ML13277A041

Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition

ML13277A041
Person / Time
Site:	Brunswick
Issue date:	09/19/2013
From:	Carolina Power & Light Co
To:	Office of Nuclear Reactor Regulation
References
TAC ME9623, TAC ME9624
Download: ML13277A041 (108)

Text

Enclosure 3 Revised Brunswick NFPA 805 Transition Report, Transitionto 10 CFR 50.48(c) - NFPA 805 Performance-BasedStandardfor Fire Protection for Light Water Reactor Electric GeneratingPlants, 2001 Edition, Transition Report, September 19, 2013 Main Report Without Attachments

Carolina Power & Light Brunswick Steam Electric Plant Units 1 and 2 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 September 19, 2013

CP&L NFPA 805 Transition Report TABLE OF CONTENTS Revision Summary ......................................................................................................... i Executive Summary ...................................................................................................... ii Acronym List ................................................................................................................ iii

1.0 INTRODUCTION

................................................................................................ I 1.1 Ba ckg ro u nd ........................................................................................................ 1 1.1.1 NFPA 805 - Requirements and Guidance ................................................. 1 1.1.2 Transition to 10 CFR 50.48(c) ................................................................ 2 1.2 Purpose ........................................................................................................ 3 2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM ............................ 4 2.1 Current Fire Protection Licensing Basis ......................................................... 4 2.2 NRC Acceptance of the Fire Protection Licensing Basis ............................... 4 3.0 TRANSITION PROCESS .................................................................................... 8 3.1 Background ..................................................................................................... 8 3.2 NFPA 805 Process ...................................................................................... 8 3.3 NEI 04 NFPA 805 Transition Process .................................................. 10 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 ........................... 15 4.2.2 Existing Engineering Equivalency Evaluation Transition .................... 23 4.2.3 Licensing Action Transition .................................................................. 24 4.2.4 Fire Area Transition ............................................................................. 24 4.3 Non-Power Operational Modes .................................................................... 28 4.3.1 Overview of Evaluation Process ........................................................ 28 4.3.2 Results of the Evaluation Process ...................................................... 31 4.4 Radioactive Release Performance Criteria .................................................. 32 4.4.1 Overview of Evaluation Process ........................................................ 32 4.4.2 Results of the Evaluation Process ...................................................... 32 4.5 Fire PRA and Performance-Based Approaches .......................................... 50 BSEP LAR Rev 3 Page i

CP&L NFPA 805 Transition Report 4.5.1 Fire PRA Development and Assessment ............................................. 51 4.5.2 Performance-Based Approaches ......................................................... 52 4.6 Monitoring Program .................................................................................... 57 4.6.1 Overview of NFPA 805 Requirements and NEI 04-02 Guidance on the NFPA 805 Fire Protection System and Feature Monitoring Program ...... 57 4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program .............. 58 4.7 Program Documentation, Configuration Control, and Quality Assurance ........ 63 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NF P A 805 ......................................................................................... . . 63 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 ............................................................................... 66 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 .... 70 4.8 Sum m ary of Results ..................................................................................... 72 4.8.1 Results of the Fire Area Review ........................................................ 72 4.8.2 Plant Modifications and Items to be Completed During the Implementation P hase ................................................................................................ . . 73 4.8.3 Supplemental Information -Other Licensee Specific Issues ............... 73

5.0 REGULATORY EVALUATION

......................................................................... 83 5.1 Introduction- 10 CFR 50.48 ....................................................................... 83 5.2 Regulatory Topics ....................................................................................... 88 5.2.1 License Condition Changes ................................................................ 88 5.2.2 Technical Specifications ...................................................................... 88 5.2.3 Orders and Exemptions ...................................................................... 88 5.3 Regulatory Evaluations ................................................................................ 88 5.3.1 No Significant Hazards Consideration ................................................. 88 5.3.2 Environmental Consideration ............................................................. 88 5.4 Revision to the UFSAR ................................................................................ 89 5.5 Transition Implementation Schedule ........................................................... 89

6.0 REFERENCES

.................................................................................................. 90 ATTACHMENTS ....................................................................................................... 92 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 Rev 33 LAR Rev BSEP LAR Page ii I I

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CP&L NFPA 805 Transition Report E. NEI 04-02 Radioactive Release Transition ................................................. E-1 F. Fire-Induced Multiple Spurious Operations Resolution ............................. F-1 G. Recovery Actions Transition ....................................................................... G-1 H. NFPA 805 Frequently Asked Question Summary Table ............................ H-1 I. 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 BSEP Rev 33 LAR Rev Page iii I I

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CP&L NFPA 805 Transition Report Revision Summary Latest Attachment Title Revision Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire 2 Protection Program & Design Elements Attachment B NEI 04-02 Table B Nuclear Safety Capability 2 Assessment - Methodology Review Attachment C NEI 04-02 Table B Fire Area Transition 2 Attachment D NEI 04-02 Non-Power Operational Modes Transition 0 Attachment E NEI 04-02 Radioactive Release Transition 0 Attachment F Fire-Induced Multiple Spurious Operations 0 Resolution Attachment G Recovery Actions Transition 2 Attachment H NFPA 805 Frequently Asked Question Summary 0 Table Attachment I Definition of Power Block 0 Attachment J Fire Modeling V&V 2 Attachment K Existing Licensing Action Transition 0 Attachment L NFPA 805 Chapter 3 Requirements for Approval 2 (10 CFR 50.48(c)(2)(vii)

Attachment M License Condition Changes 0 Attachment N Technical Specification Changes 0 Attachment O Orders and Exemptions 0 Attachment P RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) 0 Attachment Q No Significant Hazards Evaluations 0 Attachment R Environmental Considerations Evaluation 0 Attachment S Modifications and Implementation Items 2 Attachment T Clarification of Prior NRC Approvals 0 Attachment U Internal Events PRA Quality 0 Attachment V Fire PRA Quality 2 Attachment W Fire PRA Insights 3 BSEP Rev 33 LAR Rev Pagei I BSEP LAR Page i 1

CP&L Executive Summary Executive Summary CP&L will transition the Brunswick Steam Electric Plant (BSEP), Units 1 and 2 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 licensing basis per License Condition 2.B.(6) will be superseded.

The transition process consisted of a review and update of BSEP 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:

o Non-Power Operational Modes o Fire Risk Evaluations o 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 provide 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 RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this License Amendment Request.

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CP&L Acronym List CP&L Acronym List Acronym List ABH Auxiliary Boiler House AC Alternating Current AC/DC Alternating Current/Direct Current ACLE Allowable Combustible Load Equivalent ADAMS Agency wide Documents Access and Management System ADANX Admin -Annex Building (Security Office Building)

ADS Automatic Depressurization System AFEB Alternate Fire Equipment Building AFFF Aqueous Film Forming Foam AHJ Authority having jurisdiction ANS American Nuclear Society AO Auxiliary Operator AOG Augmented Off-Gas Building AOV Air Operated Valve APCSB Auxiliary and Power Conversion Systems Branch ASME American Society of Mechanical Engineers ASSD Alternate Safe Shutdown ASTM American Society for Testing and Materials ATWS Anticipated Transient Without Scram BGA Brunswick Global Analysis BKR Breaker BNP Brunswick Nuclear Plant (i.e., BSEP)

BOP Balance of Plant BSEP Brunswick Steam Electric Plant, Units 1 and 2 BTP Branch Technical Position BWR Boiling Water Reactor BWROG Boiling Water Reactor Owner's Group CAC Containment Atmosphere Control Rev 33 Page iii I I

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CP&L Acronym List CP&L Acronym List CAFTA Computer Aided Fault Tree Analysis CAP Corrective Action Program CAS Central Alarm Station CASBCH Caswell Beach CAT Capability Category CB Control Building Cause Based Decision Tree Method/Techniques for CBDTM/THERP Human Error Rate Prediction CBT Computer Based Training CBDTM Cause Based Decision Tree Method CC Capability Category CCI Capability Category I CCDF Conditional Core Damage Frequency CCDP Conditional Core Damage Probability CDF Core Damage Frequency CDM Current Design Method CET Core Exit Thermocouples CFAST Consolidated Model of Fire and Smoke Transport CFD Condensate Filter Demineralizer CFR Code of Federal Regulation CGB Cable Gripping Bushing CLB Chlorination Building CLB Current Licensing Basis CLERP Conditional Large Early Release Probability CLK Nelson Firestop CLTTM Silicone Sealant CM Clean Maintenance CP&L Carolina Power and Light CPT Control Power Transformers CR3 Crystal River Unit 3 Nuclear Power Plant CRD Control Rod Drive CRS Control Room Supervisor CS Core Spray Page iv I!

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CP&L AcoymLs CP&L Acronym List CSD Cold Shutdown CSS Core Spray System CST Condensate Storage Tank CSW Conventional Service Water CTPH1 Condensate Transfer Pump House Unit 1 CW Circwater Yard CW Circulating Water System CWOD Circulating Water Ocean Discharge DBA Design Basis Accidents DBD Design Basis Document DC Direct Current DFO Diesel Fuel Oil DG Diesel Generator Building DGB Diesel Generator Building DID Defense-in-Depth DSO Director of Site Operations DWT Demineralized Water Tank EC Engineering Change ECCS Emergency Core Cooling System EDB Equipment Database EDG Emergency Diesel Generator EEE Engineering Equivalency Evaluations EEEE Existing Engineering Equivalency Evaluations EHC Electro-Hydraulic Control EOOS Equipment Out-of-Service EPRI Electric Power Research Institute EQ Environmental Qualification ERFBS Electrical Raceway Fire Barrier Systems ESFAS Engineered Safeguards Actuation Signal EY East Yard FC Fire Compartment F&O Facts and Observations Rev 33 LAR Rev BSEP LAR Pagev I BSEP Page v I

CP&L Acronym List CP&L Acronym List FAQ Frequently Asked Question FB Fire Brigade FDS Fire Dynamics Simulator FDT Fire Dynamics Tools FHA Fire Hazards Analysis FICF Fire Induced Circuit Failure FIN Fix It Now FMEA Failure Modes and Effects Analysis FP Fire Protection FPIP Fire Protection Initiatives Project FPPM Fire Protection Program Manual FPRA Fire Probabilistic Risk Analysis or Assessment FRE Fire Risk Evaluation FSA Fire Safety Analysis FSAR Final Safety Analysis Report FSSPMD Fire Safe Shutdown Program Manager Database FTL Fault Tree Logic GDC General Design Criterion GL Generic License GPAB Global Plant Analysis Boundary GPM Gallons per Minute HCTL Heat Capacity Temperature Limit HEAF High Energy Arcing Fault HEP Human Error Probabilities HEPA High Efficiency Particulate Air HFE Human Failure Event HGL Hot Gas Layer HLP High/Low Pressure Interface HNP Shearon Harris Nuclear Power Plant HP Health Physics HPCI High Pressure Coolant Injection HPI High Pressure Injection Page vi I BSEP LAR BSEP Rev 33 LAR Rev Page vi I

CP&L Acronym List HR Human Reliability Analysis technical element from the PRA standard HRA Human Reliability Analysis HRE Higher Risk Evolutions HRR Heat Release Rate HSD Hot Shutdown HSM Horizontal Storage Module HSS High Safety Significance HVAC Heating, Ventilation and Air Conditioning HX Heat Exchanger I&C Instrumentation and Controls IE Initiating Event technical element from PRA standard Internal Flood Scenario Development technical element from the PRA standard Internal Flood Source Identification technical element from the PRA standard IPE Individual Plant Examination ISB ISFSI Storage Building ISFSI Independent Spent Fuel Storage Installation KPI Key Performance Indicator KSF Key Safety Function kV Kilovolt kW Kilowatt LA Licensing Action LAR License Amendment Request LCO Limiting Condition of Operation LDSHD Load Shed PRA model basic event LERF Large Early Release Frequency LFS Limiting Fire Scenario LOCA Loss of Coolant Accident LOOP Loss of Off-site Power LOP Loss of Power LOSP Loss of Off-site Power BSEP LAR Rev 3 Page vii I

CP&L Acronym List CP&L Acronym List LPCI Low Pressure Coolant Injection LPI Low Pressure Injection LSS Low Safety Significance MAAP Modular Accident Analysis Program MAF Manual Action Feasibility MBOCA Miscellaneous Buildings - Owner Controlled Area MBPA Miscellaneous Buildings Pre-fire Plans - Protected Area MCA Multiple Compartment Evaluation Approach MCC Motor Control Center MCR Main Control Room MEFS Maximum Expected Fire Scenario MHIF Multiple High Impedance Fault MG Motor Generator MO Motor Operated MOS Maintenance Occupancy and Storage MOV Motor Operated Valve MQH Method of McCaffrey, Quintiere, and Harkleroad MSF Members of the Security Force MSIV Main Steam Isolation Valve MSL Main Steam Line MSO Multiple Spurious Operation MSR Moisture Separator Reheater MUD Make-Up Demineralizer MWT Makeup Water Treatment Building NCR Nuclear Condition Report NDE Non-Destructive Examination NEI Nuclear Energy Institute NEIL Nuclear Electric Insurance Limited NFPA National Fire Protection Association NFPA 805 National Fire Protection Association Standard 805 NPP Nuclear Power Plant NPO Non-Power Operations Rev 33 LAR Rev Page viii I BSEP LAR BSEP Page viii I

CP&L Acronym List CP&L Acronym List NPOPMD Non-Power Operations Program Manager Database NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSCA Nuclear Safety Capability Assessment NSEL Nuclear Safety Equipment List NSP Non-Suppression Probability NSW Nuclear Service Water NUREG US Nuclear Regulatory Commission Regulation NWY Northwest Yard O&M Operations and Maintenance OCA Owner Controlled Area OMA Operator Manual Action OMB Operations/Maintenance Building OOS Out-of-Service ORAM Outage Risk Assessment and Management OSI PI Real Time plant data tracking software OSP On-Site Power PAM Post-Accident Monitoring PB Performance Based PBAA Power Block Auxiliary Areas PDC Power Distribution Center PFP Pre-Fire Plans PGM Plant General Manager P&ID Piping and Instrumentation Diagram PLC Professional Loss Control PMP Pump PNL Panel PNSC Plant Nuclear Safety Committee POM Plant Operating Manual PORV Power Operated Relief Valves POS Plant Operational State Rev 33 Page ix I I

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CP&L Acronym List PRA Probabilistic Risk Assessment or Analysis PVC Polyvinyl-chloride PWR Pressurized Water Reactor Fire Qualitative Screening technical element from the PRA standard QU Quantification technical element from the PRA standard RA Recovery Actions RAI Request for Additional Information RAW Risk Achievement Worth RB Reactor Building RBCCW Reactor Building Closed Cooling Water RCA Radiologically Controlled Area RCIC Reactor Core Isolation Cooling RCR Reactor Coolant Recirculation RCS Reactor Coolant System RFP Reactor Feed Pump RFPT Reactor Feed Pump Turbine RG Regulatory Guide RHR Residual Heat Removal RI-PB Risk-Informed Performance-Based RIS Regulatory Issues Summary RMA Radioactive Materials Area RMCSB Radioactive Material - Container Storage Building RPDC Recirc Power Distribution Center RPS Reactor Protection System RPV Reactor Pressure Vessel RSDP Remote Shutdown Panel RW Radwaste RWB Radwaste Building RWCU Reactor Water Cleanup System SAMA Severe Accident Mitigation Alternative SAP Secondary Access Point BSEP LAR Rev 3 Page x I

CP&L Acronym List CP&L Acronym List SAR Safety Analysis Report SAT Startup Auxiliary Transformer SBGT Standby Gas Treatment SBO Station Blackout SCAFF Clean Scaffold Material Storage SCBA Self Contained Breathing Apparatus SD System Description SDC Shutdown Cooling SDV Scram Discharge Volume SE Safety Evaluation SER Safety Evaluation Report SFPC Spent Fuel Pool Cooling SFPE Society of Fire Protection Engineers SHF Sodium Hypochlorite Facility SIC Site Incident Commander SJAE Steam Jet Air Ejector SLC Standby Liquid Control SM Safety Margin SP Suppression Pool SPC Suppression Pool Cooling SR Supporting Requirement SRV Safety Relief Valve SSA Safe Shutdown Analysis SSC Structures, Systems, and Components SSD Safe Shutdown SSE Safe Shutdown Earthquake SSEL Safe Shutdown Equipment List STORES Hot Shop/Material Issue/Warehouse STORM Storm Drain Monitoring SW Service Water SWB Service Water Building SWGR Switchgear Rev 33 LAR Rev BSEP LAR Page xi I l

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CP&L Acronym List CP&L Acronym List SWY Switchyard SY Switchyard TAP Training Administrative Procedure TB Turbine Building TS Technical Specification UAT Unit Auxiliary Transformer UFSAR Updated Final Safety Analysis Report VFDR Variances from the deterministic requirements VFDs Variable Frequency Drives V&V Verification and Validation WFSS Water-based Fire Suppression System WW Wet well ZOl Zone of Influence Page xii !

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CP&L 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). CP&L 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)", to transition BSEP 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 BSEP 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), Appendix R, and Section (f), Decommissioning.

As stated in 10 CFR 50.48(c)(3)(i), any licensee's adoption of a RI-PB program that complies with the rule is voluntary. This rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48(b), for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48(f), plants shutdown in accordance with 10 CFR 50.82(a)(1).

NEI developed NEI 04-02 to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805.

The NRC issued Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants, which endorses NEI 04-02, with exceptions, in December 2009.1 A depiction of the primary document relationships is shown in Figure 1-1:

1 Where referred to in this document NEI 04-02 is Revision 2 and RG 1.205 is Revision 1.

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CP&L 1.0 Introduction CP&L 1.0 Introduction NFPA 805 Incorporation by 'iu4r(C U

2001 ed. Reference 50.48(c)

E -

Performance-Based Standard for FP for National Fire Light Water Reactor Protection Electric Generating Association Plants Standard NFPA 805 NEI 04-02 RG 1.205 0 I Endorsement 0 GUIDANCE FOR RI-PB FP FOR EXISTING IMPLEMENTING A RI-PB LIGHT-WATER NUCLEAR FP PROGRAM UNDER 10 POWER PLANTS CFR 50.48(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 CP&L submitted a letter of intent to the NRC on June 10, 2005 (ML051720404), for the Shearon Harris Nuclear Power Plant (HNP) to adopt NFPA 805 in accordance with 10 CFR 50.48(c). This letter of intent also addressed other CP&L plants (Brunswick Steam Electric Plant Units No. 1 and 2, H.B. Robinson Steam Electric Plant Unit No. 2, and Crystal River Unit 3 Nuclear Generating Plant). The letter of intent requested three years of enforcement discretion and proposed that HNP be considered a Pilot Plant for the NFPA 805 transition process.

By letter dated April 29, 2007 (ML070590625), the NRC granted a three year enforcement discretion period. In accordance with NRC Enforcement Policy, the enforcement discretion period will continue until the NRC approval of the license amendment request (LAR) is completed.

1.1.2.2 Transition Process The transition to NFPA 805 includes the following high level activities:

0 Complete Safe Shutdown Analysis Reconstitution (activities started in 2003)

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CP&L 1.0 Introduction

" 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 to support the Fire 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 The project was implemented using a comprehensive project plan and individual procedures/instructions for individual scopes of work. These procedures/instructions (e.g., Project Instruction "FPIP" series procedures referenced in this report) were developed for the purposes of NFPA 805 transition. Appropriate technical content from these procedures were and will be incorporated into technical documents and configuration control procedures, as required.

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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CP&L 2.0 Overview of Existinq Fire Protection Proqram 2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1 Current Fire Protection Licensing Basis Brunswick Steam Electric Plant was licensed to operate on September 8, 1976, for Unit 1 and December 27, 1974, for Unit 2. As a result, the Brunswick Steam Electric Plant fire protection program is based on evaluation and NRC acceptance against the requirements of Design Criterion 3, Appendix A to 10 CFR 50 Part 50, and 10 CFR 50 Appendix R, Sections III.G and J. The following License Condition 2.B(6) in Amendment No. 169 to the Facility Operating License No. DPR-71 (i.e., Unit 1) and Amendment No. 200 to Facility Operating License No. DPR-62 (i.e., Unit 2) states:

"CarolinaPowerand Light Company shall implement and maintainin effect all provisions of the approved fire protectionprogram as described in the Final Safety Analysis Report for the facility and as approved in the Safety Evaluation Report, dated November 22, 1977, as supplementedApril 1979, June 11, 1980, December 30, 1986, December 6, 1989, and July 28, 1993 and February 10, 1994, respectively, subject to the following provision:

The licensee may make changes to the approved fire protection program without priorapproval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire."

2.2 NRC Acceptance of the Fire Protection Licensing Basis The Commission issued, on November 22, 1977, Amendment No. 11 to the Facility Operating License No. DPR-71, for Unit No. 1, and Amendment No. 37 to Facility Operating License No. DPR-62, for Unit No. 2, of the Brunswick Steam Electric Plant.

These amendments added license conditions relating to the completion of the facility modifications for fire protection and resolution of incomplete items. The amendment for Unit 1 also incorporated limiting conditions for operations and surveillance requirements for existing fire protection systems and administrative controls.

Amendment No. 11 contained the following changes to 2.B(6) and 2.C.(2):

2.B(6) The licensee may proceed with and is required to complete the modifications identified in Paragraphs 3.1.1 through 3.1.35 of the NRC's Fire Protection Safety Evaluation Report on the Brunswick facility dated November 22, 1977.

These modifications shall be completed by the end of the first refueling outage of Brunswick Unit 1 and prior to return to operation of Cycle 2. In addition, the licensee shall submit the additional information identified in Table 3.1 of this Safety Evaluation Report in accordance with the schedule contained therein. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

2.C.(2) The Technical Specifications contained in Appendices A, A-Prime and B, attached hereto, as revised through Amendment No. 11, are hereby incorporated in this license. Appendix A shall be effective from the date of I

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CP&L 2.0 Overview of Existinq Fire Protection Proqrarn CPL20Oeve fEitn FiePoeto rga issuance of the Unit 1 operating license until the Appendix A-Prime becomes effective on or before the initial criticality of Brunswick Unit 2 following its initial refueling outage. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications as indicated above.

The licensee shall inform the Office of Inspection and Enforcement, Region II, of the date that the Appendix A-Prime becomes effective.

Amendment No. 37 contained the following changes to 2.B(7):

2.B(7) The licensee may proceed with and is required to complete the modifications identified in Paragraphs 3.1.1 through 3.1.35 of the NRC's Fire Protection Safety Evaluation Report on the Brunswick facility dated November 22, 1977.

These modifications shall be completed by the end of the second refueling outage of Brunswick Unit 2 and prior to return to operation of Cycle 3. In addition, the licensee shall submit the additional information identified in Table 3.1 of this Safety Evaluation Report in accordance with the schedule contained therein. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

The Commission issued, on April 6, 1979, Amendment No. 23 to the Facility Operating License No. DPR-71, for Unit No. 1, and Amendment No. 47 to Facility Operating License No. DPR-62, for Unit No. 2, of the Brunswick Steam Electric Plant. These amendments consisted of changes to the operating licenses for both units to allow revised implementation dates for certain modifications intended to improve the level of fire protection. Supplement 1 of the Fire Protection Safety Evaluation Report was also included in this transmittal which addressed certain items that were identified as incomplete and requiring further information from the licensee and evaluation by the staff. The SER, Supplement 1, also listed several modifications proposed by the licensee to improve fire protection.

The Commission issued Supplement 2 to the Fire Protection Safety Evaluation Report on June 11,1980, which contained evaluations associated with four areas: 1) Protection of Redundant Safe Shutdown Cabling (greater than five foot separation, 2) Protection of Redundant Safe Shutdown Cabling (less than five foot separation), 3) Fire Protection Loop Isolation Valve, 4) Door Frames for Fire Doors.

The Commission granted, on November 10, 1981, an exemption from the requirements of 10 CFR 50 Appendix R, Section III.G.3, with regard to fixed fire suppression in the Control Room.

The Commission granted, on July 27, 1983, exemptions from the requirements of 10 CFR 50 Appendix R, Section III.G.3, with regard to fixed fire suppression in the seven fire zones in the Control Building Cable Vaults.

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CP&L 2.0 Overview of Existing Fire Protection Program The Commission granted, on September 17, 1986, an exemption from the licensee commitment to install an excess flow switch and automatic shut-off valve in the fuel supply line for the diesel fire pump to automatically isolate in the event of a fuel line rupture. The Safety Evaluation concluded that the previous commitment to provide automatic isolation of the diesel fuel line need not be implemented because of the alternative fire protection measures provided.

The Commission granted, on December 30, 1986, exemptions from the requirements of Appendix R to 10 CFR Part 50, Sections IIL.G and J. Exemptions were granted for the following:

1) Reactor Buildings, Units 1 and 2 (Fire Areas RBI-1 and RB2-1)

2) Emergency Core Cooling System Rooms, Units 1 and 2 (Fire Areas RB1-6 and RB2-6)

3) Diesel Generator Building Basement (Fire Area DG-1)

4) Service Water Building (Fire Area SW-I)

5) Diesel Generator Building (DG-08)

6) Fixed Fire Suppression System for Alternative Shutdown Areas (Fire Areas TB-i, CB-1, CB-7, CB-8, CB-9, CB-10, DG-6, DG-7, DG-9, DG-11, DG-12, DG-13 and DG-14)

7) East Yard Area The Staff concluded that the exemption request for the Control Building Extended (Fire Area CB-23E) was not needed.

The Commission issued, on May 29, 1987, a Safety Evaluation approving the use of higher unexposed side temperatures for fire barrier seals than that required by the Branch Technical Position (BTP) ASB 9.5-1 of NUREG-0800. The evaluation concluded that the acceptance criteria of 325 'F above ambient, versus 250 'F above ambient, was an acceptable deviation and was not considered likely to significantly add to the risk of igniting material on the unexposed side of the barrier.

The Commission granted, on August 27, 1987, an Exemption from 10 CFR Part 50, Appendix R, Section Ill.J, from the requirement for emergency lighting units with at least an 8-hour battery supply in all areas needed for operation of safe shutdown equipment.

The exemption permits substitution of 8-hour battery lighting with:

1) The use of diesel generators to power lighting in the plant control room upon loss of offsite power.

2) The use of two-hour battery-powered lighting upon loss of diesel generators concurrent with loss of offsite power.

3) Assurance that power sources are routed underground and are separated by at least a three-hour rated fire barrier.

The Commission issued an Appendix R Safety Evaluation Clarification and Revision on December 6, 1989. Brunswick Steam Electric Plant had identified nineteen items BSEP LAR Rev 3 Page 6 1

CP&L 2.0 Overview of Existinq Fire Protection Proqram associated with the Staffs December 30, 1986, Safety Evaluation where revisions were required to 1) correct specific errors, 2) clarify potentially confusing language, or 3) more accurately state actual conditions. The Staff provided clarifications for fifteen of the nineteen items requested. These clarifications appended the December 30, 1986, Safety Evaluation.

The Commission issued, on July 28, 1993, a Safety Evaluation approving a request to downgrade the three-hour rated masonry block walls in the control building cable access ways (separating fire areas CB-01a/b, CB-02a/b, CB-12a/b and CB-13a/b) to non-rated walls. The Staff found this change did not have an adverse impact on the III.G.3 exemption granted for the lack of fire suppression in the control building and would not impact the alternate shutdown capability.

The Commission issued, on February 10, 1994, a Safety Evaluation that revised the plant fire protection licensing condition and Technical Specifications (TS). In accordance with Generic Letter 86-10 and 88-12, CP&L requested that fire protection be removed from the Technical Specifications and a standard fire protection licensing condition be implemented. The following Technical Specification changes were proposed and granted by the NRC:

1) Delete TS 3.3.5.7 (Fire Detection Instrumentation), TS 3.7.7.1 (Fire Suppression Water System), TS 3.7.7.2 (Spray and/or Sprinkler Systems), TS 3.7.7.3, (High Pressure Carbon Dioxide), TS 3.7.7.4 (Fire Hose Stations), TS 3.7.7.5, (Foam Systems), and TS 3.7.8 (Fire Barrier Penetrations) and their associated bases and incorporate into the Updated Final Safety Analysis Report (UFSAR).

2) Delete TS 6.2.2.g for site fire brigade staffing and incorporate into the UFSAR

3) Delete TS 6.4.2 requirements related to the fire brigade training program and incorporate into the UFSAR.

4) Add TS 6.5.3.8(m) to include the review of the fire protection program and implementing procedures as an additional responsibility of the Plant Nuclear Safety Committee (PNSC).

5) Delete TS 6.9.2.d related to the requirement for special reports for the fire detection instrumentation.

6) Delete TS 6.9.2.g related to the requirement for special reports for fire suppression systems.

7) Delete TS 6.9.2.h related to the requirement for special reports for fire barrier penetrations.

CP&L also proposed, and the NRC granted the request, to replace the current fire protection licensee condition with the standard license condition provided in GL 86-10.

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CP&L 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, CP&L 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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CP&L 3.0 Transition Process Establish fundamental fire NFPA 805 Section 2.2(a) protection elements (Chapter 3)

Identify fire hazards NFPA 805 Section 2.2(b)

Nuclear safety Life safety NFPA 805 Section 2.2(c) Property damagelbusiness Interruption Evaluate compliance to Radiation release performance criteria NFPA 805 Section 2.2(d)

NFPA 805 Section 2.2(e)

Performance-BasedApproach Deterministic Approach Evaluate ability to satisfy performance Maintain compliance with existing plant 4-license basis (10 CFR 50 App. R, Approved requirements Exemptions, Engineering Evaluations)

(Chapter 4)

Dei Bi Existing PerformanceBasis Deterministic Basis Engineering Define fire scenarios and fire design basis Verify deterministic requirements are met Equivalency Evaluations for each fire area being considered.

Evaluate using, e.g.,

" Fire modeling to quantify the fire risk NFPA 805 Section 2.2(f) and margin of safety

" PSA to examine impact on overall plant risk NFPA 805 Section 2.2(g)

Risk-Informed Change Evaluation NFPA 805 Section 2.2(h)

Evaluate risk impact of changes to the approved design basis No Examples Design B~asis Documents Documentation and configuration Fire hazards analysis NFPA 805 Section 2.2(0) Douettontr an cofgrto Nuclear safety capability assessment controlSupporting engineering calculations

~Probabilistic safety analysis Risk-informed change evaluations Feedback Establish monitoring progr NFPA 805 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 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.

I IBSEP LAR Rev 3 Page 9 1

CP&L 3.0 Transition Process 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 (i.e.,

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 Use PB Approach if Needed (Fire Modeling or Report Fire Risk Evaluations)

I } Sect. 4.5 Transition Figure 3-2 Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]

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CP&L 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 HNP) 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 Issue 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.

BSEP LAR Rev 3 p7-age 11 1

CP&L 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 BSEP Fire Protection Program to the requirements of NFPA 805 Chapter 3 was performed and documented in Attachment A, Table B-I, NFPA 805 Ch. 3 Transition Details. The 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.

" 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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open items) that represent interim resolutions. Additional detail on the transition of EEEEs is included in Section 4.2.2.

I BSEP LAR Rev 3 Page 13 1

CP&L 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 BSEP 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, or

" Complies with a previously NRC approved alternative to NFPA 805 Chapter 3 and, therefore, the specific requirement of NFPA 805 Chapter 3 is supplanted.

4.1.2.2 NFPA 805 Chapter 3 Requirements Requiring Clarification of Prior NRC Approval NPFA 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. CP&L requests that the NRC concur with their finding of prior approval for the following sections of NFPA 805 Chapter 3:

0 None.

4.1.2.3 NFPA 805 Chapter 3 Requirements 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:

0 3.5.16 - Approval is requested for the use of fire protection water for specific plant evolutions.

E 3.2.3(1) - Approval is requested for the use of performance-based methods to establish the appropriate inspection, testing, and maintenance frequencies for fire protection systems and features required by NFPA 805.

The specific deviation and a discussion of how the alternative satisfies 10 CFR 50.48(c)(2)(vii) requirements are provided in Attachment L. CP&L requests NRC approval of these performance-based methods.

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CP&L 4.0 Compliance with NFPA 805 Requirements 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.

All structures within the BSEP Owner Controlled Area were reviewed to determine the potential impact of fire on the nuclear safety and radioactive release criteria described in Section 1.5 of NFPA 805. This was accomplished by identifying the structures that contain either

• Equipment that could affect

" Plant operation for power generation

" Ability to maintain nuclear safety performance criteria in the event of a fire, including Safe Shutdown Capability OR

- Radioactive materials that could potentially be released in event of a fire These structures are listed in Attachment I and define the "power block" and "plant".

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.

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.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.2.1.1 Compliance with NFPA 805 Section 2.4.2 Overview of Process NFPA 805 Section 2.4.2 Nuclear Safety Capability Assessment states:

"The purpose of this section is to define the methodology for performing a nuclearsafety capabilityassessment. The following steps shall be performed:

(1) Selection of systems and equipment and their interrelationshipsnecessary to achieve the nuclearsafety performance criteria in Chapter 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 1 (ML050310295) 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 1. 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 the section:

o Aligns o Aligns with intent 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 BSEP existing post-fire Safe Shutdown Analysis (SSA) methodology to NEI 00-01 Chapter 3 (NEI 04-02 Table B-2) was performed and documented in Attachment B, Table B-2 Nuclear Safety Capability Assessment Methodology Review.

In addition, a review of NEI 00-01, Revision 2, (ML091770265) Chapter 3, was conducted to identify the substantive changes from NEI 00-01, Revision 1 that are applicable to an NFPA 805 fire protection program. This review was performed and I

BSEP LAR Rev 3 Page 16 1

CP&L 4.0 Compliance with NFPA 805 Requirements documented in Attachment B, Table B-2 Nuclear Safety Capability Assessment Methodology Review.

Results from Evaluation Process The method used to perform the existing post-fire SSA 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 1, Chapter 3 (i.e., as supplemented by the gap analysis) directly or met the intent of the endorsed guidance with adequate justification as documented in Attachment B.

Step 11 < Assemble Documentation Step 2 Se K

2Determine

[ and Document Applicability of NEI 00-01 Sections For Applicable NEI 00-01 Sections, Perform Comparison of SSD Method vs. NEI 00-01 No Can lack of alignment Yes Has NRC approvalb No

< InStrict Alignment with No eet~sIntent of NEI 00-01 11 NEI 00-01 Guidance? Guidance? potentially result in obtained for metho Step 3 *< < dverse consequences?

Step 4 Figure 4 Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039)

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CP&L 4.0 Compliance with NFPA 805 Requirements Comparison to NEI 00-01 Revision 2 An additional review was performed of NEI 00-01, Revision 2, Chapter 3, for specific substantive changes in the guidance from NEI 00-01, Revision 1 that are applicable to an NFPA 805 transition. The results of this review are summarized below:

" Post fire manual operation of rising stem valves in the fire area of concern (NEI 00-01 Section 3.2.1.2)

A review of the NSCA results indicated that there are no recovery actions or defense-in-depth recovery actions that require manual operation of a rising stem valve in the fire area of concern.

" Analysis of open circuits on a high voltage (e.g., 4.16 kV) ammeter current transformers (NEI 00-01 Section 3.5.2.1)

The evaluation concludes that this failure mode is unlikely for CTs that could pose a threat to safe shutdown equipment.

" Analysis of control power for switchgear with respect to breaker coordination (NEI 00-01 Section 3.5.2.4)

Control power is modeled in the safe shutdown fault tree used to develop the NSCA. A loss of control power results in an assumed loss of the switchgear, and there are no cases where a bus is credited to remain operable without control power.

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.Forall other configurations,safe and stable conditions are defined as maintainingKeff <0.99 and fuel coolant temperaturebelow boiling."

The nuclear safety goal of NFPA 805 requires "...reasonableassurance that a fire during any operationalmode and plant configuration will not prevent the plant from achieving and maintainingthe fuel in a safe and stable condition"without a specific reference to a mission time or event coping duration.

For the plant to be in a safe and stable condition, it 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/hot shutdown plant operating state for the event.

I BSEP LAR Rev 3 Page 18 1

CP&L 4.0 Compliance with NFPA 805 Requirements Results Based on the criteria discussed in NCSA calculation BNP-E-9.010, "Safe Shutdown Analysis in Case of Fire," the NFPA 805 licensing basis for BSEP is to achieve and maintain hot shutdown conditions following any fire occurring prior to establishing cold shutdown. Specifically, the conditions include:

" the reactor operating at power,

" a shutdown immediately prior to aligning the RHR system for shutdown cooling, or

" the "transition" mode between these two operational phases.

Immediately following the reactor scram, RCS inventory and pressure control is maintained using the high pressure systems, HPCI and RCIC, or the low pressure injection systems using the SRV's for pressure reduction, which are the RHR System in LPCI mode or Core Spray System. For the most limiting fire scenarios in every fire area, BNP-E-9.010 documents the availability of long term cooling using the RHR system, in either the Normal Shutdown Cooling Mode or Alternate Shutdown Cooling Mode, or the Core Spray System, all of which are characterized by low pressure injection and at least 1 SRV available to provide core flow. The RHR Service Water system rejects decay heat to the ultimate heat sink.

Notably, initiation of RHR in the suppression pool cooling mode does not imply that the plant would proceed all the way to cold shutdown. Following stabilization at hot shutdown, a long term strategy for decay heat removal and inventory/pressure control would be determined based on the extent of equipment damage. If an assessment of the post-fire conditions indicated that placing RHR in the Shutdown Cooling or Alternate Shutdown Cooling modes would be advisable, then activities would commence in a safe and controlled manner to align plant equipment required for reactor cooldown.

The long-term actions required to maintain safe and stable conditions are relatively low risk activities that are largely routine and within the normal capabilities of site personnel, even in the face of fire damage, due to the assured availability of at least one train of RHR and either onsite or offsite power sources. Repairs to safe shutdown equipment would not be required and the management of the onsite inventories of makeup water, nitrogen and diesel fuel would not require resources beyond those available from normal operations staff and emergency response personnel.

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 Operations analysis that includes cold shutdown and below, or Modes 4 and 5. This analysis is discussed in Section 4.3.

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CP&L 4.0 Compliance with NFPA 805 Requirements 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 OMAs as recovery actions in the LAR (i.e., Regulatory Position 2.2.1 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 (ML110070485) and consists of the following steps:

" Step 1: Clearly define the primary control station(s) and determine which pre-transition OMAs are taken at primary control station(s) Activities that occur in the Main Control Room are not considered pre-transition OMAs. Activities that take place at primary control station(s) or in the Main Control Room are not recovery actions, by definition.

" Step 2: Determine the population of recovery actions that are required to resolve variances from deterministic requirements (VFDRs) (i.e., 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 Fire Safety Analysis for each area. 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 recommends 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 used to address MSOs for Brunswick is summarized below.

As part of the NFPA 805 transition project, a review and evaluation of Brunswick 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 (ML110140242). The BWR Generic MSO list from NEI 00-01, Revision 3 was utilized.

BSEP LAR Rev 3 Tage 20

CP&L 4.0 Compliance with NFPA 805 Requirements The approach outlined in Figure 4-3, below, (i.e., based on Figure 4-8 from FAQ 07-0038) is the method used to address fire-induced MSOs for BSEP. 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. 1 Section F.4.2).

" Updating the Fire PRA model and existing post-fire SSA / 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 will be part of the plant change review process and/or inspection process).

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CP&L, 4.0 Compliance with NFPA 805 Requirements 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 Concem Update PRA model & NSCA (as appropriate) to include MSOs of concern Step 3

• ID equipment

• ID logical relationships

• ID cables

• ID cable routing Evaluate for NFP 0 No Step 4 Compliance Pursue other resolution Compliant with NFPA 805?

Yes Step 5 Document Results Figure 4 Multiple Spurious Operations - Transition Resolution Process (Based on FAQ 07-0038)

Results Refer to Attachment F for the process used by BSEP.

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CP&L 4.0 Compliance with NFPA 805 Requirements 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 (i.e., 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 included the following determinations:

" The EEEE is not based solely on quantitative risk evaluations,

" The EEEE is an appropriate use of an engineering equivalency evaluation,

" 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 Attachment A.

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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CP&L 4.0 Compliance with NFPA 805 Requirements 4.2.3 Licensing Action Transition Overview of Evaluation Process The existing licensing actions (i.e., Appendix R exemptions) 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.

" Additionally, variances from the deterministic requirements were identified in the NEI 04-02, Table B-3 (See Attachment C). Some of these variances were subsequently dispositioned via the use of the performance-based approach.

Results Attachment K contains the detailed results of the Licensing Action Review.

None of the licensing actions will be transitioned into the NFPA 805 fire protection program. The licensing actions listed in Attachment K are no longer necessary and will not be transitioned into the NFPA 805 fire protection program. The justifications, grouped by the nature of the exemption, are provided in Attachment 0, Orders and Exemptions.

Since the exemptions are either compliant with 10 CFR 50.48(c) or no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), CP&L requests that the exemptions listed in Attachment K be rescinded as part of the LAR process. It is CP&L's understanding that implicit in the superseding of the current license condition, all prior fire protection program Safety Evaluations and commitments will be superseded in their entirety.

4.2.4 Fire Area Transition Overview of Evaluation Process The Fire Area Transition (i.e., 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.

0 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 documented the results of the review. See Section 4.2.3.

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CP&L 4.0 Compliance with NFPA 805 Requirements

" 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.

Step 4 - Performance-Based evaluations (i.e., 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 the fire safety analysis for each area.

" 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.

" Documented 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 (i.e., including fire area licensing actions and engineering evaluations) and the NFPA 805, Section 4.2.4, compliance strategies (i.e., 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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CP&L 4.0 Compliance with NFPA 805 Requirements CP&L 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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CP&L 4.0 Compliance with NFPA 805 Requirements Results of the Evaluation Process Attachment C contains the results of the Fire Area Transition review (i.e., 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 - BSEP is not transitioning any existing Licensing Actions, as noted in Attachment K.

" 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.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.3 Non-Power Operational Modes 4.3.1 Overview of Evaluation Process BSEP implemented the process outlined in NEI 04-02, Guidance for implementing a Risk-Informed, Performance-Based Program under 10 CFR 50.48(c), and FAQ 07-0040, Clarification on Non-Power Operations. The goal (i.e., as depicted in Figure 4-6) is to ensure that contingency plans are established when the plant is in a Non-Power Operational (NPO) mode where the risk is intrinsically high. During low risk periods, normal risk management controls and fire prevention/protection processes and procedures will be utilized.

The process to demonstrate that the nuclear safety performance criteria are met during NPO modes involved the following steps:

" Reviewed the existing Outage Management Processes

" Identified Equipment/Cables:

o Reviewed plant systems to determine success paths that support each of the defense-in-depth Key Safety Functions (KSFs), and o Identified cables required for the selected components and determined their routing.

" Performed 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.

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CP&L 4.0 Compliance with NFPA 805 Requirements CP&L 4.0 Compliance with NFPA 805 Requirements Figure 4-5 Review POSs, KSFs, Equipment, and Cables, and Identify Pinch Points BSEP LAR Rev 3 Page 29

CP&L 4.0 Compliance with NFPA 805 Requirements CP&L 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 BSEP LAR Rev 3 LAR Rev Page 30 I l

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CP&L 4.0 Compliance with NFPA 806 Requirements 4.3.2 Results of the Evaluation Process BSEP outage management processes were reviewed. Based on FAQ 07-0040, the Plant Operating States considered for equipment and cable selection are documented in calculation BNP-E-9.01 1, "NFPA 805 Transition - NPO Modes Review." Using a CAFTA fault tree that models NPO requirements, systems and components were identified to provide three KSFs: Decay Heat Removal, Inventory Control, and Electrical Power Availability (i.e., to the extent that it supports the Decay Heat Removal and Inventory Control functions).

For those components not already in the BSEP Access Database or those with a functional state for non-power operations differing from that in the At-Power Analysis, circuit analysis, cable selection and routing were performed as described in the plant's NSCA methodology. Once all information had been entered into the BSEP Access Database, the ARCTM software package in conjunction with the NPO fault tree was used to determine KSF Pinch Points.

Calculation BNP-E-9.011 provides the results of the fire area assessments for the Pinch Point analysis and provides recommendations for changes to fire risk and outage management procedures and other administrative controls. These include:

" Prohibition or limitation of hot work in fire areas during periods of increased vulnerability.

" Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability.

" Provision of additional fire watches in affected fire areas during increased vulnerability.

• Identification and monitoring of in-situ ignition sources for "fire precursors" (e.g.,

equipment temperatures).

• Review of work activities for possible rescheduling

• Equipment realignment (e.g., Swing pumps, Backfeed, etc.)

• Identified procedures to be briefed or walked down.

• Posting of protected equipment.

" Use of recovery actions to mitigate potential losses of KSF success paths.

Attachment D provides a more detailed discussion. Based on incorporation of the recommendations from BNP-E-9.011 into appropriate plant procedures in conjunction with establishment of the NFPA 805 fire protection program, the performance goal for NPO modes (i.e., maintain KSF availability) is fulfilled and the requirements of NFPA 805 are met.

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CP&L 4.0 Compliance with NFPA 805 Requirements 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, Table E-1, and was performed using the methodology contained in Project Instruction FPIP-0121, Radiological Release Reviews During Fire Fighting Operations, Rev. 1. The methodology consisted of the following:

" A review of fire pre-plans and fire brigade training materials to identify fire protection program elements (e.g., systems / components / procedural control actions / flow paths) 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. Specifically for BSEP, a review was conducted by a review panel to ensure specific steps are included for containment and monitoring of potentially contaminated materials so as to limit the potential for release of radioactive materials due to firefighting operations.

The review panel consisted of representatives from Operations, Engineering (i.e.,

Fire Protection, HVAC Systems), Operations Fire Brigade Training, and Radiation Protection. Site pre-fire plans were screened to identify those locations that have the potential for radiological contamination based on location within plant Radiological Controlled Areas, areas containing potentially contaminated systems, or locations where radioactive materials are routinely stored. In addition, the site fire brigade training materials were reviewed by the same review panel to ensure specific steps are included addressing containment and monitoring of potentially contaminated materials and monitoring of potentially contaminated fire suppression products following a fire event.

" A review of engineering controls to ensure containment of gaseous and liquid effluents (i.e., smoke and fire fighting agents). This review included all plant operating modes (i.e., including full power and non-power conditions).

Otherwise, provided a bounding analysis, quantitative analysis, or other analysis that demonstrates that the limitations for instantaneous release of radioactive effluents specified in the unit's Technical Specifications are met.

4.4.2 Results of the Evaluation Process Fire Pre-Plan review; The review determined the Fire Protection Program (i.e., Pre-Fire Plans) meets the radioactive release performance criteria by ensuring that radioactive materials (i.e.,

radiation) generated as a direct result of fire suppression activities is contained and monitored prior to release to unrestricted areas, such that release would be as low as reasonably achievable and would not exceed applicable 10 CFR, Part 20 limits.

Containment and monitoring is ensured through elements of the fire brigade training, guidance provided in pre-fire plans and certain plant features (i.e., engineering controls) such as curbs and ventilation systems or actions provided to control smoke management or fire suppression water run-off.

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CP&L 4.0 Compliance with NFPA 805 Requirements Site specific review of associated fire event and fire suppression related radioactive release is summarized in Attachment E, NEI 04-02, Table E-1. Containment and monitoring actions associated with fire fighting operations are included in the pre-fire plans for fire areas as appropriate based on the screening criteria previously stated (i.e.,

ref. Table 4-3 and Attachment E) to meet the radiological performance criteria.

The standardized pre-fire plan outline identifies typical fixed radiological hazards for each area. All BSEP pre-fire plans were screened for applicability. Pre-fire plans that address areas where there is no possibility of radiological hazards were screened out from further review. A summary cross-reference of fire compartment, fire area, and pre-fire plan to plant fire areas, and radioactive release input results is provided in Table 4-3. This information was included as input to the individual fire area Fire Safety Analyses (FSA's) calculations. The FSA is the Design Basis Document for NFPA 805 compliance for each fire area and will serve as the location for maintenance and configuration control of the radioactive release review results. Change, modification, or revision to the FSA's is controlled under existing plant engineering configuration control processes.

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CP&L 4.0 Compliance with NFPA 805 Requirements Table 4-3 -BSEP Pre-Fire Plan Screening Fire Rad In Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Fire Release RCA?

Procedure Pre-Plan Input Y/N (Screened)

Unit 1 Cable Access Way (North East Rattle GB-I CB-1A Unit 1 Cable Access OPFP-CB 1PFP-GB-i Out Y Space) 23ft. Elevation Ways______

Unit 1 Cable Access Way (North West Rattle CB-01 B Unit 1 Cable Access OPFP-CB 1 PFP-CB-1 Out Y Space) 23ft. Elevation Ways Unit 1 Cable Access Way (North East Rattle CB-i CB-12A Unit 1 Cable Access OPFP-GB lPFP-CB-12 Out Y Space) 49ft. Elevation Ways Unit 1 Cable Access Way (North West Rattle GB-i CB-12B Unit 1 Cable Access OPFP-GB 1PFP-GB-12 Out Y Space) 49ft. Elevation Ways Battery Room 2B3 23ft. Elevation GB-1 GB-1 Unit 2 Division 11Battery OPFP-GB 2PFP-CB-10 Out Y Room Unit 2 Cable Access Way (South East Rattle CB-2 CB-02A Unit 2 Cable Access OPFP-CB 2PFP-CB-2 Out Y Space) 23ft. Elevation Ways Unit 2 Cable Access Way (South West CB-2 CB-02B Unit 2 Cable Access OPFP-CB 2PFP-CB-2 Out Y Rattle Space) 23ft. Elevation WaysC-0C1Ro Unit 2 Cable Access Way (South East Rattle CB-2 GB-i 3A Unit 2 Cable Access OPFP-GB 2PFP-CB-13 Out Y Space) 49ft. Elevation Ways Unit 2 Cable Access Way (South West Rattle CB-2 CB-1 3B Unit 2 Cable Access OPFP-GB 2PFP-GB-13 Out Y Space) 49ft. Elevation Ways Unit 1 Northwest Stairwell 23ft. and 49ft CB-23E CB-03 Control Room Extended OPFP-CB 1 PFP-CB-4 Out Y Elevations Unit 2 Southwest Stairwell 23ft. and 49ft CB-23E CB-04 Control Room Extended OPFP-CB 2PFP-CB-3 Out Y Elevations Unit 1 Cable Spreading Room 23ft. CB-23E CB-05 Control Room Extended OPFP-CB iPFP-CB-5 Out Y Elevation ____________

Unit 2 Cable Spreading Room 23ft. CB-23E CB-06 Control Room Extended OPFP-CB 2PFP-CB-6 Out Y Elevation ____________

Control Building Elevator and Shaft CB-23E CB-0 1 Control Room Extended OPFP-CB OPFP-CB-3 1 Out Y Unit 1 Computer Room North 49ft. Elevation CB-23E CB-14 Control Room Extended OPFP-CB OPFP-CB-14 Out Y Unit 2 Computer Room South 49ft. Elevation CB-23E CB-15 Control Room Extended OPFP-CB OPFP-CB-14 Out Y Rev 33 LAR Rev Page 34 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Fire Release RCA?

Procedure Pre-Plan Input Y/N (Screened)

Auxiliary Operator Briefing Room CB-23E CB-16 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Operator Break Room CB-23E CB-17 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Ladies Washroom CB-23E CB-18 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Central Alarm Station (CAS) 52ft. Elevation CB-23E CB-19 Control Room Extended OPFP-CB OPFP-CB-19 Out Y Unit 1 Northwest Back Panel Area CB-23E CB-20 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Unit 2 Southwest Back Panel Area CB-23E CB-21 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Men's Washroom CB-23E CB-22 Control Room Extended OPFP-CB OPFP-CB-23 Out Y Control Room 49ft. Elevation CB-23E CB-23 Control Room Extended OPFP-CB OPFP-CB-23 Out Y HVAC Equipment Room - 70ft CB-23E CB-24 Control Room Extended OPFP-CB OPFP-CB-24 Out Y Air Conditioning Condenser Area - 70ft CB-23E CB-25 Control Room Extended OPFP-CB OPFP-CB-25 Out Y Control Building Elevator Machinery Room - CB-23E CB-26 Control Room Extended OPFP-CB OPFP-CB-26 Out Y 70ft Battery Room 1A 23ft. Elevation CB-7 CB-07 Unit 1 Division I Battery OPFP-CB 1PFP-CB-7 Out Y Room Battery Room 1B 23ft. Elevation CB-8 CB-08 Unit 1 Division II Battery OPFP-CB 1PFP-CB-8 Out Y Room Battery Room 2A 23ft. Elevation CB-9 CB-09 Unit 2 Division I Battery OPFP-CB 2PFP-CB-9 Out Y Room DG Building Basement - 2ft DG-1 DG-01 Diesel Generator OPFP-DG OPFP-DG-1 Out N Basement DG Building Loading Dock, 20ft DG-10 DG-10 Loading Dock OPFP-DG OPFP-013 Out N El Switchgear Room, 50ft DG-1 1 DG-1 1 El Switchgear OPFP-DG 1PFP-DG-1 1 Out N E2 Switchgear Room, 50ft DG-12 DG-12 E2 Switchgear OPFP-DG 1PFP-DG-12 Out N E3 Switchgear Room, 50ft DG-13 DG-13 E3 Switchgear OPFP-DG 2PFP-DG-13 Out N E4 Switchgear Room, 50ft DG-14 DG-14 E4 Switchgear OPFP-DG 2PFP-DG-14 Out N Supply Air Plenum, 50ft DG-16E DG-15 Fan Room Extended OPFP-DG OPFP-DG-15 Out N Diesel Building Supply Fan Room, 50ft DG-16E DG-16 Fan Room Extended OPFP-DG OPFP-DG-15 Out N Diesel Building North Air Lock, 50ft DG-16E DG-17 Fan Room Extended OPFP-DG OPFP-DG-15 Out N Page 35 I BSEP LAR BSEP Rev 33 LAR Rev Page 35 1

CP&L 4.0 Compliance with NFPA. 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure Pr-lnIpt (Screened) Y/N Diesel Building South Air Lock, 50ft DG-16E DG-18 Fan Room Extended OPFP-DG OPFP-DG-15 Out N AFFF System Room, 50ft DG-16E DG-23 Fan Room Extended OPFP-DG OPFP-DG-15 Out N Diesel Generator Fuel Oil Tank Cell #1, 2ft DG-19 DG-19 Fuel Oil Tank Cell 1 OPFP-DG OPFP-DG-19 Out N Diesel Generator Cell 4 - 20ft DG-2 DG-02 Diesel Cell 4 OPFP-DG 2PFP-DG-2 Out N Diesel Generator Fuel Oil Tank Cell #2, 2ft DG-20 DG-20 Fuel Oil Tank Cell 2 OPFP-DG OPFP-DG-19 Out N Diesel Generator Fuel Oil Tank Cell #3, 2ft DG-21 DG-21 Fuel Oil Tank Cell 3 OPFP-DG OPFP-DG-19 Out N Diesel Generator Fuel Oil Tank Cell #4, 2ft DG-22 DG-22 Fuel Oil Tank Cell 4 OPFP-DG OPFP-DG-19 Out N Diesel Generator Cell 3 - 20ft DG-3 DG-03 Diesel Cell 3 OPFP-DG 2PFP-DG-3 Out N Diesel Generator Cell 2 - 20ft DG-4 DG-04 Diesel Cell 2 OPFP-DG 1PFP-DG-4 Out N Diesel Generator Cell 1, 20ft DG-5 DG-05 Diesel Cell 1 OPFP-DG 1PFP-DG-5 Out N E5 Switchgear Room, 20ft DG-6 DG-06 E5 Switchgear OPFP-DG 1PFP-DG-6 Out N E6 Switchgear Room, 20ft DG-7 DG-07 E6 Switchgear OPFP-DG 1 PFP-DG-7 Out N E7 Switchgear Room, 20ft DG-8 DG-08 E7 Switchgear OPFP-DG 2PFP-DG-8 Out N E8 Switchgear Room, 20ft DG-9 DG-09 E8 Switchgear OPFP-DG 2PFP-DG-9 Out N Caswell Beach Pumping Station CASBCH CASBCH Caswell Beach Pumping OPFP-Station MBOCA 0PFP-CAS Out N Hydrogen/Oxygen OPFP- 0PFP-HOSF Out N Hydrogen/Oxygen Storage Facility HOSF HOSF Storage Facility MBOCA Sodium Hypochlorite Facility SHF SHF Sodium Hypochlorite OPFP-SiHphrealyHSFacility MBOCA 0PFP-SHF Out N Switchyard YARD SY Yard OPFP- 0PFP-RELAY Out N MBOCA OF-EA u Auxiliary Boiler House ABH ABH Auxiliary Boiler House OPFP-MBPA OPFP-ABH Out N Admin - Annex Building (Security Office ADANX ADANX Admin - Annex Building OPFP-MBPA OPFP-ADANX Out N Building) ADANX_ ADANX_(Security Office Building) 0PFP-MBPA 0PFP-ADANX_ OutN Admin Building - First Floor ADMIN ADMIN-01 Administration Building OPFP-MBPA OPFP-ADMIN-1 Out N Admin Building - Second Floor ADMIN ADMIN-02 Administration Building OPFP-MBPA OPFP-ADMIN-2 Out N Clean Maintenance Shop - First Floor CM CM-01 Clean Maintenance Shop OPFP-MBPA OPFP-CM-1 Out N Rev 33 LAR Rev Page 36 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements FireFieFire Rad Release RAIn Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure Pr-lnIpt (Screened) Y/N Clean Maintenance Shop - Second Floor CM CM-02 Clean Maintenance Shop OPFP-MBPA OPFP-CM-2 Out N Fab Shop #1/MOV and Electrical FAB FAB-01 Fab Shops OPFP-MBPA OPFP-FAB1 Out N Fab Shop #3/Diesel Repair FAB FAB-03 Fab Shops OPFP-MBPA OPFP-FAB3 Out N Fire House FH FH Fire House OPFP-MBPA OPFP-FH Out N ISFSI Storage Building ISB ISB ISFSI Storage Building OPFP-MBPA OPFP-ISFSI-SB IN Y Lube Oil and Paint Storage Building LUBE LUBE Lube Oil and Paint OPFP-MBPA OPFP-LUBE Out N Storage Building I&C Breaker TestINDE Building MAINT MAINT l&C Breaker TestINDE OPFP-MBPA OPFP-MAINT Out N Building Mini Warehouse/Equipment- Outage MINI MINI Mini Warehouse/

Equipment - Outage 0PFP-MBPA 0PFP-MINI Out N Storage Building Storage Building Makeup Water Treatment Building MWT-1 MWT-01 Makeup Water Treatment OPFP-MBPA 0PFP-MWT Out N O&M Building - First Floor OMB OMB-01 O&M Building OPFP-MBPA OPFP-OMB-1 Out N O&M Building - Second Floor OMB OMB-02 O&M Building OPFP-MBPA OPFP-OMB-2 Out N O&M Building - Third Floor OMB OMB-03 O&M Building OPFP-MBPA OPFP-OMB-3 Out N Radioactive Material Container Storage RMCSB Radioactive Material - OPFP-MBPA

- RMCSB Container Storage OPFP-RMCSB IN Y Building Building Secondary Access Point SAP SAP Secondary Access Point OPFP-MBPA OPFP-SAP Out N Clean Scaffold Building SCAFF SCAFF Clean Scaffold Building OPFP-MBPA OPFP-SCAFF Out N Service Building - First Floor SERV SERV-01 Service Building OPFP-MBPA OPFP-SERV-1 IN Y Service Building - Second Floor SERV SERV-02 Service Building OPFP-MBPA OPFP-SERV-2 IN Y Hot Shop/Stores/Warehouse Building STORES STORES Hot Shop/Stores/ OPFP-MBPA OPFP-STORES IN Y Warehouse Building Storm Drain Rad Monitor Building STORM STORM Storm Drain Rad Monitor OPFP-MBPA OPFP-STORM IN Y Building____

Augmented Off-Gas Building AOG-1 AOG-01 Augmented Off-Gas OPFP-PBAA OPFP-AOG-1 IN Y Building 0PFP-PBAA _0PFP-AOG-1_INY Rev 33 LAR Rev Page 37 I I

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Y/N (Screened)

Unit 1 Recirc Power Distribution Center RPDC1 RPDC1 Unit 1 Recirc Power OPFP-PBM OPFP-RPDC Out N (PDC) Distribution Center (PDC)

Unit 2 Recirc Power Distribution Center RPDC2 RPDC2 Unit 2 Recirc Power OPFP-PBM OPFP-RPDC Out N (PDC) Distribution Center (PDC)

Radwaste Building Tank Room, minus 3ft RW-1 RW-01A Radwaste Building OPFP-PBAA OPFP-RW-la IN Y Radwaste Building CFD Area, 23ft RW-1 RW-01B Radwaste Building OPFP-PBAA OPFP-RW-lb IN Y Radwaste Building Processing, 35ft RW-1 RW-01C Radwaste Building OPFP-PBAA OPFP-RW-lc IN Y Radwaste Building Processing, 47ft RW-1 RW-01D Radwaste Building OPFP-PBAA OPFP-RW-ld IN Y Radwaste Building Roof, 44ft RW-1 RW-01E Radwaste Building OPFP-PBAA OPFP-RW-le IN Y Radwaste Building Elevator Machinery RW-1 RW-01F Radwaste Building OPFP-PBAA OPFP-RW-lf IN Y Room, 70ft Service Water Building Pump Area, 20ft SW1-1 SWi-01A Service Water Building OPFP-PBAA OPFP-SW-la Out N Service Water Building Basement, 4ft SWI-1 SW1-01B Service Water Building OPFP-PBAA OPFP-SW-lb Out N Service Water Building Sump, minus 13ft SWIA SWl-01C Service Water Building OPFP-PBAA OPFP-SW-lb Out N East Yard Open Area YARD EY Yard OPFP-PBAA OPFP-EY IN N Transformer Yard YARD TY Yard OPFP-PBAA OPFP-TY Out N Chlorination Building CLB CLB Chlorination Building OPFP-PBAA OPFP-EY Out N Unit 1 Condensate Transfer Pump House CTPH1 CTPH1 Unit 1 Condensate 0PFP-PBAA 0PFP-EY IN Y Transfer Pump House OF-BA OF-YI Unit 2 Condensate Transfer Pump House CTPH2 CTPH2 Unit 2 Condensate OPFP-PBAA OPFP-EY IN Y Transfer Pump House Duct Bank under East Yard DUCTBANK DUCTBANK DUCTBANK OPFP-PBAA OPFP-EY Out N Unit 1 HPCI C02 Bottle Room HCB1 HCB1 Unit Room1 HPCI C02 Bottle OPFP-PBAA OPFP-TY IN Y Unit 2 HPCI C02 Bottle Room HCB2 HCB2 Unit 2 HPCI C02 Bottle OPFP-PBAA OPFP-TY IN Y Room HVAC Cooling Towers HCT HCT HVAC Cooling Towers OPFP-PBAA OPFP-TY Out N Old NDE Shack NDE NDE Old NDE Shack OPFP-PBAA OPFP-EY Out N BSEP LAR Rev 33 LAR Rev Page 38 I I

BSEP Page 38 1

CP&L 4.0 Compliance with NFPA. 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure PePa n (Screened) Y/N Stack Filter House SFH SFH Stack Filter House OPFP-PBAA OPFP-EY IN Y Stack Monitoring House SMH SMH Stack Monitoring House OPFP-PBAA OPFP-EY Out N Sewage Treatment Plant STP STP Sewage Treatment Plant OPFP-PBAA OPFP-TY Out N Unit 1 Valve Pit VP1 VP1 Unit 1 Valve Pit OPFP-PBAA OPFP-EY Out N Unit 2 Valve Pit VP2 VP2 Unit 2 Valve Pit OPFP-PBAA OPFP-EY Out N Circwater Yard YARD CW Yard OPFP-PBAA OPFP-EY Out N Radwaste Loading Dock YARD RWLD Yard OPFP-PBAA OPFP-RW-lb IN Y Northwest Yard YARD NWY Yard OPFP-PBAA OPFP-TY Out N Radwaste Building Elevator RW-1 RW-01G Radwaste Building OPFP-PBAA OPFP-RW-lf Out Y Reactor Building Southwest Core Spray, RB1-1 RB1-01A Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-1a IN Y minus 17ft General Areas Reactor Building Northwest Core Spray, RB1-1 RB1-01B Unit 1 Reactor Building 1PFP-RB 1PFP-RBI-1b IN Y minus 17ft General Areas Reactor Building Northeast RHR Room, RB1-1 RB1-01C Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-1c IN Y minus 17ft General Areas Reactor Building Southeast RHR Room, RB1-1 RB1-01D Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-ld IN Y minus 17ft General Areas Reactor Building Northeast RHR Heat RB1-1 RB1-O1E Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-1e IN Y Exchanger, 20ft General Areas Reactor Building Southeast RHR Heat RB1-1 RBl-01F Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lf IN Y Exchanger, 20ft General Areas Reactor Building East Central, 2Oft RB1-1 RB1-01G(EC) Unit 1 Reactor General Areas Building 1PFP-RB 1PFP-RB1-lg N 1PFP-RB1-1g S IN Y Reactor Building North Central, 20ft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lg N IN Y 01G(NC) General Areas Reactor Building Northeast Corner, 20ft RBI-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lg N IN Y O1G(NE) General Areas _____

Reactor Building Northwest Corner, 20ft RB1-1 RB1- Unit 1 Reactor Building IPFP-RB 1PFP-RB1-lg N IN Y R B N C 21 General Areas Reactor Building South Central, 20ft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lg S IN Y ReactorBuildingSouthCentral,_20ft_ RBI-1 01G(SC) General Areas Rev 33 Page 39 I I

BSEP LARLAR Rev Page 39 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure Pr-lnIpt Y/N (Screened)

Reactor Building Southeast Corner, 20ft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lg S IN Y Rc Blgoe onfB 01G(SE) General Areas Reactor Building Southwest Corner, 20ft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lg S IN Y

___________________________ ~General Areas Reactor Building East Central, 5Oft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh E IN Y ReactorBuildingEas__entral,_50ft _ RBI-1 01 H(EC) General Areas Reactor Bid Nrth Central, 50ft R11 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh E IN Y uling 0 , - 01H(NC) General Areas 1PFP-RBI-1 h W Reactor uilding Northeast Corner, 50ft ReactorBuildingNortheastCorner,_50ft RB1-1 RB-1 RB1-01H(NE) Unit 1 Reactor General Areas Building 1PFP-RB 1PFP-RB1-lh E IN Y Reactor Building Northwest Corner, 50ft RB1-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh W IN Y R B g e n t01HNW) General Areas Reactor Building Southeast Corner, 50ft R11-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh E IN Y ReactorBuildingSotheastorner50f BI-1 01H(SE) General Areas Reactor Building Southwest Corner, 50ft R11-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh W IN Y ReactorBidingSothwestoner,_50f _B-1_ 01_H(SW) General Areas Reactor Building West Central, 5ft R131-1 RB1- Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lh W IN Y ReactoruildingWestCenral,_50tRBI-1 01H(WC) General Areas Reactor Building RWCU Access Room, 77ft RB1-1 R131-11 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-12 IN Y Reactor___Building __RW _U__Access __Room, 7t IB0 General Areas Reactor Building West, 80ft RB1-1 RB1-01J Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lj W IN Y

________________________________ __________General Areas _________

Reactor Building East, 80ft RB1-1 RB1-01K Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lk IN Y General Areas Reactor Building Spent Fuel Pool, 117ft RB1-1 RB1-O1L Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lm IN Y General Areas Reactor Building Refueling Floor, 117ft RB1-1 RB1-01M Unit 1 Reactor Building 1PFP-RB IPFP-RBI-lm IN Y General Areas Reactor Bidg HPCI Roof Mezzanine 5ft R11 R11N Unit 1 Reactor Building 1PFPRB 1PFP-RB1-le IN Y uling ae, - - General Areas 1PFP-RB1-lf Reactor Building ECCS Tunnel Roof, 36ft RB1-1 RB1-010 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-1o IN Y

____________________ I____I___I_ GeneralAreas I_______ I____I___I _

Page 40 I I

BSEP LAR BSEP Rev 33 LAR Rev Page 40 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Fire Release RCA?

Procedure Pre-Plan Input Y/N (Screened)

Reactor Building HPCI Room, minus l7ft RB1-1 RBl-02 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-2 IN Y General Areas Reactor Building Drywell and Torus RB1-1 RBl-03 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-3 IN Y General Areas Reactor Building MSIV Pit, 5ft R131-1 RBl-04 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-4 IN Y General Areas Reactor Building HP Field Office, RBI-1 RB1-05 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lgS IN Y Decontamination Room, 20ft General Areas Reactor Building Drywell Entry, 2ft R131-1 RBl-07 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-7 IN Y Rc Blgr ln,0R 11 General Areas Reactor Building TIP Room, 20ft R11-1 RBl-08 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-8 IN Y ReatorBuidigTPRom20tRI-RB1-General Areas Reactor Building Elevator Shaft R11-1 RBl-09 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-9 IN Y ReatorBuidigEevaorShatR

- RBGeneral Areas Reactor Building RWCU Pump and Heat RB1-1 RBl-10 Unit 1 Reactor Building 1PFP-RB lPFP-RBl-10 IN Y Exchanger Room, 50ft General Areas Reactor Building New Fuel Vault, 117ft R11-1 RBl-11 Unit 1 Reactor Building 1PFP-RB lPFP-RBl-16 IN Y RectruldngNe RB- ueVul,11ft RBGeneral Areas Reactor Building RWCU Backwash Tank RB1-1 RBl-12 Unit 1 Reactor Building 1PFP-RB lPFP-RBl-12 IN Y Room, 77ft RBI-1__ B1-12 General Areas 1PPRB 1F-R112I_

Reactor Building CRD Repair Room, 80ft RB1-1 RB1-13 Unit 1 Reactor Building 1PFP-RB lPFP-RBl-13 IN Y East General Areas 1PPR_1F-B1-3 I_

Reactor Building Skimmer Surge Tank Vault, RB1-1 RB1-14 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-14 IN Y 117ft General Areas Reactor Building Elevator Machinery Room, RB1-1 RBl-15 Unit 1 Reactor Building 1PFP-RB 1PFP-RBl-15 IN Y 133ft General Areas Reactor Building 1A RWCU Filter Pit, 117ft RB1-1 RB1-16 Unit 1 ReactorBuilding IPFP-RB lPFP-RB1-16 IN Y

___________ ~General Areas _______

Reactor Building lB RWCU Filter Pit, 17ft RB1-1 RBl-17 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-16 IN Y ReactorBuilding_1BRWCUFilterPit,_117ft RBI-1____ R17 General Areas Reactor Building Supply Room, 9ft RB1 -1 RBl-18 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lp IN Y ReactorBuildingSupplyRoom,_98ftRB-1 RB1-18 _ General Areas I Reactor Building Platform, 98ft R11-1 RBl-18GA Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-lp IN Y General Areas 1PFP-RB1-19 Page 41 II BSEP LAR BSEP Rev 3 LAR Rev 3 Page 41 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure Pr-lnIpt (Screened) Y/N Reactor Building Clothing Change room, 98ft RB1-1 RBl-19 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-19 IN Y ReactorBuildingClothingChangeroom 98ft RBI-1 RB1-19 General Areas Reactor Building RWCU Valve Room, 77ft RB1-1 RBl-20 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-12 IN Y ReactorBuildingRWCUValveRoom,77f RBGeneral Areas Reactor Building Resin Storage Room, 80ft RB1-1 RB1-21 Unit 1 Reactor Building 1PFP-RB 1PFP-RB1-21 IN Y East General Areas Reactor Building ECCS Mini Steam Tunnel, RB1-6 RB1-06 Mini Steam Tunnel 1PFP-RB 1PFP-RB1-6 IN Y 20ft Electrical Tunnel, 9ft TB1 ET Turbine Building General 1PFP-TB 1PFP-TB1-ET IN Y Areas Pipe Tunnel, -3ft T11 PT Turbine Building General 1PFP-TB 0PFP-RW-1a IN Y Pipe__Tunnel,__-3ftTB1 PTAreas Unit 1 TB Breezeway South, 20ft TB1 TB1-01A Turbine Building General 1PFP-TB 1PFP-TB1-1 IN Y Areas Unit 1 TB Breezeway North, 2ft T131 TBl-01B Turbine Building General 1PFP-TB 1PFP-TB1-1 IN Y Unit_1TBBreezewayNorh,20ftTB TB1-01B Areas Unit 1 TB Mechanical Vacuum Pump Area, TB1 TB1-01C Turbine Building General 1PFP-TB 1PFP-TB1-lc IN Y 20ft Areas Unit 1 TB Air Compressor Area, 20ft TB1 TB1-01D Turbine Building General 1PFP-TB 1PFP-TB1-ld IN Y Areas Unit 1 TB 2A Air Dryer Area, 20ft TB1 TB1-01E Turbine Building General 1PFP-TB 1PFP-TB1-le IN Y Areas Unit 1 TB 4KV Switchgear Area, 20ft TB1 TB1-01F Turbine Building General 1PFP-TB 1PFP-TB1-lf IN Y Areas Unit 1 TB Hydrogen Seal Oil Area, 20ft TB1 TB1-01G Turbine Building General 1PFP-TB 1PFP-TB1-lg IN Y Areas Unit 1 TB Condensate Pump Area, 20ft TB1 TB1-01H Turbine Building General 1PFP-TB 1PFP-TB1-lh IN Y Areas Unit 1 TB 1A Reactor Recirc MG Set Room, TB1 TB1-011 ATurbine Building General 1PFP-TB 1PFP-TB1-li &j IN Y 38ft Areas Unit 1 TB 1B Reactor Recirc MG Set Room, TB1 TB1-01J Turbine Building General 1PFP-TB 1PFP-TB1-li &j IN Y 38ft Areas Unit 1 TB South 38ft and 45ft TB1 TB1-01K Turbine Building General 1PFP-TB 1PFP-TB1-lk IN Y Areas BSEP LAR Rev 3 Tage 42

CP&L 4.0 Compliance with NFPA 806 Requirements Fire FieFire Rad Release RAIn Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre Input RCA?

Procedure Pre-Plan Input Y/N (Screened)

Unit 1 TB3 Supply Fan Room 55f T131 TB1-1L Turbine Building General 1PFP-TB 1PFP-TBl-11 IN Y Areas Unit 1 TB Main Turbine Front Standard Area, TB1 TB1-01M Turbine Building General 1PFP-TB 1PFP-TB1-lm IN Y 70ft Areas Unit 1 TB Main Turbine and MSR Area, 70ff TB1 TB1-O1N Turbine Building General 1PFP-TB 1PFP-TB1-1n IN Y U1B nr aM A ,f1 Areas Unit 1 TB Main Generator and Exciter area, TB1 TB1-010 Turbine Building General 1PFP-TB 1PFP-TB1-lo IN Y 70ft Areas Unit 1 TB 1B SJAE Room, 20ft TB1 TB1-02 Turbine Building General 1PFP-TB 1PFP-TB1-2 IN Y Areas Unit 1 TB 1A SJAE Room, 20ft TB1 TB1-03 Turbine Building General 1PFP-TB 1PFP-TB1-3 IN Y

_______________________________Areas Unit 1 TB 1B RFPT Room, 20ft T11 TBl-04 Turbine Building General 1PFP-TB 1PFP-TB1-4 IN Y Areas Unit 1 TB 1A RFPT Room, 20ff TB1 TBl-05 Turbine Building General 1PFP-TB 1PFP-TB1-5 IN Y Areas Unit 1 TB Condensate Booster Pump Room, TB1 TB1-06 Turbine Building General 1PFP-TB 1PFP-TB1-6 IN Y 20ft Areas Unit 1 TB Heater Drain Pump Room, 9ff T11 TB1-07 Turbine Building General 1PFP-TB 1PFP-TB1-7 IN Y Unit_1_TBHeaterDrainPumpRoom,_9f TB1_TB1-07 Areas Unit 1 TB Condenser Bay Area, 20ff T11 TBl-08A Turbine Building General 1PFP-TB 1PFP-TB1-8a IN Y Areas Unit 1 TB Condenser Pit East Area, 20ff TB1 TBl-08B Turbine Building General 1PFP-TB 1PFP-TB1-8b IN Y Areas Unit 1 TB Condenser Pit West Area, 20ft T11 TBl-08C Turbine Building General 1PFP-TB 1PFP-TB1-8c IN Y Areas Unit 1 TB Condenser Bay Area, 45ft T131 TBl-8D Turbine Building General 1PFP-TB 1PFP-TB1-8d IN Y UtTC eeaA ,5T- Areas Unit 1 TB Condenser Pit East Area, 45f T131 TBl-08E Turbine Building General 1PFP-TB 1PFP-TB1-8e IN Y Areas Unit 1 TB Condenser Pit West Area, 45ft TB1 TB1-08F Turbine Building General 1PFP-TB 1PFP-TB1-8f IN Y Areas Unit 1 TB EHC and Lube Oil Room, 20ff TBI TBl-09A Turbine Building General 1PFP-TB 1PFP-TB1-9a IN Y Unit_1_TBEHCandLubeOlRoom,_20ft _TB1_TB1-09A Areas Rev 33 LAR Rev Page 43 I I

BSEP LAR Page 43 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre Input RCA?

Procedure Pre-Plan Input Y/N (Screened)

Unit 1 TB EHC and Lube Oil Room, 45ft TB1 TB1-09B Turbine Building General 1PFP-TB 1PFP-TB1-9b IN Y Areas Unit 1 TB Exhaust Fan Room, 45ft TB1 TBI-10 Turbine Building General 1PFP-TB 1PFP-TBI-10 IN Y

_____________________________Areas Unit 1 TB A Train HP Feedwater heater TB1 TBl-12 Turbine Building General 1PFP-TB 1PFP-TB1-12 IN Y Room, 45ft Areas Unit 1 TB B Train HP Feedwater heater TB1 TBl13 Turbine Building General 1PFP-TB 1PFP-TB1-13 IN Y Room, 45ft TB1_TB1-13 Areas Unit 1 TB Receiving Area T11 TBl-15 Turbine Building General 1PFP-TB OPFP-013 IN Y Unit__1_TBReceiving__Area_ TB1 TB1-15 Areas Unit 1 Heater Bay Roof YARD TB11- Yard 1PFP-TB 1PFP-TBI-1m IN Y

________________________ _______HBROOF Yad1FTB PPTB-m IY Turbine Building 1 Dragon's Breath T11 TB1-DB Turbine Building General 1PFP-TB 1PFP-TB1-12 IN Y TurbineBuilding_1_DragonsBreath _ TB1 TB1-DB__Areas Reactor Building Southwest Core Spray, RB2-1 RB2-01A Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-la IN Y minus 17ft General Areas Reactor Building Northwest Core Spray, RB2-1 RB2-01B Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1b IN Y minus 17ft General Areas Reactor Building Northeast RHR Room, RB2-1 RB2-01C Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1c IN Y minus 17ft General Areas Reactor Building Southeast RHR Room, RB2-1 RB2-01 D Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-ld IN Y minus 17ft General Areas Reactor Building Northeast RHR Heat R12-1 RB2-01 E Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1e IN Y Exchanger, 20ft General Areas Reactor Building Southeast RHR Heat R12-1 R12-01F Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lf IN Y Exchanger, 20ft RB2-1 General Areas Reactor Building East Central, 20ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg N IN Y ReactorBuildingEastCentral,_20ftRB2-1 01G(EC) General Areas 2PFP-RB2-lg S Reactor Building North Central, 2Oft RB2-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg N IN Y ReactorBuildingNorthCentral,_20ftRB2-1 01G(NC) General Areas Reactor Building Northeast Corner, 20ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg N IN Y 01 G(NE) General Areas Reactor Building Northwest Corner, 20ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg N IN Y ReactorBuildingNorthwestCorner,20ft RB2-1 01 G(NW) General Areas Rev 33 Page~ I I

BSEP LAR Rev Page 44 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Procedure Pre Pre-Plan Input Input RCA?

Y/N (Screened)

Reactor Building South Central, 20ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg S IN Y ReactorBuildigSoutCentrl,_20f_ RB2-1 01G(SC) General Areas Reactor Building Southeast Corner, 20ft RB2-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg S IN Y 01G(SE) General Areas Reactor Building Southwest Corner, 20ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg S IN Y 01G(SW) General Areas Reactor Building East Central, 50ft RB2-1 RB2- Unit 2 Reactor 01 H(EC) General Areas Building 2PFP-RB 2PFP-RB2-lh E IN Y Reactor Bid Nrth Ctl 50ft RB21 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lh E IN Y uling o enra, - 01 H(NC) General Areas 2PFP-RB2-1h W Reactor Building Northeast Corner, 5Oft RB2-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lh E IN Y R tBd Nt so r0R01 H(NE) General Areas Reactor Building Northwest Corner, 50ft RB2-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1h W IN Y R01H(NW) General Areas Reactor Building Southeast Corner, 5Oft RB2-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lh E IN Y Reactor Building Sotheast Corner,50f R-01H(SE) General Areas Reactor Building Southwest Corner, 50ft R12-1 RB2- Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lh W IN Y ReactorBuildingSouthwestCorner,50ft RB2-1V General Areas Reactor Building West Central, 50ft R12-1 RB2- Unit 2 Reactor 01 H(WC) General Areas Building 2PFP-RB 2PFP-RB2-1h W IN Y Reactor Building RWCU Access Room, 77ft RB2-1 R12-011 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-12 IN Y General Areas Reactor Building West, 80ft R12-11 R12-1J Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lj W IN Y ReactorBuildngWest,_80ftRB2-1_RB2-01J General Areas Reactor Building East, 80ft RB2-1 RB2-01 K Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1k IN Y General Areas Reactor Building Spent Fuel Pool, 117ft R132-1 RB2-01 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1m IN Y General Areas Reactor Building Refueling Floor, 117ft RB2-1 RB2-1 M Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-1m IN Y General Areas uidg HPCI Rf0 Reactor Bilding Meezzanine, 5ft R21 - R21N- Unit 2 Reactor General Areas Building 2PFP-RB 2PFP-RB2-le 2PFP-RB2-lf IN Y BSEP Rev 33 LAR Rev Page 45 I I

BSEP LAR Page 45 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire FieFire Rad Release RAIn Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre Input RCA?

Procedure Pre-Plan Input Y/N (Screened)

Reactor Building EGGS Tunnel Roof, 36ft R132-1 RB2-01 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lo IN Y General Areas Reactor Building HPCI Room, minus 17ff RB2-1 RB2-02 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-2 IN Y Reactor__BuildingHP__Room,_minus_17ft RBGeneral Areas Reactor Building Drywell and Torus RB2-1 R12-03 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-3 IN Y General Areas Reactor Building MSIV Pit, ft R132-11 R12-04 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-4 IN Y RcriiMVi5tB2 General Areas Reactor Building HP Field Office, RB2-1 RB2-05 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lg IN Y Decontamination Room, 20ft General Areas Reactor Building Drywell Entry, 20ft RB2-1 RB2-07 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-7 IN Y General Areas Reactor Building TIP Room, 20ff RB2-1 R32-08 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-8 IN Y ReactorBuildigTIPRom,_20tRB2-1 RB2-08 General Areas Reactor Building Elevator Shaft RB2-1 R12-09 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-9 IN Y General Areas Reactor Building RWCU Pump and Heat R12-1 R12-10 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-10 IN Y Exchanger Room, 50ft General Areas Reactor Building New Fuel Vault, 117ff RB2-1 R32-1 1 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lm IN Y General Areas Reactor Building RWCU Backwash Tank RB2-1 R12-12 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-12 IN Y Room, 77ft General Areas Reactor Building CRD Repair Room, 80ft RB2-1 RB2-13 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-13 IN Y East General Areas Reactor Building Skimmer Surge Tank Vault, RB2-1 RB2-14 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-14 IN Y 117ft General Areas Reactor Building Elevator Machinery Room, RB2-1 RB2-15 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-15 IN Y 133ft General Areas Reactor Building 2A RWCU Filter Pit, 117ff R12-1 R12-16 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-16 IN Y ReactorBuding2AWCUFilterPit,117f RB2-1B2General Areas Reactor Building 2B RWCU Filter Pit, 117ff RB2-1 R32-17 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-16 IN Y ReactorBuildng_2BRWCUFiterPit,_1_7f __B2-1 _ _B2-17 _ General Areas Reactor Building Supply Room, 98ff R12-1 RB2-18 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lp IN Y ReactorBuildingSupplyRoom,_98ftB2-1 RB2-18 _ General Areas Rev 33 LAR Rev BSEP LAR Page 46 I I

BSEP Page 46 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan re Release RCA?

Procedure Pre-Plan Input YIN (Screened)

Reactor Building Platform, 98ft RB2-1 RB2-18GA Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-lp IN Y

__________General Areas Reactor Building Clothing Change room, 98f RB32-1 RB2-19 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-19 IN Y General Areas Reactor Building Resin Storage Room, 80ft RB2-1 RB2-20 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-20 IN Y East RB2-1_ RB2-20 General Areas Reactor Building RWCU Valve Room, 77ft RB2-1 RB2-21 Unit 2 Reactor Building 2PFP-RB 2PFP-RB2-12 IN Y General Areas Reactor Building EGGS Mini Steam Tunnel, RB2-6 RB2-06 Mini Steam Tunnel 2PFP-RB 2PFP-RB2-6 IN Y 20ff Unit 2 TB Breezeway North TB1 TB2-01A Turbine Building General 2PFP-TB 2PFP-TB2-1 IN Y Areas BuildingGeneral Unit 2 TB Breezeway South TB1 TB2-01 B Turbine Building General 2PFP-TB 2PFP-TB2-1 IN Y Areas Unit 2 TB Mechanical Vacuum Pump Area, TB2OIC Turbine Building General 2PFP-TB 2PFP-TB2-lc IN Y 20ft TB1 Areas Unit 2 TB Air Compressor Area, 20ft TB1 TB2-01 D Turbine Building General 2PFP-TB 2PFP-TB2-ld IN Y Areas Unit 2 TB 2A Air Dryer Area, 20ft TB1 TB2-01 E Turbine Building General 2PFP-TB 2PFP-TB2-le IN Y Areas Unit 2 TB 4KV Switchgear Area, 20ft TB1 TB2-01F Turbine Building General 2PFP-TB 2PFP-TB2-lf IN Y Areas Unit 2 TB Hydrogen Seal Oil Area, 20ft TB1 TB2-01G Turbine Building General 2PFP-TB 2PFP-TB2-lg IN Y Areas Unit 2 TB Condensate Pump Area, 20ft TB1 TB2-01 H Turbine Building General 2PFP-TB 2PFP-TB2-lh IN Y Areas Unit 2 TB 2B Reactor Recirc MG Set Room, TB1 T12-01 Turbine Building General 2PFP-TB 2PFP-TB2-1 & j IN Y 38ft Areas 2F-B P-T-i& IN Unit 2 TB 2A Reactor Recirc MG Set Room, TB1 TB2-01J Turbine Building General 2PFP-TB 2PFP-TB2-1i &j IN Y 38ff Areas Unit 2 TB North 38ft and 45ft TB1 TB2-01 K Turbine Building General 2PFP-TB 2PFP-TB2-lk IN Y Areas Unit 2 TB Supply Fan Room 55ft TB1 TB2-01L Turbine Building General 2PFP-TB 2PFP-TB2-1l IN Y I Areas 2PFP-TB_2PFP-TB2-11 _IN_ Y Page 47 II BSEP LAR BSEP Rev 33 LAR Rev Page 47 1

CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre Input RCA?

Procedure Pre-Plan Input YIN (Screened)

Unit 2 TB Main Turbine Front Standard Area, TB1 TB2-01M Turbine Building General 2PFP-TB 2PFP-TB2-1m IN Y 70ft Areas Unit 2 TB3 Main Turbine and MSR Area, 70ft T1 T12-01N Turbine Building General 2PFP-TB 2PFP-TB2-1n IN Y Unit_2_TBMainTubineandMSRArea 70fTBTB-01 Areas Unit 2 TB Main Generator and Exciter area, TB1 TB2-010 Turbine Building General 2PFP-TB 2PFP-TB2-lo IN Y 70ft Areas Unit 2 TB 2B SJAE Room, 20ft T11 T12-02 Turbine Building General 2PFP-TB 2PFP-TB2-2 IN Y Unit__2__TB_2B __SJAERoom, __20ft _ TB1 T-Areas Unit 2 TB 2A SJAE Room, 20ft TB1 TB2-03 Turbine Building General 2PFP-TB 2PFP-TB2-3 IN Y Areas Unit 2 TB 2B RFP Room, 20ft TB1 TB2-04 Turbine Building General 2PFP-TB 2PFP-TB2-4 IN Y Areas Unit 2 TB 2A REP Room, 20ft T11 T12-05 Turbine Building General 2PFP-TB 2PFP-TB2-5 IN Y Unit__2_TB_2ARFPRoom,_20ft _ TB1 TB2-05_Areas Unit 2 TB Condensate Booster Pump Room, TB1 TB2-06 Turbine Building General 2PFP-TB 2PFP-TB2-6 IN Y 20ft Areas Unit 2 TB Heater Drain Pump Room, 20ft TB1 TB2-07 Turbine Building General 2PFP-TB 2PFP-TB2-7 IN Y Areas Unit 2 TB Condenser Bay Area, 20ft TB1 TB2-08A Turbine Building General 2PFP-TB 2PFP-TB2-8a IN Y Areas Unit 2 TB Condenser Pit East Area, 20ft TB1 TB2-08B Turbine Areas Building General 2PFP-TB 2PFP-TB2-8b IN Y Unit 2 TB Condenser Pit West Area, 20ft T131 T2-08C Turbine Building General 2PFP-TB 2PFP-TB2-8c IN Y Unit_2_TBCondenserPitWestArea,20 _ T2Areas Unit 2 TB Condenser Bay Area, 45ft TB1 TB2-08D Turbine Building General 2PFP-TB 2PFP-TB2-8d IN Y Areas Unit 2 TB3 Condenser Pit East Area, 45ft TB1 T2-08E Turbine Building General 2PFP-TB 2PFP-TB2-8e IN Y Areas Unit 2 TB Condenser Pit West Area, 45ft TBI TB2-08F Turbine Building General 2PFP-TB 2PFP-TB2-8f IN Y Areas Unit 2 TB EHC and Lube Oil Room, 20ft TB1 TB2-09A Turbine Building General 2PFP-TB 2PFP-TB2-9a IN Y Areas Unit 2 TB EHC and Lube Oil Room, 45ft TB1 TB2-09B Turbine Building General 2PFP-TB 2PFP-TB2-9b IN Y Areas Page 48 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements Fire Rad In FieFire Release RA Fire Zone Description Fire Area Fire Zone Fire Area Description Pre-Plan Pre-Plan Input RCA?

Procedure Pr-lnIpt (Screened) Y/N Unit 2 TB Exhaust Fan Room, 45ft T131 T12-1 Turbine Building General 2PFP-TB 2PFP-TB2-10 IN Y Areas Unit 2 TB A Train HP Feedwater heater T11 T1212 Turbine Building General 2PFP-TB 2PFP-TB2-12 IN Y Room, 45ft TB1_TB2-_2 Areas Unit 2 TB B Train HP Feedwater heater T11 TB21 Turbine Building General 2PFP-TB 2PFP-TB2-13 IN Y Room, 45ft TB1_TB2-13 Areas Turbine Building Elevator Shaft T131 T132-14 Turbine Building General 2PFP-TB 2PFP-TB2-14 IN Y T ieud EetStT2Areas 2PFP-TB 2PFP-TB2-14 IN _ Y Turbine Building Elevator Machinery Room TB1 T12-15 Turbine Building General 2PFP-TB 2PFP-TB2-15 IN Y TTT-iBd EvrceR Areas Turbine Building Laydown Area TB1 TB2-16 Turbine Building General 2PFP-TB 2PFP-TB2-16 IN Y

___ ___ Areas _ _ _ _ _ _ ________ _ _ _ _ _

Unit 2 Heater Bay Roof YARD TB12- Yard 2PFP-TB 2PFP-TB2-1m IN Y HBROOF Yad2FTB PPTB-m IY Turbine Building 2 Dragon's Breath TB1 TB2-DB Turbine Building General 2PFP-TB 2PFP-TB2-12 IN Y TuneBidig2Drgn'_ratBT2D Areas Unit 1 Control Building Roof YARD CB-ROOF1 Yard OPFP-013 *New PFP IN Y Unit 2 Control Building Roof YARD CB-ROOF2 Yard OPFP-013 *New PFP IN Y Reactor Building 1 Roof YARD RB1-ROOF Yard OPFP-013 *New PFP IN Y BSEP LAR Rev 3 LAR Rev Page 49 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements Fire Brigade Training Plan Review; BSEP has completed transition of its fire brigade and site incident commander lesson plans to a fleet standard, NFPA 600 compliant format, aligning with NFPA 805, Section 3.4.1. Attributes are included within the new NFPA 600 lesson plans to address the Radioactive Release objectives. Lesson plan topics are technical skill-set based rather than fire area specific. As such, discussion points were noted for the topics applicable to, or having potential impact to radioactive release due to firefighting activities.

Discussion points are included regarding containment and monitoring of potentially contaminated fire suppression agents and products of combustion for the following lesson plan topical areas;

" Safety and Orientation

" Personnel Protective Equipment

" Fire Hose

" Forcible Entry

" Ventilation

" Overhaul

" Fire Attack Engineering Controls Review; The review panel determined Engineering Controls are adequate to ensure that radioactive materials (i.e., radiation) generated as a direct result of fire suppression activities is contained and monitored prior to release to unrestricted areas such that such release would be as low as reasonably achievable and would not exceed applicable 10 CFR, Part 20 limits. Engineering controls such as use of forced air ventilation and damming for fire suppression agent run-off was considered during review of fire pre-plans, for areas in which this is the anticipated response identified in the pre-fire plan. No new engineering controls were identified or established as a result of this review, and all present controls are as currently in place under the approved pre-transitional fire protection program.

Documentation; Results of the radioactive release reviews described above have been documented in summary format in Attachment E. Open Items identified in the review process will be incorporated into the indicated fire pre-plans.

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 (i.e., discussed in Section 4.5.1 and Attachments U, V, and W).

" NFPA 805 Performance-Based Approaches (i.e., discussed in Section 4.5.2).

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.5.1 Fire PRA Development and Assessment In accordance with the guidance in RG 1.205, a Fire PRA model was developed for BSEP 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," (i.e., hereafter referred to as Fire PRA Standard).

CP&L 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 Brunswick Unit 1 and 2 base internal events PRA (i.e., Calculation BNP-PSA-030) 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.

4.5.1.2 Fire PRA The internal events PRA was modified to capture the effects of fire both as an initiator of an event and as a potential failure mode of affected circuits and individual targets. The Fire PRA was developed using the guidance for Fire PRA development in NUREG/CR-6850/EPRI TR 1011989, approved FAQs, and EPRI TR 1016735.

The Fire PRA quality and results are discussed in the subsequent sections and in Attachments V and W, respectively.

Fire Model Utilization in the Application RG 1.205, Regulatory Position 4.2 and Section 5.1.2 of NEI 04-02, provide guidance on documenting the fire models used, and justifying that these fire models and methods are acceptable for use in performance-based analyses when performed by qualified users, have been verified and validated, and are used within their limitations and with the rigor required by the nature and scope of the analyses.

As part of the NFPA 805 transition, fire modeling was performed as part of the Fire PRA development (i.e., NFPA 805 Section 4.2.4.2) and, therefore, maximum expected fire scenario (MEFS)/limiting fire scenario (LFS) were not analyzed separately. 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:

" Fire Dynamics Tools (FDT's)

" Consolidated Model of Fire and Smoke Transport (CFAST)

" Fire Dynamics Simulator (FDS)

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CP&L 4.0 Compliance with NFPA 805 Requirements The approach taken at BSEP to simplify the analysis process incorporates features of several fire model tools covered by NUREG-1824, as well as additional features. The approach is collectively referred to as the Fire Modeling Generic Treatments. The analysis basis and Verification and Validation (V&V) documentation was provided in a proprietary Hughes Associates, Inc. report to the NRC on January 24, 2008. The report entitled "Generic Fire Modeling Treatments" is effectively a technical reference guide, a user's guide, and the V&V basis.

The use of the Generic Treatments in specific applications at BSEP falls within their limitations as described in the "Generic Fire Modeling Treatments". In addition to the generic fire modeling treatments that were used in the hazard analysis, several calculations were produced that used FDS, CFAST, and the FDT's as documented in NUREG-1824.

The acceptability of the use of these fire models is included in Attachment J.

4.5.1.3 Results of Fire PRA Peer Review The Brunswick Unit 1 and 2 Fire PRA (i.e., Calculations BNP-PSA-080 and BNP-PSA-082) was peer reviewed against the requirements of ASME/ANS RA-Sa-2009, Part 4 and Regulatory Guide 1.200, revision 2.

The results (i.e., Supporting Requirement capability assessments and Facts &

Observations (F&Os)) documented in the February 2012 Fire PRA peer review report, and subsequent focused scope peer review reports, were used to support the Fire PRA for the NFPA 805 application.

The Fire PRA update addressed the Supporting Requirement assessed deficiencies (i.e., Not Met or Capability Category I (CC I)). Completion of recommendations related to Supporting Requirement assessments and 'Finding' F&Os results in a Capability Category II assessment for the associated Supporting Requirements. 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. The results of the peer review 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 fire initiating events that collectively represent 95% of the calculated fire risk is included as Attachment W.

4.5.2 Performance-Based Approaches NFPA 805 outlines the approaches for performing performance-based analyses. As specified in Section 4.2.4, there are generally two types of analyses performed for the performance-based approach:

" Fire Modeling (i.e., NFPA 805, Section 4.2.4.1).

" Fire Risk Evaluation (i.e., NFPA 805, Section 4.2.4.2).

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.5.2.1 Fire Modeling Approach The fire modeling approach was not utilized for demonstrating compliance with NFPA 805 for BSEP.

4.5.2.2 Fire Risk Approach Overview of Evaluation Process The Fire Risk Evaluations were completed as part of the BSEP 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 are summarized in Table 4-1.

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 Safety Analysis was performed for each fire area. For areas containing variances from the deterministic requirements (VFDRs) of Section 4.2.3 of NFPA 805, a Fire Risk Evaluation was performed for each fire area containing VFDRs.

Ifthe 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 may include the Safe shutdown/NSCA Page 53 I l

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CP&L 4.0 Compliance with NFPA 805 Requirements 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 of the Fire PRA modeling treatment of VFDR 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.

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.

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

- 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 was 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.

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CP&L 4.0 Compliance with NFPA 805 Requirements

- Codes and standards or their alternatives accepted for use by the NRC are met, and

- Safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) are met, or provides sufficient margin to account for analysis and data uncertainty.

The requirements related to safety margins for the change analysis are described for each of the specific analysis types used in support of the Fire Risk Evaluation (FRE).

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CP&L 4.0 Compliance with NFPA 805 Requirements Requirements CP&L 4.0 Compliance with NFPA 805 Prepare for Fire Risk Evaluation Determine How to Model iDiscuss and Document in l

the VFDR in the Fire PRA Fire 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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CP&L 4.0 Compliance with NFPA 805 Requirements Results of Evaluation Process Disposition of VFDRs The BSEP existing post-fire SSA / 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 decrease in risk associated with the implementation of NFPA 805 for the overallplant should be calculated by summing the risk increases and decreases for each fire area (including any risk increasesresulting from previously approvedrecovery actions). The total risk increase should be consistent with the acceptanceguidelines 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 acceptanceguidelines in Regulatory Guide 1.174, then the net change in total plant risk incurredby any proposed alternatives to the deterministic criteria in NFPA 805, Chapter4 (otherthan 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 monitoring program shall be establishedto ensure that the availabilityand reliabilityof the fire protection systems and features are maintainedand to assess the performance of the fire protection program in meeting the performance criteria.

Monitoring shall ensure that the assumptionsin the engineering analysis remain valid."

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CP&L 4.0 Compliance with NFPA 805 Requirements 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 item for implementation 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

" 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 NFPA 805 Monitoring Program scoping document developed during implementation.

Phase 1 - 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

- Required by Chapter 3 of NFPA 805 o Nuclear Safety Capability Assessment equipment 4

- Nuclear safety equipment

- Fire PRA equipment

- NPO equipment o Structures, systems and components relied upon to meet radioactive release criteria

" Fire Protection Programmatic Elements 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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CP&L 4.0 Compliance with NFPA 805 Requirements Phase 2 - Screening Using Risk Criteria The equipment from Phase 1 scoping will be screened to determine the appropriate level of NFPA 805 monitoring. As a minimum, the SSCs identified in Phase 1 will be part of an inspection and test program and system/program health reporting. If not in the current program, the SSCs will be added in order to assure that the criteria can be met reliably.

The following screening process will be used to determine those SSCs that may require additional monitoring beyond normal inspection and test program and system/program health reporting and will be documented in the NFPA 805 Monitoring Program scoping document.

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 calculation, BNP-PSA-082.

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.OE-7 per year (OR)

Large Early Release Frequency (LERF) x (RAW) ->1.0E-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) and will be documented in the calculation, BNP-PSA-082.

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 NFPA 805 Monitoring Program The HSS fire protection systems and features not already monitored via an existing inspection and test program and/or in the existing system /

program health reporting, as described in procedure EGR-NGGC-0010, will be added to the NFPA 805 Monitoring Program and documented in the NFPA 805 Monitoring Program scoping document.

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 I

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CP&L 4.0 Compliance with NFPA 805 Requirements 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 added into Maintenance Rule. All NSCA equipment that are not HSS are considered LSS and need not be included in the monitoring program.

For non-power operational modes, the qualitative use of fire prevention to manage fire risk during Higher Risk Evolutions does not lend itself to quantitative risk measurement.

Therefore, fire risk management effectiveness is monitored programmatically similar to combustible material controls and other fire prevention programs. Additional monitoring beyond inspection and test programs and system/program health reporting is not considered necessary.

3. SSCs Relied upon for Radioactive Release Criteria The evaluations performed to meet the radioactive release performance criteria are qualitative in nature. The SSCs relied upon to meet the radioactive release performance criteria are not amenable to quantitative risk measurement. Additionally, since 10 CFR Part 20 limits (i.e., 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:

" Prompt Detection, including incipient detection fire watch and hot work fire watch

" Transient Combustible Controls Program Violations against FIR-NGGC-0009

" Fire Brigade Effectiveness including Fire Brigade Response Time, Fire Brigade Fire Drill, and Fire Brigade Fire Drill Objectives Monitoring of programmatic elements is more qualitative in nature since the programs do not lend themselves to the numerical methods of reliability and availability.

Therefore, monitoring is conducted using the existing program health programs. Fire protection health reports, self-assessments, regulator and insurance company reports provide inputs to the monitoring program.

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CP&L 4.0 Compliance with NFPA 805 Requirements CP&L 4.0 Compliance with NFPA 805 Requirements Phase 3 - Risk Target Value Determination Failure criteria is established by an expert panel based on the required fire protection and nuclear safety capability SSCs and programmatic elements assumed level of performance in the supporting analyses established in Phase 2. Action levels are established for the SSCs 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 (i.e., 3 operating cycles).

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.

Documentation of the monitoring program failure criteria and action level targets will be contained in a documented evaluation. It is anticipated that the availability and reliability criterion for High Safety Significant Performance Monitoring Groups will use the guidance included in several industry documents tempered by site-specific operating experience, Fire PRA assumptions, and equipment types (and vendor data or valid design input when available). Industry documents such as the EPRI Fire Protection Equipment Surveillance Optimization and Maintenance Guide TR-1006756, Final Report July 2003, NFPA codes, and/or the NRC Fire Protection Significance Determination Process in addition to site specific operating experience data may be used. The monitoring program failure criteria and action level targets will be documented in the NFPA 805 Monitoring Program scoping document.

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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CP&L 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 procedure, CAP-NGGC-0200 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 (i.e., at a frequency of approximately every two to three operating cycles), taking into account, where practical, industry wide operating experience. 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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CP&L 4.0 Compliance with NFPA 805 Requirements

• Fully describe process used*

Figure 4 NFPA 805 Monitoring - Scoping and Screening 4.7 Program Documentation, Configuration Control, and Quality Assurance 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 In accordance with the requirements and guidance in NFPA 805 Section 2.7.1, and NEI 04-02, BSEP has documented analyses to support compliance with BSEP LAR Rev 3 Page 63 d

CP&L 4.0 Compliance with NFPA 805 Requirements 10 CFR 50.48(c). The analyses are being performed in accordance with CP&L's processes for ensuring assumptions are clearly defined, that results are easily understood, that results are clearly and consistently described, and that sufficient detail is provided to allow future review of the entire analyses.

Analyses, as defined by NFPA 805 Section 2.4, performed to demonstrate compliance with 10 CFR 50.48(c) will be maintained for the life of the plant and organized to facilitate review for 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 have been created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation. Figure 4-9 shows the Planned Post-Transition Documents.

BSEP LAR Rev 3 Page 64

CP&L 4.0 Compliance with NFPA 805 Requirements NFPA 806 DOCUMENTS

• NSCA Database SNSEL Comp Cale PRA Equipment No-we and Data Equipment and Data Comp

&Cable FA Assessment Method/Results Method/Results MSO and OMA SSA Drawings Treatment NSCA SUPPORTING INFO Manual Action T-H Calculations Feasibility

• Table B- B-3 Table J FIRE SAFETY ANALYSIS (DBD)

Coordination Plant DBDs that , On a Fire Area Basis Calculations / Support NSCA -Fire Area Description MHIF

• FHA Database information

-Nuclear Safety Performance Criteria Compliance Summary (NEI 04-02 B-3 Table Results)

-Non-Power Evaluation Results Summary Non-Power Mode NSCA Treatment

• Radioactive Release Summary

" On a Generic Basis

-B-1 Table Results Non-Power Operations Calculations alUIaCLUVO Wease I raIlnIing y,

-Monitoring Program NFPA 806 FIRE RISK EVALUATIONS Fire Risk Evaluation Calculation(s)

................... -- F............................

ire PRA FHA DATABASE DATA  :

Ignition Sources FP Systems and

& Scenarios Features Data Inventory of B-ITable Hazards Detaildoata FHA SUPPORT DOCUMENTATION FP Systems FCode Compliance FP Drawings Evaluations Bold Sold t ext indicates new NFPA 805 documents FP System andl Engineering FPaSyDBDs Equivalency Evaluations Radioactive Fire Pre-Plans Release Review Calculation Figure 4 NFPA 805 Planned Post-Transition Documents and Relationships LAR Rev Rev 33 Page 65 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 Program documentation established, revised, or utilized in support of compliance with 10 CFR 50.48(c) is subject to CP&L 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 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).

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CP&L 4.0 Compliance with NFPA 805 Requirements 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. 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 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 (i.e., change in core damage frequency) and ALERF (i.e., 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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CP&L 4.0 Compliance with NFPA 805 Requirements Defining the Change (5.3.2)

License N opis Y AmendAentm rvosyapve Request Y es License Amendment Request NOT Required Preliminary Risk Screening (5.3.3)

Risk Evaluation (5.3.4)

PRA Capability Category Assessment

• Fire PRA Capability Category 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 BSEP [AR Rev 3 LAR Rev 3 Page 68 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements The BSEP Fire Protection Program configuration is defined by the program documentation. 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 BSEP documents and databases that currently exist will be revised to reflect the new NFPA 805 licensing bases requirements (Implementation Item in Attachment S).

Several NFPA 805 document types, such as NSCA Supporting Information, Non-Power Mode NSCA Treatment, 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.

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, 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

" Performance-Based Approach: Utilize the NFPA 805 change process developed in accordance with NEI 04-02, RG 1.205, and the 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. The plant documents that ensure these requirements are met are:

CAP-NGGC-0200 - Condition Identification and Screening Process EGR-NGGC-0005 - Engineering Change ESGOl 01 N - Safe Shutdown Engineer (Post-NFPA 805 Transition)

ESGO102N - Fire Protection Plant Change Impact Review ESGO1 03N - Circuit Analysis (Post-NFPA 805 Transition)

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CP&L 4.0 Compliance with NFPA 805 Requirements ESGO104N - Fire Protection Engineer (Post-NFPA 805 Transition)

ESG0105N - Basic Fire Modeling 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 Fire Protection Program Quality CP&L will maintain the existing fire protection quality assurance program.

During the transition to 10 CFR 50.48(c), BSEP performed work in accordance with the quality requirements of Section 2.7.3 of NFPA 805.

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 CP&L 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. CP&L 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 plant 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 BNP-PSA-080. In addition, sensitivity to uncertainty associated with specific Fire PRA parameters was quantitatively addressed in BNP-PSA-095.

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 CP&L 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.

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CP&L 4.0 Compliance with NFPA 805 Requirements Specific Requirements of NFPA 805 Section 2.7.3 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 procedures that require independent review.

Reference plant procedures:

EGR-NGGC-0003 - Design Review Requirements EGR-NGGC-0005 - Engineering Change EGR-NGGC-0017 - Preparation and Control of Design Analyses and Calculations 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) 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, CP&L has developed and maintains qualification requirements for individuals assigned various tasks. Position-Specific Guides have been 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. The following Training Guides have been developed and implemented.

ESGO089N - Fire Probabilistic Safety Assessment Engineer (Quantification),

ESGO093N - Fire Probabilistic Safety Assessment Engineer (Initial Development), and ESGO094N - Fire Probabilistic Safety Assessment Engineer (Data Development), and ESGO105N - Basic Fire Modeling 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 BSEP LAR Rev 3 Page 71 1

CP&L 4.0 Compliance with NFPA 805 Requirements 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.

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 Attachment C. 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

" 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, 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 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 E - EEEE/LA Criteria: Systems/Features required for acceptability of Existing Engineering Equivalency Evaluations / NRC approved Licensing Action (i.e.,

Exemptions/Deviations/Safety 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)

An evaluation of DID was performed for all fire areas as detailed in project procedure FPIP-129, NFPA 805 Fire Safety Analysis. This evaluation was performed for all areas, regardless of whether NFPA 805 compliance was demonstrated using a performance based approach or a deterministic approach. Although a discussion of DID features is not strictly required for areas that are deterministically compliant, the decision to include the evaluation for such areas was based on two factors. First, it was seen as a way of enhancing the overall approach to providing the plant's desired level of fire protection to that area. Second, if future changes to deterministic areas dictate that a performance based approach is desired, then including these features as credited DID features now will facilitate that transition. The regulatory basis for each fire area is provided in I

BSEP LAR Rev 3 Page 72 1

CP&L 4.0 Compliance with NFPA 805 Requirements Attachment C, but the presence of deterministic features in the DID discussion does not alter any conclusions regarding the post transition licensing basis.

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.

In Attachment S, two tables are listed. Table S-1 identifies Plant Modifications required to be completed. Table S-2 identifies training, programs, personnel equipment, and document changes and upgrades required to be completed.

The Fire PRA model will represent the as-built, as-operated and maintained plant following completion of the risk related modifications identified in Attachment S. In the event the PRA model requires revision following completion of the modifications and implementation items listed in Attachment S, the changes will be controlled through normal BSEP processes. These changes are not expected to be significant. The Main Control Room ceiling modification is the only outstanding change with respect to its inclusion in the Fire PRA model.

4.8.3 Supplemental Information -Other Licensee Specific Issues The development of a FPRA requires that assumptions and methods be expanded and updated to provide more realistic treatment of the data and the phenomena involved.

The updates and expansion of methods introduce differences in plant specific results depending on which alternatives are used. This section captures the sensitivities and insights based on these alternatives. These alternatives may be based on new analysis methods, new data, or deviations from guidance in NUREG/CR-6850 which would require sensitivity analyses to be performed for the license application.

4.8.3.1 Unreviewed Analysis Methods The peer review of the BSEP FPRA identified one method that had not been reviewed by the methods panel concerning the use of a split fraction for closed cabinet fires that result in damage outside of the cabinet. This method was reviewed by the NRC for the Harris plant NFPA 805 pilot effort as documented in Section 3.4.7 and Table 3.4-6 of the Safety Evaluation for the Harris Plant license amendment (ML101130535).

There is variation in the methods in treating how MCCs can be treated as "closed" cabinets. If a cabinet were always "closed" there would be no fire impact on external targets. However, there is always the potential for the cabinet to already be open or an arc fault to have enough energy to open the cabinet. For the BSEP FPRA, it was assumed that one out of ten MCC fires may result in an "open" cabinet configuration.

This is not applied to the HRR as a severity factor, but as a split fraction on the likelihood that the cabinet remains "closed."

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CP&L 4.0 Compliance with NFPA 805 Requirements The guidance for characterizing closed cabinets at the Brunswick plant was the same as that used for the Harris Nuclear Plant pilot effort. The use of split fractions as described above was deemed acceptable for use by the NRC at HNP.

A sensitivity analysis was performed on this method for the BSEP FPRA. The sensitivity analysis essentially removed the split fraction, effectively treating the closed MCCs as always open. The results of the sensitivity study for the "closed" cabinet method are provided below.

Table 4-4 -Closed MCCs Sensitivity Delta CDF and Delta LERF Results Unit 1 Unit 2 ACDF [/yr] ALERF [lyr] ACDF [lyr] ALERF [lyr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions 9.1 E-07 9.1 E-08 9.1E-07 9.1E-08 Total 2.1 E-06 1.OE-07 3.6E-06 9.6E-08 A manual summation may differ from the Total due to rounding in the last digit.

Table 4 Closed MCCs Sensitivity Total CDF and Total LERF Results Unit I Unit 2 CDF [Iyr] LERF [Iyr] CDF [/yr] LERF [Iyr]

Internal Events plus External Flooding and 1.4E-05 6.2E-07 1.4E-05 6.2E-07 High Winds Firel'1 2.1 E-05 4.3E-06 2.OE-05 4.OE-06 2

Fire - Recovery Actions[ 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 3.6E-05 5.OE-06 3.5E-05 4.8E-06 Ili Fire results do not credit control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.8.3.2 Concerns with NUREG/CR-6850 CPT Credit Based on preliminary results for fire circuit testing, the credit allowed in Tables 10-1 and 10-3 of NUREG/CR-6850 for Control Power Transformers (CPT) in AC circuits was questioned by NRR. This is based on an RAI letter to Duane Arnold (ML12031A112).

The sensitivity analysis was performed by removing the approximate factor of two reduction in failure mode probability estimates between cables with CPT and those without. The results of the sensitivity study analysis for the CPT credit are provided below.

Table 4 CPT Sensitivity Delta CDF and Delta LERF Results Unit 1 Unit 2 ACDF [lyr] ALERF [/yr] ACDF [/yr] ALERF [lyr]

VFDRs 1.2E-06 1.4E-08 2.7E-06 5.2E-09 Recovery Actions 9.1 E-07 9.1 E-08 9.1E-07 9.1E-08 Total 2.1 E-06 1.OE-07 3.6E-06 9.6E-08 A manual summation may differ from the Total due to rounding in the last digit.

Table 4 CPT Sensitivity Total CDF and Total LERF Unit I Unit 2 CDF [/yr] LERF [/yr] CDF [lyr] LERF [/yr]

Internal Events plus External Flooding and 1.4E-05 6.2E-07 1.4E-05 6.2E-07 High Winds Fire[r] 2.1 E-05 4.3E-06 2.OE-05 4.OE-06 Fire - Recovery Actions[2 1 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 3.6E-05 5.OE-06 3.5E-05 4.8E-06 Ill Fire results do not credit control room abandonment for loss of control sequences.

[21 Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.8.3.3 Sensitivity Analysis Required by FAQ 08-0048 In order to use the updated fire bin ignition frequencies provided in Supplement 1 to NUREG/CR-6850, a sensitivity analysis must be performed comparing the impact of those bins characterized by an alpha from the EPRI TR-1 016735 analysis that is less than or equal to 1. While the new point estimates for the bin ignition frequencies better represent the data, uncertainties are large and a sensitivity analysis using the older conservative frequencies is required to assess the potential impact of using the new frequencies.

Table 4 Ignition Frequency Sensitivity Delta CDF and Delta LERF Results Unit I Unit 2 ACDF [lyr] ALERF [lyr] ACDF [/yr] ALERF [Iyr]

VFDRs 2.0E-06 2.2E-08 3.6E-06 6.9E-09 Recovery Actions 2.7E-06 2.7E-07 2.7E-06 2.7E-07 Total 4.6E-06 2.9E-07 6.3E-06 2.7E-07 A manual summation may differ from the Total due to rounding in the last digit.

Table 4 Ignition Frequency Sensitivity Total CDF and Total LERF Unit I Unit 2 CDF [lyr] LERF [lyr] CDF [/yr] LERF [lyr]

Internal Events plus External Flooding and 1.4E-05 6.2E-07 1.4E-05 6.2E-07 High Winds Firer"] 3.4E-05 8.6E-06 3.6E-05 8.3E-06 2

Fire - Recovery Actionst 3.1 E-06 3.1 E-07 3.1 E-06 3.1 E-07 Total 5.1 E-05 9.5E-06 5.3E-05 9.2E-06 Ill Fire results do not credit control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

4.8.3.4 Main Control Room Abandonment The control room abandonment has a detailed human error analysis.

Control room abandonment was not credited for loss of control scenarios.

The Brunswick control room has two main areas that contribute to control room abandonment: the area where in the control room staff generally manipulates controls and, the area that is outside that region. The region that the control room staff generally occupies while manipulating the controls has a much lower ceiling height and smaller I

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CP&L 4.0 Compliance with NFPA 805 Requirements footprint than the remaining area and, as such, has a much shorter time to suppress a fire prior to reaching control room habitability concerns that require abandonment. A shorter time to suppress the fire increases the frequency of control room abandonment which is directly proportional to CDF and LERF contributions for control room abandonment. The control room abandonment risk is conservative since the fire frequency contribution from the cabinets that comprise the boundary for the control manipulation area is all applied to the small area when there is significant probability that the fire would vent out of the back of the panels to the larger area with higher ceilings. Since methods to determine a split fraction of fires that vent to the rear of the panel were not peer reviewed, all of the frequency was conservatively applied to the smaller region with the low ceiling resulting in conservative times to conditions requiring control room abandonment.

4.8.3.5 Reduction in Transient Source Heat Release Rate Following transition to NFPA 805, BSEP will adopt a more restrictive transient control program that will nominally limit the transient fire HRR to the 143 kW range instead of the 317 kW range. The transient control program is the fleet program and is already in use at HNP. The 143 kW range was used for the transient fire locations in all areas except for the turbine building, which uses a 317 kW HRR.

4.8.3.6 Incipient Detection in Main Control Boards The FPRA credits the use of air-aspirated incipient detection, also known as Very Early Warning Fire Detection Systems (VEWFDS) in NFPA 76, in the Main Control Boards (MCBs) because that modification is expected to be completed prior to the transition to NFPA 805. To support the use of incipient detection, a walkdown was performed for a representative sample of BSEP MCBs and determined the fraction of fast-acting components to be very small (less than 0.5%) of the total component count.

A sensitivity analysis was performed using the currently installed in-panel ion smoke detection rather than the incipient detection. The NUREG/CR-6850 Appendix L method was used to determine the frequency of self-fires that cause fire damage only within the MCBs, then the ignition frequency of NUREG/CR-6850 Supplement 1 was modified by the "normal" non-suppression probability for ion smoke detectors and manual detection/suppression for fires that also cause damage in the zone-of-influence outside the MCBs. For the zone-of-influence fires, the human reliability analysis for LERF was further refined to account for operator actions to secure AC and DC power to primary containment isolation valves during MCR abandonment not related to habitability issues.

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CP&L 4.0 Compliance with NFPA 805 Reauirements Table 4 MCB Incipient Detection Sensitivity Delta CDF and Delta LERF Results Unit I Unit 2 ACDF [/yr] ALERF [/yr] ACDF [/yr] ALERF [/yr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions [ 9.1E-07 9.1E-08 9.1 E-07 9.1 E-08 Total 2.1 E-06 1.OE-07 3.6E-06 9.6E-08

[] Values are for recovery actions associated with control room abandonment due to environmental reasons and address those actions away from the remote shutdown panel.

A manual summation may differ from the Total due to rounding in the last digit.

Table 4 MCB Incipient Detection Sensitivity Total CDF and Total LERF Results Unit 1 4 Unit 2 CDF [/yr] LERF [/yr] CDF [/yr] LERF [/yr]

Internal Events plus External 1.E-05 6.2E-07 1.E-05 6.2E-07 Flooding and High Winds Fire[11 4.8E-05 5.6E-06 5.1 E-05 5.5E-06 Fire - Recovery Actions[21 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 6.3E-05 6.3E-06 6.6E-05 6.2E-06

[1]

Fire results credit operator actions to secure power during control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding inthe last digit.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.8.3.7 Pump Heat Release Rate for Motor Pumps The use of the 9 8 th percentile HRR of 69kW for motor fires from NUREG/CR-6850 as opposed to the electrical pump fire HRR of 211 kW was questioned by NRR. The sensitivity study changed the HRR to 211 kW for motor fires, which resulted in additional targets. The results of the sensitivity study are provided below.

Table 4 Pump HRR for Motor Pumps Sensitivity Delta CDF and Delta LERF Results Unit I Unit 2 ACDF [lyr] ALERF [/yr] ACDF [lyr] ALERF [lyr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions 9.1E-07 9.1 E-08 9.1E-07 9.1E-08 Total 2.1 E-06 1.OE-07 3.6E-06 9.6E-08 A manual summation may differ from the Total due to rounding inthe last digit.

Table 4 Pump HRR for Motor Pumps Sensitivity Total CDF and Total LERF Results Unit I Unit 2 CDF [/yr] LERF [lyr] CDF [lyr] LERF [/yr]

Internal Events plus External 1.E-05 6.2E-07 1.E-05 6.2E-07 Flooding and High Winds Firel11 2.OE-05 4.3E-06 2.OE-05 4.0E-06 Fire - Recovery Actions[21 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 3.5E-05 5.OE-06 3.5E-05 4.8E-06

[1]

Fire results credit operator actions to secure power durng control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.8.3.8 Sensitive Electronics Sensitivity Analysis A quantitative evaluation has been conducted for determining if the current treatment of fire damage to sensitive electronics in the BSEP FPRA has a significant effect on the quantified fire risk values. The evaluation consisted of two main activities: 1) identifying sensitive electronic components credited in the FPRA, and 2) adding the fire compartments of each identified sources full transient frequency to the IGF for each source containing sensitive electronic equipment. The results of the sensitivity study are provided below.

Table 4 Sensitive Electronics Sensitivity Delta CDF and Delta LERF Results Unit I Unit 2 ACDF [/yr] ALERF [/yr] ACDF [lyr] ALERF [lyr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions 9.1E-07 9.1E-08 9.1E-07 9.1E-08 Total 2.1 E-06 1.OE-07 3.6E-06 9.6E-08 A manual summation may differ from the Total due to rounding in the last digit.

Table 4 Sensitive Electronics Sensitivity Total CDF and Total LERF Results Unit I Unit 2 CDF [/yr] LERF [Iyr] CDF [Iyr] LERF [Iyr]

Internal Events plus External 1.4E-05 6.2E-07 1.4E-05 6.2E-07 Flooding and High Winds Firel1 ] 2.OE-05 4.3E-06 2.OE-05 4.OE-06 Fire - Recovery Actions[21 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 3.5E-05 5.OE-06 3.5E-05 4.8E-06

[I]

Fire results credit operator actions to secure power during control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

4.8.3.9 Smoke Damage Sensitivity Analysis A qualitative evaluation has been conducted for determining if the current treatment of smoke damage in the BSEP FPRA has a significant effect on the quantified fire risk values (i.e. CDF and LERF). The results of the evaluation suggest that the current treatment of smoke damage in the BSEP FPRA is consistent with the guidance in Appendix T of NUREG/CR-6850. The quantification approach for ignition sources and targets inside and outside of the control room captures failure of the credited function in Page 80 I I

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CP&L 4.0 Compliance with NFPA 805 Requirements the FPRA that could be generated by smoke damage (i.e., function failures within the panels connected to the panel of fire origin).

4.8.3.10 Main Control Room Abandonment Bundle Treatment A sensitivity analysis was done to treat all Main Control Board (MCB) panels as multi-bundle fires, rather than single bundle fires, in the MCR Abandonment study. The risk of abandonment with the single bundle treatment was compared to risk of abandonment with the multi-bundle treatment when taking credit for in-cabinet detection. The results of the sensitivity study are provided below.

Table 4 Main Control Room Abandonment Bundle Treatment Sensitivity Delta CDF and Delta LERF Results Unit 1 4 Unit 2

-~

ACDF [lyr] ALERF [/yr] ACDF [/yr] ALERF [/yr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions 1.OE-06 1.OE-07 1.OE-06 1.OE-07 Total 2.2E-06 1.1 E-07 3.7E-06 1.1 E-07 A manual summation may differ from the Total due to rounding in the last digit.

Table 4 Main Control Room Abandonment Bundle Treatment Sensitivity Total CDF and Total LERF Results Unit I Unit 2 CDF [lyr] LERF [lyr] CDF [/yr] LERF [lyr]

Internal Events plus External 1.E-05 6.2E-07 1.E-05 6.2E-07 Flooding and High Winds Fire[1 ] 2.OE-05 4.3E-06 2.OE-05 4.OE-06 Fire - Recovery Actions[21 1.2E-06 1.2E-07 1.2E-06 1.2E-07 Total 3.6E-05 5.OE-06 3.5E-05 4.8E-06

[1I Fire results credit operator actions to secure power during control room abandonment for loss of control sequences.

[2] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

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CP&L 4.0 Compliance with NFPA 805 Requirements 4.8.3.11 Maintenance Influence Factor Sensitivity Fire compartments that were assigned a maintenance influence factor of 10 were considered in this sensitivity for re-assignment to a factor of 50. A total of 5 fire compartments were selected. One fire compartment was selected for the Control/Reactor Building area for each unit, and one fire compartment was selected for the Turbine Building area for each unit. The single fire compartment selected for the Brunswick Wide area is common to both units. The results of the sensitivity study are provided below.

Table 4 Maintenance Influence Factor Sensitivity Delta CDF and Delta LERF Results Unit I Unit 2 ACDF [lyr] ALERF [lyr] ACDF [lyr] ALERF [lyr]

VFDRs 1.2E-06 1.3E-08 2.7E-06 5.2E-09 Recovery Actions 9.1E-07 9.1E-08 9.1E-07 9.1 E-08 Total 2.1E-06 1.OE-07 3.6E-06 9.6E-08 A manual summation may differ from the Total due to rounding inthe last digit.

Table 4 Maintenance Influence Factor Sensitivity Total CDF and Total LERF Results Unit I Unit 2 CDF [Iyr] LERF [lyr] CDF [lyr] LERF [lyr]

Internal Events plus External 1.E-05 6.2E-07 1.E-05 6.2E-07 Flooding and High Winds Fire[1 ] 2.OE-05 4.3E-06 2.OE-05 4.0E-06 Fire - Recovery Actions [2] 1.OE-06 1.OE-07 1.0E-06 1.OE-07 Total 3.5E-05 5.OE-06 3.5E-05 4.8E-06

[1]

Fire results credit operator actions to secure power during control room abandonment for loss of control sequences.

12] Values are for recovery actions associated with control room abandonment due to environmental reasons.

A manual summation may differ from the Total due to rounding in the last digit.

BSEP LAR BSEP Rev 3 LAR Rev 3 Page 82 I Page 82 1

CP&L 5.0 Reciulatory 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 BSEP 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 Federal Register (FR) Notice 69 FR 33536 dated June 16, 2004, ML041340086).

"NFPA 805 does not supersede the requirementsof GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(o. Those regulatory requirementscontinue to apply to licensees that adopt NFPA 805. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements may be met is different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs importantto safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter I performance criteriathrough the methodology in Chapter4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii)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 criteria in Section 1.5.1 of NFPA 805. The Section 1.5.1 criteria include provisions for ensuring that reactivitycontrol, inventory and pressure control, decay heat removal, vital auxiliaries,and process monitoring are achieved and maintained.

This methodology specifies a process to identify the fire protection systems and features requiredto achieve the nuclearsafety performance criteria in Section 1.5 of NFPA 805. Once a determination has been made that a fire protection system or feature is required to achieve the performance criteria of Section 1.5, its design must meet any applicablerequirementsof NFPA 805, Chapter3.

Having identified the required fire protection systems and features, the licensee selects either a deterministicor performance-basedapproach to demonstrate that the performance criteria are satisfied. This process satisfies the GDC 3 requirement to design and locate SSCs important to safety to minimize the probabilityand effects of fires and explosions." (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086)

The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a), which requires each operating nuclear power plant to have a 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 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 BSEP LAR Rev 3 Page 83

CP&L 5.0 Regulatory Evaluation 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 BSEP fire protection program and applicable industry and BSEP documents that address the topic.

10 CFR 50.48(a)

Table 5-1 10 CFR 50.48(a) - ApplicabilitylCompliance Reference 10 CFR 50.48(a) Section(s) ApplicabilitylCompliance 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 RDC-NGGC-0001 superseded.

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CP&L 5.0 Regulatory Evaluation Table 5-1 10 CFR 50.48(a) - ApplicabilityRCompliance Reference 10 CFR 50.48(a) Section(s) Applicability/Complicance Reference (4) Each applicant for a design approval, design Not applicable. BSEP 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 BSEP LAR Rev 3 Fage 85

CP&L 5.0 Regulatory Evaluation 10 CFR 50.48(c)

Table 5-3 10 CFR 50.48(c) - ApplicabilitylCompliance Reference 10 CFR 50.48(c) Section(s) ApplicabilitylCompliance Reference (1) Approval of incorporationby reference. National Fire Protection Association General Information.

(NFPA) Standard 805, "Performance-Based Standard for Fire Protection for NFPA 805 (2001 edition) is Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805), the 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.

this section, references to NFPA 805 are to the 2001 Edition, with the NFPA 805 (2001 edition) is following exceptions, modifications, and supplementation: the edition used.

(i) Life Safety Goal, Objectives, and Criteria.The Life Safety Goal, The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed. Objectives, and Criteria of Chapter 1 of NFPA 805 are not part of the LAR.

(ii) Plant Damage/Business InterruptionGoal, 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 BSEP is a BWR. This is not performance criteria of Sections 1.5.1(b) and (c), a high-pressure applicable.

charging/injection pump coupled with the pressurizer power-operated relief 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-1.

(vi) Water supply and distribution. The italicized exception to Section 3.6.4 is BSEP complies as not endorsed. Licensees who wish to use the exception to Section 3.6.4 documented in Attachment A.

must submit a request for a license amendment in accordance with See NEI 04-02 Table B-1.

paragraph (c)(2)(vii) of this section.

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CP&L 5.0 Regulatory Evaluation Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s) ApplicabilitylCompliance 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 § 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 § 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 § 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).

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CP&L 5.0 Regulatory Evaluation 5.2 Regulatory Topics 5.2.1 License Condition Changes The current BSEP fire protection license condition 2.B.(6) 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 BSEP conducted a review of the Technical Specifications to determine which Technical Specifications are required to be revised, deleted, or superseded. BSEP determined that the changes to the Technical Specifications and applicable justification listed in Attachment N are adequate for the BSEP adoption of the new fire protection licensing basis.

5.2.3 Orders and Exemptions A review was conducted of the BSEP 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. BSEP has evaluated the proposed amendment and determined that it involves no significant hazards consideration.

5.3.2 Environmental Consideration Pursuant to 10 CFR 51.22(b), an evaluation of the LAR has been performed to determine whether it meets the criteria for categorical exclusion set forth in BSEP LAR Rev 3 Page 88

CP&L 5.0 Regulatory Evaluation 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 BSEP UFSAR will be revised. The content will be consistent with NEI 04-02.

5.5 Transition Implementation Schedule The following schedule for transitioning BSEP to the new fire protection licensing basis requires NRC approval of the LAR in accordance with the following schedule:

" Implementation of new NFPA 805 fire protection program to include procedure changes, process updates, and training to affected plant personnel. This will occur 180 days after NRC approval. If the turnover is due to fall within an outage window then the changes will be implemented 60 days after startup from the scheduled outage.

" Modifications will be completed by the startup of the second refueling outage for each unit after issuance of the Safety Evaluation (SE). Appropriate compensatory measures will be maintained until modifications are complete.

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CP&L 6.0 References

6.0 REFERENCES

The following references were used in the development of the TR. Additional references are in the Attachments.

NRC Documents

1. Letter, 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 (ML061660105).

2. NRC Enforcement Policy, Policy Statement: Revision, Federal Register, Vol. 69, No. 115, June 16, 2004, pp. 33684-33685.

3. NRC Generic Letter 86-10, Supplement 1, Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Trains Within the Same Fire Area, March 25, 1994.

4. NRC Regulatory Issue Summary 2007-19: Communicating Clarifications of Staff Positions in RG 1.205 Concerning Issues Identified During Pilot Application of NFPA Std 805, August 20, 2007 (ML071590227).

5. NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, April 2005.

6. Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 1 - November 2002.

7. Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 2 - March 2009).

8. Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, Revision 1, December 2009.

9. Voluntary Fire Protection Requirement for Light-Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative, Final Rule, Federal Register, Vol. 69, No. 115, June 16, 2004, pp. 33536-33551.

Other Industry Documents

1. ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S 2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, American Society of Mechanical Engineers/American Nuclear Society, New York, NY.

2. EPRI Fire Protection Equipment Surveillance Optimization and Maintenance Guide TR-1 006756, Final Report July 2003

3. NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1, January 2005.

I BSEP LAR Rev 3 Page 90 1

CP&L 6.0 References

4. NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 2, May 2009.

5. NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c), Revision 2 April 2008.

6. NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition.

Licensee Correspondence

1. Letter CP&L to NRC, Letter of Intent to Transition to 10 CFR 40.48(c),

June 10, 2005 (ML051720404)

2. Letter NRC to CP&L, Grants Enforcement Discretion Regarding NFPA Standard 805, April 29, 2007 (ML070590625).

3. Letter NRC to CP&L, Issuance of Amendment Regarding Adoption of NFPA Standard 805, Safety Evaluation for the Shearon Harris Nuclear Power Plant, June 28, 2012 (ML101130535)

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