ML113130259

Questions and Issues to Be Addressed During the Audit

ML113130259
Person / Time
Site:	Cook
Issue date:	11/08/2011
From:	Leslie Fields, Lain P NRC/NRR/DRA/AFPB, NRC/NRR/DRA/APLA
To:
Tam P
References
TAC ME6629, TAC ME6630
Download: ML113130259 (13)

Text

DC Cook Site Audit (FPE/SSD)

Fundamental Fire Protection

1. Table B-1 Fire Damper Fire Protection Features LAR Table B-1 Section 3.11.3 NFPA 90A Fire Damper Requirements identify Numerous EEEEs (e.g.; Engineering Equivalency Evaluation 9.1, 9.2, 9.3, 9.4, 9.7, etc.) in the compliance strategy to meet the requirements of NFPA 805 regarding fire barrier boundary integrity. Fire protection features such as fire detection, suppression, low combustible loading, and safe shutdown equipment proximity to the damper appear to be used to justify the adequacy of fire dampers for both EEEEs and Previous NRC approval compliance strategies. However, the fire protection features relied upon for the sufficiency of boundary integrity appear not to be identified as fire protection features necessary for compliance in Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features. Please identify the areas where these features are relied upon for both EEEEs and previous NRC approved compliances, and clarify how they are addressed in Table 4-3, or justify why these features are not addressed as necessary for NFPA 805 boundary compliance.

2. Table B-1 Carbon Dioxide System Modifications LAR Attachment S item S-2.2 is a committed modification for the CO2 system. The stated purpose of this modification is to convert the manually actuated systems to be automatically actuated using the detection system. Describe the details and extent of the modification. Is there suitably approved/listed detection actuation and alarm equipment currently in place to initiate the suppression agent? Currently Table B-1 Section 3.10.1 (1) states system compliance with NFPA 12-1968, as evaluated in CNP NFPA Code Compliance Evaluations, and Engineering Equivalency Evaluations. As this appears to be a major change in the system, what version of the NFPA code will be used to modify the system(s)? Because these fire areas (AA40 and AA43) will be readily occupied, will there be any additional requirements associated with the Life Safety Code NFPA 101 regarding the automatic discharge of CO2?

The retroactive clauses identified in NFPA 12 Section 1.3.4 (2011) should be included in the code compliance statements of the LAR Section 3.10.1 regarding the CO2 system. Were these identified and included?

LAR Table B-1 Section 3.10.3 Gaseous System Ventilation system design states that per Section 9.8.1 of the UFSAR, "Many of the plant ventilating fans are arranged so that they may be shutdown on actuation of an automatic fire system to prevent spread of fire or smoke or, in the case of CO2 or Halon protected areas, to retain an extinguishing concentration of the firefighting agent." Will the modifications for Fire Areas AA40 and AA43 include automatic fan shutdown for these areas?

3. Table B-1 Hose Nozzle Clarification LAR Table B-1 Section 3.6.3 Hose station nozzle restrictions as listed in NFPA 805 Section 3.6.3 identifies complies with clarification, but it is unclear what is being clarified. Describe the clarification.

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DC Cook Site Audit (FPE/SSD)

4. NFPA Code Compliance Reviewed NFPA 22 Tanks code compliance is not addressed except to say that it is limited to underground piping between the tanks and pumps (FPPM). Table B-1 Section 3.5.2 states COMPLIES but there appears to be no evidence to demonstrate compliance. Clarify.

5. NFPA 20 (1990) Fire Pumps The following is identified non-code compliances but there appears to be no evaluation regarding the suitability of the compliance statement COMPLIES:

• Diesel engines tested monthly not weekly and no weekly timer circuit as required by the code

• Flow tests are required to be conducted annually for fire pumps, but CNP performs them every 18 months

• Diesel maintenance 18 months not 12 months.

• Diesel fuel used does not comply with code (not manufacturer recommended)

• Pump pressure sensing line is downstream of discharge check valve, not upstream as required by the code.

• Voltage surge arrestor not installed in accordance with the code

• Pump cabinet enclosure not grounded as required by the code.

• Electric pump breaker not rated to continue to operate at locked rotor current as required by code.

• Pump power supply has intermediate breakers isolations not as required by the code.

• Manual transfer switch used for power selection contrary to code requirement.

• Pump pressure recorder not installed as required by the code There does not appear to be evaluations or justifications for these code deviations. Provide appropriate documentation to show code compliance.

6. Table B-1 Section 3.2.3(1) Inspection Testing, and Maintenance Where practical, performance-based surveillance frequencies may be established as described in Electric Power Research Institute (EPRI) Technical Report (TR) 1006756, Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features.

There does not appear to be an implementation item for incorporation of this into the program.

Although the procedures may be in place, the incorporation of the EPRI methods has not yet been done. Clarify.

7. LAR Table B-1 Section 3.6.4 Hose Stations and Standpipe, This section identifies the first part of the NFPA 805 Section 3.6.4 Provisions shall be made to supply water at least to standpipes and hose stations for manual fire suppression in all areas containing systems and components needed to perform the nuclear safety functions in the event of a safe shutdown earthquake (SSE).

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DC Cook Site Audit (FPE/SSD)

But the second part of the requirement is not endorsed by 10CFR50.48:

Exception: For existing plants that are not capable of meeting this requirement, provisions to restore a water supply and distribution system for manual fire-fighting purposes shall be made.

This provisional manual fire-fighting standpipe/hose station system shall be capable of providing manual fire-fighting protection to the various plant locations important to supporting and maintaining the nuclear safety function. The provisions for establishing this provisional system shall be preplanned and be capable of being implemented in a timely manner following an SSE.

The compliance by previous NRC approval does not address seismic functionality which is the NFPA 805 Requirement. Please clarify.

8. Table B-1 Section 3.3.1.2 (5) Flammable and Combustible Liquids Code Plant procedures are in place to control the use and storage of flammable and combustible liquids. These controls use NFPA 30 as a developmental reference. Define what a developmental reference means. This request should be applied to any other codes which are treated as a developmental reference; such as NFPA 50A Hydrogen Gas.

9. Table B-1 Section 3.3.1.3.1 [Control of Ignition Sources Code Requirements]

Complies with clarification: A hot work safety procedure and a fire watch procedure have been developed, implemented, and are periodically updated as necessary. Fire watch personnel may have multiple duties. Describe what duties, who controls this decision, where is this provided in procedures, what time lime limits are imposed, and what training is given to the individual regarding priority if a choice of duties is required.

10. Table B-1 Complies with clarification Statements Relative to the Complies with clarification compliance basis descriptions for the following:

• Section 3.3.1.2 (1), b. For short durations, covering the material with a fire retardant cloth, which is not allowed by NFPA 805 Section 3.3.1.2 (1).

• Section 3.3.1.2 (3), and stored in proper containers. NFPA 805 Section 3.3.1.2 (3) does not allow for in-situ storage of waste, debris, scrap, packing materials, or other combustibles.

• Section 3.4.1, The composition of the fire brigade may be less than the minimum requirements for a period of time not to exceed 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />, which is not allowed by NFPA 805 Section 3.4.1.

Provide further justification for these allowances, such as describing where the controls are established, time limits, notification requirements, training requirements (if any), location restrictions, and any fire protection features required

11. Table B-1 Hose Station Seismic Functionality 3

DC Cook Site Audit (FPE/SSD)

The compliance basis for this element does not address the earthquake provision. Provide a revised LAR Table B-1 Section 3.6.4 that describes how the CNP complies with the earthquake provisions of NFPA 805 Section 3.6.4.

12. Table B-1 Fire Damper Closure with air flow The EEEE described in R1900-001-003 Engineering Equivalency Evaluation Review identifies that some fire damper closures were predicated on operator manual fan shutdown in order to ensure barrier integrity. Provide a list of the fire dampers that require manual shutdown of fans so that fire barriers can be credited. Describe where the control station is for manually shutting down these fans. Are these controls remote from the control room, and if so, how is feasibility determined?

13. Table B-1 Section 3.3.5.3 Electrical Cable Construction There is a commitment that any new cable installed at CNP will be constructed similar or superior to the original cable and meeting the requirements of IEEE-383. However there is no implementation item in Attachment S that reflects this outstanding work activity. Has this requirement already been incorporated in the appropriate documentation or procedures?

14. Table B-1 Section 3.3.7 Bulk Flammable Gas Storage Bulk compressed or cryogenic flammable gas storage shall not be permitted inside structures housing systems, equipment, or components important to nuclear safety. The statement of compliance is Complies with Clarification, however it is not apparent as to what is the clarification being made? There is an EEEE 11.11 listed as a reference, but there is no statement regarding compliance with the use of EEEEs. Please clarify.

15. Table B-1 Section 3.3.7.1 Bulk Flammable Gas Location Requirements states Complies with clarification: Bulk compressed flammable gas cylinder storage is located in the Gas Bottle Storage Facility. The 3-hour rated concrete wall that separates the full bottle storage area of the Gas Cylinder Storage Building is an MFL type firewall. The combination of the firewall and spatial separation from the south wall of Fire Zones 97 and 98 provides assurance that a gas cylinder fire would not adversely impact systems, equipment, or components important to nuclear safety. Please clarify what is the clarification.

16. Table B-1 Section 3.5.15 Water Supply Hydrant Code Requirements:

The compliance strategy states Complies with Clarifications but identifies numerous non-compliances such as hydrant spacing and mobile apparatus carry requirements. The references listed do not indicate a code compliance document regarding these requirements.

Provide more detail regarding the justification of not meeting these requirements. The compliance basis in one case states two hose houses carry inventory and in another refers to three hose houses.

17. Table B-1 Section 3.5.15 Fire Hydrant Configuration 4

DC Cook Site Audit (FPE/SSD)

NFPA 805 Section 3.5.15 indicates that hydrants shall be installed approximately every 250 ft (76 m) apart on the yard main system. NFPA 24 indicates that a hose house equipped with hose, combination nozzle, and other auxiliary equipment shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system. There is an exception where mobile means of providing hose and associated equipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses.

The LAR Attachment A Table B-1 Section 3.5.15 states that fire hydrants have been provided at the recommended 250-foot approximate spacing connected to the yard loop header with two exceptions. Hydrants 1 and 14 are located 350' apart in straight line distance and 422' apart in actual travel distance. Hydrants 4 and 7 are located 320' apart in straight line distance and 406' apart in actual travel distance. The applicant stated that this configuration is considered adequate given the strength of the water supply and the availability of sufficient hose from the hose houses in the yard. In addition, the LAR states that the hose houses between hydrants 2 and 7 are located more than 1000 ft apart along the yard main system. The applicant also stated that fire truck containing equipment equivalent to at least two hose houses is provided for the fire brigade's use. The applicant stated that procedure 2270-066-003 specifies the hose house inventory and confirms that all items required by NFPA 24-1984 are contained within.

The applicant also stated that procedure 12-FPP-2270-066-005 specifies that the fire truck contains the equipment equivalent to three hose houses.

It is unclear from the information provided how the hydrant configuration is adequate. Provide justification for the conclusion that the hydrant configuration (for Hydrants 1 and 14 as well as 4 and 7) is adequate, including how the strength of water supply and availability of sufficient hose length is sufficient. In addition, it is unclear why procedure 12-FPP-2270-066-005 specifies that the fire truck contains the equipment equivalent to three hose houses, while the LAR states that the fire truck contains equipment equivalent to at least two hose houses. Clarify the actual equipment equivalency for the fire truck and the reason for the discrepancy between the procedure and the LAR.

18. Table B-1 Section 3.5.16 Water Supply Dedicated Limits NFPA 805 Section 3.5.16 states that fire protection water supply system shall be dedicated for fire protection use only. NFPA 805 indicates that there are two exceptions including 1) fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided that the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis and 2) fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration.

The applicant indicated that per OP-12-5152 series flow diagrams and Section 4.1.2 of the FPPM, the fire protection water supply system is normally dedicated for fire protection use only.

The LAR states that periodically, the fire water supply system is used for nonfire protection 5

DC Cook Site Audit (FPE/SSD) related purposes, and in these cases, the fire protection water supply system is designed and maintained to deliver the combined fire and non-fire flow demands. The applicant stated that justification is documented in Engineering Equivalency Evaluation 11.61, and in accordance with 10CFR50.48(c)(2)(vii) is provided in Attachment L, Approval Request 1, of the Transition Report.

It is unclear to the staff what the extent of the fire water supply use is from the nonfire protection related purposes. Describe how fire water is used for nonfire protection purposes and provide what maximum duration (identified in the FPPM Technical Evaluation 11.61 as short term use) specified by this performance based analysis, during which fire protection water supply systems shall be permitted to be used for non-fire related purposes.

Approval Request 1 cites controls in place to cease the non-fire protection use should a fire condition occur as an element of the basis for the suitability of the request. Provide more detail regarding these controls including work control packages / procedure(s) issued, notifications made, procedural limitations or control on the users such as impairments, continuous communications, and alarm responses required when non-firewater use is underway. Describe in more detail the capacity, flow rates, and bounding values for the uses of non-firewater fire protection system. Clarify if this process constitutes temporary hose connections only or if there are permanently installed valves and piping connected to non-fire systems and, if so, describe these permanent installations.

In addition, excess capacity to supply the combined demands is identified in Approval Request 1 as the means to satisfy both safety margins and defense-in-depth (DID). The elements of DID considered, as identified in paragraph (C) of the Conclusion section, are fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown. Identify and describe the fire protection features, including procedures and work practices, if applicable, being credited for meeting these DID criteria.

Fire Area Analysis

19. [security-related information deleted]

20. EEEEs LAR Section 4.2.2 describes the process and criteria used to evaluate Existing Engineering Equivalency Evaluations (EEEEs) to determine that a fire protection system or feature is adequate for the hazard. None of the summaries of the EEEEs cited in LAR Table B-1 or described in LAR Table B-3 state that the basis of acceptability of remains valid. Provide an explicit statement that the credited EEEEs were determined to meet the NEI 04-02 criteria and 6

DC Cook Site Audit (FPE/SSD) that the basis of acceptability of previous EEEEs remains valid. Provide further justification for crediting EEEEs where the criteria are not met.

Radioactive Release

21. Contaminated Equipment Storage Building:

The Contaminated Equipment Storage Building identified in Table 3-2 of the Plant Boundary Partitioning and Definition report (R1900-0041-0001, Rev. 0) does not appear to be included in the radioactive release transition review (LAR Attachment E). It is unclear how the radioactive release performance criteria in NFPA 805 Section 1.5.2 can be shown to be met with the exclusion of this facility from the review. Clarify if this facility provides for storage of contaminated equipment and/or is radiologically contaminated and, if so, provide justification for not including it in the radioactive release transition review. Clarify whether there are any other contaminated or potentially contaminated facilities/areas that have not been excluded from the radioactive release performance review and, if so, provide justification for not including these facilities/areas in the radioactive release transition review.

Fire Safe Shutdown / Circuit Analysis

22. Fire Suppression Effects In LAR Table B-3 fire suppression effects are described in numerous fire areas indicating that In the event of discharge, any damage caused by the wet pipe sprinkler system to other equipment operating within the fire area which is not immediately involved in the originating fire is bounded by the analysis approach of postulating whole room damage. Clarify what this means. Are targets selected based on this assumption? What analysis is done to accomplish this effort?

23. Instrument Sensing Line Evaluation (TE 12.27)

Relative to Technical Evaluation 12-27, address the following:

• Analysis Areas identifies fire damage to instrument tubing / indicators. The failures are evaluated and resolved in this Technical Evaluation. However are they considered VFDRs? If so, where are they identified in the individual fire areas of LAR Table B-3? If they are not considered VFDRs (including risk), please justify why not.

• Instrument tubing sensing lines susceptible to fire damage are identified with a dummy variable -SL marking where included. [What is considered susceptible?]

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DC Cook Site Audit (FPE/SSD)

• [Security-related information deleted]

• [Security-related information deleted]

• [Security-related information deleted]

• [Security-related information deleted]

• The Conclusions of this evaluation state the credited indicator has sense lines in the fire, though indication is not considered to be affected by the heat up (i.e.; flow indication). Provide a more detailed explanation of this behavior.

• [Security-related information deleted]

24. UFSAR Section 7.0 Instrumentation and Control Describe the differences in instrumentation and control of Remote Shutdown Instrumentation

[GDC 19] and Appendix R Remote Shutdown Instrumentation? How has this list changed for NFPA 805? How will section 7.0 of the UFSAR be changed for NFPA 805 transition?

Describe the isolation technique (double fusing) for separation of Appendix R Remote Shutdown LSIs and the CR in the event of a CR fire or a fire in the LSI HSP room(s).

25. Table B-3 Fire Area AA36/42 For this fire area there are 2 independent sets of scenarios (AA36 and AA42) to satisfy the nuclear safety performance criteria and an independent set of VFDRs for each scenario. In addition there are 2 safe-shutdown strategies for Scenario AA42: Units 1 and 2 CCW provided from Unit 1 CCW and Units 1 and 2 CCW provided from Unit 1 CCW. Clarify the basis for the safe shutdown logic for this fire area. In addition, EEEE 9-4, 9-31, and 9-32 do not seem to address either scenario. Please clarify.

26. Secondary Fires Evaluations (TE 12.5.1 Rev 0) 8

DC Cook Site Audit (FPE/SSD)

The only location of concern becomes the 4kV Switchgear Rooms. A fire in that switchgear room causes loss of 125 VDC control power and, subsequently, the capability to trip the power load breaker when it is faulted in the same fire. The secondary fire could occur along the upstream incoming power line from the startup transformer or DG to the switchgear room. This secondary fire will jeopardize safe shutdown. How is this issue resolved in Table B-3?

27. NSCA Calculation R1900-0024-001 Rev 0 (7/11/2011)

This analysis assumed Instrument air failed. How was this incorporated into the initial position of components for circuit analysis? Also, how was instrument air failure considered in the non-power operations analysis?

28. Review Non-Power Operations (TE R1900-005-001 Rev 0 5/26/11)

Relative to this technical evaluation, provide the following:

• Describe what outage management procedures, or risk management tools (e.g.,

PMP-4100-SDR-001 Plant Shutdown and Risk Management) have been affected by the incorporation of Key Safety Functions identified in the NFPA 805 transition, including administrative procedures such as Control of Combustibles. Describe the changes/markups to the procedures that are being performed.

• Containment and spent fuel pool cooling were evaluated and excluded from further review under this NPO review. Cooling water, electric power source, and electric power distribution have been modeled at the equipment logic level and not as specific key safety functions. Please explain.

• Page 11. Red striped tags identified are considered available based on quick restoration. Please explain what that program is, and what criteria are used to determine quick restoration.

• Page 13. NPO considers that the plant is already on RHR. The equipment necessary to transition from hot standby to RHR is covered by the NSCA. However, LAR page 20 states that For CNP to be in a safe and stable condition, it will not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R. Therefore, the unit will remain at or below the temperature defined by a hot standby plant operating state for the event. There appears to be a discontinuity.

• Fire Area 36/42 is defined as one FA, but analyzed as two fire areas with pinch points and recovery actions. Please explain why the analysis is built this way for AA36/42.

• How are recovery actions evaluated for feasibility in NPO?

29. Current Transformer Open Circuit Concern (TE 12.6 Rev 0) 9

DC Cook Site Audit (FPE/SSD)

The technical evaluation states that the issue of secondary ignition of CTs caused by open circuiting of the secondary side was sufficiently addressed for Appendix R in FPPM Section 12.6 but that a review was performed again in support of NFPA 805 transition. This evaluation also states that the CTs reviewed were located on both trains in both Unit 1 and Unit 2 480V, 600V, 4kV non-safety and safety buses, and main generator related circuits. However, the evaluation is described as unfinished because necessary manufacturer data was not available at the time the evaluation was performed. Three different possible actions are identified for resolving this incompleteness, including plant modifications and further circuit analysis. Attachment S identifies this as an implementation item. Describe the action chosen, the status of implementation, and how the resolution will affect the analysis, including delta CDF/LERF, as presented in the LAR.

30. Recovery Actions: Confirmatory Walkdowns of Recovery Action Feasibility LAR Attachment G states that a confirmatory demonstration (field verification walk-through) of the feasibility for the credited NFPA 805 recovery actions will be performed and documented as part of the LAR implementation. LAR Attachment S Item S-3.8 includes a commitment to complete a confirmatory demonstration of RAs as part of NFPA 805. Completion of the RA commitments in LAR Attachment S as part of implementation following issuance of the safety evaluation (SE) report could impact SE conclusions if the walkdowns do not support the feasibility conclusions in the LAR. Describe the scope of the two confirmatory items, S-3.8 and S-3.9 and provide justification for the conclusion that completion of these items is not likely to impact the NFPA 805 fire protection program described in the LAR.

31. NSCA - Rising Stem Valves Table B-2 of the LAR evaluates the alignment of DC Cook with NEI 00-01 Revision 1. The DC Cook Nuclear Safety Capability Assessment (NSCA) Report, Technical Evaluation R1900-0024-001, Revision 0, references NEI 00-01 Revision 2, which is the revision currently endorsed in RG 1.205, Revision 1.

Technical Evaluation 12.29, DC Cook Nuclear Safety Capability Analysis Methodology Review, Section 1.0, states the changes between Revision 1 and 2 of NEI 00-01 were general clarifications and did not change intent, criteria, or assumptions in the NEI document.

A clarification may provide perspective or focus on an issue that wasnt previously considered in the light of the clarified information. For example, in Section 3.2.1.2 of NEI 00-01 Revision2, clarification was added regarding fire damage to rising stem valves and the expected justification necessary for post-fire operation of these types of valves. Technical Report R1900-0026-001, Recovery Action Transition Report in Support of NFPA 805, Section 3 provides criteria and assumptions for recovery actions and states, Valve handwheels are available for the manual operation of the valve after exposure to a fire. While this assumption is directed at handwheels damage, similar assumptions or discussion related to operation of rising stem valves was not identified.

Did DC Cook credit manual operation of rising stem valves that were exposed to the fire?

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DC Cook Site Audit (FPE/SSD)

32. Safe and Stable - Coping Time of 24 Hours Section 5.5 of the NSCA states, For CNP to be in a safe and stable condition, it will not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R. Therefore, the unit will remain at or below the temperature defined by a hot standby plant operating state for the event.

Section 4.2.1.2 of the DC Cook LAR describes an initial coping time of 24-hours, after which, actions are necessary to sustain Mode 3 beyond 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. Included in this section are descriptions of additional actions necessary to sustain Mode 3 operations including repairs to pressurizer heaters and PORVs.

What specific actions and additional systems (if any) are necessary to sustain safe and stable conditions beyond 24-hours? Have the necessary systems and components been included in the analysis for fire damage? What are the extent of repairs necessary? Are the actions and repairs addressed in plant procedures? Are there specific timeframes for completion of the repairs?

33. Safe and Stable - Boration LAR Section 4.2.1.2 states that boration is necessary to maintain safe and stable conditions in sustained Mode 3 operations. Technical Evaluation R1900-0026-001, Attachment 4, contains the functional requirements analysis. Under Boric Acid Concentration Requirements the document states that boron concentration in the RCS from RWST injection is sufficient as long as cooldown is initiated within 44-hours. What additional systems and actions are necessary to sustain safe and stable beyond 44-hours or to achieve cooldown?

34. Safe and Stable Hours Technical Evaluation R1900-0026-001, Attachment 4, Section 3.3, describes the HVAC system functional analysis and states, A conservative time used under Appendix R (i.e., 72-hours) bounds the NFPA 805 safe and stable requirements as the time of operation of NSCA hot standby equipment. NFPA 805 does not provide a time limit on safe and stable. What is the basis for the 72-hour assumption bounding NFPA 805? Is this statement based on the 44-hour assumption for initiating cooldown as described above?

35. Gasoline-Engine Driven Blowers Provide additional information on the configuration and use of gasoline-engine driven blowers for control room ventilation. Describe the timing required to perform this identified recovery action (VFDRs AA3-004 and AA3-009).

36. Cross-Connected Units Technical Evaluation R1900-0026-001, describes the minimum staffing per unit. For those recovery actions requiring cross-connecting of Unit 1 and Unit 2 systems (i.e., CVCS, AFW, and ESW) to achieve the nuclear safety performance criteria, do these actions require staff from both units? If so, does the feasibility analysis reflect this Unit 1 - Unit 2 staffing, communication, 11

DC Cook Site Audit (FPE/SSD) and operational interface? What are the operational impacts on the unaffected (by fire) unit created by the cross-connecting of these systems? What is the contribution to unit 1 risk (CDF and LERF) due to a fire in unit 2 and vice-versa.

37. Procedures for Cross-Connected Units Provide a discussion of the procedures for cross-connecting CVCS between units.

38. SAFE Software Provide an overview of the functionality and analysis methods of the SAFE software.

39. Table B-2 Appendix R Compliance Statements NEI 04-02, Section 4.3.2 and Appendix B, Section B.2.1 (as modified by FAQ 07-0039) provide the guidelines for performance of the nuclear safety capability assessment methodology review relative to NFPA 805, Section 2.4.2. Regulatory Guide 1.205, Rev. 1, Position C.3.3 endorses NEI 00-01, Rev. 2, as an acceptable approach to circuit analysis for meeting NFPA 805. In accordance with NEI 04-02, the alignment of nuclear safety capability methodology of NFPA 805 with the provisions of NEI 00-01 is documented in LAR Table B-2. However the alignment basis statements for several of the elements in LAR Table B-2 that were determined to Aligns refer to 10 CFR 50 Appendix R criteria, analyses, evaluations, and terminology (e.g., hot and cold shutdown, alternate shutdown, associated circuits) as the basis for the alignment. The alignment statements do not describe how the cited existing Appendix R basis meets the NSCA requirements of NFPA 805. The following alignment basis statements from Table B-2 are a few examples where Appendix R has been cited:

a. NEI 00-01 Section 3.1 provides general guidance on safe shutdown system identification and path development. The alignment statement is the methodology aligns, however, the alignment basis references the safe shutdown capability analysis (SSCA) as describing the shutdown functions, component list, separation, and exposure fire damage on the basis of Appendix R requirements and criteria.

b. NEI 00-01 Section 3.1.1.4 provides criteria and assumptions related to alternate shutdown. The alignment statement is the methodology aligns, however, the alignment basis as cited from the SSCA refers to complying with III.G of Appendix R and the existing plant alternate shutdown methodology.

c. NEI 00-01 Section 3.1.1.8 provides criteria and assumptions establishing that systems and components for post-fire safe shutdown are not required to be safety-related. The alignment statement is the methodology aligns, however, the alignment basis references the SSCA, which indicates Appendix R as providing the component selection criteria.

d. NEI 00-01 Section 3.1.3.4 provides guidance for assigning shutdown paths. The alignment statement is the methodology aligns, however, the alignment basis refers to 12

DC Cook Site Audit (FPE/SSD) the SSCA and states, an automated analysis of the system and components supporting Appendix R Safe Shutdown compliance identified...success paths for Hot Standby and Hot Shutdown/Cold Shutdown for both units...

e. NEI 00-01 Section 3.2.1.1 provides criteria and assumptions for categorizing safe shutdown equipment. The alignment statement is the methodology aligns, however, the alignment basis refers to the SSCA and states, Components were identified within the systems that are required to satisfy the Appendix R acceptance criteria.

Clarify how these alignment bases show compliance with the requirements of NFPA 805 Section 2.4.2.

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