AEP-NRC-2018-17, Fire Protection Program Change Summary
| ML18270A247 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/25/2018 |
| From: | Indiana Michigan Power Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18270A194 | List: |
| References | |
| AEP-NRC-2018-17 | |
| Download: ML18270A247 (5) | |
Text
Donald C. Cook Nuclear Plant Fire Protection Program Change Summary
- 1) Summary of Changes of the NFPA (National Fire Protection Association) 805 Fire Protection Program Manual (NFPPM)
Change Evaluation Effective Description of Change Tracking Number Date FPPR-2016-0010 6/20/2016 This change updates the NFPPM to reflect the creation of new procedure 12-EHP-2270-FPCE-001, Fire Protection Program Change Evaluation (FPCE) to separate the change evaluation process from the impact review of engineering modifications that is contained in new 12-EHP-2270-FPIR-001, Fire Protection Impact Review.
FPCE-2016-0011 7/8/2016 NFPPM Revision 2 update for minor corrections and changes from the last submittal of the Updated Final Safety Analysis Report (UFSAR) to support the new UFSAR submittal in accordance with 10 CFR 50.71(e),
UFSAR Update and PMP-2350-COM-001, Communications with the Nuclear Regulatory Commission and Other Regulatory Agencies.
FPCE-2016-0013 9/7/2016 Changed the NFPPM Attachment 1 Section 3.3.5.1 to add reference to EC 54824 and clarify that the fluorescent lighting and egg crate diffusers have been replaced and the configuration is changed. Unit 2 Control Room 4 foot fluorescent tubes will be replaced with light-emitting diode (LED) tubes and the current "egg crate" diffusers will be replaced with polycarbonate "prismatic" diffusers.
FPCE-2016-0014 9/15/2016 Encapsulating conduits/cables (1-80009PR-l and I-80046PR-1) with a fire protective barrier Darmatt will allow them to be removed from the fire scenarios in the Systems Assurance & Fire Protection Engineering (SAFE) analysis that impact these cables. Fire Modeling and Fire PRA documents are being revised to incorporate the results of wrapping these cables.
FPCE-2016-0017A 12/5/2016 NFPPM - NFPA 805 Attachment 1, Element 3.3.5. 1, Electrical Wiring Above Suspended Ceiling Limitations requires a change to the Compliance Basis to clarify that the fluorescent lighting and egg crate diffusers have been replaced and the configuration is changed. This change is acceptable because the Makrolon diffusers meet NFPA 286 for Class A material and the Flame Spread and Smoke Generation for ceiling applications as described in NFPPM Attachment 1, Element 3.3.3, Interior Finishes.
FPCE-2017-0001 1/5/2017 This change consists of moving the Donald C. Cook Nuclear Plant (CNP)-FPP from DEM-FP to Operation-Fire Protection Engineering (OP-FPE). The Fire Protection System Manager is also being moved to the OP-FPE group. This changes the physical location of the Fire Page 1 of 5
Protection Engineers to a single location and places an Operations Fire Protection Manager in place to align the Fire Protection System Manager, Fire Protection Program Manager and Fire Marshal. This change also changes the Fire Protection Engineering procedure designation from "EHP-2270" series to the "FPE-2270" series.
FPCE-2017-0004 3/14/2017 This change represents a change to clarify CNP's compliance with the NFPA 805 Element 5.3.15 only. Fire hose cabinets are provided at intervals of not more than 1000 feet (305 meters) along the yard main system and therefore, CNP complies with the NFPA 805 requirements and the use of the plant fire truck is not necessary. The physical location of the plant fire truck has changed and does not allow it to be readily accessible by the fire brigade during a plant design basis fire.
FPCE-2017-0008 4/26/2017 The NFPPM is being revised to reference Engineering Equivalency Evaluation (EEE)-11-72, "Fire Door Automatic Release Device Evaluation (12-DR-TUR224, 12-DR-TUR242, 1-DR-AUX313, and 2-DR-AUX314)" that documents the acceptability of Release Devices that deviate from the requirements of NFPA-80 1970.
FPCE-2017-0011 5/3/2017 The NFPPM is being updated to reflect EEE-1 1-71 in Attachment 1 Section 3.11.3(1), Attachment 2, Section NFPA 80, and Attachment 4. This update is editorial as EEE- 11-71 was previously referenced in the NPPPM, but was inadvertently voided.
FPCE-2017-0018 6/12/2017 The NFPPM is being updated to reflect the transition of Technical Evaluation 11.69 to EEE-11-69 in Attachment 2, Section NFPA 80, and Attachment 4. This update is editorial as the purpose and conclusion of the evaluation was not changed, only the format and number.
FPCE-2017-0019 7/10/2017 The NFPPM is being updated to reflect the transition of Technical Evaluations to Engineering Equivalency Evaluations as listed below:
Technical Evaluation 11.1 transitioned to EEE-11-1 Technical Evaluation 11. 3 transitioned to EEE-11-3 Technical Evaluation 11.18 transitioned to EEE-11-18 Technical Evaluation 11.26 transitioned to EEE-11-26 Technical Evaluation 11.27 transitioned to EEE-11-27 Technical Evaluation 11.33 transitioned to EEE-11-33 Technical Evaluation 11. 34 transitioned to EEE-11-34 Technical Evaluation 11.35 transitioned to EEE-11-35 Technical Evaluation 11.36 transitioned to EEE-11-36 Technical Evaluation 11.37 transitioned to EEE-11-37 Technical Evaluation 11.48 transitioned to EEE-11-48 Technical Evaluation 11.49 transitioned to EEE-11-49 Technical Evaluation 11.51 transitioned to EEE-11-51 Technical Evaluation 11. 55 transitioned to EEE-11-55 Technical Evaluation 11.58 transitioned to EEE-11-58 Technical Evaluation 11.59 transitioned to EEE-11-59 Page 2 of 5
Technical Evaluation 11.60 transitioned to EEE-11-60 Technical Evaluation 12.13 transitioned to EEE-12-13 Technical Evaluation 12.16 transitioned to EEE-12-16-1 Technical Evaluation 12.22 transitioned to EEE-12-22 Technical Evaluation 12.23 transitioned to EEE-12-23 Technical Evaluation 12.24 transitioned to EEE-12-24 Technical Evaluation 12.26 transitioned to EEE-12-26 There are no technical changes associated with these transitions. This is an editorial update to the NFPPM only.
No other documents are impacted by this update.
FPCE-2017-0021 8/11/2017 The CNP compliance basis for NFPA 805 Section 3.3.1.1(2) contained in the NFPPM - Revision 2 is being changed to reflect the overall compliance strategy: CNP procedures establish requirements for spot plant inspections to ensure that combustibles are properly controlled and are not allowed to accumulate* in amounts that are in excess of that analyzed in the Fire Safety Analysis (FSA). Periodic tours by the fire brigade are established by station procedures (FPCE-2017-0021). If problems with conditions or combustible loading are identified, corrective actions are required to be taken.
FPCE-2014-0024 9/27/2017 The FSA and the NFPPM are being updated to reflect EEE-11-69. The purpose of this EEE is to document acceptability of non-Underwriters Laboratory/Factory Mutual (UL/FM) approved Dynalock Model 2280 electromagnetic door locks that were installed under EC-0000050114. NFPA 80 1970 Ed. Section 516 Builders Hardware, Sub-Section b. Locks and Latches states, in part, "Only labeled fire exit hardware shall be used." The Dynalock Model 2280 magnetic door locks are installed primarily for Security purposes and are not UL/FM approved devices as required by code. NFPA 805 Section 3 .11.3 (1) requires compliance with NFPA 80.
The impacted doors of concern are 1-DR-SCN216, 1-DR-TUR200, 2-DR-TUR221, 2-DR-TUR259, 1-DR-AUX412B, and 2-DR-AUX411B. The Fire Compartment Analysis Areas Affected are AA2, AA46, AA47, and AAYD.
FPCE-2017-0025 10/04/2017 Update the NFPPM Section 3.7 and Appendix 1 (Attachment 1) Elements 3.2.3(4) and 3.3.1.1(3) to replace 12-EHP-5040-MOD-009 with IP-ENG-001, Standard Design Process.
FPCE-2017-0031 11/30/17 Evaluated reference to superseded Fire Hazard Analysis (FHA) in six locations within the NFPPM design elements (3.3.7, 3.3.7.1, 3.3.8, 3.10.3, 3.11.1 and 3.11.2).
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- 2) Summary of Changes of the NFPA 805 Fire Safety Analysis Change Evaluation Effective Description of Change Tracking Number Date FPCE-2016-0012 7/7/2016 This change to the Fire Safety Analysis, Revision 1 is being made to incorporate changes to the Fire Protection Program since the last submittal of the UFSAR to support the new UFSAR submittal in accordance with 10 CFR 50.71(e), UFSAR Update and PMP-2350-COM-001, Communications with the Nuclear Regulatory Commission and Other Regulatory Agencies. This change has considered previously completed and approved Fire Protection Change Evaluations (FPCEs),
Fire Protection Program Reviews (FPPRs), Configuration Design Impact (CDI) Action Items, Open Item Constraints (OICs) that are open, and ActionWay assignments (Corrective Actions or General Tracking).
FPCE-2017-0009 8/28/2017 The FSA was updated with additional Variances From Deterministic Requirements (VFDRs), identified during resolution of Action Request 2016-9854, to address U. S.
Nuclear Regulatory Commission (NRC) concerns for fire areas transitioned deterministically with credit being taken for Main Control Room Actions with no Variances from Deterministic Requirements requiring resolution.
Additionally, this FPCE evaluated other minor changes to update Fire Risk Evaluation Calculation changes; correct floor drain locations; and other minor corrections to Fire Analysis Area AA2.
FPCE-2017-0010 5/1/2017 The FSA is being revised to update Analysis Area 40 Section 3.9, "Monitoring Program Input". Specifically, the bullet reading "Manual Fire Suppression System (CO2)"
will be changed to read "Automatic Fire Suppression System (CO2)." This system was converted to automatic by Engineering Change (EC)-53523 as part of the transition to NFPA 805. Table 3-2 in Section 3.1.5 was correctly updated to show this system was converted to Automatic. The change to Section 3. 9 is editorial only.
FPCE-2017-012 5/24/2017 Incorporates changes due to load changes to buses 1C, 2C, 11B, and 2B (breakers 1C3, 1B34, 2C3, 2134) as documented in Action Request (AR) 2017-1339. Added 69kV system components in response to failure of 11C3 in an AA2 fire. This change is administrative in nature and changes the Nuclear Safety Capabilities Assessment (NSCA) and Non Power Operations (NPO) technical evaluations to credit equipment and components for offsite power. There are no physical changes to the plant, this is a change which credits existing plant equipment.
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FPCE-2014-0024 9/27/2017 The FSA and the NFPPM are being updated to reflect EEE-11-69. The purpose of this EEE is to document acceptability of non-UL/FM approved Dynalock Model 2280 electromagnetic door locks that were installed under EC-0000050114. NFPA 80 1970 Ed. Section 516 Builders Hardware, Sub-Section b. Locks and Latches states, in part, "Only labeled fire exit hardware shall be used." The Dynalock Model 2280 magnetic door locks are installed primarily for Security purposes and are not UL/FM approved devices as required by code. NFPA 805 Section 3.11.3 (1) requires compliance with NFPA 80.
The impacted doors of concern are 1-DR-SCN216, 1-DR-TUR200, 2-DR-TUR221, 2-DR-TUR259, 1-DR-AUX412B, and 2-DR-AUX411B. The Fire Compartment Analysis Areas Affected are AA2, AA46, AA47, and AAYD.
FPCE-2017-0030 11/30/2017 FSA for Fire Area 3 to update Section 3.1.5, Fixed Suppression to show acceptance of the use of 286F sprinkler heads in Fire Zone 32.
- 3) Summary of Changes of the NFPA 805 Nuclear Safety Capabilities Analysis Change Evaluation Effective Description of Change Tracking Number Date FPCE-2017-0006 Update the NSCA to include editorial corrections due to GT 2016-3042 Fire Protection Change Management Plan to change procedure "12-EHP-2270-SSA-004" to 12-FPE-2270- SSA-004". Additionally, this revision includes the addition of Step 7.3.4.6.6 to document the conclusions from R2684-1072-001, Review of CNP 250V DC System NFPA 805 Modeling in Response to AR 2016-0300 and 2016-0301.
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