Text

January 2008 - Transition to National Fire Protection Association (NFPA) 805 - Example Table B-1, Shearon Harris Nuclear Power Plant, Unit 1, January 7, 2008
	ML080280567
Person / Time
Site:	Harris
Issue date:	01/07/2008
From:	Ertman J; Progress Energy Co
To:	; Office of Nuclear Reactor Regulation
	Oudinot D
References
	Download: ML080280567 (33)
	v • d • e

NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.1 General N/A All Plant USA-M/BMRK-0011, Code Compliance Evaluation NFPA 805,2003,, Rev. 000, 3.1* General.

This chapter contains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features.

These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.

N/A - General statement; No technical requirements 3.2 Fire Protection Plan N/A , , Rev. , N/A N/A - General statement; No technical requirements 3.2.1 Intent Complies , , Rev. , 3.2.1 Intent.

A site-wide fire protection plan shall be established. This plan shall document management policy and program direction and shall define the responsibilities of those individuals responsible for the plan's implementation. This section establishes the criteria for an integrated combination of components, procedures, and personnel to implement all fire protection program activities No Additional Clarification 3.2.2 Management Policy Direction and Responsibility.

Complies , , Rev. , 3.2.2* Management Policy Direction and Responsibility.

A policy document shall be prepared that defines management authority and responsibilities and establishes the general policy for the site fire protection program.No Additional Clarification 3.2.2.1 [Management Policy on Senior Management]

Complies , , Rev. , 3.2.2.1*The policy document shall designate the senior management position with immediate authority and responsibility for the fire protection program.

No Additional Clarification 3.2.2.2 [Management Policy on Daily Administration]

Complies , , Rev. , 3.2.2.2*The policy document shall designate a position responsible for the daily administration and coordination of the fire protection program and its implementation.

No Additional Clarification 3.2.2.3 [Management Policy on Interfaces]

Complies , , Rev. , 3.2.2.3*The policy document shall define the fire protection interfaces with other organizations and assign responsibilities for the coordination of activities. In addition, this policy document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.

No Additional Clarification 3.2.2.4 [Management Policy on AHJ]

Further Action Required , , Rev. , 3.2.2.4*The policy document shall identify the appropriate AHJ for the various areas of the fire protection program.

Page 1 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.2.3 Procedures Complies , , Rev. , 3.2.3* Procedures.

Procedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:

(1)

Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program (2)

Compensatory actions implemented when fire protection systems and other systems credited by the fire protection program and this standard cannot perform their intended function and limits on impairment duration (3)

Reviews of fire protection program - related performance and trends (4) Reviews of physical plant modifications and procedure changes for impact on the fire protection program (5) Long-term maintenance and configuration of the fire protection program (6) Emergency response procedures for the plant industrial fire brigade.

No Additional Clarification 3.3 Prevention N/A , , Rev. , 3.3 Prevention.

A fire prevention program with the goal of preventing a fire from starting shall be established, documented, and implemented as part of the fire protection program. The two basic components of the fire prevention program shall consist of both of the following:

(1) Prevention of fires and fire spread by controls on operational activities (2) Design controls that restrict the use of combustible materials The design control requirements listed in the remainder of this section shall be provided as described.

N/A - General statement; No technical requirements 3.3.1 Fire Prevention for Operational Activities.

Complies NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.3.1 Fire Prevention for Operational Activities.

The fire prevention program activities shall consist of the necessary elements to address the control of ignition sources and the use of transient combustible materials during all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.

No Additional Clarification Page 2 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.1.1 General Fire Prevention Activities.

(1) Further Action Required , , Rev. , 3.3.1.1 General Fire Prevention Activities.

The fire prevention activities shall include but not be limited to the following program elements:

(1) Training on fire safety information for all employees and contractors including, as a minimum, familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarms (2)

Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identified (3)

Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized.

FAQ 06-0028 Rev 0 (2) Complies OMM-001, Operations-Conduct of Operations, Rev. 067, AP-930, Plant Observation Program, Rev. 005, AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026, No Additional Clarification (3) Complies EGR-NGGC-0005, Engineering Change, Rev.

026, ADM-NGGC-0104, Work Management Process, Rev.

030, No Additional Clarification Page 3 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.1.2 Control of Combustible Materials (1) Complies , , Rev. , 3.3.1.2* Control of Combustible Materials.

Procedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements: (1)

Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.

Exception: Cribbing timbers 6 in. by 6 in. (15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.

(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.

(4)

Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.

(5)

Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.

(6)

Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

FAQ 06-0019 Rev 0 (2) Complies , , Rev. , FAQ 06-0019 Rev 0 (3) LAR , , Rev. , (4) Complies , , Rev. , No additional clarification (5) Complies with Clarification , , Rev. , FAQ 06-0020 Rev 0 (6) Complies , , Rev. , No additional clarification 3.3.1.3 Control of Ignition Sources N/A , , Rev. , 3.3.1.3 Control of Ignition Sources N/A - General statement no technical requirements 3.3.1.3.1 [Control of Ignition Sources Code Requirements]

Further Action Required All FIR-NGGC-0003, Hot Work Permit, Rev. 001, 3.3.1.3.1*

A hot work safety procedure shall be developed, implemented, and periodically updated as necessary in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

FAQ 06-0020 Rev 0 Page 4 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.1.3.2 [Control of Ignition Sources on Smoking Limitations]

Complies with Clarification Section 6.2.6.5 AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026, 3.3.1.3.2 Smoking and other possible sources of ignition shall be restricted to properly designated and supervised safe areas of the plant.

Smoking is prohibited inside all site structures, and only allowed in specific designated outside areas per procedure AP-003. Restrictions for other possible ignition sources are addressed by section 3.3.1.3.1,3,4.

3.3.1.3.3 [Control of Ignition Sources for Leak Testing]Complies , , Rev. , 3.3.1.3.3 Open flames or combustion-generated smoke shall not be permitted for leak or air flow testing No Additional Clarification 3.3.1.3.4 [Control of Ignition Sources on Portable Heaters]

Further Action Required Section 5.3 AP-003, General Plant Personnel Safety and Housekeeping, Rev. 026, 3.3.1.3.4*

Plant administrative procedure shall control the use of portable electrical heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

3.3.2 Structural.

Complies Via Previous Approval SER - SSER4 Section C.5.A(9)

NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.3.2 Structural.

Walls, floors, and components required to maintain structural integrity shall be of noncombustible construction, as defined in NFPA 220, Standard on Types of Building Construction.

Submittal Document NLS-86-137 Project Conformance C.5.a(9) - "Interior walls and structural components, radiation shielding materials, and soundproofing are noncombustible." NUREG 1038 states in part "Interior walls and structural components, are noncombustible or are listed by a nationally recognized testing laboratory, such as Factory Mutual (FM) or UL, or have flame-spread, smoke, and fuel contribution of 25 or less. The staff finds this in accordance with the guidelines of BTP CMEB 9.5-1 Section C.5.a, and, therefore acceptable." 3.3.3 Interior Finishes Complies Section 9.5.1.4 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.3 Interior Finishes.

Interior wall or ceiling finish classification shall be in accordance with NFPA 101, Life Safety Code, requirements for Class A materials. Interior floor finishes shall be in accordance with NFPA 101 requirements for Class I interior floor finishes.

No Additional Clarification Page 5 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.4 Insulation Materials Further Action Required , , Rev. , 3.3.4 Insulation Materials.

Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

LAR - HVAC DUCT SER - Approval for runner material in HVAC duct Section C.5.a of BTP CMEB 9.5-l states that flexible air duct coupling in ventilation and filter systems should be noncombustible. In Revision 3 to the comparison with BTP CMEB 9.5-1, the applicant informed the staff that combustible flexible air duct coupling is utilized in ventilation and filter systems at Harris. The applicant conservatively estimated that this combustible material constitutes less than 1.5% of the total ductwork footage and that there are no large concentrations of the material in any plant area. On the basis of its limited use, the staff concludes that the combustible flexible duct couplings will not contribute appreciably to the spread of fire.

This is, therefore, an acceptable deviation from Section C.5.a of BTP CMEB 9.5-l.

3.3.5 Electrical.

N/A , , Rev. , N/A N/A - General statement; No technical requirements 3.3.5.1 [Electrical Wiring Above Suspended Ceiling Limitations]

Complies Section C.5.a(11)

NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.3.5.1 Wiring above suspended ceiling shall be kept to a minimum. Where installed, electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers.

No Additional Clarification 3.3.5.2 [Electrical Raceway Construction Limits]Further Action Required Section 9.5.1.4 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.5.2 Only metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.

FAQ 06-0021 Rev 0 3.3.5.3 [Electrical Cable Flame Propagation Limits]Complies section 9.5.1, page 9-49 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.5.3*Electric cable construction shall comply with a flame propagation test as acceptable to the AHJ.

Exception: Existing cable in place prior to the adoption of this standard shall be permitted to remain as is.

FAQ 06-0022 Rev 0 Page 6 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.6 Roofs.

Further Action Required Pg 9-48 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.6 Roofs.

Metal roof deck construction shall be designed and installed so the roofing system will not sustain a self-propagating fire on the underside of the deck when the deck is heated by a fire inside the building. Roof coverings shall be Class A as determined by tests described in NFPA 256, Standard Methods of Fire Tests of Roof Coverings.

Metal deck roofs are not used on safety-related structures. (Unremoved metal forms used for the casting of reinforced concrete floors or walls do not constitute a metal deck roof or partition.)

3.3.7 Bulk Flammable Gas Storage.

Complies via Previous Approval SSER 2 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.7 Bulk Flammable Gas Storage.

Bulk compressed or cryogenic flammable gas storage shall not be permitted inside structures housing systems, equipment, or components important to nuclear safety.

SER Supplement 2 states "Safety-related systems have been isolated or separated from combustible materials as much as possible.

Compressed gases are stored outdoors. By letter dated February 24, 1984, the applicants committed to provide hydrogen lines in safety-related areas that are either seismically designed, sleeved, or provided with excess flow valves. The staff finds this commitment acceptable. On the basis of its review, the staff concludes that the control of combustible materials meets its guidelines in Section C.5.d and is therefore, acceptable."

Page 7 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.7.1 [Bulk Flammable Gas Location Requirements]

Complies via Previous Approval AR 206165, , Rev. , 11/19/2007 AR 200493, , Rev. , 11/1/2007 3.3.7.1 Storage of flammable gas shall be located outdoors, or in separate detached buildings, so that a fire or explosion will not adversely impact systems, equipment, or components important to nuclear safety. NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites, shall be followed for hydrogen storage.

Approval Document NUREG-1038 Section 9.5.1 states "Safety-related systems have been isolated or separated from combustible materials as much as possible. Compressed gases are stored outdoors. By letter dated February 24, 1984, the applicants committed to provide hydrogen lines in safety-related areas that are either seismically designed, sleeved, or provided with excess flow valves.

The staff finds this commitment acceptable.

On the basis of its review, the staff concludes that the control of combustible materials meets its guidelines in Section C.5.d and is therefore, acceptable."

NLS 137 states "C.5.d(2) Bulk storage of compressed or cryogenic-gases is not permitted within structures housing safety-related equipment. Flammable gases such as hydrogen are stored outdoors and will not adversely affect safety-related equipment, systems of structures. Care will be taken to locate high pressure gas storage containers with the long axis parallel to building walls, to minimize the possibility of wall penetration in the event of a container failure. Use of-compressed gases (especially flammable and fuel gases) inside buildings will be controlled." 3.3.7.2 [Bulk Flammable Gas Container Restrictions]

Complies C.5.d.(2)NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.3.7.2 Outdoor high-pressure flammable gas storage containers shall be located so that the long axis is not pointed at buildings.

No Additional Clarification 3.3.7.3 [Bulk Flammable Gas Cylinder Limitations]

Complies , , Rev. , 3.3.7.3 Flammable gas storage cylinders not required for normal operation shall be isolated from the system.

No Additional Clarification 3.3.8 Bulk Storage of Flammable and Combustible Liquids.

Complies with Clarification page 266 SER open item 109 LAP-83-306, , Rev. , 3.3.8 Bulk Storage of Flammable and Combustible Liquids.Bulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code.

FAQ 06-0023 Rev. 0 is applicable.

The two Emergency Diesel Generator Day Tanks are located in the safety related Emergency Diesel Generator Building. Each tank is located within its own dedicated Fire Area separated from the remainder of the Emergency Diesel Generator Building by fire barriers.Page 8 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.3.9 Transformers.

Complies Section 5.3.10 EC 48017, Xmer pit sizing, Rev. , 9/8/2006 OMM-016, Operators Rounds, Rev. 062, 3.3.9* Transformers.

Where provided, transformer oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function.

No Additional Clarification 3.3.10 Hot Pipes and Surfaces.Complies , , Rev. , 3.3.10* Hot Pipes and Surfaces.

Combustible liquids, including high flashpoint lubricating oils, shall be kept from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

Administrative controls shall require the prompt cleanup of oil on insulation.

No additional clarification 3.3.11 Electrical Equipment Complies , , Rev. , 3.3.11 Electrical Equipment Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment.

FAQ 06-0024 Rev 0 3.3.12 Reactor Coolant Pumps.Complies sh 1-7 LER 97-10, , Rev. , 2165-S-0685, SFD -

CONTM'T, TURBINE BLDG &

TANK AREA & SEC. BLD, Rev. 027, 1364-053480, RCP-GEN ASSY OIL SPILL PROTESTON SYS, Rev. 001, NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 NUREG-1038, Safety Evaluation Report Related to the Operation of the Plant USA Nuclear Power Plant, Units 1 and 2 - Docket Nos.

STN-50-400 and STN 50-401, Rev. Original, 11/1/1983 3.3.12* Reactor Coolant Pumps.

For facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall be provided with an oil collection system. The oil collection system shall be designed and installed such that leakage from the oil system is safely contained for off normal conditions such as accident conditions or earthquakes. All of the following shall apply.

(1) The oil collection system for each reactor coolant pump shall be capable of collecting lubricating oil from all potential pressurized and nonpressurized leakage sites in each reactor coolant pump oil system.

(2) Leakage shall be collected and drained to a vented closed container that can hold the inventory of the reactor coolant pump lubricating oil system.

(3) A flame arrestor is required in the vent if the flash point characteristics of the oil present the hazard of a fire flashback.

(4) Leakage points on a reactor coolant pump motor to be protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactor coolant pumps.

(5) The collection basin drain line to the collection tank shall be large enough to accommodate the largest potential oil leak such that oil leakage does not overflow the basin.

No Additional Clarification 3.4 Industrial Fire Brigade.N/A , , Rev. , N/A N/A - General statement; No technical requirements Page 9 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.4.1 On-Site Fire-Fighting Capability.

Complies with Clarification QCC FP FBBCERTH, INITIAL FIRE BRIGADE MEMBER CERTIFICATION CARD FBBCERTH, Rev. 006, 3.4.1 On-Site Fire-Fighting Capability.

All of the following requirements shall apply.(a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:

(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting)

(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program (3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department Physicians (b)

Industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.(c) During every shift, 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 Exception: Sufficient training and knowledge shall be permitted to be provided by an operations advisor dedicated to industrial fire brigade support criteria.(d)

The industrial fire brigade shall be notified immediately upon verification of a fire.(e) Each industrial fire brigade member shall pass an annual physical examination to determine that he or she can perform the strenuous activity required during manual fire-fighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.

FAQ 06-0007 Rev 0 is applicable. NFPA 1500 and NFPA 1582 are not applicable to Plant USA as defined within their respective scope statements.

3.4.2 Pre-Fire Plans.

Further Action Required NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.4.2* Pre-Fire Plans.

Current and detailed pre-fire plans shall be available to the industrial fire brigade for all areas in which a fire could jeopardize the ability to meet the performance criteria described in Section 1.5.

3.4.2.1 [Pre-Fire Plan Contents]Further Action Required -

FAQ/Clarification , , Rev. , 3.4.2.1*The plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.

FAQ 06-0025 Rev 0 3.4.2.2 [Pre-Fire Plan Updates]Complies PRO-NGGC-0204, Procedure Review and Approval, Rev.

009, FP-002, Fire Emergency, Rev. , 3.4.2.2 Pre-fire plans shall be reviewed and updated as necessary.

No Additional Clarification Page 10 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.4.2.3 [Pre-Fire Plan Locations]

Complies , , Rev. , 3.4.2.3*Pre-fire plans shall be available in the control room and made available to the plant industrial fire brigade.

No Additional Clarification 3.4.2.4 [Pre-Fire Plan Coordination Needs]

Complies with Clarification , , Rev. , 3.4.2.4*Pre-fire plans shall address coordination with other plant groups during fire emergencies.

Site procedure FPP-002, "Fire Emergency" is not specifically a fire pre-plan however FPP-002 provides specific instructions for actions required from key groups at Plant USA supporting the fire brigade/fire emergency actions. There are detailed response coordination actions specified for Control Room personnel and the Security group. Any other coordination actions would be initiated by Control Room personnel as needed for any plant emergency.

Page 11 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.4.3 Training and Drills.

a) Complies with Clarification TPP-219, Emergency Services Training Program, Rev. 011, 3.4.3 Training and Drills.

Industrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply.

(1) Plant industrial fire brigade members shall receive training consistent with the requirements contained in NFPA 600, Standard on Industrial Fire Brigades, or NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, as appropriate.

(2) Industrial fire brigade members shall be given quarterly training and practice in fire fighting, including radioactivity and health physics considerations, to ensure that each member is thoroughly familiar with the steps to be taken in the event of a fire.

(3) A written program shall detail the industrial fire brigade training program.

(4) Written records that include but are not limited to initial industrial fire brigade classroom and hands-on training, refresher training, special training schools attended, drill attendance records, and leadership training for industrial fire brigades shall be maintained for each industrial fire brigade member.(b) Training for Non-Industrial Fire Brigade Personnel.

Plant personnel who respond with the industrial fire brigade shall be trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.(c)

Drills. All of the following requirements shall apply.

(1) Drills shall be conducted quarterly for each shift to test the response capability of the industrial fire brigade.

(2) Industrial fire brigade drills shall be developed to test and challenge industrial fire brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall evaluate the industrial fire brigade's abilities to react, respond, and demonstrate proper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.(3) Industrial fire brigade drills shall be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards.

(4) Drill records shall be maintained detailing the drill scenario, industrial fire brigade member response, and ability of the industrial fire brigade to perform as a team. (5) A critique shall be held and documented after each FAQ 06-0007 Rev 0 Page 12 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition drill.b) Complies , , Rev. , No Additional Clarification c) Complies TPP-219, Emergency Services Training Program, Rev. 011, No Additional Clarification 3.4.4 Fire-Fighting Equipment.

Complies with Clarification HPP-630, Respitory Protection Program, Rev. 020, 3.4.4 Fire-Fighting Equipment.

Protective clothing, respiratory protective equipment, radiation monitoring equipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrial fire brigade. This equipment shall conform with the applicable NFPA standards.

Fire Brigade turnout gear is purchased to meet applicable NFPA codes. Care and maintenance is based on actual field usage and sufficient to ensure the gear is capable of performing its design functions. Radiation monitoring equipment and personal dosimeters are provided to the fire brigade, and they are maintained in accordance with the site procedures consistent with other radiation monitoring equipment and personal dosimeters in use at Plant USA. Fire suppression equipment such as hose and nozzles are available to the fire brigade in the staging area or are staged in the plant for the fire brigade use. The fire suppression equipment such as hose and nozzles comply with applicable NFPA codes. Fire Extinguishers are located as necessary throughout the areas of the plant as described in the response to Section 3.7.

3.4.5 Off-Site Fire Department Interface.

N/A , , Rev. , N/A N/A - General statement; No technical requirements 3.4.5.1 Mutual Aid Agreement.

Complies TPP-219, Emergency Services Training Program, Rev. 011, 3.4.5.1 Mutual Aid Agreement.

Off-site fire authorities shall be offered a plan for their interface during fires and related emergencies on site.

No Additional Clarification 3.4.5.2 Site-Specific Training.Complies TPP-219, Emergency Services Training Program, Rev. 011, 3.4.5.2* Site-Specific Training.

Fire fighters from the off-site fire authorities who are expected to respond to a fire at the plant shall be offered site-specific training and shall be invited to participate in a drill at least annually.

No Additional Clarification 3.4.5.3 Security and Radiation Protection.

Complies PLP-201, Emergency Plan, Rev. 052, 3.4.5.3* Security and Radiation Protection.

Plant security and radiation protection plans shall address off-site fire authority response.

No Additional Clarification 3.4.6 Communications.

Complies FSAR Section 9.5.2, Communication System, Rev. , 3.4.6* Communications.

An effective emergency communications capability shall be provided for the industrial fire brigade.

No Additional Clarification 3.5 Water Supply N/A , , Rev. , N/A N/A - General statement; No technical requirements Page 13 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.5.1 [Water Supply Flow Code Requirements]

Complies with Clarification , , Rev. , 3.5.1 A fire protection water supply of adequate reliability, quantity, and duration shall be provided by one of the two following methods.(a) Provide a fire protection water supply of not less than two separate 300,000-gal (1,135,500-L) supplies.(b) Calculate the fire flow rate for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This fire flow rate shall be based on 500 gpm (1892.5 L/min) for manual hose streams plus the largest design demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulically least demanding portion of fire main loop out of service.

FAQ 06-0019 Rev. 0 is applicable. The available Plant USA water supply meets the criteria of section 3.5.1(b) for sprinkler systems which meet the Nuclear Safety Performance Criteria.3.5.2 [Water Supply Tank Code Requirements]

Complies with Clarification NUREG 1083, NUREG 1083, Rev. , 3.5.2*The tanks shall be interconnected such that fire pumps can take suction from either or both. A failure in one tank or its piping shall not allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

Exception No. 1: Water storage tanks shall not be required when fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated.

Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.

Plant USA utilizes exception No. 1. The fire protection pumps take suction from the Auxiliary Reservoir.

3.5.3 [Water Supply Pump Code Requirements]

Complies Plant USA-M/BMRK-0007, Code Compliance Evaluation NFPA 20 - Centrifugal Fire Pumps, Rev. 001, 3.5.3*Fire pumps, designed and installed in accordance with NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.

No Additional Clarifications 3.5.4 [Water Supply Pump Diversity and Redundancy]

Complies with Clarification , , Rev. , 3.5.4 At least one diesel engine-driven fire pump or two more seismic Category I Class IE electric motor-driven fire pumps connected to redundant Class IE emergency power buses capable of providing 100 percent of the required flow rate and pressure shall be provided.

Page 14 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.5.5 [Water Supply Pump Separation Requirements]

Complies via Previous Approval NUREG 1083, NUREG 1083, Rev. , 3.5.5 Each pump and its driver and controls shall be separated from the remaining fire pumps and from the rest of the plant by rated fire barriers.

Submittal Document NLS-86-137 Section C.6.b(6) Project Conformance "As shown in FSAR Figure 9.5.1-1 two 100% capacity fire pumps, one electric and one diesel driven, installed in accordance with NFPA 20, are provided. The pumps are installed at opposite ends of the emergency service water intake structure which provides spatial separation in lieu of a fire wall." SER section 9.5.1 pg 9-51 states in part "The fire pumps are located in the emergency service-water screening structure. The fire pumps are separated by the intake water structure. A single fire is, therefore, unlikely to cause damage to both pumps. Based on its review, the staff concludes that the fire protection water supply system meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable." 3.5.6 [Water Supply Pump Start/Stop Requirements]

Complies , , Rev. , 3.5.6 Fire pumps shall be provided with automatic start and manual stop only.

No Additional Clarification 3.5.7 [Water Supply Pump Connection Requirements]

Complies 2165-S-0556, , Rev. 13, 2165-S-0555, , Rev. 18, 2165-S-0557, , Rev. 7, 3.5.7 Individual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizing valves between connections.

No Additional Clarification 3.5.8 [Water Supply Pressure Maintenance Limitations]

Complies NUREG 1083, NUREG 1083, Rev. , 3.5.8 A method of automatic pressure maintenance of the fire protection water system shall be provided independent of the fire pumps.

No Additional Clarification 3.5.9 [Water Supply Pump Operation Notification]

Complies , , Rev. , 3.5.9 Means shall be provided to immediately notify the control room, or other suitable constantly attended location, of operation of fire pumps.

No Additional Clarification 3.5.10 [Water Supply Yard Main Code Requirements]

Complies Plant USA-M/BMRK-0008, Code Compliance Evaluation NFPA 24 - Standard for Outside Protection, Rev. 001, 3.5.10 An underground yard fire main loop, designed and installed in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be installed to furnish anticipated water requirements.

No Additional Clarification Page 15 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.5.11 [Water Supply Yard Main Maintenance Issues]Complies via Previous Approval , , Rev. , 3.5.11 Means shall be provided to isolate portions of the yard fire main loop for maintenance or repair without simultaneously shutting off the supply to both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.

SER Section 9.5.1 pg 9-51 states in part "Approved post-indicator sectional control valves are provided to isolate portions of the underground main for maintenance or repair without shutting off the supply to primary and backup fire suppression systems that serve areas containing or exposing safety-related systems. Based on its review, the staff concludes that the fire protection water supply system meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable.""Each automatic sprinkler system and interior hose standpipe is supplied through separate connections from the yard main or from the internal cross connections through buildings to ensure that no single failure in the water supply system will impair both the primary and backup fire protection in building areas. Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same header Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. " Submittal Document NLS-86-137 Sections C.6.b(2) and C.6.c(1) Project Conformance "Post indicator valves are provided in the distribution system for adequate sectionalization of loops and isolation of branch lines to facilitate system maintenance.

Isolation valves are located in branch lines connecting fire suppression systems in the buildings to avoid closing sectional valves in the main loop. Sectional isolation valves are provided in the yard loop piping to minimize the impairment of fire protection water supply if maintenance on the loop or yard hydrants becomes necessary. Sprinkler systems and manual hose station standpipes have connections to the plant underground water main so that a single active failure or a crack in a moderate-energy line cannot impair both the primary and backup fire suppression systems." Page 16 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.5.12 [Water Supply Compatible Thread Connections]

Complies , , Rev. , 3.5.12 Threads compatible with those used by local fire departments shall be 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.

No Additional Clarification 3.5.13 [Water Supply Header Options]

Complies , , Rev. , 3.5.13 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 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.

No Additional Clarification 3.5.14 [Water Supply Control Valve Supervision]

Complies , , Rev. , 3.5.14*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.

No Additional Clarification 3.5.15 [Water Supply Hydrant Code Requirements]

Complies with Clarification , , Rev. , 3.5.15 Hydrants shall be installed approximately every 250 ft (76 m) apart on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system.

Exception: Mobile means of providing hose and associated equipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses.

Page 17 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.5.16 [Water Supply Dedicated Limits]

Complies with Clarification , , Rev. , 3.5.16*The fire protection water supply system shall be dedicated for fire protection use only.

Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis.

Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section.

3.6 Standpipe and Hose Stations.N/A , , Rev. , N/A N/A - General statement; No technical requirements Page 18 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.6.1 [Standpipe and Hose Station Code Requirements]

Complies Via Previous Approval Section 9.5.1 NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 Plant USA SER initial and Supplement 4, , Rev. , Plant USA-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001, SPlant USAP FSAR 9.5.1, , Rev. , 3.6.1 For all power block buildings, Class III standpipe and hose systems shall be installed in accordance with NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems.

Approval Document NUREG-1038 Section 9.5.1.5 Sprinkler and Standpipe System states "Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same heat' Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual hose stations are located throughout the plant in accordance with NFPA 14. Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The staff concludes that the design of the standpipe system piping meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable." Approval Document NUREG-1038 Supplement No. 4 Section 9.5.1 states "In SER Supplement 3, the staff indicated that its review of the applicant's fire protection program for Harris was complete. By letters dated May 7, June 4, June 18, June 20, July 22, and August 6, 1986, the applicant provided additional information (including Revision 3 to its point-by-point comparison with BTP CMEB 9.5-l), requests for additional deviations from BTP CMEB 9.5-1, and FSAR Amendment 27.

The information provided contained changes resulting from continued program development, and incorporated information previously provided via docketed correspondence, editorial changes, and clarifications. Only those changes that affect the staff's previous safety evaluations are addressed in this supplement.

The Plant USA response NLS-86-137 to section C.6.c(4) states in part "Interior manual hose stations are provided in each plant area so that all portions of the plant are protected with at least one effective hose stream, except the tank area: Diesel Fuel Oil Storage Tank Page 19 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition and Transfer Pumps area and ESW intake and screen-structure, which are protected by yard hydrants." "Individual standpipes are 4 inches in diameter for multiple hose stations and 2-1/2 inches for single hose stations. These systems follow the requirements of NFPA 14 "Standpipe and Hose Systems" Class II, for sizing, spaces, and pipe support requirements.

Hose stations are located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations. Alternative hose stations are provided for an area if the fire hazard could block access to a single hose station serving that area." Page 20 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.6.2 [Standpipe and Hose Station Capability Limitations]

Complies Via Previous Approval Plant USA SER initial and Supplement 4, , Rev. , AR 76621, Evaluate Electrical Nozzles, Rev. , 11/12/2003 AR 25032, Evaluation of NFPA 14 Deviations, Rev. , 4/15/2002 Plant USA-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001, NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 SPlant USAP FSAR 9.5.1, , Rev. , 3.6.2 A capability shall be provided to ensure an adequate water flow rate and nozzle pressure for all hose stations. This capability includes the provision of hose station pressure reducers where necessary for the safety of plant industrial fire brigade members and off-site fire department personnel.

Submittal Document NLS-86-137 Section C.6.c(4) Project Conformance "Interior manual hose stations are provided in each plant area so that all portions of the plant are protected with at least one effective hose stream, except the tank area: Diesel Fuel Oil Storage Tank and Transfer Pumps area and ESW intake and screen-structure, which are protected by yard hydrants. Each interior hose station is provided with 100 feet of 1 1/2 inches Angus "Red Chief" rubber-lined, rubber coated hose and adjustable nozzles suitable for use on electrical equipment. Individual standpipes are 4 inches in diameter for multiple hose stations and 2-1/2 inches for single hose stations.

These systems follow the requirements of NFPA 14 Standpipe and Hose Systems Class II, for rising, spaces, and pipe support requirements. Hose stations are located as dictated by the fire hazard analysis to facilitate access and use for firefighting operations.

Alternative hose stations are provided for an area if the fire hazard could block access to a single hose station serving that area." Approval Document NUREG-1038 Section 9.5.1.5 Sprinkler and Standpipe Systems states "Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same heat' Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual hose stations are located throughout the plant in accordance with NFPA 14." FSAR section 9.5.1 states, "The guidelines of NFPA 14 were followed in the design of the standpipe. Individual standpipes are a minimum of 4 inches diameter for multiple hose connections and 2-1/2 inch for single hose connections. The stand pipe system is designed and sized to provide to the most remote hose station the flow rate and pressure Page 21 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition required for effective hose streams."

3.6.3 [Standpipe and Hose Station Nozzle Restrictions]

Complies AR 25032, Evaluation of NFPA 14 Deviations, Rev. , 4/15/2002 NFPA 14-1976, Standpipes and Hose Stations, Rev. , Plant USA SER initial and Supplement 4, , Rev. , NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 3.6.3 The proper type of hose nozzle to be supplied to each power block area shall be based on the area fire hazards.

The usual combination spray/straight stream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or present an electrical hazard to fire-fighting personnel. Listed electrically safe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed.

No Additional Clarification Page 22 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.6.4 [Standpipe and Hose Station Earthquake Provisions]

Complies via Previous Approval Plant USA SER initial and Supplement 4, , Rev. , NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 Plant USA-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001, 3.6.4 Provisions shall be made to supply water at least to standpipes and hose stations for manual fire suppression in all areas containing systems and components needed to perform the nuclear safety functions in the event of a safe shutdown earthquake (SSE).

Exception: For existing plants that are not capable of meeting this requirement, provisions to restore a water supply and distribution system for manual fire-fighting purposes shall be made. This provisional manual fire-fighting standpipe/hose station system shall be capable of providing manual fire-fighting protection to the various plant locations important to supporting and maintaining the nuclear safety function. The provisions for establishing this provisional system shall be preplanned and be capable of being implemented in a timely manner following an SSE.

Deviation Request-From NLS-86-315

SUMMARY

Carolina Power & Light Company (CP&L) would lie to identify a deviation from BTP 9.5-1, Section C.6.c (4) of NUREG-0800 from having to provide manual Safe Shutdown Earthquake (SSE) hose stations in three areas of the plant identified below.

BACKGROUND Section 9.5.15 of the November 1983 Harris Safety Evaluation Report (SER) stated that: "Based on its evaluation, the Staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.( c )

of BTP CMEB 9.5-l and are, therefore, acceptable." "Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The Staff concludes the design of the standpipe system piping, meets Section C.6.c of BTP CMEB 9:5-I and is, therefore, acceptable." The above SER statements were based on CP&.L's Qctober 1983 response to NRC Question 280.1. However, the SER did not address the deviations identified in CP&L's response (specifically, that SSE hose stations were not provided for the diesel generator and fuel oil storage buildings). Amendment No. 20 of the Harris Final Safety Analysis Report, dated May 10,1985, identified the Emergency Service Water Intake structure as an additional area where SSE hose stations are not provided. Following recent conversations with your Staff, CP&L was requested to provide justification for not providing SSE hose stations for the below three areas.

DISCUSSION The Company requests approval of a deviation from the requirements to provide-SSE hose stations in the following plant areas:

Plant Location:

a) Diesel Generator Building b) Diesel Fuel Oil Storage Building c) Emergency Service Water Intake Structure Fire Area:

Page 23 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition a) I-D-DGA, I-D-DCB, I-D-DTA, I-D-DTB b) 12-O-TA, 12-O-TB, I-O-PA, l-O-PB, 5-O-BAL c) I2-I-ESWPA, I2-I-ESWPB SSA Area: a) FADDGA, FADDGB, FADDTA, FADDTB b) FCOTKA. FCOTKB, FAOPA, FAOPB, FPOBAL c) FCIESA. FCIESB Other safe shutdown equipment within the SSA area: a) Diesel Generator, Diesel Generator Day Tanks, and Diesel Control Panels b) Diesel Generator Fuel Oil Transfer Pumps, Diesel Generator Storage Tanks c) Emergency Service Water Pumps and Controls The Company considers this deviation justified because: 1-the above redundant safe shutdown equipment is separated from each other by three-hour rated barriers, which are Seismic Class I structures, 2-these areas are provided with non-seismic fire protection systems, and 3-the combustible loading in these areas is considered low, except in the case of the diesel day tank and storage tank area where the enclosures are Seismic Class I or ASME Section III.

CONCLUSION Based on the fire protection provided and described above, CP&L believes that a commensurate level of protection has been provided in lieu of additional SSE hose stations as described in Section C.6,c (4) of NUREG-0800.

Plant USA initial SER states "Each sprinkler and standpipe system connection to the distribution system is equipped with an indicating gate valve, so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same heat' Based on its evaluation, the staff finds that sprinkler and standpipe systems have been provided in accordance with Section C.6.(C) of BTP CMEB 9.5-l and are, therefore, acceptable. Manual Page 24 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition hose stations are located throughout the plant in accordance with NFPA 14. Standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for SSE loading and is provided with seismic supports. The staff concludes that the design of the standpipe system piping meets Section C.6.c of BTP CMEB 9.5-l and is, therefore, acceptable." SER 4 -In the SER, the staff stated that standpipe system piping for hose stations protecting safe shutdown equipment has been analyzed for safe-shutdown earthquake (SSE) loading and is provided with seismic supports in accordance with Section C.6.c of BTP CMEB 9.5-l. In fact, this is not the case for the diesel generator building, the diesel fuel oil storage building, and the emergency service water intake structures. By letter dated August 25, 1986, the applicant justified this deviation from staff guidelines. On the basis of its review of the applicant's justification, which is based on the separation of the redundant safe-shutdown equipment located in the diesel generator building, the diesel fuel oil storage building, and the emergency service water (ESW) intake structure by seismic Category I 3-hour fire rated barriers, and the provision of alternative means of manual firefighting, the staff concludes that the standpipe system is acceptable. The lack of seismically qualified hose stations in the diesel generator and fuel oil storage buildings and the emergency service water (ESW) intake structure is an acceptable deviation from Section C.6.c of BTP CMEB 9.5-l. 9.5.1.6.

3.6.5 [Standpipe and Hose Station Seismic Connection Limitations]

Complies NLS-86-137, Point by Point Comparison of Plant USA to Requirements of NUREG 0800, Rev. , 5/7/1986 Plant USA SER initial and Supplement 4, , Rev. , Plant USA-M/BMRK-0006, Code Compliance Evaluation NFPA 14-1976, Standpipe and Hose Stations, Rev. 001, 3.6.5 Where the seismic required hose stations are cross-connected to essential seismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement.

No Additional Clarification Page 25 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.7 Fire Extinguishers.

LAR Plant USA-M/BMRK-0005, CODE COMPLIANCE EVALUATION NFPA 10, PORTABLE FIRE EXTINGUISHERS, Rev. 001, AR 25033, , Rev. , 4/15/2002 3.7 Fire Extinguishers.

Where provided, fire extinguishers of the appropriate number, size, and type shall be provided in accordance with NFPA 10, Standard for Portable Fire Extinguishers.

Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.

3.8 Fire Alarm and Detection Systems.

N/A , , Rev. , N/A N/A - General statement; No technical requirements 3.8.1 Fire Alarm.

Further Action Required Plant USA-M/BMRK-0001, CODE COMPLIANCE EVALUATION NFPA 72E, AUTOMATIC FIRE DETECTORS, Rev. 001, 3.8.1 Fire Alarm.

Alarm initiating devices shall be installed in accordance with NFPA 72, National Fire Alarm Code. Alarm annunciation shall allow the proprietary alarm system to transmit fire-related alarms, supervisory signals, and trouble signals to the control room or other constantly attended location from which required notifications and response can be initiated. Personnel assigned to the proprietary alarm station shall be permitted to have other duties. The following fire-related signals shall be transmitted:

(1) Actuation of any fire detection device (2) Actuation of any fixed fire suppression system (3) Actuation of any manual fire alarm station (4) Starting of any fire pump (5) Actuation of any fire protection supervisory device (6) Indication of alarm system trouble condition 3.8.1.1 [Fire Alarm Communication Requirements]

Complies , , Rev. , 3.8.1.1 Means shall be provided to allow a person observing a fire at any location in the plant to quickly and reliably communicate to the control room or other suitable constantly attended location.

FAQ 06-0019 Rev 0 is applicable.

3.8.1.2 [Fire Alarm Prompt Notification Limits]Complies , , Rev. , 3.8.1.2 Means shall be provided to promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriate course of action:

(1) General site population in all occupied areas (2) Members of the industrial fire brigade and other groups supporting fire emergency response (3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services No Additional Clarification 3.8.2 Detection.

Further Action Required Plant USA-M/BMRK-0001, CODE COMPLIANCE EVALUATION NFPA 72E, AUTOMATIC FIRE DETECTORS, Rev. 001, 3.8.2 Detection.

If automatic fire detection is required to meet the performance or deterministic requirements of Chapter 4, then these devices shall be installed in accordance with NFPA 72, National Fire Alarm Code, and its applicable appendixes.

3.9 Automatic and Manual Water-Based Fire Suppression Systems.

N/A , , Rev. , N/A N/A - General statement; No technical requirements Page 26 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.9.1 [Fire Suppression System Code Requirements]

Further Action Required , , Rev. , 3.9.1*If an automatic or manual water-based fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:

(1) NFPA 13, Standard for the Installation of Sprinkler Systems (2) NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection (3) NFPA 750, Standard on Water Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems 3.9.2 [Fire Suppression System Flow Alarm]

Complies Section 9.5.1, page 9.5.1-23 SPlant USAP FSAR 9.5.1 Amendment 48, , Rev. , 3.9.2 Each system shall be equipped with a water flow alarm.

No Additional Clarification 3.9.3 [Fire Suppression System Alarm Locations]

Complies Section 9.5.1, page 9.5.1-25 SPlant USAP FSAR 9.5.1 Amendment 48, , Rev. , 3.9.3 All alarms from fire suppression systems shall annunciate in the control room or other suitable constantly attended location.No Additional Clarification 3.9.4 [Fire Suppression System Diesel Pump Sprinkler Protection]

LAR , , Rev. , 3.9.4 Diesel-driven fire pumps shall be protected by automatic sprinklers.

3.9.5 [Fire Suppression System Shutoff Controls]

Complies , , Rev. , 3.9.5 Each system shall be equipped with an OS&Y gate valve or other approved shutoff valve.

No Additional Clarification 3.9.6 [Fire Suppression System Valve Supervision]

Complies OP-149, Fire Protection, Rev.

037, 3.9.6 All valves controlling water-based fire suppression systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.

No Additional Clarification 3.10 Gaseous Fire Suppression Systems.

N/A , , Rev. , N/A N/A - General statement; No technical requirements 3.10.1 [Gaseous Suppression System Code Requirements]

N/A , , Rev. , 3.10.1 If an automatic total flooding and local application gaseous fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:

(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems Gaseous suppression not used at Plant USA.

Page 27 of 33 1/3/2008 Plant USA Transition Tool Version 1.0.4 Test Plant USA for Transition Report Examples Jan. 2008.mdb NFPA 805 Ch. 3 Ref.

Compliance Statement Document Detail Reference Document Requirements/Guidance Compliance Basis Table B NFPA 805 Ch. 3 Transition 3.10.2 [Gaseous Suppression System Alarm Location]

N/A , , Rev. , 3.10.2 Operation of gaseous fire suppression systems shall annunciate and alarm in the control room or other constantly attended location identified.