turkey point, units 3 and 4, response to request for ...3.3.1.2 control of combustible 3.3.1.2 (5) *...

0FPL.

January 7, 201410 CFR 50.90

L-2014-003

U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, D.C. 20555-0001

Re: Turkey Point Nuclear Generating Station Units 3 and 4Docket Nos. 50-250 and 50-251Response to Request for Additional Information Regarding License Amendment RequestNo. 216 - Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard forFire Protection for Light Water Reactor Generating Plants (2001 Edition)

By Florida Power and Light Company (FPL) letter L-2012-092 dated June 28, 2012, inaccordance with the provisions of 10 CFR 50.90, "Application of License or ConstructionPermit," FPL requested an amendment to the Renewed Facility Operating License (RFOL) forTurkey 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 therequirements 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. Theattachment to this letter provides the response to. the request for additional information. Theadditional information does not impact the 10 CFR 50.92 evaluation of "No Significant HazardsConsideration" 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 Programto include all NFPA 805 Power Block structures/areas in the Transient Combustible AreaBoundary 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

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 7, 2014.

Michael KileyVice PresidentTurkey Point Nuclear Generating Station

Attachment

cc: Regional Administrator, Region II, USNRCSenior Resident Inspector, USNRC, Turkey PointUSNRC Project Manager for Turkey PointMs. Cindy Becker, Florida Department of Health

L-2014-003, AttachmentPage 1 of 92

L-2014-003 Attachment

Response to Request for Additional Information RegardingLicense Amendment Request No. 216

Florida Power and Light CompanyTurkey Point Nuclear Generating Station Units 3 and 4

Transition to 10 CFR 50.48(c) - NFPA 805Performance-Based Standard for Fire Protection for

Light Water Reactor Electric Generating Plants, 2001 Edition


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 flammablegas after transition and to provide the basis of those controls." The response in letter datedMarch 18, 2013 (ADAMS Accession No. ML 13099A441), indicated that "flammable gases areprogrammatically controlled via station procedures." Provide a more detailed description ofthose controls and the basis for them.

RESPONSE:

Flammable gases are programmatically controlled by station procedure 0-ADM-0 16.1, TransientCombustible and Flammable Substances Program. This procedure outlines the control of andfire prevention practices for compressed flammable gas cylinders within the TransientCombustible 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, inapproved 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 avoidedso 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 extinguishingcapability 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 toexpedite removal if necessary.

The bases for these requirements come from the FP&L Safe Work Practices Manual, NFPA FireProtection Handbook, NFPA 1, and OSH1A guidelines.

NFPA 805 requirements for bulk flammable gas storage and orientation of cylinders is includedin 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 Programadministrative procedure to include all NFPA 805 Power Block structures/areas in theTransient Combustible Area Boundary Map.

See Implementation Item in Table S-3 of Attachment S


Attachment ANEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements

ComplianceNFPA 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 specificMaterials (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 ProgramPTN-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 whichClarification NFPA standards referenced in Chapter 3 are applicable:

Arm, "applicableJAdd: alent to those NFPA

Item for Implementation: 3sis (CLB) for

Update the PTN Transient Combustible and Flammable Substances Program administrative procedure to include ion 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 asMaterials (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 standardsreferenced in Chapter 3 are applicable: "Where used in NFPA805, Chapter 3, the term, "applicable NFPA Standards" isconsidered to be equivalent to those NFPA standards identified inthe current license basis (CLB) for procedures and systems in theFire Protection Program that are transitioning to NFPA 805."Flammable gases are controlled per 0-ADM-016 and 0-ADM-016.1.


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 TitleSources

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, EvaluationStandard for Fire Prevention During Welding, Cutting, and Other HotWork, 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


Security-Related Information -Withhold Under 10 CFR 2.390Florida 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 EUpdate 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 radioactiverelease

o Develop new pre-fire plans as applicable for buildings within theRCA with contaminated equipment or areas

o Add an appendix that identifies where run-off has the potential toroute to a storm drain

. Modify the fire brigade training program to include enhanced radioactiverelease objectives

. Develop a standard operating procedure to support actions to mitigate aradioactive release

. Develop administrative controls to support compliance with NFPA 805,Radioactive Release Criteria

. Stage materials and equipment to assist in preventing potentiallycontaminated run-off from entering the storm drain system

16 3, 4 Update fire protection program documents and provide training as necessary. 4.7This implementation item is to address general program documents not alreadyaddressed in items 1-15 and 17. This includes fire protection design basisdocument, post-transition change process (including Fire PRA updates), andqualification training.

17 3, 4 Update plant procedures based upon determination of required fire protection 4.8 and Table C-2systems 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, 4Update the PTN Transient Combustible and Flammable Substance Program administrative procedure to include all NFPA 805 PowerBlock 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


Fire Protection Engineering RAI 12

National Fire Protection Association Standard 805 (NFPA 805), "Performance-Based Standardfor 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 forthis section, the licensee stated that this arrangement is not used.

Provide a description of the arrangement, including any piping codes (for example, AmericanNational Standards Institute B3 1. 1) that apply. Also, include a description of how each sprinklerand standpipe system is equipped with an approved shutoff valve (for example, an outside screwand yoke gate valve).

Justify any differences between the installed arrangement and the requirements of NFPA 805Chapter 3, Section 3.5.13.

RESPONSE:

NFPA 805 Section 3.5.13 states "Headers fed from each end shall be permitted inside buildingsto supply both sprinkler and standpipe systems, provided steel piping and fittings meeting therequirements of ANSI B3 1.1, Code for Power Piping, are used for the headers (up to andincluding the first valve) supplying the sprinkler systems where such headers are part of theseismically analyzed hose standpipe system. Where provided, such headers shall be consideredan extension of the yard main system. Each sprinkler and standpipe system shall be equippedwith 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 headersinside buildings are not applicable. However, a review of PTN piping specifications determinedthat Fire Protection piping, Service Number 11, may be Class F, G, H, or SL. Class F, G, H, andSL 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 eitherindividual 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) andthe 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 arelocated 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


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 individualshutoff valves independent of standpipe systems. Standpipes have either individual isolationcapability or sections that can be isolated. Compensatory actions are prescribed for removing orimpairing hose stations. Common cause failure of the water supply piping where primary firesuppression (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


Attachment ANEI 04-02 Table B-1 Transition of Fundamental FP Program & Design Elements

ComplianceNFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis


PTN-FPER-1 1-004 Rev. 0 - Backup Suppression on Common Water Supply Systems

3.5.12 [Water Supply 3.5.12 CompliesCompatible Thread Threads compatible with those used by local fire departments shall beConnections] provided on all hydrants, hose couplings, and standpipe risers.

Exception: Fire departments shall be permitted to be provided withadapters that allow interconnection between plant equipment and the firedepartment equipment if adequate training and procedures are provided.


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 arrAngementOptions] Headers fed from each end shall be permitted inside buildings to supply

both sprinkler and standpipe systems, provided steel piping and fittingsmeeting the requirements of ANSI B31.1, Code for Power Piping, are used Replace strikethroughs with the twofor the headers (up to and including the first valve) supplying the sprinklersystems where such headers are part of the seismically analyzed hose Compliance Statements, and associatedstandpipe system. Where provided, such headers shall be considered an Compliance Basis and References provided inextension of the yard main system. Each sprinkler and standpipe systemshall 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 byone of the following methods.(a) Electrical supervision with audible and visual signals in the maincontrol room or other suitable constantly attended location.(b) Locking valves in their normal position. Keys shall be made availableonly to authorized personnel.(c) Sealing valves in their normal positions. This option shall be utilizedonly where valves are located within fenced areas or under the directcontrol of the owner/operator.


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


Fire Protection Engineering RAT 13

The entry in LAR Attachment A, Table B-i for NFPA 805, Section 3.3.5.3 relies on previousapproval for electric cable construction using fire retardant coatings approved by the authorityhaving jurisdiction. However, this does not qualify non-rated cable to exclude the likelihood ofself-ignition. Explain what assumptions were made with regard to cabling, specifically withregard 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 cablefire. There was no credit taken for fire retardant coatings eliminating the potential for self-ignited cable fires.


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-compartmentanalysis (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 ajustification for this apparent discrepancy. If corrections to the table are required, provide areview to ensure all suppression and detection systems credited or required by the FPRA, or byNFPA 805, Chapters 3 or 4, have been fully documented in Table C-2. Also, provide thecorrected Table C-2.

RESPONSE:

The current revision of the Fire PRA MCA report is Revision 3. Revision 2 was developed forthe LAR submittal and Revision 3 was developed in response to PTN RAI PRA 01.o. Thisresponse 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 3of the MCA report identifies this appropriately, with no automatic suppression system failureprobability shown for these zones.

A revised Table C-2 is attached to this RAI response based on the research which identifiedomissions. In addition to the MCA report, the FRE report and Fire PRA Scenario report werereviewed to validate the NFPA 805 Chapter 4 required suppression and detection systems areidentified. The methodology presented in PTN LAR Section 4.8.1 identifies the purpose ofTable C-2 is to document the detection and/or suppression required based on NFPA 805 Chapter4 compliance. Detection and/or suppression required for NFPA 805 Chapter 3 will be identifiedduring the implementation period as part of development of the Monitoring Program. NFPA 805Chapter 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 previouslyprovided 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 systemsdesignated 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


Florida Power & Light 4.0 Compliance with NFPA 805 Requirements

Required Fire Protection System / Feature: Detection / suppression required inthe Fire Area based on NFPA 805 Chapter 4 compliance. Other RequiredFeatures may include Electrical Raceway Fire Barrier Systems, fire barriers, etc.The documentation of required fire protection systems and features does notinclude the documentation of the fire area boundaries. Fire area boundaries arerequired and documentation of the fire area boundaries has been performed aspart of reviews of engineering evaluations, licensing actions, or as part of thereviews of the NEI 04-02 Table B-1 process. The information is provided on afire 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 thePerformance-Based Approach (Section 4.2.4),

o0 - Defense-in-Depth Criteria: Systems/Features required to maintainade .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 NHUanalysis

During the implementation phase, the PTN procedures and processes will be updatedto reflect the NFPA 805 required fire protection systems and features. SeeImplementation Item 16 in Table S-3 of Attachment S

Attachment W contains the results of the Fire Risk Evaluations, additional risk ofrecovery actions, and the change in risk on a fire area basis.

4.8.2 Plant Modifications and Items to be Completed During the ImplementationPhase

Planned modifications, studies, and evaluations to comply with NFPA 805 are describedin Attachment S.

The Fire PRA model represents the as-built, as-operated and maintained plant as it willbe configured at the completion of the transition to NFPA 805. In addition, the Fire PRAmodel includes the extended power uprate (EPU) changes that are currently beingimplemented. The Fire PRA model includes credit for modifications completed as resultof the NFPA 805 transition effort as identified in Table S-1 of Attachment S and theplanned implementation of the modifications identified in Table S-2 of Attachment S.Following installation of modifications and the as-built installation details, additionalrefinements surrounding the. modification may need to be incorporated into the Fire PRAmodel. However, these changes are not expected to be significant. SeeImplementation Item 18 in Table S-3 of Attachment S. No other significant plantchanges are outstanding with respect to their inclusion in the Fire PRA model.

Revision 0 Page 53

L-201 4-003, AttachmentPage 1 I of 92

Attachment CTable C-2 NFPA 805 Required Fire Protection Systems and Features

Fire Area ID: A (Unit 3) - Unit 3 and 4 Auxiliary Building BasementCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach

Required RequiredSuppression 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: R004 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 ALaundry and Hot Shower TankRoom - Fire Area A

006 Units 3 and 4 Gas Compressor None None None NoneRoom - Fire Area A

007 Units 3 and 4 Gas Compressor None None None NoneRoom - Fire Area A

008 Units 3 and 4 Waste Holdup Tank None None None NoneRoom - Fire Area A

009 Units 3 and 4 Waste Evaporator None E, R, D, A None Detection System, Alarm Point 8: E R D AFeed 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 APipeway - Fire Area A

017 Units 3 and 4 Spent Resin None None None NoneStorage Tank Room - Fire Area A

018 Units 3 and 4 Area Beneath None None None NoneWaste Evaporator Skid - FireArea A


RequiredSuppression

RequiredDetection

Fire Zone ID

(All)

004

005

006

007

008

Description Syste

Area Wide None

Unit 3 and 4 Hallway South of NoneHoldup Tanks - Fire Area AUnits 3 and 4 Chemical Drain, NoneLaundry and Hot Shower TankRoom - Fire Area AUnits 3 and 4 Gas Compressor NoneRoom - Fire Area AUnits 3 and 4 Gas Compressor NoneRoom - Fire Area AUnits 3 and 4 Waste Holdup Tank NoneRoom - Fire Area A

mII QyStllln

None

E, R, D, A

E, R, D, A

None

None

None

Required FireProtection Feature

R, DE

None

None

None

None

Required Fire Protection Feature and System Details

Procedures/Recovery Actions: R D

Combustible Loading: EDetection System, Alarm Point 8: E R D ADetection System, Alarm Point 8: E R D A

None

None

None

Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 1 of 58






009 Units 3 and 4 Waste Evaporator None E, R, D, A None Detection System, Alarm Point 8: E R D AFeed 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 APipeway - Fire Area A

017 Units 3 and 4 Spent Resin None None None NoneStorage Tank Room - Fire Area A

018 Units 3 and 4 Area Beneath None None None NoneWaste Evaporator Skid - FireArea A

Fire Area ID: AA (Unit 3) - Unit 3 Train B Emergency Diesel Generator Day Tank RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



074 Unit 3 Train B Emergency Diesel A A None Detection System, Alarm Point 16: AGenerator Day Tank Room - Fire Water Suppression, 3-10-844: AArea AA

Fire Area ID: AA (Unit 4) - Unit 3 Train B Emergency Diesel Generator Day Tank RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area


Fire Zone ID Description System System Protection Feature Required Fire Protection Feature and System Details074 Unit 3 Train B Emergency Diesel A

Generator Day Tank Room - FireArea AA

A None Detection System, Alarm Point 16: AWater Suppression, 3-10-844: A



Fire Area ID:Compliance Basis:

Fire Zone ID

(All)

001

002

003

021

022

023

024

029

042

043

044

046

056

057

065

111

112

126A

126B

D

A

F

UFUF

UF

U

IFUF

U

U

UELF

UF

UFUE

UA

A

AU


AAA (Unit 3) - Unit 3 and 4 Miscellaneous ZonesNFPA 805, Section 4.2.4, Performance Based Approach


Description System System Protection Feature Required Fire Prote

•rea Wide None None R Procedures/Recoveryfnits 3 and 4 Holdup Tank A - None None E Combustible Loadingire Area AAA

Jnits 3 and 4 Holdup Tank B - None None E Combustible Loadingire Area AAA

Jnits 3 and 4 Holdup Tank C - None None E Combustible Loadingire Area AAA

Jnits 3 and 4 Counting Room - None A None Detection System, Alire Area AAA

Jnits 3 and 4 Hot Lab - Fire Area None A None Detection System, Al

knits 3 and 4 Gas Decay Tank - None None None Noneire Area AAA

Jnits 3 and 4 Gas Decay Tank None None E Combustible LoadingRoom - Fire Area AAA

Jnit 4 Spent Fuel Pit - Fire Area None None E Combustible LoadingkAAJnit 3 Spent Fuel Pit - Fire Area None None E Combustible LoadingAAJnit 4 Spent Fuel Pit Heat None None None NoneExchanger Room - Fire Area AAAJ.nit 4 New Fuel Storage Room - None None None Nonetire Area AAAJnits 3 and 4 Laundry Room - None A None Detection System, Alire Area AAA

Jnit 3 New Fuel Storage Room - None None None None:ire Area AAAJnit 3 Spent Fuel Pit Heat None None None NoneExchanger Room - Fire Area AAA

Jnits 3 and 4 QSPDS Inverter None None None None,rea - Fire Area AAAnit 4 Volume Control Tank - Fire None None None None

,rea AAAnit 3 Volume Control Tank - Fire None None None None

,rea AAAnits 3 and 4 Radwaste Control None None None None

ction Feature and System Details

Actions: R

:E

:E

:E

arm Point 39: A

arm Point 39: A

:E

:E

:E

arm Point 7: A

Room and Equipment Room -Fire Area AAA

Units 3 and 4 RadwasteProcessing Area - Fire Area AAA

None None None None




Fire Area ID: AAA (Unit 3) - Unit 3 and 4 Miscellaneous ZonesCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



126C Units 3 and 4 Health Physics None None None NoneStorage Area - Fire Area AAA

126D Units 3 and 4 Radwaste Building None None None NoneHVAC Equipment Room - FireArea AAA

126E Uhits 3 and 4 Maintenance Work None None None NoneArea - Fire Area AAA

129 Units 3 and 4 Nuclear Entrance None None None NoneBuilding - Fire Area AAA

Fire Area ID: AAA (Unit 4) - Unit 3 and 4 Miscellaneous ZonesCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)001

002

003

021

022

023

024

029

042

043

044

Area Wide

Units 3 and 4 Holdup Tank A -Fire Area AAAUnits 3 and 4 Holdup Tank B -Fire Area AAA

Units 3 and 4 Holdup Tank C -Fire Area AAA

Units 3 and 4 Counting Room -Fire Area AAA

Units 3 and 4 Hot Lab - Fire AreaAAAUnits 3 and 4 Gas Decay Tank -Fire Area AAA

Units 3 and 4 Gas Decay TankRoom - Fire Area AAAUnit 4 Spent Fuel Pit - Fire AreaAAA

Unit 3 Spent Fuel Pit - Fire AreaAAA

Unit 4 Spent Fuel Pit HeatExchanger Room - Fire Area AAAUnit 4 New Fuel Storage Room -Fire Area AAA

None None

None None

None None

None None

None A

None A

None None

None None

None None

None None

None None

None None

R

E

E

E

None

None

Procedures/Recovery Actions: R

Combustible Loading: E



Detection System, Alarm Point 39: A


None




None

None

E

E

E

None

None None




Fire Area ID: AAA (Unit 4) - Unit 3 and 4 Miscellaneous ZonesCompliance Basis: t NFPA 805, Section 4.2.4, Performance Based Approach



046 Units 3 and 4 Laundry Room - None A None Detection System, Alarm Point 7: AFire Area AAA

056 Unit 3 New Fuel Storage Room - None None None NoneFire Area AAA

057 Unit 3 Spent Fuel Pit Heat None None None NoneExchanger Room - Fire Area AAA

065 Uhits 3 and 4 QSPDS Inverter None None None NoneArea - Fire Area AAA

111 Unit 4 Volume Control Tank - Fire None None None NoneArea AAA

112 Unit 3 Volume Control Tank - Fire None None None NoneArea AAA

126A Units 3 and 4 Radwaste Control None None None NoneRoom and Equipment Room -Fire Area AAA

126B Uhits 3 and 4 Radwaste None None None NoneProcessing Area - Fire Area AAA

126C Units 3 and 4 Health Physics None None None NoneStorage Area - Fire Area AAA

126D Units 3 and 4 Radwaste Building None None None NoneHVAC Equipment Room - FireArea AAA

126E Units 3 and 4 Maintenance Work None None None NoneArea - Fire Area AAA

129 Units 3 and 4 Nuclear Entrance None None None NoneBuilding - Fire Area AAA

Fire Area ID: B (Unit 3) - Unit 3 RHRCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach

Fire Zone ID

(All)

011

012

013

Description

Area Wide

Unit 3 RHR Heat ExchangerRoom - Fire Area BUnit 3 RHR Pump A Room - FireArea B

Unit 3 RHR Pump B Room - FireArea B

Required RequiredSuppression DetectionSystem System

None None

None R, D, A

None R, D, A

None R, D, A

Required FireProtection Feature

R

E

E

None

Required Fire Protection Feature and System Details


Detection System, Alarm Point 21: R D APhysical separation: ECombustible Loading: EDetection System, Alarm Point 21: R D ADetection System, Alarm Point 21: R D A




Fire Area ID: B (Unit 4) - Unit 3 RHRCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(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 ARoom - Fire Area B Physical separation: E

012 Uhit 3 RHR Pump A Room - Fire None R, D, A E Combustible Loading: EArea 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 AArea B

Fire Area ID: BB (Unit 3) - Unit 3 Train A Emergency Diesel Generator Day Tank RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



075 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: AGenerator Day Tank Room - Fire Water Suppression, 3-10-847: AArea BB

Fire Area ID: BB (Unit 4) - Unit 3 Train A Emergency Diesel Generator Day Tank RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



075 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: AGenerator Day Tank Room - FireAiea BB

Water Suppression, 3-10-847: A

Fire Safety Analysis DataManager (4.2) FPL - Turkey Run: 12119/2013 15:34 Page: 6 of 58



Fire Area ID: BBB (Unit 3) - Units 3 and 4 Safety Injection Pump RoomsCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area


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 NoneRoom - Fire Area BBB

053 Uhit 3 Safety Injection Pump None None None NoneRoom - Fire Area BBB

Fire Area ID: BBB (Unit 4) - Units 3 and 4 Safety Injection Pump RoomsCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area





Fire Area ID: C (Unit 3) - Unit 4 RHRCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)014

015

016

Area WideUnit 4 RHR Heat ExchangerRoom - Fire Area C

Unit 4 RHR Pump A Room - FireArea C

Unit 4 RHR Pump B Room - FireArea C

None

None

None

R, D, AR

E


Detection System, Alarm Point 22: R D APhysical separation: ECombustible Loading: EDetection System, Alarm Point 22: R D A

Detection System, Alarm Point 22: R D A

None

None

R, D, A

R, D, A

E

None




Fire Area ID: C (Unit 4) - Unit 4 RHRCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R014 Unit 4 RHR Heat Exchanger None R, D, A E Detection System, Alarm Point 22: R D A

Room -Fire Area C Physical separation: E015 Unit 4 RHR Pump A Room - Fire None R, D, A E Combustible Loading: E

Aiea C Detection System, Alarm Point 22: R D A016 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



(All) Area Wide None None R, D Procedures/Recovery Actions: R D079A 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 DArea CC Detection System, Modification - CC U3: R

ERFBS, Modification CC U3: RFireBarrier, MODIFICATION - CC U3: RWater Suppression, 10-850: E D

Fire Area ID: CC (Unit 4) - Units 3 and 4 Auxiliary Building North-South BreezewayCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

079AArea Wide

Units 3 and 4 Auxiliary BuildingNorth-South Breezeway - FireArea CC

NoneE, D

None

R, DD

R

Procedures/Recovery Actions: D

Combustible Control - Transient Restrictions: RDetection System, Alarm Point 39: R DDetection System, Modification - CC U4: RERFBS, Modification CC U4: RFireBarrier, MODIFICATION - CC U4: RWater Suppression, 10-850: E D




Fire Area ID: CCC (Unit 3) - Units 3 and 4 Vestibule ElevatorCompliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS



064 Units 3 and 4 Vestibule Elevator - None None S, N ERFBS, 064-1: S NFire Area CCC ERFBS, 064-2: S N

ERFBS, 064-3: S NERFBS, 064-4: S N

Fire Area ID: CCC (Unit 4) - Units 3 and 4 Vestibule ElevatorCompliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS



064 Units 3 and 4 Vestibule Elevator - None None S, N ERFBS, 064-1: S NFire Area CCC ERFBS, 064-2: S N

ERFBS, 064-3: S NERFBS, 064-4: S N

Fire Area ID: D (Unit 3) - Unit 4 Pipe and Valve RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

030

Area Wide

Unit 4 Pipe and Valve Room -Fire Area D

None

None

None

R, AR

E


Combustible Loading: EDetection System, Alarm Point 20: R APhysical separation: E

Fire Safety Analysis Data Manager (4.2) FPL - Turkey Run: 12119/2013 15:34 Page: 9 of 58



Fire Area ID: D (Unit 4) - Unit 4 Pipe and Valve RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R030 Unit 4 Pipe and Valve Room - None R, A E Combustible Loading: E

Fire Area D Detection System, Alarm Point 20: R APhysical separation: E

Fire Area ID: DD (Unit 3) - Unit 4 480V Load Centers A and B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



093 Unit 4 480V Load Centers A and None R, D, A E Combustible Loading: EB 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



093 Unit 4 480V Load Centers A and None R, A E Combustible Loading: EB. Room - Fire Area DD Detection System, Alarm Point 2: R A

Fire Area ID: DDD (Unit 3) - Unit 4 Steam Generator Feed Pump AreaCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



066 Unit 4 Steam Generator FeedPump Area - Fire Area DDD

None None None None

Fire Safety Analysis Data Manager (4.2) FPIL - Turkey Run: 12/19/2013 15:34 Page: 10 of 58



Fire Area ID: DDD (Unit 4) - Unit 4 Steam Generator Feed Pump AreaCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



066 Unit 4 Steam Generator Feed None None None NonePump Area - Fire Area DDD

Fire Area ID: E (Unit 3) - Unit 3 Pipe and Valve RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




040 Unit 3 Pipe and Valve Room - None R, D, A E Combustible Loading: EFire Area E Detection System, Alarm Point 23: R D A

Physical separation: E

Fire Area ID: E (Unit 4) - Unit 3 Pipe and Valve RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




040 Unit 3 Pipe and Valve Room - None R, D, A E Combustible Loading: EFire Area E Detection System, Alarm Point 23: R D A


Fire Area ID: EE (Unit 3) - Unit 4 480V Load Centers C and D RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



094 Unit 4 480V Load Centers C and NoneD; Room - Fire Area EE

A E Combustible Loading: EDetection System, Alarm Point 2: A

Fire Safety Analysis Data: Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 11 of 58



Fire Area ID: EE (Unit 4) - Unit 4 480V Load Centers C and D RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None D Procedures/Recovery Actions: D094 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 AERFBS, 094-1: R S NERFBS, 094-2: R S NERFBS, 094-3: R S NERFBS, 094-4: R S NERFBS, 094-5: R S NERFBS, 094-6: R S NERFBS, 094-7: R S NERFBS, 094-8: R S N

Fire Area ID: EEE (Unit 3) - Unit 3 Steam Generator Feed Pump AreaCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



069 Unit 3 Steam Generator Feed E None E Combustible Loading: EPump Area - Fire Area EEE Curbs: E

Water Suppression, 3-10-1302: EWater Suppression, 3-10-1601: E

Fire Area ID: EEE (Unit 4) - Unit 3 Steam Generator Feed Pump AreaCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



069 Unit 3 Steam Generator Feed E None E Combustible Loading: EPump 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



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



(All) Area Wide None None R, D Procedures/Recovery Actions: R D

031

032

033

034

035036

037

038

039

048

049

050

051

058

Unit 4 Containment Spray PumpRoom - Fire Area FUnit 4 Sample Room - Fire AreaF

Units 3 and 4 Post AccidentSampling System Room - FireArea FUnit 3 Boric Acid EvaporatorPackage Room

Units 3 and 4 Valve RoomUnit 3 Boric Acid EvaporatorPackage Room - Fire Area FUnit 3 Sample Room and GasStripper Room - Fire Area FUnit 3 Containment Spray PumpRoom - Fire Area F

Unit 3 Concentrate Holding TankRoom - Fire Area F

Units 3 and 4 DeboratingDemineralizer Tank Room - FireArea F

Uhits 3 and 4 Base and CationRadwaste Demineralizers Room -Fire Area FUnits 3 and 4 PurificationDemineralizers Room - Fire AreaF:Units 3 and 4 Condensate Pumpand Monitor Tank Room - FireArea F

Units 3 and 4 Auxiliary BuildingHallway - Fire Area F

None

None

None

None

NoneNone

None

None

None

None

None

None

None

None

None

None

None

None

NoneNone

None

None

None

None

None

None

None

None

None

None

NoneNone

None

None

None

E

E

E

E

E, R

None

None

None

None

NoneNone

None

None

None

Combustible Loading: EPhysical separation: E




Combustible Control - Transient Restrictions: RCombustible Loading: EDetection System, Alarm Point 39: E R D APhysical separation: E

None

E, R, D, A

zFire Safety Analysis Data.Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 13 of 58


Fire Area ID:Compliance Basis:


F (Unit 4) - Unit 3 and 4 Auxiliary Building Hallway (18'-0")NFPA 805, Section 4.2.4, Performance Based Approach


on System System Protection Feature Required Fire Protec

e None None R, D Procedures/Recoveryntainment Spray Pump None None None Noneire Area Fmple Room - Fire Area None None None None

nd 4 Post Accident None None None None

Fire Zone ID

(All)

031

032

033

034

035036

037

038

039

048

049

050

051

058

Descripti

Area Wid

Unit 4 CoRoom - FUhit 4 SarF;Units 3 ar

ction Feature and System Details

'Actions: R D

Sampling System Room - FireArea FUnit 3 Boric Acid EvaporatorPackage Room

Units 3 and 4 Valve RoomUnit 3 Boric Acid EvaporatorPackage Room - Fire Area FUnit 3 Sample Room and GasStripper Room - Fire Area F

Unit 3 Containment Spray PumpRoom - Fire Area F

Unit 3 Concentrate Holding TankRoom - Fire Area F

Units 3 and 4 DeboratingDemineralizer Tank Room - FireArea FUnits 3 and 4 Base and CationRadwaste Demineralizers Room -Fire Area FUnits 3 and 4 PurificationDemineralizers Room - Fire AreaF.

Units 3 and 4 Condensate Pumpand Monitor Tank Room - FireArea F

Units 3 and 4 Auxiliary BuildingHallway - Fire Area F

None

NoneNone

None

None

None

None

None

None

None

None

None

NoneNone

None

None

None

None

None

None

None

None

NoneNone

None

None

None

E

E

E

E

E, R

None

NoneNone

None

None

None





Combustible Control - Transient Restrictions: RCombustible Loading: EDetection System, Alarm Point 39: E R D APhysical separation: E

E, R, D, A

Fire Safety Analysis Data'!Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 14 of 58



Fire Area ID: FF (Unit 3) - Unit 3 480V Load Centers A and B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None D Procedures/Recovery Actions: D095 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 RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



095 Unit 3 480V Load Centers A and None A None Detection System, Alarm Point 1: AB Room - Fire Area FF

Fire Area ID: FFF (Unit 3) - Units 3 and 4 Purge Supply Fan RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R107 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

107Area Wide NoneUnits 3 and 4 Purge Supply Fan NoneRoom - Fire Area FFF

None

None

R

None


None


L-2014-003. AttachmentPage 26 of 92


Fire Area ID: G (Unit 3) - Unit 3 and 4 Electrical Equipment RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



025 Units 3 and 4 Electrical None R, A E, R, S, N Combustible Loading: EEquipment Room - Fire Area G Detection System, Alarm Point 32: R A

ERFBS, 025-1: R S NERFBS, 025-2: R S NERFBS, 025-3: R S NPhysical separation: E

025A Units 3 and 4 Spare Battery None R, A None Detection System, Alarm Point 32: R ARoom - Fire Area G

Fire Area ID: G (Unit 4) - Unit 3 and 4 Electrical Equipment RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(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: EEquipment Room - Fire Area G Detection System, Alarm Point 32: R D A

ERFBS, 025-1: R S NERFBS, 025-2: R S NERFBS, 025-3: R S N

a Physical separation: E025A 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)096

Area Wide NoneUnit 3 480V Load Centers C and NoneD Room - Fire Area GG

NoneR, D, A

R, DR, S, N

Procedures/Recovery Actions: R DDetection System, Alarm Point 1: R D AERFBS, 096-1: R S NERFBS, 096-2: R S NERFBS, 096-3: R S NERFBS, 096-4: R S NERFBS, 096-5: R S NERFBS, 096-6: R S NERFBS, 096-7: R S NERFBS, 096-8: R S NERFBS, 096-9: R S N




Fire Area ID: GG (Unit 4) - Unit 3 480V Load Centers C and D RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R096 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



019 Unit 3 West Electrical Penetration None R, D R, S, N Detection System, Alarm Point 9: R DRoom - Fire Area H ERFBS, 019-1: R S N

ERFBS, 019-2: R S NERFBS, 019-3: R S NERFBS, 019-4: R S N

Fire Area ID: H (Unit 4) - Unit 3 West Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



019 Unit 3 West Electrical Penetration None None None NoneRoom - Fire Area H

Fire Area ID: HH (Unit 3) - Units 3 and 4 Cable Spreading Room and ChaseCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

098Area WideUnits 3 and 4 Cable SpreadingRoom - Fire Area HH

Units 3 and 4 Control RoomElectrical Cable Chase - FireArea HH

None

D, ANoneR, D, A

R, DR

R


Combustible Control - Transient Restrictions: RDetection System, Alarm Point 6: R D ADetection System, Modification - HH U3: RERFBS, Modification - HH U3: RGaseous Suppression, CV-1450A&B CV-1451A&B: D A

Combustible Control - Transient Restrictions: RDetection System, Alarm Point 5: D AGaseous Suppression, CV-1450A&B CV-1451A&B: D A

132 D, A D, A




Fire Area ID: HH (Unit 4) - Units 3 and 4 Cable Spreading Room and ChaseCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R, D Procedures/Recovery Actions: R D098 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 ADetection System, Modification - HH U4: RERFBS, Modification - HH U4: RGaseous 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: RElectrical Cable Chase - Fire Detection System, Alarm Point 5: D AArea HH Gaseous Suppression, CV-1450A&B CV-1451A&B: D A

Fire Area ID: I (Unit 3) - Unit 3 South Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



020 Unit 3 South Electrical None R, D, A None Detection System, Alarm Point 9: R D APenetration Room - Fire Area I

Fire Area ID: I (Unit 4) - Unit 3 South Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



020 Unit 3 South ElectricalPenetration Room - Fire Area I

None A None Detection System, Alarm Point 9: A




Fire Area ID: II (Unit 3) - Unit 4 B DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



101 Unit 4 B DC Equipment Room - None R, D, A None Detection System, Alarm Point 6: R D AFire Area II

Fire Area ID: II (Unit 4) - Unit 4 B DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None D Procedures/Recovery Actions: D101 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 RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



026 Unit 4 North Electrical None A None Detection System, Detection 026: APenetration Room - Fire Area J

Fire Area ID: J (Unit 4) - Unit 4 North Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



026 Unit 4 North ElectricalPenetration Room - Fire Area J

None R, A None Detection System, Alarm Point 10: R A

Run: 12/19/2013 15:34 Page: 19 of 58Fire Safety Analysis Data Manager (4.2) FPL - Turkey



Fire Area ID: JJ (Unit 3) - Unit 4 Battery Rack B RoomCompliance Basis:' NFPA 805, Section 4.2.4, Performance Based Approach



102 Unit 4 Battery Rack B Room - None R, D, A None Detection System, Alarm Point 6: R D AFire Area JJ

Fire Area ID: - JJ (Unit 4) - Unit 4 Battery Rack B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



102 Unit 4 Battery Rack B Room - None R, D, A None Detection System, Alarm Point 6: R D AFire Area JJ

Fire Area ID: K (Unit 3) - Unit 4 West Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



027 Unit 4 West Electrical Penetration None None None NoneRoom - Fire Area K

Fire Area ID: K (Unit 4) - Unit 4 West Electrical Penetration RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach

Fire Zone ID

027

Descripti

Unit 4 WeRoom - F

Required RequiredSuppression Detection

on System System

st Electrical Penetration None R, Dire Area K

Required FireProtection Feature Required Fire Protection Feature and System Details

None Detection System, Alarm Point 10: R D

Fire Safety Analysis Data'Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 20 of 58



Fire Area ID: KK (Unit 3) - Unit 3 Battery Rack A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



103 Unit 3 Battery Rack A Room - None R, A None Detection System, Alarm Point 6: R AFire Area KK

Fire Area ID: KK (Unit 4) - Unit 3 Battery Rack A RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



103 Unit 3 Battery Rack A Room - None A None Detection System, Alarm Point 6: AFire Area KK

Fire Area ID: L (Unit 3) - Units 3 and 4 Auxiliary Building Fan RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



028 Units 3 and 4 Auxiliary Building None None E Combustible Loading: EFan Room - Fire Area L Physical separation: E

Fire Area ID: L (Unit 4) - Units 3 and 4 Auxiliary Building Fan RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



028 Units 3 and 4 Auxiliary Building NoneFan Room - Fire Area L

None E Combustible Loading: EPhysical separation: E


L-20 14-003, AttachmentPage 32 of 92


Fire Area ID: LL (Unit 3) - Unit 3 A DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



104 Unit 3 A DC Equipment Room - None R, D, A R, S, N Detection System, Alarm Point 6: R D AFire Area LL ERFBS, 104-1: R S N

ERFBS, 104-2: R S NERFBS, 104-3: R S NERFBS, 104-4: R S NERFBS, 104-5: R S N

Fire Area ID: LL (Unit 4) - Unit 3 A DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.3.3 (a), 3-hr rated ERFBS



104 Unit 3 A DC Equipment Room - None A S, N Detection System, Alarm Point 6: AFire Area LL ERFBS, 104-1: S N

ERFBS, 104-2: S NERFBS, 104-3: S NERFBS, 104-4: S NERFBS, 104-5: S N

Fire Area ID: MM (Unit 3) - Control Room ComplexCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)097

106

Area Wide NoneUnits 3 and 4 Mechanical NoneEquipment Room - Fire Area MM

Units 3 and 4 Control Room - Fire NoneArea MM

Units 3 and 4 Control Room Roof None- Fire Area MM

None

D, A

R, D, A

None

R, DD

D

E, D


Detection System, Alarm Point 5: D AExtinguishers: DDetection System, Alarm Point 5: D ADetection System, Modification - MM: RExtinguishers: DCombustible Loading: EExtinguishers: D

106R

Fire Safety Analysis Data, Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 22 of 58



Fire Area ID: MM (Unit 4) - Control Room ComplexCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R, D Procedures/Recovery Actions: R D097 Units 3 and 4 Mechanical None D, A D Detection System, Alarm Point 5: D A

Eqluipment Room - Fire Area MM Extinguishers: D106 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: RExtinguishers: 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




045 Unit 4 Charging Pump Room - E, D, A E, D, A None Detection System, Alarm Point 7: E D AFire Area N Water Suppression, 4-10-830: E D A

Fire Area ID: N (Unit 4) - Unit 4 Charging Pump RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)045

Area WideUnit 4 Charging Pump Room -Fire Area N

None

E, ANone

E, D, ARNone

Procedures/Recovery Actions: RDetection System, Alarm Point 7: E D AWater Suppression, 4-10-830: E A




Fire Area ID: NN (Unit 3) - Units 3 and 4 A DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R108A 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 NERFBS, 108A-2: R S NERFBS, 108A-3: R S NERFBS, 108A-4: R S NGaseous Suppression, CV-1452 CV-1453: R S N A

Fire Area ID: NN (Unit 4) - Units 3 and 4 A DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




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 ARoom - Fire Area NN ERFBS, 108A-1: R S N

ERFBS, 108A-2: R S NERFBS, 108A-3: R S NERFBS, 108A-4: R S NGaseous Suppression, CV-1452 CV-1453: R S N A

Fire Area ID: 0 (Unit 3) - Unit 3 and 4 Boric Acid Tanks and Pumps RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

041

055

Area Wide NoneUnits 3 and 4 Boric Acid Tanks Noneand Pump Room - Fire Area 0Unit 3 Charging Pump Room - E, AFire Area 0

NoneNone

E, D, A

RE



Detection System, Alarm Point 7: E D AWater Suppression, 3-10-841: E A

None

Fire Safety Analysis Data'Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 24 of 58



Fire Area ID: 0 (Unit 4) - Unit 3 and 4 Boric Acid Tanks and Pumps RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




041 Units 3 and 4 Boric Acid Tanks None None E Physical separation: Eand 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 ExchangerCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



047 Unit 4 Component Cooling Pump E None E Combustible Loading: Earnd Heat Exchanger - Fire Area Water Suppression, 4-10-833: EOD Water Suppression, 4-10-835: E

Fire Area ID: OD-047 (Unit 4) - Unit 4 Component Cooling Pump and Heat ExchangerCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)047

Area Wide None

Unit 4 Component Cooling Pump Eand Heat Exchanger - Fire AreaOD

None

DDE

Procedures/Recovery Actions: D

Combustible Loading: EDetection System, Alarm Point 28: DWater Suppression, 4-10-833: EWater Suppression, 4-10-835: E




Fire Area ID: OD-054 (Unit 3) - Unit 3 Component Cooling Pump and Heat Exchanger AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



054 Unit 3 Component Cooling Pump E None E Combustible Loading: Eand Heat Exchanger Area - Fire Water Suppression, 3-10-837: EArea OD Water Suppression, 3-10-839: E

Fire Area ID: OD-054 (Unit 4) - Unit 3 Component Cooling Pump and Heat Exchanger AreaCompliance Basis: NFPA 805, Section 4.2.3.3 (b), 20ft horizontal separation



054 Unit 3 Component Cooling Pump E None E Combustible Loading: Eand Heat Exchanger Area - Fire Water Suppression, 3-10-837: EArea OD Water Suppression, 3-10-839: E

Fire Area ID: OD-076 (Unit 3) - Unit 4 Lube Oil Reservoir AreaCompliance Basis: NFPA 805, Section 4.2.3.3 (b), 20ft horizontal separation



076 Unit 4 Lube Oil Reservoir Area - None None None NoneFire Area OD

Fire Area ID: OD-076 (Unit 4) - Unit 4 Lube Oil Reservoir AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



076 Unit 4 Lube Oil Reservoir Area - NoneFire Area OD

D None Detection System, Alarm Point 12: D




Fire Area ID: OD-077 (Unit 3) - Unit 4 Laydown Area, Instrument Air Compressors and Condensate Storage AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




077 Unit 4 Laydown Area, Instrument None None None NoneAir Compressors andCondensate Storage Area - FireArea OD

Fire Area ID: OD-077 (Unit 4) - Unit 4 Laydown Area, Instrument Air Compressors and Condensate Storage AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




077 Unit 4 Laydown Area, Instrument None None None NoneAir Compressors andCondensate Storage Area - FireArea OD

Fire Area ID: OD-078 (Unit 3) - Unit 4 Instrument Air Equipment AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



078 Unit 4 Instrument Air Equipment 0Area - Fire Area OD

D D Detection System, All available - OD-078: DPre-fire Plan: DWater Suppression, 4-10-1302: DWater Suppression, 4-10-1590: DWater Suppression, 4-10-1601: D







078 Unit 4 Instrument Air Equipment D D D Detection System, All available - OD-078: DArea - Fire Area OD Pre-fire Plan: D

Water Suppression, 4-10-1302: DWater Suppression, 4-10-1590: DWater Suppression, 4-10-1601: D

Fire Area ID: OD-079 (Unit 3) - Outdoor Area West of Unit 4 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



079 Outdoor Area West of Unit 4 None None E Combustible Loading: EContainment - Fire Area OD Curbs: E

Extinguishers: EPhysical separation: E

Fire Area ID: OD-079 (Unit 4) - Outdoor Area West of Unit 4 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

079Area WideOutdoor Area West of Unit 4Containment - Fire Area OD

None

DNoneNone

R, DE, D

Procedures/Recovery Actions: R DCombustible Control - Transient Restrictions: DCombustible Loading: ECurbs: EExtinguishers: EPhysical separation: EWater Suppression, All available - OD-079: D


L-20 14-003, AttachmentPage 39 of 92


Fire Area ID: OD-080 (Unit 3) - Unit 4 Main Condenser AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



080 Unit 4 Main Condenser Area - E None E Combustible Loading: EFire Area OD Curbs: E





080 Unit 4 Main Condenser Area - E None E, D Combustible Control - Transient Restrictions: DFire Area OD Combustible Loading: E


Fire Area ID: OD-081 (Unit 3) - Unit 4 Main and Start-up Transformer and Unit 3 Turbine Lube Oil Reservoir AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

081

Area Wide

Unit 4 Main and Start-UpTransformer and Unit 3 TurbineLube Oil Reservoir Area - FireArea OD

None

E, DNone

D

R

E


Combustible Loading: ECurbs: EDetection System, Alarm Point 11: DWater Suppression, 3-10-1590: E DWater Suppression, 4-10-1575: E DWater Suppression, 4-10-1611: E D




Fire Area ID: OD-081 (Unit 4) - Unit 4 Main and Start-up Transformer and Unit 3 Turbine Lube Oil Reservoir AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



081 Unit 4 Main and Start-Up E, D D E Combustible Loading: ETransformer and Unit 3 Turbine Curbs: ELube Oil Reservoir Area - Fire Detection System, Alarm Point 11: DArea OD Water Suppression, 3-10-1590: E D

Water Suppression, 4-10-1575: E DWater Suppression, 4-10-1611: E D

Fire Area ID: OD-082 (Unit 3) - Unit 4 Auxiliary Transformer AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



082 Unit 4 Auxiliary Transformer Area E, D D E Combustible Loading: E- Fire Area OD Curbs: E

Detection System, Alarm Point 14: DExtinguishers: EHose Stations: EWater Suppression, 3-10-1590: E DWater Suppression, 4-10-1302: E DWater Suppression, 4-10-1581: E DWater Suppression, 4-10-1601: E D




082 Unit 4 Auxiliary Transformer Area E, D D E Combustible Loading: E- Fire Area OD Curbs: E

Detection System, Alarm Point 14: DExtinguishers: EHose Stations: EWater Suppression, 3-10-1590: E DWater Suppression, 4-10-1302: E DWater Suppression, 4-10-1581: E DWater Suppression, 4-10-1601: E D







(All) Area Wide None None R Procedures/Recovery Actions: R083 Unit 3 Instrument Air Equipment E, D D E Combustible Loading: E

Area - Fire Area OD Curbs: EDetection System, All available - OD-083: DExtinguishers: EPhysical separation: EWater Suppression, 3-10-1302: E DWater Suppression, 3-10-1601: E D




(All) Area Wide None None R Procedures/Recovery Actions: R083 Unit 3 Instrument Air Equipment E, D D E Combustible Loading: E

Area - Fire Area OD Curbs: EDetection System, All available - OD-083: DExtinguishers: EPhysical separation: EWater Suppression, 3-10-1302: E DWater Suppression, 3-10-1601: E D

Fire Area ID: OD-084 (Unit 3) - Units 3 and 4 Auxiliary Feedwater Pump AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




084 Units 3 and 4 Auxiliary Feedwater E, DPump Area - Fire Area OD

None E Combustible Loading: ECurbs: EExtinguishers: EWater Suppression, 3-10-1601: E D

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Fire Area ID: OD-084 (Unit 4) - Units 3 and 4 Auxiliary Feedwater Pump AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R084 Units 3 and 4 Auxiliary Feedwater E, D None E, R Combustible Loading: E

Pump Area - Fire Area OD Curbs: EExtinguishers: ETransient Combustible Restrictions: RWater Suppression, 3-10-1601: E D




085 Unit 3 Main Condenser Area - E None E Combustible Loading: EFire Area OD Curbs: E





085 Unit 3 Main Condenser Area - E None E Combustible Loadino: EFire Area OD Curbs: E





Fire Area ID: OD-086 (Unit 3) - Unit 3 Main Transformer and Startup TransformerCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



086 Unit 3 Main Transformer and E, D D E, R Combustible Loading: EStartup Transformer - Fire Area Detection System, All available - OD-086: DOD ERFBS, Modification - OD-86 U3: R

Fire Stops and Radiant Energy Heat Shield: RWater Suppression, 3-10-1575: E DWater Suppression, 3-10-1611: E D

Fire Area ID: OD-086 (Unit 4) - Unit 3 Main Transformer and Startup TransformerCompliance Basis: NFPA-805, Section 4.2.4, Performance Based Approach



086 Unit 3 Main Transformer and E, D D E, R Combustible Loading: EStartup Transformer - Fire Area Detection System, All available - OD-086: DOD ERFBS, Modification - OD-86 U4: R





087 Unit 3 Auxiliary Transformer Area E, D- Fire Area OD

D None Detection System, Alarm Point 13: DWater Suppression, 3-10-1302: E DWater Suppression, 3-10-1581: E DWater Suppression, 3-10-1601: E D







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


Fire Area ID: OD-088 (Unit 3) - Unit 3 Switchgear/D.G. Building VestibuleCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach

a Required RequiredSuppression Detection Required Fire


088 Unit 3 Switchgear / DG Building None None E Combustible Loading: EVestibule - Fire Area OD Physical separation: E

Fire Area ID: OD-088 (Unit 4) - Unit 3 Switchgear/D.G. Building VestibuleCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



088 Unit 3 Switchgear / DG Building None None E Combustible Loading: EVestibule - Fire Area OD Physical separation: E

Fire Area ID: OD-089 (Unit 3) - Unit 3 Condensate Storage Tank AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



089 Unit 3 Condensate Storage Tank None None E, D Combustible Control - Transient Restrictions: DArea - Fire Area OD Combustible Loading: E




Fire Area ID: OD-089 (Unit 4) - Unit 3 Condensate Storage Tank AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




089 Unit 3 Condensate Storage Tank None None E Combustible Loading: EArea - Fire Area OD

Fire Area ID: OD-090 (Unit 3) - Unit 3 & 4 Emergency Diesel Generator Oil Storage TankCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



090 Unit 3 & 4 Emergency Diesel None None None NoneGenerator Oil Storage Tank Area- Fire Area OD

Fire Area ID: OD-090 (Unit 4) - Unit 3 & 4 Emergency Diesel Generator Oil Storage TankCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



090 Unit 3 & 4 Emergency Diesel None None None NoneGenerator Oil Storage Tank Area- Fire Area OD

Fire Area ID: OD-091 (Unit 3) - Unit 4 Condensate Pump AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



091 Unit 4 Condensate Pump Area - E, D None E Combustible Loading: EFir'e Area OD Curbs: E








091 Unit 4 Condensate Pump Area - E, D None E Combustible Loading: EFire Area OD Curbs: E





092 Unit 3 Condensate Pump Area - E None None Water Suppression, 3-10-1302: EFire Area OD Water Suppression, 3-10-1601: E




092 Unit 3 Condensate Pump Area - E None None Water Suppression, 3-10-1302: EFire Area OD Water Suppression, 3-10-1601: E

Fire Area ID: OD-105 (Unit 3) - Units 3 and 4 Turbine Building Mezzanine DeckCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

105Area Wide

Units 3 and 4 Turbine BuildingMezzanine Deck - Fire Area OD

None

NoneNone

None

R

E






Fire Area ID: OD-1 05 (Unit 4) - Units 3 and 4 Turbine Building Mezzanine DeckCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




105 Units 3 and 4 Turbine Building None None E Combustible Loading: EMezzanine Deck - Fire Area OD

Fire Area ID: OD-113 (Unit 3) - Unit 4 Feedwater PlatformCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




113 Unit 4 Feedwater Platform - Fire None None E Combustible Loading: EArea OD




(All) Area Wide None None R Procedures/Recovery Actions: R113 Unit 4 Feedwater Platform - Fire None D E, R, D Combustible Loading: E

Area OD Detection System, Alarm Point 29: DRadiant Barrier: R D

Fire Area ID: OD-114 (Unit 3) - Unit 4 Main Steam Header PlatformCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)114

Area WideUnit 4 Main Steam HeaderPlatform - Fire Area OD

NoneNone

NoneNone

RE

Procedures/Recovery Actions: RCombustible Loading: E




Fire Area ID: OD-1 14 (Unit 4) - Unit 4 Main Steam Header PlatformCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R114 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 PlatformCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




115 Unit 3 Main Steam Header None None E Combustible Loading: EPlatform - Fire Area OD

Fire Area ID: OD-115 (Unit 4) - Unit 3 Main Steam Header PlatformCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R115 Unit 3 Main Steam Header None None E Combustible Loading: E

Platform - Fire Area OD




(All)

116

Area Wide None

Unit 3 Feedwater Platform - Fire NoneArea OD

NoneD

RE, R, D

Procedures/Recovery Actions: RCombustible Control - Transient Restrictions: DCombustible Loading: EDetection System, Alarm Point 30: DRadiant Barrier: R D








116 Unit 3 Feedwater Platform - Fire None None E, D Combustible Control - Transient Restrictions: DArea OD Combustible Loading: E

Fire Area ID: OD-117 (Unit 3) - Units 3 and 4 Turbine DeckCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




117 Units 3 and 4 Turbine Deck - Fire None None E Combustible Loading: EArea OD

Fire Area ID: OD-117 (Unit 4) - Units 3 and 4 Turbine DeckCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




117 Units 3 and 4 Turbine Deck - Fire None None E Combustible Loading: EArea OD

Fire Area ID: OD-118 (Unit 3) - Units 3 and 4 Auxiliary Building RoofCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



118 Units 3 and 4 Auxiliary Building None None E, D Combustible Control - Transient Restrictions: DRoof - Fire Area OD Combustible Loading: E

Hot Work Control: DPhysical separation: E




Fire Area ID: OD-118 (Unit 4) - Units 3 and 4 Auxiliary Building RoofCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



118 Units 3 and 4 Auxiliary Building None None E, D Combustible Control - Transient Restrictions: DRoof - Fire Area OD Combustible Loading: E

Hot Work Control: DPhysical separation: E

Fire Area ID: , OD-122 (Unit 3) - Units 3 and 4 Water Treatment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R122 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R122 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 AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



123 Units 3 and 4 Refueling WaterStorage Tanks Area - Fire AreaOD

None None None None




Fire Area ID: OD-123 (Unit 4) - Units 3 and 4 Refueling Water Storage Tanks AreaCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



123 Uhits 3 and 4 Refueling Water None None None NoneStorage Tanks Area - Fire AreaOD

Fire Area ID: OD-124 (Unit 3) - Outside Area NE of Unit 3 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



124 Outside Area NE of Unit 3 None None None NoneContainment - Fire Area OD

Fire Area ID: OD-124 (Unit 4) - Outside Area NE of Unit 3 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



124 Outside Area NE of Unit 3 None None None NoneContainment - Fire Area OD

Fire Area ID: OD-125 (Unit 3) - Units 3 and 4 Land Area South of Unit 4 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



125 Units 3 and 4 Land Area South of NoneUnit 4 Containment - Fire AreaOD

None None None




Fire Area ID: OD-125 (Unit 4) - Units 3 and 4 Land Area South of Unit 4 ContainmentCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



125 Units 3 and 4 Land Area South of None None None NoneUnit 4 Containment - Fire AreaOD

Fire Area ID: OD-128 (Unit 3) - Units 3 and 4 Distribution SwitchyardCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



128 Units 3 and 4 Distribution None None None NoneSwitchyard - Fire Area OD

Fire Area ID: OD-128 (Unit 4) - Units 3 and 4 Distribution SwitchyardCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



128 Units 3 and 4 Distribution None None None NoneSwitchyard - Fire Area OD

Fire Area ID: OD-1 31 (Unit 3) - Units 3A and 3B Diesel Generator Radiator RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



131 Units 3A and 3B DieselGenerator Radiator Rooms - FireArea OD

None None None None




Fire Area ID: OD-131 (Unit 4) - Units 3A and 3B Diesel Generator Radiator RoomsCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



131 Units 3A and 38 Diesel None None None NoneGenerator Radiator Rooms - FireArea OD

Fire Area ID: OD-143 (Unit 3) - Unit 3 Emergency Diesel Generator RoofCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



143 Unit 3 Emergency Diesel None None None NoneGenerator Roof - Fire Area OD-143

Fire Area ID: OD-143 (Unit 4) - Unit 3 Emergency Diesel Generator RoofCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



143 Unit 3 Emergency Diesel None None None NoneGenerator Roof - Fire Area OD-143

Fire Area ID: OD-999 (Unit 3) - Miscellaneous AreasCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)

999

Area Wide NoneMiscellaneous Areas - Fire Area NoneOD

None

None

RNone


None




Fire Area ID: OD-999 (Unit 4) - Miscellaneous AreasCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




999 Miscellaneous Areas - Fire Area None None None NoneOD

Fire Area ID: OD-Intake (Unit 3) - Intake StructureCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



119 Unit 4 Circulating Water Intake None None E Combustible Loading: EStructure - Fire Area OD

120 Unit 3 Circulating Water Intake None None E Combustible Loading: EStructure - Fire Area OD

121 Units 3 and 4 Intake Laydown None None None NoneArea - Fire Area OD

Fire Area ID: OD-Intake (Unit 4) - Intake StructureCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



119

120

121

Unit 4 Circulating Water IntakeStructure - Fire Area ODUnit 3 Circulating Water IntakeStructure - Fire Area ODUnits 3 and 4 Intake LaydownArea - Fire Area OD

None

None

None

D

D

None

E

E

None

Combustible Loading: EDetection System, Alarm Point 26: DCombustible Loading: EDetection System, Alarm Point 27: DNone




Fire Area ID: 00 (Unit 3) - Units 3 and 4 B DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




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 ARoom - Fire Area 00 ERFBS, 108B-1: R S N

ERFBS, 108B-2: R S NGaseous Suppression, CV-1454 CV-1455: S N A

Fire Area ID: 00 (Unit 4) - Units 3 and 4 B DC Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




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 ARoom - Fire Area 00 ERFBS, 108B-1: R S N

ERFBS, 108B-2: R S NGaseous Suppression, CV-1454 CV-1455: D S N A

Fire Area ID: P (Unit 3) - Unit 4 Containment BuildingCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



059 Unit 4 Containment Buildino - Fire None A E Combustible Loading: EArea P Detection System, Alarm Point 43: A


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Fire Area ID: P (Unit 4) - Unit 4 Containment BuildingCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



059 Unit 4 Containment Building - Fire None E, D, A E, R, S, N Combustible Loading: E S NArea P Detection System, Alarm Point 43: E D A

Detection System, Alarm Point 44: E D AERFBS, 059-1: E S NERFBS, 059-2: E S NERFBS, 059-3: E S NERFBS, 059-4: E S NERFBS, 059-5: E S NERFBS, 059-6: E S NRadiant Energy Heat Shield: E R S N

Fire Area ID: PP (Unit 3) - Unit 4 Battery Rack A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



109 Unit 4 Battery Rack A Room - None R, A None Detection System, Alarm Point 15: R AFire Area PP

Fire Area ID: PP (Unit 4) - Unit 4 Battery Rack A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



109 Unit 4 Battery Rack A Room - None R, A None Detection System, Alarm Point 15: R AFire Area PP




Fire Area ID: Q (Unit 3) - Unit 3 Containment BuildingCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



060 Unit 3 Containment Building - Fire None E, D E, R, S, N Combustible Loading: E S NArea Q Detection System, Alarm Point 3: E D

Detection System, Alarm Point 4: E DERFBS, 060-1: ES NERFBS, 060-10: E S NERFBS, 060-2: E S NERFBS, 060-3: E S NERFBS, 060-4: E S NERFBS, 060-5: E S NERFBS, 060-6: E S NERFBS, 060-7: E S NERFBS, 060-8: E S NERFBS, 060-9: E S NRadiant Energy Heat Shield: E R S N

Fire Area ID: Q (Unit 4) - Unit 3 Containment BuildingCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



060 Unit 3 Containment Building - Fire None None E Combustible Loading: EArea Q

Fire Area ID: QQ (Unit 3) - Unit 3 Battery Rack B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



110 Unit 3 Battery Rack B Room -Fire Area QQ

None R, A None Detection System, Alarm Point 15: R A

Fire Safety Analysis Data- Manager (4.2) FPL - Turkey Run: 12/19/2013 15:34 Page: 47 of 58



Fire Area ID: QQ (Unit 4) - Unit 3 Battery Rack B RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



110 Unit 3 Battery Rack B Room - None A None Detection System, Alarm Point 15: AFire Area QQ

Fire Area ID: R (Unit 3) - Unit 4 Reactor Control Rod Equipment RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



061 Unit 4 Reactor Control Rod None A None Detection System, Alarm Point 6: AEquipment Room - Fire Area R

Fire Area ID: R (Unit 4) - Unit 4 Reactor Control Rod Equipment RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None D Procedures/Recovery Actions: D061 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 RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



138 Unit 4 Train A Emergency Diesel EGenerator Room - Fire Area RR

None None Water Suppression, 4-10-1112: E




Fire Area ID: RR (Unit 4) - Unit 4 Train A Emergency Diesel Generator RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



138 Unit 4 Train A Emergency Diesel E, R, D R, D None Detection System, All available - RR: R DGenerator Room - Fire Area RR Water Suppression, 4-10-1112: E R D

Fire Area ID: S (Unit 3) - Units 3 and 4 Computer RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



062 Units 3 and 4 Computer Room - None R, D, A None Detection System, Alarm Point 31: R D AFire Area S

Fire Area ID: S (Unit 4) - Units 3 and 4 Computer RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



062 Units 3 and 4 Computer Room - None R, D, A None Detection System, Alarm Point 31: R D AFire Area S

Fire Area ID: SS (Unit 3) - Unit 4 Train B Emergency Diesel Generator RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



133 Unit 4 Train B Emergency Diesel E, A A None Detection System, All available - SS: AGenerator Room - Fire Area SS Water Suppression, 4-10-1113: E A




Fire Area ID: SS (Unit 4) - Unit 4 Train B Emergency Diesel Generator RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



133 Unit 4 Train B Emergency Diesel E, R, A R, D, A None Detection System, All available - SS: R D AGenerator 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


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: D063 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 RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



063 Unit 3 Reactor Control Rod None A None Detection System, Alarm Point 6: AEquipment Room - Fire Area T

Fire Area ID: TT (Unit 3) - Train A SD - Unit 3 Switchgear Room 3DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



134 Unit 3 Switchgear Room 3D - Fire NoneArea TT

A E Combustible Loading: EDetection System, Detection 134: A




Fire Area ID: TT (Unit 3) - Train B SD - Unit 3 Switchgear Room 3DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



134 Unit 3 Switchgear Room 3D - Fire None A E Combustible Loading: EArea TT Detection System, Detection 134: A

Fire Area ID: TT (Unit 4) - Train A SD - Unit 3 Switchgear Room 3DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area




Fire Area ID: TT (Unit 4) - Train B SD - Unit 3 Switchgear Room 3DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area




Fire Area ID: U (Unit 3) - 4160V Switchgear 4B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



067 4160V Switchgear 4B Room -Fire Area U

None R, D, A E Combustible Loading: EDetection System, Alarm Point 2: R ADetection System, Modification - U U3: DPhysical separation: E




Fire Area ID: U (Unit 4) - 4160V Switchgear 4B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R, D Procedures/Recovery Actions: R D067 4160V Switchgear 4B Room - None R, D, A E, R Combustible Loading: E

Fire Area U Detection System, Alarm Point 2: R D ADetection System, Modification - U U4: DERFBS, Modification U U4: RPhysical separation: E

Fire Area ID: UU (Unit 3) - Train A SD - Unit 4 Switchgear Room 4DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



139 Unit 4 Switchgear Room 4D - Fire None A E Combustible Loading: EArea UU Detection System, Detection 139: A

Fire Area ID: UU (Unit 3) - Train B SD - Unit 4 Switchgear Room 4DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area




Fire Area ID: UU (Unit 4) - Train A SD - Unit 4 Switchgear Room 4DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



139 Unit 4 Switchgear Room 4D - Fire NoneArea UU

A E Combustible Loading: EDetection System, Detection 139: A




Fire Area ID: UU (Unit 4) - Train B SD - Unit 4 Switchgear Room 4DCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area




Fire Area ID: V (Unit 3) - 4160V Switchgear 4A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



068 4160V Switchgear 4A Room - None R, D, A None Detection System, Alarm Point 2: R AFire Area V Detection System, Modification - V U3: D

Fire Area ID: V (Unit 4) - 4160V Switchgear 4A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



068 4160V Switchgear 4A Room - None R, D, A R, S, N Detection System, Alarm Point 2: R D AFire Area V Detection System, Modification - V U4: D

ERFBS, 068-1: R S NERFBS, 068-2: R S NERFBS, 068-3: R S NERFBS, 068-4: R S N

Fire Area ID: W (Unit 3) - Unit 4 Train A Emergency Diesel Generator Control RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



140 Unit 4 Train A Emergency Diesel None A E Combustible Loading: EGenerator Control Room - FireArea VV

Detection System, All available - VV: A




Fire Area ID: W (Unit 4) - Unit 4 Train A Emergency Diesel Generator Control RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



140 Unit 4 Train A Emergency Diesel None R, D, A E Combustible Loading: EGenerator Control Room - Fire Detection System, All available - W: R D AArea W

Fire Area ID: W (Unit 3) - 4160V Switchgear 3B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach




070 4160V Switchgear 3B Room - None R, D, A E, R, S, N Detection System, Alarm Point 1: R D AFire Area W Detection System, Modification - W U3: D

ERFBS, 070-1: R S NERFBS, 070-2: R S NPhysical separation: E

Fire Area ID: W (Unit 4) - 4160V Switchgear 3B RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)070

Area Wide4160V Switchgear 3B Room -Fire Area W

NoneNone

NoneR, D, A

RE


Detection System, Alarm Point 1: R D ADetection System, Modification - W U4: DPhysical separation: E




Fire Area ID: WW (Unit 3) - Unit 4 Train A Diesel Fuel Oil Handling AreasCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



141 Unit 4 Train A Diesel Oil Transfer E, A A None Detection System, Detection 141: APump Room - Fire Area WW Water Suppression, 4-10-1122 (4A): E A

142 Unit 4 Train A Diesel Oil Storage None None None NoneTank - Fire Area WW

Fire Area ID: WW (Unit 4) - Unit 4 Train A Diesel Fuel Oil Handling AreasCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



141 Unit 4 Train A Diesel Oil Transfer E, A A None Detection System, Detection 141: APump Room - Fire Area WW Water Suppression, 4-10-1122 (4A): E A

142 Unit 4 Train A Diesel Oil Storage None None None NoneTank - Fire Area WW

Fire Area ID: X (Unit 3) - 4160V Switchgear 3A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All)071

Area Wide

4160V Switchgear 3A Room -Fire Area X

None

None

NoneD, A

R, DR, S, N

Procedures/Recovery Actions: R DDetection System, Alarm Point 1: D ADetection System, Modification - X U3: DERFBS, 071-1: R S NERFBS, 071-2: R S N




Fire Area ID: X (Unit 4) - 4160V Switchgear 3A RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



(All) Area Wide None None R Procedures/Recovery Actions: R071 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 AreasCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



136 Unit 4 Train B Diesel Oil Transfer E, A A None Detection System, Detection 136: APump Room - Fire Area XX Water Suppression, 4-10-1122 (4B): E A

137 Unit 4 Train B Diesel Oil Storage None None None NoneTank -Fire Area XX

Fire Area ID: XX (Unit 4) - Unit 4 Train B Diesel Fuel Oil Handling AreasCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



136 Unit 4 Train B Diesel Oil Transfer E, A A None Detection System, Detection 136: APump Room - Fire Area XX Water Suppression, 4-10-1122 (4B): E A

137 Unit 4 Train B Diesel Oil Storage None None None NoneTank - Fire Area XX

Fire Area ID: Y (Unit 3) - Unit 3 Train B Emergency Diesel Generator BuildingCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



072 Unit 3 Train B Emergency DieselGenerator Building - Fire Area Y

D, A D, A None Detection System, Alarm Point 16: D AWater Suppression, 3-10-844: D A




Fire Area ID: Y (Unit 4) - Unit 3 Train B Emergency Diesel Generator BuildingCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



072 Unit 3 Train B Emergency Diesel A A None Detection System, Alarm Point 16: AGenerator Building - Fire Area Y Water Suppression, 3-10-844: A

Fire Area ID: YY (Unit 3) - Unit 4 Train B Emergency Diesel Generator Control RoomCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



135 Unit 4 Train B Emergency Diesel None A E Combustible Loading: EGenerator Control Room - Fire Detection System, Detection 135: AArea YY

Fire Area ID: YY (Unit 4) - Unit 4 Train B Emergency Diesel Generator Control RoomCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



135 Unit 4 Train B Emergency Diesel None R, D, A E Combustible Loading: EGenerator Control Room - Fire Detection System, All available - YY: R D AArea YY

Fire Area ID: Z (Unit 3) - Unit 3 Train A Emergency Diesel Generator BuildingCompliance Basis: NFPA 805, Section 4.2.4, Performance Based Approach



073 Unit 3 Train A Emergency Diesel D, A D, A None Detection System, Alarm Point 16: D AGenerator Building - Fire Area Z Water Suppression, 3-10-847: D A




Fire Area ID: Z (Unit 4) - Unit 3 Train A Emergency Diesel Generator BuildingCompliance Basis: NFPA 805, Section 4.2.3.2, Separate Fire Area



073 Unit 3 Train A Emergency Diesel A A None Detection System, Alarm Point 16: AGenerator Building - Fire Area Z Water Suppression, 3-10-847: A



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: "thebrigade leader and at least two brigade members shall have sufficient training and knowledge ofnuclear safety systems to understand the effects of fire and fire suppressants on nuclear safetyperformance criteria," or if the exception is used, which allows the "sufficient training andknowledge" 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 operationsadvisor (if the exception is used).

An approach acceptable to the staff for meeting this training and knowledge requirement isprovided in Regulatory Guide 1.189, Revision 2, "Fire Protection for Operating Nuclear PowerPlants," Section 1.6.4.1, "Qualifications," which states:

The brigade leader and at least two brigade members should have sufficienttraining in or knowledge of plant systems to understand the effects of fire and firesuppressants on safe-shutdown capability. The brigade leader should becompetent to assess the potential safety consequences of a fire and advise controlroom personnel. Such competence by the brigade leader may be evidenced bypossession of an operator's license or equivalent knowledge of plant systems.Nuclear power plants staffed with a dedicated professional fire department mayuse a fire team advisor to assess the potential safety consequences of a fire andadvise the control room and incident commander. The fire team advisor shouldpossess an operator's license or equivalent knowledge of plant systems and bededicated to supporting the fire incident commander during fire emergencyevents. The fire team advisor does not need to meet the qualifications of a firebrigade member, but if he or she does not, there should be five available qualifiedfire brigade members, in addition to the fire team advisor."

If applicable, another option available with regard to this attribute is to maintain the fireprotection 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 anoperations 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 orknowledge of plant safety related systems to understand the effects of fire and fire suppressantson 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. TheFire Brigade shall consist of at least five members and shall be maintained on site at alltimes. Fire Brigade composition may be less than the minimum required. for a period oftime not to exceed 2 hours in order to accommodate unexpected absence of Fire Brigademembers provided immediate action is taken to restore the Fire Brigade minimumrequirements.

4.2.1 The Fire Brigade consists of the Fire Brigade Leader and four other Fire Brigademembers who are listed on the active Fire Brigade assignment sheet. The Fire BrigadeLeader and at least two Fire Brigade members shall have sufficient training in orknowledge of nuclear safety related systems to understand the effects of fire or fire


suppressants on safe shutdown capability. The Fire Brigade shall not include the ShiftManager and the other members of the minimum shift crew necessary for safe shutdownof the unit and any personnel required for other essential functions during a fireemergency."

The Assistant Operations Manager is responsible for providing five individuals per shift who arequalified to be members of the Fire Brigade, one of which must be a qualified Fire BrigadeLeader. The Fire Brigade Leader and at least two Fire Brigade members shall have sufficienttraining in or knowledge of plant safety related systems to understand the effects of fire and firesuppressants on safe shutdown capability.

The Fire Brigade Leader and two members are fully qualified Nuclear System Operators, whoreceived training in Systems, Off-Normal Operating Procedures, and Fire Protection. TurkeyPoint Training and Operations have verified that their level of knowledge is commensurate withthat of a Licensed Operator for Safe Shutdown systems needed to lead the fire brigade. Thebrigade is fully manned by Nuclear System Operators.

Nuclear System Operators receive full Systems and Fire Protection Training while in InitialClass. They are required to attend requalification classes throughout the year on operation of thesystems and fire event impacts to the control room. Fire Brigade members participate, as aminimum, quarterly in fire drill exercises. Lesson Plans Fire Protection Systems and AlternateShutdown and Safe Shutdown Appendix R Systems (LP 6902143 and 6902160) are taughtduring initial Nuclear Systems Operator classes and on a recurring 4 year basis to ensure FireBrigade Leaders and members remain knowledgeable on plant systems and the effects of a fireon safe shutdown capability. With the exception of component operability determinations theNuclear Systems Operators objectives in the above lesson plans are exactly the same as LicensedOperators objectives. Both Nuclear System Operators and Licensed Operators are taught thesame level of systems training pertaining to Fire Protection and Alternate Safe Shutdown andAppendix R systems. In addition to the training requirements, Fire Brigade Leader selectionrequires 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, "Alignswith 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 whatspecifically 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


RESPONSE:

The following additional details explain why PTN's safe shutdown (SSD) methodology forassessing their nuclear safety capability post-fire "Aligns with [the] Intent" of the guidanceprovided 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 performingall of the required safe shutdown functions and designate this set of systems as a safeshutdown path. In many cases, paths may be defined on a divisional basis since theavailability of electrical power and other support systems must be demonstrated for eachpath. During the equipment selection phase, identify any additional support systems andlist them for the appropriate path.

Alignment Basis from PTN NFPA 805 LAR: The safe shutdown logics show thecombinations of systems available, but specific "paths" are not always identified. Whereapplicable, specific train, electrical division, and other support systems are evident in thesafe shutdown logic diagrams.

Additional Details: Per 5610-M-722A (Nuclear Safety Capability Fire ShutdownAnalysis Basis Document), Attachment B, Section 5.2:

"5.2 Safe Shutdown Logic Diagrams

The Safe Shutdown Logic Diagrams depict the required plant response at thesystem and component level to accomplish safe shutdown. The logic diagramsonly identify the required condition for SSD components/systems included in theMEL [(Master Equipment List)] and contain two levels of detail. Each isidentified and discussed below.

5.2.1 The objective of the System Logic Diagram (SLD) is to provide anoverview or road map regarding the plant systems credited toaccomplish post-fire safe shutdown. The following guidelinesshould be used in developing the SLD:a. The systems associated with SSD components identified in

the MEL should be modeled according to their role inaccomplishing safe shutdown given the Nuclear SafetyPerformance Criteria identified in Section 1.5.1 of NFPA805.

b. Each system required to achieve each safe shutdownfunction should be shown.

c. Each functional requirement of a system or conditionachieved when a system is required to achieve more thanone safe shutdown function should be shown separately(e.g., the CVCS System at PTN will be required for RCSmakeup, boration, and RCP seal cooling).

d. The required essential mechanical/electrical andenvironmental support systems should be shown. However,the specific relationship between the support system andthe primary system should not be shown on the SLD;rather, this relationship should be depicted on theappropriate CLD(s) discussed in Section 5.2.2 of thisattachment.


e. The required primary and support systems should becombined to depict the achievement of hot and coldshutdown."

This approach was chosen because it was felt that the pictorial representation of therequired information provided a more condensed and user friendly approach toidentifying 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 usedto achieve safe shutdown, but does not explicitly identify each separate path and providethat path with a designation as recommended in the guidance in NET 00-01, Section3.1.3.3. The specific set of systems used to achieve SSD is identified for each area, butnot through any specific path designation. Thus only the intent of the guidance in NEI00-01, Section 3.1.3.3 is met by the PTN SSD methodology for nuclear safety capabilityassessment (NSCA). This is the only reason why this section was listed as "Aligns withIntent" in the PTN NFPA 805 LAR.

See also response to b) below.

L-2014-003, AltachmentPage 73 of92

7,tCtEARf SAMlY CAPABILST LOGIC DtAGHA3P" hJNYT FOGI -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)


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. Thepath will serve to document the combination of systems relied upon for safe shutdown ineach fire area. Refer to Attachment 1 to this document for an example of a tableillustrating how to document the various combinations of systems for selected shutdownpaths.

Alignment Basis from PTN NFPA 805 LAR: Path designations are not assigned toeach possible combination of systems available to achieve safe shutdown. Rather, aspecific combination of systems capable of achieving each performance goal has beenidentified for each unit for each fire area. Within these credited systems are componentsand systems relied upon to perform the shutdown function and whose spurious operationcould adversely affect that system's ability to achieve its safe shutdown function.

Additional Details: The only reason that the PTN SSD methodology for NSCA onlyaligns with the intent of this guidance rather than aligning fully is that the safe shutdownpaths are not explicitly assigned separate designations. All systems are still identified foreach area (thus meeting the intent of the guidance), but those systems are not groupedtogether and called "Safe Shutdown Path 1", "Safe Shutdown Path 2", etc. as explicitlyprescribed by the guidance in NEI 00-01. Not naming the set of systems used to achievesafe 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 notpresent in Revision 1 of NET 00-01 is shown in bold and underlined below): Assumethat exposure fire damage to manual valves and piping does not adversely impact theirability to perform their pressure boundary or safe shutdown function (heat sensitivepiping materials, including tubing with brazed or soldered joints, are not included in thisassumption). Fire damage should be evaluated with respect to the ability to manuallyopen or close the valve should this be necessary as a part of the post-fire safe shutdownscenario. For example, post-fire coefficients of friction for rising stem valves cannotbe readily determined. Handwheel sizes and rim pulls are based on well lubricatedstems. Any post-fire operation of a rising stem valve should be well austified usingan engineering evaluation.

Alignment Basis from PTN NFPA 805 LAR: It is assumed in the analysis thatmechanical components like those identified will not suffer fire damage to the extent thatthey will not be able to perform the credited safe shutdown function. The ability tomanually operate valves within the fire area (when necessary) is evaluated as part of themanual action feasibility review. Brazed components were assumed not to fail as a resultof 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-induceddamage); additional analysis to determine the effect of allowing brazed components tofail was performed. The survivability of brazed components was the only reason why


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 (seeAttachment 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 nolonger 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 slightdifferences in the guidance found in the two documents are shown in the bold andunderlined portions below).

NEI 00-01 Revision 1 Guidance: In cases where the failure (including spuriousactuations) of a single cable could impact more than one piece of safe shutdownequipment, include the cable with each piece of safe shutdown equipment.NEI 00-01 Revision 2 Guidance: In cases where the failure (including spuriousoperations) of a single cable could impact more than one piece of safe shutdownequipment, associate the cable with each piece of safe shutdown equipment.

Alignment Basis from PTN NFPA 805 LAR: Although this specific guidance fromthis section of NEI 00-01 is not repeated in the cable selection and circuit analysisinstruction, it was followed in practice. The procedure requires that ALL cables thatcould adversely affect the ability of the component to perform its safe shutdown functionbe identified. Nothing in the procedure or database prevents assigning a safe shutdowncable to more than one component. The procedure also provides guidance on whether aninterlocked or off-scheme cable be identified with the component being analyzed orassigned to its own (or another) safe shutdown component and the interrelationshipshown on the safe shutdown system logic diagrams.

Additional Details: As described in the alignment basis, there is no instance where thisguidance from NEI 00-01 was not actually followed by PTN. The reason that this sectionwas judged to only "Align with Intent" as opposed to "Align" is that the PTNmethodology does not explicitly direct analysts to consider and assign cables which canimpact multiple components to all of those components. Though not explicitly stated, theintent of this guidance is followed by applying the methodology laid out in Section 6.0 ofAttachment C of 5610-M-722A (specifically Sections 6.1.6, 6.1.8, 6.3, 6.4, 6.5, 6.7, and6.8). Stating that a single cable should be listed against all of the components which itaffects was determined to be redundant and an unnecessary amplification of the guidanceprovided in Section 3.3.1.1 of NEI 00-01 Revision 1 (Section 3.3.1.1.1 of NEI 00-01Revision 2). PTN's methodology aligns without exception with Section 3.3.1.1 guidanceand as a result the circuit analysis performed meets the intent of the guidance in Section3.3.1.2.


e) 3.3.1.7 Circuit CoordinationNEI 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 slightdifferences in the guidance found in the two documents are shown in the bold andunderlined portions below).

NEI 00-01 Revision 1 Guidance: Cabling for the electrical distribution system is aconcern for those breakers that feed associated circuits and are not fully coordinated withupstream breakers. With respect to electrical distribution cabling, two types of cableassociations exist. For safe shutdown considerations, the direct power feed to a primarysafe shutdown component is associated with the primary component. For example, thepower feed to a pump is necessary to support the pump. Similarly, the power feed fromthe load center to an MCC supports the MCC. However, for cases where sufficientbranch-circuit coordination is not provided, the same cables discussed above would alsosupport the power supply. For example, the power feed to the pump discussed abovewould support the bus from which it is fed because, for the case of a common powersource analysis, the concern is the loss of the upstream power source and not theconnected load. Similarly, the cable feeding the MCC from the load center would also benecessary to support the load center.NEI 00-01 Revision 2 Guidance: Cabling for the electrical distribution system is aconcern for those breakers that feed circuits and are not fully coordinated with upstreambreakers. With respect to electrical distribution cabling, two types of cable associationsexist. For safe shutdown considerations, the direct power feed to a primary safe shutdowncomponent is associated with the primary component and classified as a required safeshutdown cable. For example, the power feed to a pump is necessary to support thepump. 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 samecables discussed above would also support the power supply. For example, the powerfeed to the pump discussed above would support the bus from which it is fed because, forthe case of a common power source analysis, the concern is the loss of the upstreampower source and not the connected load. Similarly, the cable feeding the MCC from theload 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 theelectrical distribution system can impact safe shutdown if not properly coordinated.These cables are classified as required for hot shutdown based on the criteriacontained in Appendix H.

Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumrescoordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPLsubmittal) that because coordination of circuit protective devices was part of the originalelectrical system design, associated circuits by common power supply should not exist.However, this review was for the plant's alternate shutdown capability, and all powersupplies being credited in the re-validation may not have been evaluated.

ITEM FOR IMPLEMENTATION (see PTN NFPA 805 LAR Attachment S Table S-2Items 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 withIntent" as opposed to "Align" with the guidance in NEI 00-01 was because it had beenidentified 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 coordinationof these panels based on this item for implementation. Until these panels have theircoordination demonstrated (which had not occurred by the time of the NFPA 805 LARsubmittal), 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 forthe NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt thatthe plant does align with the intent of the guidance.

Since the submittal of the PTN NFPA 805 LAR, 4DP86 and 4DP87 have had theircoordination demonstrated by FPL calculation PTN-4FJE-12-002. The design changepackage for DP412A is currently in progress and necessary modification will beimplemented 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 section3.2, review the appropriate electrical diagrams including the following documentation toidentify the circuits (power, control, instrumentation) required for operation or whosefailure 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 circuitswhose failure may cause a coordination concern for the bus under evaluation.If power is required for the equipment, include the closest upstream power distributionsource on the safe shutdown equipment list. Through the iterative process described inFigures 3-2 and 3-3, include the additional upstream power sources up to either theoffsite or the emergency power source.

Alignment Basis from PTN NFPA 805 LAR: The analyst obtained the applicableschematic diagrams and other available design input documentation to perform anadequate 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 cableselection 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 iswritten such that, if taken literally, that single-line electrical diagrams, elementary wiringdiagrams, electrical connection diagrams, and instrument loop diagrams would bereviewed for every piece of safe shutdown equipment. This was obviously not the intentof the section as there are many pieces of safe shutdown equipment which would not


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 wiringdiagrams at PTN have block diagrams which provide all necessary cable informationsuch that reviewing electrical connection diagrams is only required when performingcircuit analysis on an instrument loop. If the guidance was meant to be written as"... review the electrical diagrams including the following documentation asappropriate ... ", then the PTN methodology would align with the guidance becausereview of all of the listed documentation would be performed only as it would beapplicable 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 notpresent in Revision 1 of NET 00-01 is shown in bold and underlined below): Giventhe criteria/assumptions defined in Section 3.3.1, identify the cables required to operateor that may result in mal-operation of each piece of safe shutdown equipment. Cablesare classified as either required for hot shutdown or important to SSD based on theclassification of the component to which they are associated and the function of thatcomponent in supporting post-fire safe shutdown in each particular fire area. Referto Appendix H for additional guidance.

Tabulate the list of cables potentially affecting each piece of equipment in a relationaldatabase including the respective drawing numbers, their revision and any interlocks thatare investigated to determine their impact on the operation of the equipment. In certaincases, the same cable may support multiple pieces of equipment. Relate the cables to eachpiece of equipment, but not necessarily to each supporting secondary component.

If adequate coordination does not exist for a particular circuit, relate the power cable tothe power source. This will ensure that the power source is identified as affectedequipment in the fire areas where the cable may be damaged. Criteria for making thedetermination as to which cables are to be classified as required for hot shutdown oras important to SSD is contained in Appendix H.

Alignment Basis from PTN NFPA 805 LAR: The required cables for each componenthave been identified and tabulated in a relational database. The circuit analysis and cableselection instruction assumes coordination exists. In the SER dated April 16, 1984, thestaff stated (based on the FPL submittal) that because coordination of circuit protectivedevices was part of the original electrical system design, associated circuits by commonpower supply should not exist. However, this review was for the plant's alternateshutdown capability, and all power supplies being credited in the re-validation may nothave been evaluated.


Perform modifications as necessary to achieve coordination on DP412A, 4DP86,and 4DP87 (only NSCA power supplies without demonstrated coordination)


Additional Details: The only reason this section was determined to only "Align withIntent" 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 coordinationof these panels based on this item for implementation. Until these panels have theircoordination demonstrated (which had not occurred by the time of the NFPA 805 LARsubmittal), 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 forthe NFPA 805 LAR (see Items 19 and 20 in Table S-2 of Attachment S), it was felt thatthe plant does align with the intent of the guidance.


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 differencein the guidance found in the two documents are shown in the bold and underlinedportions below).

NEI 00-01 Revision 1 Guidance: Assume that circuit contacts are positioned (i.e., openor closed) consistent with the normal mode/position of the safe shutdown equipment asshown on the schematic drawings. The analyst must consider the position of the safeshutdown equipment for each specific shutdown scenario when determining the impactthat fire damage to a particular circuit may have on the operation of the safe shutdownequipment.

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 hotshutdown" or "important to safe shutdown" equipment as shown on the schematicdrawings. The analyst must consider the position of the "required for hot shutdown"and "important to safe shutdown" equipment for each specific shutdown scenariowhen determining the impact that fire damage to a particular circuit may have on theoperation of the "required for hot shutdown" and "important to safe shutdownequipment".

Alignment Basis from PTN NFPA 805 LAR: The analysis assumes components are intheir normal operating position or condition, and this is understood to include contactswithin the components' electrical circuits. Specific instructions are provided concerninglocal control station isolation switches and transfer switches. Analysis also evaluatespotential for contacts to reposition during the course of a normal shutdown to CSD orother impacts from the selected safe shutdown success path.

Additional Details: PTN methodology meets all of the associated NEI guidance andeven provides direction to perform additional analysis beyond that in the NEI guidance toprovide an additional level of assurance of the capability to safely shutdown. Theadditional guidance directs analysts to consider contacts in positions other than the


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 theposition of many RCS Pressure contacts which could affect spurious operation /maloperation of components). Because these analyses considered contact positions otherthan the positions which would occur under normal operating conditions, it was felt thatthe methodology could not be said to "Align" in the strictest sense with the NEIguidance, even though all analyses (without exception) at least consider the normalposition of contacts and may consider other contact positions which could exacerbate theeffects of the fire. For alternate shutdown areas, circuit analysis was also performedwhich evaluated the effectiveness of the transfer switches (both in the normal and isolatepositions) 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 cablestesting has demonstrated that conductor-to-conductor shorting within the same cable isthe most common mode of failure. This is often referred to as "intra-cable shorting." It isreasonable to assume that given damage, more than one conductor-to-conductor shortwill 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-cableshorting." Inter-cable shorting is less likely than intra-cable shorting. Consistent with thecurrent knowledge of fire-induced cable failures, the following configurations should beconsidered:

A. For any individual multiconductor cable (thermoset or thermoplastic), any and allpotential spurious actuations that may result from intra-cable shorting, includingany possible combination of conductors within the cable, may be postulated tooccur concurrently regardless of number. However, as a practical matter, thenumber of combinations of potential hot shorts increases rapidly with the numberof conductors within a given cable. For example, a multiconductor cable withthree conductors (3C) has 3 possible combinations of two (including desiredcombinations), while a five conductor cable (5C) has 10 possible combinations oftwo (including desired combinations), and a seven conductor cable (7C) has 21possible combinations of two (including desired combinations). To facilitate aninspection that considers most of the risk presented by postulated hot shortswithin a multiconductor cable, inspectors should consider only a few (three orfour) of the most critical postulated combinations.

B. For any thermoplastic cable, any and all potential spurious actuations that mayresult 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. Thespurious actuations should be evaluated as previously described. The


consideration of more than two cables being damaged (and subsequent spuriousactuations) is deferred pending additional research.

D. For cases involving direct current (DC) circuits, the potential spurious operationdue to failures of the associated control cables (even if the spurious operationrequires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus andminus-to-minus) should be considered when the required source and targetconductors are each located within the same multiconductor cable.

E. Instrumentation Circuits. Required instrumentation circuits are beyond the scopeof this associated circuit approach and must meet the same requirements asrequired power and control circuits. There is one case where an instrument circuitcould potentially be considered an associated circuit. If fire-induced damage of aninstrument circuit could prevent operation (e.g., lockout permissive signal) orcause maloperation (e.g., unwanted start/stop/reposition signal) of systemsnecessary to achieve and maintain hot shutdown, then the instrument circuit maybe considered an associated circuit and handled accordingly.

Alignment Basis from PTN NFPA 805 LAR: Cable selection considered any and allhot shorts, regardless of whether these hot shorts were inter-cable or intra-cable. Norestriction was placed on the number of cables or hot shorts required to fail thecomponent/circuit. No credit was taken for relative risk due to conductor combinationsavailable for a fault. All cables were conservatively assumed to be Thermo-plastic.Cables were not excluded because of being instrumentation cables or because they werepart of a DC circuit requiring multiple hot shorts of proper polarity.

Additional Details: The PTN methodology was deemed to align with the intent of theguidance in NEI 00-01 Revision I rather than aligning with the explicit guidance becausethe 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 concurrentlydamaged cables which must be assumed) rather than strictly following the guidance aswritten.

For the guidance provided in B, inter-cable shorting was considered possible even if theonly cables in the fire area were thermoset cables. For the guidance provided in C, thenumber of inter-cable hot shorts which could occur in an area would not be limited. Theinclusion of these potential failure modes can only make the results at PTN moreconservative and thereby provides a greater assurance of the ability of the plant to safelyshutdown.

j) 3.5.2.4 Circuit Failures Due to Inadequate Circuit Coordination

NEI 00-01 Guidance: Note that slight differences exist between the guidance aswritten in this section for NEI 00-01 Revision 1 and NEI 00-01 Revision 2. Thedifferences in the guidance found in the two documents are shown in bold andunderlined below.

NEI 00-01 Revision 1 Guidance: The evaluation of associated circuits of a commonpower source consists of verifying proper coordination between the supply breaker/fuseand the load breakers/fuses for power sources that are required for safe shutdown. Theconcern 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 safeshutdown 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 4supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the samefire 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 shutdownpump powered from load breaker 4 of the Train A bus cannot impact the availability ofthe Train A pump, which is redundant to the Train B pump. To assure that there is noimpact to this Train A pump due to the associated circuits' common power sourcebreaker coordination issue, load breaker 4 must be fully coordinated with the feederbreaker to the Train A bus.

A coordination study should demonstrate the coordination status for each requiredcommon power source. For coordination to exist, the time-current curves for thebreakers, fuses and/or protective relaying must demonstrate that a fault on the loadcircuits is isolated before tripping the upstream breaker that supplies the bus.Furthermore, the available short circuit current on the load circuit must be considered toensure that coordination is demonstrated at the maximum fault level.

The methodology for identifying potential associated circuits of a common power sourceand evaluating circuit coordination cases of associated circuits on a single circuit faultbasis 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 andcoordination characteristics for the incoming source breaker supplying the busand the breakers/fuses feeding the loads supplied by the bus.

For each power source, demonstrate proper circuit coordination using acceptableindustry methods.

For power sources not properly coordinated, tabulate by fire area the routing ofcables whose breaker/fuse is not properly coordinated with the supplybreaker/fuse. Evaluate the potential for disabling power to the bus in each of thefire areas in which the associated circuit cables of concern are routed and thepower source is required for safe shutdown. Prepare a list of the followinginformation 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 aremitigated by appropriate methods.


Develop analyzed safe shutdown circuit dispositions for the associated circuit ofconcern 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 staffguidance, and plant licensing bases.

NEI 00-01 Revision 2 Guidance: The evaluation of circuits of a common power sourceconsists of verifying proper coordination between the supply breaker/fuse and the loadbreakers/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 supplybreaker/fuse and the load breakers/fuses can result in the loss of power to a safeshutdown 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 4supplies power to a non-safe shutdown pump. This circuit is damaged by fire in the samefire 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 shutdownpump powered from load breaker 4 of the Train A bus cannot impact the availability ofthe Train A pump, which is redundant to the Train B pump. To assure that there is noimpact to this Train A pump due to the circuits' common power source breakercoordination issue, load breaker 4 must be fully coordinated with the feeder breaker tothe Train A bus.

A coordination study should demonstrate the coordination status for each requiredcommon power source. For coordination to exist, the time-current curves for thebreakers, fuses and/or protective relaying must demonstrate that a fault on the loadcircuits is isolated before tripping the upstream breaker that supplies the bus.Furthermore, the available short circuit current on the load circuit must be considered toensure that coordination is demonstrated at the maximum fault level.

The methodology for identifying potential circuits of a common power source andevaluating 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 andcoordination characteristics for the incoming source breaker supplying the busand the breakers/fuses feeding the loads supplied by the bus.

" For each power source, demonstrate proper circuit coordination using acceptableindustry methods. For example, for breakers that have internal breakertripping devices and do not require control power to trip the breaker, assurethat the time-current characteristic curve for any affected load breaker is tothe left of the time-current characteristic curve for the bus feeder breakerand that the available short circuit current for each affected breaker is to theright of the time-current characteristic curve for the bus feeder breaker orthat. the bus feeder breaker.has a longer time delay in the breakerinstantaneous range than the load breaker. For breakers requiring controlpower for the breaker to trip, the availability of the required control powermust be demonstrated in addition to the proper alignment of the time-


current characteristic curves described above. The requirement for theavailability of control power would apply to load breakers fed from each safeshutdown bus where a fire-induced circuit failure brings into questions theavailability of coordination for a required for hot shutdown component.

For power sources not properly coordinated, tabulate by fire area the routing ofcables whose breaker/fuse is not properly coordinated with the supplybreaker/fuse. Evaluate the potential for disabling power to the bus in each of thefire areas in which the circuit of concern are routed and the power source isrequired for hot shutdown. Prepare a list of the following infornation for eachfire 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 aremitigated by appropriate methods.

" Develop analyzed safe shutdown circuit dispositions for the circuit of concerncables routed in an area of the same path as required by the power source.Evaluate adequate separation and other mitigation measures based upon thecriteria in Appendix R, NRC staff guidance, and plant licensing bases.

Alignment Basis from PTN NFPA 805 LAR: The circuit analysis procedure assumescoordination exists. In the SER dated April 16, 1984, the staff stated (based on the FPLsubmittal) that because coordination of circuit protective devices was part of the originalelectrical system design, associated circuits by common power supply should not exist.However, this review was for the plant's alternate shutdown capability, and all powersupplies being credited in the re-validation may not have been evaluated.


Perform modifications as necessary to achieve coordination on DP412A, 4DP86, and4DP87 (only NSCA power supplies without demonstrated coordination)


Additional Details: The only reason this section was determined to only "Align withIntent" as opposed to "Align" with the guidance in NEI 00-01 was because it had beenidentified 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 coordinationof these panels based on this-item for implementation. Until these panels have theircoordination demonstrated (which had not occurred by the time of the NFPA 805 LARsubmittal), 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 thatthe plant does align with the intent of the guidance.


These details are also applicable to questions g) and j).


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'sacronym for Turkey Point] fire protection and post-fire safe shutdown, PTNOperations/PRA [probabilistic risk assessment], and supporting contract staff' ashaving participated in the MSO expert panel review. Describe in more detail thecomposition of the expert panel, including qualifications, background, andexperience.

b) Describe the criteria used in the decision process for resolution(s).

c) Currently the LAR indicates that "the proposed scenarios should not havepresupposed 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 orsimultaneously), and the time between spurious actuations (as supported byengineering analysis, test results, or both).

d) Provide typical MSO justifications or rationale for MSOs being eliminated fromfurther evaluation. Include a description of the configuration control mechanisms thatensures these exclusion bases will remain valid.

RESPONSE:

a). The qualifications, background, and experience of the MSO expert panel members are judgedto be sufficient and consistent with the guidance of Frequently Asked Question 07-0038. Thereport entitled "Expert Panel for Addressing Multiple Spurious Operations" includes a listing ofpanel participants, their specific areas of expertise and experience, and resumes/experiencesummaries. As discussed in the report, the expert panel individuals included specific experiencein (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

* Fire PRA, System Engineering, NFPA 805 MSO Process


" 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 plantexperience. The panel includes individuals with degrees in Mathematics, Nuclear Engineering,Electrical Engineering, and Civil Engineering. The panel also included individuals that hadparticipated in the development of the MSO resolution process for the industry, as well asparticipants in MSO expert panels for other plants.

b) As discussed in Attachment F of the PTN LAR, consensus was achieved in the expert panelprocess by discussing individual scenarios, reaching a conclusion, and asking for any dissentingopinions. In addition, as discussed in report entitled "Expert Panel for Addressing MultipleSpurious Operations", project action items were created when the panel members were unsure orif additional research was needed.

c) The statement "the proposed scenarios should not have presupposed limits on the number offire-induced hot shorts or spurious operations." referred to in the RAI question was a discussionof the training conducted for the MSO Expert Panel. The intent of this discussion point was tonot 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 furtherrefinement, as necessary, by the nuclear safety capability assessment (NSCA) and Fire PRA. Norestrictions were placed on the MSO Expert Panel regarding the sequential or simultaneousnature of circuit failures or the time between spurious actuations.

d) Different MSO justifications and/or rationale for MSOs being eliminated from furtherevaluation were utilized. Individual scenarios from the PWROG generic list and plant specificscenarios were reviewed by the expert panel. Example dispositions include:

" Scenario was not applicable to PTN (e.g., Spurious operation of hot leg high point ventvalves, which are not installed at PTN).

" Scenario precluded by plant design/configuration:

o Pump runout scenarios where the PTN-specific pump was a positive displacementpump and not subject to runout conditions

o Normally closed manual valve downstream of valves in question, prevent flowdiversion.

o Motor operated valves at PTN were used for piggy-back operation. MOVs aremaintained closed (and breakers are de-energized and locked) for non-high lowpressure interface/high consequence components.

The post-transition change evaluation process, as described in Section 4.7.2, Compliance withConfiguration 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 toProgrammatic 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 onmeeting the nuclear safety'perforrrmance criteria, and would include the consideration of plantconfiguration or operational changes that could adversely impact the nuclear safety capabilityassessment or Fire PRA.



LAR Attachment C for each fire area identifies performance goals, method of accomplishment,and applicable variance from deterministic requirements. The decay heat performance goal isthe only goal that is identified as hot standby and cold shutdown. Provide a description of whycold shutdown is provided for this performance goal. Describe if any other performance goalsinclude cold shutdown in the performance evaluation.

RESPONSE:

In response to the "provide a description of why CSD is provided for this performancegoal" part of this RAI:

A cold shutdown (CSD) evaluation of the Decay Heat Removal Performance Goal is providedbecause there are two distinct methods analyzed by PTN to remove decay heat post-fire. One ofthese methods is most often associated with providing decay heat removal when the plant is in ahot 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 andpressure of the Residual Heat Removal (RHR) system (350'F and 450 psig; design temperatureand pressure is 400'F and 600 psig per 5610-050-DB-001). As such, the RHR system cannot beused until the plant has been cooled down and depressurized to below these limits. Thiscooldown (CD) and depressurization requires a different system which is capable of removingdecay heat generated by the reactor and sensible heat stored in the RCS until the RHR systemcan be placed on service.

The systems which may be used for CD and depressurization until plant conditions permit entryonto the RHR system are the Auxiliary Feedwater (AFW) System or the Feedwater System usingthe Standby Steam Generator Feed Pump (SSGFP). The AFW system receives its water supplyfrom the Condensate Storage Tanks (CSTs) and the SSGFP receives its water from theDemineralized Water Storage Tank (DWST). The ability to make-up to any of these tanksindefinitely from on-site or off-site sources has not been demonstrated to exist following a fire1.As such, in accordance with the definition of safe and stable provided in Section 4.2.1.2 of thePTN NFPA 805 LAR:

"The final end state for safe and stable will be determined by the extent of equipmentdamage, existing inventory in the condensate storage tank, and the ability to providemakeup 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 systemto temporarily extend AFW / SSGFP operations if required. The CSTs and DWST have adequate inventories for many hours ofdecay heat removal and CD of the reactor. Because of the effect that raw water could have on steam generator chemistry, the useof the RWTs would only be done if an unforeseen circumstance significantly delayed the ability to transfer decay heat removaloperations tothe RHRIsystem. By the'time plant conditionswould necessitate the use of the.RWTs; those same symptoms wouldhave led operators to begin cooling down the plant in preparation for going onto RHR. Thus the capability to use the RWTs isaddressed in the Decay Heat Removal (CSD) performance goal.


to place RHR system in service then the plant will have the capability to do so. As aresult, the equipment required to initiate and maintain hot shutdown cooling including theinitiation of RHR cooling remains part of the at-power analysis. Initiation of RHRcooling does not imply however, that the plant would proceed all the way to CSD. Theplant 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 supportingsystems (except for instrument air - if available - and low voltage power) that are in commonwith the RHR system. Because of this complete independence between the two approaches todecay heat removal and because both approaches may be required to satisfy the requirements forthe Decay Heat Removal Performance Goal from NFPA 805 Section 1.5.1 (c), it is appropriate toprovide separate performance goals in Attachment C of the PTN NFPA 805 LAR to address theapproach used in each plant state. Though the operators may use all of the systems mentionedabove while the plant is in a HSD state per the Technical Specifications (Tech Specs), thedistinction of the systems identified in the performance goals as HSD or CSD was done basedon:

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 theplant.

In response to the "describe if any other performance goals include CSD in theperformance evaluation" part of this RAI:

All performance goals at PTN are inherently part of both HSD and CSD operations. Even theDecay Heat Removal Performance Goals discussed above are not distinctly limited to HSD andCSD plant conditions. Tech Specs Table 1.2 indicates that the plant is in a HSD condition if Keff<0.99 and 350 0F>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 removaltransitions from one approach to another, there must be an overlap.

As illustrated in 5610-M-722A (Nuclear Safety Capability Fire Shutdown Analysis BasisDocument), Attachment A (see figure 1 below), all systems / safety functions which are requiredto be available to support HSD operations are also required to support CSD operations. Thereare three additional safety functions which were determined to be required only prior to plant CDin 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 asdiscussed above. The RCS Pressure Control Performance Goal requires the availability of thePower Operated Relief Valves (PORVs) and the Pressurizer Backup Heaters to ensure that plantpressure is acceptable for the given plant temperature and conditions. This function tends to beof greater importance during times when plant temperatures are being changed, such as whencooling down in preparation to use the RHR system. The Reactivity Control (CD/CSD) SafetyFunction'- is shown in Attachment C of the PTN NFPA 805 LAR as ipart of the Reactivity ControlPerformance Goal along with the Reactivity Control (Trip) Safety Function. The ReactivityControl (CD/CSD) Safety Function consists of the systems and components necessary to ensure


adequate RCS boration is established. This safety function is only necessary to offset positivereactivity inserted from xenon decay (which is only significant after many hours of being shutdown) or from cooling down the RCS. Though the operator may use all of the systemsmentioned above while the plant is in a HSD state per the Tech Specs, the distinction of thesystems identified in the performance goals as HSD or CSD was done based on the plant stateswhich most closely related to when the systems would be required and to readily distinguishsafety functions which would not require time critical manual actions to ensure the ability tosafely shutdown the plant.

L-2014-003. AtachmentPage 90 of 92

ILPPLNDID R.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)


Fire Modeling RAT 01.01

In a letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), the licensee respondedto Fire Modeling RAIs 01 .j and 01 .k, which make reference to "additional work." For thisreason, 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) todetermine 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 andthe corresponding heat release rate (HRR) are calculated, and explain how the firepropagation and HRR estimates affect the ZOI determination and hot gas layercalculations.

The NRC staff noted that the "additional work" will also affect the evaluation of the responses toFM RAI 0 1 .p (wall and comer effects), FM RAI 04 (application of GFMTs outside limitations ofuse), and several PRA RAIs.

Provide the results of this "additional work" to the NRC staff for review and describe anychanges to the conclusions regarding core damage frequency (CDF), delta (A) CDF, large earlyrelease 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: TransientFuel Package Ignition Source Characteristics," Rev. 0. This document provides Zone ofInfluence (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 ZOIsfor Turkey Point Nuclear Power Plant Applications," Rev. 1. This document providesZOI tables for specific ignition source - secondary combustible configurations identifiedin Report 0027-0067-002-003, Rev. 0. The heat release rates are computed usingguidance provided in NUREG/CR-6850 and NUREG/CR-7010, Volume 1. The ZOIs arecomputed using the methods described in Report 1 SPH02902.030, Rev. 0 (Generic FireModeling Treatments).

" Report 0027-0067-002-003, "Walkdowns: Secondary Combustible Configurations," Rev.0. This document provides an assessment of the secondary combustible configurations forignition sources at PTN.

" Report 0027-0067-002-004, "Evaluation of the Development and Timing of Hot GasLayer 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 inReport 1 SPH02902.030, Rev. 0 (Generic Fire Modeling Treatments) and is based on acompilation of 29,970 new CFAST simulations.

" Report 0027-0067-002-005, "Evaluation of Control Room Abandonment Times at theTurkey Point Nuclear Power Plant," Rev. 0. This document is the updated control roomabandonment report.

These reports have been placed on the portal and are available for review. The fire PRA hasincorporated the new information from these reports and will provide the final core damage


frequency (CDF), ACDF, large early release frequency (LERF), and ALERF with the response toPRA-RAI-29.

Fire Modeling RAI 02.01

In letter dated May 15, 2013 (ADAMS Accession No. ML13157A011), in response toFM RAI 02.e, the licensee referred to Fire PRA Frequently Asked Question (FAQ) 13-0004 tojustify the use of cable damage thresholds as the criteria for sensitive electronics inside anenclosure. Fire PRA FAQ 13-0004 was still under development at the time the response wassubmitted, and the licensee therefore stated, "Resolution of this issue will be re-assessed once theFAQ is finalized."

Provide the results of the re-assessment. Quantify the impact of any changes to the guidelines inthe final version of Fire PRA FAQ 13-0004 on CDF, LERF, ACDF, and ALERF; or justify whythese changes need not be considered.

RESPONSE:

In accordance with the guidance provided in Fire PRA FAQ 13-0004, sensitive electronicswithin a panel enclosure are expected to survive an external fire based on the use of thermosetcable damage criteria as a basis for panel and internal component damage. The use ofthermoplastic cable damage criteria for the Turkey Point Fire PRA provides additional marginwith respect to that defined in the FAQ. A walkdown was performed to identify exposedsensitive electronics susceptible to fire damage. This walkdown was performed using the criteriain the final version of Fire PRA FAQ 13-0004. The walkdown produced no instances of exposedsensitive electronics. Based on the use of thermoplastic damage criteria for panels and internalcomponents and the lack of exposed sensitive electronics, the application of the FAQ 13-0004methodology does not result in an increase in CDF, LERF, ACDF, and ALERF.

turkey point, units 3 and 4, response to request for ...3.3.1.2 control of combustible 3.3.1.2 (5) *...

Documents