEra PBNP                      Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.        Requirements/Guidance              Compliance Statement          Compliance Basis                 Reference Document Complies, with Required       Controls on use and storage      R2092-001-002, "Fire Protection Action                        of flammable and combustible     Code Conformance Review," Rev.
liquids comply with NFPA         1 / Attachment A, Sections 30.1966 30-1966 and 1990 Editions as     and 30.1990 evaluated in R2092-001-002.
Implementation items are         NFPA 30, "Flammable and identified below.                Combustible Liquids Code," 1966 Edition / All NFPA 30, "Flammable and Combustible Liquids Code," 1990 Edition / All IMPLEMENTATION ITEMS:
IMP-23:     Plant documentation and procedures will be revised to include an inspection and maintenance program to ensure proper location, condition, and contents of flammable liquid storage cabinets. This work is being tracked by NAMS Action Request 1753398.
3.3.1.2(6)                 Controls on use and storage        Complies with Clarification   No NFPA standards, other         R2092-001-002, "Fire Protection of flammable gases shall be                                      than those listed in the         Code Conformance Review," Rev.
in accordance with                                               Reference Document column        1 / Attachment A, Section 567 applicable NFPA standards.                                       for this section, are applicable to controls on use and storage   NFPA 567, "Standard for Gaseous of flammable gases at Point      Hydrogen Systems at Consumer Beach Nuclear Plant, based       Sites," 1963 Edition / All on the guidance in Section K.1 of NEI 04-02.                Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Rev. 2/
Section K.1 3.3.1.3 Control of         Control of Ignition Sources.       N/A                           N/A - General Statement; No      N/A Ignition Sources                                                                            Technical Requirements Page A-13 Revision 0 0                                                                                                                                          Page A-1 3

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis            Reference Document 3.3.1.3.1           A hot work safety procedure   Complies                  No Additional Clarification R2092-001-002, "Fire Protection shall be developed,                                                                 Code Conformance Review," Rev.
implemented, and                                                                    1 / Attachment A, Sections 51B and periodically updated as                                                             241 necessary in accordance with NFPA 51B, "Standard                                                            NFPA 51B, "Standard for Fire for Fire Prevention During                                                          Prevention during Welding, Cutting, Welding, Cutting, and Other                                                         and other Hot Work," 1999 Edition /
Hot Work," and NFPA 241,                                                            All "Standard for Safeguarding Construction, Alteration, and                                                       NFPA 241, "Standard for Demolition Operations."                                                             Safeguarding Construction, Alteration, and Demolition Operations," 2000 Edition / All Procedure NP 1.9.13, "Ignition Control Procedure," Rev. 18 / All 3.3.1.3.2           Smoking and other possible    Complies                  No Additional Clarification Procedure AM 2-8, "Tobacco sources of ignition shall be                                                        Smoking Policy," Rev. 5 / All restricted to properly designated and supervised                                                           Procedure NP 1.9.13, "Ignition safe areas of the plant.                                                            Control Procedure," Rev. 18/All 3.3.1.3.3           Open flames or combustion-    Complies                  No Additional Clarification Procedure NP 1.9.13, "Ignition generated smoke shall not                                                           Control Procedure," Rev. 18 /
be permitted for leak or air                                                        Section 2.12 flow testing.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement      Compliance Basis            Reference Document 3.3.1.3.4           Plant administrative           Complies                  No Additional Clarification Procedure NP 1.9.13, "Ignition procedure shall control the                                                          Control Procedure," Rev. 18/
use of portable electrical                                                           Sections 2.7 and 2.9.3 heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.
3.3.2 Structural    Walls, floors, and             Complies                  No Additional Clarification Fire Protection Evaluation Report components required to                                                               (FPER), Rev. 13/Section 5.1.7 maintain structural integrity shall be of noncombustible                                                           NFPA 220, "Standard on Types of construction, as defined in                                                          Building Construction," 1999 NFPA 220, "Standard on                                                               Edition / All Types of Building Construction."
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NextEra PBNP                    Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement     Compliance Basis                  Reference Document 3.3.3 Interior Finishes Interior wall or ceiling finish Complies, with Required  Per section 5.1.7 of the          Fire Protection Evaluation Report classification shall be in      Action                   FPER, "Interior finishes such     (FPER), Rev. 13 / Section 5.1.7 accordance with NFPA                                     as gypsum plaster, ceramic 101, "Life Safety Code,"                               tile and acoustical ceiling       Letter NPC-27492 from Burstein requirements for Class A                                 materials are noncombustible.     (WE) to Case (NRC), dated June materials. Interior floor                                Epoxy coatings, alkyd and         20, 1977 / Sections 4.1.4.2 and finishes shall be in                                     latex paints are used."           4.1.4.3 accordance with NFPA 101 requirements for Class I                                 Per Sections 4.1.4.2 and          NFPA 101, "Life Safety Code,"
interior floor finishes.                                 4.1.4.3 of Letter NPC-27492,      2000 Edition / Sections 10.2.3.2(a)
                                                                                 "Interior walls and structural    and 10.2.7.2(a) components are noncombustible steel,             NAMS Action Request 1855689, concrete, and concrete unit       "Revision to Procedure MI 36.3 masonry and metal studs.          Interior Finish Requirements,"
Suspended ceilings are            dated March 12, 2013 constructed of metal members and UL rated noncombustible       Procedure MI 36.3, "Paint and acoustical tile.                  Coatings," Rev. 12 / All
                                                                                 ..."The coatings and paints used are limited by specification to industrial quality products with a proven history of satisfactory performance. No test for fuel contribution was required and these materials have not been tested for performance to ASTM E-84.
                                                                                 "Most of the painted areas at the Point Beach Nuclear Plant are administrative areas remote from safety-related equipment. Paintings and coatings used in safety-related areas are selected for their resistance to contamination and for surface qualities that facilitate cleanup activities... Plant areas, where combustible materials are allowed, are of unpainted masonry construction. The possibility of igniting wall and Page A-16 Revision 0   0                                                                                                                              Page A-1 6

NextEra PBNP                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         RequirementslGuidance          Compliance Statement             Compliance Basis                    Reference Document floor coatings is very remote.
It does not appear that further testing would improve the inherent safety of the plant and is not justified.
                                                                                            "The existing design is in compliance with the guidelines except for interior finish testing to ASTM E-84."
See implementation item identified below.
IMPLEMENTATION ITEMS:
IMP-134: Procedure MI 36.3, "Paint and Coatings," is being revised to require that wall and ceiling finishes installed inthe plant shall meet class A requirements of flame 2
spread 0-25 and smoke development 0-450; and floor finishes shall meet class I requirements of critical radiant flux of not less than 0.45 W/cm . This is being tracked by NAMS Action Request 1855689.
Submit for NRC Approval          NRC approval of the interior         None finishes used at PBNP is requested in Attachment L, Approval Request 2.
3.3.4 Insulation           Thermal insulation materials,   Complies                         No Additional Clarification          Fire Protection Evaluation Report Materials                   radiation shielding materials,                                                                       (FPER), Rev. 13 / Section 5.1.7 ventilation duct materials, and soundproofing materials                                                                          Specification 6118-M-41, shall be noncombustible or                                                                           "Specification for Sheetmetal limited combustible.                                                                                 Ductwork Heating, Ventilating, and Air Conditioning Systems," Rev. 0 /
Section 4.1.m.4 Specification PB-86, "Furnishing and Installing Control Building Smoke and Heat Vent System,"
Rev. 0 / Addendum 1, Section 3.3 Page A-17 Revision 00                                                                                                                                               Page A-17

NextEra PBNP                         Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.          Requirements/Guidance                Compliance Statement           Compliance Basis                 Reference Document 3.3.5 Electrical             Electrical.                          N/A                             N/A - Section Heading, see      N/A compliance bases below for compliance statements for specific subsections.
3.3.5.1                      Wiring above suspended               Complies, with Required         See implementation item         Form PBF-2060d, Fire Protection ceiling shall be kept to a           Action                          identified below.               Conformance Checklist," Rev. 1 /
minimum. Where installed,                                                                            All electrical wiring shall be listed for plenum use, routed                                                                        Procedure DG-F01, "Fire in armored cable, routed in                                                                          Protection Conformance metallic conduit, or routed in                                                                       Guidance," Rev. 2 / All cable trays with solid metal top and bottom covers.                                                                               NAMS Action Request 276093, "PBF-2060D -Allen," dated April 5, 2012 NAMS Engineering Change 276093, "DG-F01 Revision to Incorporate NFPA Requirements for Flammable Gases and Cables above Suspended Ceilings" IMPLEMENTATION ITEMS:
IMP-30:     Procedures DG-F01, "Fire Protection Conformance Guidance," and Form PBF-2060d, "Fire Protection Conformance Checklist," are being revised to require that wiring above suspended ceilings shall be kept to a minimum; and that where installed, 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. These changes are being tracked by NAMS Engineering Change 276093 and NAMS Action Request 1752387, respectively.
Submit for NRC Approval         NRC approval of instances of    None unprotected wiring above suspended ceilings is requested in Attachment L, Approval Request 3.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement        Compliance Basis                 Reference Document 3.3.5.2             Only metal tray and metal      Complies with Clarification Except as identified below,      Fire Protection Evaluation Report conduits shall be used for                                 electrical raceways comply       (FPER), Rev. 13 / Section 5.4.1 electrical raceways. Thin                                  with the requirements of this wall metallic tubing shall not                             section.                         Procedure DG-E12, "Electrical be used for power,                                                                          Raceway Installation," Rev. 1 /
instrumentation, or control                                In limited circumstances         Section 5.10 cables. Flexible metallic                                  exposed conduits have a thin conduits shall only be used                                plastic coating but the base     Specification PB-546, in short lengths to connect                                material is metal. Per Section   "Specification for Electrical components.                                                5.10 of DG-E12, only metallic    Installation," Rev. 1 / Section 10.4 conduit is used in the plant.
Likewise, Section 10.4 of Specification PB-546 identifies that only rigid steel conduit is used. Based on the fact that the conduit, although coated with plastic, is in fact constructed of metal, this requirement is met.
Submit for NRC Approval     NRC approval of the use of       None electrical metallic conduit (EMT) is requested in Attachment L, Approval Request 4.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis                  Reference Document 3.3.5.3             Electric cable construction   Complies by Previous       Per Section A.4 of the           Letter NPC-27492 from Burstein shall comply with a flame     NRC Approval               attachment to NPC-27492,         (WE) to Lear (NRC) dated June 20, propagation test as                                      "The 5 and 15kV cables were      1977 / Attachment, Section A.4 acceptable to the AHJ.                                   required to pass the vertical flame-resistance test in         Letter NPC-29597 from Schwencer accordance with IPCEA            (NRC) to Burstein (NRC) dated S-19-81, Section 6.19.6. The     August 2, 1979 / Enclosure 3, safety related 600V power        Safety Evaluation Report and control cables were          (NPC-35989), Section 4.8 required to pass the vertical flame-resistance test in         Fire Protection Technical accordance with IPCEA            Evaluation (FPTE) 011, "Technical S-19-81, Section 6.19-6 and      Evaluation of Acceptable PBNP the Bonfire Test..."              Cable Fire Retardancy Standards Power, Control and Specialty Per Section 4.8 of               Cable," Rev. 0 / All NPC-35989, "Safety-related electrical cables used at Point Beach were required to pass the vertical flame resistance tests in accordance with Insulated Power Cable Engineer's Association (IPCEA) test S-19-81, Section 6.19.6. Also, a test was conducted in which a bundle of jacketed cables was suspended with both ends approximately five inches above an open container of oil. The span was approximately five feet. The burning oil engulfed the cables for five minutes.
Cables are considered to pass the above flame tests if the material fails to propagate five minutes after the flame source is removed. The safety-related and nonsafety-related 600-Volt instrumentation cables were required to pass the IPCEA and oil fire tests. The safety-related 600-Volt power Page A-20 Revision 00                                                                                                                          Page A-20

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                 Reference Document and control cables were-required to pass the IPCEA tests. The Institute of Electrical and Electronics Engineers (IEEE) test requirements were not in effect at that time. We find that retest to the IEEE 383 procedures and criteria would not provide information that would alter our recommendations or conclusions regarding the acceptability of the jacketing and insulation. Wherever there is concern that rapid flame propagation from an electrical fire will compromise redundant safety-related divisions, a qualified flame retardant coating or material will be used to minimize the likelihood. On this basis, we find the electrical cables used at Point Beach acceptable."
The electrical cables, as approved by the referenced SER, are still installed at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP                        Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         Requirements/Guidance               Compliance Statement            Compliance Basis                   Reference Document Complies, with Required         See implementation item            Procedure DG-E13, "Insulated Action                          identified below                   Electrical Cable Insulation," Rev. 1
                                                                                                                                   / All NAMS Action Request 1855682, "Rev to Design Guideline DG-E13 for Fire Retardant Coatings," dated March 12, 2013 IMPLEMENTATION ITEMS:
IMP-136:    Design Guideline DG-E13, "Insulated Electrical Cable Insulation," is being revised to require that, wherever there is concern that rapid flame propagation from an electrical fire will compromise redundant safety-related divisions, a qualified flame retardant coating or material shall be used to minimize the likelihood. This is being tracked by NAMS Action Request 1855682.
3.3.6 Roofs                 Metal roof deck construction        Complies                        No Additional Clarification        Fire Protection Evaluation Report shall be designed and                                                                                  (FPER), Rev. 13 / Section 5.1.7 installed so the roofing system will not sustain a self-                                                                        NFPA 256, "Standard Methods of propagating fire on the                                                                                Fire Tests of Roof Coverings,"
underside of the deck when                                                                             1998 Edition / Section 1-1.2.1 the deck is heated by a fire inside the building. Roof                                                                              Specification 6118-C-44, coverings shall be Class A                                                                             "Specification for Furnishing and as determined by tests                                                                                 Installation of Built-up Roofing and described in NFPA 256,                                                                                 Insulation, Waterproofing and "Standard Methods of Fire                                                                              Dampproofing," Rev. 1 / Section Tests of Roof Coverings."                                                                              10.2.1 Specification 6118-C-45, "Precast Concrete Roof Decking," dated May 1, 1968 / Section 6.0 Page A-22 Revision 0  0                                                                                                                                                Page A-22

NextEra PBNP                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         RequirementslGuidance            Compliance Statement          Compliance Basis                  Reference Document 3.3.7 Bulk Flammable        Bulk compressed or               Complies, with Required       See implementation item           Fire Protection Evaluation Report Gas Storage                 cryogenic flammable gas          Action                        identified below.                 (FPER), Rev. 13 / Section 5.3.2 storage shall not be permitted inside structures                                                                      NAMS Engineering Change housing systems,                                                                                 276093, "DG-F01 Revision to equipment, or components                                                                         Incorporate NFPA 805 important to nuclear safety.                                                                     Requirements for Flammable Gases and Cables above Suspended Ceilings," dated April 9, 2012 NAMS Action Request 1752387, "PBF-2060D - Fire Protection Conformance Checklist Sections 4," dated April 5, 2012 IMPLEMENTATION ITEMS:
IMP-31:    Procedure DG-F01, "Fire Protection Conformance Guidance," and Form PBF-2060d, "Fire Protection Conformance Checklist," are being revised to require that bulk compressed or cryogenic flammable gases shall not be stored inside structures housing systems, equipment, or components important to nuclear safety. These changes are being tracked by NAMS Engineering Change 276093 and NAMS Action Request 1752387, respectively.
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NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       RequirementslGuidance            Compliance Statement           Compliance Basis                 Reference Document 3.3.7.1                   Storage of flammable gas         Complies, with Required        Storage of flammable gas is      R2092-001-002, "Fire Protection shall be located outdoors, or    Action                         located outdoors, or in          Code Conformance Review," Rev.
in separate detached                                            separate detached buildings,     1 / Attachment A, Section 567 buildings, so that a fire or                                    so that a fire or explosion will explosion will not adversely                                    not adversely impact systems,    NFPA 567, "Standard for Gaseous impact systems, equipment,                                      equipment, or components         Hydrogen Systems at Consumer or components important to                                      important to nuclear safety. Sites," 1963 Edition / All nuclear safety. NFPA 50A,                                       The bulk hydrogen storage "Standard for Gaseous                                           installation complies with       NAMS Action Request 1631826, Hydrogen Systems at                                             NFPA 567-1963 Edition as         "NP 1.9.9 - Transient Combustible Consumer Sites," shall be                                       evaluated in R2092-001-002.      (NFPA 805)," dated March 21, followed for hydrogen                                            Implementation items are        2011 storage.                                                        identified below.
Fire Protection Evaluation Report (FPER), Rev. 13 / Section 5.3.2 FPER Update Log / Entry 2011-FPER-01 IMPLEMENTATION ITEMS:
IMP-88:   The Fire Protection Evaluation Report (FPER) and Procedure NP 1.9.9, "Transient Combustible Control," are being revised to address the bulk storage of flammable gas in the power block. These revisions are being tracked by FPER Update Log Entry 201 1-FPER-01 and NAMS Action Request 1631826, respectively.
Submit for NRC Approval        NRC approval of the distance     R2092-001-002, "Fire Protection between the bulk hydrogen        Code Conformance Review," Rev.
storage system and the           1 / Attachment A, Section 567, Item unrated sheet steel wall on      522 the east side of the Turbine Building is requested in         NFPA 567, "Standard for Gaseous Attachment L, Approval           Hydrogen Systems at Consumer Request 5.                       Sites," 1963 Edition / Section 522 Page A-24 Revision 00                                                                                                                                        Page A-24

NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance        Compliance Statement      Compliance Basis             Reference Document 3.3.7.2             Outdoor high-pressure        Complies                   No Additional Clarification Fire Protection Evaluation Report flammable gas storage                                                               (FPER), Rev. 13 / Section 5.3.2 containers shall be located so that the long axis is not pointed at buildings.
3.3.7.3             Flammable gas storage        Complies                   No Additional Clarification Fire Protection Evaluation Report cylinders not required for                                                          (FPER), Rev. 13 / Section 5.3.2 normal operation shall be isolated from the system.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement     Compliance Basis                  Reference Document 3.3.8 Bulk Storage of Bulk storage of flammable     Complies by Previous      Per Section 5.1.3 of             Letter NPC-27492 from Burstein Flammable and         and combustible liquids shall NRC Approval              NPC-35989, "The turbine lube     (WE) to Lear (NRC) dated June 20, Combustible Liquids   not be permitted inside                                oil storage area contains         1977/ Enclosure, Sections 3.4.3.3, structures containing                                   12,300 gallons of oil located at 3.4.3.10, 3.4.6, and 3.4.7.1 systems, equipment, or                                 the north end of Unit 2 at components important to                                 elevation 8 feet. Because this   Letter NPC-29597 from Schwencer nuclear safety. As a                                    room is 200 feet from the        (NRC) to Burstein (WE) dated minimum, storage and use                                nearest safety-related area,     August 2, 1979 / Enclosure 3, shall comply with NFPA 30,                             the potential worst case effect   Safety Evaluation Report "Flammable and                                         of this fire on safety-related    (NPC-35989), Sections 5.1.3, 5.1.6, Combustible Liquids Code."                              areas would be the collapse of   5.6.1,5.6.6, 5.14.2, and 5.14.6 the turbine building roof. The licensee has indicated that      Letter NPC-30601 from Schwencer both the control and auxiliary   (NRC) to Burstein (WE) dated buildings are designed to        March 5, 1980 / Enclosure 2 withstand seismic forces ...The seismic design of the control     Letter NPC-31006 from Clark and auxiliary buildings           (NRC) to Burstein (WE) dated mitigates against any adverse    October 21, 1980 / Enclosure 2 effects that the collapse of the  (NPC-37551), Summary of Staff turbine building roof will have   Requirements, Page 6 on the auxiliary or control building walls.                  Letter NPC-27923 from Burstein "The turbine lubricating oil      (WE) to Clark (NRC) dated October reservoirs for Units 1 and 2     13, 1980 / Enclosure 1, Sections are 18 feet from the control      3.1.10 and 3.1.11 building walls. Both reservoirs are provided with oil retention   Letter NPC-30829 from Clark dikes and floor drain sumps.      (NRC) to Burstein (WE) dated The control building walls are    January 22, 1981 / Enclosure 3, two-hour rated. An                Item #3.1.4 uncontrolled lube oil fire could degrade and breach the two-       Letter NPC-27982 from Fay (WE) hour rated fire wall.            to Clark (NRC) dated March 2, 1981 / Section 3.1.24 and Attachment E Per Section 5.1.6, "The licensee has proposed the        Letter NPC-30934 from Clark following modifications:...       (NRC) to Burstein (WE) dated May (2) The fire damper in the       4, 1981 / Page 2 Paragraph 4, and turbine oil and lubrication       Enclosure 2 storage room will be replaced with a three-hour fire door       Letter NPC-28037 from Fay (WE) damper.                           to Clark (NRC) dated June 23, Page A-26 Revision 0 0                                                                                                                           Page A-26

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                  Reference Document (3) The curbing around the       1981 / Paragraph 2 lube oil storage tank and around the lube oil reservoirs   Letter NPC-37208 from Clark will be raised to ensure that    (NRC) to Fay (WE) dated April 28, the full tank contents can be    1983 / Paragraphs 2-4 contained with an appropriate margin for fire suppression      Letter NPC-38959, "Response to water. The storage of oil        10 CFR 50 Appendix R 'Alternate drums within the lube oil        Shutdown Capability'," dated storage tank curb will be        October 1983 / Section 6.2.1 discontinued.
(4) The control building walls   Letter NPC 94-07185 from Hansen that could be affected by a      (NRC) to Link (WE) dated October turbine lube oil reservoir fire  24, 1994 / Section 3.2.1 will be upgraded to a three-hour rating including fire       Letter NPC-30092 from Novak dampers, fire doors and          (NRC) to Fay (WE) dated penetration seals.               December 31, 1986 / Exemption (5) One fire detector will be    Attachment, Page 7; and Enclosure added to each turbine lube oil   2, Safety Evaluation (NPC-37908),
area.                            Section 2.3 (6) To preclude the possibility of the plant hydrogen header     Internal WE correspondence from from increasing the severity of  G.A. Casadonte to J.J. Zach dated postulated fires, the hydrogen   February 3, 1987, entitled "NRC header will be rerouted in the   Fire Protection Commitments" /
turbine building to avoid        Attachment entitled "Fire Protection passing over the turbine lube    Commitments (FPC) Punchlist,"
oil reservoir.                   Item #52 (7) A two-hour fire rated enclosure will be provided       Letter NPL 94-0264 from Krieser around the existing air intake   (WE) to Document Control Desk structures for the [GO1 and      (NRC) dated July 11, 1994 /All G02] diesel generators so that combustion and ventilation air   Fire Hazards Analysis Report can be ducted directly from      (FHAR) / Appendix A Rev. 3, Fire outdoors as well as from         Areas A27 and A28; and Appendix inside the building to ensure    C Rev. 7, FZ 308 and 309 start-up capability in the event of a turbine building fire.      Fire Protection Engineering Remote manually-operated         Evaluation (FPEE) 1999-008, fire dampers will be provided    "Control Building Fire Barrier to interrupt air intake from     Features," Rev. 3 / All inside the building in the event Page A-27 Revision 00                                                                                                                         Page A-27

NextEra PBNP             Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                  Reference Document of a lube oil fire.               Fire Protection Evaluation Report Subject to implementation of      (FPER), Rev. 13 / Section 5.3.4, the above modifications, we       Table 8.1-1 find that the fire protection for the turbine building satisfies    Modification M-605, dated May 25, the objectives identified in      1979 Section 2.2 of this report and is, therefore, acceptable."
Item #5 above has been addressed by the NRC's approval of the fire detector locator plan method of determining fire detector spacing, in Enclosure 2 to NPC-30601.
Per Sections 3.1.10 and 3.1.11 of Enclosure 1 to NPC-27923, Items #2 and #3 above, respectively, have been addressed.
The acceptability of the configuration addressed in Item #4 above has been justified in FPEE 1999-008.
Per Paragraphs 2-4 of NPC-37208, Item #6 above has been addressed. The NRC letter identifies that the fire protection for the hydrogen lines is acceptable, proposed modifications were performed as necessary to protect safety-related equipment.
Per Section 3.1.24 of NPC-27982, Item #7 above has been addressed as follows:
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document Per Section 3.1.24 of NPC-27982, "Rather than provide an alternate intake structure as originally proposed, licensee will permanently reverse the ventilation flow through the
[GO1 and G02] diesel rooms.
Since the existing intake structures will then become the exhaust structures, the fire rated enclosures discussed in the supplement will not be necessary."
Per Page 2, Paragraph 4 of Letter NPC-30934, "Based on our review of your March 2 letter, we conclude that your proposed modifications for items 3.1.5, 3.1.15, 3.1.24 and 3.1.32, which were not covered by 10 CFR Part 50 Appendix R, meet our guidelines and are, therefore, acceptable."
Per Section 5.6.1 of NPC-35989, for the G01 and G02 diesel generator rooms, "The two emergency diesel generator day tanks each have a 550-gallon capacity and are located inside their respective diesel generator rooms."
Per Section 5.6.6, "The licensee has proposed the following modifications:
(1) The three generator room walls common with other plant Revision 0                                                                                                                 Page A-29

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                   Reference Document areas will be upgraded to a three-hour rating, including dampers and penetrations.
(2) Conduits for each diesel generator passing through both rooms will be rerouted or the circuitry redesigned to avoid the possibility of a single fire affecting both diesel generators.
(3) One ionization detector per room will be added.
(4) The diesel generator room ventilation system control cables and junction boxes will be relocated outside the diesel generator rooms.
(5) The manually-actuated dry pipe sprinkler system in each room will be upgraded to a wet pipe system operated automatically with flow annunciation inthe control room.
We find that, subject to implementation of these modifications, the fire protection for the diesel generator rooms satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."
Item #1 above has been addressed per FHAR Appendix C, FZ 308 and FZ 309; and FHAR Appendix A, Fire Areas A27 and A28 Per WE Internal Correspondence dated 2/3/1987, entitled "NRC Fire Protection Commitments,"
Item 52 of attachment entitled Revision 0                                                                                                                   Page A-30

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                  Reference Document "Fire Protection Commitments (FPC) Punchlist," Item #2 above has been addressed.
Item #3 above has been addressed by the NRC's approval of the fire detector locator plan method of determining fire detector spacing, in Enclosure 2 to NPC-30601.
Item #4 above has been addressed by Enclosure 2 to NPC-30934, of which Paragraph 1 of Page 2 states, "Based on our review, we conclude.. that a fire destroying these cables would not adversely affect the ability of the plant to achieve safe shutdown. Therefore, we find that additional fire protection modifications are not required and consider this item to be resolved."
Per Modification M-605 and Table 8.1-1 of the FPER, Item
                                                                         #5 above has been addressed.
Per Section 5.14.2 of NPC-35989, "The major combustibles in the pump house are 250 gallons of diesel fuel in the fire pump day tank..."
Per Section 5.14.6, "The licensee has proposed the following modifications to the Page A-31 Revision 00                                                                                                                 Page A-31

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                    Reference Document circulating water pump house fire protection system:
(1) The existing six ionization-type fire detectors will be relocated to provide more rapid response to a fire in the vicinity of the diesel-driven fire pump and fuel oil day tank.
(2) A sprinkler system will be installed over the diesel-driven fire pump and the service water pumps.
We find that the above listed modifications represent a significant improvement to the fire protection for the circulating water pump house.
We therefore conclude that the licensee should proceed with implementing the modifications.
Implementation of the above listed modifications does not provide adequate assurance that a diesel fuel fire at the diesel-driven fire pump would not damage service water pumps required for safe shutdown and the motor-driven fire pump. The staff is concerned that the service water pumps and the other fire pump would be damaged, and safe shutdown prevented, in the event of failure of the sprinkler system. The licensee has also proposed to install a curb around the diesel-driven fire pump and to provide a floor drain in the curbed area.
The floor drain would divert fuel oil leakage to the circulating water pump pit area on the lower elevation of Page A-32 Revision 0 0                                                                                                                    Page A-32

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                  Reference Document the pumphouse. A review of this proposal by the staff is required before the overall fire protection for the service water pumps and fire pumps is judged adequate."
Item #1 above has been addressed by the NRC's approval of the fire detector locator plan method of determining fire detector spacing, in Enclosure 2 to NPC-30601.
Item #3.1.4 in Enclosure 3 to NPC-30829 identifies that the modification in Item #2 above has been addressed.
The commitment above to install a curb around the diesel-driven fire pump and to provide a floor drain in the curbed area was addressed as follows:
Per Page 6 of the "Summary of Staff Requirements" section of NPC-37551, the NRC stated that they were concerned that fire may damage redundant service water pumps and both fire water pumps in the intake structure. They concluded that installation of a curb, drain, and deflectors for the diesel fire pump, as proposed by Wisconsin Electric, were acceptable to aid in precluding a fire from damaging redundant systems.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                   Reference Document Per Attachment E to NPC-27982, Wisconsin Electric clarified the configuration of the Circulating Water Pumphouse to the NRC and restated its commitments to enhancing the fire protection in the area.
Per Page 3 of Enclosure 2 to NPC-30934, the NRC stated that inaddition to the commitments proposed by Wisconsin Electric, a fire-rated barrier should be installed to divide the service water pumps into two groups and to separate three service water pumps from the diesel-driven fire pump.
Per Paragraph 2 of NPC-28037, Wisconsin Electric committed to provide a fire-rated barrier to divide the service water pumps into two groups of three each and separate one group of three service water pumps from the diesel-driven fire pump.
Per Section 6.2.1 of NPC-38959, Wisconsin Electric requested an exemption from IIl.G.2(b) of 10 CFR 50 Appendix R in this area, and credited a 6-ft partial high wall between the two groups of service water pumps and oil drainage capabilities in the area (in lieu of curbing for the diesel fire pump), among other existing features.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement       Compliance Basis                  Reference Document Per Section 2.3 of NPC-37908, the NRC stated that the existing fire protection as described, combined with the proposed fire protection measure (to seai an opening between the two service water pump rooms) is acceptable.
Per Section 3.2.1 of NRC SER dated1 0/24/94 for the G03 and G04 diesel generators, "There is an independent fuel oil storage and transfer system for each train of EDGs. Each system consists of a 35,000-gallon fuel oil storage tank, two 100 percent capacity fuel oil transfer pumps, a 550-gallon day tank for each EDG and piping to each respective EDG... Each fuel oil storage tank will be able to provide a minimum supply of fuel oil to allow operation of one EDG for over seven days at maximum rated load or both EDGs at partial load for over five days.. .The capacity of each day tank will allow its associated EDG to run continuously at 100% rated load plus a margin of 10% for at least 120 minutes without makeup.. .Based on its review, the staff concludes that the design and operation of the new fuel oil storage and transfer system at PBNP conforms with the guidance as Page A-35 Revision 00                                                                                                                  Page A-35

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis               Reference Document described in the Standard Review Plan (SRP), Section 9.5.4, Emergency Diesel Engine Fuel Oil Storage and Transfer System. Therefore, the staff finds the system acceptable."
The configuration of bulk storage of flammable and combustible liquids, as approved by the referenced SERs, remains as described.
There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP                    Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      Requirements/Guidance              Compliance Statement           Compliance Basis                   Reference Document Complies, with Required        Bulk flammable and                 R2092-001-002, "Fire Protection Action                         combustible liquids storage        Code Conformance Review," Rev.
complies with NFPA 30-1966         1 / Attachment A, Sections 30.1966 and 1990 Editions as               and 30.1990 evaluated in R2092-001-002.
Implementation items are           NFPA 30, "Flammable and identified below.                  Combustible Liquids Code," 1966 Edition / All NFPA 30, "Flammable and Combustible Liquids Code," 1990 Edition / All NAMS Action Request 1753400, "Prepare a Procedure for Fuel and Lube Oil Tanks and Piping," dated April 9, 2012 IMPLEMENTATION ITEMS:
IMP-25:  A procedure will be prepared for inspection, maintenance, and repairs of fuel and lube oil tanks and associated piping. This is being tracked by NAMS Action Request 1753400.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement        Compliance Basis                  Reference Document Complies with Clarification Per Section 5.1.3 of              Letter NPC-29597 from Schwencer NPC-35989, "The heating           (NRC) to Burstein (WE) dated boiler room is part of the Unit   August 2, 1979 / Enclosure 3, 2 turbine building and could      Safety Evaluation Report contain 550 gallons of fuel oil.  (NPC-35989), Section 5.1.3 It is located next to the water treatment area and Unit 2         Letter NPC-30601 from Schwencer fagade. An unmitigated fire in    (NRC) to Burstein (WE) dated this room is not expected to      March 5, 1980 / Enclosure 2 affect safe shutdown."
Per Section 5.1.6, "The licensee has proposed the following modifications:
(1) Fire detectors will be added to the heating boiler room..."
Item #1 above has been addressed by the NRC's approval of the fire detector locator plan method of determining fire detector spacing, in Enclosure 2 to NPC-30601.
The location of fuel oil storage for the heating boiler is clarified in Attachment T, Clarification Request 1. NRC approval of this clarification is requested.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement        Compliance Basis                 Reference Document 3.3.9 Transformers   Where provided, transformer     Complies with Clarification In accordance with FAQ           Procedure PC 21 Part 4, oil collection basins and                                   12-0067, where used in           "Miscellaneous Data," Rev. 25 /
drain paths shall be                                        section 3.3.9, the term, "where  Sections 1.0 and 5.0 periodically inspected to                                   provided," shall mean those ensure that they are free of                                locations where provided for     FAQ 12-0067, "Transformer Oil debris and capable of                                       transformers that are installed  Collection Drain Basin Inspections,"
performing their design                                     in active or stand-by service. Rev. 1 /All function.                                                   This requirement does not apply to spare transformers. NRC Memorandum from Klein to Spare transformers are           AFPB File, "Close-Out of National defined as transformers          Fire Protection Association whose coils are not electrically Standard 805 Frequently Asked connected and energized in a     Question 12-0067: Transformer Oil manner to transfer electrical    Collection Drain Basin Inspections voltage and that cannot be switched into service in their current location. A swing transformer should not be considered a spare transformer in this context.
3.3.10 Hot Pipes and Combustible liquids,            Complies                    No Additional Clarification      Procedure NP 1.9.9, "Transient Surfaces             including high flashpoint                                                                    Combustible Control," Rev. 22 /
lubricating oils, shall be kept                                                              Section 4.1.5 from coming in contact with hot pipes and surfaces,                                                                      Procedure NP 1.9.6, "Plant including insulated pipes and                                                                Cleanliness and Storage," Rev. 45 /
surfaces. Administrative                                                                     Section 4.9.1 and Attachment E controls shall require the prompt cleanup of oil on insulation.
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NextEra PBNP                   Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance           Compliance Statement        Compliance Basis                   Reference Document 3.3.11 Electrical      Adequate clearance, free of     Complies                    No additional clarification        Procedure NP 1.9.9, "Transient Equipment              combustible material, shall                                                                    Combustible Control," Rev. 22 /
be maintained around                                                                           Section 4.1.17 energized electrical equipment.                                                                                     Nuclear Energy Institute (NEI) 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)," Rev. 2 /
Section K.5 3.3.12 Reactor Coolant For facilities with non-inerted Complies with Clarification Per Section 3.1 of FPTE 010,       Fire Protection Technical Pumps                  containments, reactor                                       PBNP acknowledges that             Evaluation (FPTE) 010, coolant pumps with an                                       Section 111.0 of 10 CFR 50         "Compliance Review of 10 CFR 50, external lubrication system                                 states, in part, that "'The oil    Appendix R, Section 111.0 RCP shall be provided with an oil                               collection system shall be so      Lube Oil Collection System," Rev. 3 collection system. The oil                                  designed, engineered, and          / Sections 2.0 and 7.4 collection system shall be                                  installed so that failure will not designed and installed such                                 lead to fire during normal or that leakage from the oil                                   design basis accident system is safely contained                                  conditions and that there is for off normal conditions                                   reasonable assurance that the such as accident conditions                                 system will withstand the Safe or earthquakes. All of the                                  Shutdown Earthquake."'
following shall apply.                                      Section 8.0 states that "...the RCPLOCS complies with Section 111.0 of 10 CFR 50, Appendix R."
3.3.12(1)              The oil collection system for   Complies                    No Additional Clarification        Fire Protection Technical each reactor coolant pump                                                                      Evaluation (FPTE) 010, shall be capable of collecting                                                                 "Compliance Review of 10 CFR 50, lubricating oil from all                                                                       Appendix R, Section 111.0 RCP potential pressurized and                                                                      Lube Oil Collection System," Rev. 3 nonpressurized leakage                                                                         / Section 8.0 sites in each reactor coolant pump oil system.
Page A-40 Revision 00                                                                                                                                   Page A-40

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance              Compliance Statement             Compliance Basis                    Reference Document 3.3.12(2)                 Leakage shall be collected         Complies                         No Additional Clarification         Fire Protection Technical and drained to a vented                                                                                 Evaluation (FPTE) 010, closed container that can                                                                               "Compliance Review of 10 CFR 50, hold the inventory of the                                                                               Appendix R, Section 111.0 RCP reactor coolant pump                                                                                    Lube Oil Collection System," Rev. 3 lubricating oil system.                                                                                 / Sections 7.8 and 8.0 3.3.12(3)                 A flame arrestor is required       Complies                         No Additional Clarification         Fire Protection Technical in the vent if the flash point                                                                          Evaluation (FPTE) 010, characteristics of the oil                                                                              "Compliance Review of 10 CFR 50, present the hazard of a fire                                                                            Appendix R, Section 111.0 RCP flashback.                                                                                              Lube Oil Collection System," Rev. 3
                                                                                                                                  / Section 7.5 NAMS Action Request 1855680, "Revise FPTE 010 to Clarify Description of RCP Lube System,"
dated March 12, 2013 NAMS Engineering Change 276631, "FPTE 010 Compliance Review of 10 CFR 50, Appendix R, Section 111.0 RCP Lube Oil Collection System, Revision 4" IMPLEMENTATION ITEMS:
IMP-127:  Section 7.5 of FPTE 010, "Compliance Review of 10 CFR 50, Appendix R, Section 111.0 RCP Lube Oil Collection System," will be revised to clarify contradictory wording concerning the characteristics of the lube oil used for the reactor coolant pump lube oil collection system, in order to correctly demonstrate that the oil does not present the hazard of a fire flashback, in accordance with NFPA 805 Section 3.3.12(3). This is being tracked by NAMS Action Request 1855680 and NAMS Engineering Change 276631.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance            Compliance Statement   Compliance Basis             Reference Document 3.3.12(4)           Leakage points on a reactor      Complies                No Additional Clarification Fire Protection Technical coolant pump motor to be                                                             Evaluation (FPTE) 010, protected shall include but                                                          "Compliance Review of 10 CFR 50, not be limited to the lift pump                                                      Appendix R, Section 111.0 RCP and piping, overflow lines, oil                                                      Lube Oil Collection System," Rev. 3 cooler, oil fill and drain lines                                                     / Section 7.2 and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactor coolant pumps.
3.3.12(5)           The collection basin drain       Complies                No Additional Clarification Fire Protection Technical line to the collection tank                                                          Evaluation (FPTE) 010, shall be large enough to                                                             "Compliance Review of 10 CFR 50, accommodate the largest                                                              Appendix R, Section 111.0 RCP potential oil leak such that oil                                                     Lube Oil Collection System," Rev. 3 leakage does not overflow                                                            / Section 7.7 the basin.
3.4 Industrial Fire                                  N/A                     N/A - General statement; No N/A Brigade                                                                     technical requirements 3.4.1 On-Site Fire- All of the following             N/A                     N/A - Section Heading, see  N/A Fighting Capability requirements shall apply.                               compliance bases below for compliance statements for specific subsections.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement        Compliance Basis                   Reference Document 3.4.1(a)            A fully staffed, trained, and   Complies with Clarification Per Section 3.1.4.2 of the         Fire Protection Evaluation Report equipped fire-fighting force                                FPER, "A site fire brigade of      (FPER), Rev. 13 / Section 3.1.4.2 shall be available at all times                             at least five members shall be to control and extinguish all                               maintained onsite at all           FAQ 12-0063, "Fire Brigade Make-fires on site. This force shall                             times.. .This shift crew may be    Up," Rev. 1 /All have a minimum                                              less than the minimum complement of five persons                                  requirements for a period of       NRC Memorandum from Klein to on duty and shall conform                                   time not to exceed 2 hours in      AFPB file, "Close-Out of National with the following NFPA                                     order to accommodate               Fire Protection Association standards, as applicable:                                   unexpected absence of              Standard 805 Frequently Asked personnel, provided                Question 12-0063: Fire Brigade immediate action is taken to       Make-Up," dated July 31, 2012 / All restore the shift makeup to within the minimum                 Nuclear Energy Institute (NEI) requirements."                     04-02, "Guidance for Implementing a Risk-Informed, Performance-In accordance with the             Based Fire Protection Program guidance of FAQ 12-0063,           under 10 CFR 50.48(c)," Rev. 2 /
prior NRC approval is claimed      Section K.6 for conditions where the fire brigade complement may be less than the minimum requirement for a period of time, as discussed below.
The PBNP fire brigade complies with NFPA 600 for interior fire fighting operations as discussed in Section 3.4.1 (a)(1).
As required, and in accordance with the guidance of K.6 of NEI 04-02, the PBNP fire brigade has the ability to control and extinguish exterior fires similarly to interior fires, through the development, review, and maintenance of associated fire emergency plans and fire attack plans; regular training and education; the use of appropriate protective clothing and Page A-43 Revision 00 Revision                                                                                                                                   Page A-43

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                 Reference Document equipment; and brigade member medical and physical performance requirements; as addressed through compliance with Section 3.4.1(a)(1).
Complies by Previous       Per the attachment to           Letter NPC-27738 from Burstein NRC Approval              enclosures 1 and 2 of            (WE) to Denton (NRC) dated NPC-30103, "A Fire Brigade      October 1, 1979 / All of at least 5 members shall be maintained onsite at all times. Letter NPC-30103 from Schwencer Fire Brigade composition may    (NRC) to Burstein (WE) dated be less than the minimum        November 13, 1979 / Enclosures 1 requirements for a period of    and 2, Amendment No. 41 to time not to exceed 2 hours in    DPR-24 and Amendment No. 46 to order to accommodate             DPR-27, Attachment, Changes to unexpected absence of Fire      Technical Specifications, Section Brigade members provided        15.6.2-2 immediate action is taken to restore the Fire Brigade to within the minimum requirements."
The fire brigade site presence requirement, as approved by the referenced SER, is still in place at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         RequirementslGuidance              Compliance Statement          Compliance Basis                 Reference Document 3.4.1(a)(1)                 NFPA 600, "Standard on             Complies, with Required       The industrial fire brigade      R2092-001-002, "Fire Protection Industrial Fire Brigades"          Action                        complies with NFPA               Code Conformance Review," Rev.
(interior structural fire                                        600-2000 Edition as              1 / Attachment A, Section 600 fighting)                                                        evaluated in R2092-001-002.
Implementation items are        NFPA 600, "Standard on Industrial identified below.                Fire Brigades," 2000 Edition / All NAMS Action Request 1753430, "Fire Brigade Update to Meet NFPA 600, 2000 Edition," dated April 9, 2012 IMPLEMENTATION ITEMS:
IMP-121:     The Fire Brigade will be updated as necessary to meet the applicable requirements of NFPA 600, 2000 Edition. This is being tracked by NAMS Action Request 1753430.
3.4.1 (a)(2)                NFPA 1500, "Standard on            N/A                           NFPA 1500 is not applicable      Nuclear Energy Institute (NEI)
Fire Department                                                  to PBNP per Section K.6 of       04-02, "Guidance for Implementing Occupational Safety and                                          NEI 04-02, which states, "The    a Risk-Informed, Performance-Health Program"                                                  NFPA standards divide fire       Based Fire Protection Program brigades into two types, based   under 10 CFR 50.48(c)," Rev. 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)."
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NextEra PBNP                         Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.          Requirements/Guidance              Compliance Statement            Compliance Basis                  Reference Document 3.4.1 (a)(3)                 NFPA 1582, "Standard on            N/A                              NFPA 1582 is not applicable      Nuclear Energy Institute (NEI)
Medical Requirements for                                           to PBNP per Section K.6 of        04-02, "Guidance for Implementing Fire Fighters and Information                                       NEI 04-02, which states, "The    a Risk-Informed, Performance-for Fire Department                                                 NFPA standards divide fire       Based Fire Protection Program Physicians"                                                         brigades into two types, based   under 10 CFR 50.48(c)," Rev. 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)."
3.4.1(b)                     Industrial fire brigade            Complies, with Required         See implementation item           FAQ 12-0063, "Fire Brigade Make-members shall have no             Action                            identified below.                Up," Rev. 1 /All other assigned normal plant duties that would prevent                                                                            NRC Memorandum from Klein to immediate response to a fire                                                                         AFPB file, "Close-Out of National or other emergency as                                                                                Fire Protection Association required.                                                                                            Standard 805 Frequently Asked Question 12-0063: Fire Brigade Make-Up," dated July 31, 2012 / All NAMS Action Request 1839217, "NP 1.9.14- Fire Protection Organization," dated January 14, 2013 IMPLEMENTATION ITEMS:
IMP-9:       Procedure NP 1.9.14, "Fire Protection Organization," is being revised to require that fire brigade members shall not be assigned to any plant duties that would prevent the immediate response to a fire. In accordance with FAQ 12-0063, this would exclude the fire brigade members from assignment to on-shift Emergency Response Organization (ERO) positions (other than fire brigade). Further, the licensed Reactor Operator / Senior Reactor Operator (RO/SRO) positions, and the Shift Technical Advisor (STA) position assigned to the on-shift ERO, would likewise not be assigned to the fire brigade. This procedure change is being tracked by NAMS Action Request 1839217.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis               Reference Document 3.4.1(c)            During every shift, the       Complies with Clarification Per Section 1.1 of FOP 1.1,    Fire Protection Evaluation Report brigade leader and at least                               fire brigade members are also  (FPER), Rev. 13 / Section 3.1.1 two brigade members shall                                 plant operators.
have sufficient training and                                                             Procedure FOP 1.1, "Brigade knowledge of nuclear safety                               Per Section 3.1.1 of the       Training," Rev. 10 /All systems to understand the                                 FPER, "Qualifications of effects of fire and fire                                  individuals in the fire suppressants on nuclear                                   protection organization are safety performance criteria.                              administratively controlled to ensure qualification of the Exception to (c): Sufficient                              individual commensurate with training and knowledge shall                              the position being held and be permitted to be provided                               activities being preformed."
by an operations advisor dedicated to industrial fire brigade support.
3.4.1(d)            The industrial fire brigade   Complies                    No Additional Clarification    Procedure NP 1.9.14, "Fire shall be notified immediately                                                            Protection Organization," Rev. 13 /
upon verification of a fire.                                                             Section 4.2.2 3.4.1(e)            Each industrial fire brigade  Complies                    No Additional Clarification    Procedure NP 4.2.12, member shall pass an                                                                     "Requirements for Radiologically annual physical examination                                                              Controlled Area Entry," Rev. 24 /
to determine that he or she                                                              Section 4.8.3 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.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement    Compliance Basis           Reference Document 3.4.2 Pre-Fire Plans Current and detailed pre-fire   Complies, with Required See implementation items   Procedure FAP 3.0, "Fire Attack plans shall be available to     Action                  identified below.          Plans," Rev. 9 / All the industrial fire brigade for all areas in which a fire could                                                    Procedure FAP 3.1, "Fire Attack jeopardize the ability to meet                                                     Plan for Class 'A' Fires," Rev. 1 / All the performance criteria described in Section 1.5.                                                          Procedure FAP 3.2, "Fire Attack Plan for Class 'B' Fires," Rev. 3 / All Procedure FAP 3.3, "Fire Attack Plan for Class 'C' Fires in Distribution Equipment and Machinery," Rev. 1 / All Procedure FAP 3.4, "Fire Attack Plan for Class 'C' Fires in Cable Runs, Cable Trays, and Battery Racks," Rev. 2 / All Procedure FAP 3.5, "Fire Attack Plan for Class 'A' and 'B' Fires,"
Rev. 3 / All Procedure FAP 3.6, "Fire Attack Plan for Class 'A' and 'C' Fires,"
Rev. 1 /All Procedure FAP 3.7, "Fire Attack Plan for Class B and C Fires," Rev.
4 / All Procedure FAP 3.8, "Fire Attack Plan for Class 'A', 'B' and 'C' Fires,"
Rev. 3 / All Procedure FAP 3.9, "Fire Attack Plan for Fire in a Filing Cabinet and Combustible Trailer," Rev. 1 / All Procedure FAP 3.10, "Fire Attack Plan for Flammable Gas Fire," Rev.
1 /All Procedure FAP 3.11, "Fire Attack Page A-48 Revision 0 0                                                                                                                      Page A-48

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis            Reference Document Plan for PCB Transformer Fires,"
Rev. 4 / All Procedure FEP 4.0, "Fire Emergency Plan," Rev. 5 / All Procedure FEP 4.1, "PAB West and Central," Rev. 11 / All Procedure FEP 4.2, "PAB South,"
Rev. 7 / All Procedure FEP 4.3, "PAB North,"
Rev. 9 / All Procedure FEP 4.4, "Fagade Unit 1," Rev. 8 / All Procedure FEP 4.5, "Containment Unit 1," Rev. 8 / All Procedure FEP 4.6, "Fagade Unit 2," Rev. 8 / All Procedure FEP 4.7, "Containment Unit 2," Rev. 9 / All Procedure FEP 4.8, "PAB," Rev. 9 All Procedure FEP 4.9, "South Service Building," Rev. 7 / All Procedure FEP 4.10, "Auxiliary Building," Rev. 8 / All Procedure FEP 4.11, "Auxiliary Building," Rev. 9 / All Procedure FEP 4.12, "Auxiliary Feedwater Pump and Vital Switchgear Area," Rev. 8 / All Procedure FEP 4.13, "Emergency Revision 0                                                                                                                   Page A-49

NextEra PBNP                   Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance            Compliance Statement              Compliance Basis                  Reference Document Diesel Generator (G01/G02) and Compressor Rooms, Rev. 10 / All Procedure FEP 4.14, "Turbine Hall Unit 1," Rev. 15 / All Procedure FEP 4.15, "Turbine Hall Unit 2," Rev. 12 / All Procedure FEP 4.16, "Control Room/Cable Spreading Room/Computer Room," Rev. 7 /
All Procedure FEP 4.17, "Gas Turbine Building (West Yard)," Rev. 7 / All Procedure FEP 4.18, "Fuel Oil Pumping House and Storage Tanks," Rev. 7 / All Procedure FEP 4.19, "Circulating Water Pumphouse," Rev. 8 / All Procedure FEP 4.20, "Site," Rev. 6
                                                                                                                               / All Procedure FEP 4.27, "Emergency Diesel Generator Building (G-03/G-04)," Rev. 4 / All NAMS Action Request 1753424, "Pre-Fire Plan to Address Radioactive Release for Outside PA," dated April 9, 2012 NAMS Action Request 1845926, "Revise Pre-Fire Plans and Training Materials per NFPA 805,"
dated February 6, 2013 IMPLEMENTATION ITEMS:
IMP-92:  A pre-fire plan document will be developed to provide off-site fire responders with a plan to address special considerations concerning radioactive Revision 0                                                                                                                                              Page A-50

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance                Compliance Statement            Compliance Basis                Reference Document release due to fire suppression activities inthe Steam Generator Storage Facility and other places outside the protected area of the plant. This document will be a supplement or addition to any documentation that currently exists between Point Beach and offsite fire responders to qualify the duties of such organizations when responding to the site. This is being tracked by NAMS Action Request 1753424.
IMP-130: Pre-fire plans and fire brigade training materials will be revised to address radioactive release requirements of NFPA 805. This is being tracked by NAMS Action Request 1845926.
Page A-51 Revision 00                                                                                                                                            Page A-51

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance           Compliance Statement        Compliance Basis                Reference Document 3.4.2.1             The plans shall detail the fire Complies with Clarification The Fire Emergency Plans        Procedure FAP 3.0, "Fire Attack area configuration and fire                                 (FEP) each contain a section    Plans," Rev. 9 / All hazards to be encountered                                   describing the fire area in the fire area, along with                                location by common name         Procedure FAP 3.1, "Fire Attack any nuclear safety                                          and elevation; a section        Plan for Class 'A' Fires," Rev. 1 / All components and fire                                         detailing all known fire, protection systems and                                      radiation, electrical, and      Procedure FAP 3.2, "Fire Attack features that are present.                                  physical hazards that are to    Plan for Class 'B' Fires," Rev. 3 / All encountered in each area; a section describing nuclear      Procedure FAP 3.3, "Fire Attack safety components located in    Plan for Class 'C' Fires in each area; and a section        Distribution Equipment and describing all the fire         Machinery," Rev. 1 /All protection systems installed in each area.                      Procedure FAP 3.4, "Fire Attack Plan for Class 'C' Fires in Cable The Fire Attack Plans (FAP)     Runs, Cable Trays, and Battery each contain hazard-specific    Racks," Rev. 2 / All information for the fire brigade, including equipment    Procedure FAP 3.5, "Fire Attack hazards; radiation,             Plan for Class 'A' and 'B' Fires,"
contamination or medical        Rev. 3 / All considerations; follow-up notifications; and area         Procedure FAP 3.6, "Fire Attack cleanup/reentry criteria. The   Plan for Class 'A' and 'C' Fires,"
FAP's also provide hazard-      Rev. 1 /All specific information regarding what types of extinguishing     Procedure FAP 3.7, "Fire Attack methods to use, and how to      Plan for Class B and C Fires," Rev.
apply those methods.            4 / All Procedure FAP 3.8, "Fire Attack Plan for Class 'A', 'B' and 'C' Fires,"
Rev. 3 / All Procedure FAP 3.9, "Fire Attack Plan for Fire in a Filing Cabinet and Combustible Trailer," Rev. 1 / All Procedure FAP 3.10, "Fire Attack Plan for Flammable Gas Fire," Rev.
1 /All Procedure FAP 3.11, "Fire Attack Page A-52 Revision 0 0                                                                                                                                Page A-52

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement       Compliance Basis           Reference Document Plan for PCB Transformer Fires,"
Rev. 4 / All Procedure FEP 4.0, "Fire Emergency Plan," Rev. 5 / All Procedure FEP 4.1, "PAB West and Central," Rev. 11 / All Procedure FEP 4.2, "PAB South,"
Rev. 7 / All Procedure FEP 4.3, "PAB North,"
Rev. 9 / All Procedure FEP 4.4, "Fagade Unit 1," Rev. 8 / All Procedure FEP 4.5, "Containment Unit 1," Rev. 8 / All Procedure FEP 4.6, "Fagade Unit 2," Rev. 8 / All Procedure FEP 4.7, "Containment Unit 2," Rev. 9 / All Procedure FEP 4.8, "PAB," Rev. 9 /
All Procedure FEP 4.9, "South Service Building," Rev. 7 / All Procedure FEP 4.10, "Auxiliary Building," Rev. 8 / All Procedure FEP 4.11, "Auxiliary Building," Rev. 9 / All Procedure FEP 4.12, "Auxiliary Feedwater Pump and Vital Switchgear Area," Rev. 8 / All Procedure FEP 4.13, "Emergency Revision 0                                                                                                                   Page A-53

NextEra PBNP             Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis            Reference Document Diesel Generator (G01/G02) and Compressor Rooms, Rev. 10 / All Procedure FEP 4.14, "Turbine Hall Unit 1," Rev. 15/All Procedure FEP 4.15, "Turbine Hall Unit 2," Rev. 12 / All Procedure FEP 4.16, "Control Room/Cable Spreading Room/Computer Room," Rev. 7 All Procedure FEP 4.17, "Gas Turbine Building (West Yard)," Rev. 7 / All Procedure FEP 4.18, "Fuel Oil Pumping House and Storage Tanks," Rev. 7 / All Procedure FEP 4.19, "Circulating Water Pumphouse," Rev. 8 / All Procedure FEP 4.20, "Site," Rev. 6
                                                                                                     / All Procedure FEP 4.27, "Emergency Diesel Generator Building (G-03/G-04)," Rev. 4 / All Page A-54 Revision 00                                                                                                                  Page A-54

NextEra PBNP                   Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      RequirementslGuidance             Compliance Statement             Compliance Basis               Reference Document Complies, with Required          See implementation items        NAMS Engineering Change Action                           identified below.              274391, "Drawings PBC-219 SHEETS 30, 35, and 39 Administrative Changes," dated March 6, 2012 IMPLEMENTATION ITEMS:
IMP-56:  Drawing PBC-219 Sheet 39, "Fire Emergency Procedure 4.17 Gas Turbine Building," is being revised to show locations for local manual actuation of the dry chemical suppression system in the gas turbine building. This revision is being tracked by NAMS Engineering Change 274391.
Page A-55 Revision 0 0                                                                                                                                       Page A-55

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis                Reference Document 3.4.2.2             Pre-fire plans shall be       Complies with Clarification Per the cover pages of the      Procedure DG-F01, "Fire reviewed and updated as                                   Fire Attack Plans and Fire      Protection Conformance necessary.                                                Emergency Plans, the            Guidance," Rev. 2 / Section 5.2.1 documents are controlled reference documents.            Procedure FAP 3.0, "Fire Attack Plans," Rev. 9 / Cover Page Per Section 2.2 of NP 1.1.6, "Controlled reference           Procedure FEP 4.0, "Fire documents need to be            Emergency Plan," Rev. 5 / Cover maintained current as an        Page information or data source to personnel who have a need to    Procedure NP 1.1.6, "Controlled create implementing             Reference Documents," Rev. 13 /
procedures or instructions      Sections 2.2 and 4.1.3.c based upon the data provided in the documents; or need to use the data as a basis for calculations, modifications, or other support activities."
Per Section 4.1.3.c, "The individual preparing the controlled reference document should determine if a particular document is subject to periodic review/audit requirements. Review/auditing requirements shall be integrated into activities as appropriate to satisfactorily address the requirements."
Per Section 5.2.1 of DG-FO1,
                                                                              "...Designs that require fire attack plan revision for access and/or smoke control shall be approved by the PBNP Fire Protection Engineer..."
Page A-56 Revision 0 0                                                                                                                            Page A-56

NextEra PBNP                      Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance          Compliance Statement        Compliance Basis                Reference Document 3.4.2.3                   Pre-fire plans shall be        Complies with Clarification Section 4.3.2 of NP 1.9.14      Procedure NP 1.9.14, "Fire available in the control room                              states, with respect to         Protection Organization," Rev. 13 /
and made available to the                                  requirements of the Shift       Section 4.3.2 plant industrial fire brigade.                             Manager (SM), "The SM should refer to the appropriate fire attack plan and fire emergency plan found in the fire protection manual and supply this information to the fire brigade leader as needed." The fire brigade has "access" to the guides by being provided the information by the Control Room.
3.4.2.4                   Pre-fire plans shall address   Complies with Clarification Coordination with other plant   Procedure NP 1.9.14, "Fire coordination with other plant                              groups during fire              Protection Organization," Rev. 13 /
groups during fire                                         emergencies is addressed in     Sections 4.2.3, 4.3.5, 4.3.6, and emergencies.                                               the identified sections of NP   4.10.2 1.9.14.
3.4.3 Training and Drills Industrial fire brigade        N/A                         N/A - Section Heading, see      N/A members and other plant                                    compliance bases below for personnel who would                                        compliance statements for respond to a fire in                                       specific subsections.
conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.
3.4.3(a) Plant Industrial Plant Industrial Fire Brigade  N/A                         N/A - Section Heading, see      N/A Fire Brigade Training     Training. All of the following                             compliance bases below for requirements shall apply.                                  compliance statements for specific subsections.
Page A-57 Revision 0  0                                                                                                                                 Page A-57

NextEra PBNP                       Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.        Requirements/Guidance             Compliance Statement           Compliance Basis                 Reference Document 3.4.3(a)(1)                Plant industrial fire brigade      Complies with Clarification   NFPA 1500 is not applicable      Nuclear Energy Institute (NEI) members shall receive                                            to PBNP per Section K.6 of       04-02, "Guidance for Implementing training consistent with the                                     NEI 04-02, which states, "The    a Risk-Informed, Performance-requirements contained in                                        NFPA standards divide fire       Based Fire Protection Program NFPA 600, "Standard on                                           brigades into two types, based   under 10 CFR 50.48(c)," Rev. 2/
Industrial Fire Brigades," or                                    on organization and duties:      Section K.6 NFPA 1500, "Standard on                                          'Industrial Fire Brigades' and Fire Department                                                  'Industrial Fire Departments.'
Occupational Safety and                                          Practically, this means that a Health Program," as                                              fire fighting organization at a appropriate.                                                     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)."
Complies, with Required       Fire brigade training complies   R2092-001-002, "Fire Protection Action                         with NFPA 600-2000 Edition       Code Conformance Review," Rev.
as evaluated in                  1 / Attachment A, Section 600 R2092-001-002.
Implementation items are         NFPA 600, "Standard on Industrial identified below.                Fire Brigades," 2000 Edition / All NAMS Action Request 1753430, "Fire Brigade Update to Meet NFPA 600, 2000 Edition," dated April 9, 2012 IMPLEMENTATION ITEMS:
IMP-121:    The Fire Brigade will be updated as necessary to meet the applicable requirements of NFPA 600, 2000 Edition. This is being tracked by NAMS Action Request 1753430.
Page A-58 Revision 00                                                                                                                                          Page A-58

NextEra PBNP                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         RequirementslGuidance            Compliance Statement           Compliance Basis                Reference Document 3.4.3(a)(2)                 Industrial fire brigade           Complies, with Required       See implementation items         NFPA 600, "Standard on Industrial members shall be given           Action                         identified below.                Fire Brigades," 200 Edition /
quarterly training and                                                                            Section 5-2.1 practice in fire fighting, including radioactivity and                                                                       Procedure FOP 1.1, "Brigade health physics                                                                                    Training," Rev. 10 / Section 7.1 considerations, to ensure that each member is                                                                               Procedure PC 74, "Conducting and thoroughly familiar with the                                                                      Evaluating Fire Drills," Rev. 12 /
steps to be taken in the                                                                          Section 2.4 event of a fire.
NAMS Action Request 1753430, "Fire Brigade Update to Meet NFPA 600, 2000 Edition," dated April 9, 2012 IMPLEMENTATION ITEMS:
IMP-121:    The Fire Brigade will be updated as necessary to meet the applicable requirements of NFPA 600, 2000 Edition. This is being tracked by NAMS Action Request 1753430.
3.4.3(a)(3)                A written program shall detail     Complies                      No Additional Clarification      Procedure FOP 1.1, "Brigade the industrial fire brigade                                                                       Training" Rev. 10 /All training program.
3.4.3(a)(4)                Written records that include       Complies                      No Additional Clarification      Procedure FOP 1.1, "Brigade but are not limited to initial                                                                    Training," Rev. 10 / Section 8.0 industrial fire brigade classroom and hands-on training, refresher training, special training schools attended, drill attendance records, and leadership training for industrial fire brigades shall be maintained for each industrial fire brigade member.
Page A-59 Revision 00                                                                                                                                            Page A-59

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement    Compliance Basis             Reference Document 3.4.3(b) Training for Industrial fire brigade         Complies                 No Additional Clarification Fire Protection Evaluation Report Non-Industrial Fire   members and other plant                                                              (FPER), Rev. 13 / Section 3.1.3.1 Brigade Personnel     personnel who would respond to a fire in                                                                 Procedure NP 1.9.14, "Fire conjunction with the brigade                                                         Protection Organization," Rev. 13/
shall be provided with                                                               Sections 4.3.5 and 4.8 training commensurate with their emergency                                                                      Procedure PBSAP 5.9, "Off-Site responsibilities.                                                                    Emergency Agency Interface," Rev.
9 / All (b) Training for Non-Industrial Fire Brigade                                                              Radiation Protection Technologist Personnel. Plant personnel                                                           Training Program Document who respond with the                                                                 HPI-02-LP010, "Radiological Alarm Response," Rev. 2 / Section IL.H industrial fire brigade shall be trained as to their Training Lesson Plan EPI                       responsibilities, potential LP008, "Radiation Protection hazards to be encountered, Emergency Actions Inside of and interfacing with the                                                             Protected Area," Rev. 0 / Section industrial fire brigade.                                                             IL.D Training Lesson Plan PB-BSU-BSE-003-O4L, "Off-Site Agency Response," Rev. 3 / All 3.4.3(c) Drills       Drills. All of the following    N/A                      N/A - Section Heading, see  N/A requirements shall apply.                                compliance bases below for compliance statements for specific subsections.
3.4.3(c)(1)           Drills shall be conducted       Complies                 No Additional Clarification Procedure FOP 1.1, "Brigade quarterly for each shift to                                                          Training," Rev. 10 / Section 7.1 test the response capability of the industrial fire brigade.
Page A-60 Revision 00                                                                                                                        Page A-60

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement     Compliance Basis             Reference Document 3.4.3(c)(2)         Industrial fire brigade drills Complies                 No Additional Clarification  Procedure PC 74, "Conducting and shall be developed to test                                                           Evaluating Fire Drills," Rev. 12 /
and challenge industrial fire                                                        Sections 2.2, 2.3, 2.6, and 4.3 brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall evaluate the industrial fire brigade's abilities to react, respond, and demonstrate proper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.
3.4.3(c)(3)         Industrial fire brigade drills Complies                  No Additional Clarification Procedure PC 74, "Conducting and shall be conducted in                                                                Evaluating Fire Drills," Rev. 12 /
various plant areas,                                                                 Sections 2.6 and 2.7 especially in those areas identified to be essential to plant operation and to contain significant fire hazards.
3.4.3(c)(4)         Drill records shall be         Complies                  No Additional Clarification Procedure FOP 1.1, "Brigade maintained detailing the drill                                                       Training," Rev. 10 / Section 8.1 scenario, industrial fire brigade member response,                                                             Procedure PC 74, "Conducting and and ability of the industrial                                                        Evaluating Fire Drills," Rev. 12 /
fire brigade to perform as a                                                         Attachments A and B team.
Page A-61 Revision 00                                                                                                                        Page A-61

NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance           Compliance Statement    Compliance Basis             Reference Document 3.4.3(c)(5)          A critique shall be held and    Complies                 No Additional Clarification Procedure PC 74, "Conducting and documented after each drill.                                                         Evaluating Fire Drills," Rev. 12 /
Section 4.6 3.4.4 Fire-Fighting  Protective clothing,            Complies                 No Additional Clarification Fire Protection Evaluation Report Equipment            respiratory protective                                                               (FPER), Rev. 13 / Section 3.1.4.4 equipment, radiation monitoring equipment,                                                                Fire Protection Technical personal dosimeters, and                                                             Evaluation (FPTE) 013, "Technical fire suppression equipment                                                           Evaluation of PBNP Fire Hose such as hoses, nozzles, fire                                                         Details," Rev. 0 / All extinguishers, and other needed equipment shall be                                                            Procedure HP 1.9, "Security Group provided for the industrial                                                          Radiation Protection fire brigade. This equipment                                                         Responsibilities," Rev. 26 / Section shall conform with the                                                               3.6 applicable NFPA standards.
Procedure NP 1.9.14, "Fire Protection Organization," Rev. 12/
Section 2.12.9 3.4.5 Off-Site Fire  Off-Site Fire Department        N/A                      N/A - General statement; No N/A Department Interface Interface.                                              technical requirements 3.4.5.1 Mutual Aid   Off-site fire authorities shall Complies                 No Additional Clarification Fire Protection Evaluation Report Agreement            be offered a plan for their                                                          (FPER), Rev. 13 / Section 3.1.4.2 interface during fires and related emergencies on site.                                                         Procedure NP 1.9.14, "Fire Protection Organization," Rev. 13/
Section 4.10.1 Page A-62 Revision 0  0                                                                                                                       Page A-62

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement    Compliance Basis             Reference Document 3.4.5.2 Site-Specific Fire fighters from the off-site Complies                 No Additional Clarification Fire Protection Evaluation Report Training              fire authorities who are                                                             (FPER), Rev. 13 / Section 3.1.4.3 expected to respond to a fire at the plant shall be offered                                                        Procedure FOP 1.1, "Brigade site-specific training and                                                           Training," Rev. 10 /Section 7.3 shall be invited to participate in a drill at least annually.
3.4.5.3 Security and  Plant security and radiation    Complies                 No Additional Clarification Procedure NP 1.9.14, "Fire Radiation Protection  protection plans shall                                                               Protection Organization," Rev. 13/
address off-site fire authority                                                      Section 4.10.2 response.
3.4.6 Communications  An effective emergency          Complies                 No Additional Clarification Fire Protection Evaluation Report communications capability                                                            (FPER), Rev. 13 / Sections 3.1.4.4 shall be provided for the                                                            and 5.6.2 industrial fire brigade.
3.5 Water Supply      Water Supply.                   N/A                      N/A - General statement; No N/A technical requirements 3.5.1                 A fire protection water supply  N/A                      N/A - Section Heading, see  N/A of adequate reliability,                                 compliance bases below for quantity, and duration shall                             compliance statements for be provided by one of the                                specific subsections.
two following methods.
Page A-63 Revision 00                                                                                                                        Page A-63

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis                 Reference Document 3.5.1(a)            Provide a fire protection     Complies by Previous       Per Section 4.3.1(1) of         Letter NPC-27492 from Burstein water supply of not less than NRC Approval               NPC-35989, "Water for fire      (WE) to Case (NRC) dated June two separate 300,000-gal                                 protection is obtained directly 20, 1977 / Attachment, Section 2.1 (1,1 35,500-L) supplies.                                 from Lake Michigan through two inlet forebays at the       Letter NPC-29597 from Schwencer lakeside pump house. The        (NRC) to Burstein (WE) dated water is drawn in through two   August 2, 1979 / Enclosure 3, separate travelling screens     Safety Evaluation Report supplying suction to two        (NPC-35989), Section 4.3.1(1) automatic-starting fire pumps.
A secondary water supply is available by having fire department pumpers take suction from the lake and discharge through hose lines to the fire water system by connecting to the Siamese fire department connection at the lakeside pump house. The licensee has proposed to provide a sign at the Siamese connection to indicate the connection point. We conclude that the basic water supply system conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."
The water supply from Lake Michigan, as approved by the referenced SER, is still used at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
Page A-64 Revision 0 0                                                                                                                          Page A-64

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement     Compliance Basis              Reference Document 3.5.1(b)            Calculate the fire flow rate   N/A                       PBNP utilizes the method     N/A for two hours. This fire flow                            allowed in subsection (a) to rate shall be based on 500                               comply with Section 3.5.1.
gpm (1892.5 L/min) for manual hose streams plus the largest design demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, "Standard for the Installation of Sprinkler Systems," or NFPA 15, "Standard for Water Spray Fixed systems for Fire Protection." The fire water supply shall be capable of delivering this design demand with the hydraulically least demanding portion of fire main loop out of service.
Page A-65 Revision 0 0                                                                                                                 Page A-65

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement        Compliance Basis                 Reference Document 3.5.2               The tanks shall be             Complies with Clarification Per section 6.2.1 of the         Fire Protection Evaluation Report interconnected such that fire                              FPER, "The water supply for      (FPER), Rev. 13 / Section 6.2.1 pumps can take suction from                                fire protection is taken from either or both. A failure in                               Lake Michigan and can be one tank or its piping shall                               supplied from either a motor-not allow both tanks to drain.                             driven fire pump or a diesel-The tanks shall be designed                                driven fire pump.. .The in accordance with NFPA 22,                                individual fire pumps take their "Standard for Water Tanks                                  suction from independent for Private Fire Protection."                              bays of the Circulating Water Pumphouse." Therefore, Point Exception No. 1: Water                                     Beach complies with storage tanks shall not be                                 Exception No. 1 to this required when fire pumps                                   requirement.
are able to take suction from NFPA 22 is not applicable as a large body of water (such fire water tanks are not as a lake), provided each fire utilized.
pump has its own suction and both suctions and pumps are adequately separated.
Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.
Page A-66 Revision 0 0                                                                                                                              Page A-66

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis                 Reference Document 3.5.3               Fire pumps, designed and      Complies with Clarification Except as identified below, fire R2092-001-002, "Fire Protection installed in accordance with                              pumps comply with NFPA           Code Conformance Review," Rev.
NFPA 20, "Standard for the                                20-1968 edition as evaluated     1 / Attachment A, Section 20 Installation of Stationary                                in R2092-001-002. Section Pumps for Fire Protection,"                               6.2.1 of the FPER identifies     NFPA 20, "Standard for the shall be provided to ensure                               that fire suppression system     Installation of Centrifugal Fire that 100 percent of the                                   flow demands can be met with     Pumps," 1968 Edition / All required flow rate and                                    one fire pump.
pressure are available                                                                     Fire Protection Evaluation Report assuming failure of the                                                                    (FPER), Rev. 13 / Section 6.2.1 largest pump or pump power                                                                 Paragraph 2 source.
Procedure Record and Field Copy Tracking File for Procedure 0-PT-FP-004, "Annual Fire Pump Capacity Test" / Record dated September 24, 2009 Page A-67 Revision 00                                                                                                                              Page A-67

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document Complies by Previous       Per Section 4.3.1 (1) of        Letter NPC-27492 from Burstein NRC Approval               NPC-35989, "Water for fire      (WE) to Case (NRC) dated June protection is obtained directly 20, 1977 / Attachment, Section 2.1 from Lake Michigan through two inlet forebays at the       Letter NPC-29597 from Schwencer lakeside pump house. The        (NRC) to Burstein (WE) dated water is drawn in through two   August 2, 1979 / Enclosure 3, separate travelling screens     Safety Evaluation Report supplying suction to two        (NPC-35989), Section 4.3.1(1) automatic-starting fire pumps.
A secondary water supply is available by having fire department pumpers take suction from the lake and discharge through hose lines to the fire water system by connecting to the Siamese fire department connection at the lakeside pump house. The licensee has proposed to provide a sign at the Siamese connection to indicate the connection point. We conclude that the basic water supply system conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."
The water supply from Lake Michigan, as approved by the referenced SER, is still used at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis                Reference Document Submit for NRC Approval   Approval of the electric motor- None driven fire pump, which cannot hold stalled rotor current indefinitely, is requested in Attachment L, Approval Request 6.
3.5.4               At least one diesel engine-   Complies                   No Additional Clarification    Fire Protection Evaluation Report driven fire pump or two more                                                            (FPER), Rev. 13 / Section 6.2.1 seismic Category I Class IE electric motor-driven fire                                                              Procedure 0-PT-FP-004, "Annual pumps connected to                                                                      Fire Pump Capacity Test," Rev. 10 redundant Class IE                                                                      / All emergency power buses capable of providing 100                                                                NAMS Work Order 40131985, "Fire percent of the required flow                                                            Pump Capacity Test," closed rate and pressure shall be                                                              November 4, 2012 / All provided.
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NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement     Compliance Basis                  Reference Document 3.5.5               Each pump and its driver      Complies by Previous      Per Section 6.2.1 of the         Fire Protection Evaluation Report and controls shall be         NRC Approval              FPER, "The Fire pumps are        (FPER), Rev. 13 / Section 6.2.1 separated from the                                     separated by a partial height remaining fire pumps and                               fire barrier and protected        Letter from Burstein (WE) to Lear from the rest of the plant by                          similarly to the service water    (NRC) dated June 20, 1977 /
rated fire barriers.                                   pumps as described in the fire    Attachment, Sections 4.3.1(2) and zone hazard elevation for Fire    5.14.6 Zone 552."
Letter NPC-29597 from Schwencer Per Section 4.3.1(2) of          (NRC) to Burstein (WE) dated NPC-35989, "The two fire          August 2, 1979 / Enclosure 3, pumps are separated by            Safety Evaluation Report approximately 22 feet, and the    (NPC-35989), Section 4.3.1(2) service water pumps are separated from the fire pumps     Letter NPC-31006 from Clark by approximately 7 feet--all      (NRC) to Burstein (WE) dated measured centerline to            October 21, 1980 / Enclosure 2, centerline of pump                Summary of Staff Requirements heads.. .Although the capacity    (NPC-37551), Section 3.2.2 of the water supply is adequate, both fire pumps are     Letter NPC-30934 from Clark susceptible to damage from a      (NRC) to Burstein (WE) dated May single fire because of the lack   4, 1981 / Enclosure 2, Safety of separation between the         Evaluation Report (NPC-37554),
pumps. The adequacy of the        Section 3.2.2 fire protection afforded the fire water pumps is discussed in       "Point Beach Nuclear Plant Units 1 section 5.14 of this report.      & 2 Final Report Response to 10 Per Section 5.14.6, "We will     CFR 50 Appendix R 'Alternate address the adequacy of the       Shutdown Capability'," NPC-38959, fire protection afforded the      dated October 1, 1983 / Section 6.2 service water pumps and the fire pumps in a supplement to     Letter NPC-30092 from Novak this report after completion of   (NRC) to Fay (WE) dated the evaluation of this matter."   December 31, 1986 / Enclosure 1, Exemption, Page 7 Per Section 3.2.2 of NPC-37551, "In order to meet the requirements of Section III.G of proposed Appendix R to 10 CFR 50, the licensee should install two one-and-one-half hour fire rated barriers separating the service Page A-70 Revision 00                                                                                                                          Page A-70

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement       Compliance Basis                  Reference Document water pumps in the intake structure into three sections with a service water pump in each section. Also the diesel fire pump day tank should be relocated to the same side of the fire rated barrier as the diesel fire pump. Any opening in the 1-1/2 hour fire barrier should be properly protected including a curb installed at all door openings to prevent a flammable liquid spill from reaching both sides of a barrier."
Per page 7 of Enclosure 1 to NPC-30092, "Although 20 feet of separation without intervening combustibles is not available between redundant systems, the licensee has installed a partial height, noncombustible wall between the service water pumps such that they are divided into two sets of three.
Because the fire load in these locations is low, if a fire were to occur, we expect it would develop slowly, with initially low heat release, and slow room temperature rise.
Because of the presence of the early warning fire detection systems, the fire would be detected in its incipient stages. The fire brigade would then be dispatched and would extinguish the fire manually.
Until the fire was extinguished, the noncombustible, partial height Page A-71 Revision 0 0                                                                                                                   Page A-71

NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance        Compliance Statement        Compliance Basis                Reference Document partition between the two sets of shutdown service water pumps and the automatic sprinkler system would provide sufficient passive and active fire protection. Based on the above evaluation, the staff concludes that the existing fire protection combined with the proposed fire protection measures in the service water pump room provides a level of fire protection equivalent to the technical requirements for Section IIl.G.2.b of Appendix R."
The fire pump configuration, as approved by the referenced SERs, remainsas described. There have been no plant modifications or other changes that would invalidate the basis for approval.
3.5.6               Fire pumps shall be provided Complies with Clarification Per Section 6.2.1 of the        Fire Protection Evaluation Report with automatic start and                                 FPER, the diesel fire pump is   (FPER), Rev. 13 / Section 6.2.1, manual stop only.                                        provided with automatic and     Paragraph 2 manual start, and manual stop only.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement     Compliance Basis               Reference Document Submit for NRC Approval  The electric fire pump is      None provided with automatic and manual start, and manual stop, but can also stop automatically. Approval of the ability of the electric motor-driven fire pump to stop automatically is requested in Attachment L, Approval Request 6.
3.5.7               Individual fire pump           Complies                 No Additional Clarification    Drawing 6118 M-208 Sheet 1, "Fire connections to the yard fire                                                           Water," Rev. 45 / All main loop shall be provided and separated with sectionalizing valves between connections.
3.5.8               A method of automatic          Complies                 Per Grid Sections E7-F7 and    Drawing 6118 M-208 Sheet 1, "Fire pressure maintenance of the                             E8-F8 of Drawing 6118          Water," Rev. 45 / Grid Sections fire protection water system                            M-208 Sheet 1, Jockey Pump     E7-F7 and E8-F8 shall be provided                                       P-36 is provided as an independent of the fire                                 independent means for pumps.                                                  automatic pressure maintenance of the fire protection water system.
3.5.9               Means shall be provided to     Complies                 No Additional Clarification    Fire Protection Evaluation Report immediately notify the                                                                 (FPER), Rev. 13 /Section 6.2.1, control room, or other                                                                 Paragraph 2 suitable constantly attended location, of operation of fire pumps.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement       Compliance Basis            Reference Document 3.5.10              An underground yard fire      Complies                   No Additional Clarification R2092-001-002, "Fire Protection main loop, designed and                                                              Code Conformance Review," Rev.
installed in accordance with                                                         1 / Attachment A, Section 24 NFPA 24, "Standard for the Installation of Private Fire                                                         NFPA 24, "Standard for Outside Service Mains and Their                                                              Protection," 1966 Edition / All Appurtenances," shall be installed to furnish anticipated water requirements.
3.5.11              Means shall be provided to    Complies                   No Additional Clarification Drawing 6118 M-208 Sheet 1, "Fire isolate portions of the yard                                                         Water," Rev. 45 / All fire main loop for maintenance or repair                                                                Fire Protection Evaluation Report without simultaneously                                                               (FPER), Rev. 13 / Sections 3.3, shutting off the supply to                                                           Paragraph 3; and 6.2.2 both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement      Compliance Basis             Reference Document 3.5.12              Threads compatible with       Complies                   No Additional Clarification Letter NPC 2011-00468 from those used by local fire                                                             Reynolds (TCVFD) to Binette departments shall be                                                                 (EPM) dated October 21, 2011 / All provided on all hydrants, hose couplings, and standpipe risers.
Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate training and procedures are provided.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement        Compliance Basis               Reference Document 3.5.13              Headers fed from each end      Complies with Clarification The hose stations and          Fire Protection Technical shall be permitted inside                                  standpipes provided for Point  Evaluation (FPTE) 016, "Resolution buildings to supply both                                   Beach are in accordance with   of Identified Deviations to National sprinkler and standpipe                                    the requirements of BTP        Fire Protection Code systems, provided steel                                    9.5-1, Appendix A for plants   Requirements," Rev. 6 / Sections piping and fittings meeting                                which received a construction  13-DEV-13 and 13-DEV-26 the requirements of ANSI                                   permit before July 1, 1976 B31.1, "Code for Power                                     which do not require a seismic Fire Protection Evaluation Report Piping," are used for the                                  category I water system. The   (FPER), Rev. 13 / Section 6.3.1, headers (up to and including                               existing system as installed   Paragraph 2; Table 8.1-1 the first valve) supplying the                             was accepted by the NRC as sprinkler systems where                                    discussed below.               Specification 6118-M-3320, "Piping such headers are part of the                                                              Class Summary" / Sheet 7, Rev. 7 seismically analyzed hose                                  Per Section 6.3.1 of the standpipe system. Where                                    FPER, "The underground yard main headers are extended provided, such headers shall into and interconnected within be considered an extension the buildings. Each header of the yard main system.                                   serves several fire protection Each sprinkler and                                         systems such as the sprinkler standpipe system shall be                                  and deluge systems in equipped with an outside                                   specific plant areas. Each screw and yoke (OS&Y) gate                                 sprinkler, deluge and valve or other approved                                    standpipe system is equipped shutoff valve.                                             with an individual isolation valve."
Per Sheet 7 of 6118-M-3320, aboveground fire service water piping is Class KB-1.
Per Sheet 19 of 6118-M-3320, Class KB piping is carbon steel.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                   Reference Document Complies by Previous       Per Section IV.A.4 of the         Letter NPC-27447 from Burstein NRC Approval               attachment to NPC-27447,          (WE) to Stello (NRC) dated "We do not believe that the       November 1, 1976 / Attachment, application of seismic criteria   Section IV.A.4 to water type fire suppression systems is a realistic            Letter NPC-27492 from Burstein approach to fire protection.      (WE) to Lear (NRC) dated June 20, The NRC Probabilistic             1977 / Sections 2.1 through 2.4 and Analysis Branch has               3.4.3.3 concluded that, 'It appears that the contribution to overall  Letter NPC-29597 from Schwencer risk from potential seismically   (NRC) to Burstein (WE) dated induced fires is minimal and      August 2, 1979 / Attachment 3, would not be significantly        Safety Evaluation Report affected whether the fire         (NPC-35989), Sections 4.3.1(3) protection system is designed     through 4.3.1(5) to Category I requirements or not."'                            Modification M-605, dated May 25, 1979 / Section 3.5 Per Section 4.3.1(4) of NPC-35989, "the interior hose     Specification 6118-M-66, "Fire installation.. .[is] acceptable." Protection System," Rev. 0 I Section 4.1.9 Per Section 4.3.1(3) of NPC-35989, "...the fire water     Specification 6118-M-3320, "Piping piping system...[is]              Class &Valve List Data Sheets,"
acceptable."                      Rev. 4 / Sheets 7 and 19 Per Section 4.3.1(5) of           Specification 6704-1-1 Section NPC-35989 for the G01 and         15302, "Specification for G02 diesel generator rooms,       Procurement and Installation of the "The manual sprinkler system      Diesel Generator Building Fire in the diesel generator rooms     Protection System," Rev. 2 /
is supplied by the service        Section 2.03.1 water system and utilizes nonlisted/approved operating      Specification PB-83, "Specification control valves. The diesel        for Furnishing, Installing and generator rooms are normally      Testing Fire Protection Sprinkler unoccupied and a fire in this     Systems," Rev. 0 / Section 1.7 area would develop to full intensity quickly because of      Specification PB-175, the flammable liquids present.     "Specification for Furnishing, If a diesel fuel oil fire reached Installing and Testing Fire full intensity prior to manual     Protection Sprinkler Systems," Rev.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                 Reference Document actuation of the present         1 / Section 1.7 deluge system, structural damage and damage to the         Specification PB-241, deluge system itself could       "Specification for Furnishing, occur. For these reasons the     Installing and Testing Fire manual sprinkler system         Protection Piping," Rev. 0 / Section protecting the diesel generator 1.7 rooms will be upgraded to an automatic wet pipe sprinkler system with flow alarm annunciation in the control room. We conclude that, subject to the implementation of the above modification, the existing sprinkler systems... [are] acceptable."
Modification M-605 installed an automatic wet pipe suppression system in the diesel generator rooms. Table 8.1-1 of the FPER identifies automatic wet pipe sprinkler systems in the diesel generator rooms. Thus, the proposed modification has been completed and the use of nonlisted/approved operating control valves for these suppression systems is approved.
The fire water supply arrangement, as approved by the referenced SER, is still installed at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement      Compliance Basis                  Reference Document Submit for NRC Approval    NRC approval is requested for    None the use of containment hose reel station control valves that are not listed or approved for fire protection service due to the fact that the reels are fed by the service water system.
This approval is requested in Attachment L, Approval request 7.
3.5.14              All fire protection water      Complies                   No Additional Clarification      Procedure O-PT-FP-006, "Monthly supply and fire suppression                                                                Fire Protection Control Valve system control valves shall                                                                Position Verification," Rev. 5 / All be under a periodic inspection program and shall                                                               Procedure PC 73 Part 4, "Monthly be supervised by one of the                                                                Fire Protection Control Valve following methods.                                                                         Position Verification," Rev. 27 / All 3.5.14(a)           Electrical supervision with    Complies                   No Additional Clarification      Fire Protection Evaluation Report audible and visual signals in                                                              (FPER), Rev. 13 / Section 6.3.2 the main control room or other suitable constantly attended location.
3.5.14(b)           Locking valves in their        N/A                        Valve locking is not performed   N/A normal position. Keys shall                               at Point Beach.
be made available only to authorized personnel.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement        Compliance Basis                 Reference Document 3.5.14(c)           Sealing valves in their       Complies with Clarification Per Section 6.3.2 of the         Fire Protection Evaluation Report normal positions. This option                             FPER, "The yard main post-       (FPER), Rev. 13 / Section 6.3.2 shall be utilized only where                              indicator valves, the fire valves are located within                                 header isolation valves, and     Procedure O-PT-FP-006, "Monthly fenced areas or under the                                 hose station isolation valves    Fire Protection Control Valve direct control of the                                     are not electrically supervised. Position Verification," Rev. 5 /
owner/operator.                                           The manually operated valves     Attachments A and B listed above are provided with identification tags and are      Procedure PC 73 Part 4, "Monthly administratively controlled. Fire Protection Control Valve The position of these valves is  Position Verification," Rev. 27 /
verified locally during periodic Attachments A and B inspections."
Per Attachments A and B of Procedure O-PT-FP-006 and Attachments A and B of Procedure PC 73 Part 4, valves are sealed in position and are within the owner-controlled area.
Complies                    Except as identified below,      R2092-001-002, "Fire Protection hose houses comply with          Code Conformance Review," Rev.
NFPA 24-1966 Edition as          1 / Attachment A, Section 24 evaluated in R2092-001-002.
NFPA 24, "Standard for Outside Protection," 1966 Edition / All Page A-80 Revision 00                                                                                                                             Page A-80

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement     Compliance Basis                Reference Document 3.5.15              Hydrants shall be installed    Complies by Previous      Per Section 4.3.1(3) of        Letter NPC-27492 from Burstein approximately every 250 ft     NRC Approval              NPC-35989, "Seven yard         (WE) to Case (NRC) dated June (76 m) apart on the yard                                 hydrants have been provided    20, 1977 / Section 5.2.7.2 main system. A hose house                                at approximately 250-foot equipped with hose and                                   intervals. Four of these       Letter NPC-29597 from Schwencer combination nozzle and                                   hydrants are provided with     (NRC) to Burstein (WE) dated other auxiliary equipment                                hose houses...we conclude      August 2, 1979 / Enclosure 3, specified in NFPA 24,                                    that.. .the fire water piping  Safety Evaluation Report "Standard for the Installation                           system... [is] acceptable.     (NPC-35989), Section 4.3.1(3) of Private Fire Service Mains and Their Appurtenances,"                                The hydrant and hose house shall be provided at intervals                           configuration, as approved by the referenced SER, still of not more than 1000 ft (305 m) along the yard main                              exists at PBNP. There have system.                                                  been no plant modifications or other changes that would invalidate the basis for Exception: Mobile means of                               approval.
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.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis                   Reference Document 3.5.16              The fire protection water     Complies by Previous       Per Item C of NPC-37206, "In      Letter NPC-28005 from Fay (WE) supply system shall be        NRC Approval               our original SER, we indicated    to Denton (NRC) dated April 9, dedicated for fire protection                            that the licensee had not         1981 / Pages 2 and 3 use only.                                                provided sufficient information to demonstrate why bearing        Letter NPC-29206 from Clark Exception No. 1: Fire                                    lube oil cooling for the turbine  (NRC) to Fay (WE) dated April 21, protection water supply                                  driven AFW pump can not be        1982 / Enclosure, Safety Evaluation systems shall be permitted                               automatically provided by a       Report (NPC-37206), Item C to be used to provide backup                             design involving no other to nuclear safety systems,                               external plant systems such provided the fire protection                             as the firewater system in the water supply systems are                                 event of a total loss of AC designed and maintained to                               power for a two hour period.
deliver the combined fire and                            By letter dated April 9, 1981 nuclear safety flow demands                             the licensee provided for the duration specified by                            additional information to justify the use of the diesel driven the applicable analysis.
firewater pump to provide bearing cooling for the turbine Exception No. 2: Fire                                    driven AFW pump. The protection water storage can                             licensee indicates that be provided by plant                                     periodic warming of the water systems serving other                                    stored in the condensate functions, provided the                                  storage tank results in an storage has a dedicated                                  unacceptable cooling water capacity capable of                                     temperature thus precluding providing the maximum fire                               use of primary auxiliary protection demand for the                               feedwater supply for bearing specified duration as                                    cooling. Further, modifications determined in this section.                             would be required to return the condensate flow to the tank if it were used for bearing cooling in order to prevent unacceptable depletion in the water inventory available to the steam generators. The licensee also points out that monthly technical specification testing and surveillance assure availability of the diesel driven firewater to the extent practical. We conclude that the licensees response satisfactorily resolves our Page A-82 Revision 00                                                                                                                           Page A-82

NextEra PBNP                      Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.        Requirements/Guidance             Compliance Statement           Compliance Basis                Reference Document concern and thus, use of the diesel driven firewater pump to automatically provide bearing cooling for the turbine driven AFW pump in a total loss of AC power is acceptable. The licensee is therefore in compliance with this recommendation."
The ability of the fire water system to supply cooling water to the turbine-driven AFW pump, as approved by the referenced SER, still exists at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
Complies, with Required        See implementation item         NAMS Action Request 1753428, Action                         identified below.               "Procedures for Fire Prot Water Supply for Non-Fire Prot Uses,"
dated April 9, 2012 IMPLEMENTATION ITEMS:
IMP-1 19: PBNP procedures will be revised to address controls and communication protocols necessary to support the use of fire protection (FP) water supply in non-fire protection plant evolutions. These procedure revisions are being tracked by NAMS Action Request 1753428.
Submit for NRC Approval        NRC approval of manual uses     None of fire water at PBNP is requested in Attachment L, Approval Request 8.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement        Compliance Basis             Reference Document 3.6 Standpipe and   Standpipe and Hose             N/A                         N/A - General statement; No  N/A Hose Stations       Stations.                                                  technical requirements 3.6.1               For all power block buildings, Complies with Clarification Standpipe and hose systems   Fire Protection Technical Class III standpipe and hose                               were reviewed against the    Evaluation (FPTE) 016, "Resolution systems shall be installed in                              requirements of NFPA         of Identified Deviations to National accordance with NFPA 14,                                   14-1963 Edition in V878  Fire Protection Code "Standard for the Installation                             TD-05. Justification of      Requirements," Rev. 6 / Sections of Standpipe, Private                                      deviations from this code is 14-DEV-1 through 14-DEV-9, et al.
Hydrant, and Hose Systems."                                provided in FPTE 016, Sections 14-DEV-1 through    NFPA 14, "Standard for the 14-DEV-9, et al.             Installation of Standpipe and Hose Systems," 1963 Edition / All Technical Document V878                                                                                                             TD-05, "NFPA Code Compliance Assessment," Rev. 0 Page A-84 Revision 0 0                                                                                                                         Page A-84

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document Complies by Previous      System was designed for          Letter NPC-27447 from Burstein NRC Approval              class II service, not class III  (WE) to Rusche (NRC) dated as required by this section. November 1, 1976 / Attachment, Per Section 4.3.1(4) of         Section IV.A.4 NPC-35989, "The licensee has proposed to add 13 hose     Letter NPC-27492 from Burstein stations equipped with 1 1/2-    (WE) to Lear (NRC) dated June 20, inch diameter hose.. .The       1977 / Attachment, Section 5.3.4.2 licensee will also install additional hose stations with    Letter NPC-29597 from Schwencer 100 feet of 1-inch hose and     (NRC) to Burstein (WE) dated ball shutoff variable fog       August 2, 1979 / Enclosure 3, nozzles for the protection of   Safety Evaluation Report the control room and             (NPC-35989), Section 4.3.1(4) switchgear room. Five hose reels with 100 feet of 1-inch   Internal WE correspondence from hose will be installed in each  G.A. Casadonte to J.J. Zach dated containment building.            February 3, 1987, entitled "NRC
                                                                          ... "We conclude that, subject  Fire Protection Commitments" /
to implementation of these       Attachment entitled "Fire Protection modifications, the interior     Commitments (FPC) Punchlist,"
hose installation satisfies the Items #52, #45, and #48 objectives identified in Section 2.2 of this report and is, therefore, acceptable."
Per WE Internal Correspondence dated 2/3/1987, entitled "NRC Fire Protection Commitments,"
Item 44 of attachment entitled "Fire Protection Commitments (FPC) Punchlist," the commitment to install 13 hose stations with 1 1/2-inch diameter hose was completed via Modification M-598. Per Items 45 and 48 of the same attachment, the commitments to install hose stations for protection of the control room, switchgear room, and containment building have been completed as Page A-85 Revision 0 0                                                                                                                        Page A-85

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement      Compliance Basis                  Reference Document committed.
The standpipe and hose system, as approved by the referenced SER, remains as described. There have been no plant modifications or other changes that would invalidate the basis for approval.
Submit for NRC Approval    NRC approval is requested for    None the use of containment hose reel station control valves that are not listed or approved for fire protection service due to the fact that the reels are fed by the service water system.
This approval is requested in Attachment L, Approval request 7.
3.6.2               A capability shall be         Complies                   No Additional Clarification      Fire Protection Evaluation Report provided to ensure an                                                                     (FPER), Rev. 13 / Section 6.2.1 adequate water flow rate and                                                              Paragraph 2; and Section 6.3.4 nozzle pressure for all hose                                                              Paragraph 2 stations. This capability includes the provision of                                                                 Technical Document V878                     hose station pressure                                                                     TD-05, "NFPA Code Compliance reducers where necessary                                                                  Assessment," Rev. 0 for the safety of plant industrial fire brigade members and off-site fire department personnel.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement      Compliance Basis             Reference Document 3.6.3               The proper type of hose        Complies                   No Additional Clarification Fire Protection Evaluation Report nozzle to be supplied to                                                              (FPER), Rev. 13 / Sections 6.3.4 each power block area shall                                                           and 6.3.5 be based on the area fire hazards. The usual                                                                    Technical Document V878                     combination spray/straight                                                            TD-05, "NFPA Code Compliance stream nozzle shall not be                                                            Assessment," Rev. 0 used in areas where the straight stream can cause unacceptable damage or present an electrical hazard to fire-fighting personnel.
Listed electrically safe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed.
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NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance        Compliance Statement      Compliance Basis                  Reference Document 3.6.4               Provisions shall be made to  Complies by Previous      The hose stations and             Letter NPC-27447 from Burstein supply water at least to     NRC Approval              standpipes provided for Point     (WE) to Stello (NRC) dated standpipes and hose                                     Beach are in accordance with     November 1, 1976 / Attachment, stations for manual fire                               the requirements of BTP           Section IV.A.4 suppression in all areas                               9.5-1, Appendix A for plants containing systems and                                 which received a construction     Letter NPC-29597 from Schwencer components needed to                                    permit before July 1, 1976       (NRC) to Burstein (WE) dated perform the nuclear safety                             which do not require a seismic    August 2, 1979 / Enclosure 3, functions in the event of a                            category I water system. The      Safety Evaluation Report safe shutdown earthquake                               existing system as installed      (NPC-35989), Section 4.3.1(4)
(SSE).                                                 was accepted by the NRC as discussed below.
Per Section IV.A.4 of the attachment to NPC-27447, "We do not believe that the application of seismic criteria to water type fire suppression systems is a realistic approach to fire protection.
The NRC Probabilistic Analysis Branch has concluded that, 'It appears that the contribution to overall risk from potential seismically induced fires is minimal and would not be significantly affected whether the fire protection system is designed to Category I requirements or not'.
Per Section 4.3.1(4) of NPC-35989, "the interior hose installation... [is] acceptable.
The fire water supply arrangement, as approved by the referenced SER, is still installed at PBNP. There have been no plant modifications or other changes that would invalidate this approval.
Page A-88 Revision 0 0                                                                                                                          Page A-88

NextEra PBNP                   Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis                Reference Document 3.6.5                  Where the seismic required    N/A                         Seismic hose stations are not   N/A hose stations are cross-                                  provided.
connected to essential seismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement.
3.7 Fire Extinguishers Where provided, fire          Complies with Clarification Based on the clarification      Nuclear Energy Institute (NEI) extinguishers of the                                      provided in Section K.8 of NEI  04-02, "Guidance for Implementing appropriate number, size,                                 04-02, review of fire           a Risk-Informed, Performance-and type shall be provided in                             extinguishers is limited to     Based Fire Protection Program accordance with NFPA 10,                                  those locations where they      Under 10 CFR 50.48(c)," Rev. 2/
                       "Standard for Portable Fire                               exist at present as part of the Section K.8 Extinguishers."                                           approved plant design.
Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.
Page A-89 Revision 00                                                                                                                              Page A-89

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance             Compliance Statement           Compliance Basis                    Reference Document Complies, with Required         Fire extinguishers comply with     R2092-001-002, "Fire Protection Action                          NFPA 10-1967 and 1990              Code Conformance Review," Rev.
Editions as evaluated in            1 / Attachment A, Sections 10.1967 R2092-001-002.                     and 10.1990 Implementation items are identified below.                  NFPA 10, "Standard for the Installation of Portable Fire Extinguishers," 1967 Edition / All NFPA 10, "Standard for Portable Fire Extinguishers," 1990 Edition I All NAMS Action Request 1839912, "PC 76 PART 5 - Annual Inspection of Carbon Dioxide Fire Exti," dated January 17, 2013 NAMS Action Request 1839893, "PC 76 PART 3 - Annual Inspection of Spare, Outside, and Nort," dated January 17, 2013 NAMS Action Request 1855681, "Tracking RWT for Additional Fire Extinguishers," dated March 12, 2013 NAMS Work Request 45307, "FP I Install New Fire Extinguishers,"
dated October 7, 2010 IMPLEMENTATION ITEMS:
IMP-16:  A work request has been generated to install additional fire extinguishers inthe G03/G04 Diesel Generator Building to comply with NFPA 10-1990 Edition. This is being tracked by NAMS Action Request 1855681 and NAMS Work Request 45307.
IMP-17:  A work request has been generated to install additional fire extinguishers inthe Unit 1 and Unit 2 Fagades to comply with NFPA 10-1967 Edition. This is being tracked by NAMS Action Request 1855681 and NAMS Work Request 45307.
IMP-40:  Procedures PC 76 Part 3, "Annual Inspection of Spare, Outside, and North Service Building Hand-Held Dry Chemical Extinguishers," and PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," are being revised to require that inspections identifying extinguisher deficiencies shall result in immediate corrective action and execution of the applicable maintenance procedures. These revisions are being tracked by NAMS Action Requests 1839893 and 1839912.
Revision 0                                                                                                                                               Page A-90

NextEra PBNP                         Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.           Requirements/Guidance             Compliance Statement              Compliance Basis                Reference Document IMP-41:     Procedures PC 76 Part 3, "Annual Inspection of Spare, Outside, and North Service Building Hand-Held Dry Chemical Extinguishers," and PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," are being revised to require an on-site supply of recharging materials for dry chemical extinguishers, and that recharging materials are to be provided by the extinguisher manufacturer. These revisions are being tracked by NAMS Action Requests 1839893 and 1839912.
IMP-43:     Procedure PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," is being revised to address extinguisher recharging inthe G03/G04 Diesel Generator Building inaccordance with the applicable sections of NFPA 10-1990. These revisions are being tracked by NAMS Action Request 1839912.
IMP-44:     Procedure PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," is being revised to address the requirements for the quality of carbon dioxide used in portable extinguishers, interms of water and oil contents by weight. This revision is being tracked by NAMS Action Request 1839912.
IMP-45:     Procedure PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," is being revised to ensure that all precautionary pressurization measures are in place (compliant replacement pressure gauges, acceptable pressurization of stored pressure extinguishers, acceptable pressurizing gas). This revision is being tracked by NAMS Action Request 1839912.
IMP-46:     Procedure PC 76 Part 5, "Annual Inspection of Carbon Dioxide Fire Extinguishers," is being revised to require the destruction of fire extinguishers where any of the following conditions exist:
(a)When there exist repairs by soldering, welding, brazing, or use of patching compounds NOTE: For welding or brazing on mild steel shells, consult the manufacturer of the extinguisher.
(b)When the cylinder or shell threads are damaged.
(c)When there exists corrosion that has caused pitting, including under removable nameplate band assemblies.
(d)When the extinguisher has been burned in a fire.
(e)When a calcium chloride type of extinguisher agent was used in a stainless steel extinguisher.
(f)When the shell is of copper or brass construction joined by soft solder or rivets.
(g)AII inverting-type extinguishers.
This revision is being tracked by NAMS Action Request 1839912.
3.8 Fire Alarm and            Fire Alarm and Detection          N/A                               N/A - General statement; No     N/A Detection Systems             Systems.                                                            technical requirements Page A-91 Revision 00                                                                                                                                               Page A-91

NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement    Compliance Basis             Reference Document 3.8.1 Fire Alarm    Alarm initiating devices shall Complies, with Required Alarm initiating devices     R2092-001-002, "Fire Protection be installed in accordance     Action                  comply with NFPA 72-1999     Code Conformance Review," Rev.
with NFPA 72, "National Fire                            Edition as evaluated in     1 / Attachment A, Section 72 Alarm Code@." Alarm                                     R2092-001-002. Fire alarm annunciation shall allow the                           system equipment will be     Fire Protection Evaluation Report proprietary alarm system to                             upgraded as necessary to be (FPER), Rev. 13 / Sections 6.1 and transmit fire-related alarms,                           in accordance with the      6.1.1 supervisory signals, and                               applicable requirements of trouble signals to the control                          NFPA 72. This is being      NFPA 72, "National Fire Alarm room or other constantly                               tracked by LTAM PB-12-0038. Code," 1999 Edition / All attended location from which                           See Table S-2 in Attachment required notifications and                             S.
response can be initiated.
Personnel assigned to the proprietary alarm station shall be permitted to have other duties.
The following fire-related signals shall be transmitted:
3.8.1(1)            Actuation of any fire          Complies                 No Additional Clarification Fire Protection Evaluation Report detection device                                                                    (FPER), Rev. 13/Section 6.1.1 3.8.1(2)            Actuation of any fixed fire    Complies                 No Additional Clarification Fire Protection Evaluation Report suppression system                                                                  (FPER), Rev. 13 / Section 6.1.1 Page A-92 Revision 0  0                                                                                                                   Page A-92

NextEra PBNP                 Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement        Compliance Basis                Reference Document 3.8.1(3)            Actuation of any manual fire   Complies with Clarification Per PC 78 Part 3, Pull boxes    Procedure PC 78 Part 3, "Monthly alarm station                                              are installed in the North      North Service Building Evacuation Service Building.               Alarm Test," Rev. 11 1 All Per FPER Section 5.6.2, Gai-    Fire Protection Evaluation Report tronics communications sets     (FPER), Rev. 13 / Section 5.6.2 provide an acceptable substitute for the reporting of fires in other areas of the plant.
3.8.1(4)            Starting of any fire pump      Complies                    No Additional Clarification     Fire Protection Evaluation Report (FPER), Rev. 13 / Section 6.1.1 3.8.1(5)            Actuation of any fire          Complies                    No Additional Clarification     Fire Protection Evaluation Report protection supervisory device                                                              (FPER), Rev. 13 / Section 6.1.1 3.8.1(6)            The following fire-related     Complies                    No Additional Clarification     Procedure ARB COI B 4-2, "Alarm signals shall be transmitted:                                                              Response Book - Fire Protection and Smoke Detector Panel," Rev.
(6) Indication of alarm                                                                    12 / Section 4.0 system trouble condition 3.8.1.1             Means shall be provided to     Complies                    No Additional Clarification     NANTeL NUC GET PAT 004 (FPL allow a person observing a                                                                 Plant Access Site Specific Training) fire at any location in the                                                                / Fire Protection section, "Fire plant to quickly and reliably                                                              Fighting" communicate to the control room or other suitable constantly attended location.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement     Compliance Basis              Reference Document 3.8.1.2             Means shall be provided to     N/A                       N/A - Section Heading, see   N/A promptly notify the following                            compliance bases below for of any fire emergency in                                 compliance statements for such a way as to allow them                              specific subsections.
to determine an appropriate course of action:
3.8.1.2(1)          General site population in all Complies                  No additional clarification. Procedure NP 1.9.14, "Fire occupied areas                                                                        Protection Organization," Rev. 13/
Section 4.2.2 3.8.1.2(2)          Members of the industrial      Complies                  No Additional Clarification  Fire Protection Evaluation Report fire brigade and other groups                                                         (FPER), Rev. 13 / Section 5.6.2 supporting fire emergency response 3.8.1.2(3)          Off-site fire emergency        Complies                  No Additional Clarification  Procedure EP 7.0, "Emergency response agencies. Two                                                                Facilities and Equipment," Rev. 55 /
independent means shall be                                                            Section 3.0 available (e.g., telephone and radio) for notification of off-site emergency services.
Page A-94 Revision 00                                                                                                                       Page A-94

NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement     Compliance Basis                  Reference Document 3.8.2 Detection     If automatic fire detection is Complies by Previous      Per Enclosure 2 to               Letter NPC-27785 from Fay (WE) required to meet the           NRC Approval             NPC-30601, "...in response to     to Schwencer (NRC) dated performance or deterministic                            the requirements of the SER,      December 20, 1979 / All requirements of Chapter 4,                              the utility developed their own then these devices shall be                             plan for locating fire detectors. Letter NPC-30601 from Schwencer installed in accordance with                            This plan was submitted to the    (NRC) to Burstein (WE) dated NFPA 72, "National Fire                                 Nuclear Regulatory                March 5, 1980 / Enclosure 2 Alarm Code," and its                                    Commission with their letter applicable appendixes.                                  dated December 20, 1979.. Based on our evaluation of the Point Beach letter of December 20, 1979, we find that this method of determining the spacing is adequate. Therefore, the modification.. .and the requirement.. .of the SER with regard to detector locations are adequately resolved..."
Detectors installed using the guidance in the fire detector location plan, as approved by the referenced SER, are still installed at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
Complies with Use of      FPEE 2011-001 justifies the      FPEE 2011-001, "Engineering EEEEs                    acceptability of a lack of        Evaluation for the acceptability of detection in the G03/G04          the Lack of Fire Detection in the Emergency Diesel Generator       DGB Stairwell and Fan Rooms,"
Building stairwell and fan        Rev. 0 / All rooms.
Page A-95 Revision 0 0                                                                                                                          Page A-95

NextEra PBNP                        Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.         Requirements/Guidance               Compliance Statement         Compliance Basis                Reference Document Complies, with Required      Fire detection devices not      R2092-001-002, "Fire Protection Action                       installed in accordance with    Code Conformance Review," Rev.
the PBNP Fire Detector          1 / Attachment A, Section 72 Location Plan comply with NFPA 72-1999 Edition as         Fire Protection Technical evaluated in R2092-001-002. Evaluation (FPTE) 006, "Technical Fire alarm system equipment     Evaluation of Fire Detector will be upgraded as necessary   Location Plan at Point Beach to be in accordance with the    Nuclear Plant," Rev. 1 / All applicable requirements of NFPA 72. This is being          NFPA 72, "National Fire Alarm tracked by LTAM PB-12-0038. Code," 1999 Edition / All See Table S-2 in Attachment S. Implementation items are     NAMS Work Order 40122645, identified below.               "XS-05763 / Install Mechanical Guard for Detector," dated November 20, 2011 IMPLEMENTATION ITEMS:
IMP-66:    A mechanical guard will be provided for heat detector XS-05763 installed in Fire Zone 323, Battery Charger Room to prevent mechanical damage due to the low ceiling height. This work is being tracked by NAMS Work Order 40122645.
3.9 Automatic and           Automatic and Manual                N/A                          N/A - General Statement; No     N/A Manual Water-Based          Water-Based Fire                                                 Technical Requirements Fire Suppression            Suppression Systems.
Systems 3.9.1                       If an automatic or manual           N/A                          N/A - Section Heading, see      N/A water-based fire suppression                                     compliance bases below for system is required to meet                                       compliance statements for the performance or                                               specific subsections.
deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:
Page A-96 Revision 00                                                                                                                                          Page A-96

NextEra PBNP                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.        Requirements/Guidance                Compliance Statement          Compliance Basis                     Reference Document 3.9.1(1)                   NFPA 13, "Standard for the           Complies, with Required       Sprinkler systems were               R2092-001-002, "Fire Protection Installation of Sprinkler            Action                        reviewed against the                 Code Conformance Review," Rev.
Systems"                                                           requirements of NFPA                 1 / Attachment A, Section 13 13-1966 and 1978 Editions in V878-04-TD-05. Justification         Fire Protection Technical of deviations from these             Evaluation (FPTE) 016, "Resolution codes is provided in FPTE            of Identified Deviations to National 016, Sections 13-DEV-1               Fire Protection Code through 13-DEV-29.                   Requirements," Rev. 6 / Sections 13-DEV-1 through 13-DEV-29 Sprinkler systems not reviewed in V878-04-TD-05            NFPA 13, "Standard for the comply with NFPA 13-1989             Installation of Sprinkler Systems,"
Edition as evaluated in              1966 Edition / All R2092-001-002.
Implementation items are            NFPA 13, "Standard for the identified below.                    Installation of Sprinkler Systems,"
1978 Edition / All NFPA 13, "Standard for the Installation of Sprinkler Systems,"
1989 Edition / All Technical Document V878                                                                                                                                    TD-05, "NFPA Code Compliance Assessment," Rev. 0 NAMS Work Order 40177199, "FP
                                                                                                                                   /Brigade Locker Room Pendent Sprinklers Need Return Bends,"
dated August 10, 2012 NAMS Work Order 40122644, "FP I Baffle for Sprinklers between Fire Zones 151 and 156," dated November 20, 2011 IMPLEMENTATION ITEMS:
IMP-1 10: Baffles will be provided for the sprinkler system in the Unit 1 charging pump area where sprinklers are located within 6 feet of each other. This modification is being tracked by NAMS Work Order 40122644.
IMP-124: A modification will be performed to correct the installation of pendent sprinkler not installed on return bends in the fire brigade locker room. This is being tracked by NAMS Work Order 40177199.
Revision 0                                                                                                                                                   Page A-97

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis             Reference Document 3.9.1(2)            NFPA 15, "Standard for        Complies with Clarification Water spray systems were     Fire Protection Technical Water Spray Fixed Systems                                 reviewed against the         Evaluation (FPTE) 016, "Resolution for Fire Protection"                                      requirements of NFPA         of Identified Deviations to National 15-1962 Edition in V878  Fire Protection Code TD-05. Justification of      Requirements," Rev. 6 / Sections deviations from this code is 15DEV-1 through 15-DEV-9 provided in FPTE 016, Sections 15-DEV-1 through    NFPA 15, "Water Spray Systems 15-DEV-9.                    for Fire Protection," 1962 Edition /
All Technical Document V878                                                                                                            TD-05, "NFPA Code Compliance Assessment," Rev. 0 3.9.1(3)            NFPA 750, "Standard on        N/A                         Water mist systems are not   N/A Water Mist Fire Protection                                installed at PBNP.
Systems" 3.9.1(4)            NFPA 16, "Standard for the    N/A                         Foam-water systems are not   N/A Installation of Foam-Water                                installed at PBNP.
Sprinkler and Foam-Water Spray Systems" Page A-98 Revision 0 0                                                                                                                          Page A-98

NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement      Compliance Basis             Reference Document 3.9.2               Each system shall be          Complies                   No Additional Clarification Fire Protection Evaluation Report equipped with a water flow                                                           (FPER), Rev. 13 /Sections 6.1.1 alarm.                                                                               and 6.3.1 Paragraph 2 Procedure PC 77 Part 1, "Refueling Interval Automatic Fire Protection System Valve Trip-Test and Alarm Verification Test Unit 1," Rev. 14 /
All Procedure PC 77 Part 2, "Refueling Interval Automatic Fire Protection System Valve Trip-Test and Alarm Verification Test Unit 2," Rev. 17!
All Procedure PC 77 Part 4, "Annual Automatic Dry-Pipe Fire Protection System Valve Trip-Test and Alarm Verification Test," Rev. 13 / All Procedure PC 77 Part 5, "Automatic Wet-Pipe Fire Protection System Alarm Verification Test," Rev. 14 / All Procedure PC 77 Part 6, "Annual Gas Turbine and Auxiliary Transformer Fire Protection System Valve Trip-Test and Alarm Verification Test," Rev. 15 / All 3.9.3               All alarms from fire          Complies                   No Additional Clarification Fire Protection Evaluation Report suppression systems shall                                                            (FPER), Rev. 13 / Sections 6.1.1, annunciate in the control                                                            6.3.1 Paragraph 2, and 6.3.2 room or other suitable constantly attended location.
Page A-99 Revision 0 0                                                                                                                         Page A-99

NextEra PBNP               Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance        Compliance Statement        Compliance Basis                  Reference Document 3.9.4               Diesel-driven fire pumps     Complies with Clarification Per Section 6.2.1 of the          Fire Hazards Analysis Report shall be protected by                                    FPER, "The fire pumps             (FHAR), dated 8/05 / Appendix C, automatic sprinklers.                                    are... protected similarly to the Rev. 7, Fire Zone 552 service water pumps as described in the fire zone        Fire Protection Evaluation Report hazard evaluation for Fire        (FPER), Rev. 13 / Section 6.2.1 Zone 552."
Per Appendix C of the FHAR, Fire Zone 552, in which the diesel fire pump is located, is protected by a full-coverage, wet-pipe sprinkler system.
3.9.5               Each system shall be         Complies with Clarification Except as noted below, per        Fire Protection Evaluation Report equipped with an OS&Y gate                               Section 6.3.1 of the FPER,        (FPER), Rev. 13 / Section 6.3.1 valve or other approved                                  "Each sprinkler, deluge and       and Table 8.1-1 shutoff valve.                                           standpipe system is equipped with an individual isolation valve."
Page A-100 Revision 00                                                                                                                          Page A-1 00

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                Reference Document Complies by Previous       Per Section 4.3.1(5) of        Letter NPC-27492 from Burstein NRC Approval               NPC-35989 for the G01 and      (WE) to Lear (NRC) dated June 20, G02 diesel generator rooms,     1977 / Attachment, Section 2.3, "The manual sprinkler system    Paragraph 6 in the diesel generator rooms is supplied by the service     Letter NPC-27561 from Burstein water system and utilizes       (WE) to Lear (NRC) dated January nonlisted/approved operating   13, 1978 / Appendix B, Section control valves.. .the manual    PF-20 sprinkler system protecting the diesel generator rooms      Letter NPC-59597 from Schwencer will be upgraded to an          (NRC) to Burstein (WE) dated automatic wet pipe sprinkler    August 2, 1979 / Enclosure 3, system with flow alarm          Safety Evaluation Report annunciation in the control     (NPC-35989), Section 4.3.1(5) room. We conclude that, subject to the implementation   Modification M-605, dated May 25, of the above modification, the  1979 / Section 3.5 existing sprinkler systems conform to the provisions of Appendix A to BTP 9.5-1 and are, therefore, acceptable."
Modification M-605 installed an automatic wet pipe suppression system in the diesel generator rooms. Table 8.1-1 of the Fire Protection Evaluation Report (FPER) identifies automatic wet pipe sprinkler systems in the diesel generator rooms. Thus, the proposed modification has been completed and the use of nonlisted/approved operating control valves for these suppression systems is approved.
The fire suppression system isolation valve arrangement, as approved by the referenced SER, is still installed at PBNP. There have Page A-101 Revision 0 0                                                                                                                     Page A-1 01

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement      Compliance Basis                Reference Document been no plant modifications or other changes that would invalidate the basis for approval.
3.9.6               All valves controlling water- Complies                   No Additional Clarification    Fire Protection Evaluation Report based fire suppression                                                                  (FPER), Rev. 13 / Section 6.3.2 systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.
3.10 Gaseous Fire   Gaseous Fire Suppression      N/A                        N/A - General Statement; No    N/A Suppression Systems Systems.                                                Technical Requirements Page A-102 Revision 0 Revision  0                                                                                                                       Page A-1 02

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.      RequirementslGuidance             Compliance Statement            Compliance Basis                  Reference Document 3.10.1                   If an automatic total flooding    Complies, with Required         N/A - Section Heading, see        NFPA 17, "Standard for Dry and local application             Action                          compliance bases below for        Chemical Extinguishing Systems,"
gaseous fire suppression                                          compliance statements for         1972 Edition / All system is required to meet                                        specific subsections.
the performance or                                                                                  R2092-001-002, "Fire Protection deterministic requirements of                                     NOTE: While not a gaseous         Code Conformance Review," Rev.
Chapter 4, then the system                                        system, a fixed dry chemical      1 / Attachment A, Section 17 shall be designed and                                             system exists for the turbine installed in accordance with                                      bearings. These systems           NAMS Engineering Change the following applicable                                          comply with NFPA 17-1972          274391, "Drawings PBC-219 NFPA codes:                                                       Edition as evaluated in           SHEETS 30, 35, AND 39 R2092-001-002.                    Administrative Changes", dated Implementation items are          March 6, 2012 identified below.
NAMS Action Request 1789890, "NFPA 805 Performance Based Surveillance Frequencies Per EPRI," dated August 1, 2012 IMPLEMENTATION ITEMS:
IMP-55:   Drawings PBC-219 Sheet 30, "Fire Emergency Procedure 4.14 Turbine Building & Aux Building Elev. 44'-0"," and PBC-219 Sheet 35, "Fire Emergency Procedure 4.15 Turbine Building & Aux Building Elev. 44'-0"," are being revised to identify the manual connection locations for the dry chemical suppression systems at each turbine bearing, and the location of the wheeled dry chemical fire extinguishers. These revisions are being tracked by NAMS Engineering Change 274391.
IMP-132:  Performance-based surveillance frequencies will be established for the turbine bearing dry chemical suppression systems as described in Electric Power Research Institute (EPRI) Technical Report TR-1 006756, "Fire Protection Equipment Surveillance Optimization and Maintenance Guide."
Establishment of performance-based frequencies is being tracked by NAMS Action Request 1789890.
3.10.1(1)                NFPA 12, "Standard on             N/A                             Carbon dioxide extinguishing      N/A Carbon Dioxide                                                    systems are not used at Extinguishing Systems"                                            PBNP.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement        Compliance Basis                Reference Document 3.10.1(2)           NFPA 12A, "Standard on        Complies with Clarification Halon systems were reviewed     NFPA 12A, "Standard on Halon Halon 1301 Fire                                           against the requirements of     1301 Fire Extinguishing Systems,"
Extinguishing Systems"                                    NFPA 12A-1987 Edition in        1987 Edition / All V878-04-TD-05. Justification of deviations from this code is Technical Document V878                                                                               provided in FPTE 016,           TD-05, "NFPA Code Compliance Sections 12A-DEV-1 and 12A-     Assessment," Rev. 0, dated DEV-2.                          3/24/99 Fire Protection Technical Evaluation (FPTE) 016, "Resolution of Identified Deviations to National Fire Protection Code Requirements," Rev. 6 / Sections 12A-DEV-1 and 12A-DEV-2 Complies with Use of        FPEE 1999-015 justifies the     Fire Protection Engineering EEEEs                       acceptability of                Evaluation (FPEE) 1999-015, overpressurized halon           "NFPA 12A Code Deviation -
suppression system agent        Halon Agent Storage Container containers.                     Pressures," Rev. 0 / All 3.10.1(3)           NFPA 2001, "Standard on       N/A                         There are no clean agent        N/A Clean Agent Fire                                          extinguishing systems at Extinguishing Systems"                                    PBNP.
3.10.2              Operation of gaseous fire     Complies                    No Additional Clarification     Drawing 35105 E-44, "C900 suppression systems shall                                                                 Annunciator Panel Terminations,"
annunciate and alarm in the                                                               Rev. 8 / All control room or other constantly attended location identified.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement        Compliance Basis              Reference Document 3.10.3              Ventilation system design     Complies with Clarification Per Section 6.4.2 of the      Fire Protection Evaluation Report shall take into account                                   FPER, "In the fire area/zones (FPER), Rev. 13 / Section 6.4.2 prevention from over-                                     where the Halon 1301 system pressurization during agent                               provides fire suppression injection, adequate sealing                               capability, the ventilation to prevent loss of agent, and                             system is controlled in confinement of radioactive                                accordance with applicable contaminants.                                             codes and standards to maintain the necessary gas concentration."
There are no halon suppression systems installed in radiological areas.
3.10.4              In any area required to be    N/A                         Not Applicable. PBNP does     N/A protected by both primary                                 not have any areas required and backup gaseous fire                                   to be protected by both suppression systems, a                                    primary and backup gaseous single active failure or a                                fire suppression systems.
crack in any pipe in the fire suppression system shall not impair both the primary and backup fire suppression capability.
3.10.5              Provisions for locally        Complies                    No Additional Clarification   Procedure OP-AA-100-1002, "Plant disarming automatic                                                                     Status Control Management," Rev.
gaseous suppression                                                                     0 / All systems shall be secured and under strict administrative control.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement       Compliance Basis              Reference Document 3.10.6              Total flooding carbon dioxide N/A                        Not Applicable. There are no  N/A systems shall not be used in                             total flooding carbon dioxide normally occupied areas.                                 systems installed at PBNP.
3.10.7              Automatic total flooding      N/A                        Not Applicable. There are no  N/A carbon dioxide systems shall                             total flooding carbon dioxide be equipped with an audible                              systems installed at PBNP.
pre-discharge alarm and discharge delay sufficient to permit egress of personnel.
The carbon dioxide system shall be provided with an odorizer.
3.10.8              Positive mechanical means     N/A                        Not Applicable. There are no  N/A shall be provided to lock out                            total flooding carbon dioxide total flooding carbon dioxide                            systems installed at PBNP.
systems during work in the protected space.
3.10.9              The possibility of secondary  N/A                        Not Applicable. Halon 1301    Electric Power Research Institute thermal shock (cooling)                                  does not present a risk of    (EPRI) Report NP-7253, "Effects of damage shall be considered                               secondary thermal shock.      Fire Suppressants on Electrical during the design of any                                                               Components in Nuclear Power gaseous fire suppression                                                               Plants," dated March 1991 /
system, but particularly with                                                          Section 1 Summary carbon dioxide.
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NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance           Compliance Statement     Compliance Basis                  Reference Document 3.10.10             Particular attention shall be   Complies with Use of     Per FPTE 017, the use of          FPTE 017, "Evaluation of the given to corrosive              EEEEs                    Halon 1301 as a fire              Corrosive Effects of Halon 1301 characteristics of agent                                 suppression agent at PBNP         Decomposition Products," Rev. 0 /
decomposition products on                                will not result in degradation of All safety systems.                                          equipment function due to exposure to Halon 1301 decomposition products.
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                                 Technical Requirements installation requirements for passive protection features.
Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals. Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.
Page A-107 Revision 00                                                                                                                          Page A-107

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement       Compliance Basis                 Reference Document 3.11.1 Building     Each major building within    Complies with Use of       The Primary Auxiliary            NFPA 80A, "Recommended Separation          the power block shall be      EEEEs                      Building, South Service          Practice for Protection of Buildings separated from the others by                             Building, and North Service      from Exterior Fire Exposures,"
barriers having a designated                             Building are separated from      1996 Edition / All fire resistance rating of 3                              the Turbine Building by 3-hour hours or by open space of at                             barriers.                        Fire Protection Evaluation Report least 50 ft (15.2 m) or space                                                             (FPER), Rev. 13 / Section 5.1.2 that meets the requirements                              The Circulating Water Pump of NFPA 80A,                                              House, G03/G04 Diesel           Drawing PBC-218 Sheet 1, "Site "Recommended Practice for                                Generator building,              Plan," Rev. 11 / All Protection of Buildings from                             Warehouses No. 1-4, Exterior Fire Exposures."                                Switchgear Enclosure, Gas        FPEE 2012-001, "Engineering Turbine building, Extension      Evaluation for the Acceptability of Exception: Where a                                       Building, Fuel Oil Pump          Separation between Power Block House, and the South Gate       Buildings," Rev. 0 / All performance-based analysis House are all separated from determines the adequacy of the Turbine Building, Auxiliary building separation, the                                 Building, and Reactor requirements of 3.11.1 shall                             Buildings by open space not apply.                                               greater than 50 feet.
Per section 5.1.2 of the FPER, "Walls, floors, and ceilings enclosing fire areas utilize fire resistant construction with a minimum concrete thickness of ten inches. Using the 1977 edition of the Pre-stressed Concrete Institute (PCI) publication,
                                                                             'Design for Fire Resistance,' it has been estimated that for the worst case condition using siliceous aggregate, 6.2 inches of concrete would be required for a 3-hour fire rating. Therefore, plant barriers with a minimum thickness of 10 inches are considered to provide an equivalent 3-hour fire rating."
FPEE 2012-001 justifies the acceptability of fire barrier Page A-108 Revision 0  0                                                                                                                         Page A-108

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis            Reference Document anomalies in barriers separating power block buildings.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance          Compliance Statement        Compliance Basis                 Reference Document 3.11.2 Fire Barriers Fire barriers required by      Complies with Clarification Per Section 5.1.2 of the         Fire Hazards Analysis Report Chapter 4 shall include a                                  FPER, "Walls, floors, and        (FHAR), Rev. 5 / Sections 2.0 and specific fire-resistance                                   ceilings enclosing fire areas    3.1.d rating. Fire barriers shall be                             utilize fire resistant designed and installed to                                  construction with a minimum      Fire Protection Evaluation Report meet the specific fire                                     concrete thickness of ten        (FPER), Rev. 13 / Section 5.1.2 resistance rating using                                    inches. Using the 1977 edition assemblies qualified by fire                               of the Pre-stressed Concrete     NFPA 251, "Standard Methods of tests. The qualification fire                              Institute (PCI) publication,     Tests of Fire Endurance of Building tests shall be in accordance                               "Design for Fire Resistance," it Construction and Materials," 1999 with NFPA 251, "Standard                                   has been estimated that for      Edition / All Methods of Tests of Fire                                   the worst case condition using Endurance of Building                                      siliceous aggregate, 6.2 Construction and Materials,"                               inches of concrete would be required for a 3-hour fire or ASTM E 119, "Standard rating. Therefore, plant Test Methods for Fire Tests barriers with a minimum of Building Construction and                               thickness of 10 inches are Materials."                                                considered to provide an equivalent 3-hour fire rating.
                                                                                "The construction of hollow concrete block walls has been evaluated in accordance with accepted standard designs such as UL fire resistance ratings to ensure the protection provided is appropriate for the area protected. Other special cases (e.g., metal wall panels with fire resistant coatings) have been evaluated to ensure the fire resistance provided is commensurate with the boundary of the area protected. Underwriters' Laboratories, Inc. listed fire doors and dampers have been installed to protect barrier door and duct openings commensurate with the boundary protection for the area. Doors and dampers receive periodic surveillance Page A-hO Revision 00                                                                                                                            Page A-1 10

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement       Compliance Basis                  Reference Document to ensure operability. Special cases, such as door openings protected with spray nozzles or solid steel ventilation ducts penetrating fire barriers, have been evaluated to determine the equivalent fire resistance rating as described in specific fire zone hazard evaluations."
Per Section 5.1.5, "Redundant safe shutdown related equipment, components and systems are provided with adequate spatial separation or are separated by fire resistant barriers as described in the safe shutdown analysis according to the separation requirements of 10 CFR 50, Appendix R, Section 11I.G.
Fire areas are bounded by 3-hour rated fire barriers, spatial separation, or other configurations considered to provide separation equivalent to fire rated barriers or adequate for the hazard in accordance with GL 86-10."
Per Section 5.1.11,
                                                                          %The Unit 1 Turbine Building south wall is protected by an open-head deluge water spray to compensate for not having a barrier with sufficient rating to withstand the effects of an adjacent transformer fire...
                                                                          - Closed head water spray nozzles supplied by a preaction sprinkler system protect the northeast corner of the Gas Turbine Building from exposure of a Station Auxiliary Transformer fire."
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NextEra PBNP             Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                   Reference Document Per Section 2.0 of the FHAR, "Fire Barrier: Those components of construction (walls, floors and their supports, including beams, joists, columns, penetration seals or closures, fire doors and fire dampers) that are rated by approving laboratories in hours of resistance to fire and are used to prevent the spread of fire."
Section 3.1 .d, "Fires are considered to be passively contained where Appendix R separation criteria are satisfied such as adequate spatial separation, fire barriers or their equivalent as described in granted exemptions or approved FPEEs. The containment structures are considered to provide at least a 3 hour fire rating."
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                   Reference Document Complies by Previous       Per Section 3.4.7.4 of the        Letter NPC-27492 from Burstein NRC Approval              Attachment to NPC-27492,           (WE) to Lear (NRC) dated June 20,
                                                                         "...Outdoor transformers are       1977 / Attachment, Sections protected by automatic deluge     3.4.7.4 and 4.1.8 systems and are more than 50 feet from safety-related           Letter NPC-29597 from Schwencer structures, with interposing 2-    (NRC) to Burstein (WE) dated hr rated walls. These             August 2, 1979 / Enclosure 3, transformers are not               Safety Evaluation Report considered a hazard to safety-     (NPC-35989), Section 5.15.4 related systems or safe plant shutdown. This subject is also addressed in Section 4.1.8."
Section 4.1.8 of the Attachment to NPC-27492 limits the scope of the term "outdoor transformers" as follows: "The main, unit auxiliary and station auxiliary transformers are oil cooled and are located outside of the plant buildings."
Per Section 5.15.4 of NPC-35989, "The oil-filled transformers are protected by automatic water spray systems. Building walls adjacent to the transformers are protected by a water spray system which provides a water curtain for the exterior walls in the event of a transformer fire.. .the fire protection for the yard area satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
The separation of the transformers and adjacent plant structures, as approved Page A-113 Revision 0 Revision 0                                                                                                                       Page A-1 13

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                Reference Document by the referenced SER, still exists at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement       Compliance Basis                 Reference Document Complies with Use of       FPEE 1999-002 justifies the      Fire Protection Engineering EEEEs                      acceptability of the barriers    Evaluation (FPEE) 1999-002, separating the Train A Fuel      "Diesel Generators G03 & G04 Oil Transfer Pump cables for     Duct Banks & Manholes," Rev. 1 /
Diesel Generators G01 and        All G02 in Fire Area A70 and Train B Diesel Generators        Fire Protection Engineering G03 and G04 in Fire Area 68      Evaluation (FPEE) 1999-004, contained in the duct banks      "Turbine Building Embedded and manholes between the         Conduits," Rev. 0 / All G03/G04 Diesel Generator Building and the Turbine         Fire Protection Engineering Building.                        Evaluation (FPEE) 1999-008, "Control Building Fire Barrier FPEE 1999-004 justifies the      Features," Rev. 3 / All acceptability of the barriers separating the Train A Fuel      Fire Protection Engineering Oil Transfer Pump cables for     Evaluation (FPEE) 1999-012, "Fire Diesel Generators G01 and        Area Boundary Evaluation, G02 and Train B Diesel           Separation of Unit 1 and Unit 2 Generators G03 and G04           Fagades from Fire area A01-E,"
routed through duct banks        Rev. 1 /All underneath the 8' elevation floor of the Unit 2 Turbine      Fire Protection Engineering Building.                        Evaluation (FPEE) 1999-016, "Fire Separation of the Cable Spreading FPEE 1999-008 justifies the      Room and Control room Via a 2-Hr acceptability of barriers in the Fire Rated concrete Block Wall,"
control building boundary that   Rev. 0 / All do not carry the required fire rating.                          Fire Protection Engineering Evaluation (FPEE) 1999-018, FPEE 1999-012 justifies the      "Evaluation of Fire Propagation acceptability of the boundary    through Floor Trenching at the 8' separating Fire Zones 245        PAB," Rev. 0 / All and 250 from Fire Zone 524, and Fire Zones 246, 251, 222,    Fire Protection Engineering 223, and 224 from Fire Zone      Evaluation (FPEE) 2002-002, "3-596.                             Hour Fire Rated Gypsum Board Fire Barrier in the Auxiliary FPEE 1999-016 justifies the      Feedwater Pump Room," Rev. 0 I acceptability of the barrier     All between the Control Room kitchen and the Control Room     Fire Protection Engineering Page A-115 Revision 00                                                                                                                        Page A-1 15

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                   Reference Document and Cable Spreading Room.         Evaluation (FPEE) 2003-001, "Evaluation of the 3-Hour Fire FPEE 1999-018 justifies the       Rated Spancrete Ceiling Assembly acceptability of an unsealed      Separating the Auxiliary Feedwater pipeway trench that passes        Tunnel and Pump Room," Rev. 0 /
beneath the fire barrier that     All separates the Safety Injection/Containment Spray       Fire Protection Engineering Pump Room and the                 Evaluation (FPEE) 2006-006, Component Cooling Water           "Evaluation of Checker Steel Plate Pump Room.                        Floor Penetration Seal Number M-1-5-1-F22," Rev. 0 / All FPEE 2003-001 justifies the acceptability of separation       Fire Protection Engineering provided by the ceiling           Evaluation (FPEE) 2006-007, assembly that separates the       "Evaluation of Indeterminate Fire Auxiliary Feedwater Tunnel         Barrier Rating, PAB 8ft to Ul and the Auxiliary Feedwater       Fagade, Rev. 0 / All Pump Room.
Fire Protection Engineering FPEE 2006-006 justifies the       Evaluation (FPEE) 2013-001, acceptability of an unrated       "Engineering Evaluation for the steel checker plate cover over    Acceptability of Separation the Boric Acid Batch Tank in      between Primary Auxiliary Building the barrier between Fire          Fire Areas," Rev. 0 / All Zones 237 and 271.
FPEE 2006-007 justifies the acceptability of the fire barrier separating the 8'-0" Auxiliary Building and the Unit 1 Fagade.
FPEE 2013-001 justifies the acceptability of unrated fire area barriers and openings in fire area barriers in the Primary Auxiliary Building.
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NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement        Compliance Basis                 Reference Document 3.11.3 Fire Barrier Penetrations in fire barriers  Complies with Clarification Per Section 5.1.3.1 of the       Fire Protection Evaluation Report Penetrations        shall be provided with listed                              FPER, "Fire dampers in rated     (FPER), Rev. 13 / Sections 5.1.3.2 fire-rated door assemblies or                              barriers are rated               and 5.1.11 listed rated fire dampers                                  commensurate with the fire having a fire resistance                                   resistance rating of the rating consistent with the                                 barrier. Solid steel ventilation designated fire resistance                                 ducts without fire dampers rating of the barrier as                                   that penetrate the fire barriers determined by the                                          are evaluated to determine performance requirements                                   the equivalent fire resistance established by Chapter 4.                                  rating. Fire dampers receive (See 3.11.3.4 for penetration                              periodic surveillance to ensure seals for through penetration                              operability."
fire stops.) Passive fire                                  Per Section 5.1.3.2, "Fire Doors in barrier walls, protection devices such as including frame and doors and dampers shall                                    installation hardware, are conform with the following                                 rated commensurate with the NFPA standards, as                                         fire resistance rating of the applicable:                                                barrier. Only labeled or listed doors are used. Where listed Exception: Where fire area                                 doors are not available for boundaries are not wall-to-                                specific applications wall, floor-to-ceiling                                     engineering evaluations have boundaries with all                                        been performed.
penetrations sealed to the                                 Entranceways in fire barriers fire rating required of the                                without doors that are boundaries, a performance-                                 protected by spray curtains based analysis shall be                                    are discussed in Section required to assess the                                     5.1.11."
adequacy of fire barrier                                   Per Section 5.1.11, "The use forming the fire boundary to                               of water curtains provides a determine if the barrier will                              method of utilizing active withstand the fire effects of                              systems in order to the hazards in the area.                                   compensate for and enhance Openings in fire barriers                                  the effectiveness of shall be permitted to be                                   unqualified physical fire protected by other means as                                barriers. The use of water acceptable to the AHJ.                                     curtains at PBNP has been limited.. .as follows:...
                                                                               - Closed-head water spray nozzles supplied by a wet-pipe sprinkler system protect doorless openings at the 8' Page A-117 Revision 0 0                                                                                                                          Page A-1 17

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis              Reference Document elevation of the Primary Auxiliary Building in designated fire barriers..."
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement       Compliance Basis                   Reference Document Complies by Previous       Per Page 6 of the Exemption        Letter NPC-28413 from Fay (WE)
NRC Approval               Attachment to NPC-29916, for       to Clark (NRC) dated July 20, 1983 the Unit 1 Motor Control           / Fire Zones 1, 2, 3, and 4 Center Room, "Fire Zone 1 is located in the Auxiliary           Letter NPC-29916 from Butcher Building at elevation 8'-0". It is (NRC) to Fay (WE) dated July 3, not separated from adjoining       1985 / Exemption Attachment, areas by fire-rated barriers.      Pages 6, 7, 9, 10, 11, and 13 Access to the area is by 8-feet high doorless entrance ways.
By letter dated July 20, 1983 the licensee committed to install water curtains in each unprotected entranceway to prevent the spread of products of combustion from postulated fires into the zone."
Per Page 7, for the Unit 2 Motor Control Center Room, "Fire Zone 4 is located in the Auxiliary Building at elevation 8'-0" and is not separated from adjoining areas by fire-rated walls. Access to the area is via 8-feet-high doorless entranceways. By letter dated July 20, 1983, the licensee committed to install water curtains in each unprotected entranceway to prevent the spread of products of combustion from postulated fires into the zone."
Per Page 9, "Based on the above evaluation, the staff concludes that the proposed modifications and commitments with the existing fire protection for Motor Control Center Rooms for Unit 1 and Unit 2 provide a level of fire protection equivalent to the technical requirements of Section III.G of Appendix R..."
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document Per Page 10, for the Safety Injection and Containment Spray Pump Room, "Fire Zone 2 is located in the Auxiliary Building on elevation 8'-0". It is not separated from adjoining areas by fire-rated walls. Access to the area is by 8 feet high doorless entranceways. By letter dated July 20, 1983, the licensee committed to install a water curtain at each entranceway into the zone.
Per Page 11, "Based on the above evaluation, the staff concludes that the proposed modifications and the existing protection for the safety injection and containment spray pump room provide a level of fire protection equivalent to the technical requirements of Section IIl.G."
Per Page 11, for the Component Cooling Water Pump Room, "Fire Zone 3 is located in the Auxiliary Building on elevation 8'-0". It is not separated from adjoining areas by fire-rated walls. Access to the area is by 8 feet high doorless entranceways. By letter dated July 20, 1983, the licensee committed to install water curtains in each unprotected entranceway to prevent the spread of products of combustion from postulated fires into the zone."
Per Page 13, "Based on the above evaluation, the staff concludes that the proposed Revision 0                                                                                                                Page A-1 20

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                Reference Document modifications, the additional commitments, and the existing protection for the component cooling water pump room provides a level of fire protection equivalent to the technical requirements of Section M.G."
The water curtains protecting doorways, as approved by the referenced SER, still exist at PBNP. There have been no plant modifications or other changes that would invalidate the basis for approval.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                  Reference Document Complies with Use of       FPEE 1999-003 justifies the      Fire Protection Engineering EEEEs                      acceptability of an unsealed     Evaluation (FPEE) 1999-003, plugged hatchway, an exhaust     "Diesel Generators G03 & G04 fan opening, drain openings,     Building Boundaries," Rev. 1 / All larger than normal door gaps, duct bay penetrations, and an    Fire Protection Engineering air intake louver without a fire Evaluation (FPEE) 1999-006, damper on fire barriers that     "Service Water Duct Banks &
separate Fire Area A61 (Fuel     Manholes," Rev. 2 / All Oil Pump Room) and Fire Area A71 (Train B Areas) in      Fire Protection Engineering the G03/G04 Diesel               Evaluation (FPEE) 1999-009, Generator Building.              "Undampered Ventilation Ducts in Significant Fire Barriers in the FPEE 1999-006 justifies the      Control, Primary Auxiliary and acceptability of unrated         Turbine Buildings," Rev. 2 / All manhole covers and manhole ceiling penetrations between     Fire Protection Engineering the service Water Pump           Evaluation (FPEE) 1999-010, Room and the Control             "Auxiliary Building 26' Elevation Building.                        Separation," Rev. 1 / All FPEE 1999-009 justifies the      Fire Protection Engineering acceptability of undampered      Evaluation (FPEE) 2006-006, ventilation ducts in the Unit 1  "Evaluation of Checker Steel Plate and Unit 2 Containment           Floor Penetration Seal Number Fagades, the Control and         M-1-5-1-F22," Rev. 0 / All Primary Auxiliary Buildings, and the Unit 1 and Unit 2        Fire Protection Engineering Turbine Buildings.               Evaluation (FPEE) 2013-001, "Engineering Evaluation for the FPEE 1999-010 justifies the      Acceptability of Separation acceptability of open            between Primary Auxiliary Building passageways and various          Fire Areas," Rev. 0 / All unsealed penetrations between the north and south      Fire Protection Technical wings of the Primary Auxiliary   Evaluation (FPTE) 016, "Resolution Building and the Monitor Tank    of Identified Deviations to National Room, Fire Zone 187.             Fire Protection Code Requirements," Rev. 6 / Section FPEE 2006-006 justifies the      13-DEV-20 acceptability of an unrated steel checker plate cover over the Boric Acid Batch Tank in Page A-122 Revision 00 Revision                                                                                                                           Page A-1 22

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis               Reference Document the barrier between Fire Zones 237 and 271.
FPEE 2013-001 justifies the acceptability of unrated fire area barriers and openings in fire area barriers inthe Primary Auxiliary Building.
13-DEV-20 in FPTE 016 justifies the acceptability of the hydraulic design of the suppression system providing water curtains in Fire Zones 142, 151, 156, and 166.
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NextEra PBNP              Attachment A - NEI 04-02 Table B-I Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance       Compliance Statement      Compliance Basis                 Reference Document 3.11.3(1)           NFPA 80, "Standard for Fire Complies with Use of       FPEE 1999-003 justifies the     FPEE 1999-003, "Diesel Doors and Fire Windows"     EEEEs                     acceptability of an excessive    Generators G03 & G04 Building gap under the fire door          Boundaries," Rev. 1 /All separating the Fuel Oil Pump Room and the G03 Diesel         FPEE 1999-008, "Control Building Generator Room.                  Fire Barrier Features," Rev. 3 / All FPEE 1999-008 justifies the     FPEE 1999-012, "Fire Area acceptability of doors with a    Boundary Evaluation, Separation of 1.5-hour rating and windows     Unit 1 and Unit 2 Facades from Fire with less than a 3-hour rating   Area A01-E," Rev. 2 / All installed in a 3-hour barrier.
FPEE 2001-002, "Evaluation of Fire FPEE 1999-012 justifies the     Propagation Beneath Auxiliary acceptability of unrated doors   Feedwater Pump Room Doors separating the Facades and       DOOR-321, DOOR-322, the Auxiliary Building.          DOOR-323 & DOOR-324," Rev. 0/
All FPEE 2001-002 justifies the acceptability of clearances      FPEE 2011-002, "Engineering between the floor and several   Evaluation for the Acceptability of doors, which exceeds 3/4".       Fire Doors Reviewed in Accordance with NFPA 80," Rev. 0 FPEE 2011-002 justifies the     / All acceptability of doors and frames that do not meet the required rating of the barriers in which they are installed.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis              Reference Document Complies, with Required    Fire doors comply with NFPA  NFPA 80, "Standard for Fire Doors Action                     80-1967 and 1990 Editions as and Windows," 1967 Edition / All evaluated in R2092-001-002.
Implementation items are     NFPA 80, "Standard for Fire Doors identified below.            and Windows," 1990 Edition / All R2092-001-002, "Fire Protection Code Conformance Review," Rev.
1 / Attachment A, Sections 80.1967 and 80.1990 NAMS Action Request 1399522, "RMP 9011-1 Rev. 12 (NFPA 805),"
dated November 4, 2010 NAMS Action Request 1399529, "RMP 9011-2, Rev. 8 (NFPA 805),"
dated November 4, 2010 NAMS Action Request 1768544, "Merge Fire Doors Required by NFPA 805 into One Procedure,"
dated May 18, 2012 NAMS Engineering Change 276911, "FPEE 1999-008 Rev. 4 Control Building Fire Barrier Features" NAMS Work Request 00045310, "Doors / Removed Abandoned Doors Fill with Fire Rated Wall",
dated October 7, 2010 NAMS Work Order 213047, "Replace with Construction Wall,"
dated March 8, 2006 NAMS Work Order 40150402, "NSB DOOR-301A / Door Is Breaking Apart," dated March 9, 2012 IMPLEMENTATION ITEMS:
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NextEra PBNP                       Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.        Requirements/Guidance              Compliance Statement           Compliance Basis                     Reference Document IMP-12:   Door Inspections," are being revised to require that unused doors and windows shall be filled with construction equivalent to that of the wall, or that an engineering evaluation be performed to justify the acceptability of the unused doors and windows. These procedure changes are being tracked by NAMS Action Requests 1399522 and 1399529, respectively.
IMP-13:   FPEE 1999-008, "Control Building Fire Barrier Features," is being revised to add a justification of the acceptability of fire shutters VNCR-6550, VNCR-6552, and VNCR-6553 inthe Turbine Building/Control Building interface, and signage is being added to these shutters to ensure that they are not manipulated from their closed position. This is being tracked by NAMS Engineering Change 276911.
IMP-19:   A work request has been generated to remove Door NSB DOOR-417B and fill the opening with fire rated construction equivalent to that of the wall.
This is being tracked by NAMS Work Order 213047.
IMP-20:   A work request has been generated to replace the glazing in NSB DOOR-301A with fire rated glazing. This is being tracked by NAMS Work Order 40150402.
IMP-37:   Fire door inspection procedures RMP 9011-1, "Safe Shutdown Fire Door Inspections," and RMP 9011-2, "Industrial Fire Door, HELB Door, Seismic 2/1 Door and Flood Door Inspections," will be revised as necessary to require all doors credited inthe NFPA 805 program to meet the inspection, testing, and maintenance requirements of NFPA 80. This is being tracked by NAMS Action Request 1768544.
3.11.3(2)                  NFPA 90A, "Standard for the        Complies with Use of           FPEE 1999-009 justifies the          FPEE 1999-009, "Undampered Installation of Air-               EEEEs                          acceptability of undampered          Ventilation Ducts in Significant Fire Conditioning and Ventilating                                      ventilation ducts that               Barriers in the Control, Primary Systems"                                                          penetrate fire barriers.             Auxiliary and Turbine Buildings,"
Rev. 2 / All Page A-126 Revision 00                                                                                                                                               Page A-1 26

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       Requirements/Guidance              Compliance Statement           Compliance Basis                    Reference Document Complies, with Required        Fire dampers comply with            NFPA 90A, "Standard for the Action                         NFPA 90A-1978 and 2002              Installation of Air Conditioning and Editions as evaluated in            Ventilating Systems," 1978 Edition /
R2092-001-002.                      All Implementation items are identified below.                   NFPA 90A, "Standard for the Installation of Air-Conditioning and Ventilating Systems," 2002 Edition /
All R2092-001-002, "Fire Protection Code Conformance Review," Rev.
1 / Attachment A, Sections 90A.1978 and 90A.2002 NAMS Action Request 1753403, "Drawing M-1 11 Revision Per MR 99-034 Modification," dated April 9, 2012 NAMS Action Request 1789890, "NFPA 805 Performance Based Surveillance Frequencies Per EPRI," dated August 1, 2012 IMPLEMENTATION ITEMS:
IMP-69:   Drawing M-1 11, "Heating and Ventilation Turbine Building Plan Area 3 EL. 8'-0"," will be revised to reflect the changes of additional dampers installed in the ductwork and the wall in the Auxiliary Feedwater Pump Room as a result of Modification MR 99-034. This revision is being tracked by NAMS Action Request 1753403.
IMP-133:  Performance-based surveillance frequencies will be established for fire dampers that do not meet deterministic testing frequencies per NFPA 90A as described in Electric Power Research Institute (EPRI) Technical Report TR-1006756, "Fire Protection Equipment Surveillance Optimization and Maintenance Guide." Establishment of performance-based frequencies is being tracked by NAMS Action Request 1789890.
Page A-127 Revision 00                                                                                                                                             Page A-127

NextEra PBNP                   Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance         Compliance Statement        Compliance Basis             Reference Document 3.11.3(3)              NFPA 101, "Life Safety        Complies with Clarification The requirements of NFPA     NFPA 101, "Life Safety Code,"
Code"                                                     101 applicable to fire doors 2000 Edition / Sections 8.2.3.2.1 and fire dampers are bounded and 9.2.1 by NFPA 80 and NFPA 90A.
NFPA 101 Section 8.2.3.2.1 refers to NFPA 80, and NFPA 101 Section 9.2.1 refers to NFPA 90A. Compliance with these codes is addressed in Sections 3.11.3(1) and 3.11.3(2) of this review.
3.11.4 Through         Through penetration fire      N/A                         N/A - Section Heading, see   N/A Penetration Fire Stops stops for penetrations such                               compliance bases below for as pipes, conduits, bus                                   compliance statements for ducts, cables, wires,                                     specific subsections.
pneumatic tubes and ducts, and similar building service equipment that pass through fire barriers shall be protected as follows.
Page A-128 Revision 00                                                                                                                         Page A-1 28

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance          Compliance Statement        Compliance Basis                Reference Document 3.11.4(a)           The annular space between      Complies with Clarification Per Section 5.1.3.3 of the      Fire Protection Evaluation Report the penetrating item and the                               FPER, "Fire penetration seals   (FPER), Rev. 13 / Section 5.1.3.3 through opening in the fire                                are provided for the barrier shall be filled with a                             appropriate mechanical and      Procedure DG-F02, "Fire Barrier qualified fire-resistive                                   electrical fire barrier         Penetration Seal Typical Detail penetration seal assembly                                  penetrations in credited fire   Designs," Rev. 5 / All capable of maintaining the                                 barriers. Penetration seals are fire resistance of the fire                                installed in accordance with barrier. The assembly shall                                approved seal designs by a be qualified by tests in                                   qualified installer. The seal accordance with a fire test                                designs have been tested and protocol acceptable to the                                 are qualified to provide a fire AHJ or be protected by a                                   resistance rating listed fire-rated device for                               commensurate with the barrier in, which they are installed."
the specified fire-resistive period.
Per Section 1.0 of DG-F02, "The design guideline provides typical design details for Fire Barrier Penetration Seals. These details are the approved designs used at Point Beach Nuclear Plant for replacement, repair or installation of fire barrier penetration seals."
Page A-129 Revision 00                                                                                                                           Page A-1 29

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document Complies with Use of       FPEE 1999-003 justifies the     FPEE 1999-003, "Diesel EEEEs                      acceptability of an unsealed    Generators G03 & G04 Building plugged hatchway, an exhaust    Boundaries," Rev. 1 / All fan opening, drain openings, larger than normal door gaps,   Fire Protection Engineering duct bay penetrations, and an    Evaluation (FPEE) 1999-008, air intake louver without a fire "Control Building Fire Barrier damper on fire barriers that     Features," Rev. 3 / All separate Fire Area A61 (Fuel Oil Pump Room) and Fire         Fire Protection Engineering Area A71 (Train B Areas) in      Evaluation (FPEE) 1999-010, the G03/G04 Diesel               "Auxiliary Building 26' Elevation Generator Building.             Separation," Rev. 1 / All FPEE 1999-008 justifies the     Fire Protection Engineering acceptability of an unrated      Evaluation (FPEE) 1999-012, "Fire maintenance access opening,     Area Boundary Evaluation, and damper openings and fire     Separation of Unit 1 and Unit 2 rated and unrated panels        Fagades from Fire Area A01-E,"
protected with hotboard seal    Rev. 1 /All material.
Fire Protection Engineering FPEE 1999-010 justifies the     Evaluation (FPEE) 2000-002, acceptability of open            "Qualification of ICMS Product 60 passageways and various         Fire Penetration Seal for 3-Hour unsealed penetrations           Fire-Rated Gypsum Board Walls,"
between the north and south     Rev. 0 / All wings of the Primary Auxiliary Building and the Monitor Tank   Fire Protection Engineering Room, Fire Zone 187.            Evaluation (FPEE) 2001-004, "Evaluation of the Adequacy of Fire FPEE 1999-012 justifies the     Penetration Seals M-7-3-7-$8 &
acceptability of unrated         M-7-3-23-E24," Rev. 0 / All penetration seals between Fire Area A01-E and the Unit    Fire Protection Engineering 1 and Unit 2 Fagades.           Evaluation (FPEE) 2002-001, "Qualification of PCI-Promatec SE-FPEE 2003-003 justifies the     Foam Fire Penetration Seal for 3-acceptability of oversized       Hour Fire-Rated Gypsum Board penetrants in seals M-7-3     Walls," Rev. 1 / All W2 and M-7-3-5-W3 and the use of a non-typical seal detail Fire Protection Engineering for penetration M-5-4-21-S10. Evaluation (FPEE) 2002-002, "3-Hour Fire Rated Gypsum Board Page A-130 Revision 00                                                                                                                       Page A-1 30

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                Reference Document FPEE 2006-004 justifies the    Fire Barrier in the Auxiliary acceptability of fire barrier  Feedwater Pump Room," Rev. 0 /
penetration seals installed in All wall or floor openings where the critical characteristic,   Fire Protection Engineering maximum free area or           Evaluation (FPEE) 2003-003, opening size, as outlined in   "Evaluation of the Adequacy of Fire DG-F02, has been exceeded. Penetration Seals M-7-3-5-W2, M-7-3-5-W3, and M-5-4-21-S10,"
FPEE 2006-005 justifies the    Rev. 1 /All acceptability of penetrations that connect the RHR pipeway   Fire Protection Engineering and the Tendon Gallery that    Evaluation (FPEE) 2006-001, are sealed with grout but not  "Minimum Spacing Requirements to a depth that will achieve a for Penetration Seal Typical Details 3-hour rating.                 M-W-03-02, M0209, H0203, M-352-10, and W-E-20-04," Rev. 0 FPEE 2008-001 justifies the    / All acceptability of unrated penetration seals between the  Fire Protection Engineering Cable Spreading Room and       Evaluation (FPEE) 2006-002, the Control Room.              "Evaluation of Boot Seal Assemblies on Pipes over 2 Inches FPEE 2013-001 justifies the    in Diameter," Rev. 1 /All acceptability of unrated fire area barriers and openings in  Fire Protection Engineering fire area barriers in the      Evaluation (FPEE) 2006-003, Primary Auxiliary Building.    "Evaluation of Penetration Seals with Structural Steel Penetrants,"
Rev. 0 / All Fire Protection Engineering Evaluation (FPEE) 2006-004, "Evaluation of Maximum Free Area for Silicone Foam Seals Exceeding DG-F02 Limitations," Rev. 0 / All Fire Protection Engineering Evaluation (FPEE) 2006-005, "RHR Pipeway and Fagade Tendon Gallery Fire Area Boundaries, Units 1 and 2," Rev. 0 / All Fire Protection Engineering Page A-I 31 Revision 00                                                                                                                     Page A-1 31

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis            Reference Document Evaluation (FPEE) 2008-001, "Evaluation of the Ability of Penetrations M-0-39-F2, F3, F4 and M-3-3-42-N3, N4, N5 to Provide an Adequate Fire Barrier,"
Rev. 0 / All Fire Protection Engineering Evaluation (FPEE) 2013-001, "Engineering Evaluation for the Acceptability of Separation between Primary Auxiliary Building Fire Areas," Rev. 0 / All Fire Protection Technical Evaluation (FPTE) 001, "Technical Evaluation of Fire Barrier Penetration Seals, Fire Rated Wrapping and Cable Tray Fire Stops at Point Beach Nuclear Plant," Rev. I / All Page A-132 Revision 00                                                                                                                 Page A-1 32

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. RequirementslGuidance      Compliance Statement      Compliance Basis                  Reference Document Complies, with Required    Unsealed bus duct                NAMS Action Request 1741299, Action                     penetrations in the floor of the "Caution Tags on 1B03/04 and cable spreading room to the      2B03/04 Crossties not Needed,"
auxiliary feedwater pump         dated March 5, 2012 rooms will be provided with penetration seals. This is       NAMS Engineering Change being tracked by NAMS            271218, "Install a Modification to Engineering Changes 271218       the 480-Volt B-03 to B-04 Bus Ties and 278396; and NAMS             to Provide a 3-hr Rated Fire Action Request 1741299. See      Barrier" Table S-2 in Attachment S.
NAMS Engineering Change Unsealed bus duct                278396, "Fire Barrier for B-03 /
penetrations in the floor of the B-04 Cross Tie" non-vital switchgear room to the vital switchgear room will be provided with penetration seals. This is being tracked by MOD-27 in Table S-2 in Attachment S.
Page A-133 Revision 00                                                                                                                       Page A-1 33

NextEra PBNP                  Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. 'RequirementslGuidance           Compliance Statement        Compliance Basis                   Reference Document 3.11.4(b)            Conduits shall be provided      Complies with Clarification Per Section 5.1.3.4 of the         Fire Protection Evaluation Report with an internal fire seal that                             FPER, "Conduits that               (FPER), Rev. 13 / Section 5.1.3.4 has an equivalent fire-                                     penetrate fire barriers have resistive rating to that of the                             been conservatively provided fire barrier through opening                                with internal seals, either at fire stop and shall be                                      the wall or at the first available permitted to be installed on                                access point of the conduit.
either side of the barrier in a                             Small conduits that are location that is as close to                                provided for items such as the barrier as possible.                                    lighting circuits and are embedded in the concrete Exception: Openings inside                                  construction are not conduit 4 in. (10.2 cm) or                                  considered to be paths for the less in diameter shall be                                   spread of fire and have not been sealed."
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.
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NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis               Reference Document Complies with Use of       FPEE 1999-008 justifies the   Fire Protection Engineering EEEEs                      acceptability of an unrated   Evaluation (FPEE) 1999-008, maintenance access opening    "Control Building Fire Barrier that includes an unrated      Features," Rev. 3 / All conduit seal.
Fire Protection Engineering FPEE 1999-018 justifies the   Evaluation (FPEE) 1999-018, acceptability of an unsealed  "Evaluation of Fire Propagation pipeway trench that passes    through Floor Trenching at the 8' beneath the fire barrier that PAB," Rev. 0 / All separates the Safety Injection/Containment Spray   Fire Protection Technical Pump Room and the             Evaluation (FPTE) 001, "Technical Component Cooling Water       Evaluation of Fire Barrier Pump Room.                    Penetration Seals, Fire Rated Wrapping and Cable Tray Fire Stops at Point Beach Nuclear Plant," Rev. 1 / All Revision 0                    Revison                                           0PageA-1I Page A-1 35

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                  Reference Document Complies, with Required    Unsealed bus duct                NAMS Action Request 1741299, Action                     penetrations in the floor of the "Caution Tags on 1 B03/04 and cable spreading room to the       2B03/04 Crossties not Needed,"
auxiliary feedwater pump          dated March 5, 2012 rooms will be provided with penetration seals. This is       NAMS Engineering Change being tracked by NAMS            271218, "Install a Modification to Engineering Changes 271218       the 480-Volt B-03 to B-04 Bus Ties and 278396; and NAMS              to Provide a 3-hr Rated Fire Action Request 1741299. See       Barrier" Table S-2 in Attachment S.
NAMS Engineering Change Unsealed bus duct                278396, "Fire Barrier for B-03 /
penetrations in the floor of the B-04 Cross Tie" non-vital switchgear room to the vital switchgear room will be provided with penetration seals. This is being tracked by MOD-27 in Table S-2 in Attachment S.
Page A-136 Revision 00                                                                                                                       Page A-1 36

NextEra PBNP                 Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance            Compliance Statement   Compliance Basis                Reference Document 3.11.5 Electrical    ERFBS required by Chapter        Complies with Use of    FPEE 2001-005 justifies the    Fire Protection Engineering Raceway Fire Barrier 4 shall be capable of            EEEEs                   acceptability of raceway fire  Evaluation (FPEE) 2001-005, Systems (ERFBS)      resisting the fire effects of                            barrier configurations on      "Adequacy of 1-Hour Raceway Fire the hazards in the area.                                 raceways JB-1017 and           Barriers Constructed of 3M Interam ERFBS shall be tested in                                 PBN02 in the Vital Switchgear  Materials Installed on JB-1017 and accordance with and shall                                Room.                          PBNO2 in the Vital Switchgear meet the acceptance criteria                                                            Room," Rev. 0 / All of NRC Generic Letter 86-                                FPEE 2001-006 justifies the 10, Supplement 1, "Fire                                  acceptability of raceway fire  Evaluation FPEE 2001-006, Endurance Test Acceptance                                barriers on four-inch diameter "Adequacy of One-Hour Raceway Criteria for Fire Barrier                                conduits in the Vital          Fire Barriers Constructed of 3M Systems Used to Separate                                 Switchgear Room, the D05       Interam Materials Installed on Four-and D06 Battery Rooms, and     Inch Diameter Conduits," Rev. 0 /
Safe Shutdown Trains the Auxiliary Feedwater Pump   All Within the Same Fire Area."
Room.
The ERFBS needs to                                                                      Evaluation FPEE 2003-004, "Fire adequately address the                                                                  Protection of Raceway Supports,"
Evaluation FPEE 2003-004 design requirements and                                 justifies the acceptability of  Rev. 0 / All limitations of supports and                              the number of layers of E-54A intervening items and their                              mat material used to protect   Evaluation FPEE-2004-001, impact on the fire barrier                               raceway supports in the        "Qualification of PCI-Promatec system rating. The fire                                  Auxiliary Feedwater Pump       Interam Flexible Fire Protective barrier system's ability to                              Room to achieve a 1-hour fire  Systems Protection of Conduits maintain the required                                    rating.                        FP-3, FK-1, N02-3 and 1-S079 for nuclear safety circuits free of                                                         a One-Hour Fire Rating," Rev. 0 fire damage for a specific                               Evaluation FPEE-2004-001       All thermal exposure, barrier                               justifies the acceptability of design, raceway size and                                 raceway fire barrier           Procedure RMP 9057, "Fire Barrier type, cable size, fill, and type                         configuration for conduit      Penetration Fire Seal Surveillance,"
shall be demonstrated.                                   1S079 in the Auxiliary         Rev. 17 / Section 5.5.8 Feedwater Pump Room.
Exception No. 1: When the temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, "Fire Endurance Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area,"
Supplement 1,functionality Revision 0                                                                                                                          Page A-1 37

NextEra PBNP                Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance         Compliance Statement      Compliance Basis            Reference Document of the cable at these elevated temperatures shall be demonstrated.
Qualification demonstration of these cables shall be performed in accordance with the electrical testing requirements of Generic Letter 86-10, Supplement 1, Attachment 1, "Attachment Methods for Demonstrating Functionality of Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure."
Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements as specified by the AHJ at the time of acceptance.
Page A-138 Revision 00                                                                                                              Page A-1 38

NextEra PBNP            Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance     Compliance Statement      Compliance Basis                Reference Document Complies, with Required    Per Section 5.4.3 of the       Fire Protection Evaluation Report Action                     FPER, "The use of ERFBS        (FPER), Rev. 13 / Section 5.4.3 (commonly known as "cable wraps") at PBNP supports the    Internal WE Correspondence NPM requirement to separate         96-0020 from Ksobiech to Maxfield redundant trains of safe        dated January 19, 1996 / All shutdown equipment where installation of classical       Modification MR 99-033, Fire Wrap physical structural barriers    Cables in the AFW Pump Room to may not be practical. Cable     Meet Appendix R Separation wraps installed to meet the     Requirements / All requirements of Section IIl.G.2.a of 10 CFR 50         NAMS Action Request 1837986, Appendix R, shall be 3-hour     "Ensure Credited Fire Wrap fire rated. One hour fire rated Included in Periodic Surveillance" barriers are acceptable in accordance with the             NAMS Work Order 370104, "U2 EC requirements of 10 CFR 50       13399, Replace AF Mtr. Repower Appendix R, Section IIl.G.2.c   from DC Bus." / Task 18, "EC provided fire detection and     13399, 3 Hr Fire Wrap of Conduits,"
suppression are also            Task 63, "AFW Phase 2 Fire Wrap furnished. Inside containment   EC 13399 (Cond. For 2MS-2020/2,"
cable wrap may also be used     and Task 64, "AFW Phase 3 Fire to provide a non-combustible    Wrap EC 13399 (Cond. D04-11)"
radiant energy shield in accordance with Section         NAMS Work Order 370133, "Aux IIl.G.2.f of Appendix R. The   Control Board and AFW Mod" /
ERFBS used at PBNP is 1-        Task 14, "EC 13401, 1 Hr Fire hour rated with the exception   Wrap U1 AFW & U2 South Remote of that installed in            SD Room" containment, which is qualified as radiant energy     NAMS Work Order 374010, "EC shielding."                     13403, Install Electrical for New AFW Motors/Instruments" / Task All ERFBS credited for NFPA     24, "EC 13403, 3 Hr Fire Wrap of 805 Chapter 4 compliance at     Conduits" PBNP is 3M Interam E-50 series fire wrap. The wrap      NAMS Work Order 374013, "Shift meets the requirements of       Power Supply Per EC 13398 Generic Letter 86-10            1P-29, And Remaining AFW Mods" Supplement 1 as discussed in    / Task 26, "3 Hr Conduit Fire Wrap NPM 96-0020.                    EC 13398" In fire area A01-A, raceways   NAMS Work Order 381971, "AF /
Page A-139 Revision 00                                                                                                                     Page A-1 39

NextEra PBNP             Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref. Requirements/Guidance      Compliance Statement      Compliance Basis                 Reference Document 2NP2C1, 2P2C1, and FV07          Conduit and Cable Pull / Testing for are protected with 1-hour fire   AFW Mod" Task 25, "EC 13403, wrap in fire zone 142 per NPM    Phase 3 Firewrap for D04-7" and 96-0020. Raceways 2-2019D        Task 86, "EC 13403 3 Hr Fire Wrap and 2-2020D, and raceway         (For Conduits in W/O 383080" D03-12, and raceway D04-11, and raceway D31-11, and          Procedure RMP 9057, "Fire Barrier raceway D04-7 are protected     Penetration Fire Seal Surveillance,"
with 3-hour fire wrap in fire    Rev. 17 / All zone 142 per WO 370104 Task 63, WO 374010 Task 24, WO 370104 Task 64, and WO 370104 Task 18, and WO 381971 Task 25, respectively.
In fire area A01-B, raceway 1-2020D, and raceways 1S394-1 and 2S394-1, and raceways 2-2019D and 2-2020D, and raceway D03-12, and raceway D04-1 1, are protected with 3-hour fire wrap in fire zone 187 per WO 374013 Task 26, WO 381971-86, WO 370104 Task 63, WO 374010 Task 24, and WO 370104 Task 64, respectively.
In fire area A01-B/46, raceways 1S394-1 and 2S394-1 are protected with 3-hour fire wrap in fire zone 237 per WO 381971 Task 86.
In fire area A01-CN, raceways D03-12 and D04-11 are protected with 3-hour fire wrap in fire zones 215 and 217, respectively, per WO 374010 Task 24 and WO 370104 Task 64, respectively.
In fire area A23N, raceways Page A-140 Revision 00                                                                                                                     Page A-140

NextEra PBNP                     Attachment A - NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Ref.       RequirementslGuidance            Compliance Statement             Compliance Basis                   Reference Document 2P2A-4, 2P2B-4, 2S079, and D301-1, and raceways A969, A973, FK-1, FP-3, and JB4178, and raceway D04-7, are protected with 1-hour fire wrap in fire zone 304N per NPM 96-0020, MR 99-033, and WO 381971 Task 25, respectively.
In fire Area A23S, raceway 1S077, and raceways 1S079 and N02-3, and raceway D31-11, are protected with 1-hour fire wrap infire zone 304S per NPM 96-0020, MR 99-03, and WO 370133 Task 14, respectively.
In fire area A24, raceways A130, A131, A134, A135, JB1017, PBNO.1B, PBNO.2A, S1030, and S1032 are protected with 1-hour fire wrap infire zone 305 per NPM 96-0020.
In fire area A25, raceway D301-1 is protected with 1-hour fire wrap infire zone 306 per NPM 96-0020.
In fire area A26, raceway D301-1 is protected with 1-hour fire wrap infire zone 307 per NPM 96-0020.
See implementation items identified below.
IMPLEMENTATION ITEMS:
IMP-129: RMP 9057, "Fire Barrier Penetration Fire Seal Surveillance," will be revised to include inspection, testing, and maintenance requirements and criteria for all raceways credited for compliance with NFPA 805. This is being tracked by NAMS Action Request 1837986.
Revision 0                                                                                                                                         Page A-141

Attachment B - NEI 04-02 Table B-2 NextEra PBNP                 Nuclear Safety Capability Assessment - Methodology Review B.      NEI 04-02 Table B Nuclear Safety Capability Assessment -
Methodology Review 104 Pages Attached Page B-I Revision 0 Revision 0                                                                       Page B-1

NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection A comprehensive list of systems and equipment and their interrelationships to be analyzed for a fire event shall be developed. The equipment list shall contain an inventory of those critical components required to achieve the nuclear safety performance criteria of Section 1.5. Components required to achieve and maintain the nuclear safety functions and components whose fire-induced failure could prevent the operation or result in the maloperation of those components needed to meet the nuclear safety criteria shall be included. Availability and reliability of equipment selected shall be evaluated.
NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.0           Deterministic Methodology         This section discusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe shutdown analysis to 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 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 lIl.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 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 Alignment Statement          Alignment Basis                                                                                         Reference Documents Aligns                       A deterministic methodology was used to assess conformance with the Nuclear Safety Page B-2 Revision 0 Revision                                                                                                                                                         Page B-2

NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection Performance Criteria (NSPC) from Section 1.5.1 of NFPA 805 for the Point Beach Nuclear Plant.
The Point Beach 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 Point Beach NSCA has been performed consistent with (i.e., aligns with) the deterministic methodology guidance, criteria, and assumptions from Chapter 3 of NEI 00-01.
Although not required by the criteria, Point Beach has utilized database-oriented approaches in the past and continues to do so. The cable and raceway database is known as EDISON (a.k.a.
CARDS); pre-transition the analytical aspects were maintained in a standalone Access database known as SSAMS (Safe Shutdown Analysis Management System). During transition Point Beach has adopted an Oracle-based analysis tool directly linked to the EDISON database for cable and equipment records and location information. References to SSAMS should be understood as the legacy data repository. Most logical relationships are maintained in the replacement software (SAFE).
Page B-3 Revision 00                                                                                                                        Page B-3

NextEra PBNP                               Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1         Safe Shutdown Systems        This section discusses the identification of systems necessary to perform the required safe shutdown functions. It and Path Development         also provides information on the process for combining these systems into safe shutdown paths. Appendix R Section IIl.G.l.a requires that the capability to achieve and maintain hot shutdown be free of fire damage. Appendix R Section Ill.G.1.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 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. If these 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.
Revision 0                                                                                                                                              Page B-4

NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection 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:
                                              - 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. (Ifthe 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).
Applicability                                 Comments Applicable Alignment Statement      Alignment Basis                                                                                          Reference Documents Aligns                   Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 7.2.             R2167-1019-001     section 5.4.
This methodology identified the systems, components and cables needed for evaluation of the              R2167-1019-001     section 7.2.
plant's ability to achieve Safe and Stable conditions following a fire event. Refer to R2167-1019-       R2167-1019-001    Attachment D 001 Attachment D & E for Performance Goal and System structure.                                          R2167-1019-001     Attachment E A computer database tool, SAFE, is utilized to demonstrate that the Nuclear Safety Performance Criteria of NFPA 805 are met for each fire area of the plant.
Page B-5 Revision 0                                                                                                                                                   Page B-5

NextEra PBNP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 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.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                    Reference Documents Not Required                This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
Page B-6 Revision 00                                                                                                                                              Page B-6

NextEra P13NP                                Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Ill.G.1 of 10CFR 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 Alignment Statement         Alignment Basis                                                                                  Reference Documents Page B-7 Revision 00                                                                                                                                         Page B-7

NextEra PBNP                                Attachment B - NEI 04-02 Table B 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 Section 3.0 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 10CFR50 Appendix R Sections II.G.1 and II.G.2.
The NRC has accepted the BWROG position and issued an SER dated Dec. 12, 2000.
Applicability                              Comments Not Applicable Alignment Statement        Alignment Basis                                                                                 Reference Documents Page B-8 Revision 00                                                                                                                                         Page B-8

NextEra PBNP                                     Attachment B - NEI 04-02 Table B 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 Section 3.0 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 RCS through the steam generators. The cooldown rate must be controlled to prevent the formation of a bubble in the reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                         Reference Documents Aligns                      Operation of the Pressurizer Heaters is not relied upon for Safe and Stable conditions.                 R2167-1019-001 section 3.1.1 Availability to secure Pressurizer Heaters is analyzed to demonstrate Reactor Coolant Pressure          CALC-WE0005-06 Control. RCS Pressure control is maintained by a combination of charging pump operation, Pressurizer PORVs or Reactor Pressure Vessel Head Vent valves, and steam generator ADVs.
CALC-WE0005-06: Current analysis presented in the FPER states that RCS pressure control can be accomplished by maintaining the pressurizer level constant.
Reactor heat removal is required to ensure that the reactor core and primary system temperatures are maintained within acceptable limits. To achieve decay heat removal, the following criterion were analyzed:
                            "Establishing natural circulation in the Reactor Coolant System
                            " Isolating the Steam Generators at Main Steam lines and isolating the blowdown and sample lines "Closing the Atmospheric Dump Valves for Hot Standby
                            " Isolating Main Feedwater "Main Steam Code Safety Valves available "Establishing and controlling Auxiliary Feedwater flow to the Steam Generators Page B-9 Revision 0                                                                                                                                                 Page B-9

NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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 III.G.1 and III.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 Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      PBNP classifies the Control Room, Cable Spreading Room, 4160V Vital Switchgear Room,                   R2167-1019-001 section 7.6 Computer and Instrument Rack Room, Monitor Tank Room, and CCW Heat Exchanger and                       NRC SER dated 1/11/1989 Boric Acid Tank Room as alternative shutdown fire areas based on separation requirements of Sections III.G.1 and III.G.2. For more detail, refer to "NSCA Report", R2167-1019-001 section 7.6.
Page B-b Revision 0                                                                                                                                                Page B-1 0

NextEra PBNP                                    Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                    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 Section 3.0 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, etc. in progress. The units are assumed to be operating at full power under normal conditions and normal lineups.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      Assumptions- Systems and Equipment:                                                                    R2167-1019-001 section 3.1.1
: a. The units are operating at 100% power upon the occurrence of a fire.                                FPER section 5.2.1.2
: b. The reactors are tripped either manually or automatically, at the onset of a fire.
: c. No additional single failures are considered other than those directly attributable to the fire.
: d. No equipment required for post-fire safe shutdown is assumed to be out of service.
: e. All required mechanical components (valves, tanks, heat exchangers, etc.) are assumed operable and free of damage due to fire.
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NextEra P13NP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.1.6       Criteria/Assumptions             No Final Safety Analysis Report accidents or other design basis events (e.g. loss of coolant accident, earthquake),
single failures or non-fire induced transients need be considered in conjunction with the fire.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                       Reference Documents Aligns                      No additional single failures are considered other than those directly attributable to the fire.      R2167-1019-001 section 3.1.1 Page B-12 Revision 0                                                                                                                                                Page B-12

NextEra P13NP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      Offsite power is analyzed and credited where demonstrated available.                                     R2167-1019-001 section 3.1.1 Page B-13 Revision 00                                                                                                                                                 Page B-13

NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.1.8       Criteria/Assumptions             Post-fire safe shutdown systems and components are not required to be safety-related.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                   Reference Documents Aligns                      Both safety-related and non-safety related equipment are credited to achieve a safe and stable    R2167-1019-001 section 3.1.1 condition. PBNP Report R2167-1019-001 does not restrict the use of only safety related systems and components to achieve the nuclear safety performance criteria and is aligned with NEI 00-01 guidance.
Page B-14 Revision 0 Revision                                                                                                                                           Page B-14

NextEra Pl3NP                                     Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      The NFPA 805 Nuclear Safety Performance Criteria (NSPC) requires the licensee to                         R2167-1019-001 section 3.1.1 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 Point Beach 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.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.1.10      Criteria/Assumptions             Manual initiation from the main control room or emergency control stations of systems required to achieve and maintain safe shutdown is 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, Auxiliary Feedwater, High Pressure Coolant Injection, Reactor Core Isolation Cooling, etc.) due to fire damage, however, should be evaluated.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                       Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section               R2167-1019-001 Section 3.1.1 3.1.1. Control of SSD-credited devices from the MCR is modeled; where provided by plant design, operation of SSD-credited devices from alternate or local control stations is also modeled.
To address ESFAS actuation (valid or spurious), the ability to BLOCK (override) Safety Injection was incorporated into the SSD model during Transition to NFPA-805.
Page B-16 Revision 0                                                                                                                                                Page B-1 6

NextEra P13NP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.1.11      Criteria/Assumptions             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 be demonstrated.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      The NSCA analysis for Point Beach concurrently evaluates the impact on both Units for all                R2167-1019-001 section 3.1.1 postulated fire events.
Page B-17 Revision 0                                                                                                                                                  Page B-17

NextEra P13NP                              Attachment B - NEI 04-02 Table B 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 Section 3.0 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 safe shutdown. For additional information on BWR system selection, refer to GE Report GENE-T43-00002-00-01-RO1 entitled "Original Safe Shutdown Paths for the BWR."
Applicability                             Comments Applicable Alignment Statement      Alignment Basis                                                                                 Reference Documents Not Required             This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequnt subsections.
Page B-18 Revision 0                                                                                                                                       Page B-18

NextEra PBNP                                Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                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 Section 3.0 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.
Applicability                              Comments Not Applicable Alignment Statement        Alignment Basis                                                                                        Reference Documents Page B-19 Revision 0                                                                                                                                                 Page B-19

NextEra PB3NP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Alignment Statement        Alignment Basis                                                                                    Reference Documents Aligns                     The Point Beach reactor core design ensures that Keff is maintained <0.99 while the plant is in    R2167-1019-001 section 5.6.3 sustained Mode 3 (Hot Standby). Gravity insertion of the control rods into the reactor core will   R2167-1019-001 section 7.2.1 ensure reactivity control is achieved for Mode 3 (Hot Standby) for the first 24 hours.             CALC 2004-0021 "Appendix R Subsequently, maintaining Keff <0.99 for "safe and stable" conditions will require boration of the Reactivity Analysis" RCS as described in FSAR Chapter 3.2. Makeup sources are controlled to ensure that RCS             FSAR Chapter 3.2 boron concentration is not diluted and borated makeup water is supplied from the Refueling Water Storage Tank (RWST) to ensure reactivity margin throughout safe shutdown.
Page B-20 Revision 0                                                                                                                                           Page B-20

NextEra PBNP                               Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                               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 Section 3.0 Guidance 3.1.2.2       Pressure Control Systems    [BWR] Safety Relief Valves (SRVs)
Initial pressure control may be provided by the SRVs mechanically cycling at their setpoints (electrically cycling for 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 Alignment Statement       Alignment Basis                                                                                     Reference Documents Page B-21 Revision 0 Revision                                                                                                                                               Page B-21

NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.2.2       Pressure Control Systems        [PWR] Makeup/Charging 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.
Applicability                                 Comments Applicable Alignment Statement       Alignment Basis                                                                                      Reference Documents Aligns                    Reactor Coolant Pressure Control is necessary to prevent exceeding RCS design pressure-              R2167-1019-001 section 5.6.3 temperature limits and to minimize void formation in the reactor. Reactor Coolant Pressure           R2167-1019-001 section 7.2.2 Control is accomplished by the following actions:
                          " Isolating Normal and Auxiliary Spray
                          " Closing or isolating the Pressurizer Power-Operated Relief Valves (PORVs)
                          "Assuring the availability of a Pressurizer Safety Valve
                          " Controlling Makeup to the RCS
                          " Controlling/Securing the Pressurizer Heaters Page B-22 Revision 0 Revision                                                                                                                                                 Page B-22

NextEra PBNP                                Attachment B - NEI 04-02 Table B 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 Section 3.0 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.).
Applicability                              Comments Not Applicable Alignment Statement        Alignment Basis                                                                                  Reference Documents Page B-23 Revision 00                                                                                                                                         Page B-23

NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                     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 Section 3.0 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, however, should be evaluated (Safety Injection, High Pressure Injection, Auxiliary Feedwater, Emergency Feedwater, etc.).
Applicability                                   Comments Applicable Alignment Statement        Alignment Basis                                                                                          Reference Documents Aligns                     Reactor Coolant Inventory Control is required for maintenance of RCS integrity and for reactor           R2167-1019-001 section 5.6.3 coolant makeup capability to compensate for Reactor Coolant System fluid losses and                      R2167-1019-001 section 7.2.2 shrinkage. Reactor Coolant Inventory Control is accomplished by the following actions:
                           "Isolation of Normal and Excess Letdown flow paths "Isolation of the Reactor Coolant System "Isolation of Safety Injection and Containment Spray flow paths "Isolation of Residual Heat Removal flow paths
* Isolation of potential Refueling Water Storage Tank draindown to containment sump "Control of charging It should be noted that, unlike 10CFR50 Appendix R, the Nuclear Safety Performance Criteria for NFPA 805 does not require Pressurizer Level to be maintained within the indicated band for a PWR. NFPA 805 requires reasonable assurance that the fuel will be maintained in a safe and stable condition such that the plant is not placed in an unrecoverable condition. The impact of this change upon the PBNP safe shutdown model/analysis is negligible, due to having to ensure the availability of CVCS for makeup/inventory control.
To address ESFAS actuation (valid or spurious), the ability to BLOCK (override) Safety Injection was incorporated into the SSD model during Transition to NFPA-805.
Page B-24 Revision 00                                                                                                                                                  Page B-24

NextEra PBNP                               Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.2.4       Decay Heat Removal          [BWR] 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 Alignment Statement       Alignment Basis                                                                                   Reference Documents Page B-25 Revision 0 Revision   0                                                                                                                                       Page B-25

NextEra P13NP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 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 in lieu 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.
Applicability                                 Comments Applicable Alignment Statement      Alignment Basis                                                                                            Reference Documents Aligns                    Reactor heat removal is required to ensure that the reactor core and primary system                       R2167-1019-001 section 5.6.3 temperatures are maintained within acceptable limits. The decay heat removal function is                   R2167-1019-001 section 7.2.3 accomplished by the following actions:                                                                    R2092-1500-001 section 4.3
                          " Establishing natural circulation in the Reactor Coolant System
                          " Isolating the Steam Generators at Main Steam lines and isolating the blowdown and sample lines
* Closing the Atmospheric Dump Valves for Hot Standby
                          " Isolating Main Feedwater "Main Steam Code Safety Valves available
                          " Establishing and controlling Auxiliary Feedwater flow to the Steam Generators It should be noted that, unlike 10CFR50 Appendix R, the Nuclear Safety Performance Criteria for NFPA 805 does not specifically address achieving and maintaining Cold Shutdown per se.
NFPA 805 requires reasonable assurance that the fuel will be maintained in a safe and stable condition such that the plant is not placed in an unrecoverable condition. However, NFPA 805 does require Cold Shutdown to be addressed with respect to Non-Power Operations. Decay Heat Removal during cold shutdown conditions is addressed by R2092-1500-001, Non-Power Operation Modes Transition Review.
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NextEra PBNP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 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.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
                                             *0 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 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.
Applicability                                Comments Applicable Alignment Statement       Alignment Basis                                                                                         Reference Documents Aligns                    Process monitoring capability must be available to control equipment and system alignments to           R2167-1019-001 section 5.6.3 ensure safe shutdown of the plant in the event of a fire. The following instruments are included        R2167-1019-001 section 7.2 in the NSCA:
                          " RCS Hot and Cold Leg Temperature Instrumentation
                          " RCS Wide Range Pressure Instrumentation
                          " Pressurizer Level Instrumentation Page B-27 Revision 0                                                                                                                                               Page B-27

NextEra PBNP                                 Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection "Nuclear Instrumentation / Source Range Monitoring "RWST Level Indication "Condensate Storage Tank (CST) Level Indication "EDG Fuel Oil Day Tank Level Indication (1)
                         "Steam Generator level and pressure "Auxiliary Feedwater Pump Suction Pressure Indication Diagnostic instrumentation such as pump suction pressure, flow, and temperature are generally provided by local indicators that require no electrical power. In addition, instruments which provide permissive or controlling signals to safe shutdown components are modeled in direct support of the component as part of the cable selection process.
(1) Level instrumentation for the Emergency Diesel Generator Fuel Oil Day Tanks is included in the safe shutdown analysis as required to initiate and terminate the automatic transfer of diesel fuel oil from the Fuel Oil Storage Tank(s) to the Day Tank(s). As the transfer is analyzed to function automatically with no operator intervention, monitoring of Day Tank level by the plant operators is not required for fire areas where the automatic transfer function is free of fire damage for the credited diesel generator(s).
Page B-28 Revision 0                                                                                                                      Page B-28

NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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 4.16 KV Class 1 E 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).
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      The NSCA Report identifies which Emergency Power System components are included in the                   R2167-1019-001 section 7.1 analysis. Sections 7.1 and 8.0 identify how power supplies were identified during cable                  R2167-1019-001 section 7.2.5 selection. Power supplies (motive, control, AC, DC) are included where the loss of the power             R2167-1019-001 section 8.0 supply can impact the credited function of required components. Some components may only                 R2168-1003C-001 require power in support of certain system success paths and may be creditable in the loss of Revision 0                                                                                                                                                    Page B-29

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection power position for other system success paths. Spurious operation resulting from cable damage always assumes the presence of power where its availability may adversely impact the NSPC.
Additional electrical system reviews performed for NFPA 805 transition are documented in R2168-1003C-001.
Page B-30 Revision 00                                                                                                                      Page B-30

NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.2.6.2     Cooling Systems                 Various cooling water systems may be required to support safe shutdown system operation, based on plant-specific considerations. Typical uses include:
                                              - RHRISDC/DH Heat Exchanger cooling water
                                              - Safe shutdown pump cooling (seal coolers, oil coolers)
                                              - Diesel generator cooling Applicability                                 Comments Applicable Alignment Statement        Alignment Basis                                                                                  Reference Documents Aligns                     The NSCA Report identifies the cooling water systems evaluated in support of achieving and       R2167-1019-001 section 7.2.5 maintaining "safe and stable" plant conditions following a fire. Where necessary supporting calculations are referenced in the NSCA Report.
The NSCA has determined that the only required cooling water system in support of "safe and stable" plant conditions is the Service Water System.
Page B-31 Revision 00                                                                                                                                        Page B-31

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                  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 Section 3.0 Guidance 3.1.2.6.3     HVAC Systems                  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
                                            - 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 Alignment Statement      Alignment Basis                                                                                         Reference Documents Aligns                   The NSCA Report identifies the HVAC systems evaluated in support of achieving and                        R2167-1019-001 section 7.2.4 maintaining "safe and stable" plant conditions following a fire. Where necessary supporting             Calculation PRA-5.25A "Cable calculations are referenced in the NSCA Report.                                                         Spreading and Computer Room (IRR) Heat-Up Analysis" The NSCA states that the following HVAC systems are required in support of "safe and stable"            Calculation PRA-5.25B "Control plant conditions:                                                                                       Building (EI-8') Heat-Up Analysis" Calculation PRA-5.25C "PAB New Page B-32 Revision 0                                                                                                                                               Page B-32

NextEra PBNP                                 Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection
                         " PAB Battery & Inverter Ventilation (VNBI)                                           Battery and Inverter Room Heat-
                         " Emergency Diesel Generator Ventilation System                                       Up Analysis"
                         " G-03/G-04 Switchgear Room Ventilation
                         " Cable Spreading Room Ventilation System (VNCSR)
                         " Primary Auxiliary Building (VNPAB)
                         "AFW Pump Rooms (VNAFW)
                         "Vital Switchgear Room
                         " Computer Room Page B-33 Revision 0 0                                                                                                                            Page B-33

NextEra PBNP                                 Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.3         Methodology for Shutdown      Refer to NEI-00-01 Rev 1 Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe shutdown System Selection              systems and developing the shutdown paths.
The following methodology may be used to define the safe shutdown systems and paths for an Appendix R analysis:
Applicability                               Comments Applicable Alignment Statement       Alignment Basis                                                                                       Reference Documents Not Required               This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
Page B-34 Revision 00                                                                                                                                              Page B-34

Equipment Selection NextEra PBNP                                     Attachment Capability        B - and System     NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review Safety 2.4.2.1 Nuclear NFPA 805 Section:
NFPA 805 Section: 2.4.2.1 Nuclear Safety Capability System and Equipment Selection NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.1.3.1       Identify Safe Shutdown            Review available documentation to obtain an understanding of the available plant systems and the functions Functions                         required to achieve and maintain safe 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" Applicability                                   Comments Applicable Alignment Statement          Alignment Basis                                                                                     Reference Documents Aligns                       The necessary documentation was reviewed in support of identifying the performance goals            R2167-1019-001 section 7.0 required to achieve and maintain the NSPC. The documents referenced are listed in sections          R2167-1019-001 section 12.0 7.0 and 12.0 of the NSCA Report.
Page B-35 Revision 0                                                                                                                                              Page B-35

NextEra PBNP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.3.2       Identify Combinations of       Given the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of Systems That Satisfy Each      achieving the safe shutdown functions of reactivity control, pressure control, inventory control, decay heat removal, Safe Shutdown Function         process monitoring and support systems such as electrical 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 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 Alignment Statement        Alignment Basis                                                                                       Reference Documents Aligns                     Each safe shutdown function (performance goal) is described in detail in section 7 of the NSCA        R2167-1019-001 section 7.0 Report. The supporting systems are identified in logical paths necessary to satisfy each function through AND/OR statements. Equipment whose mal-operation or spurious operation, alone or in combination, could impair achieving the required function/ condition is included.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.3.3       Define Combination of           Select combinations of systems with the capability of performing all of the required safe shutdown functions and Systems for Each Safe           designate this set of systems as a safe shutdown path. In many cases, paths may be defined on a divisional basis Shutdown Path                   since the availability of electrical power and other support systems 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 Alignment Statement        Alignment Basis                                                                                        Reference Documents Aligns                     The NSCA Report identifies the different combinations of systems that successfully achieve the         R2167-1019-001 section 7.0 safe shutdown functions. The SAFE software analysis engine identifies which paths are free of fire damage for each fire area analysis. Support systems and functions are logically associated with particular components as identified in section 7 of the NSCA Report.
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NextEra PBNP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.1.3.4       Assign Shutdown Paths to       Assign a path designation to each combination of systems. The path will serve to document the combination of Each Combination of            systems relied upon for safe shutdown in each fire area. Refer to Attachment 1 to this document for an example of a Systems                        table illustrating how to document the various combinations of systems for selected shutdown paths.
Applicability                                Comments Applicable Alignment Statement       Alignment Basis                                                                                      Reference Documents Aligns                     Path designations are assigned by the SAFE sofware; each success path is a specific                 R2167-1019-001 section 7.0 combination of components supporting the performance goals, as described in the NSCA Report. The analysis of each fire area ensures that at least one success path remains available or is recovered for performance goal.
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NextEra PBNP                                Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2           Safe Shutdown Equipment      The previous section described the methodology for selecting the systems and paths necessary to achieve and Selection                    maintain safe shutdown for an 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 mitigating the affects.
Applicability                              Comments Applicable Alignment Statement       Alignment Basis                                                                                       Reference Documents Not Required              This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
Page B-39 Revision 0                                                                                                                                             Page B-39

NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2.1         C riteria/Assumptions           Consider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                   Reference Documents Not Required                 This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
Page B-40 Revision 00                                                                                                                                           Page B-40

NextEra PB3NP                                     Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                         Reference Documents Aligns                      All selected equipment in support of the NSCA is identified in Attachment A of the NSCA                  R2167-1019-001 section 7.0 Report. The specific equipment that support each system success path are identified in section           R2167-1019-001 section 8.0 7.0 of the NSCA Report.                                                                                  R2167-1019-001 Attachment A The equipment selection criteria for primary components is described in section 7.0 of the NSCA Report. Additionally, section 8.0 identifies the criteria used to determine when secondary components (e.g., associated instruments) are explicitly identified in the SSEL and when such components are associated to their primary component (i.e., components listed on the SSEL) by the circuit analysis process.
Page B41 Revision 0                                                                                                                                                   Page B-41

NextEra PBNP                                       Attachment B - NEI 04-02 Table B 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 Section 3.0 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.
Applicability                                    Comments Applicable Alignment Statement         Alignment Basis                                                                                            Reference Documents Aligns                      All required mechanical componenlts (valves, etc.) are assumed operable and free of damage                 R2167-1019-001 section 3.1.2 due to fire.                                                                                               R2168-1012-01 Piping, heat exchangers, and tanks that are exposed to a fire are assumed to be unaffected in their ability to function as pressure boundaries or as safe shutdown components. Brazed and soldered lines are assumed to be damaged in the event of a fire. For valves, the fire damage is limited to power-assisted operators such as motors, air operators, hydraulic or solenoid operators.
Availability of Instrument Air (IA) is not assured. Devices requiring IA (P-29 and P-53 AOVs) are provided with local reservoirs providing 24-hr supply; IA supplies for the P-38 AOVs and PORVs are being upgraded and modifications are being implemented to eliminate this vulnerability. See Attachment S Table S-2.
Instances where HW operation of valves located in the fire-affected area is credited for compliance was evaluated by the Recovery Action Feasibility Report (R2168-1012-01) during transition.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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 in effect, that the Unit is operating at 100% power and that no equipment has been taken out of service for maintenance.
Applicability                                  Comments Applicable Alignment Statement        Alignment Basis                                                                                         Reference Documents Aligns                     The NSCA Report documents that all components including manual valves are assumed to be                 R2167-1019-001 section 3.1.1 in their normal positions; all safe shutdown systems are assumed operational with no repairs,          R2167-1019-001 section 3.1.2 maintenance, testing LCOs in progress. The units are assumed to be operating at full power under normal conditions and normal lineups.
Page B-43 Revision 00                                                                                                                                              Page B-43

NextEra PBNP                                      Attachment B - NEI 04-02 Table B 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 Section 3.0 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.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      The NSCA Report documents the following:                                                               R2167-1019-001 section 3.1.2 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.
Page B-44 Revision 00                                                                                                                                                  Page B-44

NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                      Reference Documents Aligns                      The NSCA Report documents the following:                                                             R2167-1019-001 section 3.1.2 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.
Page B-45 Revision 0 Revision                                                                                                                                                Page B-45

NextEra PBNP                                Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2.2         Methodology for Equipment    Refer to NEI-00-01 Rev 2 Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown Selection                    equipment.
Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:
Aoolicabilitv                              Comments Applicable Alignment Statement       Alignment Basis                                                                                      Reference Documents Not Required              This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
Page B-46 Revision 0                                                                                                                                              Page B-46

NextEra PBNP                                     Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2.2.1       Identify the System Flow          Mark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path.
Path for Each Shutdown            Refer to Attachment 2 for an example of an annotated P&ID illustrating this concept. When developing the SSEL, Path                              determine which equipment should be included on the Safe 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 Alignment Statement         Alignment Basis                                                                                       Reference Documents Aligns with Intent          The NSCA Report section 7.0 describes the NSCA model development and component                        R2167-1019-001 section 7.0 selection process. The combinations of plant components supporting each system success                R2167-1019-001 Attachment A path are identified and the components are included on the SSEL.
A review of P&IDs, electrical drawings, instrument loop diagrams, etc. was performed tooidentify the NSCA systems and components and to develop system-to-equipment and equipment-to-equipment logic relationships (i.e. Boolean logic success paths). The logical relationships are maintained in the SAFE database.
Page B-47 Revision 0 Revision                                                                                                                                                 Page B-47

NextEra PBNP                                    Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                    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 Section 3.0 Guidance 3.2.2.2       Identify the Equipment in        Review the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all Each Safe Shutdown              equipment in each system's flow path has been identified. Assure that any equipment that could spuriously operate System Flow Path Including      and adversely affect the desired system function(s) is also identified. Additionally, refer to Section 4 for the Equipment That May               Resolution Methodology for determining the Plant Specific List of MSOs requiring evaluation. Criteria for making the Spuriously Operate and          determination as to which of these components are to be classified as required for hot shutdown or as important to Affect System                   SSD is contained in Appendix H. Ifadditional systems are identified which are necessary for the operation of the Operation                       safe shutdown system under review, include these as required for hot shutdown systems. Designate these new systems with the same safe shutdown path as the primary safe shutdown system under review (Refer to Figure 3-1).
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      The NSCA Report section 7.0 describes the NSCA model development and component                         R2167-1019-001 section 3.1.2 selection process, including documentation reviewed (P&IDs, electrical drawings, instrument            R2167-1019-001 section 7.0 loop diagrams).                                                                                        P2092-11i A P2091-2500-02 The NSCA Report section 3.1.2, P2092-11 OA and P2091-2500-02 document the review process for spurious operations including MSOs. MSOs that could impact the NSPC were included in the NSCA logical model for each system/function as described in the NSCA Report section 7.4.
The combinations of plant components impacting each system success path due to spurious operation are included on the SSEL.
Page B-48 Revision 0                                                                                                                                                   Page B-48

NextEra PBNP                                     Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2.2.3       Develop a List of Safe            Prepare a table listing the equipment identified for each system and the shutdown path that it supports. Identify any Shutdown Equipment and            valves or other equipment that could spuriously operate and impact the operation of that safe shutdown system.
Assign the corresponding          Criteria for making the determination as to which of these components are to be classified as required for hot System and Safe Shutdown          shutdown or as important to SSD is contained in Appendix H. Assign the safe shutdown path for the affected Path(s) Designation to Each       system to this equipment. During the cable selection phase, identify additional equipment required to support the safe shutdown function of the path (e.g., electrical distribution system equipment). Include this additional equipment in the safe shutdown equipment list. 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.
Applicability                                   Comments Applicable Alignment Statement        Alignment Basis                                                                                            Reference Documents Aligns                     The SSEL is documented in the NSCA Report Attachment A. The NSCA Report section 7.0                        R2167-1019-001  section 7.0 identifies the systems that each component supports. The system success paths are                          R2167-1019-001  section 7.3 maintained in the SAFE database.                                                                           R2167-1019-001  section 8.0 R2167-1019-001  Attachment A The NSCA Report section 8.0 documents the circuit identification and analysis process which                FPEE-1999-017 included identification of the power supplies required to support proper safe shutdown operation           FPEE-1999-019.
of the credited components. The required power supply components have been included in the SSEL and in the SAFE database.
The NSCA Report section 7.3, FPEE-1999-017 and FPEE-1999-019 document the reviews that were performed on instrument tubing that as a result of fire may impact credited indications or instrument signals. Instrument sensing lines for level, pressure, and flow transmitters that are exposed to a fire are considered to have the potential of causing erratic or unreliable indication, unless a fire hazards analysis demonstrates that this failure is not credible. Since sensing lines are not accounted for in the circuit analysis, there exists the possibility that the sensing lines may route outside of a zone where the instrument cabling is located. This could result in a potential masking of the failure of both redundant instruments. In addition, some redundant sensing lines are routed in the same area. A separate analysis of the instrument sensing lines in relation to their instruments was performed to show that adequate separation and/or barriers exist to ensure that at least one set of instruments will always be available for any postulated fire. Refer to FPEE-1999-017 and FPEE-1 999-019.
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                     Attachment B NEt 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 Section 3.0 Guidance 3.2.2.4       Identify Equipment                Collect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for Information Required for the      the equipment. In order to facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer Safe Shutdown Analysis            to Attachment 3 to this document for an example of a 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 Alignment Statement         Alignment Basis                                                                                           Reference Documents Aligns                      The SSEL is docu mented in the NSCA Report Attachment A. The NSCA Report section 7.0                      R2167-1019-001 Attachment A identifies the systeems that each component supports. The system success paths are                        R2167-1019-001 section 7.0 maintained in the SAFE database. All required and recommended equipment-related information is mai.ntained in the SAFE database.
Page B-50 Revision 0                                                                                                                                                   Page B-50

NextEra P13NP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.2.2.5       Identify Dependencies            In the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as Between Equipment,               electrical power and interlocked equipment. As an aid in assessing identified impacts to safe shutdown, consider Supporting Equipment, Safe       modeling the dependency between equipment within each safe shutdown path either in a relational database or in Shutdown Systems and             the form of a Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an example of a SSLD that may be Safe Shutdown Paths              developed to document these relationships.
Applicability                                  Comments Applicable Alignment Statement        Alignment Basis                                                                                        Reference Documents Aligns                     The NSCA Report section 7.0 describes the NSCA model development and component                         R2167-1019-001 section 7.0 selection process. The combinations of plant components supporting each system success                 R2167-1019-001 section 8.0 path are identified. A review of P&iDs, electrical drawings, instrument loop diagrams, etc. was        R2167-1019-001 section 9.0 performed to identify the NSCA systems and components and to develop system-to-equipment and equipment-to-equipment logic relationships (i.e. Boolean logic success paths). The logical relationships are maintained in the SAFE database.
The NSCA Report section 8.0 describes the circuit identification and analysis process.
Additional components required for electrical power, control, permissive or interlock circuits, etc.
were added to the logic relationships in the SAFE database.
The SAFE database is described in section 9.0 of the NSCA Report.
Page B-SI Revision 00                                                                                                                                             Page B-51

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Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFx~aPA 0 NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 2.4.2.2.1 Circuits Required in Nuclear Safety Functions. Circuits required for the nuclear safety functions shall be identified. This includes circuits that are required for operation, that could prevent the operation, or that result in the maloperation of the equipment identified in 2.4.2.1. This evaluation shall consider fire-induced failure modes such as hot shorts (external and internal), open circuits, and shorts to ground, to identify circuits that are required to support the proper operation of components required to achieve the nuclear safety performance criteria, including spurious operation and signals. This will ensure that a comprehensive population of circuitry is evaluated.
2.4.2.2.2 Other Required Circuits. Other circuits that share common power supply and/or common enclosure with circuits required to achieve nuclear safety performance criteria shall be evaluated for their impact on the ability to achieve nuclear safety performance criteria.
(a) Common Power Supply Circuits. Those circuits whose fire-induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur if the upstream protection device (i.e., breaker or fuse) is not properly coordinated with the downstream protection device.
(b) Common Enclosure Circuits. Those circuits that share enclosures with circuits required to achieve the nuclear safety performance criteria and whose fire-induced failure could cause the loss of the required components shall be identified. The concern is that the effects of a fire can extend outside of the immediate fire area due to fire-induced electrical faults on inadequately protected cables or via inadequately sealed fire area boundaries.
NEI 00-01 Ref                                    NEI 00-01 Section 3.0 Guidance 3.3            Safe Shutdown Cable               This section provides industry guidance on one acceptable approach for selecting safe shutdown cables and Selection and Location            determining their potential impact on 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 Alignment Statement          Alignment Basis                                                                                          Reference Documents Not Required                  This is an introductory paragraph with no specific criteria. Requirements are in the subsequent subsections.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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:
Applicability                                  Comments Applicable Alignment Statement        Alignment Basis                                                                                         Reference Documents Not Required                This is an introductory paragraph with no specific criteria. Requirements are in the subsequent subsections.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                   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 Section 3.0 Guidance 3.3.1.1.1     Criteria/Assumptions            The list of cables whose failure could impact the operation of a piece of safe shutdown equipment includes more than those cables connected to 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.
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.0.             R2167-1019-001 section 3.1.3 This methodology includes consideration of hot shorts (external and internal), open circuits,            R2167-1019-001 section 8.0 shorts to ground, and interlock circuits.                                                                R2167-1019-001 Attachment B R2168-1003C-001, "Circuit The screening criteria from Section 3.5 are applied as discussed in Section 3.5 of this table.           Evaluation Tasks" P2092-11i A, "MSO Expert Panel Report" P2091-2500-02, "Systematic MSO Review Report" Page B-54 Revision 00                                                                                                                                                 Page B-54

NextEra P13NP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.2     Criteria/Assumptions             In cases where the failure (including spurious actuations) of a single cable could impact more than one piece of safe shutdown equipment, include the cable with each piece of safe shutdown equipment.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.           R2167-1019-001 section 3.1.3 This methodology identifies the types of cables considered and selection criteria including            R2167-1019-001 section 8.2 control, permissive/interlock, indication/signal and annunciation circuits that could result in the    R2168-1003C-001, "Circuit spurious actuation of NSCA Equipment.                                                                  Evaluation Tasks" Page B-55 Revision 0                                                                                                                                               Page B-55

NextEra P13NP                                 Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.2.1 Criteria/Assumptions             Electrical devices such as relays, switches and signal resistor units are considered to be acceptable isolation devices. In the case of instrument 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.
Applicability                                Comments Applicable Alignment Statement       Alignment Basis                                                                                        Reference Documents Aligns                    Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.           R2167-1019-001 section 3.1.3 The circuit analysis and cable selection procedure requires identification of suitable isolation       R2167-1019-001 section 8.2 devices before a cable can be considered "Not Required" for safe shutdown. Optical isolators           R2168-1003C-001, "Circuit and other isolation circuits are evaluated for their capability to isolate cables to non-credited      Evaluation Tasks" functions such as the process computer or annunciators on all circuits, including instrument loops.
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NextEra PBNP                                       Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.3     Criteria/Assumptions                Screen out cables for circuits that do not impact the safe shutdown function of a component (i.e., annunciator circuits, space heater circuits and 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.
Applicability                                     Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.             R2167-1019-001 section 3.1.3 R2167-1019-001 section 8.2 Ifa fire-induced failure of the cable (short circuit, hot short, open circuit, short to ground) could     R2167-1019-001 Attachment C place the safe shutdown component in a position other than the desired safe shutdown position,           R2168-1003C-001, "Circuit then the cable was designated a REQD safe shutdown cable. If a fire induced failure of the                Evaluation Tasks" cable could not spuriously reposition or prevent the desired operation of the safe shutdown component, then the cable was designated a NOT REQD cable.
Fault designation codes differ for safe shutdown and non-safe shutdown cables:
                            - Safe shutdown (REQD) cables - The fault designation code indicates what basic functionality of the circuit is lost
                            - NOT REQD cables - The fault designation code reflects the reason/rationale as to why the cable is not a safe shutdown cable.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.4     Criteria/Assumptions            For each circuit requiring power to perform its safe shutdown function, identify the cable supplying power to each safe shutdown and/or required 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 Alignment Statement        Alignment Basis                                                                                        Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.           R2167-1019-001 section 3.1.3 R2167-1019-001 section 8.2 For individual components, power supply cables were identified up to the immediate upstream            R2167-1019-001 Attachment C power source. The power supply udergoes circuit analysis, and this iterative process travels           R2168-1003C-001, "Circuit upstream to EDGs and off-site power.                                                                   Evaluation Tasks" Page B-58 Revision 0                                                                                                                                                Page B-58

NextEra PBNP                                    Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                    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 Section 3.0 Guidance 3.3.1.1.4.1   Criteria/Assumptions             The automatic initiation logics for the credited post-fire safe shutdown systems are generally not required to support safe shutdown. Typically, each 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.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                               Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section                       R2167-1019-001 section 3.1.3 7.2.4.4.                                                                                                      R2167-1019-001 section 7.2.5.4 R2167-1019-001 Attachment C Spurious safeguards actuation was evaluated for its ability to cause component realignments                   R2168-1003C-001, "Circuit which could impact the safe shutdown success path. Considering that ESFAS initiation could be                 Evaluation Tasks" spurious (fire-induced) or valid (due to plant transient), the ability to block/ override an ESFAS signal was modeled, and associated with devices whose ESFAS-directed position/ condition negatively impacted the SSD success path.
Page B-59 Revision 0                                                                                                                                                        Page B-59

NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.5     Criteria/Assumptions            Cabling for the electrical distribution system is a concern for those breakers that feed circuits and are not fully coordinated with upstream breakers. 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 an 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.
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section                R2167-1019-001 section 3.1.3 7.2.4.5 and 8.3.                                                                                       R2167-1019-001 section 7.2.5.5 R2167-1019-001 section 8.3 See also subsection 3.5.2.4 for a discussion of circuit coordination.                                  R2167-1019-001 Attachment C R2168-1003C-001, "Circuit Evaluation Tasks" Page B-60 Revision 00                                                                                                                                                 Page B-60

NextEra PBNP                                  Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.1.1.6     Criteria/ Assumptions          Exclusion analyses may be used to demonstrate a lack of potential for any impacts to post-fire safe shutdown from a component or group of components regardless of the cable routing. For these cases, rigorous cable searching and cable to component associations may not be required.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                  Reference Documents Aligns                      Analyses "by exclusion" are not utilized in the development of the Point Beach NSCA. That approach would be considered given the appropriate circumstances.
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NextEra PBNP                               Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.2         Associated Circuit Cables  Appendix R, through the guidance provided in NRC Generic Letter 81-12, requires that separation features be provided for associated non-safety 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
                                         - Common power source
                                         - Common enclosure.
Each of these cables is classified as an associated circuit of concern cable.
Cables Whose Failure May Cause Spurious Operations:
Safe shutdown system spurious operation concerns can result from fire damage to a cable whose failure could cause the spurious operation/mal-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.
Common Power Source Cables:
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.
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.
Applicability                            Comments Page B-62 Revision 00                                                                                                                                              Page B-62

NextEra PBNP                                 Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis Applicable Alignment Statement      Alignment Basis                                                                                  Reference Documents Not Required             This is an introductory paragraph with no specific criteria. Discussion is provided in Table B-2 subsections 3.5.1.2 (spurious operations), 3.5.2.4 (common power supply) and 3.5.2.5 (common enclosure).
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.3         Methodology for Cable           Refer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for Selection and Location          performing a post-fire safe shutdown analysis.
Use the following methodology to define the cables required for safe shutdown including cables that may be circuits of concerns for a post-fire safe shutdown analysis. Criteria for making the determination as to which circuits are to be classified as required for hot shutdown or as important to SSD is contained in Appendix H.
Applicability                                 Comments Applicable Alignment Statement        Alignment Basis                                                                                           Reference Documents Not Required               This is an introductory paragraph with no specific criteria. Requirements are in the subsequent subsections.
Page B-64 Revision 00                                                                                                                                                 Page B-64

NextEra PBNP                                      Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                      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 Section 3.0 Guidance 3.3.3.1       Identify Circuits Required         For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams for the Operation of the           including the following documentation to identify the circuits (power, control, instrumentation) required for operation Safe Shutdown Equipment            or whose failure may impact the operation of each piece of 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.
Applicability                                    Comments Applicable Alignment Statement          Alignment Basis                                                                                           Reference Documents Aligns                       Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.              R2167-1019-001 section 8.2 R2167-1019-001 Attachment A A review of electrical control schematics, instrument loop diagrams and other available input             R2168-1003C-001, "Circuit documenttation was performed for the required circuit analysis for each SSD component from                Evaluation Tasks" SSEL (R2167-1019-001 Attachment A) to identify SSD circuits.
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NextEra PBNP                                       Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.3.2       Identify Interlocked Circuits       In reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and and Cables Whose                    equipment. Assign to the equipment 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 Shutdown                            these interlocked equipment or 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 Alignment Statement          Alignment Basis                                                                                            Reference Documents Aligns                       Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2.               R2167-1019-001 section 8.2 This methodology includes consideration of interlock and permissive circuits.                              R2168-1003C-001, "Circuit Evaluation Tasks" Automatic logic interlocks and permissive contacts from other circuits (i.e., interposing contacts in control circuits) are included in the circuit analysis to address their potential adverse affect on circuit operation. Interposing contacts are evaluated using one of two options:
                             "The contacts are assumed to be in a permissive position (worst case position), or "The circuits associated with the interlock or permissive are analyzed and included in the safe shutdown cable selection for the component under review.
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NextEra PBINP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.3.3.3       Assign Cables to the Safe        Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in Shutdown Equipment               mal-operation of each piece of safe shutdown equipment. Cables are classified as either required for hot shutdown or important to SSD based on the classification of the 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 Alignment Statement       Alignment Basis                                                                                            Reference Documents Aligns                     Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 8.2,              R2167-1019-001 section 8.2 Attachment B & Attachment C. This methodology includes consideration of interlock and                      R2167-1019-001 Attachment B permissive circuits.                                                                                      R2167-1019-001 Attachment C R2168-1003C-001, "Circuit A "Circuit Analysis Worksheet" is prepared for each SSD component being reviewed. The                      Evaluation Tasks" required fields of the datasheet include:
0     Equipment ID 0     Equipment Description 0    System 0    SSD Category (i.e., HSD, CSD) 0    Fire Zone Location 0     Normal Position 0    HSD/CSD Position 0    Failed Position (air and power) 0    Cable ID 0    Cable Function (i.e., Power, Control, or Instrument) 0    Fault Category 0    Safe Shutdown (Y or N) 0    Drawing Reference Page B-67 Revision 00                                                                                                                                                 Page B-67

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis o    Additional Comments In parallel with the cable selection, the data listed above is entered into the SAFE database, from which the Worksheets can then be generated.
Refer to subsection 3.5.2.4 of this table for discussion of Circuit Failures Due to Inadequate Circuit Coordination.
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NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                  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 Section 3.0 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 Evaluation                     and power required for hot 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 lIl.G.2 of Appendix R requires consideration of hot shorts, shorts-to-ground and open circuits.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Not Required                This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
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NextEra P1BNP                                 Attachment B - NEI 04-02 Table B 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 Section 3.0 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.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                      Reference Documents Not Required                This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections 3.5.1.1 through 3.5.1.3.
Page B-70 Revision 0                                                                                                                                               Page B-70

NextEra PBNP                              Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.1.1     Criteria/Assumptions         Circuit Failure Criteria: The criteria provided below addresses the effects of multiple fire-induced circuit failures impacting circuits for components 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 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, 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 in two 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 in a 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, in addition, 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.
Circuits for "required for hot shutdown" components: Because Appendix R Section 1II.G.1 requires that the hot shutdown capability remain "free of 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 Revision 0                                                                                                                                              Page B-71

NextEra PBNP                              Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis be protected in accordance with one of the requirements of Appendix R Section III.G.2 or plant specific license conditions.
Circuits for "important to safe shutdown" components: Circuits for components classified as "important to safe shutdown" are not specifically 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. (Ifthe effect of the spurious actuation involves a "sealing in" or "latching" mechanism, that is addressed Revision 0                                                                                                                                               Page B-72

NextEra PBNP                                 Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis 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 Ill.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 Ill.G.2. (Other resolution options may also be acceptable, if accepted by the Authority Having Jurisdiction.)
Applicability                               Comments Applicable Alignment Statement      Alignment Basis                                                                                       Reference Documents Aligns                   Existing PBNP methodology is consistent with NEI 00-01 Section 3.5.                                   R2167-1019-001 Section 3.1.5 R2167-1019-001 Section 7.5 Refer to P2168-1008-001 for discussion of IN 92-18 concerns for MOVs                                  R2167-1019-001 Section 8.2 FPER Section 5.2.1.2.2 Refer to sub-section 3.5.2.1 of this table for discussion of open circuits.                           Calc V878-15-CA-01, Appendix R Associated Circuits Analysis Refer to sub-section 3.5.2.2 of this table for discussion of shorts to ground.
Refer to sub-section 3.5.2.3 of this table for discussion of hot shorts and wire-to wire shorts.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.1.2       Criteria/Assumptions             Spurious Operation Criteria: The following criteria address the effect of multiple spurious operations of components classified as either "required 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.
Applicability                                  Comments Applicable Alignment Statement        Alignment Basis                                                                                          Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01 Section 3.5.                                     NISYS-1300-TROOl/RO R2167-1019-001 Section 7.4 The Point Beach MSO Expert Panel review was conducted in November 2008 and MSO Expert                    P2092-Taskl 1OA Panel Report NISYS-1300-TR001/R0 (NISYS) was generated.
During the Transition, Systematic MSO Review Report P2092-Task 1 10A performed MSO reviews to the level of detail expected by RIS 2004-03.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                         Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01 Section 3.5.                                     R2167-1019-001 Section 3.1.5 and 3.2 Cable selection methodology (R2167-1019-001 Section 8.2) includes consideration of switch               R2167-1019-001 Section 8.2 and relay contacts.
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NextEra P1BNP                                 Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2         Types of Circuit Failures     Appendix R requires that nuclear power plants must be designed to prevent exposure fires from defeating the ability to achieve and maintain post-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.
Applicability                               Comments Applicable Alignment Statement        Alignment Basis                                                                                          Reference Documents Not Required               This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections 3.5.2.1 through 3.5.2.5.
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NextEra PBNP                                    Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2.1       Circuit Failures Due to an       This section provides guidance for addressing the effects of an open circuit for required for hot shutdown and Open Circuit                     important to safe shutdown 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.
Applicability                                  Comments Applicable Alignment Statement          Alignment Basis                                                                                            Reference Documents Aligns                       The reference documents require that open circuits be assumed in the circuit analysis for AC               SSAR, Section 3.2.2.4.1 and DC power cables, control and indication cables, and instrumentation cables.                            SSAR, Section 1.4.3, item g FPER, Section 5.2.1.2.3, item g EPM Report No. R2014-001, "Technical Evaluation Associated with the Open Circuiting of                     R2167-1019-001 Section 3.1.5 Current Transformers Contained in 13.8KV, 4KV and 480V Switchgear" assess the possibility of               R2014-001 Rev 0 a secondary fire being initiated as a result of a fault associated with the open circuiting of current transformers located in safe shutdown switchgear. The process uses screening criteria to determine if each set of current transformers has the potential to become an ignition hazard when the secondary circuitry is open circuited.
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NextEra PBNP                                        Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2.2        Circuit Failures Due to a          This section provides guidance for addressing the effects of a short-to-ground on circuits for required for hot Short-to-Ground                     shutdown and important to safe 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 in the 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.
Applicability                                     Comments Applicable                                        See "Alignment Basis" for exceptions to 'Align with Intent' grade.
Alignment Statement           Alignment Basis                                                                                          Reference Documents Aligns with Intent            The existing PBNP methodology for analysis of Circuit failures Due to a Short to Ground is               SSAR, Section 3.2.2.4.1 consistent with NEI 00-01, Section 3.5, however existing coordination issues for plant protective        SSAR, Section 1.4.3, item g circuit breakers could lead to loss of electrical distribution equipment affecting safe shutdown         FPER, Section 5.2.1.2.3, item g equipment operability. Specifically:                                                                     R2167-1019-001 Section 3.1.5, 8.3.2.1 and 8.3.2.3 SSAR Section 3.2.2.4.1 states "Itwas assumed that fire damage results in an unusable cable that cannot be considered functional with regard to ensuring proper circuit operation. The insulation and external jacket material of electrical cables are susceptible to fire damage.
Damage may assume several forms including deformation, loss of structure, cracking, and ignition. The relationship between exposure of electrical cable insulation to fire conditions, the failure mode, and time to failure may vary with the configuration and cable type. To accommodate these uncertainties in a consistent and conservative manner, the circuit analysis assumes that the functional integrity of electrical cables was lost when cables are exposed to a fire, except where protected by a fire rated barrier.
Electrical circuits exposed to a fire are considered susceptible to the following credible failure modes:
* Short Circuit - A path of low resistance where the conductor passes abnormally high current.
* Short to Ground - An individual conductor that comes into electrical contact with a grounded conducting device, such as a cable tray, conduit, or metal housing.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.2 Nuclear Safety Capability Circuit Analysis
                         - Hot Short - An energized external conductor that comes into electrical contact with another conductor, thereby energizing the affected conductor.
                         - Open Circuit - An individual conductor that loses electrical continuity.
Credible circuit failures include:
                         "Open circuits, shorts-to-ground, and short circuits "One hot short/short circuit per affected component or multiple hot shorts/short circuits for high/low pressure interface components NOTE: Cases in which it was necessary to have a hot short in combination with another specific fault in order to produce adverse circuit affects are analogous to multiple proper polarity faults and are thus considered not credible.
Two types of cable hot short conditions are considered to be of sufficiently low likelihood that they are not assumed credible, except for cases involving high/low pressure interface components. These hot shorts are:
* 3-phase ac power circuit cable-to-cable proper phase sequence faults
* 2-wire ungrounded dc circuit cable-to-cable proper polarity faults Instrument circuits that operate at low signal levels (4-20 mA, 0-1 V, 1-5 V, etc.) and are enclosed in a grounded metal shield are not considered to be susceptible to hot shorts from other adjacent instrument or control circuits external to the shield. External circuits are assumed to short to ground via the shield and do not have the potential of creating a signal of proper polarity and amplitude to simulate a valid instrument signal. Instrument circuits are, however, assumed to be susceptible to short circuits (from conductors within the shield), open circuits and shorts-to-ground."
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NextEra PBNP                                      Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2.3       Circuit Failures Due to a         This section provides guidance for analyzing the effects of a hot short on circuits for required for required for hot Hot Short                         shutdown and important to safe 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.
Applicability                                    Comments Applicable Alignment Statement          Alignment Basis                                                                                            Reference Documents Aligns                       The existing PBNP methodology is consistent with NEI 00-01, Section 3.5.2.3.                               R2167-1019-001 Section 3.1.5 R2168-1003c-001 During the course of NFPA-805 Transition, the majority of SSD-credited devices received a cable selection review. To address the question of "legacy" cable selection (pre-transition and not reviewed), two "sampling" efforts were undertaken and documented in R2168-1003c-001.
Legacy cable selection was deemed to be adequate and conservative.
All instrument circuits using twisted shielded pair wiring were specifically reviewed during transition and their cable selection updated in SAFE.
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NextEra P13NP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review                     Review NextEra PBNP                                    Attachment B NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location Physical location of equipment and cables shall be identified.
NEI 00-01 Ref                                  NEI 00-01 Section 3.0 Guidance 3.3.3.4       Identify Routing of Cables       Identify the routing for each cable including all raceway and cable endpoints. Typically, this information is obtained from joining the list of safe shutdown cables with an existing cable and raceway database.
Applicability                                  Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section                R2167-1019-001 section 8.3.5 8.3.5. This methodology includes identification of fire area locations for SSD equipment, SSD cable to/from equipment and SSD raceways.
The routing for each SSD cable, including all raceways and cable endpoints is obtained from the controlled PBNP Cable and Raceway System EDISON.
Note that during the course of the Transition, many cable endpoint (FROM and TO Equipment fields) were populated in EDISON. When calculating cable-FZs, EDISON includes the FZ location of the end devices as listed in the FROM and TO Equipment fields. EDISON then provides that cable-FZ info to the SAFE analysis tool.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B 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 Section 3.0 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 Raceway and Cables by           information with the cable routing data. For raceway and cable endpoints in multiple fire areas, each fire area where Fire Area                       the raceway or cable endpoint exists must be included. In 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 Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                       Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section               R2167-1019-001 section 8.3.5 8.3.5. This methodology includes identification of fire area locations for SSD equipment, SSD cable to/from equipment and SSD raceways.
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NextEra PBNP                               Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2.4     Circuit Failures Due to      The evaluation of circuits of a common power source consists of verifying proper coordination between the supply Inadequate Circuit           breaker/fuse and the load breakers/fuses for power sources that are required for hot shutdown. The concern is that, Coordination                 for fire damage to a single power cable, lack of 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.
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.
                                         - Sequence of the raceway in the cable route.
                                         - Fire zone/area in which the raceway is located.
Revision 0                                                                                                                                              Page B-83

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location For fire zones/areas in which 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.
Applicability                                Comments Applicable Alignment Statement      Alignment Basis                                                                                         Reference Documents Aligns with Intent       The PBNP SSAR, Section 3.3.1.2 identifies requirements for the Common Power Supply                      FPTE-2007-001 concern. Section 6.0 of FPTE-2007-001 provides a qualitative assessment of the Inadequate               Calculations:
Circuit Coordination concern for PBNP Units 1 and 2. The overall conclusion of this                     2004-0009 assessment is that proper selectivity (i.e., fault current trips branch breaker before main             2001-0049 breaker) has been demonstrated for the Non-i E 13.KV systems and the Class 1E 4kV, 480V,                2004-0030 120V AC, and 125V DC Electrical Distribution Systems at the site with some identified                   N-92-005 exceptions. This assessment is supported by the following site Electrical Design Calcs and              V878-15-CA-02 evaluations:                                                                                            R2167-1019-001 Section 8.3.3 Sargent & Lundy Report, "Safe o FPTE-2007-001 (Technical Evaluation for Assoc. Circuits by Common Power Supply and                    Shutdown 120VAC Distribution Common Enclosure)                                                                                       Panel Coordination Evaluation" o 2004-0009 (13.8KV & 4KV Switchgear) o 2001-0049 (480V Switchgear) o 2004-0030 (480V MCC's) o N-92-005 (125VDC Distribution Panels) o V878-15-CA-02 (120VAC & 125VDC Distribution Panels) o Sargent & Lundy report, "Safe Shutdown 120VAC Distribution Panel Coordination Evaluation" Overall, the existing PBNP methodology for analysis of Circuit Failures Due to Inadequate Circuit Coordination is consistent with NEI 00-01, Section 3.5, however existing coordination issues for plant protective circuit breakers could lead to loss of electrical distribution equipment affecting safe shutdown equipment operability. Subsequently, FPTE-2007-001 was performed to verify coordination and new power supplies identifed during NFPA 805 transition. Further evaluations were performed to validate each of the coordination issues identified in FPTE-2007-001 to determine the impact upon the safe shutdown analysis and whether design changes are required. Summary results are as follows:
13KV & 4KV Switchgear Various instances of potential impact to Appendix R were identified in calculation 2004-0009.
Action requests were initiated and the issues were evaluated to identify design changes Page B-84 Revision 0                                                                                                                                              Page B-84

NextEra Pl3NP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location required to meet Appendix R requirements. The issues were reviewed for compliance to NFPA 805 and no additional changes were identified. Refer to Action Request Nos. AR # 01298593, AR # 01298594 for disposition of those instances where there was a lack of coordination. See Alignment Basis for 3.5.2.5 for a discussion of loss of breaker coordination due to loss of DC control power.
480V Switchgear Calculation 2001-0049 identified nine instances where there was a lack of coordination. New breaker settings were identified by the Calculations Reconstitution Project and CAP #028771 (NAMS AR 01224052) was initiated. This CAP is shown as being complete and closed 3/11/2003. With the recommended breaker settings made, the breaker coordination for the 480 volt switchgear busses evaluated in this calculation is complete. In addition, Action Requests 01224052 and 01339558 were issued to disposition many of the issues identified in the calculation. The dispositions were reviewed and there are no additional impacts on NFPA-805.
480V Motor Control Centers Calculation 2004-0030 identified various instances where coordination could not be demonstrated. In each of these cases, the technical evaluation review was able to identify a technical justification to support that there is no impact to NFPA-805 compliance.
Full selective coordination does not exist between the supply breaker to MCC B-21 and all load breakers. Modify MCC B-21 supply breaker settings to provide full coordination. Refer to Attachment S-2.
120VAC Distribution Panels (Addressed in FPTE-2007-001)
The technical evaluation review identified a potential coordination issue associated with 120VAC distribution panels 1Y103, 1Y1 04, 2Y103 and 2Y104. Each of these panels contain a 100 ampere breaker associated with Radiation Monitoring System. Since these branch breakers are large thermal magnetic breakers they require long time durations to trip open on low fault levels.
The inverter output breakers associated with powering these distribution panels are designed to trip when fault levels reach 260 amperes or more for a duration in excess of 5 seconds. Since the inverters are capable of generating fault currents in this order of magnitude, this condition could result in the tripping of the associated inverter output breaker upon a fault of the cable(s) providing power to the Radiation Monitoring System. As a result, AR # 01316511 has been initiated to identify this issue. See Attachment S Table S-2.
PBNP does not have a single calculation which addresses both safe shutdown and non-safe shutdown branch feeder protective devices with respect to coordination. As a result, it was necessary for the technical evaluation review to review the various distribution panels required for safe shutdown. With exception of the four 120VAC buses identified above, the technical Revision 0                                                                                                                        Page B-85

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                  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 evaluation was successful in demonstrating that most of the circuits from these panels are routed in alternate shutdown areas or that electrical coordination exists. Since many of the cables are in alternate shutdown fire areas, the failure of these circuits is not of concern with respect to the failure of these power supplies. PBNP has alternate shutdown capability which is independent of these fire areas.
Full selective coordination does not exist regarding the 120VAC safety related instrument busses, as documented in Sargeant and Lundy Report, "Safe Shutdown 120VAC Distribution Panel Coordination Evaluation". Modifications are being implemented to eliminate this vulnerability. See Attachment S Table S-2.
125VDC Distribution Panels A review of calculation N-92-005 Revision 2 concluded that the only lack of coordination potentially impacting NFPA-805 compliance is the lack of coordination of fuse D72-14-02 on panel D-14 with fuse D72-02-06 on panel D-02. The replacement of fuse D72-14-02 is to be accomplished by AR # 01232138.
Numerous fuses associated with 13.8KV system 125VDC control power have ratings below the normal operating voltage and require replacement. Refer to AR 01877063.
120VAC and 125 VDC Distribution Panels Calculation no. V878-15-CA-02 performed a review of both the 120VAC and 125VDC distribution panels. The 125 VDC branch circuits are coordinated and, as a result, have no impact on NFPA-805 compliance. For the 120 VAC branch circuits, the inverter backup power supply has high available fault current which results in a lack of coordination. In order to achieve coordination, modifications will be performed. Refer to Attachment S, "Modification and Implementation Items".
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NextEra PBNP                                      Attachment B - NEI 04-02 Table B 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 Section 3.0 Guidance 3.5.2.5       Circuit Failures Due to            The common enclosure associated circuit concern deals with the possibility of causing secondary failures due to fire Common Enclosure                   damage to a circuit either whose isolation device fails to isolate the cable fault or protect the faulted cable from Concerns                           reaching its ignition temperature, or the fire somehow propagates along the cable into 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                                       See "Alignment Basis" for exceptions to 'Align with Intent' grade.
Alignment Statement          Alignment Basis                                                                                            Reference Documents Aligns with Intent           The primary issue is the ignition of a secondary fire which then results in failure of cables local        SSAR Section 3.3.2.1 to that fire.                                                                                              FPTE-2007-001 Calculations:
The PBNP SSAR, Section 3.3.2 identifies requirements for the Common Enclosure concern.                     2004-0009 Section 6.0 of FPTE-2007-001 provides a qualitative assessment of the Common Enclosure                     2001-0049 concern for Point Beach Units 1 and 2.                                                                     2004-0030 2005-0005 Overall, the existing PBNP methodology for analysis of Circuit Failures Due to Common                      N-92-005 Enclosure Concerns is consistent with NEI 00-01, Section 3.5, however existing cable protection            V878-15-CA-02 issues for proper circuit protection could lead to loss of electrical distribution equipment affecting     R2167-1019-001 Section 8.3.4.1 safe shutdown equipment operability.
FPTE-2007-001 was performed to further resolve these common enclosure issues. Summary results are as follows:
13kV & 4kV Switchgear Calculation 2004-0009 either demonstrated adequate cable protection or a technical justification was provided in the evaluation.
Point Beach reviewed the loss of DC control and the effect of that loss on the ability of breakers to clear a fault. The concern is ignition of the faulted cable in a location other than the affected fire area. Point Beach determined that several breakers at the 4 kV and 13 kV level were susceptible to this failure mode. Modifications are being implemented to eliminate this vulnerability. See Attachment S Table S-2.
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NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.3 Nuclear Safety Equipment and Cable Location 480V Switchgear Calculation 2001-0049 identified several instances where cable protection was in question.
However, it was demonstrated that these cables were either in the same fire area as their associated power supplies or that the fault current only exceeds the thermal withstand for a short distance from the power supply at which point the fault current decreased to an acceptable level.
480V Motor Control Centers Nine cables were identified in Sargent and Lundy Calculation 2013-01785 that are not fully protected for overloads in the short time region. Modifications are being implemented to eliminate this vulnerability. See Attachment S Table S-2.
Numerous cables were identified in Sargent and Lundy Calculation 2013-01785 that are not fully protected for short circuits in the instantaneous region. However, the fault current only exceeds the thermal withstand for a short distance from the power supply at which point the fault current decreases to an acceptable level.
Evaluation of cable protection for cables supplied from non-safe shutdown 480V MCCs and power panels, and 208/120V lighting panels is incomplete (Ref. AR 1877063). Modifications are being implemented to eliminate this vulnerability. See Attachment S Table S-2.
120VAC Distribution Panels Calculation 2005-0005 addresses the thermal withstand capability of power cables directly connected to the individual panel busses. Although a large portion of the cables were shown to have sufficient thermal withstand capability, there were a number cables which were deficient.
As a result, FPTE-2007-001 addressed many of these deficiencies by either identifying those circuits routed in a single fire area or in Alternate Shutdown fire areas only. Only single circuit failed meet one of these conditions. Further analysis was performed on the cable to demonstrate that its thermal withstand capability would not be exceeded for a fire outside of the fire area of the power supply.
125VDC Distribution Panels No issues have been identified regarding protection of 125VDC system cables.
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                     Attachment B NEI 04-02 Table B-2 Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment An engineering analysis shall be performed in accordance with the requirements of Section 2.3 for each fire area to determine the effects of fire or fire suppression activities on the ability to achieve the nuclear safety performance criteria of Section 1.5. See Chapter 4 for methods of achieving these performance criteria (performance-based or deterministic).
NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.4            Fire Area Assessment and         By determining the location of each component and cable by fire area and using the cable to equipment Compliance Strategies            relationships described above, the affected 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.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                           Reference Documents Aligns                      The methodology for performing the NSCA Analysis for PBNP is provided in Section 10 of                    R2167-1019-001 Section 10 R2167-1019-001. The instructions include assessment of fire-affected equipment in each area, and the compliance strategies for SSD equipment and systems.
The results of the Fire Area Analysis were documented for each Fire Area in the SAFE database and R2167-1019-001.
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                       ... ieAraAssmn Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPt~A805SetiN:P NextEra    PBNP                               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 Section 3.0 Guidance 3.4.1         Criteria/Assumptions           The following criteria and assumptions apply when performing "deterministic" 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.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                       Reference Documents Not Required                This paragraph provides introductory information but contains no specific guidance for comparison. Discussion is provided in subsequent subsections.
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.4.1.1       Criteria/Assumptions             Assume only one fire in any single fire area at a time.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                   Reference Documents Aligns                      An exposure fire involving either transient or in situ combustibles is assumed to occur in only   R2167-1019-001 Section 3.2.1 one fire area at a time. The only failures that are considered are those directly attributable to the postulated fire and spurious operation of equipment due to fire induced cable damage. No other failures (equipment out of service) or design basis events (DBEs) (e.g., High Energy Line Break, Station Blackout, etc.) are assumed to occur simultaneously. Simultaneous fire concerns as discussed in USNRC Information Notice (IN) 97-01 are not credible, as Point Beach's electrical distribution system, including transformers, are properly grounded by design.
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                   NEI 00-01 Section 3.0 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 required by the regulation.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                          Reference Documents Aligns                      Fire damage is assumed to render a cable and electrical components nonfunctional with regard             R2167-1019-001 Section 3.2.1 to ensuring proper circuit operation. The insulation and external jacket material of electrical cables are susceptible to fire damage, as are the materials of electrical components. Damage may assume several forms including deformation, loss of structure, loss of function, cracking, and ignition. The relationship between exposure of electrical cables and components to fire conditions, the failure mode, and the time to failure may vary with the configuration and cable/component type. To accommodate these uncertainties in a consistent and conservative manner, it is assumed that the functional integrity of electrical cables and components is lost when they are exposed to a postulated fire in a Fire Area, except where protected by a fire rated barrier within the Fire Area (or radiant energy shield within containment).
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                   NEI 00-01 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                         Reference Documents Aligns                      The NSCA addresses all impacts of cables and equipment in the affected fire area.                       R2167-1019-001 Section 10 Components directly impacted by the fire, as well as those located outside the fire area with impacted control or power circuitry in the fire area, are addressed.
All equipment affected by a postulated fire is identified, using SAFE displays which identify equipment and cables affected by a fire in the area. This equipment includes:
                            " Equipment physically located in the area
                            " Equipment whose REQD cables are physically located in the Fire Area
                            " Equipment affected for other reasons, such as instrument tubing, instrument air, loss of motive or control power, etc.
For each safe shutdown equipment impacted by a fire in the area, the method to achieve compliance with NSCA requirements is documented using Resolutions in SAFE. Note that ALL failures are not resolved, only those that are required to recover a successful path of logics, including spurious ops impacting that path.
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NextEra P13NP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 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 Alignment Statement         Alignment Basis                                                                                   Reference Documents Aligns                      NSCA Report Section 3.1.2 provides instruction for component selection. Support component         R2167-1019-001 Section 3.1.2 logics and system logics relationships are established in SAFE; all components supporting Required SAFE Performance Goals are considered to be Required for Hot Shutdown. An "Optional" Performance Goal collects those systems that are not required to succeed in all cases.
Reviion                                                                                                    Pag B-I Revision 0                                                                                                                                           Page B-94

NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 Guidance 3.4.1.5       Criteria/Assumptions            Use operator manual actions where appropriate, for cable component impacts classified as important to SSD cables/
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 the primary flow path, refer to Appendix H.
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                    Reference Documents Aligns                      Use of Operator Manual Actions (OMAs) in II.G.2 areas is a key focus area in the NFPA-805          FPTE-012 (10/2005)
Transition and determination of SSD Strategies in each Fire Area. OMAs that are needed will        R2167-1019-001 Section 10.3 be evaluated as Variances From Deterministic Requirements (VFDRs).                                 R2168-1012-001 R2168-1012-001, "Recovery Actions Transition" evaluates the feasibility of credited Recovery Actions Page B-95 Revision 0                                                                                                                                           Page B-95

NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 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 Applicable Alignment Statement         Alignment Basis                                                                                  Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section          R2167-1019-001 Section 3.2.2 3.2.2. Plant procedures provide required details to repair the necessary equipment to achieve    R2092-1500-001 Revision E, "Non-cold shutdown conditions.                                                                        Power Operation Modes Transition Review".
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NextEra PB3NP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NextEra PBNP                                    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 Section 3.0 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, including associated circuits, 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 path(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 (lll.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 (llI.G.2.b).
                                              - Enclosure of cable and equipment and associated non-safety 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 (lll.G.2.c).
For fire areas inside noninerted 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 (lll.G.2.d);
                                              - Installation of fire detectors and an automatic fire suppression system in the fire area (lIl.G.2.e); or
                                              - Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield (lll.G.2.f).
Use exemptions, deviations and licensing change processes to satisfy the requirements mentioned above and to demonstrate equivalency depending upon the plant's license requirements.
Applicability                                 Comments Applicable Alignment Statement        Alignment Basis                                                                                          Reference Documents Aligns                     Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 5.0.             R2167-1019-001 Section 5.5 The deterministic criteria are part of the acceptable compliance strategies used in the transition.
Where recovery actions are specified because of a lack of separation in accordance with NFPA 805 section 4.2.3, Variances from Deterministic Requirements (VFDR) are documented and evaluated via the Fire Risk Evaluation (FRE) process.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 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.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                      Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 7.2.         R2167-1019-001   Attachment  A The PBNP NSCA has identified redundant trains and equipment in the SSEL (Attachment A)               R2167-1019-001   Attachment  C and logic diagrams (Attachments C, D & E).                                                           R2167-1019-001   Attachment  D R2167-1019-001   Attachment  E Note: The compliance strategy focus is on recovery of the least impacted train by preventive measures or mitigating actions.
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NextEra P13NP                                Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                               NEI 00-01 Section 3.0 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 posffire safe shutdown capability. This can be done systematically or via procedures such as Emergency Operating Procedures.
Applicability                               Comments Applicable Alignment Statement        Alignment Basis                                                                                        Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 7.3.          R2167-1019-001 Section 7.3 FPEE-1999-017 and -019 evaluate the separation of redundant instrumentation. Additionally,            FPEE-1999-017 and -019 CALC-WE0005-13 addresses instrument line freezing following a loss of heat tracing.                   CALC-WE0005-13 Page B-99 Revision 0 Revision                                                                                                                                                 Page B-99

NextEra PBNP                                  Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.4.2         Methodology for Fire Area      Refer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.
Assessment Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:
Applicability                                Comments Applicable Alignment Statement       Alignment Basis                                                                                          Reference Documents Not Required              This is an introductory paragraph with no specific criteria. Requirements are in the subsequent subsections.
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NextEra P13NP                                      Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                     NEI 00-01 Section 3.0 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 Equipment by Fire Area              by the fire. Provide this 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).
Applicability                                     Comments Applicable Alignment Statement         Alignment Basis                                                                                           Reference Documents Aligns                       Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 9.1.             R2167-1019-001 section 9.1 The utilized analysis tool (SAFE) displays provides reports of all potentially damaged equipment          R2167-1019-001 Attachment F in the fire area (or analysis area) being evaluated.
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NextEra PBNP                                     Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.4.2.2       Determine the Shutdown            Based on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are Paths Least Impacted By a         either unaffected or least impacted by a postulated fire within the fire area. Typically, the safe shutdown path with Fire in Each Fire Area            the least number of cables and equipment in the fire area would be selected as the required safe shutdown path.
Consider the circuit failure criteria and the possible mitigating strategies, however, in 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.
Applicability                                   Comments Applicable Alignment Statement         Alignment Basis                                                                                           Reference Documents Aligns                      Existing PBNP methodology is consistent with NEI 00-01, refer to R2167-1019-001 section 10.               R2167-1019-001 Section 10 The SAFE analysis tool displays failed performance goals, systems, equipment and cables and               R2167-1019-001 Attachment F provides the ability to resolve failures of cables or equipment. Resolved cables and equipment are not considered failed during subsequent analysis runs, and supported equipment and systems are recovered thereby. Resolutions may direct operator actions, discuss why a failure is acceptable, or demonstrate that the failure will not occur in a given fire scenario.
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NextEra PBNP                                 Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                               NEI 00-01 Section 3.0 Guidance 3.4.2.3       Determine Safe Shutdown       Using the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment Equipment Impacts             that can impact safe shutdown and that can potentially be impacted by a fire in the fire area, and what those possible impacts are.
Applicability                               Comments Applicable Alignment Statement       Alignment Basis                                                                                         Reference Documents Aligns                    The impact of each component or cable on safe shutdown is assessed as part of the NSCA                  R2167-1019-001 Section 10 methodology.
The existing PBNP methodology for Fire Area Assessment and Compliance Strategies is consistent with NEI 00-01, Section 3.4.
Note: See also sub-section 3.5 of this table for impacted circuit analysis.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 Guidance 3.4.2.4       Develop a Compliance           The available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Strategy or Disposition to      Figure 1-1):
Mitigate the Effects Due to Fire Damage to Each             Required for Hot Shutdown Components:
Required Component or          - Re-design the circuit or component to eliminate the concern. This option will require a revision to the post-fire safe Cable                          shutdown analysis.
                                             - 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 Ill.G.2.d, e and f.
Applicability                                Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      A compliance strategy that addresses circuit failures is included as part of the NSCA                  R2167-1019-001 Section 5.5 methodology. The methods included are the same as in NEI 00-01 guidance, and are included in R2167-1019-001 Section 5.5: providing fire barriers, ensuring separation, using redundant equipment, developing exemptions, etc.
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NextEra PBNP                                   Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review NFPA 805 Section: 2.4.2.4 Fire Area Assessment NEI 00-01 Ref                                 NEI 00-01 Section 3.0 Guidance 3.4.2.5       Document the Compliance         Assign compliance strategy statements or codes to components or cables to identify the justification or mitigating Strategy or Disposition         actions proposed for achieving safe shutdown. The justification should address the cumulative effect of the actions Determined to Mitigate the      relied upon by the licensee to mitigate a fire in the area. Provide each piece of safe shutdown equipment, equipment Effects Due to Fire Damage      not in the path whose spurious operation or mal-operation could affect safe shutdown, and/or cable for the required to Each Required                safe shutdown path with a specific compliance strategy or disposition. Refer to Attachment 6 for an example of a Component or Cable              Fire Area Assessment Report documenting each cable disposition.
Applicability                                 Comments Applicable Alignment Statement         Alignment Basis                                                                                        Reference Documents Aligns                      The SAFE Reports contained in R2167-1019-01 document the compliance strategy for each                  R2167-1019-001 Section 10 analysis area at Point Beach.
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