L-2014-003, Response to Request for Additional Information Regarding License Amendment Request No. 216 - Transition to 10 CFR 50.48(c)- NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants..: Difference between revisions
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The additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2012-092. | January 7, 2014 10 CFR 50.90 L-2014-003 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Additional Information Regarding License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) | ||
By Florida Power and Light Company (FPL) letter L-2012-092 dated June 28, 2012, in accordance with the provisions of 10 CFR 50.90, "Application of License or Construction Permit," FPL requested an amendment to the Renewed Facility Operating License (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. The license Amendment Request (LAR) will enable FPL to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205. | |||
On November 7, 2013, the NRC Staff requested additional information regarding the LAR. The attachment to this letter provides the response to. the request for additional information. The additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2012-092. | |||
This letter adds a new implementation item to FPL letter L-2012-092 Attachment S, Table S-3, Implementation Items, regarding the Transient Combustible and Flammable Substance Program to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. This letter does not change any previous commitments. | This letter adds a new implementation item to FPL letter L-2012-092 Attachment S, Table S-3, Implementation Items, regarding the Transient Combustible and Flammable Substance Program to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. This letter does not change any previous commitments. | ||
If you should have any questions regarding this application, please contact Robert Tomonto, Licensing Manager, at 305-246-7327. | If you should have any questions regarding this application, please contact Robert Tomonto, Licensing Manager, at 305-246-7327. | ||
Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 L-2014-003 Page 2 I declare under penalty of perjury that the foregoing is true and correct.Executed on January 7, 2014.Michael Kiley Vice President Turkey Point Nuclear Generating Station Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Ms. Cindy Becker, Florida Department of Health L-2014-003, Attachment Page 1 of 92 L-2014-003 Attachment Response to Request for Additional Information Regarding License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) -NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition L-2014-003, Attachment Page 2 of 92 Fire Protection Engineering RAI 02.c.01 In the letter dated March 15, 2013 (ADAMS Accession No. ML13038A310), FPE RAI 02(c)requested the licensee to "identify what controls and requirements will be in place for flammable gas after transition and to provide the basis of those controls." The response in letter dated March 18, 2013 (ADAMS Accession No. ML13099A441), indicated that "flammable gases are programmatically controlled via station procedures." Provide a more detailed description of those controls and the basis for them.RESPONSE | Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035 | ||
Controls identified in this procedure include: " Locations for storage" When in storage, cylinders shall always be placed upright, with their caps in place, in approved storage areas away from sources of heat (i.e., radiators, furnaces)." When a cylinder is not in use, the valve shall be closed and hoses relieved of pressure." Cylinders shall be labeled as 'flammable', if applicable." When handling flammable gas cylinders, gas release to the atmosphere shall be avoided so that a means for combustion or an explosion will not be provided." Cylinders should never be subjected to temperatures above 125 'F." No smoking signs shall be posted in areas where any flammable cylinders are stored." In areas where cylinders are being handled, adequate and appropriate fire extinguishing capability shall be provided." Cylinders shall be secured so that they cannot be knocked over." Compressed flammable and oxygen gas cylinders should be left on a wheeled cart to expedite removal if necessary. | |||
L-2014-003 Page 2 I declare under penalty of perjury that the foregoing is true and correct. | |||
Executed on January 7, 2014. | |||
Michael Kiley Vice President Turkey Point Nuclear Generating Station Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Ms. Cindy Becker, Florida Department of Health | |||
L-2014-003, Attachment Page 1 of 92 L-2014-003 Attachment Response to Request for Additional Information Regarding License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition | |||
L-2014-003, Attachment Page 2 of 92 Fire Protection Engineering RAI 02.c.01 In the letter dated March 15, 2013 (ADAMS Accession No. ML13038A310), FPE RAI 02(c) requested the licensee to "identify what controls and requirements will be in place for flammable gas after transition and to provide the basis of those controls." The response in letter dated March 18, 2013 (ADAMS Accession No. ML13099A441), indicated that "flammable gases are programmatically controlled via station procedures." Provide a more detailed description of those controls and the basis for them. | |||
===RESPONSE=== | |||
Flammable gases are programmatically controlled by station procedure 0-ADM-0 16.1, Transient Combustible and Flammable Substances Program. This procedure outlines the control of and fire prevention practices for compressed flammable gas cylinders within the Transient Combustible Area Boundary. Controls identified in this procedure include: | |||
" Locations for storage | |||
" When in storage, cylinders shall always be placed upright, with their caps in place, in approved storage areas away from sources of heat (i.e., radiators, furnaces). | |||
" When a cylinder is not in use, the valve shall be closed and hoses relieved of pressure. | |||
" Cylinders shall be labeled as 'flammable', if applicable. | |||
" When handling flammable gas cylinders, gas release to the atmosphere shall be avoided so that a means for combustion or an explosion will not be provided. | |||
" Cylinders should never be subjected to temperatures above 125 'F. | |||
" No smoking signs shall be posted in areas where any flammable cylinders are stored. | |||
" In areas where cylinders are being handled, adequate and appropriate fire extinguishing capability shall be provided. | |||
" Cylinders shall be secured so that they cannot be knocked over. | |||
" Compressed flammable and oxygen gas cylinders should be left on a wheeled cart to expedite removal if necessary. | |||
The bases for these requirements come from the FP&L Safe Work Practices Manual, NFPA Fire Protection Handbook, NFPA 1, and OSH1A guidelines. | The bases for these requirements come from the FP&L Safe Work Practices Manual, NFPA Fire Protection Handbook, NFPA 1, and OSH1A guidelines. | ||
NFPA 805 requirements for bulk flammable gas storage and orientation of cylinders is included in 0-ADM-016, Fire Protection Program.PTN LAR Attachment A, NEI 04-02 Table B-1 Transition of Fundamental FP Program &Design Elements, Section 3.3.1.2(6) will be modified to add the following implementation item: Item for Implementation: | NFPA 805 requirements for bulk flammable gas storage and orientation of cylinders is included in 0-ADM-016, Fire Protection Program. | ||
Update the PTN Transient Combustible and Flammable Substances Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map.See Implementation Item in Table S-3 of Attachment S | PTN LAR Attachment A, NEI 04-02 Table B-1 Transition of Fundamental FP Program & | ||
L-2014-003, Attachment Page 3 of 92 Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements | Design Elements, Section 3.3.1.2(6) will be modified to add the following implementation item: | ||
/ Guidance Statement Compliance Basis 3.3.1.2 Control of Combustible 3.3.1.2 (5) | Item for Implementation: | ||
* Controls on use and storage of flammable and combustible Complies via Refer to the NFPA 30 Code Compliance Evaluation for specific Materials (5) liquids shall be in accordance with NFPA 30, Flammable and Combustible Engineering measures used for controlling combustible materials., Liquids Code, or other applicable NFPA standards. | Update the PTN Transient Combustible and Flammable Substances Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. | ||
Evaluation References Document ID 0-ADM-016 Rev. 5 -Fire Protection Program PTN-FPER-07-030 Rev. 1 -Code Compliance Evaluation, NFPA 30 -Flammable and Combustible Liquids Code Complies with Per FAQ 06-0020, the following guidance applies as to which Clarification NFPA standards referenced in Chapter 3 are applicable: | See Implementation Item in Table S-3 of Attachment S | ||
Arm, "applicable | |||
3sis (CLB) for Update the PTN Transient Combustible and Flammable Substances Program administrative procedure | L-2014-003, Attachment Page 3 of 92 Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis 3.3.1.2 Control of Combustible 3.3.1.2 (5) | ||
* Controls on use and storage of flammable gases all be in Complies with PTN is not committed to any flammable gas standards, and as Materials (6) accordance with applicable NFPA standards. | * Controls on use and storage of flammable and combustible Complies via Refer to the NFPA 30 Code Compliance Evaluation for specific Materials (5) liquids shall be in accordance with NFPA 30, Flammable and Combustible Engineering measures used for controlling combustible materials. | ||
Clarification such are not part of the current license basis. Per FAQ 06-0020, the following guidance applies as to which NFPA standards referenced in Chapter 3 are applicable: "Where used in NFPA 805, Chapter 3, the term, "applicable NFPA Standards" is considered to be equivalent to those NFPA standards identified in the current license basis (CLB) for procedures and systems in the Fire Protection Program that are transitioning to NFPA 805." Flammable gases are controlled per 0-ADM-016 and 0-ADM-016.1.References Document ID 0-ADM-016 Rev. 5 -Fire Protection Program 0-ADM-016.1 Rev. 1 -Transient Combustible and Flammable Substances Program 3.3.1.3 Control of Ignition 3.3.1.3 Control of Ignition Sources N/A Section Title Sources 3.3.1.3.1 | , Liquids Code, or other applicable NFPA standards. Evaluation References Document ID 0-ADM-016 Rev. 5 - Fire Protection Program PTN-FPER-07-030 Rev. 1 - Code Compliance Evaluation, NFPA 30 - Flammable and Combustible Liquids Code JAdd: | ||
[Control of Ignition 3.3.1.3.1" Complies via See code compliance evaluation for NFPA 51B.Sources Code Requirements] | Complies with Per FAQ 06-0020, the following guidance applies as to which Clarification NFPA standards referenced in Chapter 3 are applicable: | ||
A hot work safety procedure shall be developed, implemented, and Engineering periodically updated as necessary in accordance with NFPA 51B, Evaluation Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. | Arm, "applicable alent to those NFPA Item for Implementation: 3sis (CLB) for to include ion Update the PTN Transient Combustible and Flammable Substances Program administrative procedure Program that are all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. t dSee Implementation Item in Table S-3 of Attachment SI 0-ADM-016.1 Rev. 1 - Transient Combustible and Flamable Substances Program 3.3.1.2 Control of Combustible 3.3.1.2 (6) | ||
Fire Safety Analysis Data .Manager (4.1)Turkey Point Run: 06/26/2012 11:05 Page: 7 of 48 L-2014-003, Attachment Page 4 of 92 Security-Related Information -Withhold Under 10 CFR 2.390 Florida Power & Light Attachment S -Plant Modifications and Items to be Completed Table S-3 Implementation Items Item Unit Description LAR Section / Source 15 3, 4 Implement the results of the Radioactive Release Analysis 4.4.2 and Attachment E Update pre-fire plans to: o Clearly and consistently identify RCA boundaries (graphically or with text)o Add generic wording to prompt measure to mitigate a radioactive release o Develop new pre-fire plans as applicable for buildings within the RCA with contaminated equipment or areas o Add an appendix that identifies where run-off has the potential to route to a storm drain.Modify the fire brigade training program to include enhanced radioactive release objectives | * Controls on use and storage of flammable gases all be in Complies with PTN is not committed to any flammable gas standards, and as Materials (6) accordance with applicable NFPA standards. Clarification such are not part of the current license basis. Per FAQ 06-0020, the following guidance applies as to which NFPA standards referenced in Chapter 3 are applicable: "Where used in NFPA 805, Chapter 3, the term, "applicable NFPA Standards" is considered to be equivalent to those NFPA standards identified in the current license basis (CLB) for procedures and systems in the Fire Protection Program that are transitioning to NFPA 805." | ||
.Develop a standard operating procedure to support actions to mitigate a radioactive release.Develop administrative controls to support compliance with NFPA 805, Radioactive Release Criteria.Stage materials and equipment to assist in preventing potentially contaminated run-off from entering the storm drain system 16 3, 4 Update fire protection program documents and provide training as necessary. | Flammable gases are controlled per 0-ADM-016 and 0-ADM-016.1. | ||
4.7 This implementation item is to address general program documents not already addressed in items 1-15 and 17. This includes fire protection design basis document, post-transition change process (including Fire PRA updates), and qualification training.17 3, 4 Update plant procedures based upon determination of required fire protection 4.8 and Table C-2 systems and features.18 3, 4 Update the Fire PRA Model, as necessary, after all modifications are complete 4.8.2 and as-built.19 3, 4 Create response procedures for the incipient detection systems. Attachment S, Table S-2 Items 3, 4, 25, and 32.New Implementation Item: Unit 3, 4 Update the PTN Transient Combustible and Flammable Substance Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map.LAR Section: Section 4.1.2; Attachment A, 3.3.1.2(6) | References Document ID 0-ADM-016 Rev. 5 - Fire Protection Program 0-ADM-016.1 Rev. 1 - Transient Combustible and Flammable Substances Program 3.3.1.3 Control of Ignition 3.3.1.3 Control of Ignition Sources N/A Section Title Sources 3.3.1.3.1 [Control of Ignition 3.3.1.3.1" Complies via See code compliance evaluation for NFPA 51B. | ||
Revi Ba S-21 L-2014-003, Attachment Page 5 of 92 Fire Protection Engineering RAI 12 National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, Chapter 3, Section 3.5.13 identifies certain requirements for inside headers that are fed from both ends, which supply sprinkler and standpipe systems. In the entry in LAR Attachment A, Table B-I for this section, the licensee stated that this arrangement is not used.Provide a description of the arrangement, including any piping codes (for example, American National Standards Institute B3 1. 1) that apply. Also, include a description of how each sprinkler and standpipe system is equipped with an approved shutoff valve (for example, an outside screw and yoke gate valve).Justify any differences between the installed arrangement and the requirements of NFPA 805 Chapter 3, Section 3.5.13.RESPONSE | Sources Code Requirements] A hot work safety procedure shall be developed, implemented, and Engineering periodically updated as necessary in accordance with NFPA 51B, Evaluation Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. | ||
However, a review of PTN piping specifications determined that Fire Protection piping, Service Number 11, may be Class F, G, H, or SL. Class F, G, H, and SL are all ANSI B3 1.1 classified. | Fire Safety Analysis Data .Manager (4.1) Turkey Point Run: 06/26/2012 11:05 Page: 7 of 48 | ||
Each sprinkler system is equipped with an OS&Y or other approved shutoff valve.Each standpipe system is not provided with an individual isolation valve. Standpipes have either individual isolation capability or sections that can be isolated.New Table B-1 compliance discussion for Attachment A Section 3.5.13 Compliance Statement: | |||
Complies Compliance Basis: While PTN does not have seismically analyzed hose standpipe systems (See Section 3.6.4) and the ANSI B3 1.1 requirement for piping and fittings for headers inside buildings is not applicable, fire protection piping is specified to be ANSI B3 1.1.Each sprinkler system is equipped with an OS&Y or listed control valve. The control valves are located on the supply side to provide system isolation/shutoff. | L-2014-003, Attachment Page 4 of 92 Security-Related Information -Withhold Under 10 CFR 2.390 Florida Power & Light Attachment S - Plant Modifications and Items to be Completed Table S-3 Implementation Items Item Unit Description LAR Section / Source 15 3, 4 Implement the results of the Radioactive Release Analysis 4.4.2 and Attachment E Update pre-fire plans to: | ||
o Clearly and consistently identify RCA boundaries (graphically or with text) o Add generic wording to prompt measure to mitigate a radioactive release o Develop new pre-fire plans as applicable for buildings within the RCA with contaminated equipment or areas o Add an appendix that identifies where run-off has the potential to route to a storm drain | |||
. Modify the fire brigade training program to include enhanced radioactive release objectives | |||
. Develop a standard operating procedure to support actions to mitigate a radioactive release | |||
. Develop administrative controls to support compliance with NFPA 805, Radioactive Release Criteria | |||
. Stage materials and equipment to assist in preventing potentially contaminated run-off from entering the storm drain system 16 3, 4 Update fire protection program documents and provide training as necessary. 4.7 This implementation item is to address general program documents not already addressed in items 1-15 and 17. This includes fire protection design basis document, post-transition change process (including Fire PRA updates), and qualification training. | |||
17 3, 4 Update plant procedures based upon determination of required fire protection 4.8 and Table C-2 systems and features. | |||
18 3, 4 Update the Fire PRA Model, as necessary, after all modifications are complete 4.8.2 and as-built. | |||
19 3, 4 Create response procedures for the incipient detection systems. Attachment S, Table S-2 Items 3, 4, 25, and 32. | |||
New Implementation Item: | |||
Unit 3, 4 Update the PTN Transient Combustible and Flammable Substance Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. | |||
LAR Section: Section 4.1.2; Attachment A, 3.3.1.2(6) | |||
Revi Ba S-21 | |||
L-2014-003, Attachment Page 5 of 92 Fire Protection Engineering RAI 12 National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, Chapter 3, Section 3.5.13 identifies certain requirements for inside headers that are fed from both ends, which supply sprinkler and standpipe systems. In the entry in LAR Attachment A, Table B-I for this section, the licensee stated that this arrangement is not used. | |||
Provide a description of the arrangement, including any piping codes (for example, American National Standards Institute B3 1.1) that apply. Also, include a description of how each sprinkler and standpipe system is equipped with an approved shutoff valve (for example, an outside screw and yoke gate valve). | |||
Justify any differences between the installed arrangement and the requirements of NFPA 805 Chapter 3, Section 3.5.13. | |||
===RESPONSE=== | |||
NFPA 805 Section 3.5.13 states "Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B3 1.1, Code for Power Piping, are used for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve." | |||
PTN does not have seismically analyzed hose standpipe systems per Section 3.6.4 of NFPA 805 (See LAR Attachment A, Table B- 1). Therefore, the ANSI B3 1.1 requirements for headers inside buildings are not applicable. However, a review of PTN piping specifications determined that Fire Protection piping, Service Number 11, may be Class F, G, H, or SL. Class F, G, H, and SL are all ANSI B3 1.1 classified. | |||
Each sprinkler system is equipped with an OS&Y or other approved shutoff valve. | |||
Each standpipe system is not provided with an individual isolation valve. Standpipes have either individual isolation capability or sections that can be isolated. | |||
New Table B-1 compliance discussion for Attachment A Section 3.5.13 Compliance Statement: | |||
Complies Compliance Basis: | |||
While PTN does not have seismically analyzed hose standpipe systems (See Section 3.6.4) and the ANSI B3 1.1 requirement for piping and fittings for headers inside buildings is not applicable, fire protection piping is specified to be ANSI B3 1.1. | |||
Each sprinkler system is equipped with an OS&Y or listed control valve. The control valves are located on the supply side to provide system isolation/shutoff. | |||
==References:== | ==References:== | ||
PTN-FPER-07-013A, Attachment 3, Section 3-14.2 PTN-FPER-07-013C, Attachment 3, Section 3-14.2 PTN-FPER-07-013D, Attachment 3, Section 4-14.1 PTN-FPER-07-015A, Attachment 3, Section 4070 PTN-FPER-07-015B, Attachment 3, Section 4-7 L-2014-003, Attachment Page 6 of 92 Specification MN-3. 10, Piping Class Summary Specification MN-3. 11, Piping Class Sheets Compliance Statement: | PTN-FPER-07-013A, Attachment 3, Section 3-14.2 PTN-FPER-07-013C, Attachment 3, Section 3-14.2 PTN-FPER-07-013D, Attachment 3, Section 4-14.1 PTN-FPER-07-015A, Attachment 3, Section 4070 PTN-FPER-07-015B, Attachment 3, Section 4-7 | ||
Complies via Engineering Evaluation Compliance Basis: The PTN standpipe system, per the code compliance report, is not provided witlf individual shutoff valves independent of standpipe systems. Standpipes have either individual isolation capability or sections that can be isolated. | |||
Compensatory actions are prescribed for removing or impairing hose stations. | L-2014-003, Attachment Page 6 of 92 Specification MN-3. 10, Piping Class Summary Specification MN-3. 11, Piping Class Sheets Compliance Statement: | ||
Common cause failure of the water supply piping where primary fire suppression (sprinkler systems) and backup fire suppression (manual hose station standpipes) supplies are shared is addressed in Section 3.5.11. | Complies via Engineering Evaluation Compliance Basis: | ||
The PTN standpipe system, per the code compliance report, is not provided witlf individual shutoff valves independent of standpipe systems. Standpipes have either individual isolation capability or sections that can be isolated. Compensatory actions are prescribed for removing or impairing hose stations. Common cause failure of the water supply piping where primary fire suppression (sprinkler systems) and backup fire suppression (manual hose station standpipes) supplies are shared is addressed in Section 3.5.11. | |||
==References:== | ==References:== | ||
PTN-FPER-07-014, Attachment 3, Section 622 PTN-FPER- 11-004 CR 2006-29106 (AR 00434496) Item 62 Drawing 5610-M-3016 Sheet 5 Drawing 5610-M-3016 Sheet 6 | |||
L-2014-003, Attachment Page 7 of 92 Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis References Document ID PTN-FPER-1 1-004 Rev. 0 - Backup Suppression on Common Water Supply Systems 3.5.12 [Water Supply 3.5.12 Complies Compatible Thread Threads compatible with those used by local fire departments shall be Connections] provided on all hydrants, hose couplings, and standpipe risers. | |||
Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate training and procedures are provided. | |||
References Document ID O-ADM-016 Rev. 5 [Sections 5.3.1.3, 5.3.3.4.] - Fire Protection Program 3.5.13 [Water Supply Header 3.5.13 N/A The plant does not use this arrAngement Options] Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, Code for Power Piping | |||
B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration | B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration | ||
.of thermoset cable inter-cable shorts is deferred pending additional research.) | . of thermoset cable inter-cable shorts is deferred pending additional research.) | ||
C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently. | C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently. The spurious actuations should be evaluated as previously described. The | ||
The spurious actuations should be evaluated as previously described. | |||
L-2014-003, Attachment Page 81 of 92 consideration of more than two cables being damaged (and subsequent spurious actuations) is deferred pending additional research. | |||
Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits. | D. For cases involving direct current (DC) circuits, the potential spurious operation due to failures of the associated control cables (even if the spurious operation requires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus and minus-to-minus) should be considered when the required source and target conductors are each located within the same multiconductor cable. | ||
There is one case where an instrument circuit could potentially be considered an associated circuit. If fire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly. | E. Instrumentation Circuits. Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits. There is one case where an instrument circuit could potentially be considered an associated circuit. If fire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly. | ||
Alignment Basis from PTN NFPA 805 LAR: Cable selection considered any and all hot shorts, regardless of whether these hot shorts were inter-cable or intra-cable. | Alignment Basis from PTN NFPA 805 LAR: Cable selection considered any and all hot shorts, regardless of whether these hot shorts were inter-cable or intra-cable. No restriction was placed on the number of cables or hot shorts required to fail the component/circuit. No credit was taken for relative risk due to conductor combinations available for a fault. All cables were conservatively assumed to be Thermo-plastic. | ||
No restriction was placed on the number of cables or hot shorts required to fail the component/circuit. | Cables were not excluded because of being instrumentation cables or because they were part of a DC circuit requiring multiple hot shorts of proper polarity. | ||
No credit was taken for relative risk due to conductor combinations available for a fault. All cables were conservatively assumed to be Thermo-plastic. | Additional Details: The PTN methodology was deemed to align with the intent of the guidance in NEI 00-01 Revision I rather than aligning with the explicit guidance because the PTN methodology took a conservative approach on the guidance provided in B (potential for inter-cable shorting based on cable material) and C (number of concurrently damaged cables which must be assumed) rather than strictly following the guidance as written. | ||
Cables were not excluded because of being instrumentation cables or because they were part of a DC circuit requiring multiple hot shorts of proper polarity.Additional Details: The PTN methodology was deemed to align with the intent of the guidance in NEI 00-01 Revision I rather than aligning with the explicit guidance because the PTN methodology took a conservative approach on the guidance provided in B (potential for inter-cable shorting based on cable material) and C (number of concurrently damaged cables which must be assumed) rather than strictly following the guidance as written.For the guidance provided in B, inter-cable shorting was considered possible even if the only cables in the fire area were thermoset cables. For the guidance provided in C, the number of inter-cable hot shorts which could occur in an area would not be limited. The inclusion of these potential failure modes can only make the results at PTN more conservative and thereby provides a greater assurance of the ability of the plant to safely shutdown.j) 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination NEI 00-01 Guidance: | For the guidance provided in B, inter-cable shorting was considered possible even if the only cables in the fire area were thermoset cables. For the guidance provided in C, the number of inter-cable hot shorts which could occur in an area would not be limited. The inclusion of these potential failure modes can only make the results at PTN more conservative and thereby provides a greater assurance of the ability of the plant to safely shutdown. | ||
Note that slight differences exist between the guidance as written in this section for NEI 00-01 Revision 1 and NEI 00-01 Revision 2. The differences in the guidance found in the two documents are shown in bold and underlined below.NEI 00-01 Revision 1 Guidance: | j) 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination NEI 00-01 Guidance: Note that slight differences exist between the guidance as written in this section for NEI 00-01 Revision 1 and NEI 00-01 Revision 2. The differences in the guidance found in the two documents are shown in bold and underlined below. | ||
The evaluation of associated circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown. | NEI 00-01 Revision 1 Guidance: The evaluation of associated circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown. The concern is that, for fire damage to a single power cable, lack of coordination between the | ||
The concern is that, for fire damage to a single power cable, lack of coordination between the L-2014-003, Attachment Page 82 of 92 supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment. | |||
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the associated circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus.Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows: Identify the power sources required to supply power to safe shutdown equipment. | L-2014-003, Attachment Page 82 of 92 supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment. | ||
For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.For each power source, demonstrate proper circuit coordination using acceptable industry methods.For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. | For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump. | ||
Evaluate the potential for disabling power to the bus in each of the fire areas in which the associated circuit cables of concern are routed and the power source is required for safe shutdown. | To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the associated circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus. | ||
Prepare a list of the following information for each fire area: " Cables of concern." Affected common power source and its path." Raceway in which the cable is enclosed." Sequence of the raceway in the cable route.1 | A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus. | ||
Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level. | |||
L-2014-003, Attachment Page 83 of 92 Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source.Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.NEI 00-01 Revision 2 Guidance: | The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows: | ||
The evaluation of circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for hot shutdown. | Identify the power sources required to supply power to safe shutdown equipment. | ||
The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment. | For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus. | ||
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus.Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.The methodology for identifying potential circuits of a common power source and evaluating circuit coordination cases on a single circuit fault basis is as follows: " Identify the power sources required to supply power to safe shutdown equipment." For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus." For each power source, demonstrate proper circuit coordination using acceptable industry methods. For example, for breakers that have internal breaker tripping devices and do not require control power to trip the breaker, assure that the time-current characteristic curve for any affected load breaker is to the left of the time-current characteristic curve for the bus feeder breaker and that the available short circuit current for each affected breaker is to the right of the time-current characteristic curve for the bus feeder breaker or that. the bus feeder breaker.has a longer time delay in the breaker instantaneous range than the load breaker. For breakers requiring control power for the breaker to trip, the availability of the required control power must be demonstrated in addition to the proper alignment of the time-L-2014-003, Attachment Page 84 of 92 current characteristic curves described above. The requirement for the availability of control power would apply to load breakers fed from each safe shutdown bus where a fire-induced circuit failure brings into questions the availability of coordination for a required for hot shutdown component. | For each power source, demonstrate proper circuit coordination using acceptable industry methods. | ||
For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. | For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the associated circuit cables of concern are routed and the power source is required for safe shutdown. Prepare a list of the following information for each fire area: | ||
Evaluate the potential for disabling power to the bus in each of the fire areas in which the circuit of concern are routed and the power source is required for hot shutdown. | " Cables of concern. | ||
Prepare a list of the following infornation for each fire area: o Cables of concern." Affected common power source and its path.o Raceway in which the cable is enclosed.o Sequence of the raceway in the cable route.o Fire zone/area in which the raceway is located.For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods." Develop analyzed safe shutdown circuit dispositions for the circuit of concern cables routed in an area of the same path as required by the power source.Evaluate adequate separation and other mitigation measures based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumes coordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPL submittal) that because coordination of circuit protective devices was part of the original electrical system design, associated circuits by common power supply should not exist.However, this review was for the plant's alternate shutdown capability, and all power supplies being credited in the re-validation may not have been evaluated. | " Affected common power source and its path. | ||
ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2 Items 19 and 20): Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and 4DP87 (only NSCA power supplies without demonstrated coordination) | " Raceway in which the cable is enclosed. | ||
This task will be performed by FPL.Additional Details: The only reason this section was determined to only "Align with Intent" as opposed to "Align" with the guidance in NEI 00-01 was because it had been identified during the review of circuit coordination at the plant for all SSD related buses /panels that coordination had not been analyzed for three of the panels (DP412A, 4DP86, and 4DP87, see item for implementation above). The NSCA had assumed coordination of these panels based on this-item for implementation. | " Sequence of the raceway in the cable route. | ||
Until these panels have their coordination demonstrated (which had not occurred by the time of the NFPA 805 LAR submittal), it was felt that it could not be said that PTN aligned with the guidance.However, because this item for implementation is listed as a committed modification for L-2014-003, Attachment Page 85 of 92 the NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt that the plant does align with the intent of the guidance.Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had their coordination demonstrated by FPL calculation PTN-4FJE-12-002. | 1 Fire zone/area in which the raceway is. located. | ||
The design change package for DP412A is currently in progress and necessary modification will be implemented for transition to the performance-based fire protection licensing basis.These details are also applicable to questions g) and j).Safe Shutdown RAI 18 LAR Attachment F identifies the steps used to perform the multiple spurious operations (MSO)evaluation. | * For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods. | ||
Provide the following additional details of the evaluation performed: | |||
a) Currently the LAR identifies "representatives from PTN [PTN is the licensee's acronym for Turkey Point] fire protection and post-fire safe shutdown, PTN Operations/PRA | L-2014-003, Attachment Page 83 of 92 Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source. | ||
[probabilistic risk assessment], and supporting contract staff' as having participated in the MSO expert panel review. Describe in more detail the composition of the expert panel, including qualifications, background, and experience. | Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases. | ||
NEI 00-01 Revision 2 Guidance: The evaluation of circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for hot shutdown. The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment. | |||
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump. | |||
To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus. | |||
A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus. | |||
Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level. | |||
The methodology for identifying potential circuits of a common power source and evaluating circuit coordination cases on a single circuit fault basis is as follows: | |||
" Identify the power sources required to supply power to safe shutdown equipment. | |||
" For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus. | |||
" For each power source, demonstrate proper circuit coordination using acceptable industry methods. For example, for breakers that have internal breaker tripping devices and do not require control power to trip the breaker, assure that the time-current characteristic curve for any affected load breaker is to the left of the time-current characteristic curve for the bus feeder breaker and that the available short circuit current for each affected breaker is to the right of the time-current characteristic curve for the bus feeder breaker or that.the bus feeder breaker.has a longer time delay in the breaker instantaneous range than the load breaker. For breakers requiring control power for the breaker to trip, the availability of the required control power must be demonstrated in addition to the proper alignment of the time- | |||
L-2014-003, Attachment Page 84 of 92 current characteristic curves described above. The requirement for the availability of control power would apply to load breakers fed from each safe shutdown bus where a fire-induced circuit failure brings into questions the availability of coordination for a required for hot shutdown component. | |||
For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the circuit of concern are routed and the power source is required for hot shutdown. Prepare a list of the following infornation for each fire area: | |||
o Cables of concern. | |||
" Affected common power source and its path. | |||
o Raceway in which the cable is enclosed. | |||
o Sequence of the raceway in the cable route. | |||
o Fire zone/area in which the raceway is located. | |||
For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods. | |||
" Develop analyzed safe shutdown circuit dispositions for the circuit of concern cables routed in an area of the same path as required by the power source. | |||
Evaluate adequate separation and other mitigation measures based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases. | |||
Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumes coordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPL submittal) that because coordination of circuit protective devices was part of the original electrical system design, associated circuits by common power supply should not exist. | |||
However, this review was for the plant's alternate shutdown capability, and all power supplies being credited in the re-validation may not have been evaluated. | |||
ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2 Items 19 and 20): | |||
Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and 4DP87 (only NSCA power supplies without demonstrated coordination) | |||
This task will be performed by FPL. | |||
Additional Details: The only reason this section was determined to only "Align with Intent" as opposed to "Align" with the guidance in NEI 00-01 was because it had been identified during the review of circuit coordination at the plant for all SSD related buses / | |||
panels that coordination had not been analyzed for three of the panels (DP412A, 4DP86, and 4DP87, see item for implementation above). The NSCA had assumed coordination of these panels based on this-item for implementation. Until these panels have their coordination demonstrated (which had not occurred by the time of the NFPA 805 LAR submittal), it was felt that it could not be said that PTN aligned with the guidance. | |||
However, because this item for implementation is listed as a committed modification for | |||
L-2014-003, Attachment Page 85 of 92 the NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt that the plant does align with the intent of the guidance. | |||
Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had their coordination demonstrated by FPL calculation PTN-4FJE-12-002. The design change package for DP412A is currently in progress and necessary modification will be implemented for transition to the performance-based fire protection licensing basis. | |||
These details are also applicable to questions g) and j). | |||
Safe Shutdown RAI 18 LAR Attachment F identifies the steps used to perform the multiple spurious operations (MSO) evaluation. Provide the following additional details of the evaluation performed: | |||
a) Currently the LAR identifies "representatives from PTN [PTN is the licensee's acronym for Turkey Point] fire protection and post-fire safe shutdown, PTN Operations/PRA [probabilistic risk assessment], and supporting contract staff' as having participated in the MSO expert panel review. Describe in more detail the composition of the expert panel, including qualifications, background, and experience. | |||
b) Describe the criteria used in the decision process for resolution(s). | b) Describe the criteria used in the decision process for resolution(s). | ||
c) Currently the LAR indicates that "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations." Provide more detail regarding the manner in which they occur (e.g., sequentially or simultaneously), and the time between spurious actuations (as supported by engineering analysis, test results, or both).d) Provide typical MSO justifications or rationale for MSOs being eliminated from further evaluation. | c) Currently the LAR indicates that "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations." | ||
Include a description of the configuration control mechanisms that ensures these exclusion bases will remain valid.RESPONSE | Provide more detail regarding the manner in which they occur (e.g., sequentially or simultaneously), and the time between spurious actuations (as supported by engineering analysis, test results, or both). | ||
As discussed in the report, the expert panel individuals included specific experience in (by individual): " Turkey Point Systems/Operations/Internal Events PRA" FPL Turkey Point Design Engineering, Fire Protection" Safe Shutdown, Turkey Point Safe Shutdown Analysis, Circuit Analysis Turkey. Point Fire PRA,. System. Engineering | d) Provide typical MSO justifications or rationale for MSOs being eliminated from further evaluation. Include a description of the configuration control mechanisms that ensures these exclusion bases will remain valid. | ||
......* Safe Shutdown, Circuit Analysis, NFPA 805 MSO Process* Fire PRA, System Engineering, NFPA 805 MSO Process L-2014-003, Attachment Page 86 of 92" Turkey Point Safe Shutdown, Circuit Analysis" Turkey Point Fire PRA, Safe Shutdown All members of the panel, with the exception of one, have over 20 years of nuclear power plant experience. | |||
The panel includes individuals with degrees in Mathematics, Nuclear Engineering, Electrical Engineering, and Civil Engineering. | ===RESPONSE=== | ||
The panel also included individuals that had participated in the development of the MSO resolution process for the industry, as well as participants in MSO expert panels for other plants.b) As discussed in Attachment F of the PTN LAR, consensus was achieved in the expert panel process by discussing individual scenarios, reaching a conclusion, and asking for any dissenting opinions. | a). The qualifications, background, and experience of the MSO expert panel members are judged to be sufficient and consistent with the guidance of Frequently Asked Question 07-0038. The report entitled "Expert Panel for Addressing Multiple Spurious Operations" includes a listing of panel participants, their specific areas of expertise and experience, and resumes/experience summaries. As discussed in the report, the expert panel individuals included specific experience in (by individual): | ||
In addition, as discussed in report entitled "Expert Panel for Addressing Multiple Spurious Operations", project action items were created when the panel members were unsure or if additional research was needed.c) The statement "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations." referred to in the RAI question was a discussion of the training conducted for the MSO Expert Panel. The intent of this discussion point was to not exclude scenarios during the expert panel meeting at the start because of likelihood only.This guidance was followed to ensure that a broad list of scenarios was identified for further refinement, as necessary, by the nuclear safety capability assessment (NSCA) and Fire PRA. No restrictions were placed on the MSO Expert Panel regarding the sequential or simultaneous nature of circuit failures or the time between spurious actuations. | " Turkey Point Systems/Operations/Internal Events PRA | ||
d) Different MSO justifications and/or rationale for MSOs being eliminated from further evaluation were utilized. | " FPL Turkey Point Design Engineering, Fire Protection | ||
Individual scenarios from the PWROG generic list and plant specific scenarios were reviewed by the expert panel. Example dispositions include: " Scenario was not applicable to PTN (e.g., Spurious operation of hot leg high point vent valves, which are not installed at PTN)." Scenario precluded by plant design/configuration: | " Safe Shutdown, Turkey Point Safe Shutdown Analysis, Circuit Analysis Turkey. Point Fire PRA,. System. Engineering ...... | ||
o Pump runout scenarios where the PTN-specific pump was a positive displacement pump and not subject to runout conditions o Normally closed manual valve downstream of valves in question, prevent flow diversion. | * Safe Shutdown, Circuit Analysis, NFPA 805 MSO Process | ||
o Motor operated valves at PTN were used for piggy-back operation. | * Fire PRA, System Engineering, NFPA 805 MSO Process | ||
MOVs are maintained closed (and breakers are de-energized and locked) for non-high low pressure interface/high consequence components. | |||
The post-transition change evaluation process, as described in Section 4.7.2, Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805, of the PTN LAR, will be utilized to maintain the configurations that support MSO exclusions. | L-2014-003, Attachment Page 86 of 92 | ||
The responses to Programmatic RAI 4 and Programmatic RAI 5 also address configuration control and the post-transition change evaluation. | " Turkey Point Safe Shutdown, Circuit Analysis | ||
This process will include the review of plant changes for impact on meeting the nuclear safety'perforrrmance criteria, and would include the consideration of plant configuration or operational changes that could adversely impact the nuclear safety capability assessment or Fire PRA. | " Turkey Point Fire PRA, Safe Shutdown All members of the panel, with the exception of one, have over 20 years of nuclear power plant experience. The panel includes individuals with degrees in Mathematics, Nuclear Engineering, Electrical Engineering, and Civil Engineering. The panel also included individuals that had participated in the development of the MSO resolution process for the industry, as well as participants in MSO expert panels for other plants. | ||
L-2014-003, Attachment Page 87 of 92 Safe Shutdown RAI 19 LAR Attachment C for each fire area identifies performance goals, method of accomplishment, and applicable variance from deterministic requirements. | b) As discussed in Attachment F of the PTN LAR, consensus was achieved in the expert panel process by discussing individual scenarios, reaching a conclusion, and asking for any dissenting opinions. In addition, as discussed in report entitled "Expert Panel for Addressing Multiple Spurious Operations", project action items were created when the panel members were unsure or if additional research was needed. | ||
The decay heat performance goal is the only goal that is identified as hot standby and cold shutdown. | c) The statement "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations." referred to in the RAI question was a discussion of the training conducted for the MSO Expert Panel. The intent of this discussion point was to not exclude scenarios during the expert panel meeting at the start because of likelihood only. | ||
Provide a description of why cold shutdown is provided for this performance goal. Describe if any other performance goals include cold shutdown in the performance evaluation. | This guidance was followed to ensure that a broad list of scenarios was identified for further refinement, as necessary, by the nuclear safety capability assessment (NSCA) and Fire PRA. No restrictions were placed on the MSO Expert Panel regarding the sequential or simultaneous nature of circuit failures or the time between spurious actuations. | ||
RESPONSE | d) Different MSO justifications and/or rationale for MSOs being eliminated from further evaluation were utilized. Individual scenarios from the PWROG generic list and plant specific scenarios were reviewed by the expert panel. Example dispositions include: | ||
One of these methods is most often associated with providing decay heat removal when the plant is in a hot shutdown (HSD) state and the other when the plant is in a CSD state.During normal, at-power operations and immediately following a fire, Reactor Coolant System (RCS) pressure and temperature exceed the upper limits of the operating temperature and pressure of the Residual Heat Removal (RHR) system (350'F and 450 psig; design temperature and pressure is 400'F and 600 psig per 5610-050-DB-001). | " Scenario was not applicable to PTN (e.g., Spurious operation of hot leg high point vent valves, which are not installed at PTN). | ||
As such, the RHR system cannot be used until the plant has been cooled down and depressurized to below these limits. This cooldown (CD) and depressurization requires a different system which is capable of removing decay heat generated by the reactor and sensible heat stored in the RCS until the RHR system can be placed on service.The systems which may be used for CD and depressurization until plant conditions permit entry onto the RHR system are the Auxiliary Feedwater (AFW) System or the Feedwater System using the Standby Steam Generator Feed Pump (SSGFP). The AFW system receives its water supply from the Condensate Storage Tanks (CSTs) and the SSGFP receives its water from the Demineralized Water Storage Tank (DWST). The ability to make-up to any of these tanks indefinitely from on-site or off-site sources has not been demonstrated to exist following a fire 1.As such, in accordance with the definition of safe and stable provided in Section 4.2.1.2 of the PTN NFPA 805 LAR: "The final end state for safe and stable will be determined by the extent of equipment damage, existing inventory in the condensate storage tank, and the ability to provide makeup to the condensate storage tank. If any of these conditions indicate it is advisable Note that the CSTs and DWST are capable of being refilled from the Raw Water Tanks (RWTs) via the Fire Protection system to temporarily extend AFW / SSGFP operations if required. | " Scenario precluded by plant design/configuration: | ||
The CSTs and DWST have adequate inventories for many hours of decay heat removal and CD of the reactor. Because of the effect that raw water could have on steam generator chemistry, the use of the RWTs would only be done if an unforeseen circumstance significantly delayed the ability to transfer decay heat removal operations tothe RHRIsystem. | o Pump runout scenarios where the PTN-specific pump was a positive displacement pump and not subject to runout conditions o Normally closed manual valve downstream of valves in question, prevent flow diversion. | ||
By the'time plant conditionswould necessitate the use of the.RWTs; those same symptoms would have led operators to begin cooling down the plant in preparation for going onto RHR. Thus the capability to use the RWTs is addressed in the Decay Heat Removal (CSD) performance goal. | o Motor operated valves at PTN were used for piggy-back operation. MOVs are maintained closed (and breakers are de-energized and locked) for non-high low pressure interface/high consequence components. | ||
L-2014-003, Attachment Page 88 of 92 to place RHR system in service then the plant will have the capability to do so. As a result, the equipment required to initiate and maintain hot shutdown cooling including the initiation of RHR cooling remains part of the at-power analysis. | The post-transition change evaluation process, as described in Section 4.7.2, Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805, of the PTN LAR, will be utilized to maintain the configurations that support MSO exclusions. The responses to Programmatic RAI 4 and Programmatic RAI 5 also address configuration control and the post-transition change evaluation. This process will include the review of plant changes for impact on meeting the nuclear safety'perforrrmance criteria, and would include the consideration of plant configuration or operational changes that could adversely impact the nuclear safety capability assessment or Fire PRA. | ||
Initiation of RHR cooling does not imply however, that the plant would proceed all the way to CSD. The plant may remain on RHR cooling at other than CSD conditions for an extended period* of time." Neither the AFW nor the Feedwater system uses any components, material, or supporting systems (except for instrument air -if available | |||
-and low voltage power) that are in common with the RHR system. Because of this complete independence between the two approaches to decay heat removal and because both approaches may be required to satisfy the requirements for the Decay Heat Removal Performance Goal from NFPA 805 Section 1.5.1 (c), it is appropriate to provide separate performance goals in Attachment C of the PTN NFPA 805 LAR to address the approach used in each plant state. Though the operators may use all of the systems mentioned above while the plant is in a HSD state per the Technical Specifications (Tech Specs), the distinction of the systems identified in the performance goals as HSD or CSD was done based on: 1. The plant states with which the systems are most commonly associated when in operation 2. Not requiring time critical manual actions to ensure the ability to safely shutdown the plant.In response to the "describe if any other performance goals include CSD in the performance evaluation" part of this RAI: All performance goals at PTN are inherently part of both HSD and CSD operations. | L-2014-003, Attachment Page 87 of 92 Safe Shutdown RAI 19 LAR Attachment C for each fire area identifies performance goals, method of accomplishment, and applicable variance from deterministic requirements. The decay heat performance goal is the only goal that is identified as hot standby and cold shutdown. Provide a description of why cold shutdown is provided for this performance goal. Describe if any other performance goals include cold shutdown in the performance evaluation. | ||
Even the Decay Heat Removal Performance Goals discussed above are not distinctly limited to HSD and CSD plant conditions. | |||
Tech Specs Table 1.2 indicates that the plant is in a HSD condition if Keff<0.99 and 350 0 F>Tavg>200'F; which is entirely within the operating limits of the RHR system.The SSGFP can also continue to remove decay heat with the plant in a CSD condition (Keff<0.99, Tavge<200°F per Tech Specs). In fact, for the period during which decay heat removal transitions from one approach to another, there must be an overlap.As illustrated in 5610-M-722A (Nuclear Safety Capability Fire Shutdown Analysis Basis Document), Attachment A (see figure 1 below), all systems / safety functions which are required to be available to support HSD operations are also required to support CSD operations. | ===RESPONSE=== | ||
There are three additional safety functions which were determined to be required only prior to plant CD in preparation for CSD / RHR operations. | In response to the "provide a description of why CSD is provided for this performance goal" part of this RAI: | ||
Those safety functions are Decay Heat Removal (CSD), RCS Pressure Control, and Reactivity Control (CD/CSD).Decay Heat Removal (CSD) requires the availability of the RHR and Fire Protection systems as discussed above. The RCS Pressure Control Performance Goal requires the availability of the Power Operated Relief Valves (PORVs) and the Pressurizer Backup Heaters to ensure that plant pressure is acceptable for the given plant temperature and conditions. | A cold shutdown (CSD) evaluation of the Decay Heat Removal Performance Goal is provided because there are two distinct methods analyzed by PTN to remove decay heat post-fire. One of these methods is most often associated with providing decay heat removal when the plant is in a hot shutdown (HSD) state and the other when the plant is in a CSD state. | ||
This function tends to be of greater importance during times when plant temperatures are being changed, such as when cooling down in preparation to use the RHR system. The Reactivity Control (CD/CSD) Safety Function'- | During normal, at-power operations and immediately following a fire, Reactor Coolant System (RCS) pressure and temperature exceed the upper limits of the operating temperature and pressure of the Residual Heat Removal (RHR) system (350'F and 450 psig; design temperature and pressure is 400'F and 600 psig per 5610-050-DB-001). As such, the RHR system cannot be used until the plant has been cooled down and depressurized to below these limits. This cooldown (CD) and depressurization requires a different system which is capable of removing decay heat generated by the reactor and sensible heat stored in the RCS until the RHR system can be placed on service. | ||
is shown in Attachment C of the PTN NFPA 805 LAR as ipart of the Reactivity Control Performance Goal along with the Reactivity Control (Trip) Safety Function. | The systems which may be used for CD and depressurization until plant conditions permit entry onto the RHR system are the Auxiliary Feedwater (AFW) System or the Feedwater System using the Standby Steam Generator Feed Pump (SSGFP). The AFW system receives its water supply from the Condensate Storage Tanks (CSTs) and the SSGFP receives its water from the Demineralized Water Storage Tank (DWST). The ability to make-up to any of these tanks indefinitely from on-site or off-site sources has not been demonstrated to exist following a fire 1 . | ||
The Reactivity Control (CD/CSD) Safety Function consists of the systems and components necessary to ensure L-2014-003, Attachment Page 89 of 92 adequate RCS boration is established. | As such, in accordance with the definition of safe and stable provided in Section 4.2.1.2 of the PTN NFPA 805 LAR: | ||
This safety function is only necessary to offset positive reactivity inserted from xenon decay (which is only significant after many hours of being shut down) or from cooling down the RCS. Though the operator may use all of the systems mentioned above while the plant is in a HSD state per the Tech Specs, the distinction of the systems identified in the performance goals as HSD or CSD was done based on the plant states which most closely related to when the systems would be required and to readily distinguish safety functions which would not require time critical manual actions to ensure the ability to safely shutdown the plant. | "The final end state for safe and stable will be determined by the extent of equipment damage, existing inventory in the condensate storage tank, and the ability to provide makeup to the condensate storage tank. If any of these conditions indicate it is advisable Note that the CSTs and DWST are capable of being refilled from the Raw Water Tanks (RWTs) via the Fire Protection system to temporarily extend AFW / SSGFP operations if required. The CSTs and DWST have adequate inventories for many hours of decay heat removal and CD of the reactor. Because of the effect that raw water could have on steam generator chemistry, the use of the RWTs would only be done if an unforeseen circumstance significantly delayed the ability to transfer decay heat removal operations tothe RHRIsystem. By the'time plant conditionswould necessitate the use of the.RWTs; those same symptoms would have led operators to begin cooling down the plant in preparation for going onto RHR. Thus the capability to use the RWTs is addressed in the Decay Heat Removal (CSD) performance goal. | ||
L-2014-003. | |||
Atachment Page 90 of 92 | L-2014-003, Attachment Page 88 of 92 to place RHR system in service then the plant will have the capability to do so. As a result, the equipment required to initiate and maintain hot shutdown cooling including the initiation of RHR cooling remains part of the at-power analysis. Initiation of RHR cooling does not imply however, that the plant would proceed all the way to CSD. The plant may remain on RHR cooling at other than CSD conditions for an extended period | ||
L-2014-003, Attachment Page 91 of 92 Fire Modeling RAT 01.01 In a letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), the licensee responded to Fire Modeling RAIs 01 .j and 01 .k, which make reference to "additional work." For this reason, a final review of these RAI responses could not be completed." FM RAI 01 .j pertains to the use of the Generic Fire Modeling Treatments (GFMTs) to determine the zone of influence (ZOI) for fires that involve intervening combustibles." FM RAI 01 .k requests that the licensee describe how fire propagation in cable trays and the corresponding heat release rate (HRR) are calculated, and explain how the fire propagation and HRR estimates affect the ZOI determination and hot gas layer calculations. | *of time." | ||
The NRC staff noted that the "additional work" will also affect the evaluation of the responses to FM RAI 0 1 .p (wall and comer effects), FM RAI 04 (application of GFMTs outside limitations of use), and several PRA RAIs.Provide the results of this "additional work" to the NRC staff for review and describe any changes to the conclusions regarding core damage frequency (CDF), delta (A) CDF, large early release frequency (LERF), and ALERF resulted from the "additional work." RESPONSE | Neither the AFW nor the Feedwater system uses any components, material, or supporting systems (except for instrument air - if available - and low voltage power) that are in common with the RHR system. Because of this complete independence between the two approaches to decay heat removal and because both approaches may be required to satisfy the requirements for the Decay Heat Removal Performance Goal from NFPA 805 Section 1.5.1 (c), it is appropriate to provide separate performance goals in Attachment C of the PTN NFPA 805 LAR to address the approach used in each plant state. Though the operators may use all of the systems mentioned above while the plant is in a HSD state per the Technical Specifications (Tech Specs), the distinction of the systems identified in the performance goals as HSD or CSD was done based on: | ||
Transient Fuel Package Ignition Source Characteristics," Rev. 0. This document provides Zone of Influence (ZOI) tables and their limitations for transient ignition sources in open, wall, and comer configurations." Report 0027-0067-002-002, "Combined Ignition Source -Cable Tray Fire Scenario ZOIs for Turkey Point Nuclear Power Plant Applications," Rev. 1. This document provides ZOI tables for specific ignition source -secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0. The heat release rates are computed using guidance provided in NUREG/CR-6850 and NUREG/CR-7010, Volume 1. The ZOIs are computed using the methods described in Report | : 1. The plant states with which the systems are most commonly associated when in operation | ||
Secondary Combustible Configurations," Rev.0. This document provides an assessment of the secondary combustible configurations for ignition sources at PTN." Report 0027-0067-002-004, "Evaluation of the Development and Timing of Hot Gas Layer Conditions in Generic PTN Fire Compartments with Secondary Combustibles," Rev. 1. This document provides Hot Gas Layer (HGL) tables for specific ignition source-secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0.The HGL tables are evaluated in generic enclosures using the methods described in Report | : 2. Not requiring time critical manual actions to ensure the ability to safely shutdown the plant. | ||
Fire Modeling RAI 02.01 In letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), in response to FM RAI 02.e, the licensee referred to Fire PRA Frequently Asked Question (FAQ) 13-0004 to justify the use of cable damage thresholds as the criteria for sensitive electronics inside an enclosure. | In response to the "describe if any other performance goals include CSD in the performance evaluation" part of this RAI: | ||
Fire PRA FAQ 13-0004 was still under development at the time the response was submitted, and the licensee therefore stated, "Resolution of this issue will be re-assessed once the FAQ is finalized." Provide the results of the re-assessment. | All performance goals at PTN are inherently part of both HSD and CSD operations. Even the Decay Heat Removal Performance Goals discussed above are not distinctly limited to HSD and CSD plant conditions. Tech Specs Table 1.2 indicates that the plant is in a HSD condition if Keff | ||
Quantify the impact of any changes to the guidelines in the final version of Fire PRA FAQ 13-0004 on CDF, LERF, ACDF, and ALERF; or justify why these changes need not be considered. | <0.99 and 350 0 F>Tavg>200'F; which is entirely within the operating limits of the RHR system. | ||
RESPONSE | The SSGFP can also continue to remove decay heat with the plant in a CSD condition (Keff | ||
Based on the use of thermoplastic damage criteria for panels and internal components and the lack of exposed sensitive electronics, the application of the FAQ 13-0004 methodology does not result in an increase in CDF, LERF, ACDF, and ALERF.}} | <0.99, Tavge<200°F per Tech Specs). In fact, for the period during which decay heat removal transitions from one approach to another, there must be an overlap. | ||
As illustrated in 5610-M-722A (Nuclear Safety Capability Fire Shutdown Analysis Basis Document), Attachment A (see figure 1 below), all systems / safety functions which are required to be available to support HSD operations are also required to support CSD operations. There are three additional safety functions which were determined to be required only prior to plant CD in preparation for CSD / RHR operations. Those safety functions are Decay Heat Removal (CSD), RCS Pressure Control, and Reactivity Control (CD/CSD). | |||
Decay Heat Removal (CSD) requires the availability of the RHR and Fire Protection systems as discussed above. The RCS Pressure Control Performance Goal requires the availability of the Power Operated Relief Valves (PORVs) and the Pressurizer Backup Heaters to ensure that plant pressure is acceptable for the given plant temperature and conditions. This function tends to be of greater importance during times when plant temperatures are being changed, such as when cooling down in preparation to use the RHR system. The Reactivity Control (CD/CSD) Safety Function'- is shown in Attachment C of the PTN NFPA 805 LAR as ipart of the Reactivity Control Performance Goal along with the Reactivity Control (Trip) Safety Function. The Reactivity Control (CD/CSD) Safety Function consists of the systems and components necessary to ensure | |||
L-2014-003, Attachment Page 89 of 92 adequate RCS boration is established. This safety function is only necessary to offset positive reactivity inserted from xenon decay (which is only significant after many hours of being shut down) or from cooling down the RCS. Though the operator may use all of the systems mentioned above while the plant is in a HSD state per the Tech Specs, the distinction of the systems identified in the performance goals as HSD or CSD was done based on the plant states which most closely related to when the systems would be required and to readily distinguish safety functions which would not require time critical manual actions to ensure the ability to safely shutdown the plant. | |||
L-2014-003. Atachment Page 90 of 92 ILPPLNDIDR | |||
.WCLZAR SAFETY CAPAI'fLITY LOGIC DIAGRAMI | |||
- LOGIC NO Re | |||
* ~-SS502 Figure 1 - PTN System Logic Diagram from 5610-M-722A Attachment A (Note: Figure is available in the portal for review) | |||
L-2014-003, Attachment Page 91 of 92 Fire Modeling RAT 01.01 In a letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), the licensee responded to Fire Modeling RAIs 01 .j and 01 .k, which make reference to "additional work." For this reason, a final review of these RAI responses could not be completed. | |||
" FM RAI 01 .j pertains to the use of the Generic Fire Modeling Treatments (GFMTs) to determine the zone of influence (ZOI) for fires that involve intervening combustibles. | |||
" FM RAI 01 .k requests that the licensee describe how fire propagation in cable trays and the corresponding heat release rate (HRR) are calculated, and explain how the fire propagation and HRR estimates affect the ZOI determination and hot gas layer calculations. | |||
The NRC staff noted that the "additional work" will also affect the evaluation of the responses to FM RAI 0 1 .p (wall and comer effects), FM RAI 04 (application of GFMTs outside limitations of use), and several PRA RAIs. | |||
Provide the results of this "additional work" to the NRC staff for review and describe any changes to the conclusions regarding core damage frequency (CDF), delta (A) CDF, large early release frequency (LERF), and ALERF resulted from the "additional work." | |||
===RESPONSE=== | |||
The additional work associated with the first round Fire Modeling (FM) RAI responses, including FM RAI 01 .j and FM RAI 01 .k, is provided in the following documents: | |||
" Report 0027-0067-002-001, "Supplemental Generic Fire Modeling Treatments: Transient Fuel Package Ignition Source Characteristics," Rev. 0. This document provides Zone of Influence (ZOI) tables and their limitations for transient ignition sources in open, wall, and comer configurations. | |||
" Report 0027-0067-002-002, "Combined Ignition Source - Cable Tray Fire Scenario ZOIs for Turkey Point Nuclear Power Plant Applications," Rev. 1. This document provides ZOI tables for specific ignition source - secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0. The heat release rates are computed using guidance provided in NUREG/CR-6850 and NUREG/CR-7010, Volume 1. The ZOIs are computed using the methods described in Report 1SPH02902.030, Rev. 0 (Generic Fire Modeling Treatments). | |||
" Report 0027-0067-002-003, "Walkdowns: Secondary Combustible Configurations," Rev. | |||
: 0. This document provides an assessment of the secondary combustible configurations for ignition sources at PTN. | |||
" Report 0027-0067-002-004, "Evaluation of the Development and Timing of Hot Gas Layer Conditions in Generic PTN Fire Compartments with Secondary Combustibles," | |||
Rev. 1. This document provides Hot Gas Layer (HGL) tables for specific ignition source | |||
- secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0. | |||
The HGL tables are evaluated in generic enclosures using the methods described in Report 1SPH02902.030, Rev. 0 (Generic Fire Modeling Treatments) and is based on a compilation of 29,970 new CFAST simulations. | |||
" Report 0027-0067-002-005, "Evaluation of Control Room Abandonment Times at the Turkey Point Nuclear Power Plant," Rev. 0. This document is the updated control room abandonment report. | |||
These reports have been placed on the portal and are available for review. The fire PRA has incorporated the new information from these reports and will provide the final core damage | |||
L-2014-003, Attachment Page 92 of 92 frequency (CDF), ACDF, large early release frequency (LERF), and ALERF with the response to PRA-RAI-29. | |||
Fire Modeling RAI 02.01 In letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), in response to FM RAI 02.e, the licensee referred to Fire PRA Frequently Asked Question (FAQ) 13-0004 to justify the use of cable damage thresholds as the criteria for sensitive electronics inside an enclosure. Fire PRA FAQ 13-0004 was still under development at the time the response was submitted, and the licensee therefore stated, "Resolution of this issue will be re-assessed once the FAQ is finalized." | |||
Provide the results of the re-assessment. Quantify the impact of any changes to the guidelines in the final version of Fire PRA FAQ 13-0004 on CDF, LERF, ACDF, and ALERF; or justify why these changes need not be considered. | |||
===RESPONSE=== | |||
In accordance with the guidance provided in Fire PRA FAQ 13-0004, sensitive electronics within a panel enclosure are expected to survive an external fire based on the use of thermoset cable damage criteria as a basis for panel and internal component damage. The use of thermoplastic cable damage criteria for the Turkey Point Fire PRA provides additional margin with respect to that defined in the FAQ. A walkdown was performed to identify exposed sensitive electronics susceptible to fire damage. This walkdown was performed using the criteria in the final version of Fire PRA FAQ 13-0004. The walkdown produced no instances of exposed sensitive electronics. Based on the use of thermoplastic damage criteria for panels and internal components and the lack of exposed sensitive electronics, the application of the FAQ 13-0004 methodology does not result in an increase in CDF, LERF, ACDF, and ALERF.}} | |||
Revision as of 10:01, 4 November 2019
| ML14030A114 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/07/2014 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-2014-003 | |
| Download: ML14030A114 (94) | |
Text
0FPL.
January 7, 2014 10 CFR 50.90 L-2014-003 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Nuclear Generating Station Units 3 and 4 Docket Nos. 50-250 and 50-251 Response to Request for Additional Information Regarding License Amendment Request No. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)
By Florida Power and Light Company (FPL) letter L-2012-092 dated June 28, 2012, in accordance with the provisions of 10 CFR 50.90, "Application of License or Construction Permit," FPL requested an amendment to the Renewed Facility Operating License (RFOL) for Turkey Point Nuclear Generating Station Units 3 and 4. The license Amendment Request (LAR) will enable FPL to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205.
On November 7, 2013, the NRC Staff requested additional information regarding the LAR. The attachment to this letter provides the response to. the request for additional information. The additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in FPL letter L-2012-092.
This letter adds a new implementation item to FPL letter L-2012-092 Attachment S, Table S-3, Implementation Items, regarding the Transient Combustible and Flammable Substance Program to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. This letter does not change any previous commitments.
If you should have any questions regarding this application, please contact Robert Tomonto, Licensing Manager, at 305-246-7327.
Florida Power & Light Company 9760 SW 344 St Homestead, FL 33035
L-2014-003 Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 7, 2014.
Michael Kiley Vice President Turkey Point Nuclear Generating Station Attachment cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point USNRC Project Manager for Turkey Point Ms. Cindy Becker, Florida Department of Health
L-2014-003, Attachment Page 1 of 92 L-2014-003 Attachment Response to Request for Additional Information Regarding License Amendment Request No. 216 Florida Power and Light Company Turkey Point Nuclear Generating Station Units 3 and 4 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition
L-2014-003, Attachment Page 2 of 92 Fire Protection Engineering RAI 02.c.01 In the letter dated March 15, 2013 (ADAMS Accession No. ML13038A310), FPE RAI 02(c) requested the licensee to "identify what controls and requirements will be in place for flammable gas after transition and to provide the basis of those controls." The response in letter dated March 18, 2013 (ADAMS Accession No. ML13099A441), indicated that "flammable gases are programmatically controlled via station procedures." Provide a more detailed description of those controls and the basis for them.
RESPONSE
Flammable gases are programmatically controlled by station procedure 0-ADM-0 16.1, Transient Combustible and Flammable Substances Program. This procedure outlines the control of and fire prevention practices for compressed flammable gas cylinders within the Transient Combustible Area Boundary. Controls identified in this procedure include:
" Locations for storage
" When in storage, cylinders shall always be placed upright, with their caps in place, in approved storage areas away from sources of heat (i.e., radiators, furnaces).
" When a cylinder is not in use, the valve shall be closed and hoses relieved of pressure.
" Cylinders shall be labeled as 'flammable', if applicable.
" When handling flammable gas cylinders, gas release to the atmosphere shall be avoided so that a means for combustion or an explosion will not be provided.
" Cylinders should never be subjected to temperatures above 125 'F.
" No smoking signs shall be posted in areas where any flammable cylinders are stored.
" In areas where cylinders are being handled, adequate and appropriate fire extinguishing capability shall be provided.
" Cylinders shall be secured so that they cannot be knocked over.
" Compressed flammable and oxygen gas cylinders should be left on a wheeled cart to expedite removal if necessary.
The bases for these requirements come from the FP&L Safe Work Practices Manual, NFPA Fire Protection Handbook, NFPA 1, and OSH1A guidelines.
NFPA 805 requirements for bulk flammable gas storage and orientation of cylinders is included in 0-ADM-016, Fire Protection Program.
PTN LAR Attachment A, NEI 04-02 Table B-1 Transition of Fundamental FP Program &
Design Elements, Section 3.3.1.2(6) will be modified to add the following implementation item:
Item for Implementation:
Update the PTN Transient Combustible and Flammable Substances Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map.
See Implementation Item in Table S-3 of Attachment S
L-2014-003, Attachment Page 3 of 92 Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis 3.3.1.2 Control of Combustible 3.3.1.2 (5)
- Controls on use and storage of flammable and combustible Complies via Refer to the NFPA 30 Code Compliance Evaluation for specific Materials (5) liquids shall be in accordance with NFPA 30, Flammable and Combustible Engineering measures used for controlling combustible materials.
, Liquids Code, or other applicable NFPA standards. Evaluation References Document ID 0-ADM-016 Rev. 5 - Fire Protection Program PTN-FPER-07-030 Rev. 1 - Code Compliance Evaluation, NFPA 30 - Flammable and Combustible Liquids Code JAdd:
Complies with Per FAQ 06-0020, the following guidance applies as to which Clarification NFPA standards referenced in Chapter 3 are applicable:
Arm, "applicable alent to those NFPA Item for Implementation: 3sis (CLB) for to include ion Update the PTN Transient Combustible and Flammable Substances Program administrative procedure Program that are all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map. t dSee Implementation Item in Table S-3 of Attachment SI 0-ADM-016.1 Rev. 1 - Transient Combustible and Flamable Substances Program 3.3.1.2 Control of Combustible 3.3.1.2 (6)
- Controls on use and storage of flammable gases all be in Complies with PTN is not committed to any flammable gas standards, and as Materials (6) accordance with applicable NFPA standards. Clarification such are not part of the current license basis. Per FAQ 06-0020, the following guidance applies as to which NFPA standards referenced in Chapter 3 are applicable: "Where used in NFPA 805, Chapter 3, the term, "applicable NFPA Standards" is considered to be equivalent to those NFPA standards identified in the current license basis (CLB) for procedures and systems in the Fire Protection Program that are transitioning to NFPA 805."
Flammable gases are controlled per 0-ADM-016 and 0-ADM-016.1.
References Document ID 0-ADM-016 Rev. 5 - Fire Protection Program 0-ADM-016.1 Rev. 1 - Transient Combustible and Flammable Substances Program 3.3.1.3 Control of Ignition 3.3.1.3 Control of Ignition Sources N/A Section Title Sources 3.3.1.3.1 [Control of Ignition 3.3.1.3.1" Complies via See code compliance evaluation for NFPA 51B.
Sources Code Requirements] A hot work safety procedure shall be developed, implemented, and Engineering periodically updated as necessary in accordance with NFPA 51B, Evaluation Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.
Fire Safety Analysis Data .Manager (4.1) Turkey Point Run: 06/26/2012 11:05 Page: 7 of 48
L-2014-003, Attachment Page 4 of 92 Security-Related Information -Withhold Under 10 CFR 2.390 Florida Power & Light Attachment S - Plant Modifications and Items to be Completed Table S-3 Implementation Items Item Unit Description LAR Section / Source 15 3, 4 Implement the results of the Radioactive Release Analysis 4.4.2 and Attachment E Update pre-fire plans to:
o Clearly and consistently identify RCA boundaries (graphically or with text) o Add generic wording to prompt measure to mitigate a radioactive release o Develop new pre-fire plans as applicable for buildings within the RCA with contaminated equipment or areas o Add an appendix that identifies where run-off has the potential to route to a storm drain
. Modify the fire brigade training program to include enhanced radioactive release objectives
. Develop a standard operating procedure to support actions to mitigate a radioactive release
. Develop administrative controls to support compliance with NFPA 805, Radioactive Release Criteria
. Stage materials and equipment to assist in preventing potentially contaminated run-off from entering the storm drain system 16 3, 4 Update fire protection program documents and provide training as necessary. 4.7 This implementation item is to address general program documents not already addressed in items 1-15 and 17. This includes fire protection design basis document, post-transition change process (including Fire PRA updates), and qualification training.
17 3, 4 Update plant procedures based upon determination of required fire protection 4.8 and Table C-2 systems and features.
18 3, 4 Update the Fire PRA Model, as necessary, after all modifications are complete 4.8.2 and as-built.
19 3, 4 Create response procedures for the incipient detection systems. Attachment S, Table S-2 Items 3, 4, 25, and 32.
New Implementation Item:
Unit 3, 4 Update the PTN Transient Combustible and Flammable Substance Program administrative procedure to include all NFPA 805 Power Block structures/areas in the Transient Combustible Area Boundary Map.
LAR Section: Section 4.1.2; Attachment A, 3.3.1.2(6)
Revi Ba S-21
L-2014-003, Attachment Page 5 of 92 Fire Protection Engineering RAI 12 National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, Chapter 3, Section 3.5.13 identifies certain requirements for inside headers that are fed from both ends, which supply sprinkler and standpipe systems. In the entry in LAR Attachment A, Table B-I for this section, the licensee stated that this arrangement is not used.
Provide a description of the arrangement, including any piping codes (for example, American National Standards Institute B3 1.1) that apply. Also, include a description of how each sprinkler and standpipe system is equipped with an approved shutoff valve (for example, an outside screw and yoke gate valve).
Justify any differences between the installed arrangement and the requirements of NFPA 805 Chapter 3, Section 3.5.13.
RESPONSE
NFPA 805 Section 3.5.13 states "Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B3 1.1, Code for Power Piping, are used for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve."
PTN does not have seismically analyzed hose standpipe systems per Section 3.6.4 of NFPA 805 (See LAR Attachment A, Table B- 1). Therefore, the ANSI B3 1.1 requirements for headers inside buildings are not applicable. However, a review of PTN piping specifications determined that Fire Protection piping, Service Number 11, may be Class F, G, H, or SL. Class F, G, H, and SL are all ANSI B3 1.1 classified.
Each sprinkler system is equipped with an OS&Y or other approved shutoff valve.
Each standpipe system is not provided with an individual isolation valve. Standpipes have either individual isolation capability or sections that can be isolated.
New Table B-1 compliance discussion for Attachment A Section 3.5.13 Compliance Statement:
Complies Compliance Basis:
While PTN does not have seismically analyzed hose standpipe systems (See Section 3.6.4) and the ANSI B3 1.1 requirement for piping and fittings for headers inside buildings is not applicable, fire protection piping is specified to be ANSI B3 1.1.
Each sprinkler system is equipped with an OS&Y or listed control valve. The control valves are located on the supply side to provide system isolation/shutoff.
References:
PTN-FPER-07-013A, Attachment 3, Section 3-14.2 PTN-FPER-07-013C, Attachment 3, Section 3-14.2 PTN-FPER-07-013D, Attachment 3, Section 4-14.1 PTN-FPER-07-015A, Attachment 3, Section 4070 PTN-FPER-07-015B, Attachment 3, Section 4-7
L-2014-003, Attachment Page 6 of 92 Specification MN-3. 10, Piping Class Summary Specification MN-3. 11, Piping Class Sheets Compliance Statement:
Complies via Engineering Evaluation Compliance Basis:
The PTN standpipe system, per the code compliance report, is not provided witlf individual shutoff valves independent of standpipe systems. Standpipes have either individual isolation capability or sections that can be isolated. Compensatory actions are prescribed for removing or impairing hose stations. Common cause failure of the water supply piping where primary fire suppression (sprinkler systems) and backup fire suppression (manual hose station standpipes) supplies are shared is addressed in Section 3.5.11.
References:
PTN-FPER-07-014, Attachment 3, Section 622 PTN-FPER- 11-004 CR 2006-29106 (AR 00434496) Item 62 Drawing 5610-M-3016 Sheet 5 Drawing 5610-M-3016 Sheet 6
L-2014-003, Attachment Page 7 of 92 Attachment A NEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis References Document ID PTN-FPER-1 1-004 Rev. 0 - Backup Suppression on Common Water Supply Systems 3.5.12 [Water Supply 3.5.12 Complies Compatible Thread Threads compatible with those used by local fire departments shall be Connections] provided on all hydrants, hose couplings, and standpipe risers.
Exception: Fire departments shall be permitted to be provided with adapters that allow interconnection between plant equipment and the fire department equipment if adequate training and procedures are provided.
References Document ID O-ADM-016 Rev. 5 [Sections 5.3.1.3, 5.3.3.4.] - Fire Protection Program 3.5.13 [Water Supply Header 3.5.13 N/A The plant does not use this arrAngement Options] Headers fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, Code for Power Piping, are used Replace strikethroughs with the two for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose Compliance Statements, and associated standpipe system. Where provided, such headers shall be considered an Compliance Basis and References provided in extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or the RAI response.
other approved shutoff valve.
3.5.14 [Water Supply Control 3.5.14* Complies PTN uses a combination of (a), (b), and (c).
Valve Supervision] All fire protection water supply and fire suppression system control valves shall be under a periodic inspection program and shall be supervised by one of the following methods.
(a) Electrical supervision with audible and visual signals in the main control room or other suitable constantly attended location.
(b) Locking valves in their normal position. Keys shall be made available only to authorized personnel.
(c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner/operator.
References Document ID 0-OP-016.1 Rev. 2 [Section 1.2, Attachment 1] - Fire Protection Water System 5610-M-3016 series - Fire Protection System drawings Fire Safety Analysis Data ,Manager (4.1) Turkey Point Run: 06/26/2012 11:05 Page: 31 of 48
L-2014-003, Attachment Page 8 of 92 Fire Protection Engineering RAT 13 The entry in LAR Attachment A, Table B-i for NFPA 805, Section 3.3.5.3 relies on previous approval for electric cable construction using fire retardant coatings approved by the authority having jurisdiction. However, this does not qualify non-rated cable to exclude the likelihood of self-ignition. Explain what assumptions were made with regard to cabling, specifically with regard to self-ignition. Provide the technical bases and justifications for these assumptions.
RESPONSE
All cables at Turkey Point Units 3 & 4 were treated as potentially causing a self-ignited cable fire. There was no credit taken for fire retardant coatings eliminating the potential for self-ignited cable fires.
L-2014-003, Attachment Page 9 of 92 Fire Protection Engineering RAT 14 LAR Attachment C, Table C-2, "NFPA 805 Required Fire Protection Systems and Features,"
does not appear to identify Fire Probabilistic Risk Assessment (FPRA) multi-compartment analysis (MCA) credited automatic suppression systems in fire zones 074 (Fire Area AA) and 075 (Fire Area BB). Additionally, the MCA credits suppression systems in fires zones 053 (Fire Area 13BB) and 129 (Fire Area AAA) where these systems do not exist. Provide a justification for this apparent discrepancy. If corrections to the table are required, provide a review to ensure all suppression and detection systems credited or required by the FPRA, or by NFPA 805, Chapters 3 or 4, have been fully documented in Table C-2. Also, provide the corrected Table C-2.
RESPONSE
The current revision of the Fire PRA MCA report is Revision 3. Revision 2 was developed for the LAR submittal and Revision 3 was developed in response to PTN RAI PRA 01.o. This response is based on the credited fire protection systems identified in Revision 3.
Fire Zones 074 and 075 were inadvertently not identified in LAR Attachment C, Table C-2.
PTN concurs that Fire Zones 053 and 129 do not have fixed suppression systems and Revision 3 of the MCA report identifies this appropriately, with no automatic suppression system failure probability shown for these zones.
A revised Table C-2 is attached to this RAI response based on the research which identified omissions. In addition to the MCA report, the FRE report and Fire PRA Scenario report were reviewed to validate the NFPA 805 Chapter 4 required suppression and detection systems are identified. The methodology presented in PTN LAR Section 4.8.1 identifies the purpose of Table C-2 is to document the detection and/or suppression required based on NFPA 805 Chapter 4 compliance. Detection and/or suppression required for NFPA 805 Chapter 3 will be identified during the implementation period as part of development of the Monitoring Program. NFPA 805 Chapter 3 required fire protection features are not documented in Table C-2.
The revised Table C-2 includes the following updates, as well as updates that were previously provided in response to RAI FPE 08 in Attachment 3 to FPL letter L-2013-086 dated March 18, 2013 (ML13099A441). The revisions as part of RAI FPE 14 are indicated by systems designated with an "A", as described in the attached markup of LAR Section 4.8.1.
Automatic suppression is credited in the MCA report for the following Fire Zones:
045, 055, 072, 073, 074, 075, 098, 108A, 108B, 132, 133, 136, and 141 Automatic detection is credited in the MCA report for the following Fire Zones:
004, 005, 009, 010, 011, 012, 013, 014, 015, 016, 020, 021, 022, 025, 025A, 026, 030, 040, 045,046, 055, 058, 059, 061,062, 063,067, 068, 070, 071,072, 073,074, 075, 093, 094, 095,096, 097, 098, 101,102, 103, 104, 106, 108A, 108B, 109, 110, 132, 133, 134, 135, 136, 139, 140, and 141
L-2014-003, Attachment Page 10 of 92 Florida Power & Light 4.0 Compliance with NFPA 805 Requirements 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 information is provided on a fire zone basis. The basis for the requirement of the fire protection system /
feature is designated as follows:
o S - Separation Criteria: Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3, o 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),
o0 - Defense-in-Depth Criteria: Systems/Features required to maintain ade .te balanc Insert new bullet: . ..
(Section .. ),o A - MCA: Systems/Features required to meet the o N - Non-Power assumptions in the Multi-Compartment Analysis, nuclear safety performance criteria ot NI-A 805 as identified by Me NHU analysis During the implementation phase, the PTN procedures and processes will be updated to reflect the NFPA 805 required fire protection systems and features. See Implementation Item 16 in Table S-3 of Attachment S 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.
The Fire PRA model represents the as-built, as-operated and maintained plant as it will be configured at the completion of the transition to NFPA 805. In addition, the Fire PRA model includes the extended power uprate (EPU) changes that are currently being implemented. The Fire PRA model includes credit for modifications completed as result of the NFPA 805 transition effort as identified in Table S-1 of Attachment S and the planned implementation of the modifications identified in Table S-2 of Attachment S.
Following installation of modifications and the as-built installation details, additional refinements surrounding the. modification may need to be incorporated into the Fire PRA model. However, these changes are not expected to be significant. See Implementation Item 18 in Table S-3 of Attachment S. No other significant plant changes are outstanding with respect to their inclusion in the Fire PRA model.
Revision 0 Page 53
L-201 4-003, Attachment Page 1 I of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: A (Unit 3) - Unit 3 and 4 Auxiliary Building Basement Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 004 Unit 3 and 4 Hallway South of None E, R, D, A E Combustible Loading: E Holdup Tanks - Fire Area A Detection System, Alarm Point 8: E R D A 005 Uhits 3 and 4 Chemical Drain, None E, R, D, A None Detection System, Alarm Point 8: E R D A Laundry and Hot Shower Tank Room - Fire Area A 006 Units 3 and 4 Gas Compressor None None None None Room - Fire Area A 007 Units 3 and 4 Gas Compressor None None None None Room - Fire Area A 008 Units 3 and 4 Waste Holdup Tank None None None None Room - Fire Area A 009 Units 3 and 4 Waste Evaporator None E, R, D, A None Detection System, Alarm Point 8: E R D A Feed Pump Room - Fire Area A 010 Units 3 and 4 Radioactive None E, R, D, A None Detection System, Alarm Point 8: E R D A Pipeway - Fire Area A 017 Units 3 and 4 Spent Resin None None None None Storage Tank Room - Fire Area A 018 Units 3 and 4 Area Beneath None None None None Waste Evaporator Skid - Fire Area A Fire Area ID: A (Unit 4) - Unit 3 and 4 Auxiliary Building Basement Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description Syste mII QyStllln Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 004 Unit 3 and 4 Hallway South of None E, R, D, A E Combustible Loading: E Holdup Tanks - Fire Area A Detection System, Alarm Point 8: E R D A 005 Units 3 and 4 Chemical Drain, None E, R, D, A None Detection System, Alarm Point 8: E R D A Laundry and Hot Shower Tank Room - Fire Area A 006 Units 3 and 4 Gas Compressor None None None None Room - Fire Area A 007 Units 3 and 4 Gas Compressor None None None None Room - Fire Area A 008 Units 3 and 4 Waste Holdup Tank None None None None Room - Fire Area A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 1 of 58
L-2014-003, Attachment Page 12 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: A (Unit 4) - Unit 3 and 4 Auxiliary Building Basement Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 009 Units 3 and 4 Waste Evaporator None E, R, D, A None Detection System, Alarm Point 8: E R D A Feed Pump Room - Fire Area A 010 Units 3 and 4 Radioactive None E, R, D, A None Detection System, Alarm Point 8: E R D A Pipeway - Fire Area A 017 Units 3 and 4 Spent Resin None None None None Storage Tank Room - Fire Area A 018 Units 3 and 4 Area Beneath None None None None Waste Evaporator Skid - Fire Area A Fire Area ID: AA (Unit 3) - Unit 3 Train B Emergency Diesel Generator Day Tank Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 074 Unit 3 Train B Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Day Tank Room - Fire Water Suppression, 3-10-844: A Area AA Fire Area ID: AA (Unit 4) - Unit 3 Train B Emergency Diesel Generator Day Tank Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 074 Unit 3 Train B Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Day Tank Room - Fire Water Suppression, 3-10-844: A Area AA Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 2 of 58
L-2014-003, Attachment Page 13 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: AAA (Unit 3) - Unit 3 and 4 Miscellaneous Zones Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID DDescription System System Protection Feature Required Fire Prote ction Feature and System Details (All) A*rea Wide None None R Procedures/Recovery Actions: R 001 fnits 3 and 4 Holdup Tank A - None None E Combustible Loading :E F ire Area AAA 002 UJnits 3 and 4 Holdup Tank B - None None E Combustible Loading :E F ire Area AAA 003 UJnits 3 and 4 Holdup Tank C - None None E Combustible Loading :E Fire Area AAA 021 UJnits 3 and 4 Counting Room - None A None Detection System, Alarm Point 39: A Fire Area AAA 022 UJnits 3 and 4 Hot Lab - Fire Area None A None Detection System, Al arm Point 39: A 023 I knits 3 and 4 Gas Decay Tank - None None None None Fire Area AAA 024 UJnits 3 and 4 Gas Decay Tank None None E Combustible Loading :E FRoom - Fire Area AAA 029 UJnit 4 Spent Fuel Pit - Fire Area None None E Combustible Loading :E kAA 042 UJnit 3 Spent Fuel Pit - Fire Area None None E Combustible Loading :E AA 043 UJnit 4 Spent Fuel Pit Heat None None None None EExchanger Room - Fire Area AAA 044 LJ.nit 4 New Fuel Storage Room - None None None None Ftire Area AAA 046 UJnits 3 and 4 Laundry Room - None A None Detection System, Alarm Point 7: A Fire Area AAA 056 UJnit 3 New Fuel Storage Room - None None None None F:ire Area AAA 057 UJnit 3 Spent Fuel Pit Heat None None None None EExchanger Room - Fire Area AAA 065 UJnits 3 and 4 QSPDS Inverter None None None None A,rea - Fire Area AAA 111 nit 4 Volume Control Tank - Fire None None None None A,rea AAA 112 Unit 3 Volume Control Tank - Fire None None None None A,rea AAA 126A nits 3 and 4 Radwaste Control None None None None Room and Equipment Room -
Fire Area AAA 126B Units 3 and 4 Radwaste None None None None Processing Area - Fire Area AAA Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 3 of 58
L-2014-003, Attachment Page 14 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: AAA (Unit 3) - Unit 3 and 4 Miscellaneous Zones Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 126C Units 3 and 4 Health Physics None None None None Storage Area - Fire Area AAA 126D Units 3 and 4 Radwaste Building None None None None HVAC Equipment Room - Fire Area AAA 126E Uhits 3 and 4 Maintenance Work None None None None Area - Fire Area AAA 129 Units 3 and 4 Nuclear Entrance None None None None Building - Fire Area AAA Fire Area ID: AAA (Unit 4) - Unit 3 and 4 Miscellaneous Zones Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 001 Units 3 and 4 Holdup Tank A - None None E Combustible Loading: E Fire Area AAA 002 Units 3 and 4 Holdup Tank B - None None E Combustible Loading: E Fire Area AAA 003 Units 3 and 4 Holdup Tank C - None None E Combustible Loading: E Fire Area AAA 021 Units 3 and 4 Counting Room - None A None Detection System, Alarm Point 39: A Fire Area AAA 022 Units 3 and 4 Hot Lab - Fire Area None A None Detection System, Alarm Point 39: A AAA 023 Units 3 and 4 Gas Decay Tank - None None None None Fire Area AAA 024 Units 3 and 4 Gas Decay Tank None None E Combustible Loading: E Room - Fire Area AAA 029 Unit 4 Spent Fuel Pit - Fire Area None None E Combustible Loading: E AAA 042 Unit 3 Spent Fuel Pit - Fire Area None None E Combustible Loading: E AAA 043 Unit 4 Spent Fuel Pit Heat None None None None Exchanger Room - Fire Area AAA 044 Unit 4 New Fuel Storage Room - None None None None Fire Area AAA Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 4 of 58
L-2014-003, Attachment Page 15 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: AAA (Unit 4) - Unit 3 and 4 Miscellaneous Zones Compliance Basis: t NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 046 Units 3 and 4 Laundry Room - None A None Detection System, Alarm Point 7: A Fire Area AAA 056 Unit 3 New Fuel Storage Room - None None None None Fire Area AAA 057 Unit 3 Spent Fuel Pit Heat None None None None Exchanger Room - Fire Area AAA 065 Uhits 3 and 4 QSPDS Inverter None None None None Area - Fire Area AAA 111 Unit 4 Volume Control Tank - Fire None None None None Area AAA 112 Unit 3 Volume Control Tank - Fire None None None None Area AAA 126A Units 3 and 4 Radwaste Control None None None None Room and Equipment Room -
Fire Area AAA 126B Uhits 3 and 4 Radwaste None None None None Processing Area - Fire Area AAA 126C Units 3 and 4 Health Physics None None None None Storage Area - Fire Area AAA 126D Units 3 and 4 Radwaste Building None None None None HVAC Equipment Room - Fire Area AAA 126E Units 3 and 4 Maintenance Work None None None None Area - Fire Area AAA 129 Units 3 and 4 Nuclear Entrance None None None None Building - Fire Area AAA Fire Area ID: B (Unit 3) - Unit 3 RHR Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 011 Unit 3 RHR Heat Exchanger None R, D,A E Detection System, Alarm Point 21: R D A Room - Fire Area B Physical separation: E 012 Unit 3 RHR Pump A Room - Fire None R, D, A E Combustible Loading: E Area B Detection System, Alarm Point 21: R D A 013 Unit 3 RHR Pump B Room - Fire None R, D, A None Detection System, Alarm Point 21: R D A Area B Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 5 of 58
L-2014-003, Attachment Page 16 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: B (Unit 4) - Unit 3 RHR Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 011 Unit 3 RHR Heat Exchanger None R, D, A E Detection System, Alarm Point 21: R D A Room - Fire Area B Physical separation: E 012 Uhit 3 RHR Pump A Room - Fire None R, D, A E Combustible Loading: E Area B Detection System, Alarm Point 21: R D A 013 Unit 3 RHR Pump B Room - Fire None R, D, A None Detection System, Alarm Point 21: R D A Area B Fire Area ID: BB (Unit 3) - Unit 3 Train A Emergency Diesel Generator Day Tank Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 075 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Day Tank Room - Fire Water Suppression, 3-10-847: A Area BB Fire Area ID: BB (Unit 4) - Unit 3 Train A Emergency Diesel Generator Day Tank Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 075 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Day Tank Room - Fire Water Suppression, 3-10-847: A Aiea BB Fire Safety Analysis DataManager (4.2) FPL - Turkey Run: 12119/2013 15:34 Page: 6 of 58
L-2014-003, Attachment Page 17 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: BBB (Unit 3) - Units 3 and 4 Safety Injection Pump Rooms Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID D~scription System System Protection Feature Required Fire Protection Feature and System Details 052 Unit 4 Safety Injection Pump None None None None Room - Fire Area BBB 053 Uhit 3 Safety Injection Pump None None None None Room - Fire Area BBB Fire Area ID: BBB (Unit 4) - Units 3 and 4 Safety Injection Pump Rooms Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 052 Unit 4 Safety Injection Pump None None None None Room - Fire Area BBB 053 Unit 3 Safety Injection Pump None None None None Room - Fire Area BBB Fire Area ID: C (Unit 3) - Unit 4 RHR Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 014 Unit 4 RHR Heat Exchanger None R, D, A E Detection System, Alarm Point 22: R D A Room - Fire Area C Physical separation: E 015 Unit 4 RHR Pump A Room - Fire None R, D, A E Combustible Loading: E Area C Detection System, Alarm Point 22: R D A 016 Unit 4 RHR Pump B Room - Fire None R, D, A None Detection System, Alarm Point 22: R D A Area C Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 7 of 58
L-2014-003, Attachment Page 18 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: C (Unit 4) - Unit 4 RHR Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 014 Unit 4 RHR Heat Exchanger None R, D, A E Detection System, Alarm Point 22: R D A Room -Fire Area C Physical separation: E 015 Unit 4 RHR Pump A Room - Fire None R, D, A E Combustible Loading: E Aiea C Detection System, Alarm Point 22: R D A 016 Uhit 4 RHR Pump B Room - Fire None R, D, A None Detection System, Alarm Point 22: R D A Area C Fire Area ID: CC (Unit 3) - Units 3 and 4 Auxiliary Building North-South Breezeway Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 079A Units 3 and 4 Auxiliary Building E, D R, D R Combustible Control - Transient Restrictions: R North-South Breezeway - Fire Detection System, Alarm Point 39: R D Area CC Detection System, Modification - CC U3: R ERFBS, Modification CC U3: R FireBarrier, MODIFICATION - CC U3: R Water Suppression, 10-850: E D Fire Area ID: CC (Unit 4) - Units 3 and 4 Auxiliary Building North-South Breezeway Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 079A Units 3 and 4 Auxiliary Building E, D R, D R Combustible Control - Transient Restrictions: R North-South Breezeway - Fire Detection System, Alarm Point 39: R D Area CC Detection System, Modification - CC U4: R ERFBS, Modification CC U4: R FireBarrier, MODIFICATION - CC U4: R Water Suppression, 10-850: E D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 8 of 58
L-2014-003, Attachment Page 19 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: CCC (Unit 3) - Units 3 and 4 Vestibule Elevator Compliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 064 Units 3 and 4 Vestibule Elevator - None None S, N ERFBS, 064-1: S N Fire Area CCC ERFBS, 064-2: S N ERFBS, 064-3: S N ERFBS, 064-4: S N Fire Area ID: CCC (Unit 4) - Units 3 and 4 Vestibule Elevator Compliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 064 Units 3 and 4 Vestibule Elevator - None None S, N ERFBS, 064-1: S N Fire Area CCC ERFBS, 064-2: S N ERFBS, 064-3: S N ERFBS, 064-4: S N Fire Area ID: D (Unit 3) - Unit 4 Pipe and Valve Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 030 Unit 4 Pipe and Valve Room - None R, A E Combustible Loading: E Fire Area D Detection System, Alarm Point 20: R A Physical separation: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12119/2013 15:34 Page: 9 of 58
L-2014-003, Attachment Page 20 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: D (Unit 4) - Unit 4 Pipe and Valve Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 030 Unit 4 Pipe and Valve Room - None R, A E Combustible Loading: E Fire Area D Detection System, Alarm Point 20: R A Physical separation: E Fire Area ID: DD (Unit 3) - Unit 4 480V Load Centers A and B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 093 Unit 4 480V Load Centers A and None R, D, A E Combustible Loading: E B Room - Fire Area DD Detection System, Alarm Point 2: R D A Fire Area ID: DD (Unit 4) - Unit 4 480V Load Centers A and B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 093 Unit 4 480V Load Centers A and None R, A E Combustible Loading: E B.Room - Fire Area DD Detection System, Alarm Point 2: R A Fire Area ID: DDD (Unit 3) - Unit 4 Steam Generator Feed Pump Area Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 066 Unit 4 Steam Generator Feed None None None None Pump Area - Fire Area DDD Fire Safety Analysis Data Manager (4.2) FPIL - Turkey Run: 12/19/2013 15:34 Page: 10 of 58
L-2014-003, Attachment Page 21 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: DDD (Unit 4) - Unit 4 Steam Generator Feed Pump Area Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 066 Unit 4 Steam Generator Feed None None None None Pump Area - Fire Area DDD Fire Area ID: E (Unit 3) - Unit 3 Pipe and Valve Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 040 Unit 3 Pipe and Valve Room - None R, D,A E Combustible Loading: E Fire Area E Detection System, Alarm Point 23: R D A Physical separation: E Fire Area ID: E (Unit 4) - Unit 3 Pipe and Valve Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 040 Unit 3 Pipe and Valve Room - None R, D,A E Combustible Loading: E Fire Area E Detection System, Alarm Point 23: R D A Physical separation: E Fire Area ID: EE (Unit 3) - Unit 4 480V Load Centers C and D Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 094 Unit 4 480V Load Centers C and None A E Combustible Loading: E D; Room - Fire Area EE Detection System, Alarm Point 2: A Fire Safety Analysis Data: Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 11 of 58
L-2014-003, Attachment Page 22 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: EE (Unit 4) - Unit 4 480V Load Centers C and D Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 094 Unit 4 480V Load Centers C and None R, D, A E, R, S, N Combustible Loading: E D Room - Fire Area EE Detection System, Alarm Point 2: R D A ERFBS, 094-1: R S N ERFBS, 094-2: R S N ERFBS, 094-3: R S N ERFBS, 094-4: R S N ERFBS, 094-5: R S N ERFBS, 094-6: R S N ERFBS, 094-7: R S N ERFBS, 094-8: R S N Fire Area ID: EEE (Unit 3) - Unit 3 Steam Generator Feed Pump Area Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 069 Unit 3 Steam Generator Feed E None E Combustible Loading: E Pump Area - Fire Area EEE Curbs: E Water Suppression, 3-10-1302: E Water Suppression, 3-10-1601: E Fire Area ID: EEE (Unit 4) - Unit 3 Steam Generator Feed Pump Area Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 069 Unit 3 Steam Generator Feed E None E Combustible Loading: E Pump Area - Fire Area EEE Water Suppression, 3-10-1302: E Water Suppression, 3-10-1601: E Fire Safety Analysis DatwManager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 12 of 58
L-2014-003, Attachment Page 23 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: F (Unit 3) - Unit 3 and 4 Auxiliary Building Hallway (18'-0")
Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 031 Unit 4 Containment Spray Pump None None None None Room - Fire Area F 032 Unit 4 Sample Room - Fire Area None None None None F
033 Units 3 and 4 Post Accident None None None None Sampling System Room - Fire Area F 034 Unit 3 Boric Acid Evaporator None None None None Package Room 035 Units 3 and 4 Valve Room None None None None 036 Unit 3 Boric Acid Evaporator None None None None Package Room - Fire Area F 037 Unit 3 Sample Room and Gas None None None None Stripper Room - Fire Area F 038 Unit 3 Containment Spray Pump None None None None Room - Fire Area F 039 Unit 3 Concentrate Holding Tank None None None None Room - Fire Area F 048 Units 3 and 4 Deborating None None E Combustible Loading: E Demineralizer Tank Room - Fire Physical separation: E Area F 049 Uhits 3 and 4 Base and Cation None None E Combustible Loading: E Radwaste Demineralizers Room - Physical separation: E Fire Area F 050 Units 3 and 4 Purification None None E Combustible Loading: E Demineralizers Room - Fire Area Physical separation: E F:
051 Units 3 and 4 Condensate Pump None None E Combustible Loading: E and Monitor Tank Room - Fire Physical separation: E Area F 058 Units 3 and 4 Auxiliary Building None E, R, D, A E, R Combustible Control - Transient Restrictions: R Hallway - Fire Area F Combustible Loading: E Detection System, Alarm Point 39: E R DA Physical separation: E z
Fire Safety Analysis Data.Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 13 of 58
L-2014-003, Attachment Page 24 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: F (Unit 4) - Unit 3 and 4 Auxiliary Building Hallway (18'-0")
Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Descripti on System System Protection Feature Required Fire Protecction Feature and System Details (All) Area Wid e None None R, D Procedures/Recovery 'Actions: R D 031 Unit 4 Co ntainment Spray Pump None None None None Room - Fire Area F 032 Uhit 4 Sarmple Room - Fire Area None None None None F;
033 Units 3 ar nd 4 Post Accident None None None None Sampling System Room - Fire Area F 034 Unit 3 Boric Acid Evaporator None None None None Package Room 035 Units 3 and 4 Valve Room None None None None 036 Unit 3 Boric Acid Evaporator None None None None Package Room - Fire Area F 037 Unit 3 Sample Room and Gas None None None None Stripper Room - Fire Area F 038 Unit 3 Containment Spray Pump None None None None Room - Fire Area F 039 Unit 3 Concentrate Holding Tank None None None None Room - Fire Area F 048 Units 3 and 4 Deborating None None E Combustible Loading: E Demineralizer Tank Room - Fire Physical separation: E Area F 049 Units 3 and 4 Base and Cation None None E Combustible Loading: E Radwaste Demineralizers Room - Physical separation: E Fire Area F 050 Units 3 and 4 Purification None None E Combustible Loading: E Demineralizers Room - Fire Area Physical separation: E F.
051 Units 3 and 4 Condensate Pump None None E Combustible Loading: E and Monitor Tank Room - Fire Physical separation: E Area F 058 Units 3 and 4 Auxiliary Building None E, R, D, A E, R Combustible Control - Transient Restrictions: R Hallway - Fire Area F Combustible Loading: E Detection System, Alarm Point 39: E R D A Physical separation: E Fire Safety Analysis Data'!Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 14 of 58
L-2014-003, Attachment Page 25 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: FF (Unit 3) - Unit 3 480V Load Centers A and B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 095 Unit 3 480V Load Centers A and None R, D, A None Detection System, Alarm Point 1: R D A B Room - Fire Area FF Fire Area ID: FF (Unit 4) - Unit 3 480V Load Centers A and B Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 095 Unit 3 480V Load Centers A and None A None Detection System, Alarm Point 1: A B Room - Fire Area FF Fire Area ID: FFF (Unit 3) - Units 3 and 4 Purge Supply Fan Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 107 Units 3 and 4 Purge Supply Fan None None None None Room - Fire Area FFF Fire Area ID: FFF (Unit 4) - Units 3 and 4 Purge Supply Fan Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 107 Units 3 and 4 Purge Supply Fan None None None None Room - Fire Area FFF Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 15 of 58
L-2014-003. Attachment Page 26 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: G (Unit 3) - Unit 3 and 4 Electrical Equipment Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 025 Units 3 and 4 Electrical None R, A E, R, S, N Combustible Loading: E Equipment Room - Fire Area G Detection System, Alarm Point 32: R A ERFBS, 025-1: R S N ERFBS, 025-2: R S N ERFBS, 025-3: R S N Physical separation: E 025A Units 3 and 4 Spare Battery None R, A None Detection System, Alarm Point 32: R A Room - Fire Area G Fire Area ID: G (Unit 4) - Unit 3 and 4 Electrical Equipment Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 025 Units 3 and 4 Electrical None R, D, A E, R, S, N Combustible Loading: E Equipment Room - Fire Area G Detection System, Alarm Point 32: R D A ERFBS, 025-1: R S N ERFBS, 025-2: R S N ERFBS, 025-3: R S N a Physical separation: E 025A Units 3 and 4 Spare Battery None R, D, A None Detection System, Alarm Point 32: R D A Room - Fire Area G Fire Area ID: GG (Unit 3) - Unit 3 480V Load Centers C and D Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 096 Unit 3 480V Load Centers C and None R, D, A R, S, N Detection System, Alarm Point 1: R DA D Room - Fire Area GG ERFBS, 096-1: R S N ERFBS, 096-2: R S N ERFBS, 096-3: R S N ERFBS, 096-4: R S N ERFBS, 096-5: R S N ERFBS, 096-6: R S N ERFBS, 096-7: R S N ERFBS, 096-8: R S N ERFBS, 096-9: R S N Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 16 of 58
L-2014-003, Attachment Page 27 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: GG (Unit 4) - Unit 3 480V Load Centers C and D Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 096 Unit 3 480V Load Centers C and None R, D,A None Detection System, Alarm Point 1: R D A D Room - Fire Area GG Fire Area ID: H (Unit 3) - Unit 3 West Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 019 Unit 3 West Electrical Penetration None R, D R, S, N Detection System, Alarm Point 9: R D Room - Fire Area H ERFBS, 019-1: R S N ERFBS, 019-2: R S N ERFBS, 019-3: R S N ERFBS, 019-4: R S N Fire Area ID: H (Unit 4) - Unit 3 West Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 019 Unit 3 West Electrical Penetration None None None None Room - Fire Area H Fire Area ID: HH (Unit 3) - Units 3 and 4 Cable Spreading Room and Chase Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 098 Units 3 and 4 Cable Spreading D, A R, D,A R Combustible Control - Transient Restrictions: R Room - Fire Area HH Detection System, Alarm Point 6: R D A Detection System, Modification - HH U3: R ERFBS, Modification - HH U3: R Gaseous Suppression, CV-1450A&B CV-1451A&B: D A 132 Units 3 and 4 Control Room D, A D, A R Combustible Control - Transient Restrictions: R Electrical Cable Chase - Fire Detection System, Alarm Point 5: D A Area HH Gaseous Suppression, CV-1450A&B CV-1451A&B: D A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 17 of 58
L-2014-003, Attachment Page 28 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: HH (Unit 4) - Units 3 and 4 Cable Spreading Room and Chase Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 098 Units 3 and 4 Cable Spreading D, A R, D, A R Combustible Control - Transient Restrictions: R Room - Fire Area HH Detection System, Alarm Point 6: R D A Detection System, Modification - HH U4: R ERFBS, Modification - HH U4: R Gaseous Suppression, CV-1450A&B CV-1451A&B: D A 132 Units 3 and 4 Control Room D, A D, A R Combustible Control - Transient Restrictions: R Electrical Cable Chase - Fire Detection System, Alarm Point 5: D A Area HH Gaseous Suppression, CV-1450A&B CV-1451A&B: D A Fire Area ID: I (Unit 3) - Unit 3 South Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 020 Unit 3 South Electrical None R, D, A None Detection System, Alarm Point 9: R D A Penetration Room - Fire Area I Fire Area ID: I (Unit 4) - Unit 3 South Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 020 Unit 3 South Electrical None A None Detection System, Alarm Point 9: A Penetration Room - Fire Area I Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 18 of 58
L-2014-003, Attachment Page 29 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: II (Unit 3) - Unit 4 B DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 101 Unit 4 B DC Equipment Room - None R, D, A None Detection System, Alarm Point 6: R D A Fire Area II Fire Area ID: II (Unit 4) - Unit 4 B DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 101 Unit 4 B DC Equipment Room - None R, D, A None Detection System, Alarm Point 6: R D A Fire Area II Fire Area ID: J (Unit 3) - Unit 4 North Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 026 Unit 4 North Electrical None A None Detection System, Detection 026: A Penetration Room - Fire Area J Fire Area ID: J (Unit 4) - Unit 4 North Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 026 Unit 4 North Electrical None R, A None Detection System, Alarm Point 10: R A Penetration Room - Fire Area J Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 19 of 58
L-2014-003, Attachment Page 30 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: JJ (Unit 3) - Unit 4 Battery Rack B Room Compliance Basis:' NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 102 Unit 4 Battery Rack B Room - None R, D, A None Detection System, Alarm Point 6: R D A Fire Area JJ Fire Area ID: - JJ (Unit 4) - Unit 4 Battery Rack B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 102 Unit 4 Battery Rack B Room - None R, D, A None Detection System, Alarm Point 6: R D A Fire Area JJ Fire Area ID: K(Unit 3) - Unit 4 West Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 027 Unit 4 West Electrical Penetration None None None None Room - Fire Area K Fire Area ID: K(Unit 4) - Unit 4 West Electrical Penetration Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Descripti on System System Protection Feature Required Fire Protection Feature and System Details 027 Unit 4 We st Electrical Penetration None R, D None Detection System, Alarm Point 10: R D Room - Fire Area K Fire Safety Analysis Data'Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 20 of 58
L-2014-003, Attachment Page 31 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: KK (Unit 3) - Unit 3 Battery Rack A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 103 Unit 3 Battery Rack A Room - None R, A None Detection System, Alarm Point 6: R A Fire Area KK Fire Area ID: KK (Unit 4) - Unit 3 Battery Rack A Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 103 Unit 3 Battery Rack A Room - None A None Detection System, Alarm Point 6: A Fire Area KK Fire Area ID: L (Unit 3) - Units 3 and 4 Auxiliary Building Fan Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 028 Units 3 and 4 Auxiliary Building None None E Combustible Loading: E Fan Room - Fire Area L Physical separation: E Fire Area ID: L (Unit 4) - Units 3 and 4 Auxiliary Building Fan Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 028 Units 3 and 4 Auxiliary Building None None E Combustible Loading: E Fan Room - Fire Area L Physical separation: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 21 of 58
L-20 14-003, Attachment Page 32 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: LL (Unit 3) - Unit 3 A DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 104 Unit 3 A DC Equipment Room - None R, D, A R, S, N Detection System, Alarm Point 6: R D A Fire Area LL ERFBS, 104-1: R S N ERFBS, 104-2: R S N ERFBS, 104-3: R S N ERFBS, 104-4: R S N ERFBS, 104-5: R S N Fire Area ID: LL (Unit 4) - Unit 3 A DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 104 Unit 3 A DC Equipment Room - None A S, N Detection System, Alarm Point 6: A Fire Area LL ERFBS, 104-1: S N ERFBS, 104-2: S N ERFBS, 104-3: S N ERFBS, 104-4: S N ERFBS, 104-5: S N Fire Area ID: MM (Unit 3) - Control Room Complex Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 097 Units 3 and 4 Mechanical None D, A D Detection System, Alarm Point 5: D A Equipment Room - Fire Area MM Extinguishers: D 106 Units 3 and 4 Control Room - Fire None R, D, A D Detection System, Alarm Point 5: D A Area MM Detection System, Modification - MM: R Extinguishers: D 106R Units 3 and 4 Control Room Roof None None E, D Combustible Loading: E
- Fire Area MM Extinguishers: D Fire Safety Analysis Data, Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 22 of 58
L-2014-003, Attachment Page 33 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: MM (Unit 4) - Control Room Complex Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 097 Units 3 and 4 Mechanical None D, A D Detection System, Alarm Point 5: D A Eqluipment Room - Fire Area MM Extinguishers: D 106 Units 3 and 4 Control Room - Fire None R, D, A D Detection System, Alarm Point 5: D A Area MM Detection System, Modification - MM: R Extinguishers: D 106R Units 3 and 4 Control Room Roof None None E, D Combustible Loading: E
- Fire Area MM Extinguishers: D Fire Area ID: N (Unit 3) - Unit 4 Charging Pump Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 045 Unit 4 Charging Pump Room - E, D, A E, D, A None Detection System, Alarm Point 7: E D A Fire Area N Water Suppression, 4-10-830: E D A Fire Area ID: N (Unit 4) - Unit 4 Charging Pump Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 045 Unit 4 Charging Pump Room - E, A E, D, A None Detection System, Alarm Point 7: E D A Fire Area N Water Suppression, 4-10-830: E A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 23 of 58
L-2014-003, Attachment Page 34 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: NN (Unit 3) - Units 3 and 4 A DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 108A Units 3 and 4 A DC Equipment R, S, N, A R, D, S, N, A R, S, N Detection System, Alarm Point 15: R D S N A Room - Fire Area NN ERFBS, 108A-1: R S N ERFBS, 108A-2: R S N ERFBS, 108A-3: R S N ERFBS, 108A-4: R S N Gaseous Suppression, CV-1452 CV-1453: R S N A Fire Area ID: NN (Unit 4) - Units 3 and 4 A DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 108A Units 3 and 4 A DC Equipment R, S, N, A R, D, S, N, A R, S, N Detection System, Alarm Point 15: R D S N A Room - Fire Area NN ERFBS, 108A-1: R S N ERFBS, 108A-2: R S N ERFBS, 108A-3: R S N ERFBS, 108A-4: R S N Gaseous Suppression, CV-1452 CV-1453: R S N A Fire Area ID: 0 (Unit 3) - Unit 3 and 4 Boric Acid Tanks and Pumps Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 041 Units 3 and 4 Boric Acid Tanks None None E Physical separation: E and Pump Room - Fire Area 0 055 Unit 3 Charging Pump Room - E, A E, D, A None Detection System, Alarm Point 7: E D A Fire Area 0 Water Suppression, 3-10-841: E A Fire Safety Analysis Data'Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 24 of 58
L-2014-003, Attachment Page 35 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 0 (Unit 4) - Unit 3 and 4 Boric Acid Tanks and Pumps Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 041 Units 3 and 4 Boric Acid Tanks None None E Physical separation: E and Pump Room - Fire Area 0 055 Unit 3 Charging Pump Room E, A E, A None Detection System, Alarm Point 7: E A
- 'Fire Area 0 Water Suppression, 3-10-841: E A Fire Area ID: OD-047 (Unit 3) - Unit 4 Component Cooling Pump and Heat Exchanger Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 047 Unit 4 Component Cooling Pump E None E Combustible Loading: E arnd Heat Exchanger - Fire Area Water Suppression, 4-10-833: E OD Water Suppression, 4-10-835: E Fire Area ID: OD-047 (Unit 4) - Unit 4 Component Cooling Pump and Heat Exchanger Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 047 Unit 4 Component Cooling Pump E D E Combustible Loading: E and Heat Exchanger - Fire Area Detection System, Alarm Point 28: D OD Water Suppression, 4-10-833: E Water Suppression, 4-10-835: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 25 of 58
L-2014-003, Attachment Page 36 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-054 (Unit 3) - Unit 3 Component Cooling Pump and Heat Exchanger Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 054 Unit 3 Component Cooling Pump E None E Combustible Loading: E and Heat Exchanger Area - Fire Water Suppression, 3-10-837: E Area OD Water Suppression, 3-10-839: E Fire Area ID: OD-054 (Unit 4) - Unit 3 Component Cooling Pump and Heat Exchanger Area Compliance Basis: NFPA 805, Section 4.2.3.3 (b), 20ft horizontal separation Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 054 Unit 3 Component Cooling Pump E None E Combustible Loading: E and Heat Exchanger Area - Fire Water Suppression, 3-10-837: E Area OD Water Suppression, 3-10-839: E Fire Area ID: OD-076 (Unit 3) - Unit 4 Lube Oil Reservoir Area Compliance Basis: NFPA 805, Section 4.2.3.3 (b), 20ft horizontal separation Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 076 Unit 4 Lube Oil Reservoir Area - None None None None Fire Area OD Fire Area ID: OD-076 (Unit 4) - Unit 4 Lube Oil Reservoir Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 076 Unit 4 Lube Oil Reservoir Area - None D None Detection System, Alarm Point 12: D Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 26 of 58
L-2014-003, Attachment Page 37 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-077 (Unit 3) - Unit 4 Laydown Area, Instrument Air Compressors and Condensate Storage Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 077 Unit 4 Laydown Area, Instrument None None None None Air Compressors and Condensate Storage Area - Fire Area OD Fire Area ID: OD-077 (Unit 4) - Unit 4 Laydown Area, Instrument Air Compressors and Condensate Storage Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 077 Unit 4 Laydown Area, Instrument None None None None Air Compressors and Condensate Storage Area - Fire Area OD Fire Area ID: OD-078 (Unit 3) - Unit 4 Instrument Air Equipment Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 078 Unit 4 Instrument Air Equipment 0 D D Detection System, All available - OD-078: D Area - Fire Area OD Pre-fire Plan: D Water Suppression, 4-10-1302: D Water Suppression, 4-10-1590: D Water Suppression, 4-10-1601: D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 27 of 58
L-2014-003, Attachment Page 38 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-078 (Unit 4) - Unit 4 Instrument Air Equipment Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 078 Unit 4 Instrument Air Equipment D D D Detection System, All available - OD-078: D Area - Fire Area OD Pre-fire Plan: D Water Suppression, 4-10-1302: D Water Suppression, 4-10-1590: D Water Suppression, 4-10-1601: D Fire Area ID: OD-079 (Unit 3) - Outdoor Area West of Unit 4 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 079 Outdoor Area West of Unit 4 None None E Combustible Loading: E Containment - Fire Area OD Curbs: E Extinguishers: E Physical separation: E Fire Area ID: OD-079 (Unit 4) - Outdoor Area West of Unit 4 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 079 Outdoor Area West of Unit 4 D None E, D Combustible Control - Transient Restrictions: D Containment - Fire Area OD Combustible Loading: E Curbs: E Extinguishers: E Physical separation: E Water Suppression, All available - OD-079: D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 28 of 58
L-20 14-003, Attachment Page 39 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-080 (Unit 3) - Unit 4 Main Condenser Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 080 Unit 4 Main Condenser Area - E None E Combustible Loading: E Fire Area OD Curbs: E Water Suppression, 4-10-1302: E Water Suppression, 4-10-1601: E Fire Area ID: OD-080 (Unit 4) - Unit 4 Main Condenser Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 080 Unit 4 Main Condenser Area - E None E, D Combustible Control - Transient Restrictions: D Fire Area OD Combustible Loading: E Water Suppression, 4-10-1302: E Water Suppression, 4-10-1601: E Fire Area ID: OD-081 (Unit 3) - Unit 4 Main and Start-up Transformer and Unit 3 Turbine Lube Oil Reservoir Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 081 Unit 4 Main and Start-Up E, D D E Combustible Loading: E Transformer and Unit 3 Turbine Curbs: E Lube Oil Reservoir Area - Fire Detection System, Alarm Point 11: D Area OD Water Suppression, 3-10-1590: E D Water Suppression, 4-10-1575: E D Water Suppression, 4-10-1611: E D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 29 of 58
L-2014-003, Attachment Page 40 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-081 (Unit 4) - Unit 4 Main and Start-up Transformer and Unit 3 Turbine Lube Oil Reservoir Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 081 Unit 4 Main and Start-Up E, D D E Combustible Loading: E Transformer and Unit 3 Turbine Curbs: E Lube Oil Reservoir Area - Fire Detection System, Alarm Point 11: D Area OD Water Suppression, 3-10-1590: E D Water Suppression, 4-10-1575: E D Water Suppression, 4-10-1611: E D Fire Area ID: OD-082 (Unit 3) - Unit 4 Auxiliary Transformer Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 082 Unit 4 Auxiliary Transformer Area E, D D E Combustible Loading: E
- Fire Area OD Curbs: E Detection System, Alarm Point 14: D Extinguishers: E Hose Stations: E Water Suppression, 3-10-1590: E D Water Suppression, 4-10-1302: E D Water Suppression, 4-10-1581: E D Water Suppression, 4-10-1601: E D Fire Area ID: OD-082 (Unit 4) - Unit 4 Auxiliary Transformer Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 082 Unit 4 Auxiliary Transformer Area E, D D E Combustible Loading: E
- Fire Area OD Curbs: E Detection System, Alarm Point 14: D Extinguishers: E Hose Stations: E Water Suppression, 3-10-1590: E D Water Suppression, 4-10-1302: E D Water Suppression, 4-10-1581: E D Water Suppression, 4-10-1601: E D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 30 of 58
L-2014-003, Attachment Page 41 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-083 (Unit 3) - Unit 3 Instrument Air Equipment Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 083 Unit 3 Instrument Air Equipment E, D D E Combustible Loading: E Area - Fire Area OD Curbs: E Detection System, All available - OD-083: D Extinguishers: E Physical separation: E Water Suppression, 3-10-1302: E D Water Suppression, 3-10-1601: E D Fire Area ID: OD-083 (Unit 4) - Unit 3 Instrument Air Equipment Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 083 Unit 3 Instrument Air Equipment E, D D E Combustible Loading: E Area - Fire Area OD Curbs: E Detection System, All available - OD-083: D Extinguishers: E Physical separation: E Water Suppression, 3-10-1302: E D Water Suppression, 3-10-1601: E D Fire Area ID: OD-084 (Unit 3) - Units 3 and 4 Auxiliary Feedwater Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 084 Units 3 and 4 Auxiliary Feedwater E, D None E Combustible Loading: E Pump Area - Fire Area OD Curbs: E Extinguishers: E Water Suppression, 3-10-1601: E D Fire Safely Analysis Data .Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 31 of 58
L-2014-003, Attachment Page 42 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-084 (Unit 4) - Units 3 and 4 Auxiliary Feedwater Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 084 Units 3 and 4 Auxiliary Feedwater E, D None E, R Combustible Loading: E Pump Area - Fire Area OD Curbs: E Extinguishers: E Transient Combustible Restrictions: R Water Suppression, 3-10-1601: E D Fire Area ID: OD-085 (Unit 3) - Unit 3 Main Condenser Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 085 Unit 3 Main Condenser Area - E None E Combustible Loading: E Fire Area OD Curbs: E Water Suppression, 3-10-1302: E Water Suppression, 3-10-1601: E Fire Area ID: OD-085 (Unit 4) - Unit 3 Main Condenser Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 085 Unit 3 Main Condenser Area - E None E Combustible Loadino: E Fire Area OD Curbs: E Water Suppression, 3-10-1302: E Water Suppression, 3-10-1601: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 32 of 58
L-2014-003, Attachment Page 43 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-086 (Unit 3) - Unit 3 Main Transformer and Startup Transformer Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 086 Unit 3 Main Transformer and E, D D E, R Combustible Loading: E Startup Transformer - Fire Area Detection System, All available - OD-086: D OD ERFBS, Modification - OD-86 U3: R Fire Stops and Radiant Energy Heat Shield: R Water Suppression, 3-10-1575: E D Water Suppression, 3-10-1611: E D Fire Area ID: OD-086 (Unit 4) - Unit 3 Main Transformer and Startup Transformer Compliance Basis: NFPA-805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 086 Unit 3 Main Transformer and E, D D E, R Combustible Loading: E Startup Transformer - Fire Area Detection System, All available - OD-086: D OD ERFBS, Modification - OD-86 U4: R Water Suppression, 3-10-1575: E D Water Suppression, 3-10-1611: E D Fire Area ID: OD-087 (Unit 3) - Unit 3 Auxiliary Transformer Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 087 Unit 3 Auxiliary Transformer Area E, D D None Detection System, Alarm Point 13: D
- Fire Area OD Water Suppression, 3-10-1302: E D Water Suppression, 3-10-1581: E D Water Suppression, 3-10-1601: E D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 33 of 58
L-2014-003, Attachment Page 44 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-087 (Unit 4) - Unit 3 Auxiliary Transformer Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 087 Unit 3 Auxiliary Transformer Area E, D D None Detection System, Alarm Point 13: D
- Fire Area OD Water Suppression, 3-10-1302: E D Water Suppression, 3-10-1581: E D Water Suppression, 3-10-1601: E D Fire Area ID: OD-088 (Unit 3) - Unit 3 Switchgear/D.G. Building Vestibule Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach a Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 088 Unit 3 Switchgear / DG Building None None E Combustible Loading: E Vestibule - Fire Area OD Physical separation: E Fire Area ID: OD-088 (Unit 4) - Unit 3 Switchgear/D.G. Building Vestibule Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 088 Unit 3 Switchgear / DG Building None None E Combustible Loading: E Vestibule - Fire Area OD Physical separation: E Fire Area ID: OD-089 (Unit 3) - Unit 3 Condensate Storage Tank Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 089 Unit 3 Condensate Storage Tank None None E, D Combustible Control - Transient Restrictions: D Area - Fire Area OD Combustible Loading: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 34 of 58
L-2014-003, Attachment Page 45 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-089 (Unit 4) - Unit 3 Condensate Storage Tank Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 089 Unit 3 Condensate Storage Tank None None E Combustible Loading: E Area - Fire Area OD Fire Area ID: OD-090 (Unit 3) - Unit 3 & 4 Emergency Diesel Generator Oil Storage Tank Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 090 Unit 3 & 4 Emergency Diesel None None None None Generator Oil Storage Tank Area
- Fire Area OD Fire Area ID: OD-090 (Unit 4) - Unit 3 & 4 Emergency Diesel Generator Oil Storage Tank Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 090 Unit 3 & 4 Emergency Diesel None None None None Generator Oil Storage Tank Area
- Fire Area OD Fire Area ID: OD-091 (Unit 3) - Unit 4 Condensate Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 091 Unit 4 Condensate Pump Area - E, D None E Combustible Loading: E Fir'e Area OD Curbs: E Water Suppression, 4-10-1302: E D Water Suppression, 4-10-1601: E D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 35 of 58
L-2014-003, Attachment Page 46 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-091 (Unit 4) - Unit 4 Condensate Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 091 Unit 4 Condensate Pump Area - E, D None E Combustible Loading: E Fire Area OD Curbs: E Water Suppression, 4-10-1302: E D Water Suppression, 4-10-1601: E D Fire Area ID: OD-092 (Unit 3) - Unit 3 Condensate Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 092 Unit 3 Condensate Pump Area - E None None Water Suppression, 3-10-1302: E Fire Area OD Water Suppression, 3-10-1601: E Fire Area ID: OD-092 (Unit 4) - Unit 3 Condensate Pump Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 092 Unit 3 Condensate Pump Area - E None None Water Suppression, 3-10-1302: E Fire Area OD Water Suppression, 3-10-1601: E Fire Area ID: OD-105 (Unit 3) - Units 3 and 4 Turbine Building Mezzanine Deck Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 105 Units 3 and 4 Turbine Building None None E Combustible Loading: E Mezzanine Deck - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 36 of 58
L-2014-003, Attachment Page 47 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-1 05 (Unit 4) - Units 3 and 4 Turbine Building Mezzanine Deck Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 105 Units 3 and 4 Turbine Building None None E Combustible Loading: E Mezzanine Deck - Fire Area OD Fire Area ID: OD-113 (Unit 3) - Unit 4 Feedwater Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 113 Unit 4 Feedwater Platform - Fire None None E Combustible Loading: E Area OD Fire Area ID: OD-113 (Unit 4) - Unit 4 Feedwater Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 113 Unit 4 Feedwater Platform - Fire None D E, R, D Combustible Loading: E Area OD Detection System, Alarm Point 29: D Radiant Barrier: R D Fire Area ID: OD-114 (Unit 3) - Unit 4 Main Steam Header Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 114 Unit 4 Main Steam Header None None E Combustible Loading: E Platform - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 37 of 58
L-2014-003, Attachment Page 48 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-1 14 (Unit 4) - Unit 4 Main Steam Header Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 114 Unit 4 Main Steam Header None None E Combustible Loading: E Platform - Fire Area OD Fire Area ID: OD-1 15 (Unit 3) - Unit 3 Main Steam Header Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 115 Unit 3 Main Steam Header None None E Combustible Loading: E Platform - Fire Area OD Fire Area ID: OD-115 (Unit 4) - Unit 3 Main Steam Header Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 115 Unit 3 Main Steam Header None None E Combustible Loading: E Platform - Fire Area OD Fire Area ID: OD-116 (Unit 3) - Unit 3 Feedwater Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 116 Unit 3 Feedwater Platform - Fire None D E, R, D Combustible Control - Transient Restrictions: D Area OD Combustible Loading: E Detection System, Alarm Point 30: D Radiant Barrier: R D Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 38 of 58
L-2014-003, Attachment Page 49 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-116 (Unit 4) - Unit 3 Feedwater Platform Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 116 Unit 3 Feedwater Platform - Fire None None E, D Combustible Control - Transient Restrictions: D Area OD Combustible Loading: E Fire Area ID: OD-117 (Unit 3) - Units 3 and 4 Turbine Deck Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 117 Units 3 and 4 Turbine Deck - Fire None None E Combustible Loading: E Area OD Fire Area ID: OD-117 (Unit 4) - Units 3 and 4 Turbine Deck Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 117 Units 3 and 4 Turbine Deck - Fire None None E Combustible Loading: E Area OD Fire Area ID: OD-118 (Unit 3) - Units 3 and 4 Auxiliary Building Roof Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 118 Units 3 and 4 Auxiliary Building None None E, D Combustible Control - Transient Restrictions: D Roof - Fire Area OD Combustible Loading: E Hot Work Control: D Physical separation: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 39 of 58
L-2014-003, Attachment Page 50 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-118 (Unit 4) - Units 3 and 4 Auxiliary Building Roof Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 118 Units 3 and 4 Auxiliary Building None None E, D Combustible Control - Transient Restrictions: D Roof - Fire Area OD Combustible Loading: E Hot Work Control: D Physical separation: E Fire Area ID: , OD-122 (Unit 3) - Units 3 and 4 Water Treatment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 122 Units 3 and 4 Water Treatment None None None None Room - Fire Area OD Fire Area ID: OD-122 (Unit 4) - Units 3 and 4 Water Treatment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 122 Units 3 and 4 Water Treatment None None None None Room - Fire Area OD Fire Area ID: OD-123 (Unit 3) - Units 3 and 4 Refueling Water Storage Tanks Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 123 Units 3 and 4 Refueling Water None None None None Storage Tanks Area - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 40 of 58
L-2014-003, Attachment Page 51 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-123 (Unit 4) - Units 3 and 4 Refueling Water Storage Tanks Area Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 123 Uhits 3 and 4 Refueling Water None None None None Storage Tanks Area - Fire Area OD Fire Area ID: OD-124 (Unit 3) - Outside Area NE of Unit 3 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 124 Outside Area NE of Unit 3 None None None None Containment - Fire Area OD Fire Area ID: OD-124 (Unit 4) - Outside Area NE of Unit 3 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 124 Outside Area NE of Unit 3 None None None None Containment - Fire Area OD Fire Area ID: OD-125 (Unit 3) - Units 3 and 4 Land Area South of Unit 4 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 125 Units 3 and 4 Land Area South of None None None None Unit 4 Containment - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 41 of 58
L-2014-003, Attachment Page 52 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-125 (Unit 4) - Units 3 and 4 Land Area South of Unit 4 Containment Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 125 Units 3 and 4 Land Area South of None None None None Unit 4 Containment - Fire Area OD Fire Area ID: OD-128 (Unit 3) - Units 3 and 4 Distribution Switchyard Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 128 Units 3 and 4 Distribution None None None None Switchyard - Fire Area OD Fire Area ID: OD-128 (Unit 4) - Units 3 and 4 Distribution Switchyard Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 128 Units 3 and 4 Distribution None None None None Switchyard - Fire Area OD Fire Area ID: OD-1 31 (Unit 3) - Units 3A and 3B Diesel Generator Radiator Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 131 Units 3A and 3B Diesel None None None None Generator Radiator Rooms - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 42 of 58
L-2014-003, Attachment Page 53 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-131 (Unit 4) - Units 3A and 3B Diesel Generator Radiator Rooms Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 131 Units 3A and 38 Diesel None None None None Generator Radiator Rooms - Fire Area OD Fire Area ID: OD-143 (Unit 3) - Unit 3 Emergency Diesel Generator Roof Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 143 Unit 3 Emergency Diesel None None None None Generator Roof - Fire Area OD-143 Fire Area ID: OD-143 (Unit 4) - Unit 3 Emergency Diesel Generator Roof Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 143 Unit 3 Emergency Diesel None None None None Generator Roof - Fire Area OD-143 Fire Area ID: OD-999 (Unit 3) - Miscellaneous Areas Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 999 Miscellaneous Areas - Fire Area None None None None OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 43 of 58
L-2014-003, Attachment Page 54 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: OD-999 (Unit 4) - Miscellaneous Areas Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 999 Miscellaneous Areas - Fire Area None None None None OD Fire Area ID: OD-Intake (Unit 3) - Intake Structure Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 119 Unit 4 Circulating Water Intake None None E Combustible Loading: E Structure - Fire Area OD 120 Unit 3 Circulating Water Intake None None E Combustible Loading: E Structure - Fire Area OD 121 Units 3 and 4 Intake Laydown None None None None Area - Fire Area OD Fire Area ID: OD-Intake (Unit 4) - Intake Structure Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 119 Unit 4 Circulating Water Intake None D E Combustible Loading: E Structure - Fire Area OD Detection System, Alarm Point 26: D 120 Unit 3 Circulating Water Intake None D E Combustible Loading: E Structure - Fire Area OD Detection System, Alarm Point 27: D 121 Units 3 and 4 Intake Laydown None None None None Area - Fire Area OD Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 44 of 58
L-2014-003, Attachment Page 55 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: 00 (Unit 3) - Units 3 and 4 B DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 108B Units 3 and 4 DC Equipment S, N, A R, D, S, N, A R, S, N Detection System, Alarm Point 15: R D S N A Room - Fire Area 00 ERFBS, 108B-1: R S N ERFBS, 108B-2: R S N Gaseous Suppression, CV-1454 CV-1455: S N A Fire Area ID: 00 (Unit 4) - Units 3 and 4 B DC Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 108B Units 3 and 4 DC Equipment D, S, N, A R, D, S, N, A R, S, N Detection System, Alarm Point 15: R D S N A Room - Fire Area 00 ERFBS, 108B-1: R S N ERFBS, 108B-2: R S N Gaseous Suppression, CV-1454 CV-1455: D S N A Fire Area ID: P (Unit 3) - Unit 4 Containment Building Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 059 Unit 4 Containment Buildino - Fire None A E Combustible Loading: E Area P Detection System, Alarm Point 43: A Detection System, Alarm Point 44: A Fire Safety Analysis Data, Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 45 of 58
L-2014-003, Attachment Page 56 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: P (Unit 4) - Unit 4 Containment Building Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 059 Unit 4 Containment Building - Fire None E, D, A E, R, S, N Combustible Loading: E S N Area P Detection System, Alarm Point 43: E D A Detection System, Alarm Point 44: E D A ERFBS, 059-1: E S N ERFBS, 059-2: E S N ERFBS, 059-3: E S N ERFBS, 059-4: E S N ERFBS, 059-5: E S N ERFBS, 059-6: E S N Radiant Energy Heat Shield: E R S N Fire Area ID: PP (Unit 3) - Unit 4 Battery Rack A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 109 Unit 4 Battery Rack A Room - None R, A None Detection System, Alarm Point 15: R A Fire Area PP Fire Area ID: PP (Unit 4) - Unit 4 Battery Rack A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 109 Unit 4 Battery Rack A Room - None R, A None Detection System, Alarm Point 15: R A Fire Area PP Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 46 of 58
L-2014-003, Attachment Page 57 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: Q (Unit 3) - Unit 3 Containment Building Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 060 Unit 3 Containment Building - Fire None E, D E, R, S, N Combustible Loading: E S N Area Q Detection System, Alarm Point 3: E D Detection System, Alarm Point 4: E D ERFBS, 060-1: ES N ERFBS, 060-10: E S N ERFBS, 060-2: E S N ERFBS, 060-3: E S N ERFBS, 060-4: E S N ERFBS, 060-5: E S N ERFBS, 060-6: E S N ERFBS, 060-7: E S N ERFBS, 060-8: E S N ERFBS, 060-9: E S N Radiant Energy Heat Shield: E R S N Fire Area ID: Q (Unit 4) - Unit 3 Containment Building Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 060 Unit 3 Containment Building - Fire None None E Combustible Loading: E Area Q Fire Area ID: QQ (Unit 3) - Unit 3 Battery Rack B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 110 Unit 3 Battery Rack B Room - None R, A None Detection System, Alarm Point 15: R A Fire Area QQ Fire Safety Analysis Data- Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 47 of 58
L-2014-003, Attachment Page 58 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: QQ (Unit 4) - Unit 3 Battery Rack B Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 110 Unit 3 Battery Rack B Room - None A None Detection System, Alarm Point 15: A Fire Area QQ Fire Area ID: R (Unit 3) - Unit 4 Reactor Control Rod Equipment Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 061 Unit 4 Reactor Control Rod None A None Detection System, Alarm Point 6: A Equipment Room - Fire Area R Fire Area ID: R (Unit 4) - Unit 4 Reactor Control Rod Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 061 Unit 4 Reactor Control Rod None D, A None Detection System, Alarm Point 6: D A Equipment Room - Fire Area R Fire Area ID: RR (Unit 3) - Unit 4 Train A Emergency Diesel Generator Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 138 Unit 4 Train A Emergency Diesel E None None Water Suppression, 4-10-1112: E Generator Room - Fire Area RR Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 48 of 58
L-2014-003, Attachment Page 59 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: RR (Unit 4) - Unit 4 Train A Emergency Diesel Generator Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 138 Unit 4 Train A Emergency Diesel E, R, D R, D None Detection System, All available - RR: R D Generator Room - Fire Area RR Water Suppression, 4-10-1112: E R D Fire Area ID: S (Unit 3) - Units 3 and 4 Computer Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 062 Units 3 and 4 Computer Room - None R, D, A None Detection System, Alarm Point 31: R D A Fire Area S Fire Area ID: S (Unit 4) - Units 3 and 4 Computer Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 062 Units 3 and 4 Computer Room - None R, D, A None Detection System, Alarm Point 31: R D A Fire Area S Fire Area ID: SS (Unit 3) - Unit 4 Train B Emergency Diesel Generator Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 133 Unit 4 Train B Emergency Diesel E, A A None Detection System, All available - SS: A Generator Room - Fire Area SS Water Suppression, 4-10-1113: E A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 49 of 58
L-2014-003, Attachment Page 60 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: SS (Unit 4) - Unit 4 Train B Emergency Diesel Generator Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 133 Unit 4 Train B Emergency Diesel E, R, A R, D, A None Detection System, All available - SS: R D A Generator Room - Fire Area SS Water Suppression, 4-10-1113: E R A Fire Area ID: T (Unit 3)- Unit 3 Reactor Control Rod Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID D~scrlption System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None D Procedures/Recovery Actions: D 063 Unit 3 Reactor Control Rod None D,A None Detection System, Alarm Point 6: D A Equipment Room - Fire Area T Fire Area ID: T (Unit 4) - Unit 3 Reactor Control Rod Equipment Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 063 Unit 3 Reactor Control Rod None A None Detection System, Alarm Point 6: A Equipment Room - Fire Area T Fire Area ID: TT (Unit 3) - Train A SD - Unit 3 Switchgear Room 3D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 134 Unit 3 Switchgear Room 3D - Fire None A E Combustible Loading: E Area TT Detection System, Detection 134: A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 50 of 58
L-2014-003, Attachment Page 61 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: TT (Unit 3) - Train B SD - Unit 3 Switchgear Room 3D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 134 Unit 3 Switchgear Room 3D - Fire None A E Combustible Loading: E Area TT Detection System, Detection 134: A Fire Area ID: TT (Unit 4) - Train A SD - Unit 3 Switchgear Room 3D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 134 Unit 3 Switchgear Room 3D - Fire None A E Combustible Loading: E Area TT Detection System, Detection 134: A Fire Area ID: TT (Unit 4) - Train B SD - Unit 3 Switchgear Room 3D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 134 Unit 3 Switchgear Room 3D - Fire None A E Combustible Loading: E Area TT Detection System, Detection 134: A Fire Area ID: U (Unit 3) - 4160V Switchgear 4B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 067 4160V Switchgear 4B Room - None R, D, A E Combustible Loading: E Fire Area U Detection System, Alarm Point 2: R A Detection System, Modification - U U3: D Physical separation: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 51 of 58
L-2014-003, Attachment Page 62 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: U (Unit 4) - 4160V Switchgear 4B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 067 4160V Switchgear 4B Room - None R, D, A E, R Combustible Loading: E Fire Area U Detection System, Alarm Point 2: R DA Detection System, Modification - U U4: D ERFBS, Modification U U4: R Physical separation: E Fire Area ID: UU (Unit 3) - Train A SD - Unit 4 Switchgear Room 4D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 139 Unit 4 Switchgear Room 4D - Fire None A E Combustible Loading: E Area UU Detection System, Detection 139: A Fire Area ID: UU (Unit 3) - Train B SD - Unit 4 Switchgear Room 4D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 139 Unit 4 Switchgear Room 4D - Fire None A E Combustible Loading: E Area UU Detection System, Detection 139: A Fire Area ID: UU (Unit 4) - Train A SD - Unit 4 Switchgear Room 4D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 139 Unit 4 Switchgear Room 4D - Fire None A E Combustible Loading: E Area UU Detection System, Detection 139: A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 52 of 58
L-2014-003, Attachment Page 63 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: UU (Unit 4) - Train B SD - Unit 4 Switchgear Room 4D Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 139 Unit 4 Switchgear Room 4D - Fire None A E Combustible Loading: E Area UU Detection System, Detection 139: A Fire Area ID: V (Unit 3) - 4160V Switchgear 4A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 068 4160V Switchgear 4A Room - None R, D, A None Detection System, Alarm Point 2: R A Fire Area V Detection System, Modification - V U3: D Fire Area ID: V (Unit 4) - 4160V Switchgear 4A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 068 4160V Switchgear 4A Room - None R, D, A R, S, N Detection System, Alarm Point 2: R DA Fire Area V Detection System, Modification - V U4: D ERFBS, 068-1: R S N ERFBS, 068-2: R S N ERFBS, 068-3: R S N ERFBS, 068-4: R S N Fire Area ID: W (Unit 3) - Unit 4 Train A Emergency Diesel Generator Control Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 140 Unit 4 Train A Emergency Diesel None A E Combustible Loading: E Generator Control Room - Fire Detection System, All available - VV: A Area VV Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 53 of 58
L-2014-003, Attachment Page 64 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: W (Unit 4) - Unit 4 Train A Emergency Diesel Generator Control Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 140 Unit 4 Train A Emergency Diesel None R, D, A E Combustible Loading: E Generator Control Room - Fire Detection System, All available - W: R D A Area W Fire Area ID: W (Unit 3) - 4160V Switchgear 3B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 070 4160V Switchgear 3B Room - None R, D, A E, R, S, N Detection System, Alarm Point 1: R DA Fire Area W Detection System, Modification - W U3: D ERFBS, 070-1: R S N ERFBS, 070-2: R S N Physical separation: E Fire Area ID: W (Unit 4) - 4160V Switchgear 3B Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 070 4160V Switchgear 3B Room - None R, D, A E Detection System, Alarm Point 1: R D A Fire Area W Detection System, Modification - W U4: D Physical separation: E Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 54 of 58
L-2014-003, Attachment Page 65 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: WW (Unit 3) - Unit 4 Train A Diesel Fuel Oil Handling Areas Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 141 Unit 4 Train A Diesel Oil Transfer E, A A None Detection System, Detection 141: A Pump Room - Fire Area WW Water Suppression, 4-10-1122 (4A): E A 142 Unit 4 Train A Diesel Oil Storage None None None None Tank - Fire Area WW Fire Area ID: WW (Unit 4) - Unit 4 Train A Diesel Fuel Oil Handling Areas Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 141 Unit 4 Train A Diesel Oil Transfer E, A A None Detection System, Detection 141: A Pump Room - Fire Area WW Water Suppression, 4-10-1122 (4A): E A 142 Unit 4 Train A Diesel Oil Storage None None None None Tank - Fire Area WW Fire Area ID: X (Unit 3) - 4160V Switchgear 3A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R, D Procedures/Recovery Actions: R D 071 4160V Switchgear 3A Room - None D, A R, S, N Detection System, Alarm Point 1: D A Fire Area X Detection System, Modification - XU3: D ERFBS, 071-1: R S N ERFBS, 071-2: R S N Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 55 of 58
L-2014-003, Attachment Page 66 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: X (Unit 4) - 4160V Switchgear 3A Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details (All) Area Wide None None R Procedures/Recovery Actions: R 071 4160V Switchgear 3A Room - None R, D, A None Detection System, Alarm Point 1: R D A Fire Area X Detection System, Modification - X U4: D Fire Area ID: XX (Unit 3) - Unit 4 Train B Diesel Fuel Oil Handling Areas Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 136 Unit 4 Train B Diesel Oil Transfer E, A A None Detection System, Detection 136: A Pump Room - Fire Area XX Water Suppression, 4-10-1122 (4B): E A 137 Unit 4 Train B Diesel Oil Storage None None None None Tank -Fire Area XX Fire Area ID: XX (Unit 4) - Unit 4 Train B Diesel Fuel Oil Handling Areas Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 136 Unit 4 Train B Diesel Oil Transfer E, A A None Detection System, Detection 136: A Pump Room - Fire Area XX Water Suppression, 4-10-1122 (4B): E A 137 Unit 4 Train B Diesel Oil Storage None None None None Tank - Fire Area XX Fire Area ID: Y (Unit 3) - Unit 3 Train B Emergency Diesel Generator Building Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 072 Unit 3 Train B Emergency Diesel D, A D, A None Detection System, Alarm Point 16: D A Generator Building - Fire Area Y Water Suppression, 3-10-844: D A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 56 of 58
L-2014-003, Attachment Page 67 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: Y (Unit 4) - Unit 3 Train B Emergency Diesel Generator Building Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 072 Unit 3 Train B Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Building - Fire Area Y Water Suppression, 3-10-844: A Fire Area ID: YY (Unit 3) - Unit 4 Train B Emergency Diesel Generator Control Room Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 135 Unit 4 Train B Emergency Diesel None A E Combustible Loading: E Generator Control Room - Fire Detection System, Detection 135: A Area YY Fire Area ID: YY (Unit 4) - Unit 4 Train B Emergency Diesel Generator Control Room Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 135 Unit 4 Train B Emergency Diesel None R, D, A E Combustible Loading: E Generator Control Room - Fire Detection System, All available - YY: R D A Area YY Fire Area ID: Z (Unit 3) - Unit 3 Train A Emergency Diesel Generator Building Compliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 073 Unit 3 Train A Emergency Diesel D, A D, A None Detection System, Alarm Point 16: D A Generator Building - Fire Area Z Water Suppression, 3-10-847: D A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 57 of 58
L-2014-003, Attachment Page 68 of 92 Attachment C Table C-2 NFPA 805 Required Fire Protection Systems and Features Fire Area ID: Z (Unit 4) - Unit 3 Train A Emergency Diesel Generator Building Compliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area Required Required Suppression Detection Required Fire Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details 073 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: A Generator Building - Fire Area Z Water Suppression, 3-10-847: A Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 58 of 58
L-2014-003, Attachment Page 69 of 92 Fire Protection Engineering RAI 15 The compliance statement for LAR Attachment A, Table B-1, Element 3.4.1 (c) [On-Site Fire-Fighting Capability] is "Complies," with no further elaboration.
Describe how the requirements of NFPA 805, Section 3.4.1 (c) are met, namely either: "the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria," or if the exception is used, which allows the "sufficient training and knowledge" to be provided by an operations advisor.
Clarify whether the exception is used.
Explain the level of training and knowledge of the fire brigade members or the operations advisor (if the exception is used).
An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, Revision 2, "Fire Protection for Operating Nuclear Power Plants," Section 1.6.4.1, "Qualifications," which states:
The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems.
Nuclear power plants staffed with a dedicated professional fire department may use a fire team advisor to assess the potential safety consequences of a fire and advise the control room and incident commander. The fire team advisor should possess an operator's license or equivalent knowledge of plant systems and be dedicated to supporting the fire incident commander during fire emergency events. The fire team advisor does not need to meet the qualifications of a fire brigade member, but if he or she does not, there should be five available qualified fire brigade members, in addition to the fire team advisor."
If applicable, another option available with regard to this attribute is to maintain the fire protection program consistent with existing commitments and use a compliance category of "Complies by previous NRC Approval" in accordance with NFPA 805, Section 3.1.
RESPONSE
PTN currently does not use the exception to NFPA 805, Section 3.4. 1(c). PTN does not use an operations advisor at this time, but reserves the right for future use.
PTN requires the brigade leader and at least two brigade members have sufficient training in or knowledge of plant safety related systems to understand the effects of fire and fire suppressants on safe shutdown capability. This is documented in 0-ADM-16.2, Section 4.2.
"4.2 Fire Brigade - A group of individuals trained and equipped for fire fighting. The Fire Brigade shall consist of at least five members and shall be maintained on site at all times. Fire Brigade composition may be less than the minimum required. for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of Fire Brigade members provided immediate action is taken to restore the Fire Brigade minimum requirements.
4.2.1 The Fire Brigade consists of the Fire Brigade Leader and four other Fire Brigade members who are listed on the active Fire Brigade assignment sheet. The Fire Brigade Leader and at least two Fire Brigade members shall have sufficient training in or knowledge of nuclear safety related systems to understand the effects of fire or fire
L-2014-003, Attachment Page 70 of 92 suppressants on safe shutdown capability. The Fire Brigade shall not include the Shift Manager and the other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency."
The Assistant Operations Manager is responsible for providing five individuals per shift who are qualified to be members of the Fire Brigade, one of which must be a qualified Fire Brigade Leader. The Fire Brigade Leader and at least two Fire Brigade members shall have sufficient training in or knowledge of plant safety related systems to understand the effects of fire and fire suppressants on safe shutdown capability.
The Fire Brigade Leader and two members are fully qualified Nuclear System Operators, who received training in Systems, Off-Normal Operating Procedures, and Fire Protection. Turkey Point Training and Operations have verified that their level of knowledge is commensurate with that of a Licensed Operator for Safe Shutdown systems needed to lead the fire brigade. The brigade is fully manned by Nuclear System Operators.
Nuclear System Operators receive full Systems and Fire Protection Training while in Initial Class. They are required to attend requalification classes throughout the year on operation of the systems and fire event impacts to the control room. Fire Brigade members participate, as a minimum, quarterly in fire drill exercises. Lesson Plans Fire Protection Systems and Alternate Shutdown and Safe Shutdown Appendix R Systems (LP 6902143 and 6902160) are taught during initial Nuclear Systems Operator classes and on a recurring 4 year basis to ensure Fire Brigade Leaders and members remain knowledgeable on plant systems and the effects of a fire on safe shutdown capability. With the exception of component operability determinations the Nuclear Systems Operators objectives in the above lesson plans are exactly the same as Licensed Operators objectives. Both Nuclear System Operators and Licensed Operators are taught the same level of systems training pertaining to Fire Protection and Alternate Safe Shutdown and Appendix R systems. In addition to the training requirements, Fire Brigade Leader selection requires Management Approval and is based on experience and integrated plant knowledge.
Safe Shutdown RAI 17 LAR Attachment B, Table B-2 identifies 10 areas of Nuclear Energy Institute (NEI) 00-01, "Guidance for Post Fire Safe Shutdown Circuit Analysis," guidance using the statement, "Aligns with Intent." For many of these, it is not clear why "aligns with intent" was identified instead of "aligns." For each of the following items, provide a more detailed explanation of what specifically does not align with the guidance.
a) 3.1.3.3 Define Combination of Systems for Each Safe Shutdown Path b) 3.1.3.4 Assign Shutdown Paths to Each Combination of Systems c) 3.2.1.2 Fire Damage to Mechanical Colnponents (not electrically supervised) d) 3.3.1.2 Cables Affecting Multiple Components e) 3.3.1.7 Circuit Coordination f) 3.3.3.1 Identify Circuits Required for the Operation of the Safe Shutdown Equipment g) 3.3.3.3 Assign Cables to the Safe Shutdown Equipment h) 3.5.1.2 Circuit Contacts and Operational Modes i) 3.5.1.5 B, Cable Failure Modes j) 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination
L-2014-003, Attachment Page 71 of 92
RESPONSE
The following additional details explain why PTN's safe shutdown (SSD) methodology for assessing their nuclear safety capability post-fire "Aligns with [the] Intent" of the guidance provided for deterministic methodology in NEI 00-01:
a) 3.1.3.3 Define Combination of Systems for Each Safe Shutdown Path NEI 00-01 Guidance: Select combinations of systems with the capability of performing all of the required safe shutdown functions and designate this set of systems as a safe shutdown path. In many cases, paths may be defined on a divisional basis since the availability of electrical power and other support systems must be demonstrated for each path. During the equipment selection phase, identify any additional support systems and list them for the appropriate path.
Alignment Basis from PTN NFPA 805 LAR: The safe shutdown logics show the combinations of systems available, but specific "paths" are not always identified. Where applicable, specific train, electrical division, and other support systems are evident in the safe shutdown logic diagrams.
Additional Details: Per 5610-M-722A (Nuclear Safety Capability Fire Shutdown Analysis Basis Document), Attachment B, Section 5.2:
"5.2 Safe Shutdown Logic Diagrams The Safe Shutdown Logic Diagrams depict the required plant response at the system and component level to accomplish safe shutdown. The logic diagrams only identify the required condition for SSD components/systems included in the MEL [(Master Equipment List)] and contain two levels of detail. Each is identified and discussed below.
5.2.1 The objective of the System Logic Diagram (SLD) is to provide an overview or road map regarding the plant systems credited to accomplish post-fire safe shutdown. The following guidelines should be used in developing the SLD:
- a. The systems associated with SSD components identified in the MEL should be modeled according to their role in accomplishing safe shutdown given the Nuclear Safety Performance Criteria identified in Section 1.5.1 of NFPA 805.
- b. Each system required to achieve each safe shutdown function should be shown.
- c. Each functional requirement of a system or condition achieved when a system is required to achieve more than one safe shutdown function should be shown separately (e.g., the CVCS System at PTN will be required for RCS makeup, boration, and RCP seal cooling).
- d. The required essential mechanical/electrical and environmental support systems should be shown. However, the specific relationship between the support system and the primary system should not be shown on the SLD; rather, this relationship should be depicted on the appropriate CLD(s) discussed in Section 5.2.2 of this attachment.
L-2014-003, Attachment Page 72 of 92
- e. The required primary and support systems should be combined to depict the achievement of hot and cold shutdown."
This approach was chosen because it was felt that the pictorial representation of the required information provided a more condensed and user friendly approach to identifying the possible paths which the analyst could use to demonstrate safe shutdown (see Figure 1 below). This approach provides all of the various paths which may be used to achieve safe shutdown, but does not explicitly identify each separate path and provide that path with a designation as recommended in the guidance in NET 00-01, Section 3.1.3.3. The specific set of systems used to achieve SSD is identified for each area, but not through any specific path designation. Thus only the intent of the guidance in NEI 00-01, Section 3.1.3.3 is met by the PTN SSD methodology for nuclear safety capability assessment (NSCA). This is the only reason why this section was listed as "Aligns with Intent" in the PTN NFPA 805 LAR.
See also response to b) below.
L-2014-003, Altachment Page 73 of92 7,tCtEARf SAMlY CAPABILSTLOGICDtAGHA3 P" hJNYTFOGI -i -1 SI s ~ ::] R, Figure I - PTN System Logic Diagram from 5610-M-722A Attachment A (Note: Figure is available in the portal for review)
L-2014-003, Attachment Page 74 of 92 b) 3.1.3.4 Assign Shutdown Paths to Each Combination of Systems NEI 00-01 Guidance: Assign a path designation to each combination of systems. The path will serve to document the combination of systems relied upon for safe shutdown in each fire area. Refer to Attachment 1 to this document for an example of a table illustrating how to document the various combinations of systems for selected shutdown paths.
Alignment Basis from PTN NFPA 805 LAR: Path designations are not assigned to each possible combination of systems available to achieve safe shutdown. Rather, a specific combination of systems capable of achieving each performance goal has been identified for each unit for each fire area. Within these credited systems are components and systems relied upon to perform the shutdown function and whose spurious operation could adversely affect that system's ability to achieve its safe shutdown function.
Additional Details: The only reason that the PTN SSD methodology for NSCA only aligns with the intent of this guidance rather than aligning fully is that the safe shutdown paths are not explicitly assigned separate designations. All systems are still identified for each area (thus meeting the intent of the guidance), but those systems are not grouped together and called "Safe Shutdown Path 1", "Safe Shutdown Path 2", etc. as explicitly prescribed by the guidance in NEI 00-01. Not naming the set of systems used to achieve safe shutdown does not adversely affect the ability to perform the safe shutdown analysis.
See also response to a) above.
c) 3.2.1.2 Fire Damage to Mechanical Components (not electrically supervised)
NEI 00-01 Guidance (additional guidance in Revision 2 of NEI 00-01 which was not present in Revision 1 of NET 00-01 is shown in bold and underlined below): Assume that exposure fire damage to manual valves and piping does not adversely impact their ability to perform their pressure boundary or safe shutdown function (heat sensitive piping materials, including tubing with brazed or soldered joints, are not included in this assumption). Fire damage should be evaluated with respect to the ability to manually open or close the valve should this be necessary as a part of the post-fire safe shutdown scenario. For example, post-fire coefficients of friction for rising stem valves cannot be readily determined. Handwheel sizes and rim pulls are based on well lubricated stems. Any post-fire operation of a rising stem valve should be well austified using an engineering evaluation.
Alignment Basis from PTN NFPA 805 LAR: It is assumed in the analysis that mechanical components like those identified will not suffer fire damage to the extent that they will not be able to perform the credited safe shutdown function. The ability to manually operate valves within the fire area (when necessary) is evaluated as part of the manual action feasibility review. Brazed components were assumed not to fail as a result of a fire in this analysis.
Additional Details: In response to Safe Shutdown RAI 01 from the first round of RAls (regarding the assumption that brazed piping would not fail because of fire-induced damage); additional analysis to determine the effect of allowing brazed components to fail was performed. The survivability of brazed components was the only reason why
L-2014-003, Attachment Page 75 of 92 this section was originally listed as "Aligns with Intent". As a result of this analysis, changes were made to the PTN NFPA 805 LAR, included changing this section from "Aligns with Intent" to "Aligns" and changing the alignment basis statement (see Attachment 1, Safe Shutdown RAI 01 and Attachment 2 of FPL Letter L-2013-086 (ADAMS accession number ML13099A441)). As such, this portion of this RAI is no longer applicable.
d) 3.3.1.2 Cables Affecting Multiple Components NEI 00-01 Guidance: Note that the referenced section is for NEI 00-01 Revision 1.
NEI 00-01 Revision 2 has equivalent guidance in section 3.3.1.1.2 (the slight differences in the guidance found in the two documents are shown in the bold and underlined portions below).
NEI 00-01 Revision 1 Guidance: In cases where the failure (including spurious actuations) of a single cable could impact more than one piece of safe shutdown equipment, include the cable with each piece of safe shutdown equipment.
NEI 00-01 Revision 2 Guidance: In cases where the failure (including spurious operations) of a single cable could impact more than one piece of safe shutdown equipment, associate the cable with each piece of safe shutdown equipment.
Alignment Basis from PTN NFPA 805 LAR: Although this specific guidance from this section of NEI 00-01 is not repeated in the cable selection and circuit analysis instruction, it was followed in practice. The procedure requires that ALL cables that could adversely affect the ability of the component to perform its safe shutdown function be identified. Nothing in the procedure or database prevents assigning a safe shutdown cable to more than one component. The procedure also provides guidance on whether an interlocked or off-scheme cable be identified with the component being analyzed or assigned to its own (or another) safe shutdown component and the interrelationship shown on the safe shutdown system logic diagrams.
Additional Details: As described in the alignment basis, there is no instance where this guidance from NEI 00-01 was not actually followed by PTN. The reason that this section was judged to only "Align with Intent" as opposed to "Align" is that the PTN methodology does not explicitly direct analysts to consider and assign cables which can impact multiple components to all of those components. Though not explicitly stated, the intent of this guidance is followed by applying the methodology laid out in Section 6.0 of Attachment C of 5610-M-722A (specifically Sections 6.1.6, 6.1.8, 6.3, 6.4, 6.5, 6.7, and 6.8). Stating that a single cable should be listed against all of the components which it affects was determined to be redundant and an unnecessary amplification of the guidance provided in Section 3.3.1.1 of NEI 00-01 Revision 1 (Section 3.3.1.1.1 of NEI 00-01 Revision 2). PTN's methodology aligns without exception with Section 3.3.1.1 guidance and as a result the circuit analysis performed meets the intent of the guidance in Section 3.3.1.2.
L-2014-003, Attachment Page 76 of 92 e) 3.3.1.7 Circuit Coordination NEI 00-01 Guidance: Note that the referenced section is for NEI 00-01 Revision 1.
NEI 00-01 Revision 2 has equivalent guidance in section 3.3.1.1.5 (the slight differences in the guidance found in the two documents are shown in the bold and underlined portions below).
NEI 00-01 Revision 1 Guidance: Cabling for the electrical distribution system is a concern for those breakers that feed associated circuits and are not fully coordinated with upstream breakers. With respect to electrical distribution cabling, two types of cable associations exist. For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component. For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to an MCC supports the MCC. However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center.
NEI 00-01 Revision 2 Guidance: Cabling for the electrical distribution system is a concern for those breakers that feed circuits and are not fully coordinated with upstream breakers. With respect to electrical distribution cabling, two types of cable associations exist. For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component and classified as a required safe shutdown cable. For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to an MCC supports the MCC.
However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center. Additionally, the non-safe shutdown circuits off of each of the required safe shutdown components in the electrical distribution system can impact safe shutdown if not properly coordinated.
These cables are classified as required for hot shutdown based on the criteria contained in Appendix H.
Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumres coordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPL submittal) that because coordination of circuit protective devices was part of the original electrical system design, associated circuits by common power supply should not exist.
However, this review was for the plant's alternate shutdown capability, and all power supplies being credited in the re-validation may not have been evaluated.
ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2 Items 19 and 20):
Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and 4DP87 (only NSCA power supplies without demonstrated coordination)
L-2014-003, Attachment Page 77 of 92 This task will be performed by FPL.
Additional Details: The only reason this section was determined to only "Align with Intent" as opposed to "Align" with the guidance in NEI 00-01 was because it had been identified during the review of circuit coordination at the plant for all SSD related buses /
panels that coordination had not been analyzed for three of the panels (DP412A, 4DP86, and 4DP87, see item for implementation above). The NSCA had assumed coordination of these panels based on this item for implementation. Until these panels have their coordination demonstrated (which had not occurred by the time of the NFPA 805 LAR submittal), it was felt that it could not be said that PTN aligned with the guidance.
However, because this item for implementation is listed as a committed modification for the NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt that the plant does align with the intent of the guidance.
Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had their coordination demonstrated by FPL calculation PTN-4FJE-12-002. The design change package for DP412A is currently in progress and necessary modification will be implemented for transition to the performance-based fire protection licensing basis.
These details are also applicable to questions g) and j).
f) 3.3.3.1 Identify Circuits Required for the Operation of the Safe Shutdown Equipment NEI 00-01 Guidance: For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including the following documentation to identify the circuits (power, control, instrumentation) required for operation or whose failure may impact the operation of each piece of equipment:
- Single-line electrical diagrams
- Elementary wiring diagrams
- Electrical connection diagrams
- Instrument loop diagrams.
For electrical power distribution equipment such as power supplies, identify any circuits whose failure may cause a coordination concern for the bus under evaluation.
If power is required for the equipment, include the closest upstream power distribution source on the safe shutdown equipment list. Through the iterative process described in Figures 3-2 and 3-3, include the additional upstream power sources up to either the offsite or the emergency power source.
Alignment Basis from PTN NFPA 805 LAR: The analyst obtained the applicable schematic diagrams and other available design input documentation to perform an adequate circuit analysis of the component's ability to perform its safe shutdown function (including availability of power supplies) as required by the circuit analysis and cable selection instruction.
Additional Details: The only reason this section was listed as "Aligns with Intent" instead of "Aligns" in the PTN NFPA 805 LAR is because the guidance in NEI 00-01 is written such that, if taken literally, that single-line electrical diagrams, elementary wiring diagrams, electrical connection diagrams, and instrument loop diagrams would be reviewed for every piece of safe shutdown equipment. This was obviously not the intent of the section as there are many pieces of safe shutdown equipment which would not
L-2014-003, Attachment Page 78 of 92 show up on an instrument loop diagram (e.g., MOVs which do not have an auto open /
close signal) or even some of the other diagrams listed. Also, elementary wiring diagrams at PTN have block diagrams which provide all necessary cable information such that reviewing electrical connection diagrams is only required when performing circuit analysis on an instrument loop. If the guidance was meant to be written as
"... review the electrical diagrams including the following documentation as appropriate ... ", then the PTN methodology would align with the guidance because review of all of the listed documentation would be performed only as it would be applicable to the specific analysis.
g) 3.3.3.3 Assign Cables to the Safe Shutdown Equipment NEI 00-01 Guidance (additional guidance in Revision 2 of NEI 00-01 which was not present in Revision 1 of NET 00-01 is shown in bold and underlined below): Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in mal-operation of each piece of safe shutdown equipment. Cables are classified as either required for hot shutdown or important to SSD based on the classification of the component to which they are associated and the function of that component in supporting post-fire safe shutdown in each particular fire area. Refer to Appendix H for additional guidance.
Tabulate the list of cables potentially affecting each piece of equipment in a relational database including the respective drawing numbers, their revision and any interlocks that are investigated to determine their impact on the operation of the equipment. In certain cases, the same cable may support multiple pieces of equipment. Relate the cables to each piece of equipment, but not necessarily to each supporting secondary component.
If adequate coordination does not exist for a particular circuit, relate the power cable to the power source. This will ensure that the power source is identified as affected equipment in the fire areas where the cable may be damaged. Criteria for making the determination as to which cables are to be classified as required for hot shutdown or as important to SSD is contained in Appendix H.
Alignment Basis from PTN NFPA 805 LAR: The required cables for each component have been identified and tabulated in a relational database. The circuit analysis and cable selection instruction assumes coordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPL submittal) that because coordination of circuit protective devices was part of the original electrical system design, associated circuits by common power supply should not exist. However, this review was for the plant's alternate shutdown capability, and all power supplies being credited in the re-validation may not have been evaluated.
ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2 Items 19 and 20):
Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and 4DP87 (only NSCA power supplies without demonstrated coordination)
This task will be performed by FPL.
Additional Details: The only reason this section was determined to only "Align with Intent" as opposed to "Align" with the guidance in NEI 00-01 was because it had been
L-2014-003, Attachment Page 79 of 92 identified during the review of circuit coordination at the plant for all SSD related buses /
panels that coordination had not been analyzed for three of the panels (DP412A, 4DP86, and 4DP87, see item for implementation above). The NSCA had assumed coordination of these panels based on this item for implementation. Until these panels have their coordination demonstrated (which had not occurred by the time of the NFPA 805 LAR submittal), it was felt that it could not be said that PTN aligned with the guidance.
However, because this item for implementation is listed as a committed modification for the NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt that the plant does align with the intent of the guidance.
Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had their coordination demonstrated by FPL calculation PTN-4FJE-12-002. The design change package for DP412A is currently in progress and necessary modification will be implemented for transition to the performance-based fire protection licensing basis.
These details are also applicable to questions e) and j).
h) 3.5.1.2 Circuit Contacts and Operational Modes NEI 00-01 Guidance: Note that the referenced section is for NEI 00-01 Revision 1.
NEI 00-01 Revision 2 has equivalent guidance in section 3.5.1.3 (the slight difference in the guidance found in the two documents are shown in the bold and underlined portions below).
NEI 00-01 Revision 1 Guidance: Assume that circuit contacts are positioned (i.e., open or closed) consistent with the normal mode/position of the safe shutdown equipment as shown on the schematic drawings. The analyst must consider the position of the safe shutdown equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the safe shutdown equipment.
NET 00-01 Revision 2 Guidance: Assume that circuit contacts are initiallV positioned (i.e., open or closed) consistent with the normal mode/position of the "required for hot shutdown" or "important to safe shutdown" equipment as shown on the schematic drawings. The analyst must consider the position of the "required for hot shutdown" and "important to safe shutdown" equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the "required for hot shutdown" and "important to safe shutdown equipment".
Alignment Basis from PTN NFPA 805 LAR: The analysis assumes components are in their normal operating position or condition, and this is understood to include contacts within the components' electrical circuits. Specific instructions are provided concerning local control station isolation switches and transfer switches. Analysis also evaluates potential for contacts to reposition during the course of a normal shutdown to CSD or other impacts from the selected safe shutdown success path.
Additional Details: PTN methodology meets all of the associated NEI guidance and even provides direction to perform additional analysis beyond that in the NEI guidance to provide an additional level of assurance of the capability to safely shutdown. The additional guidance directs analysts to consider contacts in positions other than the
L-2014-003, Attachment Page 80 of 92 normal position if those contacts could reposition due to other than fire-induced causes (e.g., depressurization during operations to proceed to cold shutdown will change the position of many RCS Pressure contacts which could affect spurious operation /
maloperation of components). Because these analyses considered contact positions other than the positions which would occur under normal operating conditions, it was felt that the methodology could not be said to "Align" in the strictest sense with the NEI guidance, even though all analyses (without exception) at least consider the normal position of contacts and may consider other contact positions which could exacerbate the effects of the fire. For alternate shutdown areas, circuit analysis was also performed which evaluated the effectiveness of the transfer switches (both in the normal and isolate positions) to isolate the circuit / restore operability of the component following the fire.
i) 3.5.1.5 B, Cable Failure Modes NEI 00-01 Guidance: Note that the referenced section is for NET 00-01 Revision 1.
NEI 00-01 Revision 2 deleted the guidance which was present in this section.
NEI 00-01 Revision 1 Guidance: Cable Failure Modes. For multiconductor cables testing has demonstrated that conductor-to-conductor shorting within the same cable is the most common mode of failure. This is often referred to as "intra-cable shorting." It is reasonable to assume that given damage, more than one conductor-to-conductor short will occur in a given cable. A second primary mode of cable failure is conductor-to-conductor shorting between separate cables, commonly referred to as "inter-cable shorting." Inter-cable shorting is less likely than intra-cable shorting. Consistent with the current knowledge of fire-induced cable failures, the following configurations should be considered:
A. For any individual multiconductor cable (thermoset or thermoplastic), any and all potential spurious actuations that may result from intra-cable shorting, including any possible combination of conductors within the cable, may be postulated to occur concurrently regardless of number. However, as a practical matter, the number of combinations of potential hot shorts increases rapidly with the number of conductors within a given cable. For example, a multiconductor cable with three conductors (3C) has 3 possible combinations of two (including desired combinations), while a five conductor cable (5C) has 10 possible combinations of two (including desired combinations), and a seven conductor cable (7C) has 21 possible combinations of two (including desired combinations). To facilitate an inspection that considers most of the risk presented by postulated hot shorts within a multiconductor cable, inspectors should consider only a few (three or four) of the most critical postulated combinations.
B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration
. of thermoset cable inter-cable shorts is deferred pending additional research.)
C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently. The spurious actuations should be evaluated as previously described. The
L-2014-003, Attachment Page 81 of 92 consideration of more than two cables being damaged (and subsequent spurious actuations) is deferred pending additional research.
D. For cases involving direct current (DC) circuits, the potential spurious operation due to failures of the associated control cables (even if the spurious operation requires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus and minus-to-minus) should be considered when the required source and target conductors are each located within the same multiconductor cable.
E. Instrumentation Circuits. Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits. There is one case where an instrument circuit could potentially be considered an associated circuit. If fire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly.
Alignment Basis from PTN NFPA 805 LAR: Cable selection considered any and all hot shorts, regardless of whether these hot shorts were inter-cable or intra-cable. No restriction was placed on the number of cables or hot shorts required to fail the component/circuit. No credit was taken for relative risk due to conductor combinations available for a fault. All cables were conservatively assumed to be Thermo-plastic.
Cables were not excluded because of being instrumentation cables or because they were part of a DC circuit requiring multiple hot shorts of proper polarity.
Additional Details: The PTN methodology was deemed to align with the intent of the guidance in NEI 00-01 Revision I rather than aligning with the explicit guidance because the PTN methodology took a conservative approach on the guidance provided in B (potential for inter-cable shorting based on cable material) and C (number of concurrently damaged cables which must be assumed) rather than strictly following the guidance as written.
For the guidance provided in B, inter-cable shorting was considered possible even if the only cables in the fire area were thermoset cables. For the guidance provided in C, the number of inter-cable hot shorts which could occur in an area would not be limited. The inclusion of these potential failure modes can only make the results at PTN more conservative and thereby provides a greater assurance of the ability of the plant to safely shutdown.
j) 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination NEI 00-01 Guidance: Note that slight differences exist between the guidance as written in this section for NEI 00-01 Revision 1 and NEI 00-01 Revision 2. The differences in the guidance found in the two documents are shown in bold and underlined below.
NEI 00-01 Revision 1 Guidance: The evaluation of associated circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown. The concern is that, for fire damage to a single power cable, lack of coordination between the
L-2014-003, Attachment Page 82 of 92 supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.
To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the associated circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.
A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus.
Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.
The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows:
Identify the power sources required to supply power to safe shutdown equipment.
For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.
For each power source, demonstrate proper circuit coordination using acceptable industry methods.
For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the associated circuit cables of concern are routed and the power source is required for safe shutdown. Prepare a list of the following information for each fire area:
" Cables of concern.
" Affected common power source and its path.
" Raceway in which the cable is enclosed.
" Sequence of the raceway in the cable route.
1 Fire zone/area in which the raceway is. located.
- For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods.
L-2014-003, Attachment Page 83 of 92 Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source.
Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.
NEI 00-01 Revision 2 Guidance: The evaluation of circuits of a common power source consists of verifying proper coordination between the supply breaker/fuse and the load breakers/fuses for power sources that are required for hot shutdown. The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.
For the example shown in Figure 3.5.2-6, the circuit powered from load breaker 4 supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the same fire area as the circuit providing power to from the Train B bus to the Train B pump, which is redundant to the Train A pump.
To assure safe shutdown for a fire in this fire area, the damage to the non-safe shutdown pump powered from load breaker 4 of the Train A bus cannot impact the availability of the Train A pump, which is redundant to the Train B pump. To assure that there is no impact to this Train A pump due to the circuits' common power source breaker coordination issue, load breaker 4 must be fully coordinated with the feeder breaker to the Train A bus.
A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus.
Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.
The methodology for identifying potential circuits of a common power source and evaluating circuit coordination cases on a single circuit fault basis is as follows:
" Identify the power sources required to supply power to safe shutdown equipment.
" For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.
" For each power source, demonstrate proper circuit coordination using acceptable industry methods. For example, for breakers that have internal breaker tripping devices and do not require control power to trip the breaker, assure that the time-current characteristic curve for any affected load breaker is to the left of the time-current characteristic curve for the bus feeder breaker and that the available short circuit current for each affected breaker is to the right of the time-current characteristic curve for the bus feeder breaker or that.the bus feeder breaker.has a longer time delay in the breaker instantaneous range than the load breaker. For breakers requiring control power for the breaker to trip, the availability of the required control power must be demonstrated in addition to the proper alignment of the time-
L-2014-003, Attachment Page 84 of 92 current characteristic curves described above. The requirement for the availability of control power would apply to load breakers fed from each safe shutdown bus where a fire-induced circuit failure brings into questions the availability of coordination for a required for hot shutdown component.
For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the circuit of concern are routed and the power source is required for hot shutdown. Prepare a list of the following infornation for each fire area:
o Cables of concern.
" Affected common power source and its path.
o Raceway in which the cable is enclosed.
o Sequence of the raceway in the cable route.
o Fire zone/area in which the raceway is located.
For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods.
" Develop analyzed safe shutdown circuit dispositions for the circuit of concern cables routed in an area of the same path as required by the power source.
Evaluate adequate separation and other mitigation measures based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.
Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumes coordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPL submittal) that because coordination of circuit protective devices was part of the original electrical system design, associated circuits by common power supply should not exist.
However, this review was for the plant's alternate shutdown capability, and all power supplies being credited in the re-validation may not have been evaluated.
ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2 Items 19 and 20):
Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and 4DP87 (only NSCA power supplies without demonstrated coordination)
This task will be performed by FPL.
Additional Details: The only reason this section was determined to only "Align with Intent" as opposed to "Align" with the guidance in NEI 00-01 was because it had been identified during the review of circuit coordination at the plant for all SSD related buses /
panels that coordination had not been analyzed for three of the panels (DP412A, 4DP86, and 4DP87, see item for implementation above). The NSCA had assumed coordination of these panels based on this-item for implementation. Until these panels have their coordination demonstrated (which had not occurred by the time of the NFPA 805 LAR submittal), it was felt that it could not be said that PTN aligned with the guidance.
However, because this item for implementation is listed as a committed modification for
L-2014-003, Attachment Page 85 of 92 the NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt that the plant does align with the intent of the guidance.
Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had their coordination demonstrated by FPL calculation PTN-4FJE-12-002. The design change package for DP412A is currently in progress and necessary modification will be implemented for transition to the performance-based fire protection licensing basis.
These details are also applicable to questions g) and j).
Safe Shutdown RAI 18 LAR Attachment F identifies the steps used to perform the multiple spurious operations (MSO) evaluation. Provide the following additional details of the evaluation performed:
a) Currently the LAR identifies "representatives from PTN [PTN is the licensee's acronym for Turkey Point] fire protection and post-fire safe shutdown, PTN Operations/PRA [probabilistic risk assessment], and supporting contract staff' as having participated in the MSO expert panel review. Describe in more detail the composition of the expert panel, including qualifications, background, and experience.
b) Describe the criteria used in the decision process for resolution(s).
c) Currently the LAR indicates that "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations."
Provide more detail regarding the manner in which they occur (e.g., sequentially or simultaneously), and the time between spurious actuations (as supported by engineering analysis, test results, or both).
d) Provide typical MSO justifications or rationale for MSOs being eliminated from further evaluation. Include a description of the configuration control mechanisms that ensures these exclusion bases will remain valid.
RESPONSE
a). The qualifications, background, and experience of the MSO expert panel members are judged to be sufficient and consistent with the guidance of Frequently Asked Question 07-0038. The report entitled "Expert Panel for Addressing Multiple Spurious Operations" includes a listing of panel participants, their specific areas of expertise and experience, and resumes/experience summaries. As discussed in the report, the expert panel individuals included specific experience in (by individual):
" Turkey Point Systems/Operations/Internal Events PRA
" FPL Turkey Point Design Engineering, Fire Protection
" Safe Shutdown, Turkey Point Safe Shutdown Analysis, Circuit Analysis Turkey. Point Fire PRA,. System. Engineering ......
- Safe Shutdown, Circuit Analysis, NFPA 805 MSO Process
L-2014-003, Attachment Page 86 of 92
" Turkey Point Safe Shutdown, Circuit Analysis
" Turkey Point Fire PRA, Safe Shutdown All members of the panel, with the exception of one, have over 20 years of nuclear power plant experience. The panel includes individuals with degrees in Mathematics, Nuclear Engineering, Electrical Engineering, and Civil Engineering. The panel also included individuals that had participated in the development of the MSO resolution process for the industry, as well as participants in MSO expert panels for other plants.
b) As discussed in Attachment F of the PTN LAR, consensus was achieved in the expert panel process by discussing individual scenarios, reaching a conclusion, and asking for any dissenting opinions. In addition, as discussed in report entitled "Expert Panel for Addressing Multiple Spurious Operations", project action items were created when the panel members were unsure or if additional research was needed.
c) The statement "the proposed scenarios should not have presupposed limits on the number of fire-induced hot shorts or spurious operations." referred to in the RAI question was a discussion of the training conducted for the MSO Expert Panel. The intent of this discussion point was to not exclude scenarios during the expert panel meeting at the start because of likelihood only.
This guidance was followed to ensure that a broad list of scenarios was identified for further refinement, as necessary, by the nuclear safety capability assessment (NSCA) and Fire PRA. No restrictions were placed on the MSO Expert Panel regarding the sequential or simultaneous nature of circuit failures or the time between spurious actuations.
d) Different MSO justifications and/or rationale for MSOs being eliminated from further evaluation were utilized. Individual scenarios from the PWROG generic list and plant specific scenarios were reviewed by the expert panel. Example dispositions include:
" Scenario was not applicable to PTN (e.g., Spurious operation of hot leg high point vent valves, which are not installed at PTN).
" Scenario precluded by plant design/configuration:
o Pump runout scenarios where the PTN-specific pump was a positive displacement pump and not subject to runout conditions o Normally closed manual valve downstream of valves in question, prevent flow diversion.
o Motor operated valves at PTN were used for piggy-back operation. MOVs are maintained closed (and breakers are de-energized and locked) for non-high low pressure interface/high consequence components.
The post-transition change evaluation process, as described in Section 4.7.2, Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805, of the PTN LAR, will be utilized to maintain the configurations that support MSO exclusions. The responses to Programmatic RAI 4 and Programmatic RAI 5 also address configuration control and the post-transition change evaluation. This process will include the review of plant changes for impact on meeting the nuclear safety'perforrrmance criteria, and would include the consideration of plant configuration or operational changes that could adversely impact the nuclear safety capability assessment or Fire PRA.
L-2014-003, Attachment Page 87 of 92 Safe Shutdown RAI 19 LAR Attachment C for each fire area identifies performance goals, method of accomplishment, and applicable variance from deterministic requirements. The decay heat performance goal is the only goal that is identified as hot standby and cold shutdown. Provide a description of why cold shutdown is provided for this performance goal. Describe if any other performance goals include cold shutdown in the performance evaluation.
RESPONSE
In response to the "provide a description of why CSD is provided for this performance goal" part of this RAI:
A cold shutdown (CSD) evaluation of the Decay Heat Removal Performance Goal is provided because there are two distinct methods analyzed by PTN to remove decay heat post-fire. One of these methods is most often associated with providing decay heat removal when the plant is in a hot shutdown (HSD) state and the other when the plant is in a CSD state.
During normal, at-power operations and immediately following a fire, Reactor Coolant System (RCS) pressure and temperature exceed the upper limits of the operating temperature and pressure of the Residual Heat Removal (RHR) system (350'F and 450 psig; design temperature and pressure is 400'F and 600 psig per 5610-050-DB-001). As such, the RHR system cannot be used until the plant has been cooled down and depressurized to below these limits. This cooldown (CD) and depressurization requires a different system which is capable of removing decay heat generated by the reactor and sensible heat stored in the RCS until the RHR system can be placed on service.
The systems which may be used for CD and depressurization until plant conditions permit entry onto the RHR system are the Auxiliary Feedwater (AFW) System or the Feedwater System using the Standby Steam Generator Feed Pump (SSGFP). The AFW system receives its water supply from the Condensate Storage Tanks (CSTs) and the SSGFP receives its water from the Demineralized Water Storage Tank (DWST). The ability to make-up to any of these tanks indefinitely from on-site or off-site sources has not been demonstrated to exist following a fire 1 .
As such, in accordance with the definition of safe and stable provided in Section 4.2.1.2 of the PTN NFPA 805 LAR:
"The final end state for safe and stable will be determined by the extent of equipment damage, existing inventory in the condensate storage tank, and the ability to provide makeup to the condensate storage tank. If any of these conditions indicate it is advisable Note that the CSTs and DWST are capable of being refilled from the Raw Water Tanks (RWTs) via the Fire Protection system to temporarily extend AFW / SSGFP operations if required. The CSTs and DWST have adequate inventories for many hours of decay heat removal and CD of the reactor. Because of the effect that raw water could have on steam generator chemistry, the use of the RWTs would only be done if an unforeseen circumstance significantly delayed the ability to transfer decay heat removal operations tothe RHRIsystem. By the'time plant conditionswould necessitate the use of the.RWTs; those same symptoms would have led operators to begin cooling down the plant in preparation for going onto RHR. Thus the capability to use the RWTs is addressed in the Decay Heat Removal (CSD) performance goal.
L-2014-003, Attachment Page 88 of 92 to place RHR system in service then the plant will have the capability to do so. As a result, the equipment required to initiate and maintain hot shutdown cooling including the initiation of RHR cooling remains part of the at-power analysis. Initiation of RHR cooling does not imply however, that the plant would proceed all the way to CSD. The plant may remain on RHR cooling at other than CSD conditions for an extended period
- of time."
Neither the AFW nor the Feedwater system uses any components, material, or supporting systems (except for instrument air - if available - and low voltage power) that are in common with the RHR system. Because of this complete independence between the two approaches to decay heat removal and because both approaches may be required to satisfy the requirements for the Decay Heat Removal Performance Goal from NFPA 805 Section 1.5.1 (c), it is appropriate to provide separate performance goals in Attachment C of the PTN NFPA 805 LAR to address the approach used in each plant state. Though the operators may use all of the systems mentioned above while the plant is in a HSD state per the Technical Specifications (Tech Specs), the distinction of the systems identified in the performance goals as HSD or CSD was done based on:
- 1. The plant states with which the systems are most commonly associated when in operation
- 2. Not requiring time critical manual actions to ensure the ability to safely shutdown the plant.
In response to the "describe if any other performance goals include CSD in the performance evaluation" part of this RAI:
All performance goals at PTN are inherently part of both HSD and CSD operations. Even the Decay Heat Removal Performance Goals discussed above are not distinctly limited to HSD and CSD plant conditions. Tech Specs Table 1.2 indicates that the plant is in a HSD condition if Keff
<0.99 and 350 0 F>Tavg>200'F; which is entirely within the operating limits of the RHR system.
The SSGFP can also continue to remove decay heat with the plant in a CSD condition (Keff
<0.99, Tavge<200°F per Tech Specs). In fact, for the period during which decay heat removal transitions from one approach to another, there must be an overlap.
As illustrated in 5610-M-722A (Nuclear Safety Capability Fire Shutdown Analysis Basis Document), Attachment A (see figure 1 below), all systems / safety functions which are required to be available to support HSD operations are also required to support CSD operations. There are three additional safety functions which were determined to be required only prior to plant CD in preparation for CSD / RHR operations. Those safety functions are Decay Heat Removal (CSD), RCS Pressure Control, and Reactivity Control (CD/CSD).
Decay Heat Removal (CSD) requires the availability of the RHR and Fire Protection systems as discussed above. The RCS Pressure Control Performance Goal requires the availability of the Power Operated Relief Valves (PORVs) and the Pressurizer Backup Heaters to ensure that plant pressure is acceptable for the given plant temperature and conditions. This function tends to be of greater importance during times when plant temperatures are being changed, such as when cooling down in preparation to use the RHR system. The Reactivity Control (CD/CSD) Safety Function'- is shown in Attachment C of the PTN NFPA 805 LAR as ipart of the Reactivity Control Performance Goal along with the Reactivity Control (Trip) Safety Function. The Reactivity Control (CD/CSD) Safety Function consists of the systems and components necessary to ensure
L-2014-003, Attachment Page 89 of 92 adequate RCS boration is established. This safety function is only necessary to offset positive reactivity inserted from xenon decay (which is only significant after many hours of being shut down) or from cooling down the RCS. Though the operator may use all of the systems mentioned above while the plant is in a HSD state per the Tech Specs, the distinction of the systems identified in the performance goals as HSD or CSD was done based on the plant states which most closely related to when the systems would be required and to readily distinguish safety functions which would not require time critical manual actions to ensure the ability to safely shutdown the plant.
L-2014-003. Atachment Page 90 of 92 ILPPLNDIDR
.WCLZAR SAFETY CAPAI'fLITY LOGIC DIAGRAMI
- LOGIC NO Re
- ~-SS502 Figure 1 - PTN System Logic Diagram from 5610-M-722A Attachment A (Note: Figure is available in the portal for review)
L-2014-003, Attachment Page 91 of 92 Fire Modeling RAT 01.01 In a letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), the licensee responded to Fire Modeling RAIs 01 .j and 01 .k, which make reference to "additional work." For this reason, a final review of these RAI responses could not be completed.
" FM RAI 01 .j pertains to the use of the Generic Fire Modeling Treatments (GFMTs) to determine the zone of influence (ZOI) for fires that involve intervening combustibles.
" FM RAI 01 .k requests that the licensee describe how fire propagation in cable trays and the corresponding heat release rate (HRR) are calculated, and explain how the fire propagation and HRR estimates affect the ZOI determination and hot gas layer calculations.
The NRC staff noted that the "additional work" will also affect the evaluation of the responses to FM RAI 0 1 .p (wall and comer effects), FM RAI 04 (application of GFMTs outside limitations of use), and several PRA RAIs.
Provide the results of this "additional work" to the NRC staff for review and describe any changes to the conclusions regarding core damage frequency (CDF), delta (A) CDF, large early release frequency (LERF), and ALERF resulted from the "additional work."
RESPONSE
The additional work associated with the first round Fire Modeling (FM) RAI responses, including FM RAI 01 .j and FM RAI 01 .k, is provided in the following documents:
" Report 0027-0067-002-001, "Supplemental Generic Fire Modeling Treatments: Transient Fuel Package Ignition Source Characteristics," Rev. 0. This document provides Zone of Influence (ZOI) tables and their limitations for transient ignition sources in open, wall, and comer configurations.
" Report 0027-0067-002-002, "Combined Ignition Source - Cable Tray Fire Scenario ZOIs for Turkey Point Nuclear Power Plant Applications," Rev. 1. This document provides ZOI tables for specific ignition source - secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0. The heat release rates are computed using guidance provided in NUREG/CR-6850 and NUREG/CR-7010, Volume 1. The ZOIs are computed using the methods described in Report 1SPH02902.030, Rev. 0 (Generic Fire Modeling Treatments).
" Report 0027-0067-002-003, "Walkdowns: Secondary Combustible Configurations," Rev.
- 0. This document provides an assessment of the secondary combustible configurations for ignition sources at PTN.
" Report 0027-0067-002-004, "Evaluation of the Development and Timing of Hot Gas Layer Conditions in Generic PTN Fire Compartments with Secondary Combustibles,"
Rev. 1. This document provides Hot Gas Layer (HGL) tables for specific ignition source
- secondary combustible configurations identified in Report 0027-0067-002-003, Rev. 0.
The HGL tables are evaluated in generic enclosures using the methods described in Report 1SPH02902.030, Rev. 0 (Generic Fire Modeling Treatments) and is based on a compilation of 29,970 new CFAST simulations.
" Report 0027-0067-002-005, "Evaluation of Control Room Abandonment Times at the Turkey Point Nuclear Power Plant," Rev. 0. This document is the updated control room abandonment report.
These reports have been placed on the portal and are available for review. The fire PRA has incorporated the new information from these reports and will provide the final core damage
L-2014-003, Attachment Page 92 of 92 frequency (CDF), ACDF, large early release frequency (LERF), and ALERF with the response to PRA-RAI-29.
Fire Modeling RAI 02.01 In letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), in response to FM RAI 02.e, the licensee referred to Fire PRA Frequently Asked Question (FAQ) 13-0004 to justify the use of cable damage thresholds as the criteria for sensitive electronics inside an enclosure. Fire PRA FAQ 13-0004 was still under development at the time the response was submitted, and the licensee therefore stated, "Resolution of this issue will be re-assessed once the FAQ is finalized."
Provide the results of the re-assessment. Quantify the impact of any changes to the guidelines in the final version of Fire PRA FAQ 13-0004 on CDF, LERF, ACDF, and ALERF; or justify why these changes need not be considered.
RESPONSE
In accordance with the guidance provided in Fire PRA FAQ 13-0004, sensitive electronics within a panel enclosure are expected to survive an external fire based on the use of thermoset cable damage criteria as a basis for panel and internal component damage. The use of thermoplastic cable damage criteria for the Turkey Point Fire PRA provides additional margin with respect to that defined in the FAQ. A walkdown was performed to identify exposed sensitive electronics susceptible to fire damage. This walkdown was performed using the criteria in the final version of Fire PRA FAQ 13-0004. The walkdown produced no instances of exposed sensitive electronics. Based on the use of thermoplastic damage criteria for panels and internal components and the lack of exposed sensitive electronics, the application of the FAQ 13-0004 methodology does not result in an increase in CDF, LERF, ACDF, and ALERF.