Text

License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information
	ML16152A046
Person / Time
Site:	Prairie Island
Issue date:	05/24/2016
From:	Northard S; Northern States Power Company, Minnesota, Xcel Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16152A058	List: L-PI-16-005, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information;
References
	L-PI-16-005, TAC ME9734, TAC ME9735
	Download: ML16152A046 (138)
	v • d • e

Enclosure 5 Contains Security-Related Information Witbhold from Public Disclosure in accordance with 10 CFR 2.390 Xcel Energy Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 May 24, 2016 L-Pl-16-005

10 CFR 50.90 10 CFR 50.48(c)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50.;282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information (TAC Nos. ME9734 and ME9735)

References:

1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-Pl-12-089, dated September*28, 2012, ADAMS Accession No. ML12278A405.

2*. NSPM letter, S. Sharp to NRC Document Control Desk,-Supplement to License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors, L-Pl-14-045, dated April 30, 2014 (ADAMS Nos. ML.14125A106 and ML14125A149).

3. NRC email, T. Beltz to S. Chesnutt, Prairie Island Nuclear Generating Plant, Units 1and2 - NFPA 805 Requests for Additiona/1nformation and Response Timeline (TAC Nos. ME9734 and ME9735), dated March 30, 2015 (ADAMS Accession No. ML15089A157).

4. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information, L-Pl-15.-041, dated May 28, 2015 (ADAMS No. ML15153A018).

5. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information- 90-Day Responses, L-Pl-15-052, dated June 19, 2015 (ADAMS No. ML15174A139).

Document Control Desk Page 2

6. NSPM letter, K. Davison to NRG Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Final Request for Additional Information (PRA - Second Round), L-Pl-15-059, dated October 22, 2015 (ADAMS No. ML15296A259).

7. NRG email, T. Beltz to A. Hazelhoff, Prairie Island Nuclear Generating Plant-Requests for Additional Information (AFPB) re: LAR to Adopt NFPA 805 (TAC Nos. ME9734 and ME9735), dated January 8, 2016 (ADAMS No.

ML16008A109).

8. NSPM letter, K. Davison to NRG Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Final Request for Additional Information, L-Pl-16-004, dated January 20, 2016 (ADAMS No.

ML16020A375).

In Reference 1, the Northern States Power Company, a Minnesota Corporation (NSPM) doing business as Xcel Energy requested approval from the Nuclear Regulatory Commission (NRG) to transition the fire protection licensing basis.for the Prairie Island Nuclear Generating Plant (PINGP) to 10 CFR 50.48(c), National Fire Protection

Association Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents AGcess and Management System (ADAMS) Accession No. ML12314A144) and December 18, 2012.(ADAMS Accession No. ML12354A464).

In Reference 2, NSPM submitted a revised Fire Probabilistic Risk Assessment (PRA) in a supplement to the subject License Amendment Request (LAR). In Reference 3, the NRG staff provided requests for additional information (RAls) regarding this request and also provided a timeline and due dates for submitting responses within 60, 90, or 120 days after an on-site Audit that was-conducted March 23-25, 2015. NSPM letter dated May 28, 2015 (Reference 4) provided responses to the 60-day RAls and* one of the .90-day RAls (Fire Protection Engineering RAI 03). NSPM letter dated June 19, 2015 (Reference 5) provided responses to the remaining 90-day RAls.

NSPM letter dated October 22, 201 S (Reference 6) provided responses to second round RAls and included an Attachment L request, "Approval Request 4 - Wiring Above Suspended Ceilings." In Reference 7, the NRG staff provided RAls on this Attachment L request. In Reference 8, NSPM provided responses to these RAls. to this letter provides NSPM's response to PRA RAI 03, including the response to PRA RAI 01.h. Enclosure 2 provides lice.nsee identified LAR changes. provides an updated Attachment M, License Condition Changes. provides an updated Attachment S, Plant Modifications and Items for Implementation. Enclosure 5 provides an updated.Attachment W, Fire PRA Insights, which contains Security-Related information. Accordingly, NSPM requests that be withheld from public disclosure under 10 CFR 2.390(d)(1 ).

Document Control Desk Page 3 This letter is submitted in accordance with 10 CFR 50.90. The additional information provided in this letter does not impact the conclusions of the No Significant Hazards Evaluation or Environmental Considerations Evaluation presented in Reference 2.

In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this additional information by transmitting a copy of this letter to the designated State Official.

If there are any questions or if additionarinformation is needed, please contact Gene Eckholt at 651-267-1742.

Summary of Commitments This letter contains two new commitments and makes no revisions to any existing commitments.

NSPM will implement the items listed in Attachment S, Table S-3, "Implementation Items," at PINGP within twelve months after NRC approval, with the exception of Implementation Item 20 and 66 which are associated with modifications and will be completed 180 days after modifications are complete ..

NSPM will implement the modifications in Attachment S, Table S-2, "Plant Modifications Committed," at PINGP before the end of the second full operating cycle for each unit after approval of the LAR. NSPM will maintain appropriate

.compensatory measures in place until completion of these modifications.

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

[i;d~2016 Scott Northard Acting Site Vice President - Prairie Island Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (5) cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

L-Pl-16-005 NSPM Response to Requests for Additional lnformation.(RAls)

, . Regarding the License Amendment Request 1to ** j._...:

Adopt National Fire Protection Association (NFPA) Standard 805 at Prairie Island Nuclear Generating Plant Units 11 and 2 ~; l NRCRequest PRA RA/ 03 - Integrated Analysis ,

Seetion 2.4.3.3 of NFJ?A 805 states that the PRA approach, methods, and data shall be;,L acceptable to the NRC. Section 2.4.4. 1 of NFPA 805 further states that the change in .....

public health risk arising from transition from the current fire protection *program to an -*

NFPA 805 based program, and all future plant changes to the program, shall be ..

acceptab/e!:to the NRG. The RG 1. 174 provides quantitative guidelines on GDF, LERF, ;*;::

and identifies acceptable changes to these frequencies that result from proposed changes to the plant's licensing basis and describes a general framework to determine the acceptability of risk-informed changes. The NRG stafts review of the information in the LAR identified additional information that is required to fully characterize the risk estimates.

The PRA methods currently under review in the LAR include the following:

PRA RA/ 01.a, regarding fire-induced instrument failure

PRA RA/ 01.b, regarding conduits with unknown routing

PRA RA/ 01.c, regarding instrument air piping in the Relay Room

PRA RA/ 01. d, regarding cable raceways under the raised floor within the MGR

PRA RA/ 01.e, regarding main control board fire scenarios

PRA RA/ 01.f, regarding self-ignited cable fires

PRA RA/ 01.g, regarding detection and suppression system failure probabilities

PRA RA/ 02.a, regarding minimum fot joint human error probabilities

PRA RA/ 02.b, regarding instrumentation and control modeling inconsistencies

PRA RA/ 02. c, regarding the loss of pump net positive suction head

PRA RA/ 04, regarding placement of transient fires

PRA RA/ 05, regarding cable fires caused by welding and cutting

PRA RA/ 06, regarding junction boxes

PRA RA/ 07, regarding sensitive electronics

PRA RA/ 08, regarding circuit failure probabilities

PRA RA/ 09, regarding Bin 15 electrical cabinets

PRA RA/ 10, regarding high energy arcing faults

PRA RA/ 11, regarding the time to delayed detection

- . PRA RA/ 12, regarding MGR abandonment Page 1 of23

L-Pl-16-005 NSPM Enclosure* 1

PRA RAJ: 1 i regarding LJ.CDF, LJ.LERF and additional risk of recovery actions

*

PRA RA/ 1.6, regarding incipient detection [

PRA RA/I 18, regarding dev/ations from ac~eptable methods Please provide the following:

NRC Request (PRA RA/ 03.a)

. a. *Results of an aggregate ai"j~Jysis that provipes the integrated impact on the fire risk (i.e., the total transition.,CDF, LERF, fJ.CDF, LJ.LE..RF and additional risk of recovery 'pctions) of replacing specific methods identified above with altema(ive methods that are. acceptaq{e to the NRG. In this aggregate analysis, for those cases where the individual Issues have a synergistic impact on the results, a simultaneous analysis must be performed. For those cases where no synergy exists, a one-at-a-time analysis may be done. For those cases that have a negligible impact, a qualitative evaluation may be done. It should be noted that this list may change depending on NRC's review of the responses to other RA/s in this document.

NSPM Response (PRA RAl-03.a)

a. An updated NFPA 805 LAR Attachment W has been qeveloped and is included as part of the response to PRA RAI 03. The updated Attachment W lists and discusses the quantification for CDF, LERF, LiCDF, .LiLERF and additional.risk of recovery actions. The results of the quantification include the effects of the comprehensive incorporation of updates associated with RAI responses. The updated Attachment W is provided in Enclosure 5.

Reference:

1. FPRA-Pl-FQ-2.0, Fire PRA Quantification, Revision 2.0.

NRC Request (PRA RA/ 03.b)

b. For each method (i.e., each bullet) above, explain how the issue will be addressed in 1) the final aggregate analysis results provided in support of the LAR, and 2) the PRA that will be used at the beginning of the self-approval of post-transition changes. In addition, provide a process to ensure that all changes will be made, that a focused-scope peer review will be performed on changes that are PRA upgrades as defined in the PRA standard, and that any findings will be resolved before self-approval of post-transition changes.

NSPM Response (PRA RAI 03.b)

b. Table 1 below summarizes how the specific issues are addressed and incorporated in the Fire PRA. This table* also lists the specific RAI responses where further technical details are provided. All the updates and changes

identified as part of the RAI response process have been incorporated in the Fire PRA and *are part of the base model (i.e., the composite model). This integrated Page 2 of 23

L-Pl-16-005 , NSPM Enclosure 1 model is the base Fire: PRA tbat will be used at the beginning of the self-approval of post-transition changes. This base Fire PRA model njlay require updates to reflect the as-built condition of the facilitf modifications Wentified in Table S-2, as required by Implementation Item 20 in Ttable S-3. Consi*stent with the NSPM PRA Guideline for Model Mainteoance and Updates procedure, a peer review will be performed on changes that are PRA l!pgrades as defined in the PRA standard. The scope of the peer review s_hould be commensurate with the scope of the upgrade, (focus~d-scope), and any findings will be resolved before self-approval of post-transition changes as re,quired in TableS-3 Item #25.

Reference:

. 1. FP-PE-PRA-02, PRA Guideline for Model Maintenance and. Update

. ' ~:

2. Table S-3 Item #25 * ;-F*

NRC Request (PRA 'RA/ 03.c)

c. In the response, explain how the Regulatory Guide (RG) 1.205 riskacceptance guidelines are satisfied for the aggregate analysis. Additionally,' discuss the likelihood that the risk increase in any individual fire area would exceed the

acceptance guidelines, and if so, why exceedingthe guidelines should be

, acceptable. If applicable, include a description of any new modifications or operator actions being credited to reduce delta risk as well as a discussion of the .

associated impacts to the fire protection program.

NSPM Response (PRA RAI 03.c)

c. The results described in the updated Attachment W include CDF, LERF, l\CDF,

~LERF and additional risk -of recovery actions that satisfy the RG 1..205 risk acceptance guidelines. The quantification results indicate that the risk of all the fire areas does not exceed the risk thresholds listed in RG 1.205. An updated Attachment Sis provided listing change_s to the *modifications originally listed in the NFPA 805 LAR Supplement. No new risk reduction modifications *have been added. The updated Attachment Sis provided in Enclosure 4. Changes to Attachment S are described in a table of explanation in Enclosure 2.

Reference:

1. FPRA-Pl-FQ-2.o, Fire PRA Quantification, Revision 3.0.

NRC Request (PRA RA/ 03.d)

d. If any unacceptable methods identified above will be retained in the PRA and will be used to estimate the change in risk of post-transition changes to supporl self-approval, explain how the quantification results for each future change will .

account fOr the use of these methods.

Page 3 of 23

L-Pl-16-005 NSPM Enclosure 1 NSPM Response (PRA RAI 03.d)

d. TGe PINGP Fire PRA has been developed 'using a~d~'pted methods, ~ith the t;.~.!.

.*;l't following exception. As described i: n the response to**PRA RAI 18, one deviation

'( from the guidance in NUREG/CR-6.850 has been idelitified. The appbrtioning of fir~ scenario frequencies associated with the main col)trol board fires is not 1

~.:.*

based ori the guidance provided in Appendix L of NUf{EG/CR-6850.; The PINGP

. *: f approach ensures that the full main control board firet'i.gnition frequericy, j {

induding credit for severity factor and non.::suppressi6h probability, is.apportioned

'1.:

to; the different panels. The target n'iapping approac~ giscussed in th~ response_

to; PRA RA! 18, together with the fr~quency apportion~ng process, ensures that the resulting risk values (i.e., CDF c;ind LERF) are boµ,nding in the PINGP Fire PRA. ,[

~~ .... *

Reference:

1. FPRA-Pl-MCR-3.0, Main Control Room Analysis, Revision 3.

Page 4 of 23

L-Pl-16-005 NSPM Table 1 - Response to PRA RAI 03.b

~ _;..* ..

Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment Every single Fire PRA HEP has specific instrumentation associated with the actions and all The final composite treatment includes . The post transition analysis treatment the HEPs were analyzed within the human reliability PRA RAI 01.a, instrument cable mapping to fire includes instrument cable mapping to analysis. When mapped to a fire scenario, the regarding fire- scenarios supporting the human failure fire scenarios supporting the human quantification process fails the instrument ~able~ .

induced events. This treatment is reflected in

failure events. This treatment Is that are mapped to the different fire scenarios w1thm instrument failure the quantification of CDF, LERF, LlCDF, reflected in the quantification of CDF, the plant. The response to PRA RAI 01.a offers and LlLERF. LERF, LlCDF, and LlLERF.

specific technical details regarding the treatment of instrumentation in the Fire PRA.

To facilitate conduit mapping to fire scenarios, the cable routing information from SAFE GENESIS is manipulated to map specific cable/conduit combinations to specific fire areas. The cable routing sequence for each cable is studied ~o evaluate the location of the cable through different raceways (cable trays and conduits). The cond~it location in the routing is established by comparing the location of the known cable trays in the route The final composite treatment includes sequence to the known fire area locations of the The post transition analysis treatment the identified conduit location and its PRA RAI 01.b, cable itself and determining the conduit to fire area includes the conduit location as appropriate fire induced failure as regarding relationship based on that routing. The conduit identified by inspection of the cable identified by inspection of the cable conduits with generic identification is concatenated with the cable routing* sequence.* This treatment is routing sequence. This treatment is unknown routing name. reflected in the quantification of CDF, reflected in the quantification of CDF, LERF, LlCDF, and LlLERF.

LERF, LlCDF, and LlLERF.

The approach described above provides a high level of confidence that conduits containing Fire PRA target cables are mapped to the appropriate fire compartments. For cases where additional refinement was needed for detailed fire modeling, additional walkdowns were performed to identify .... - .,

conduits and cable trays within the zone of - -- -- :*

r

"{- - --=' *- ~- -

influence.

Page 5 of 23

L-Pl-16-005 NSPM .

Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment PRA RAI 01.c, The final composite treatment does not The, post transitio'n *analysis treatment regarding include credit for instrument air in the does not include credit for instrument Instrument air is not credited in the PINGP Fire instrument air Relay Room. This treatment is reflected air in the Relay Room. This treatment PRA.

piping in the in the quantification of CDF, LERF, is reflected in the quantification of Relay Room LiCDF, and LiLERF. CDF, LERF, LiCDF, and LiLERF.

The response to PRA RAI 01.d provides a detailed description of the fire scenarios described in the main control room. These scenarios include fires associated with electrical cabinets, the niain control board, transient fires, transient fires due to hotwork, and junction box fires. As part of the development and analysis of these scenarios, the fire modeling The post transition analysis treatment results for the Main Control Room abandonment The final composite treatment includes PRA RAI 01.d, includes the.cable mapping to.

analysis suggest that electrical cabinets alone are the cable mapping to cabinets in the regarding cable cabinets in the control room and the enough to generate abandonment conditions. Since control room and the area under the raceways under area under the raised floor. This the Fire PRA cables are mapped to the applicable raised floor. This treatment is reflected the raised floor treatment is reflected in the panels as targets, the quantified CCDPs and in the quantification of CDF, LERF, within the MCR quantification of CDF, LERF, LiCDF, CLERPs include the impact of cables that may be LiCDF, and LiLERF.

and LiLERF.

routed through the area under the raised floor.

Furthermore, given the relatively quick suppression activities in the control room (as suggested by a manual suppression curve with a constant of 0.33),

the analysis assumes that transient and cabinet fires will, on average, be controlled before propagating to the area under the raised floor.

As described in the responses to PRA RAI 01.e and PRA RAI 18, the generic frequency associated with the fire scenarios defined in the PINGP main control board has not been apportioned following the The final composite treatment includes The post transition analysis treatment guidance in Appendix L of NUREG/CR-6850. the apportioning main control board includes the-apportioning main .control PRA RAI 01.e, Alternatively, the frequency has been apportioned frequencies as described in the board frequencies as described in the regarding main so that its full value is accounted for as part of response to PRA RAI 18 and PRA RAI response to PRA RAI 18 and PRA RAI control board fire different damage states in the fire scenario 01 e. This treatment is reflected in the 01 e. This treatment is reflected in the scenarios progression. The responses to both PRA RAI 18 quantification of CDF, LERF, LiCDF, quantification of CDF, LERF, LiCDF, and PRA RAI 01.e provide: 1) a description of the and LiLERF. and LiLERF.

methodology used in the PINGP Fire PRA, and 2) a technical justification for the methodology based on its conservative application.

Page 6 of 23

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment The risk contribution of self-ignited cable fires is not included in the PINGP Fire PRA. As indicated in the The post transition analysis treatment The final composite treatment does not PRA RAI 01.f, response to PRA RAI 01.f, the majority of the cables does not include the risk contribution include the risk contribution of self-regarding self- at PINGP are characterized as qualified. Therefore, of self-ignited *cable fires. Tnis - **

ignited able fires. This treatment is ignited cable consistent with the guidance in Chapter 6 of treatment is reflected in the reflected in the quantification ofCDF, fires NUREG/CR-6850, and FAQ-13-0005, the risk quantification of GDF, LERF, LlCDF, LERF, LlCDF, arid LlLERF.

contribution of self-ignited cable fires is not included and LlLERF.

in the Fire PRA. '.

The response to PRA RAI 01.g describes that the discrepancy regarding the inconsistent determination of total failure probabilities of credited detection and suppression systems has been corrected in the aggregate PRA analyses for The post transition analysis treatment The final composite treatment includes PRA RAI 01.g, NSPM's response to PRA RAI 03. The non- includes the consistent treatment of the consistent treatment of detection regarding suppression probability has been calculated as the detection and suppression credit as and suppression credit as the sum of detection and sum of the unreliability and the unavailability values the sum of the unreliability and the unreliability and unavailability of the suppression corresponding to each credited automatic detection unavailability of the corresponding corresponding systems. This treatment system failure and suppression system. This approach has been systems. This treatment is reflected in is reflected in the quantification of GDF, probabilities implemented in all the scenarios analyzed with the quantification of GDF, LERF, LERF, LlCDF, and LlLERF.

detailed fire modeling crediting automatic LlCQF, and_LlLER.F. .. . ___ ... _

suppression in the Fire PRA. This treatment is integrated within the base Fire PRA model and reflected in the quantification of GDF, LERF, LlCDF, and LlLERF.

PRA RAI 02.a, The final composite treatment includes The post transition analysis treatment regarding As described in the response to PRA RAI 02.a, the 1 E-05 minimum value for joint includes the 1 E-05 minimum value for minimum for joint NSPM has applied the 1 E-05 minimum value for HEPs. This treatment is reflected in the joint HEPs. This treatment is reflected human err.or joint HEPs. quantification of GDF, LERF, LlCDF, in the quantification of GDF, LERF, probabilities and LlLERF. LlCDF, and LlLERF.

Page 7 of 23

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRA RAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment As described in the response to PRA RAI 02.b, the current instrumentation and control modeling in the Fire PRA is considered conservative. This The final composite treatment includes The post transition analysis treatment PRA RAI 02.b, conservatism is due to inclusion of individual basic the explicit instrumentation modeling includes the explicit instrumentation regarding events within the Fire PRA model that are already that is already accounted for within the modeling that is already accounted for instrumentation accounted for within the overall component overall component boundary. This within the overall component and control boundary (and are therefore included in the treatment is reflected in the boundary. This treatment is reflected modeling associated failure rate) of a larger component. The quantification of GDF, LERF, i1CDF, in the quantification of GDF, LERF, inconsistencies result is a double-counting of failures associated and i1LERF. i1CDF, and i1LERF.

with these components, which is deemed conservative.

PRA RAI 02.c describes that the PRA model considers potential net positive suction head (NPSH) issues related to RHR pump operability during events in which the containment sump is used as the supply source to the Reactor Coolant System (RCS). Based on pump NPSH requirements and NPSH testing and analysis, it has been concluded that: 1) the pump operability would not be The final composite treatment does not The.post transition. analysis treatment PRA RAI 02.c, impacted by debris if containment systems operate model Containment Fan Coil Units does not model Containment Fari Coil regarding the as designed (sump water is passed through and/or Containment Spray Units and/or Containment Spray loss of pump net filter/strainer prior to pump suction), and 2) the operation/failure in the accident operation/failure in the accident positive suction pump operability would also not be adversely sequence evaluations. This treatment sequence evaluations. This treatment head impacted by the rising temperatures in the is reflected in the quantification of GDF, is reflected in the quantification of containment sump and does not rely on LERF, i1CDF, and i1LERF. GDF, LERF, i1CDF, and i1LERF.

containment over pressure for NPSH requirements.

Based on the above assumptions and additional thermodynamic calculations it was concluded that there is no need to model Containment Fan Coil Units and/or Containment Spray operation/failure in the accident sequence evaluations.

Page 8 of 23*

L-Pl-16-005 NSPM Enclosure* 1 Table 1: PRA RAI 03 Analysis Treatment Summary PRA RAI No. Technical Summary Final Composite Analysis Treatment f>os_t-Trarlsition Analysis. Treatment Transient fires are assumed to occur in all "open" floor areas within the fire zones. Open floor areas refer to floor locations that are not occupied by fixed The final composite treatment assumes The post transition analysis treatment plant equipment. Based on this assumption, the PRA RAI 04, transient fires are located in all open assumes transient fires are located in contribution from transient fires, including transient regarding floor areas within the fire zone. This all open floor areas within the fire fires due to hotwork, is quantified for all open floor placement of treatment is reflected in the zone. This treatment is reflected in areas. The quantification includes identification of transient fires quantification of CDF, LERF, b.CDF, the quantification of CDF, LERF, different floor areas within the fire zone where the and b.LERF. b.CDF, and b.LERF.

transient fire could occur, mapping the targets to the different floor areas, and the application of the corresponding floor area ratio to the scenario.

The final composite treatment includes The post transition analysis treatment PRA RAI 05, the risk contribution of cable fires due to includes the risk contribution of cable As described in the response to PRA RAI 05, the regarding cable welding and cutting following the fires due to welding and cutting risk contribution of cable fires due to welding and fires caused by guidance in FAQ-13-0005. This following the guidance in FAQ cutting is included in the PINGP Fire PRA following welding and treatment is reflected in the 0005. This treatment is reflected in the guidance in FAQ-13-0005.

cutting quantification of CDF, LERF, b.CDF, the quantification of CDF, LERF, and b.LERF. b.CDF, and b.LERF.

The post transition analysis treatment The final composite treatment includes includes the risk contribution of As described in the response to PRA RAI 06, the the risk contribution of junction box fires PRA RAI 06, junction box fires following the risk contribution of junction box fires is included in following the guidance in FAQ-13-0006.

regarding guidance in FAQ-13-0006. This the PINGP Fire PRA following the guidance in FAQ- This treatment is reflected in the .

junction boxes treatment is reflected in the 13-0006. quantification of CDF, LERF, b.CDF, quantification of CDF, LERF, b.CDF, and b.LERF. *, ,, ,. an*d-LlLERF.'0 *s. 'J.. "< .o rr:.

As described in the response to PRA RAI 07, the The post transition analysis treatment The final composite treatment includes risk contribution associated with fire induced failure includes the treatment of'sensitive PRA RAI 07, the treatment of sensitive electronics of sensitive electronics is included in the PINGP Fire electronics consistent with the regarding consistent with the guidance in FAQ-PRA following the guidance in FAQ-13-0004. Fire guidance in FAQ-13-004. This sensitive 13-004. This treatment is reflected in induced failures of sensitive electronics are treatment is reflected in the electronics the quantification of CDF, LERF, b.CDF, evaluated in the Relay Room and in the Main quantification of CDF, LERF, b.CDF, and b.LERF.

Control Room. and b.LERF ..

Page 9 of 23

.j;

~- 1 .,..

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary 'lj. \ :*

PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment The response to PRA RAI 08 describes the The final composite treatment includes The post transition analysis treatment application of circuit failure mode probabilities in the the latest circuit failure mode probability includes the latest circuit failure mode PRA RAI 08, PINGP Fire PRA. The latest circuit failure mode values available in NUREG 7150 and probability values available in NU REG regarding circuit values and application guidance available in does not utilize option #2 in 7150 and does not utilize option #2 in failure NUREG-7150 Volumes 1 & 2 have been used. NUREG/CR-6850, Chapter 10. This NUREG/CR-6850, Chapter 10. This probabilities Option #2 of NUREG/CR-6850, Task 10, Circuit treatment is reflected in the treatment is reflected in the Failure Mode Likelihood Analysis, was not used in quantification of CDF, LERF, LlCDF, quantification of CDF, LERF, LlCDF, the PINGP Fire PRA. and LlLERF. and LlLERF.

As described in the response to PRA RAI 09, the electrical cabinets in the PINGP Fire PRA have The final composite treatment includes The post transition analysis treatment been counted following the guidance in the counting and treatment as ignition includes the counting and treatment as NUREG/CR-6850 and Supplement 1 to PRA RAI 09, sources of electrical cabinets with ignition sources of electrical cabinets NUREG/CR-6850. Specifically, no cabinets regarding Bin 15 voltages higher than 440V. These with voltages higher than 440V.

containing circuits with voltages higher than 440V electrical panels have not been classified as well- These panels have not been classified have been identified as "well sealed." In addition, cabinets sealed. This treatment is reflected in as well-sealed. This treatment is cabinets containing circuits with voltages higher the quantification of CDF, LERF, LlCDF, reflected in the quantification of CDF, than 440V have been identified as ignition sources and LlLERF. LERF, LlCDF, and LlLERF.

with fires that propagate outside the boundaries of the electrical enclosures.

As described in the response to PRA RAI 10, high energy arcing faults have been modeled in the PINGP Fire PRA following the guidance in Appendix The final composite treatment includes The post*transition analysis treatment M of NUREG/CR-6850. In addition, the high energy the use of the suppression curve for includes the use of the suppression PRA RAI 10, arcing fault fire scenarios are quantified using the high energy arcing faults for the entire curve for high energy arcing faults for regarding high suppression curve listed in Table 14-2 of scenario progression where the the entire scenario progression where energy arcing Supplement 1 to NUREG/CR-6850 for high energy initiating fire is a high energy arcing *: the initiating fire is a high energy '*

faults arcing fault scenarios. This suppression curve for fault. This treatment is reflected in the arcing fault. This treatment is high energy arcing faults is used for determining the

quantification of CDF, LERF, LlCDF, reflected in the quantification of CDF, non-suppression probabilities associated with the and LlLERF. LERF, LlCDF, and LlLERF.

different damage states associated with each fire scenario.

As described in the response to PRA RAI 11, the The final composite treatment includes The post transition analysis treatment PRA RAI 11, PINGP Fire PRA no longer uses the delayed a delayed detection time of 15 minutes. includes a delayed detection time of regarding the detection time of 10 minutes. The time to delayed This treatment is reflected in the 15 minutes. This treatment is time to delayed detection has been updated to 15 minutes. The quantification of CDF, LERF, LlCDF, reflected in the quantification of CDF, detection Integrated analysis reflects the use of a 15 minute and LlLERF. LERF, LlCDF, and LlLERF.

delayed detection time.

Page 10 of 23

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Pqst-Tran~ition Analysis Treatment The response to PRA RAI 12 provides a comprehensive description of the main control room abandonment modeling in the PINGP Fire PRA.

The final composite treatment includes The post transition analysis treatment The response is comprehensive as it describes the the modeling of control room includes the modeling qf control room treatment of control room abandonment from both PRA RAI 12, . abandonment reflecting both habitability abandonm'ent reflecting both habitability and operability perspectives. Control regarding MCR and operability conditions. This habitability and operability-conditions.

room abandonment is credited and modeled in the abandonment treatment is reflected in the This treatment is reflected in the -

Fire PRA in fire scenarios in the Relay Room and in quantification of CDF, LERF, LlCDF, quantification of CDF, LERF, LlCDF, the Main Control Room. The abandonment and LlLERF. and LlLERF.

procedure has been modeled in detail so that CCDP and CLERP values can be quantified using the CAFTA and FRANX models.

As described in the response to PRA RAI 13, for a given fire area, the additional risk of recovery actions was calculated as the difference in CDF The final composite treatment The post transition analysis treatment (LERF) in the variant plant (post-transition plant calculates the additional risk of calculates the additional risk of PRA RAI 13, where the credited recovery actions take their recovery actions in all fire areas, recovery actions in all fire areas, regarding LlCDF, nominal HEPs), and the CDF (LERF) of the post-regardless of whether a fire area does regardless of whether a fire area does LlLERF and transition plant where the credited recovery actions or does not credit control room or does not credit control room additional risk of have the execution portion of their HEP set to 0 (or, abandonment. This treatment is abandonment. This treatment is recovery actions for some VFDRs, the entire HEP of the associated reflected in the quantification of CDF, reflected in the quantification of CDF, credited recovery action conservatively set to 0).

LERF, LlCDF, and LlLERF. . LERF, LlCDF, and LlLERF.

This method is applied to all fire areas, regardless of whether a fire area does or does not credit control room abandonment.

The final composite treatment includes The post transition analysis treatment As described in the response to PRA RAI 16, the credit for an in cabinet incipient includes credit for an in cabinet PRA RAI 16, effect of an incipient detection system has been detection system in selected panels incipient detection system in selected regarding credited in the PINGP Fire PRA for selected consistent with the guidance in panels- conSistenrwith-thef*guida*nce* in incipient cabinets in the Relay Room. The incipient detection Supplement 1 to NUREG/CR-6850. Supplement 1 to NUREG/CR-6850.

detection system has been modeled following the guidance in This treatment is reflected in the This treatment is reflected in the Supplement 1 to NUREG/CR 6850. quantification of CDF, LERF, LlCDF, quantification of CDF, LERF, LlC[),F, and LlLERF. and LlLERF ..

Page 11 of 23

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Tr~atment As described in the response to PRA RAI 17, a focused peer review was conducted to evaluate the model changes made to address the incorporation of Flowserve N9000 Reactor Coolant Pump (RCP) seals at PINGP. The findings associated with the reactor coolant pump (RCP) seal PRA modeling were incorporated into the Fire PRA.

The Flowserve Corporation topical report "PRA Model for Flowserve 3 Stage N-Seals with The final composite treatment includes PRA RAI 17, The post transition analysis treatment Abeyance Seal", Revision 0, dated December 20 the modeling of Flowserve N9000 regarding reactor includes NRC Approved RCP seal coolant pump. 2013, concluded that the seals allow for an oper~tor Reactor Coolant Pump (RCP) seals at modeling. This treatment is reflected response time for RCP trips of up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The PINGP. This treatment is reflected iri' (RCP) seal PRA in the quantification of CDF LERF volume of water inside of the RCP above the cold the quantification of CDF, LERF, .liCDF, modeling .liCDF, and liLERF. ' '

leg will be purged in conservatively 60 minutes and and .liLERF.

Flowserve tests show that at least an additional 60 minutes will be available until the seals have measurable changes in leakage. The report also concluded that for Station Blackout (SBO) scenarios a failure probability of 6.83E-07 is appropriate and with no SBO and a time to trip of two hours the failure probability of 2.73E-04 is appropriate for the Fire PRA.

Page 12 of 23

L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRA RAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment As described in the response to PRA RAI 18, the PINGP Fire PRA has been developed with accepted methods. One deviation from the guidance in NUREG/CR-6850 has been identified. The apportioning of the main control board generic frequency to the different fire scenarios is defined in the Fire PRA. Specifically, the generic frequency The final composite treatment includes The post transition analysis treatment PRA RAI 18, associated with the fire scenarios defined in the the apportioning main control board includes the apportioning main control Regarding PINGP main control board has not been frequencies as described in the board frequencies as*described in the deviations from apportioned following the guidance in Appendix L of response to PRA RAI 18 and PRA RAI response to PRA RAI 18 and PRA RAI acceptable NUREG/CR-6850. Alternatively, the frequency has 01.e. This treatment is reflected in the 01.e. This treatment is reflected in the methods been apportioned so that its full value is accounted quantification of CDF, LERF, t.CDF, quantification of CDF, LERF, t.COF, as part of different damage states in the fire and t.LERF. and t.LERF. .

scenario progression. The responses to both PRA RAI 18 as well as PRA RAI 01.e provide: 1) a description of the methodology used in the PINGP Fire PRA, and 2) a technical justification for the methodology based on its conservative implementation.

As described in the response to FM 01.f, for those fire scenarios where fire propagation outside the The final composite treatment includes The post transition analysis treatment .

transient zone is possible, additional damage states the risk contribution of propagating includes the risk contribution of FM 01.f, have been added to the Fire PRA capturing the risk damage states from transient fires. propagating damage states from regarding associated with such conditions. The target set Damage states resulting from transient fires. Damage states propagating associated with these propagating damage states propagating transient fires have been resulting from* propagating-transient damage states includes the failure of the targets mapped to the included in the Fire PRA. This fires have been included in the Fire from transient adjacent zone of influence. The fire ignition treatment is reflected in the PRA. This treatment is reflected in the fires. frequency associated with these propagating quantification of CDF, LERF, t.CDF, quantification of CDF, LERF, t.CDF, damage states includes credit for the non-and t.LERF. and t.LERF.

suppression probability at the time of fire propagation.

Page 13 of 23

- -~ l ..

I' c_,

~~ *In, L-Pl-16-005 NSPM Table 1: PRA RAI 03 Analysis Treatment Summary PRARAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysis Treatment As described in the response to FM RAl-01.i.01, a fifteen minute delayed detection is credited because: 1) NUREG/CR-6850, Appendix P and NRC Inspection Manual Chapter 0609, Appendix F Attachment 8 recommend the use of 15 minutes for delayed detection, 2) the twenty-one fire The final composite treatment includes The post transition analysis treatment compartments where delayed detection is credited credit for a 15 minute delayed detection includes credit for a 15 minute delayed for the calculation of non-suppression probabilities time for 21 fire compartments, and the detection time for 21 fire FM RAl-01.i.01, are equipped with automatic detection.systems, 3) removal of delayed detection credit for compartments, and the removal of regarding credit these twenty-one fire compartments contain plant the Unit 1 and 2 containments and delayed detection credit for the Unit 1 for delayed equipment and cables credited for shutdown containment annulus respectively. This and 2 containments and containment detection. activities that will generate alarms or indications of treatment is reflected in the annulus respectively. This treatment abnormal conditions, and 4) the twenty-one fire quantification of CDF, LERF, t.CDF, is reflected in the quantification of compartments are routinely visited by plant and t.LERF. CDF, LERF, t.CDF, and t.LERF.

personnel or are nearby the regular travel path of plant operations. Therefore, there are no fire compartments in which 15 minutes for delayed detection cannot be justified. Delayed detection credit has been removed from the Unit 1 and 2 containments and containment annulus .

As described in the response to PRA RAJ 01.d.01, PRA RAJ 01.d.01 The final composite treatment includes The post transition analysis treatment the Core Damage Frequency (CDF) and the Large regarding the risk contribution of transient fire includes the risk contribution of Early Release Frequency (LERF) associated with transient fires in scenarios in the area under ttie raise_d transient fire scenarios in the area the transient fires and transient fires due to hotwork the area under floor in the main control room. This under lhe rai"seci'fl6or in the main:.

in the area under the raised floor in the main control the raised floor in treatment is reflected in the control room. This treatment is room (MCR) has been quantified and explicitly the main control quantification of CDF, LERF, t.CDF, reflected in the quantification of CDF, included in the PINGP Fire PRA using the guidance room and t.LERF. LERF, t.CDF, and t.LERF. '-

in FAQ 12-0064.

Page 14 of 23

L-Pl-16-005 NSPM L.**

Table 1: PRA RAI 03 Analysis Treatment Summary PRA RAI No. Technical Summary Final Composite Analysis Treatment Post-Transition Analysjs Treatment As described in the response to PRA RAI 01.e.01 the risk (i.e., Core Damage Frequency and Large Early Release Frequency) associated with fire scenarios generated from Sequences 1 and 2 of the main control room (MGR) event tree model has The final composite treatment includes The* post transition analysis treatment PRA RAI 01.e.01 been re-quantified as follows: the quantification of transient fires in the includes the quantification of transient regarding the The Conditional Core Damage Probability (CCDP) main control room failing all the targets fires in the main control room failing all target sets of and Conditional Large Early Release Probability associated with an electrical cabinet or the targets associated with an transient fires in (CLERP) for scenarios involving non main control main control board panel. This electrical cabinet or main control board the main control board electrical cabinets has been quantified treatment is reflected in the panel. This treatment is reflected in room assuming full damage of the corresponding quantification .of GDF, LERF, LlCDF, the quantification of GDF, LERF, electrical cabinet. and LlLERF. LlCDF, and LlLERF.

The CCDP and CLERP associated with transient fires postulated near the main control board has been quantified assuming full damage of the corresponding main control board panel.

The final composite treatment includes The post tran'sition analysis treatment PRA RAI 07.01 the revised treatment of targets includes the revised treatment of As described in the response to PRA RAI 07.01 &

& PRA RAI associated sensitive electronics targets associated sensitive PRA RAI 07.02, the treatment of sensitive 07.02 regarding damage criteria as described in the electronics damage criteria as electronics in the PINGP Fire PRA has been the treatment of response to PRA RAI 07.01 and 07.02. described in thEfresponse tcf PRA RAI updated based on the guidance in NUREG/CR-sensitive This treatment is reflected in the 07.01 and 07.02. This treatment is 6850 and FAQ 13 0004.

electronics quantification of GDF, LERF, LlCDF, reflected in the quantification of GDF, and LlLERF. LERF, LlCDF, and LlLERF.

NSPM has re-revaluated the Refueling Water The final composite treatment no longer The post transition analysis treatment Storage Tank (RWST) to containment Sump B drain SSA RAI 07 credits recovery actions to isolate no longer credits recovery actions to down scenario and has determined that recovery regarding valves to isolate the RWST. This isolate valves to isolate the RWST.

actions are no longer needed to de-energize Sump recovery actions treatment is reflected in the ,, T~is)~eatment_i~, r~flectep ir t.h.~ ~.

B motor operated valves and de-energize and to isolate RWST quantification of GDF, LERF, LlCDF," quantification of*GDF, LERF,*LlCDF, manually operate RWST to RHR pump isolation and LlLERF. and LlLERF.

valves.

Page 15 of 23

L-Pl-16-005 NSPM NRC Reque~t (PRA RA/ 01.h) ! . ,.\;i IGN-A 1-01: f.he disposition to this F&O appears to indicate th~t generic fire ignition frequencies *t11ere based upon those provided in Supplement 1: to NUREGICR-6~,50. .

Chapter 10 df'this supplement, however, states that a sensitivity analysis should be petformed when using the fire ignition frequencies in the supplement instead of tl)ose provided in T~ble 6-1 of NUREGICR-6850, provide the results: (i.e., GDF, LERF,~CDF an,(111LERF)'bf a sensitivity analysis that evaluates the impact!of using the supp~(?ment frequencies, 96nsistent with Chapter 10 of Supplement 1 to N{/REGICR-6850 using the FPRA deve/0ped in response to RA/ 03. . i .;;f:

~ ~

If RG 1.174 risk acceptance guidelines are exceeded, then please (1) discuss which are exceeded; (2) describe the fire protection, or related, measures that will be taken to ...

provide additional defense-in-depth; and (3) discuss conservatisms in the analysis and the risk significance of these conservatisms.

NSPM Response (PRA RAI 01.h).

The PINGP Fire PRA uses the ignition frequencies from the latest guidance related to fire PRAs as given in Supplement 1 to NUREG/CR-6850. Supplement 1 to NUREG/CR-6850 (Section 10.2) addresses the use of the ignition frequencies as follows:

"The NRC accepts use of these revised fire bin ignition frequencies for fire PRAs conducted for NFPA-805 transition for best-/point-estimate calculations of fire risk (core damage frequency [CDF] and large earlyrelease frequency [LERF]),

including delta-risk values from plant change evaluations, with the following provision. The fire PRA, including plant change evaluations, must also evaluate the sensitivity of the risk and delta-risk results to evaluations performed using the current fire bin ignition frequencies in EPRI 1011989, NUREG/CR-6850, Chapter 6, "Fire Ignition Frequencies," Table 6-1, "Fire Frequency Bins and Generic Frequencies," and Appendix C, "Determination of Generic Fire Frequencies,"

Table C-3, "Generic Fire Ignition Frequency Model for U.S. Nuclear Power Plants." For those cases where the results from this sensitivity analysis inqicate a change in the potential risk significance associated with elements of the fire PRA or plant change evaluations that affects the decisions being made (e.g.,

what is acceptable with the new frequencies from EPRI 1016735 might not be acceptable with the current applicable set frQm EPRI 1011989, NUREG/CR-6850), the licensee must address this situation by consjdering fire protection, or related, measures that can be taken to provide addition.al defense in-depth."

With respect to the required sensitivity analysis, a footnote provides the following clarification:

"The sensitivity analyses should be performed for a fire ignition frequency bin using the mean of the fire ignition frequency bins contained in NUREG/CR-6850.'

Furthermore, sensitivity analyses only need to be performed for those bins characterized by an alpha from the EPRI 1016735 analysis that is less than or equal to 1. Note that an alpha value less than or equal to 1 is characteristic of a Page 16 of 23

L-Pl-16-005 NSPM r~verse-J shaped probability density function, i.e., the same shape qS the non-i~formafive prior di~lributions used in EPRI 1016735. This reverse-~ shape !is iradicative~ of the large uncertainty in the bin fire frequency due to the: sparsity of data for that bin, ahd therefore, the potential for significant changes should the p:ost-2000 fire event data differ significantly from the 1991-2000 data. The*

r~quired sensitivity;~nalysis is, for the purpose of this interim solutio~, judged to provide *an adequate indication of the effects on risk and delta-risk i~ such a.

case." *: ,. ,. *,j:.,...

An evaluation of the sensitivity results ag~inst Regulatory Guide 1.174 indicates that the delta risks by fire area in Table 3 below using the NUREG/CR-6850 ignition frequencies meet the risk acceptance guidelines defined for Region II of Figures 4 and 5 in Regulatory Guide 1.174 0n an individual fire area basis. However, the total increase in , it

risk for the overall plant exceeds the acceptance guidelines as indicated in 'Tables 1 and 2 below.

Table 3 below lists the contribution to delta CDF and delta LERF for each fire area when the Fire: PRA model is quantified using the frequencies from NUREG/CR-6850. The results indicate that most of the contribution to delta CDF (Unit 1/Unit 2) is generated by Fire Areas 13 (59% /71%), Fire Area 18 (21%/28%), Fire Area 20 (14%/0%), Fire Area 31 (4%/0%), Fire Area 58 (1.4%/0.0%), and Fire Area 59 (0.3%/0.2%). These areas are the top contributors to LERF as well.

Consistent with the guidance in Section 10.2 of Supplement 1 to NUREG/CR-6850, fire protection, or related, measures that can be taken to provide Defense In-Depth (DID) for these top contributing fire areas have been evaluated. DID was evaluated for each fire area (i.e. 13, 18, 20, 31, 58, and 59) via the Fire Risk Evaluation (FRE) process that supports the NFPA 805 application. The FRE analysis concludes that there is an adequate balance between the DID echelons. Additional information regarding the evaluation of DID is provided in the following risk evaluations that support the NFPA 805 application:

FRE-FA-13, NFPA 805 Fire Risk Evaluation - Control Room

FRE-FA-18, NFPA 805 Fire Risk Evaluation-:-- Relay and Cable Spreading Room

FRE-FA-20, NFPA 805 Fire Risk Evaluation- Unit 1 4.16kV Safeguards Switchgear (Bus 16)

FRE-FA-31, NFPA 805 Fire Risk Evaluation -A Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room

FRE-FA-58, NFPA 805 Fire Risk Evaluation -Auxiliary Building Ground Floor Unit 1

FRE-FA-59, NFPA 805 Fire Risk Evaluation -Auxiliary Building Mezzanine Levels Units 1 and 2 The Fire Quantification notebook addresses conservatisms that remain in the analysis after FPRA updates and refinements. Some of the conservatisms include the assumption of conduit failures in fire scenarios, the assumption of plant trip for both units, the treatment of cable damage criteria, circuit failure mode likelihood analysis, cable selection, and instrument air failure. Specifically, Page 17 of 23

L-Pl-16-005 NSPM:

Conduits in fire areas are conservatively failed in all fire scenarios. For cases t'"!

where the quantification indicated that specific cables in conduits were risk- ,

significant, detailed walkdowns r~nd drawing reviews were performed to only map:

these conduit~ to the fire scenarios where the conduit could be damage in the '

zone of influence of the fire, thereby removing excessive conservatism.

w-:: 1

Since comprehensive: cable trading for all syste~s that could r~sult in a plant trip i is not available, it cannot be assured that a fire i:n a compartment on one unit will :

not also affect the.other unit. Consequently, a dual plant trip is assumed in the :

quantification.: .!11 *

Thermoplastic damage criteria are used for the damage threshold for all targets of the Fire PRA. This 'provides fi.n appropriate treatment of target damage for ~ r:;

cables that are made of thermoplastic materials. For other targets, which are typically more resistant to effects of the fire, this approach is conservative.

Instrument Air is not credited in the Fire PRA due to the wide distribution of Instrument Air piping and potential for soldered joint failures. Therefore, the uncertainty about Instrument Air was addressed by assuming that Instrument Air*

would be failed by fire, which is conservative.

Conclusion The PINGP FPRA uses ignition frequencies from the latest guidance given in Supplement 1 to NUREG/CR-6850. Per section 10.2 of the Supplement, a sensitivity analysis was performed using the mean of the fire ignition frequency bins contained in NUREG/CR-6850 for alpha values less'than or equal to 1. An evaluation of the sensitivity results against Regulatory Guide 1.174 indicates the total. increase in risk for the overall plant exceeds the acceptance guidelines. Consistent with the guidance in Section 10.2 of Supplement 1 to NUREG/CR-6850, DID was evaluated for each fire area during the FRE process. The FRE analysis concludes that there is an adequate balance between DID echelons.

Page 18 of 23

L-Pl-16-005 NSPM Table 1 - Sensitivity Stu"y Results for Alpha <-1;;Sensitivity for PIN<3P Unit 1

~ ..

.dCDF *ht .dLERF Unit 1 CDF' "unit 1 LERF

(/rx-y) . (from Baseline)! (from Baseline)

(/rx-y)

(/rx-y) " .;, (/rx-y) lBaseline (Variant Plant) 6.44E-05 9.93E-07 I

6850 Means for Alpha <1 9.75E-05 ;, 3.31E-05 ;.: 1.54E-06 5.47E-07

.: :AL!;Rl1 (fron:i., . \.,

' Baselirie*4L'ERF)Y:*',,

, '" , ,s+,, *_ ""~:;: (irx=rt ..... "'*""

'.Baseline Delta Risk 9.28E-06 -*- 1.80E-07 6850 Means for Alpha <1 1.28E-05 3.52E-06 ;'>. 2.60E-07 8.00E-08 Table 2 - Sensitivity Study Results for Alpha <1 Sensitivity for PINGP Unit 2

.dCDF .dLERF Unit2 CDF Unit2 LERF:

(from Baseline) (from Baseline)

(/rx-y) (/rx-y)

Baseline (Variant Plant) 6.51E-05 9.72E-07 6850 Means for Alpha <1 9.89E-05 3.38E-05 1.51E-06 5.38E-07 Baseline Delta Risk 5.71E-06 1.06E-07 6850 Means for Alpha <1 8.03E-06 2.32E-06 1.60E-07 5.40E-08 Page 19of23

L-Pl-16-005 NSPM Enclosure 1 Jf r. ):t

. Table 3 - Sensitivity Study Results for Alpha <1 Sensitivity'~}'._ Fire Area

...... Unit 1 ~'1'1' Unit2 i i{ ; *;t Fire Delta Delta Delta. Delta

" Area Description CDF LERF CDF LERF CDF LERF CDF LERF Containrnent Unit ;: *:

1 1

4.1E-06 4.9E-08 e e 1.6E-08 *

2.0E-10 NIA NIA

- *~~~' .'!

Ventilation Fan 2 3.7E-08 4.9E-10 NIA NIA. 3.6E-08 4.7E-10 NIA NIA Room Unit 1 & 2 Water Chiller 3 6.8E-09 8.8E-11 NIA NIA 7.2E-09 9.4E-11 NIA NIA

~~-~

Room *\.~ \

- \:~

Fuel Handling 4 1.1E-07 1.5E-09 NIA NIA 1.0E-07 1.4E-09 NIA NIA Area Old Administration

~t:n ,,.....! .

Building, HVAC 6 2.0E-09 2.5E-11 NIA NIA 2.1 E-09 "' 2.7E-11 NIA NIA Equipment Area 750' 8 Turbine Building 6.5E-06 8.9E-08 NIA NIA 4.3E-06 5.7E-08 NIA NIA Train A Event 10 Monitoring 1.2E-07 1.7E-09 NIA NIA 1.7E-08 2.2E-10 NIA NIA Equipment Room Unit 1 Normal Switchgear &

11 5.0E-08 6.5E-10 NIA NIA 4.3E-08 5.7E-10 NIA NIA Control Rod Drive Room 12 OSC Room 1.9E-09 2.4E-11 NIA NIA 2.0E-09 2.6E-11 NIA NIA 13 Control Room 1.1 E-05 1.7E-07 7.4E-06 1.2E-07 1.0E-05 1.4E-07 5.6E-06 8.1 E-08 15 Access Control 3.8E-08 5.1E-10 NIA NIA 2.7E-08 3.5E-10 NIA NIA Train B Event 16 Monitoring 1.3E-08 1.7E-10 NIA NIA 1.1E-08 1.4E-10 NIA NIA Equipment Room Unit 2 Normal Switchgear Room 17 3.6E-08 4.8E-10 NIA NIA 4.6E-08 6.0E-10 NIA NIA

& Control Rod Drive Room Relay and Cable 18 2.9E-05 6.1 E-07 2.6E-06 1.0E-07 2.8E-05 5.7E-07 2.2E-06 7.8E-08 Spreading Room Unit 1 4.16 KV 20 Safeguards Swgr, 6.1E-06 7.8E-08 1.8E-06 2.5E-08 8.5E-08 1.1E-09 NIA NIA (Bus 16) 480V Safeguards 22 Switchgear (Bus 8.8E-07 1.2E-08 e e 5.2E-06 7.7E-08 e e 121)

Diesel Generator 25 1

2.1E-08 2.8E-10 e e 2.1E-08 2.8E-10 e e Diesel Generator 26 1.9E-08 2.6E-10 NIA NIA 2.1E-08 2.7E-10 NIA NIA 2

28 Transformers 8.9E-08 1.2E-09 NIA NIA 1.0E-07 1.3E-09 NIA NIA Administration 29 Building Elect & 1.4E-11 1.6E-13 e e 1.4E-11 1.6E-13 e e Piping Room #1 Administration 30 Building Elect & 2.0E-08 2.7E-10 e 2.1 E-08 2.8E-10 Piping Room #2 Page 20 of 23

L-Pl-16-005 NSPM Table 3 - Sensitivity Study Results for Alpha <1 Sensitivity by Fire Area

'(, .: .*{4;... ,.

Unit 1 Unit2 ****

"~ .

Fire ' ,; ~ ' Delta Delta Delta Delta Area D~scription CDF LERF CDF LERF CDF LERF CDF .. LERF "A" Train Hot /

Shutdown Panel &

Air *,~

31 2.3E'-06 3.1 E-08 5.5E-07 7.6E-09 4.0E-06 5.5E-08 3.1fa09 4.0E-11 Compressor/Aux 695' Feedwater Room*

"B" Train Hot Shutdown Panel &

Air 32 3.7E-06 5.5E-08 4.0E-09 6.7E-11 1.5E-06 2.0E-08 2.0E-08 2.7E-10 Comp~essor/Aux 695' f.:~edwater :~)'i Room 33 Battery Room 11 1.5E-06 2.0E-08 N/A N/A 8.8E-08 1.2E-09 N/A NIA 34 Battery Room 12 5.2E-07 7.1 E-09 N/A N/A 4.7E-08 6.5E-10 N/A N/A 35 Battery Room 21 1.4E-08 1.9E-10 N/A N/A 6.9E-07 9.2E-09 N/A N/A 36 Battery Room 22 3.9E"07 5.4E-09 N/A N/A 4.6E-08 6.0E-10 N/A N/A Unit 1 480V 37 Normal 3.5E-07 4.6E-09 9.4E-10 1.2E-11 3.4E-07 4.5E-09 8 8 Switchgear Room Unit 2 480V 38 Normal 1.4E-08 1.7E-10 8 8 1.5E-08 2.0E-10 8 8 Switchgear Room Screen house 41 7.1 E-07 9.3E-09 N/A N/A 7.1E-07 9.3E-09 N/A N/A (General Area)

Screen house 41A 3.7E-08 4.8E-10 8 8 3.9E-08 5.0E-10 8 8 (DDCWP Rooms)

Screen house 41B Basement Below 1.2E-06 1.5E-08 1.2E-06 1.5E-08 Grade Cooling Tower 46 Equipment House 6.4E-08 8.5E-10 N/A N/A 6.3E-08 8.3E-10 N/A N/A and Transformers Auxiliary Building 58 Ground Floor 6.3E-06 8.7E-08 1.8E-07 2.3E-09 1.3E-05 1.8E-07 3.0E-10 3.5E-12 Units 1 and 2 Auxiliary Building 59 Mezzanine Units 1 1.9E-05 2.5E-07 3.5E-08 4.3E-10 1.2E-05 1.6E-07 1.7E-08 2.5E-10 and 2 Auxiliary Building 60 Operating Level 2.1E-08 2.8E-10 N/A N/A 7.4E-09 9.6E-11 N/A N/A Unit 1 63 Filter Room 2.0E-09 2.6E-11 N/A N/A 2.2E-09 2.8E-11 N/A N/A Auxiliary Building 64 Low Level Decay 1.3E-09 1.7E-11 N/A N/A 1.2E-09 1.6E-11 N/A N/A Area Unit 1 66 03 Lunch Room O.OE+OO O.OE+OO 8 8 O.OE+OO O.OE+OO 8 8 Containment Unit 1.8E-10 N/A 3.3E-06 71 1.5E-08 N/A 4.1E-08 NIA N/A 2

Auxiliary Building 75 Operating Level 9.0E-09 1.2E-10 N/A N/A 1.1 E-06 1.5E-08 N/A N/A Unit2 Page 21 of 23

L-Pl-16-005 NSPM Table 3 - Sensitivity Study Results for Alpha <1 Sensitivity by Fire Area

r-.. ,*

Unit 1 Unit 2 Fire Delta Delta Delta Delta ,J Area Description *'*'CDF LERF CDF LERF CDF LERF : CDF LERF' h*i Auxiliary Building

~~J *-;'

77 Low Level Decay 1':1E-09 1.4E-11 N/A N/A 1.2E-09 1.5E-11 N/A N/A

Area Unit2 .,, t~ ~

II" Waste Gas 78 5:1E-09 6.5E-11 N/A N/A 5.4E-09 7.0E-11 N/A N/A Compressor Area 480V Safeguard \ ~~

79 Switchgear Room 9:5E-09 1.2E-10 N/A N/A 7.8E-09 1.0E-10 N/A N/A .,g**

. (Bus 112) 480V Safeguard 80 Switchgear Room 5.3E-07 7.4E-09 e 5.8E-07 6.9E-09 e *** .I.~

(Bus 111) 4.16 kV Safeguard 81 Switchgear Room 8.4E-07 1.1 E-08 9.9E-08 1.3E-09 (Bus 15) 480V Safeguard 82 Switchgear Room 1.5E-08 2.0E-10 N/A N/A 7.8E-09 1.0E-10 N/A N/A (Bus 122) 83 Operators Lounge 2.1 E-09 2.6E-11 N/A N/A 2.2E-09 2.8E-11 N/A N/A Counting Room 84 O.OE+OO O.OE+OO N/A N/A O.OE+OO O.OE+OO N/A N/A and Labs Hold-up Tank 85 Area/Demineralize 2.5E-07 3.4E-09 N/A N/A 2.3E-09 2.9E-11 N/A N/A r Area Intake 86 8.7E-07 1.2E-08 N/A N/A 8.7E-07 1.2E-08 N/A N/A Screenhouse Water Chiller 92 6.8E-09 8.9E-11 N/A N/A 7,2E-09 9.5E-11 N/A NIA Room Unit2 Service 94 Building/Computer 1.3E-07 1.7E-09 N/A N/A 1.4E-07 1.8E-09 NIA N/A Room 05 Diesel 97 Generator 1.0E-07 1.3E-09 1.8E-06 2.5E-08 Buildin 06 Diesel 98 Generator 1.1E-07 1.4E-09 N/A N/A 9.1 E-06 1.1 E-07 N/A N/A Buildin Note: Results shown for unscreened and non-zero fire areas only. Epsilon, e. Represents a small positive infinitesimal quantity whose impact is too small to affect the analysis. N/A indicates that no Fire Risk Evaluation was required or no Recovery Actions were credited.

Page 22 of 23

L-Pl-16-005 NSPM Enclosure 1

References:

1. FPRA-Pl-FQ Fire PRA Quantification, Rev 3.

2. FRE-FA-13, NFPA 805 Fire Risk,;Evaluation

. ., - Control Room . .

3. FRE-FA-18, NFPA 805 Fire Risk-Evaluation - Relay and Cable Spreading Room*

4. FRE-FA-20, NFPA 805 Fire Risk*Evaluation - Unit 1 4.16kV Safeguards Switchgear (Bus 16) "*

5. FRE-FA~31, NFPA 805 Fire Risk . Evaluation -A Train Hot Shutdown Panel & Air Compressor/A1..Jxiliary Feedwater Room

6. FRE-FA-58, NFPA 805 Fire Risk Evaluation -Auxiliary Building Ground Floor Unit 1

7. FRE-FA-59, NFPA 805 Fire Risk*Evaluation -Auxiliary Building Mezzanine Levels Units 1 and 2 t:. .,,

Page 23 of 23

L-Pl-16-005 NSPM Enclosure 2 Licensee Identified Changes

! ,'l .1 This Enclosure identifies changes, to the LAR and inc.,14des the following:

Licensee LAR Section Change Identified I Issue ..

I

. ;,,r 1 PRA RAI 15.c An update to PRA RAI 15.c is provided regarding implementation items.

f:, .,

Attachment A, Table 8 Transition A summary of changes table is provided 2 of Fundamental Fire Protection to reflect changes, clarifications, and Program & Design Elements corrections made to the information previously submitted for Attachment A, Table 8-1.

3 Attachment C, Table 8 Fire Area A summary of changes table is provided Transition to reflect changes due to modification reductions, modification additions, and clarifications to the information previously submitted for Attachment C, Table 8-3.

4 Attachment D - Non-Power A summary of changes is provided to Operational Modes Transition reflect changes due to modification reductions to the information previously submitted for Attachment D, NPO.

5 Attachment S - Plant Modifications A summary of changes table is provided and Items for Implementation to reflect changes made to Attachment S. The updated Attachment S is provided in Enclosure 4.

6 PRA RAI 14.a.ii A correction to PRA RAl.a.ii is provided regarding previously submitted information in Attachment W. The updated Attachment W is provided in Enclosure 5.

Page 1 of 74

L-Pl-16-005 NSPM Enclosure 2 Licensee Identified Issue #1: Update to PRA RAI 15.c

/*.f As discLi!;>sed with the NRC Staff during the public meeting teleconference held on March 24,

?016, NSPM is providing an updated response to PRA RAI 15.c reg~rding Implementation Items, as follows: : *"~ **

Updated NSPM Response to PRA RAI 15.c Transition to NFPA 805 can be achieved with the following, updated implementation items as follows:

t.J.,t

Tabl~ S-1:

o Remove Item 1 which conveyed RCP seal replacem'~nt on Unit 2

Table S-2:

o Revise Item 18 to remove reference to N-9000 RCP Seal and return to original LAR wording of low leakage RCP seals. *

Table S-3:

p Pending Item 66 to be revised to remove reference to the Flowserve Topical Report

Update to Table S-3, Item 66:

. The PINGP Fire PRA model shall be reviewed using an NRC approved RCP Seal Model, as well as any exceptions/clarifications included in the NRC approval, to determine if the internal events and Fire PRA require a revision.

The Prairie Island internal events and Fire PRA will be updated, if applicable, with the latest RCP seal model inform*ation. If the updates result in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results. Compensatory measures established prior to the RCP seal replacement shall. remain in place until the calculated risk increase is within RG 1.174 limits.

Note that Item 66 implementation timing Will be reflected in the introduction section of Table S-3 as follows:

o "Item 20 and Item. 66 are associated with modifications described in Table S-2 and will be completed 180 days after the modification implementation timeline" Page 2 of 74

L-Pl-16-005 NSPM Licensee Identified Issue #2: Summary of Changes to Attachment A, Table 8-1 During iraternal reviews, NSPM identified a number of changes to the information,provided in Attachment A, Table B-1 to account for recent Fire Protection [Barrier Walkdowns'and new/revised FPEEs. These changes are described in the following table: '~

Page 3 of 74

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table 8-1 Att. A NFPA 805 Description Summary of Change Justification Page# Section Add to EEEE's:

EEEE/Summary: NFPA 72E Code Compliance Review.

~.1. . !" - - - .: ----

':. . *.__:...:.. z ----

~

Description:

The purpose of this analysis is to Add FPEE 16-001, document the review of NFPA 72E Code compliance review for Fire detectors and alarms located in beam This clarifies that Rev. 0, because the compliance with use of

FPEE explains pockets and the ceiling.

3.8.1 FPEE 16-001 Rev. 0 with A-124 deviations from the Summary: FPEE 16-001. Rev. 0: The Turbine Building this NFPA 805 section is Fire Alarm subject NFPA ionization smoke detection systems were*previously based -on discussions in-*-

standard. evaluated against the requirements of the 1974 Edition the EEEE, as cited in Plant of NFPA 72E in FPP-5, "NFPA 72E Code Compliance Documentation.

Review." This evaluation used the results of the analysis documented in V.SMN.16.006, "PINGP Turbine Building Detection" to show that despite the non-compliances identified in FPP-5, the actuation time of these detection systems was adequate to support the fire risk calculation.

Add to EEEE's:

EEEE/Summary: NFPA 72E Code Compliance This clarifies that Add FPEE 16-001, Review.

compliance with use of Rev. 0, because th~

3.8.2

Description:

The purpose of this analysis is to FPEE 16-001 Rev: 0 with FPEE explains A-131 document the review of NFPA 72E Code compliance this NFPA 805 section is Detection deviations from the review for Fire* detectors and alarms located in beam based on discussions in subject NFPA pockets and the ceiling. the EEEE, as cited in Plarit standard.

Documentation.

Summary: FPEE 16-001. Rev. 0: The Turbine Building ionization smoke detection systems were previously evaluated aQainst the requirements of the 1974 Edition

...... - .. ~ _

Page 4 of 74

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table B-1 Att.A NFPA 805 Description Summary of Change Justification Page# Section of NFPA 72E in FPP-5, "NFPA 72E Code Compliance Review." This evaluation used the results of the .. . .. ---*----

analysis documented in V.SMN.16.006, "PINGP Turbine Building Detection" to show that despite the non-compliances identified in FPP-5, the a:ctuation'time of these detection systems was adequate to support the fire risk calculation.

Add to Compliance Compliance Statement: Add: "Complies with use of Statement: Existing Engineering Equivalency Evaluations" . , -*** .. - ~ ~ .. ~: -- -

"Complies with use EEEE/Summarv: FPEE 16-004 Rev. O; This calculation of Existing reviewed the fire hazards in the yard area to determine Engineering if the external wall boundaries will withstand the FPEE 16-004, Rev. 0:

Equivalency hazards associated with the yard. The walls evaluated This clarifies that Evaluations" are those surrounding the main walls of the turbine compliance with use of because the FPEE building, new service building, auxiliary building, fuel FPEE 16-004, Rev:o,-wifh explains deviations handling/radwaste building, containment buildings, and this NFPA 805 section is 3.11.1 from the subject D5/D6 diesel buildings.

based on discussions in NFPA standard.

A-156

Description:

The purpose of this evaluation is to assess the EEEE, as cited in Plant Building the hazards in the Yard in order to demonstrate that Documentation.

Separation -

external walls are adequate for the hazards to comply with LAR Attachment A - NEI 04-02, Table B-1, NFPA Section 3.11.1.

Summary: This evaluation assessed the adequacy and acceptability of the exterior barriers to outside fire

, hazards in the yard.

Compliance Statement: Add: "Complies with Item for Page 5 of 74

"";._ --.:_' ; . .i.. ... __-

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table 8-1 Att.A NFPA 805 Description Summary of Change Justification Page# Section Implementation" Add to .Compliance EEEE/Summarv: FPEE 16-009, Rev. O; documents the Statement: review and summary of all Barrier FPEE's.

"Complies with item for implementation"

Description:

The purpose of this evaluation is to for. upgrades of determine if the fire area barriers and fire area barrier barriers or penetrations being added to the Prairie Island Fire penetrations. Protection Program meet the requirements of NFPA 805, Section 3.11.2 and Section 3.11.3. FPEE 16-009, Rev. 0:

This clarifies that Summary: This evaluation summarized all barrier compliance with use of Add to EEEEs: FPEE's and determined that all sections of the code FPEE 16-009, Rev. 0, with have been met; deviations justified, or items for FPEE 16-004 and this NFPA 805 section is implementation identified.

FPEE 16-009 ., based on discussions in Item for Implementation: As described in Table S-2, the EEEE, or fo *upgrade:-

Item 43, required modifications have been identified the barriers or and will be completed in accordance with the penetrations.

associated schedule.

See Table S-2 item 43 for

' barrier upgrades.

~-*- . -- . . . . - .... *-* ---

A-157 3.11.2 Add to Compliance Compliance Statement: Add: "Complies with Item for See Table S-2 item 43 for Fire Statement: Implementation" barrier upgrades.

Barriers "Complies with Item for Implementation" Add to EEEE's:

Add summaries of FPEE's because EEEE/Summary: FPEE 12-006, Rev. 1, FA 85, 59, 60, This clarifies that these FPEE's 65, 74, 75 & 78 Boundaries and F5 Appendix K Barriers compliance with use of explain deviations bescriotion: The purpose of this evaluation is to assess FPEE 12-006, Rev. 1, with Page ff of 74

.- * .,. ~,_, * ***- .... d~ .:;._

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table 8-1 Att. A NFPA 805 Description Summary of Change ~U!;_tifi~ation _

Page# Section from the subject the acceptability of the as-built configuration of the Fire this* NFPA 805 section is NFPA standard. Area_ 85 Boundaries in the Units 1 and 2 Auxiliary based on discu$sions in Building. the EEEE, as- cited in Plant

Summary: A fire spreading between the referenced Documentation.

Fire Areas in this FPEE is not likely but if it were to occur it would not prevent either Unit 1 or Unit 2 at Prairie Island Nuclear (3enerating Plant (PINGP) from being safely shutdown. Safe shutdown of both units is

_ thus ensured for a fire in any of the referenced Frre Areas in this FPEE.

This clarifies that EEEE/Summary: EPEE 16-002 Rev. O; Prairie Island compliance with-use of .

Nuclear Generating Plant (PINGP) de~ign details allow FPEE 16-002, Rev. 0, with _

the use of a thru-bolt or threaded tie rod with a steel

.this NFPA 805 section is plate or "washer on the back face *in fire barrier walls based on discussions in

~nd floors in order to facilitate mounting equipment I the EEEE, as cited in Plant components.

This opening between adjacent fire areas Documentation.

is not sealed with a qualified fir~ barrier detail.

Description:

The purpose of this bounding Fire Protection Engineering Evaluation (FPEE) is to asses~;

the acceptability of using the configuration in a 3-hour rated fire barrier.

Summary: The thru-bolt or threaded rod with a steel plate or "washer on the back face configuration meets the requirements of a three hour barrier.

EEEE/Summarv: FPEE 16-003 Rev. O; Reviews the This clarifies* that adequacy of rated fire barriers where. installed , compliance with use of Page 7 of 74

L-Pl-16-005 NSPM Summary of Changes to Attachment A,. Table 8-1 Att. A NFPA 805 - ~ * *- f'-* *t r~ *~

Description Summary of Change Justification Page# Section expansion anchors that were abandoned in place. FPEE 16-003, Rev. 0, with

Description:

The purpose of this bounding Fire this NFPA 805 $ection is Protection Engineering Evaluation (FPEE) is to assess based on discussions in the acceptability of using the configuration in a 3-hour the EEEE, as cited in plant rated fire barrier. Documentation.

Summary: Fire rated barriers with installed expansion anchors abandoned in place do not prevent the fire barrier in which they are installed from providing 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months of protection.

EEEE/Summary: FPEE 16-005 Rev. 1; Reviews the This clarifies that acceptability of the bus duct a~semblies in containing compliance with use of the effects of fire by providing substantial separation of FPEE 16-005, Rev. 1, with the station transformers (FA 28) from the adjacent this NFPA 805 section is Turbine building (FA 8). based on discussions in

Description:

The purpose of this evaluation is to assess the EEEE, as cited in Plant the adequacy of the existing design for the bus duct

Document_ation.__ . _ ___ _

wall assemblies separating FA 8 from FA 28 in containing the effects of fire by providing substantial separation from adjacent fire areas.

Summary: All sections of the code have been met or deviations have been justified.

EEEE/Summary: . FPEE 16-006 Rev. 1; documents the . ... .-.~. : ~*- ... .:.. ,:;_

review of the Turbine building truck aisle and Service This clarifies that Building Stairwell. compliance with use of

Description:

The purpose of this evaluation is to assess FPEE 16-006, Rev. 1, with the adequacy of the existing design for the 2-hour this NFPA 805 section is stairwell and fire door/stairwell in separating FA 8 from based on discussions in FA 94 in containina the effects of fire by providing the EEEE, as cited i_n p1a11t Page 8 of 74

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table B-1 Att.A NFPA 805 Description Summary of Change Justification Page# Section substantial separation from adjacent fire areas. Documentation.

Summary: The existing 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months wall and 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months stairwell boundary and the 4' x 4' pipe chase sep~ra~ing the . *; *~

Turbine Building Truck Aisle (FA8) from the Service.

Building stairwell (FA 94) is considered adequate for the hazard.

EEEE/Summary: FPEE 16-009 Rev. O; documents the review and summary of all Barrier FPEE's.

FPEE 16-009 Rev. 0: This

Description:

The purpose of this evaluation 'is to determine if the fire area barriers arid fire area barrier clarifies that compliance penetrations being added to the Prairie Island Fire with use of FPEE 16-009 Protectioq Program meet the requirements of NFPA Rev 0 with this NFPA 805 805, Section 3.11.2 and Section 3.11.3. section is based on Summary: This evaluation summarized all barrier discussions in the EEEE, FPEE's and determined that all sections of the code or to upgrade the barriers have been met; deviations justified, or items for or penetrations.

implementation identified.

Item for Implementation: As described in Table S-2, Item 43, required modifications have been identified and will be completed in accordance with.the associated schedule.

A-160 3 . 11.3 Add to Compliance Compliance Statement: Add "Previous NRC SER oatec;I See FPEE 11-022, Rev. 2, \:

Fire Barrier Statement: 9/6/1979 establishes the commitment to install Fire below.

Penetration "Complies with Dampers."

s previous approval."

Compliance Statenient: Add: "Complies with Item for?,f - *Se,e.=Table S:'2;itemA:3Jor- -

Add to Compliance

Page 9 of 74

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table 8-1 Att.A NFPA 805 Description Summary of Change Justification Page# Section Statement: Implementation" barrier upgrades.

"Complies with Item for Implementation." .,

Add to EEEE's:

FPEE 11-022 Rev. 2:

Based on the evaluations EEEE/Summarv: FPEE 11-022, Rev. "2; NFPA90A documented in the revision Code Compliance Review.

to this FPEE All identified *

Description:

The purpose of this analysis is to -- c_ode compliance - ;

~

document the review of NFPA 90A "Standard for the deviations have been Installation of Air-Conditioning and Ventilating Systems" determined to 1) meet the for compliance with applicable requirements. intent of the code, 2) meet Summary: FPEE 11-022 was revised and it has been commitments to the NRC, determined that the HVAC systems are in compliance or 3) are adequate for the with or meet the intent of Codes of Record with one hazard as documented in exception. --** --

an Fire Protection Engineering Evaluation, 4)

Upgrades to fire barrier between Fire Area 15 and

59 (unprotected HVAC penetration).

EEEE/Summarv: FPEE 16-009 Rev. O; documents the FPEE 16-009 Rev. 0: If review and summary of all Barrier FPEE's. the fire area barriers and

Description:

The purpose of this evaluation is to fire area penetrations did determine if the fire area barriers and fire area barrier not meet the requirements penetrations being added to the Prairie Island Fire of NFPA 805, Section Protection Program meet the requirements of NFPA 3.11.2 and Section 3.11.3, 805, Section 3.11.2 and Section 3.11.3. an engineering Summary: This evaluation summarized all barrier equivalency evaluation FPEE's and determined that all sections of the code was perf_~!ryi~d or have been met; deviations iustified, or items for

Page 10of74

L-Pl-16-005 NSPM Summary of Changes to Attachment A, Table 8-1 Att. A NFPA 805 Description Summary of Change Justification Page# Section implementation identified. recommendations to Item for Implementation: As described in Table S-2, upgrade the barriers or Item 43, required modifications have been identified penetrations-were made.

and will be completed in accordance with the associated schedule.

See Table S-2 item 43 for barrier upgrades.

EEEE/Summary: FPEE 16-007 Rev. O; Documents the review of the unprotected ceiling penetrations in the *-

barriers credited to meet the NFPA 805 Performance FPEE 16-007 Rev. 0:. This Criteria and the fire effects across unsealed clarifies that compliance penetrations and stairwells. with use of FPEE 16-007

Description:

The purpose of this evaluation is to assess ~ey:; Qwithftt;iis NFPA 805 the effect of unprotected ceiling penetrations and open section is based on stairwells located in the Auxiliary Building in meeting the discussions in the EEEE, NFPA 805 performance criteria. as cited in Plant Documentation.

Summary: Results of the analysis show that the open penetrations and stairwells do not result in any change in the Fire CDF and LERF results. _ . -- .. ***-

. Page 11 of 74

L-Pl-16-005 NSPM Enclosure 2 Licensee Identified Issue #3: Summary of Changes to Attachment C, Table B-3 Durin*g internal reviews, NSPM identified a number of changes to the information provided in Attachment C, Table B-3, to account for the modification redWctions. These changes are described as follows: **

t'.~

(1)

Page 12 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area 4 Fire Areas included N/A Fire Area 4 includes Fire Area(s): Added Fire Area 61. The NSCA model has been evaluated with Fire 39 Radwaste Building Areas 4 and 61 combined and no VFDRs are 40 Maintenance Storage created as a result of merging the fire areas. The Shed/GAF combined fire area meets the deterministic 61 Aux Building Anti "C" Clothing requirements of, section 4.2.3.2, ~_FPA 80_5.

Area 61A Aux Building Hatch Area 62 Spent Fuel Pool Area 67 Resin Disposal Building 93 Drum Storage/Low Level Rad Waste.

4 EEEE N/A EEEE

Title:

AR 1266236-01, Added AR 1266236-01 EEEE

Title:

AR 1266236-01, Class B (1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) fire Class B (1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ) fire doors in doors in Appendix R-required fire barriers was Appendix R-required fire barriers previously identified for Fire Area 61, and has been added to FA 4 as a result of combining the areas.

Summary: This evaluation demonstrates that the Class B doors are compliant to the requirements of the 9/6/1979 SER. The maximum fire exposure duration to a 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes.

Applying a "one-half barrier rating" acceptance criteria, the 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ! : : ....

ratina.

4 Required Fire N/A Required Systems for FA 61 Added Required Systems and This change reflects the combination of Fire Areas 4 Protection Systems include: Features for FA 61 and 61.

and Features Detection - 28, Ionization Suppression- WPS 27, 28, Wet Pipe SLERD Column entries are all "N" for the above systems Page 13 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area 8 Performance Goal N/A Decay Heat Removal (HSB) Revised the Performance Goal The Performance Goal Table is revised due to a Table Hot: Table as follows: strategy change and plant modifications identified in Unit 1 - 12 MDAFW Pump to 11 Table S-2, Items #10 and #24, which allow for SG Decay Heat Removal (HSB) -

CJediting tj'le 12MDAEW Pump _c;is_w_ell g~ removal Unit 2 - 21 MDAFW Pump to 21 changed Unit 1 AFW Pump of a modification identified in Table S-2, Item #11.

SG Process Monitoring - changed A re-evaluation of the NSCA model has determined Process Monitoring Pressurizer Level instruments Pressurizer Level instrument, 1L-433, is not RCS Pressure available. Pressurize Level Red Channel, 1L-426-(LOOP 1 P-709) U1 Loop A RCS Vital Auxiliaries - changed power RP, has been determined to remain available and is Wide Range Press source, CC and CL trains credited in lieu of Pressurizer Level instrument, 1L-(LOOP 2P-709) U2 Loop A RCS 433.

Wide Range Press The modifications identified in Table S-2, Item #10 Pressurizer Level and #24, allow BUS 15 and BUS 16 to remain (LOOP 1L-426-RP) Pressurizer available from the CT source. Therefore, Trains 'A' Level Red Channel and 'B' Component Cooling will not fail due to a loss (LOOP 2L-427) Pressurizer Level of power and either train of Component Cooling can be credited.

Ex-core Neutron Monitoring (Source Range) Note: The strategy change employed to credit the 12 (LOOP 1 N51) U1 Excore MDAFW Pump allowing removal of the modification Detection Train A 1N51 identified in S-2 Table, Item #11, was employed (LOOP 2N51) U2 Excore exclusively for Fire Area 8.

Detection Train A 2N51 RCS Temperature (LOOP 1Tc450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Ranae Level Page 14 of 74

L-Pl-16-005 NSPM Enclosure 2 Summ~rv of Chanaes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Inventory and Pressure Control" Unit 1 - Charging System (Train A)

Unit2 - Charging System (Train A)

Reactivity Control Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject

,,. ' t borated *water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Vital Auxiliaries Unit 1 - Offsite Power (CT11) supplying Electrical Distribution Train A and B Unit 2 - Offsite Power (CT12) supplying Electrical Distribution Train A Unit 1 - CC Train A or B Unit 2 - CC Train A CL Train A and B 8 VFDR VFDR-008-1*01 This Variance From Deterministic Revised Components and VFDR-008-1-01 is revised due to a strategy change Requirements is due to fire _Disposition as follows: and plant modifications identified in Table S-2, Items damage to cable(s) that could #10 and #24, which allow for crediting the 12 cause spurious closure of the Comp'onents and Cables - MDAFW Pump. Crediting the 12 MDAFW Pump steam supply valve (CV-31998) to added: allows for the' removal of modification identified in 11 Turbine Driven Aux Feedwater Table S-2, Item #11 to re-wire and re-route cables Pump or spurious closure of CV- BKR-16-10; Bustie between allowing for the *11 TDAFW Pump to remain 31153, 11 TDAFWP recirculation Buses 16 and 26 available.

and lube oil cooling. 12 MDAFWP is failed due to loss of power to BKR-16-12, Bus 16 Feed to 22A Note: The strateav chanae employed to credit the 12 Page 15 of 74 *~. : .:;*, '. / *:J

' -- ;. -*o:-~ =

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area BUS-16. This could prevent the XFMR MDAFW Pump allowing removal of the modification 11 TDAFWP from providing AFW identified in S-2 Table, Item #11, was employed flow to the Steam Generators to BKR-CT11-6, Bus CT11 Feed to exclusively for Fire Area 8.

support Decay Heat Removal. Bus 15 and Bus 16 The Nuclear Safety Performance Disposition -

Criteria is not met for Decay Heat.

Deleted modification S-2 #11 This represents a variance from the deterministic requirements of Added modifications S-2 #10 and NFPA 805 Section 4.2.3, lack of #24 separation between redundant trains of Decay Heat Removal.

Components and Cables:

11 Turbine Driven AFW Pump Main Steam Supply, CV-31998, (1CA-1109, 1CA-1111, 1CA-1248) 11 Turbine Driven AFW Pump Recirc. Lube Oil CLG Control Valve, CV-31153, (1CA-1111, 1CA-1248)

Bustie Bus 16 and Bus 26, BKR-16-10, (1CB-697, 26401-1, 26401-2,)

Bus 16 Feed to 22A XFMR, BKR-16-12, (16412-1, 2CB-697)

Bus CT11 Feed to Bus 15 and Bus 16, BKR-CT11-6, (1CS-3, 1CS-4)

Compliant Case: ,

The 11 TDAFWP (CV-31998 and CV-31153) should remain unaffected by a fire to provide

~

AFW to 11 Steam Generator.

Recovery Action(s):

Page 16 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment _C, Table B-3 . --** - ..... ... . . -

Fire VFDR Revised Version Summary of Change Justification Revision to Area No recovery actions credited .

Modification identified in Table S-2, Item #24 will re-route cables 1CS-3 and 1CS-4 out of Fire Area 8, Turbine Building so the CT11 transformer source remains available to power BUS 16.

Modification identified in Table S-2, Item #10 will ensure that fire damage in FA 8 does not cause a loss of coordination and lockout of BUS 16..

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.3 with a plant modification credited.

13 VFDR VFDR-013-1-01 This Variance From Deterministic Revised Disposition I Recovery -VFDR-013-1 is revised and is now resolved with Requirements is due to fire Actions as follows: a plant modification as well as recovery actions damage to cable(s) that could credited. Table S-2, Item #41 will rewire the torque cause loss of equipment required Added credit for the modification and limit switches for MV-32006 and MV-3201 Oto to maintain Reactivity Control. identified in Table S-2, ltem#41 address IN 92-18 concerns and ensure the valves This could cause a loss of can be manually operated per LER 50-282-2016-Reactivity Control. Revised resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions and a Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance plant modification. -L-Pl-16-012,. dated February 18, 2016 (ADAMS No.

Criteria is not met for Reactivity

.. ML16049A514).

Control.

This represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between ~

redundant equipment required to perform the Nuclear Safety Page 17 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Performance Criteria for Reactivity Control.

Components and Cables:

Many Compliant Case:

The ability to maintain Reactivity Control should remain available from the Control Room.

Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment B and C) to manually trip Unit 1 Turbine at the Front Standard, and close steam valves MV-32006 and MV-32010.

Modification identified in Table S-2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and - -

limit switches preventing an over-

,f*.- ' - .. ; - '-:. .. *-~?-*

4* .j ;_. .. .-. f-* ..:...

torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 -- -

with recovery actions and a plant modification credited.

Page 18 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 .

Fire VFDR Revised Version Summary of Change Justification Revision to Area 13 VFDR VFDR-013-1-02 This Variance From Deterministic Revised description to include VFDR-013-1-02 is revised due to a re-evaluation of Requirements is due to fire loss of Pressure Control, in the Reactor Water Storage Tank (RWST) drain damage to cable(s) that could addition to loss of Inventory down scenario, and is now resolved by a fire risk cause loss of equipment required Control evaluation as well as recovery actions and a plant to maintain RCS Inventory modification credited. Re-evaluation of the Refueling Control. This could cause a loss Revised Disposition I Recovery Water Storage Tank (RWST) to Containment Sump of Inventory and Pressure Actions-by removing the drain down scenario has determined recovery Control. following Recovery Actions: actions to de-energize MV-32084 and MV-32085 are isolate Letdown, Excess no longer needed per the response to RAI SSA The Nuclear Safety Performance Letdown, Head vents, 07.a, License Amendment Request to Adopt NFPA Criteria is not met for Inventory Pressurizer vents, de-energize 805 Performance-Based Standard for Fire and Pressure Control. Sump B valves, de-energize MV- Protection for Light Water Reactors - Response to 32084, manually operate MV- Request for Additional Information Day This represents a variation from 32084, de-energize MV-32085, Responses, L-Pl-15-052, dated June 19, 2015 the deterministic requirements of and manually operate MV-32085. (ADAMS No. ML15174A139). The revised delta-risk NFPA 805 Section 4.2.3 due to a values were calculated in a sensitivity study and lack of separation between Revised resolution statement to meet the acceptance criteria defined in Regulatory redundant equipment required to include recovery actions, fire risk Guide 1.174.

perform the Nuclear Safety evaluation, and a plant Performance Criteria for Inventory modification. Additionally, a re-evaluation of the Recovery Actions and Pressure Control. has determined it is not re*quired to: isolate Letdown, Excess Letdown, Head vents, Pressurizer vents, Components and Cables: and de-energize Sump B valves. The revised delta-risk values were calculated in a fire risk evaluation Many and meet the acceptance criteria defined in Regulatory Guide 1.174.

Compliant Case:

The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.

Recovery Action(s):

Evaluate Recovery Actions performed in procedure F5 *'***

. , i: . i :

Appendix B [Reference 15]

(Attachments A, B, C, E, and F) to*

de-energize Pressurizer Heaters, de-enerQize the Containment Page 19 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Spray Pumps, locally trip the Reactor Coolant Pumps, and actions to re-align 12 Charging Pump suction to the RWST and restart a charging pump, Fire Risk Evaluation has determined it is not required to credit recovery actions to isolate Letdown, Excess Letdown, Head

-i.- *. - . ,,.. .... .. - - ' . .... ..... . .. .... * .... f ~

vents, the RWST to the RHR system, Pressurizer vents, and de-energize Sump B valves.

Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited.

13 VFDR VFDR-013-1-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-013-1-03 is revised and is now resolved with Requirements is due* to fire Actions as follows: a plant modification, fire risk evaluation, and damage to cable(s) that could recovery actions credited. Table S-2, Item #41 will cause loss of equipment required Add the modification identified in rewire the torque and limit switches for MV-32238 to to maintain Decay Heat Removal. Table S-2, Item #41 address IN 92-18 concerns and ensure the valve This could cause a loss of Decay can be manually operated per LER 50-282-2016-Heat Removal. Revise resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions, fire risk Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance evaluation, and a plant L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Decay Heat modification credited. ML16049A514).

. *, . . . *~r*~* -** *** **-*~, .... ,, "l ~

Page 20 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Chanaes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Removal.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between

- -- . - - redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.

Components and Cables:

Many Compliant Case:

"*J'". ~ ~* - - - ' ., - ' I.,

The ability to maintain Decay Heat Removal should remain available from the Control Room.

Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment I) to manually start the 11 TDAFWP and align to 11 SG.

Modification identified in Table S-2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety marQin and defense-Page 21 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited. \

13 VFDR VFDR-013-2-01 This Variance From Deterministic Revised Disposition I Recovery VFDR-013-2-01 is revised and is now resolved with Requirements is due to fire Actions as follows: a plant modification as well as recovery actions damage to cable(s) that could credited. Table S-2, Item #41 will rewire the torque cause loss of equipment required Added the modification identified and limit switches for MV-32021 and MV-32022 to to maintain Reactivity Control. in Table S-2, Item #41 address IN 92-18 concerns and ensure the valves This could cause a loss of can be manually operated per LER 50-282-2016-Reactivity Control. Revised resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions and a Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance plant modification. L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Reactivity ML16049A514).

Control.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to ... .- -. .. . ,

perform the Nuclear Safety Performance Criteria for Reactivity Control.

Components and Cables:

Many Compliant Case:

The ability to maintain Reactivity Control should remain available from the Control Room.

Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Page 22 of 74

L-Pl-16-005 NSPM Enclosure 2

,,1,*. !I *-'*' . . . : ..... ,. ,* ..... ,., .c- ..,., .-. :i. **-* ; c '.(**

Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Appendix B (Attachment B and C) to manually trip Unit 2 Turbine at the Front Standard, and close . - *- . --- .- -- .. - . --

steam valves MV-32021 and MV-32022.

Modification identified in Table S-2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated .

and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.

13 VFDR VFDR-013-2-02 This Variance From Deterministic Revised description to include VFDR-013-2-02 is revised due to a re-evaluation of Requirements is due to fire loss of Pressure Control, in the Reactor Water Storage Tank (RWST) drain damage to cable(s) that could addition to loss of Inventory down scenario, and is now resolved by a fire risk cause loss of equipment required Control. evaluation as well as recovery actions and a plant to maintain RCS Inventory modification credited. Re-evaluation of the Refueling Control. This could cause a loss Revised Disposition I Recovery Water Storage Tank (RWST) to Containment Sump of Inventory and Pressure Actions by removing the drain down-scenario has determined* recovery Control. following Recovery Actions: actions to de-energize MV-32178 and MV-32179 are isolate Letdown, Excess no longer needed per the response to RAI SSA The Nuclear Safety Performance Letdown, Head vents, 07.a, License Amendment Request to Adopt NFPA Criteria is not met for Inventory Pressurizer vents, de-energize 805 Performance-Based Standard for Fire and Pressure Control. Sump B valves, de-energize MV- Protection for Light Water Reactors - Response to 32187, manually operate MV- Request for Additional Information Day This represents a variation from 32187, de-energize MV-32188, Responses, L-Pl-15-052, dated June 19, 2015 the deterministic requirements of and manually operate MV-32188. (ADAMS No. ML15174A139). The revised delta-risk NFPA 805 Section 4.2.3 due to a values were calculated in a sensitivity study, and lack of separation between Revised resolution statement to meet the acceptance criteria defined in Regulatory redundant equipment required to include recovery actions, fire risk Guide 1.174.

Page 23 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area perform the Nuclear Safety evaluation, and a plant Performance Criteria for Inventory modification. Additionally, a re-evaluation of the. Recovery Actions and Pressure Control. has determined it is not required to: isolate Letdown, Excess Letdown, Head vents, Pressurizer vents, Components and Cables: and de-energize Sump B valves. The revised delta-risk values were calculated in a fire risk evaluation Many and meet the acceptance criteria defined in Regulatory Guide 1.174.

Compliant Case:

The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.

Recovery Action(s):

Evaluate Recovery Actions performed in procedure F5 App_endix B [Reference 15]

(Attachments A, B, D, and G) to de-energize Pressurizer Heaters, de-energize the Containment Spray Pumps, locally trip the Reactor Coolant Pumps, and actions to re-align 22 Charging Pump suction to the RWST and restart a charging pump.

Fire Risk Evaluation has determined it is not required to credit recovery actions to isolate Letdown, Excess Letdown, Head vents, the RWST to the RHR system, Pressurizer vents, and de-energize the Sump B valves. -~>- .1 * - ,!. * "* ,. .. .-. . . . * .,_-. *i * .-. *! **- *= ;

Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charaina oumo can be Page 24 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area restarted after suction from the RWST is restored to inject borated water into the RCS.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance

.. ;._ _: - -~ ~. - ~ ':. -~'- _;

criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk

evaluation, and a plant modification credited.

13 VFDR VFDR-013-2-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-013-2-03 is revised and is now resolved with Requirements is due to fire Actions to: a* piant modification, fire risk evaluation, and damage to cable(s) that could recovery actions credited. Table S-2, Item #41 will cause loss of equipment required Add the modification identified in rewire the torque and limit switches for MV-32246 to to maintain Decay Heat Removal. Table S-2, Item #41 address IN 92-18 concerns and ensure the valve This could cause a loss of Decay can be manually operated per LER 50-282-2016-Heat Removal. Revise resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions and a Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance plant modification credited. L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Decay Heat ML16049A514).

Removal.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a Lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.

Components and Cables:

Many Compliant Case:

_. \J~. ~: _, ': .:... \j Page 25 of 74

L-:-P 1-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area The ability to maintain Decay Heat Removal should remain available from the Control Room.

Recovery Action(s):

Evaluate Recovery Actions performed in procedure F5 Appendix B (Attachment I) to manually start the 22 TDAFWP and align to 21 Steam Generator.

Modification identified in Table S-2, Item #41 will re-wire MOV -*' .. . .~ . *-** '" . - r" I' torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited.

13 VFDR VFDR-013-2-07 This Variance From Deterministic Revised VFDR description to: VFDR-013-2-07 is revised and is now resolved by Requirements is due to fire the modification identified in Table S-2, Item #18.

damage to cable(s) that could Add 22 Component Cooling cause loss of the 21 and 22 Water Pump Additionally, the VFDR description was revised to Component Cooling Water indicate a loss of both the 21 and 22 Component Pumps. Revised Disposition I Recovery Cooling Water Pumps is necessary for the VFDR Actions to: scenario to occur.

The Nuclear Safety Performance Criteria is not met for Vital Delete the modification in S-1, Auxiliaries. Item #1 Page 26 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area This represents a variance from Add the modification identified in the deterministic requirements of Table S-2, Item #18 NFPA 805, Section 4.2.3, due to 1.ack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliaries.

Components and Cables:

None Compliant Case:

Cooling to the RCP seals should remain unaffected by a fire in this area.

Recovery Action(s):

No Recovery Actions credited.

Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump (RCP) seals that are not subject to excessive leakage upon loss of all seal cooling.

This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

18 VFDR VFDR-018-1-01 This Variance From Deterministic Revised Disposition I Recovery VFDR-018-1-01 is revised and is now resolved with Requirements is due to fire Actions as follows: a plant modification as well as recovery actions damage to cable(s) that could credited. Table S-2, Item #41 will rewire the torque cause loss of eauioment reauired Added credit for the modification and limit switches for MV-32006 and MV-3201 Oto Page 27 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area to maintain Reactivity Control. identified in Table S-2, Item #41 address IN 92-18 concerns and ensure the valves This could cause a loss of can be manually operated per LER 50-282-2016-Reactivity Control. Revised resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions and a Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance plant modification. L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Reactivity ML16049A514).

Control.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3, due to a lack of separation between redundant equipment to perform the Nuclear Safety Performance Criteria for Reactivity Control.

Components and Cables:

Many Compliant Case:

The ability to maintain Reactivity Control should remain available from the Control Room.

Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment B and C) to manually trip Unit 1 Turbine at the Front Standard and close steam valves MV-32006 and MV-32010.

Modification identified in Table S-2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, Page 28 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area from bypassing the torque and - -* '*

limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.

18 VFDR VFDR-018-1-02 This Variance From Deterministic Revised description to include VFDR-018-1-02 is revised due to a re-evaluation of Requirements is due to fire loss of Pressure Control, in the Reactor Water Storage Tank (RWST) drain damage to cable(s) that could addition to loss of Inventory down scenario, and is now resolved by a fire risk cause loss of equipment required Control evaluation as well as recovery actions and a plant to maintain RCS Inventory modification credited. Re-evaluation of the Refueling Control. This could cause a loss Revised Disposition I Recovery Water Storage Tank (RWST) to Containment Sump of Inventory and Pressure Actions by removing the drain down scenario has determined recovery Control. following Recovery Actions: actions to de-energize MV-32084 and MV-32085 are isolate Letdown, Excess no longer needed per the response to RAI SSA The Nuclear Safety Performance Letdown, Head vents, 07.a, License Amendment Request to Adopt NFPA Criteria is not met for Inventory Pressurizer vents, de-energize 805 Performance-Based Standard for Fire and Pressure Control. Sump B valves, de-energize MV- Protection for Light Water Reactors - Response to 32084, manually operate MV- Request for Additional Information Day This represents a variation from 32084, de-energize MV-32085, Responses, L-Pl-15-052, dated June 19, 2015 the deterministic requirements of and manually operate MV-32085. (ADAMS No. ML15174A139). The revised delta-risk NFPA 805 Section 4.2.3 due to a values were calculated in a sensitivity study and lack of separation between Revised modification identified in meet the acceptance criteria defined in Regulatory redundant equipment required to Table S-2, Item #27 to exclude Guide 1.174.

perform the Nuclear Safety isolation of Excess Letdown, Performance Criteria for Inventory Head vents, and Pressurizer Additionally, a re-evaluation of the Recovery Actions and Pressure Control. vents. has determined it is not required to: isolate Letdown, Excess Letdown, Head vents, Pressurizer vents, Components and Cables: Revised resolution statement to and de-energize Sump B valves. The revised delta-include recovery actions, fire risk risk values were calculated in a fire risk evaluation Many evaluation, and a plant and meet the acceptance criteria defined in modification. Regulatory Guide 1.174.

Compliant Case:

Table S-2, Item #27 is re-scoped due to a re-Page 29 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area The ability to maintain RCS evaluation of Recovery Actions and now excludes Inventory and Pressure Control actions to: isolate Excess letdown, Head vents, and should remain available from the Pressurizer vents. The revised delta-risk values Control Room. were calculated in a fire risk evaluation and meet the acceptance criteria defined in Regulatory Guide Recovery Action(s): 1.174.

Evaluate Recovery Actions performed in procedure F5 Appendix B [Reference 15]

(Attachments A, B, E, arid F) to de-energize Pressurizer Heaters, de-energize the Containment Spray Pumps, locally trip the Reactor Coolant Pumps, and actions to re-align 12 Charging Pump suction to the RWST and restart a charging pump.

Fire Risk Evaluation has determined it is not required to credit recovery actions to isolate Letdown, Excess Letdown, Head vents, the RWST to the RHR system, Pressurizer vents, and de-energize the Sump B valves.

Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.

Modification identified in Table S-2, Item #27 will provide an additional means to isolate Pressurizer PORVs and Pressurizer Heaters prior to control room evacuation.

Page 30 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change* Justification Revision to Area This VFDR has been.evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4

with recovery actions, fire risk evaluation, and a plant * *'

modification credited.

18 VFD~ VFDR-018-1-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-018-1-03 is revised and is now resolved with Requir:.ements is due to fire Actions as follows: a plant modification, fire risk evaluation, and damage to cable(s) that coul~ recovery adions credited. Table S-2, Item #41 will qrnse loss of equipment required Add the modification identified in rewire the torque.and limit switches for. MV-32238 to to maintain Decay He~t Removal. Table ~-2, Item #41 address IN 92-18 concerns and ensure the valve This could cause a loss of Decay can be manually operated per LER 50-282-2016-Heat Removal. Revise resolution statement to 001-00,.Unanalyzed Condition Due to Non-include recovery actions, fire risk . Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance evaluation, and a plant L-Pl-16-012, dated February .18, 2016 (ADAMS No.

Criteria is not met for Decay Heat modification credited. ML16049A514).

Removal.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack ofseparation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.

Components and Cables:

Many Compliant Case:

J The ability to maintain Decay Heat Removal should remain available from the Control Room. '

Page 31of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment I) to manually start the 11 TDAFWP and align to 11 SG.

Modification identified in Table S-2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense- J -7 * .;; ..: : ..: :. .,,. r. '" - . ;'. ; .. r. *: ;. ~ .:.

. . -!i' in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited.

18 VFDR VFDR-018-2-01 This Variance From Deterministic Revised Disposition I Recovery VFDR-018-2-01 is revised and is now resolved with Requirements is due to fire Actions as follows: a plant modification as well as recovery actions damage to cable(s) that could credited. Table S-2, Item #41 will rewire the torque cause loss of equipment required Added credit for the modification and limit switches for MV-32021 and MV-32022 to to maintain Reactivity Control. identified in Table S-2, ltem#41 address IN 92-18 concerns and ensure the valves This could cause a loss of can be manually operated per LER 50-282-2016-Reactivity Control. Revised resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions and a Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance plant modification. L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Reactivity ML16049A514). .

Control.

This represents a variation from the deterministic requirements of NFPA805 Section 4.2.3 due to a Page 32 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.

Components and Cables:

Many Compliant Case:

The ability to maintain Reactivity Control should remain available from the Control Room.

Recovery Action(s):

Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment B and C) to manually trip Unit 2 Turbine at the Front Standard, and close steam valves MV-32021 and MV-32022.

Modification identified in Table S- *- :.. .~. ... *I I*' , ... .:~

2, Item #41 will re-wire MOV torque and limit switches to prevent fire induced hot shorts, for cables routed in FA 1'3 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-

. in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recoverv actions and a plant Page 33 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area i: : ; .. *, :'j modification credited.

18 VFDR VFDR-018-2-02 This Variance From Deterministic Revised description to include VFDR-018-2-02 is revised due to a re-evaluation of Requirements is due to fire loss of Pressure Control, in the Reactor Water Storage Tank (RWST) drain damage to cable(s) that could addition to loss of Inventory down scenario, and is now resolved by a fire risk cause loss of equipment required Control. evaluation as well as recovery actions and a plant to maintain RCS Inventory modification credited. Re-evaluation of the Refueling Control. This could cause a loss Revised Disposition I Recovery Water Storage Tank (RWST) to Containment Sump of Inventory and Pressure Actions by removing the drain down scenario has determined recovery Control. following Recovery Actions: actions to de-energize MV-32178 and MV-32179 are isolate Letdown, Excess no longer needed per the response to RAI SSA The Nuclear Safety Performance Letdown, Head vents, 07.a, License Amendment Request to Adopt NFPA Criteria is not met for Inventory Pressurizer vents, de-energize 805 Performance-Based Standard for Fire and Pressure Control. Sump B valves, de-energize MV- Protection for Light Water Reactors - Response to 32187, manually operate MV- Request for Additional Information Day This represents a variation from 32187, de-energize MV-32188, Responses, L-Pl-15-052, dated June 19, 2015 the deterministic requirements of and manually operate MV-32188. (ADAMS No. ML15174A139). The revised delta-risk NFPA 805 Section 4.2.3 due to a values were calculated in a sensitivity study, meet lack of separation between Revised modification identified in the acceptance criteria defined in Regulatory Guide redundant equipment required to Table S-2, Item #27 to exclude 1.174.

perform the Nuclear Safety isolation of Excess Letdown, Performance Criteria for Inventory Head vents, and Pressurizer Additionally, a re-evaluation of the Recovery Actions Control. vents. has determined it is not required to: isolate Letdown, Excess Letdown, Head vents, Pressurizer vents, Components and Cables: Revised resolution statement to and de-energize Sump B valves. The revised delta-include recovery actions, fire risk risk values were calculated in a fire risk evaluation Many evaluation, and a plant and meet the acceptance criteria defined in modification. R_egulatory Guide 1.174.

Compliant Case:

Table S-2, Item #27 is re-scoped due to a re-The ability to maintain RCS evaluation of Recovery Actions and now excludes Inventory and Pressure Control actions to: isolate Excess letdown, Head vents, and should remain available from the Pressurizer vents. The revised delta-risk values Control Room. were calculated in a fire risk evaluation and meet the a-cceptance criteria defined in RegulatorY Guide Recovery Action(s): 1.174.

Evaluate Recovery Actions performed in procedure F5 Appendix B [Reference 15]

(Attachments A, B, D, and G) to Page 34 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area de-energize Pressurizer Heaters, de-energize the Containment Spray Pumps, locally trip the Reactor Coolant Pumps, and actions to re-align 22 Charging Pump suction to the RWST and -*.

._: - ~ -- .

-- I

!**- (- ~

.. ... 1---1*

restart a charging pump.

'

f! ::

Fire Risk Evaluation has determined it is not required to credit recovery actions to isolate Letdown, Excess Letdown, Head vents, the RWST to the RHR system, Pressurizer vents, and ... . .. .. .

de-energize the Sump B valves.

Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.

Modification identified in Table S-2, Item #27 will provide an additional means to isolate Pressurizer PORVs and Pressurizer Heaters prior to control room evacuation.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited.

18 VFDR VFDR-018-2-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-018-2~03 is revised and is now re5olved with Page 35 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Chan"es to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Requirements is due to fire Actions as follows: a plant modification, fire risk evaluation, and damage to cable(s) that could recovery actions credited. Table S-2, Item #41 will cause loss of equipment required Add the modification identified in rewire the torque and limit switches for MV-32246 to to maintain Decay Heat Removal. Table S-2, Item #41 address IN 92-18 concerns and ensure the valve This could cause a loss of Decay can be manually operated per LER 50-282-2016-Heat Removal. Revise resolution statement to 001-00, Unanalyzed Condition Due to Non-include recovery actions, fire risk Compliant Fire Protection Manual Operator Actions, The Nuclear Safety Performance evaluation, and a plant L-Pl-16-012, dated February 18, 2016 (ADAMS No.

Criteria is not met for Decay Heat modification credited. ML16049A514).

Removal.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a

.. ' 'i Lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.

Components and Cables:

Many Compliant Case:

The ability to maintain Decay Heat Removal should remain available from the Control Room.

Recovery Action(s):

Evaluate Recovery Actions performed in procedure F5 Appendix B (Attachment I) to manually start the 22 TDAFWP and align to 21 Steam Generator.

Modification identified in Table S-2, Item #41 will re-wire MOV toraue and limit switches to Page 36 of 74 f, , {*~* ; r j .;

L-Pl-16-005 NSPM Enclosure 2 Summary of Chanaes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area prevent fire induced hot shorts, for cables routed in FA 13 and 18, from bypassing the torque and limit switches preventing an over-torque condition.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions, fire risk evaluation, and a plant modification credited.

18 VFDR VFDR-018-2-07 This Variance From Deterministic Revised VFDR description to: VFDR-018-2-07 is revised and is now resolved by Requirements is due to fire the modification identified in Table S-2, Item #18.

damage to cable(s) that could Add 22 Component Cooling cause loss of the 21 and 22 Water Pump Additionally, the VFDR description was revised to Component Cooling Water indicate a loss of both the 21 and 22 Component Pumps. Revised Disposition I Recovery Cooling Water Pumps is necessary for the VFDR Actions to: scenario to occur.

The Nuclear Safety Performance Criteria is not met for Vital Delete the modification in S-1, Auxiliaries. Item #1 This represents a variance from Add the modification identified in the deterministic requirements of Table S-2, Item #18 NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliaries.

Components and Cables:

None Compliant Case:

Page 37 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Chanaes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Cooling to the RCP seals should remain unaffected by a fire in this area.

Recovery Action:

No Recovery Actions credited.

Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump (RCP) ,

seals that are not subject to excessive leakage upon loss of all seal cooling.

This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

31 VFDR VFDR-031-1-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-031-1-03 is revised and is now resolved with Requirements is due to fire Actions to: a fire risk evaluation credited. The revised delta-risk damage to cable(s) that could values are calculated in a fire risk evaluation and cause a loss of DC control power Delete the modification in S-2, meet the acceptance criteria defined in ~egulatory to BUS 16 and damage to power Item #10 GY!d~ 1-F~:- - ,_ -**- "'*- . **~ .. -..-y.

cables that could over-heat and cause secondary fires. If the fire Add credit for a fire risk damaged DC control power, and evaluation to resolve potential then damaged 4kV power cables, loss of over-current trip capability the excessive current could cause for BKR-16-3 load power cables to over-heat and develop secondary fires in Revised resolution statement to other fire areas which violates remove a plant modification and common enclosure requirements. include a fire risk evaluation credited.

The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.

This represents a VFDR of NFPA Page 38 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change -- -* ~ - - :. ... .Justification- -~-

Revision to Area 805 Section 4.2.3, due to lack of separation between redul')dant trains of Vital Auxiliaries.

Components and Cables:

12 MDAFW Pump Breaker, BKR-16-3 ( 16403-1 , 16403-C, 1CB-30, 1CB-920)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Recovery Action(s): '

No recovery actions credited.

The impact of BKR-16-3 losing over-current trip capability has been modeled in the Fire PRA and the risk is acceptable.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 .. .< . - k' with a fire risk evaluation credited. ..... --. -- - . ~- - .... - - ~~" -* - .-... ~ ~* .... ,. *. ... .. .,....

31 VFDR VFDR-031-2-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-031-2-03 is revised and is now resolved with

.Requirements is due to fire Actions to:. a fire risk evaluation credited. The revised delta-risk damage to cable(s) that could values are calculated in a fire risk evaluation and cause a loss of DC control power Delete the modification in S-2,

meet the acceptance criteria defined in Regulatory to Bus .24.and damage to power Item #10 Guide 1.174.

cables that could over-heat and .. . ..

cause secondary fires. If the fire Add credit for a fire risk Page 39 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area damaged DC control power, and evaluation to resolve potential then damaged 4kV power cables, loss of over-current trip capability the excessive current could cause for BKR-24-6 load power cables to over-heat and develop secondary fires in Revised resolution statement to ..

- . *- \ * .i.** -. "

other fire areas which violates remove a plant modification and common enclosure requirements. include a fire risk evaluation credited.

The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.

This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.

Components and Cables:

Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24406-3, 24403-F, 24404-F, 2C-2552, 2C-866, 2DC-5)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and -

causing secondary fires to meet common enclosure requirements.

Recovery Action(s): -

No recovery actions credited.

The impact of BKR-24-6 losing over-current trip capability and .. *- - - . .:: -*~.:;-~ - _;,y_ ~

causing secondary fire damage has been modeled in the Fire Page 40 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area PRA and the risk is acceptable.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation credited.

32 VFDR VFDR-032-1-02 This Variance From Deterministic Revised Disposition I Recovery VFDR-032-1-02 is revised to credit the modification Requirements is due to fire Actions to: identified in Table S-2, Item #35 to re-route cable damage to cable(s) that could 1C-332 out of Fire Area *32 as well as the cause loss of power to BUS-15 Add the modification in S-2, Item modification identified in Table S-2, Item #6. A re-and BUS-16 from the offsite #35 evaluation of the NSCA model determined power sources 1 R, CT11 and D1 modifications identified in Table S-2, Items #6 and to BUS-15 and D2 to BUS-16. #35, need to be credited for the 1RY source to Loss of power to BUS-15 and remain available to supply BUS-16.

BUS-16 could cause a station black-out on *Unit 1 and would not meet Vital Auxiliaries Performance Criteria of NFPA 805.

The Nuclear Safety Performance Criteria is not met for Vital AC Power.

This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of safeguard power.

Components and Cables:

Bus 16 4.16KV Switchgear, BUS 16 (1DCB-1)

Bus 16 Source from 1R XFMR, BKR 16-2 (1 C-332, 1C-333)

Bus 16 Source from Bus CT 11, BKR 16-8 (15407-1, 15407-2, 16408-1)

Page 41 of 74

L-PI-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area D2 Diesel Generator, 034-021 (1 DCB-2, 1DCB-95)

Bus 15 4.16KV Switchgear, BUS 15 (15406-B, 1DCA-1)

Bus 15 Source from D1 Diesel Generator, BKR 15-2 (15402-G, 15402-K, 15402-1)

Bus 15 Source from 1R XFMR, BKR 15-3 (1C-332, 1C-333, 15403-B)

Bus 15 Source from Bus CT 11, BKR 15-7 (15407-1, 15407-2, 15407-A, 16408-1)

Compliant Case:

BUS-16 should remain energized from 1RY (BKR-16-2) or D2 (BKR-16-9) to provide vital AC

~

power to support safe shutdown.

Recovery Action(s):

No recovery actions credited.

Modification identified in Table S-2, Item #6 and #35 will respectively re-route cables 1C-333 and 1C-332 out of Fire Area 32 so that the 1 RY source will remain available to BUS-16.

Modification identified in Table S-2, Item #1 O will protect cable 1DCB-1 to ensure BUS-16 control power remains available.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 Page 42 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area with plant modifications credited.

32 VFDR VFDR-032-1-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-032-1-03 is revised and is now resolved with Requirements is due to fire Actions to: a fire risk evaluation as well as a plant modification damage to cable(s) that could credited. The revised delta-risk values are cause loss of DC control power to Add credit for a fire risk calculated in a fire risk evaluation and meet the BUS-13, 14, 15, and 16, which evaluation to resolve potential acceptance criteria defined in Regulatory Guide would preclude operation of the loss of over-current trip capability 1.174.

over-current trip relay protection for BKR-13-3, BKR-14-3, and on the following 4 kV breakers: BKR-16-3 BKR-13-3, BKR-14-3, BKR-15-1, BKR-15-4, BKR-15-5, BKR-15-9, Revised resolution statement to and BKR-16-3. If the fire include a plant modification and damaged DC control power, and a fire risk evaluation credited.

then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.

The Nuclear Safety Performance Criteria is not met for Vital AC Power.

This represents a VFDR of NFPA ,, -. . ~* ....._

805 Section 4.2.3, due to lack of separation between redundant trains of Vital and Non-Vital AC power.

Components and Cables:

Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR-13-3 (13403-3, 13408-B, 1C-1293, 1C-1295, 1C-4637, 1DC-3) 12 Heater Drain Pump Breaker, BKR-14-3 (14403-1, 14403-D, 1C-1294, 1C-4637, 1DC-4) 11 SI Pump Breaker, BKR-15-1 (15401-1, 15401-B, 15401-C, Page 43 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 -

Fire VFDR Revised Version Summary of Change Justification Revision to Area 15401-E, 15406-B, 1DCA-1) 11 RHR Pump Breaker, BKR 4 (15404-1, 15404-C, 15404-E, 15404-B, 15406-B, 1 DCA-1) 11 CC Pump Breaker, BKR-15-5 (15405-1 , 15405-A, 15405-G, 15406-B, 1DCA-1) 11 CS Pump Breaker, BKR-15-9 (15406-B, 15409-1, 15409-B, 15409-C, 1DCA-1) 12 MDAFW Pump Breaker, BKR-16-3 (16403-1, 16403-C, 1DCB-1)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

The impact of BKR-13-3, BKR 3, and BKR-16-3 losing over-current trip capability and causing_

secondary fire damage has been modeled in the Fire PRA and the risk is acceptable. .. . -. . -- -

Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for BKR-15-1, BKR-15-4, BKR-15-5, and BKR-15-9.

This VFDR has been evaluated and it was determined that the risk, safetv marain and defense-Page 44 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation and plant modification credited. --

32 VFDR VFDR-032-2-03 This Variance From Deterministic Revised Description to indicate A re-evaluation of the NSCA model has determined Requirements is due to fire control power to BKR-25-10 is control power to BUS-25 remains available; damage to cable(s) that could lost and not control power to however, control power to breaker cubicle, BKR cause a loss of DC control power BUS-25. 10, is lost.

to BKR-25-10 which would preclude operation of the over- '

current trip relay protection on 4 kV breaker BKR-25-10. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat

-and develop secondary fires in other fire areas which violates common enclosure requirements.

The Nuclear Safety Performance Criteria is not met for Vital Auxilia~ies.

This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital and Non-Vital AC power.

Components and Cables:

21 MDAFW Pump Breaker, BKR-25-10 (25410-1, 25410-E, 2CA-525, 2CA-778)

Compliant Case:

Cable over-current protection . -- - -

should be maintained to protect cables from over-heating and causino secondarv fires to meet Page 45 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

Modification identified in Table S-2, Item #10 will ensure protection of the over-current trip function of 4kV breakers and preclude secondary ignition of cables in other fire areas.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

37 VFDR VFDR-037-1-01 This Variance from Deterministic Revised Disposition I Recovery VFDR-037-1-01 is revised and is now resolved with Requirements (VFDR) is due to Actions to: a fire risk evaluation credited. The revised delta-risk fire damage to cable(s) that could values are calculated in a fire risk evaluation and cause a loss. of DC control power Delete the modification in S-2, meet the acceptance criteria defined in Regulatory to BUS-13 which would preclude Item #10 Guide 1.174.

operation of the over-current trip relay protection on the 4KkV Add credit for a fire risk breakers. If the fire damaged DC evaluation to resolve potential control power, and then damaged loss of over-current trip capability 4kV power cables, the excessive for BKR-13-3, BKR-13-7, and current could cause load power BKR-13-8 cables to over-heat and develop secondary fires in other fire areas Revised resolution statement to which violates common enclosure remove a plant modification and requirements. include a fire risk evaluation The Nuclear Safety Performance credited.

Criteria is not met for Vital Auxiliaries.

This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of Page 46 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area separation between redundant trains of Vital Auxiliaries.

Components and Cables:

Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR-13-3 (13403-2, 13403-3, 13403-4, 13404-B, 13405-B, 13408-B, 1DC-3)

11 Condensate Pump Breaker, BKR-13~7 (13407-1, 13404-B, 13405-B, 13408-B, 1DC-3) 1.1 Cooling Water Pump Breaker, .

BKR-13-8 (13408-1, 13404-B, 13405-8, 13408-B, 1DC-3)

Compliant Gase:

Cable over-current protection should be maintained to protect cables from over-heating and. --

causing secondary fires to meet common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

The impact of these breakers losing over-current trip capability and causing secondary fire damage has been modeled in the Fire PRA and the risk is acceptable.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense- -

in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 Page 47 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area with a fire risk evaluation credited.

38 VFDR VFDR-038-2-01 This Variance from Deterministic Revised Disposition I Recovery VFDR-038-2-01 is revised and is now resolved with Requirements (VFDR) is due to Actions to: a fire risk evaluation credited. The revised delta-risk fire damage to cable(s) that could values are calculated in a fire risk evaluation and cause a loss of DC control power Delete the modification in S-2, meet the acceptance criteria defined in Regulatory to BUS-23 and BUS-24 which Item #10 Guide 1.174.

would preclude operation of the over-current trip relay protection Add credit for a fire risk on the 4kV breakers. If the fire evaluation to resolve potential damaged DC control power, and loss of over-current trip capability then damaged 4kV power cables, for BKR-23-1, BKR-23-4, BKR-the excessive current could cause 23-5, BKR-24-2, BKR-24-5, and load power cables to over-heat BKR-24-6 and develop secondary fires in other fire areas which violates Revised resolution statement to common enclosure requirements. remove a plant modification and include a fire risk evaluation The Nuclear Safety Performance credited.

Criteria is not met for Vital Auxiliaries.

This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.

Components and Cables:

121 Screenwash Pump Breaker, BKR-23-1 (23401-1, 23401-A, 23401-B,23405-F,23406-C, 23407-B, 2DC-4) 21 Cooling Water Pump Breaker, BKR-23-4 (23404-1, 23401-A, 23401-B,23405-F,23406-C, 23407-B, 2DC-4) 21 Condensate Pump Breaker, BKR-23-5 (23405-1, 23401-A, 23401-B,23405-F,23406-C, 23407-B, 2DC-4) 22 Gire. Water Pumo Breaker, Page 48 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Changes to Attachment C, Table B-3 Fire VFD.R Revised Version. Summary of Change Justification

Revision to Area BKR-24-2 (24402-1, 24403-F, 24404-F, 24405-E, 2DC-5) 22 heater Drain Pump breaker, BKR-24-5 (24405-1, 24403-F,

~

24404-F, 24405-E, 2DC-5)

Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24406-2, 24406-3, 24403-F, 24404-F, 24405-E, 2DC-5)

Compliant Case:

Cable over-current protection .

should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

The impact of these breakers losing over-current trip capability and causing secondary fire damage has been modeled in the Fire PRA and the risk is acceptable:

This VFDR has been eva_luated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation credited.

418 VFDR VFDR-041 B-0-2 This Variance From* Deterministic Revised Components and 221C-4 is protected by a one-hour rated barrier in Requirements is due to fire Cables as follows: 41 B with detection and suppression provided damage to cable(s) that could throughout the fire area. MCC-1AB2 i~ not subject to cause a loss of automatic coolini:i Removed MCC-1AB2 and its failure for the deterministic requirements of NFPA Page 49 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area water strainer backwash function associated cable 221 C-4 805, section 4.2.3.3 (c), have been met for its for 11, 12, 21, and 22 Cooling associated cable 221 C-4.

Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.

This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water cables.

This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries.

Components and Cables:

11 Cooling Water Strainer Backwash Valve, CV-31652, (1 CA-529, 1CB-370) 22 Cooling Water Strainer Backwash Valve, CV-31655 (1 CA-529, 1CB-370) 12 Cooling Water Strainer Backwash Valve, CV-31653 (1 CA-529, 1CB-370) 21 Cooling Water Strainer Backwash Valve, CV-31654 (1 CA-529, 1CB-370) 11 Cooling Water Strainer Motor, MTR-111C-21(1CA-529,1CB-370) 22 Coolina Water Strainer Motor, Page 50 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area MTR-121C-22 (1CA-529, 1CB-370) 12 CL Strainer Motor, MTR-121 C-21 (1CA-529, 1CB-370) 21 CL Strainer Motor, MTR-111 C-22 (1 CA-529, 1CB-370)

AC Distribution Panel 136, PNL-136 (1 CA-529, 1CB-370)

AC Distribution Panel 137, PNL-137 (1 CB-370)

Motor Control Center 1AB Bus 1, MCC-1AB1 (111C-5)

Compliant Case:

Train A or Train B Cooling Water Strainers should remain unaffected by a fire in this area.

Recovery Action(s):

Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 74.

Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136 and PNL-137.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.

418 VFDR VFDR-041 B-0-03 This Variance From Deterministic Revised Disposition I Recovery VFDR-041 B-0-03 is revised and is now resolved Requirements is due to fire Actions to: with a fire risk evaluation credited. The revised Page 51 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area damage to cable(s) that could delta-risk values are calculated in a fire risk cause a loss of DC control power Delete the modification in S-2, evaluation and meet the acceptance criteria defined to Bus 23 and damage to power Item #10 in Regulatory Guide 1.174.

cables that could over-heat and cause secondary fires. If the fire Add credit for a fire risk damaged DC control power, and evaluation to resolve potential then damaged 4kV power cables, loss of over-current trip capability the excessive current could cause for BKR-23-1 and BKR-23-4 load power cables to over-heat and develop secondary fires in other fire areas which violates Revised resolution statement to common enclosure requirements. remove a plant modification and include a fire risk evaluation The Nuclear Safety Performance credited.

Criteria is not met for Vital Auxiliaries.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3.4.b due to a lack of OCT protection for the Power and Control cables for the Screenwash pump.

Components and Cables:

121 Screenwash Pump MTR 23-1 (23401-2, 1C-1550, 1C-1552, 1C-2280, 1C-2285, 1C-4661, 2C-1359) 21 Cooling Water Pump, BKR 4 (1 C-2285, 2C-1359, 23404-2)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Page 52 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Chanaes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Recovery Action(s):

No recovery actions credited.

The impact of BKR-23-1 and BKR 23-4 losing over-current trip capability and causing secondary fire damage has been modeled in the Fire PRA and the risk is acceptable.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation credited.

58 VFDR VFDR-058-1-04 This Variance From Deterministic Revised Disposition I Recovery VFDR-058-1-04 is revised and is now resolved with Requirements is due to fire Actions to: a fire risk evaluation as well as a plant modification damage to cable(s) that could credited. The revised delta-risk values are cause loss of DC control power Add credit for a fire risk calculated in a fire risk evaluation and meet the*

for and damage to power cables evaluation to resolve potential acceptance criteria defined in Regulatory Guide for the following 4kV motor loss of over-current trip capability 1.174.

breakers: BKR-13-3, BKR-15-1, for BKR-13-3 BKR-15-4, BKR-15-5, BKR-15-9, BKR-16-1, BKR-16-5, BKR-16-6, Revised resolution statement to and BKR-16-7. If the fire include a plant modification and damaged DC control power, and a fire risk evaluation credited.

then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.

The Nuclear Safety Performance Criteria is not met for Vital AC Power.

This represents a variation from Page 53 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of vital buses.

Components and Cables:

Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR 13-3 (13403-3, 13403-8, 1C-1293, 1C-1295, 1C-4637) 11 SI Pump, MTR 15-1 (15401-1, 15401-8, 15401-C, 15401-E) 11 RHR Pump, MTR 15-4, (15404-1, 15404-C, 15404-E, 1CA-753, 1CA-98) 11 CC Pump, MTR 15-5 (15405-1, 15405-A,, 15405-G, 1CA-184) 11 CS Pump, MTR 15-9 (15409-1, 15409-8, 1CA-97) 12 .RHR Pump, MTR 16-6 (16406-1, 1CB-36, 1CB-564) 12 CS Pump, MTR 16-1 (16401-1, 16401-8, 1CB-29) 12 SI, MTR 16-7 (16407-1, 16407-8) 12 CC Pump, MTR 16-5 (16405-1, 16405-A,, 1CB-71)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

Page 54 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Chanaes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area The impact of BKR-13-3 losing over-current trip capability and causing secondary fire damage has been modeled in the Fire PRA and the risk is acceptable.

Modification #10 will ensure the remaining breakers, associated with this VFDR, will not cause secondary fire damage.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation and plant modification credited.

58 VFDR VFDR-058-1-11 This Variance From Deterministic Revised Disposition I Recovery VFDR-058-1-11 is revised to credit the modification Requirements is due to fire Actions to: identified in Table S-2, Item #35 to re-route cable damage to cable(s) that could 1C-332 out of Fire Area 32 as well as the cause loss of CT11 and 1R Add the modification in S-2, Item modification identified in Table S-2, Item #6. A re-source to BUS-15 and BUS-16 #35 evaluation of the NSCA model determined and the 01 source (034-011) to modifications identified in Table S-2, Items #6 and BUS-15 and the 02 source (034- #35, need to be credited for the 1RY source to 021) to BUS-16. The power remain available to supply BUS-16.

sources to safeguards BUS-15 and BUS-16 could be impacted by a fire in this area. BUS-15 and/or BUS-16 are required to power safe shutdown equipment.

The Nuclear Safety Performance Criteria is not met for Vital AC Power. :

This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the Page 55 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area area.

Components and Cables:

Bus 15 Source from D1 Diesel Generator, BKR-15-2 (15402-1, 15402-G, 15402-K, 1CA-1140) - - *- . - .. -

Bus 15 Source from 1R XFMR, BKR-15-3 (1C-332, 1C-333, 15403-B)

Bus 15 Source from CT 11, BKR-15-7 (15407-3, 15407-A, 16408-1)

Bus 16 Source from 1R XFMR, BKR-16-2 (1C-332, 1C-333)

Bus 16 Source from CT 11, BKR-16-8 (15407-$, 16408-1)

Bus 16 Source from D2 Diesel Generator, BKR-16-9 (16409-1, 1CB-135)

D2 Diesel Generator, 034-021 (1CB-116, 1CB-117, 1CB-121, 1CB-130, 1CB-133, 1CB-135, 1CB-140, 1CB-526, 1DCB-2)

CT-11 4.16KV CLG TWR Switchgear, BUS-CT11 (1 CT-1)

Compliant Case:

BUS-16 should remain powered from either the 1 RY or D2 source.

BUS-15 should remain powered from the 1RY source for fire scenarios that impact Train B safe shutdown equipment in this area.

Recovery Action(s):

No recovery actions credited.

Modifications identified in Table - *- -

Page 56 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area S-2, Items #6 and # 35 will ensure BUS-16 will remain powered from either the 1RY or D2 source.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

58 VFDR VFDR-058-2-04 This Variance From Deterministic Revised Disposition I Recovery VFDR-058-2-04 is revised and is now resolved with Requirements is due to fire Actions to: a fire risk evaluation as well as a plant modification damage to cable(s) that could credited. The revised delta-risk values are cause loss of DC control power Add credit for a fire risk calculated in a fire risk evaluation and meet the for and damage to power cables evaluation to resolve potential acceptance criteria defined in Regulatory Guide for the following 4kV breakers: loss of over-current trip capability 1.174.

BKR-24-6, BKR-25-7, BKR-25-8, for BKR-24-6 and BKR-26-10 BKR-25-9, BKR-25-10, BKR 13, BKR-26-5, BKR-26-9, BKR- Revised resolution statement to 26-10, and BKR-26-11. lfthefire include a plant modification and damaged DC control power, and a fire risk evaluation credited.

then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.

The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.

This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of Vital Auxiliaries.

Components and Cables:

Page 57 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24403-F, 24404-F, 24406-3, 2C-2552, 2C-866) 21 RHR Pump, MTR 25-7 (25407-1, 25407-C, 2CA-8, 25410-E) 21 SI Pump, MTR 25-8 (25408-1, 25408-B,25408-C,25410-E) 21 CS Pump, MTR 25-9 (25409-1, 25409-D, 2CA-7, 25410-E) 21 AFW Pump, MTR 25-10 (25410-1, 25410-E, 2CA-778) 21 CC Pump, MTR 25-13 (25413-1, 25413-D, 25413-E, 2CA-4, 25410-E) 22 CC Pmp, MTR 26-5 (26405-1, 26405-D, 2CB-7) 22 CS, MTR 26-9 (26409-1, 26409-E, 2CB-315) 22 SI Pump, MTR 26-10 (26410- '.

' ' ; < ] .~ . ' ; .~

1, 26410-C) 22 RHR Pump, MTR 26-11 (26411-1, 2CB-9)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Recovery Action(s):

No recovery actions credited.

The impact of BKR-24-6 and BKR-26-10 losing over-current trip capability and causing secondary fire damaqe has been Page 58 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area modeled in the Fire PRA and the risk is acceptable. Modification

10 will ensure the remaining breakers, associated with this VFDR, will not cause secondary fire damage.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation and plant modification credited.

59 VFDR VFDR-059-2-01 This Variance From Deterministic Revised Disposition I Recovery VFDR-059-2-01 is revised and is now resolved by Requirements is due to fire Actions to: the modification identified in Table S-2, Item #18.

damage to cable(s) that could cause spurious closure of CV- Delete the modification in S-1, 31248 (22 RCP TBHX) and CV- Item #1 31427 (22 RCP Seal Injection).

This could cause a loss of all Add the modification identified in RCP seal cooling to 22 RCP, Table S-2, Item #18 which could result in increased leakage through the RCP seals.

The Nuclear Safety Performance ; .... ' ..- : ;

Criteria is not met for RCS Inventory Control.

This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of RCP seal cooling.

Components and Cables:

22 RCP TBHX, CV-31248 (2C-2556) 22 RCP Seal Injection, CV-31427 (2C-1455)

Page 59 of 74

L-Pl-16-005 NSP.M Enclosure 2 Summarv of Chanaes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to . -*

Area Compliant Case:

CV-31248 or CV-31427 should remain free of fire damage to .

provide cooling to the RCP seals.

Recovery Action(s):

No recovery actions credited.

Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in~depth meet the acceptance \.

criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

59 VFDR VFDR-059-2-12 This Variance -From Deterministic Revised Disposition I Recovery VFDR-059-2-12 is revised and is now resolved with Requirements is due to fire Actions to: a fire risk evaluation as well as a plant modification damage to cable(s) that could credited. The revised delta-risk values are cause damage to DC control Add credit for a fire risk calculated in a fire risk evaluation and meet the power to Bus 26 tripping circuits evaluation to resolve potential acceptance criteria. defined in Regulatory Guide and subsequent damage to AC loss of over-current trip capability 1.174.

power cables resulting and could for BKR-26-10 fail Bus 26. If the fire damaged DC control power, and then Revised resolution statement to ' i :;*

damaged 4kV power cables, the include a plant modification and excessive current could cause a fire risk evaluation credited.

load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure ~equirements.

Page 60 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area The Nuclear Safety Performance Criteria is not met for Vital AC Power.

This represents a variation from the deterministic requirements of NFPA 805 Section 4.2.3 due to a

- lack of separation between 4KV Breakers.

Components and Cables:

22 CC, MTR 26-5 (26405-1, 26405-D) 22 CS, MTR 26-9 (26409-1, 26409-E) 22 SI, MTR 26-10 (26410-1, 26410-8,26410-C) 22 RHR, MTR 26-11 (26411-1, 26411-C)

Compliant Case:

Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.

Coordination of BUS-26 should (

remain unaffected by a fire in this area.

Recovery Action(s):

No Recovery Actions credited.

The impact of BKR-26-10 losing over-current trip capability and causing secondary fire damage has been modeled in the Fire PRA and the risk is acceptable.

Page 61 of 74

L-Pl-16-005 NSPM Enclosure 2 Summarv of Chan{:les to Attachment C, Table 8-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Modification #10 will ensure BKR-26-5, BKR-26-9, and BKR-26-11 will not cause secondary fire damage.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation and plant modification credited.

59 VFDR VFDR-059-2-13 This Variance From Deterministic Revised Disposition I Recovery VFDR-059-2-13 is revised and is now resolved by Requirements is due to fire Actions to: the modification identified in Table S-2, Item #18.

damage to cable(s) that could cause spurious closure of Delete the modification in S-1, CV-31247 (21 RCP TBHX) and Item #1 CV-31426 (21 RCP Seal Injection) which could cause a Add the modification identified in loss of all seal cooling to the Table S-2, Item #18 Reactor Coolant Pump. This could cause a loss of all RCP seal cooling to 21 RCP, which could result in increased leakage through the RCP seals.

The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.

This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of RCP seal cooling.

Components and Cables:

21 RCP TBHX, CV-31247 (2C-Page 62 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area 2553) 21 RCP Seal Injection, CV-31426 (2C-1455)

Compliant Case:

RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.

Recovery Action(s):

No recovery actions credited.

Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.

61 Fire Area 61 N/A Note: Fire Area 61 is now Removed information about FA The NSCA model has been evaluated with Fire combined into Fire Area 4 61 Areas 4 and 61 combined and no VFDRs are created as a result of merging the fire areas.

Information about FA 61 was moved to FA 4.

97 VFDR VFDR-097-0-01 This Variance From Deterministic Revised Components and A re-evaluation of the NSCA model has determined Requirements is due to fire Cables as follows: BKR-15-12 and its associated cables as well as the damage to cable(s) that could cable associated with BKR-15-8 may fault BUS-15 cause damage to Bus 25 and Added BKR-15-12 and its leading to loss of the 11, 12, 21, and 22 CL cables that could cause a associated cables (2CA-748, strainers.

Page 63 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area spurious closure of BKR-25-17 2CA-749, 212A-1, 212A-2, 211A-and BKR-15-8 which could fault 1, 211A-2, 211A-3, 15412-1)

Bus 15 and cause a loss of power to PNL 136 which powers the CL Added cable 25417-D to strainer backwash control panel component BKR-15-8 for 11, 12, 21, and 22 CL Strainers.

The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.

This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers.

Components and Cables:

BKR-15-8 (2CA-749, 25417-1, 25417-2, 25417-D)

BKR-15-12 (2CA-748, 2CA-749, 212A-1, 212A-2, 211A-1, 211A-2, 211A-3, 15412-1) 22 CL Strainer Backwash CB, CV-31655 (none) 22 CL Strainer Motor, MTR-121 C-22 (none)

Motor Control Center 2A Bus 1, MCC-2A1 (211E-1)

Compliant Case:

Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121 C-22) should remain unaffected by a fire in this area.

Recovery Action(s):

Page 64 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Changes to Attachment C, Table B-3 Fire VFDR Revised Version Summary of Change Justification Revision to Area Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 97.

This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.

Changes to Required Fire Protection Systems and Features The following changes are made to the required fire protection systems and features in the indicated fire areas of LAR Attachment C, Revision 1. The following fire areas have updated required systems and features based on further refinements in the Fire PRA. These changes are justified based on the result of the Single Compartment Analysis and Multi-Compartment Analysis Notebooks that have been made since the submittal of LAR Supplement 1. In addition, fire risk evaluations have been performed to evaluate systems required for defense in depth and those have been updated as appropriate.

1. Fire Area 69 (within Fire Area 8 Group), Change Detection ID 107 entry for "R" from "Y" to "N".

2. Fire Area 69 (within Fire Area 8 Group), Change Suppression ID PA-14 entry for "R" from "N" to "Y".

3. Fire Area 69 (within Fire Area 8 Group), Change Suppression ID SWP-3 entry for "R" from "Y" to "N".

4. Fire Area 70 (within Fire Area 8 Group), Change Suppression ID PA-15 entry for "R" from "N" to "Y".

5. Fire Area 18, Add Detection ID "HADs for C02 System", Type- Thermal, with entries as follows: "S"="N","L"="N", "E"="N", "R"="Y", "D"="N"

6. Fire Area 26, Add Suppression ID "PA-9", Type= Pre-Action, with entries as follows: "S"="N","L"="N", "E"="N", "R"="Y", "D"="N"

7. Fire Area 97, Change Detection ID 97 entry for "R" from "Y" to "N".

8. Fire Area 97, Change Suppression ID PA-12 entry for "R" from "Y" to "N".

Page 65 of 74

L-Pl-16-005 NSPM Enclosure 2 Licensee Identified Issue #4: Changes to Attachment D The NPO model has been updated to reflect modification reductions and combining Fire Areas 4 and 61, which are areas with previously identified pinch points. This resulted in the reduction

of the total number of fire areas.

Section F.3 is revised as follows: ,,.

F.3 - Perform Fire Area Assessments (Identify pinch points)

There is a total of fifty-seven (57) fire areas at the PINGP.

Twenty-eight (28) fire areas were found to have an adequate number of KSF success paths to survive the entire contents loss of the fire area. ,

Twenty-nine (29) fire areas were found to have pinch points resulting in the potential loss of one or more KSF success paths.

In addition, the Reference Documents section is revised to include the following additional reference:

EC 26988, "Attachment D Summary of Change" Page 66 of 74

L-Pl-16-005 NSPM Licensee Identified Issue #5: Summary of Revisions for Attachment S Attachment S has been updat~d to reflect revisions to the Fire PRA and to incorporate revisions due to RAI responses. The following table provides an itemized list of the changes and the reason for each change.

Enclq$ure 4 provides the complete revised Attachment S, which supersedes the Attachment S provided in the NFPA 805 LAR Supplement, dated April 30, 2015.

Summary of Revisions for Attachment S Item Attachment S Revision Reason for Change Page S The statement Code Conformance Modifications 9 and 15 have been regarding implementing Code completed. Regarding Code Conformance Modification 8, 1

Conformance modifications 8, . the code conformance detection aspect of the modification is 9 and 15 has been deleted. complete; however, the C02 fire suppression system aspect of the modification is not yet complete, and therefore, Item 8 rernains in Table S-2. All remaining modifications will be completed per the implementation timing specified.

Page S The Aligns with submittal dated May 28, 2015.

implementation timing 2

statement was revised in the

introduction section of Attachment S to align with

Licensee Identified Issue #1 in the 60-DAY RAI Response, dated May 2e, 2015.

Page S The statement

Table S-2 lists the required compensatory:measures per regarding interim modification.

3 compensatory measures has been deleted.

Page S The following To allow future design flexibility with the NFPA 805 statement was added: modifications because they are conceptual at this stage.

4 The Proposed Modification statements in Table S-2 provide a conceptual design to address the Problem Statement. The final design and installation to resolve the Problem Statement will be developed and approved in accordance with {<eel Engineering processes, hence implementation details may vary.

Item S1-1 was removed from This modification is incomplete and remains in Table S-2, Table S-1. Item S2-18 and includes both Unit 1 and Unit 2. In addition, 5 reference to the Flowserve N-9000 RCP Seal package has been removed. See Licensee Identified Issue #1 for further details.

Page 67 of 74

L-Pl-16-005 NSPM Summary of Revisions for Attachment S Item Attachment S Revision Reason :tor Change Item 81-9 was added because The modification was completed and moved from Table S-2, the modification was Item 9, to Table S-1.

6 completed and moved from '"

Table S-2, Item 9, to Table S- '.

1.

Item 81-12 was added The modification was completed and moved from Table S-2, because the modification was Item 12, to Table S-1.

7 completed and moved from Table S-2, Item 12, to Table S-1.

Item 81-13 was added The modification was completed and moved from Table S-2, because the modification was Item 13, to Table S-1.

8 completed and moved from Table S-2, Item 13, to Table S-1.

Item 81-16 was added The modification was completed and moved from Table S-2, because the modification was Item 16, to Table S-1.

9 completed and moved from Table S-2, Item 16, to Table S-1.

Items 82 82-4 under These modifications are conceptual and this level of detail "Problem Statement" were was determined unnecessary.

10 revised to remove the lists of Cables of Concern.

Item 82-2 under 'Proposed Editorial corrections Modification' - Fire Area 3 11 was corrected to Fire Area 31.

Other minor editorial changes.

Item 82-3 under 'Proposed Editorial corrections Modification' - Fire Area 3 12 was corrected to Fire Area 32.

Other minor editorial changes.

Item 82-9 has been completed Modification was completed per EC21578.

and moved to Table S-1, Item 13 9.

Item 82-10 scope was The Fire PRA was updated to model the impact of loss of DC reduced. control power and determined the change in risk was low and 14 therefore, breaker scope could be reduced. Fire damage to medium voltage (4.16KV) switchgear breaker 125 DC control cables could cause a loss of power to the over-current relay protection for these breakers. If the fire also faulted the medium voltage AC power cable, the cable could over-heat causing secondary damage to other cables located in the common enclosure (cable tray) due to the loss of over-current protection for that load cable. Variances from Deterministic Requirements (VFDR) of NFPA 805 were identified in several fire areas. The Fire PRA was refined to model the impact of these VFDRs. There are three items to consider; (1) loss of coordination for the upstream bus, (2)

Page 68 of 74

L-Pl-16-005 NSPM Enclosure 2 Summary of Revisions for Attachment S Item

Attachment S Revision Reason for Change , . :

, secondary damage to cable in the common enclosure, and (3) High Energy Arcing Fault 5' vertical and 3' horizontal Zone of lnfluenGe at the fault location. The Fire PRA model incorporated the impact of loss of coordination in these scenarios by modeling the upstream electrical bus as failed in scenarios where the over~current DC control circuit and AC power cable are damaged. The Fire PRA also includes failure of all the other cables (and their associated components) that is in the common enclosure or common raceway with the affected AC cable from the point of the fault back to the upstream electrical bus.

Item S2-11 was removed as Limited scope fire modeling, consistent with already 1,1sed fire the modification was modeling methods was performed in Fire Area 8, Turbine 15 determined to no longer be Building to better characterize the risk impact of this required. modification. No new fire modeling methods were utilized.

The fire scenarios that impact the cables for the 11 Turbine Driven Aux Feedwater Pump (TDAFWP) were not risk significant and there was very little risk benefit to Modificat.ion

11. Item .11 was credited in the NFPA 805 LAR Attachment C

. for Fire Area 8 to meet Deterministic Requirements. To ensure that Fire Area 8 still meets Deterministic

Requirements of NFPA 805, Section 4.2, modification Item

24 will ensure the CT11 offsite power transformer remains available to power Bus 16 which powers the 12 Motor Driven Aux Feedwater Pump, and Fire Area 8 will still meet

Deterministic Requirements. Therefore Item 11 to modify the *

11 TDAFWP control circuit was deleted.

Item S2-12 has been Modification was completed per EC21574.

. c*ompleted and moved to 16 T.able S-1, Item 12.

Item S2-13 has been Modification was complet~d per EC18746.

completed and moved to 17 Table S-1, Item 13.

Item S2-14 was revised under This modification is conceptual and this level of detail was

'Problem Statement' to delete determined unnecessary. In addition, CV-31505 was 18 the second paragraph, "A fire adc;lressed under Item S2-13.

that results in ... " In addition, CV-31505 was removed as this valve was addressed under Item S2-13.

Item S2-15 was revised under The modification as written was not clear.

'Proposed Modification' for 19 clarity. In addition, Item S2-15 was revised to include speeific

.information on the positive displacement charging pumps (11, 12, 13, 21, 22 and 23 positive displacement charging pumps)

Page 69 of 74

L-Pl-16-005

NSPM Enclosure 2 Summary of Revisions for Attachment S Item Attachment S Revision Reason for Change .,

'~ Item S2-16 has been Modification was completed per EC21572.

completed and moved to 20 Table S-1, Item 16. :

Item S2-18 has been revised As discussed with the NRC Staff during the public meeting to include Unit 2-and remove teleconference held on March 24, 2016, this modification is 21 reference to the Flowserve incomplete and remains in Table S-2, Item S2-18 and 1' N-9000 RCP Seal package. includes both Unit 1 and Unit 2. In addition, reference to the In addition, the sentence Flowserve N-9000 RCP Seal package has been removed.

regarding 13 minutes under See Licensee Identified Issue #1 for further details.

'Problem Statement' has been Enclosure 4 provides the Updated Attachment S. The

' deleted. sentence regarding 13 minutes was deleted as this level of detail was determined unnecessary.

Item S2-20 was revised from There were several electrical panels originally credited ih the High rank to Low Rank. In Fire PRA model that lacked electrical coordination and 22 addition, panels 136, 137 and originally required modification to resolve. The Fire PRA 217 were added for clarity. model was updated to account for the lack of electrical coordination on these electrical panels by following the guidance in NUREG/CR-6850. For the cables on load breakers that are not properly coordinated, include these load cables as affecting the upstream power supply (source breaker to the electrical panel). These changes were made and the CDF and LERF did not increase for many of these electrical panels. This ls because these load cables were in the same fire scenarios where the source cables were already affected, so there were no new fire scenarios where the electrical panels were affected due to loss of

coordination, and therefore no increase in risk 'for these*

panels. Three panels remain on the list because they support equipment credited to be available in certain fire scenarios.

Item S2-24 was revised to add Additional detail was added to Item 24 to describe 4 cables to more detail and expand scope be re-routed outside Fire Area 8, Turbine Building to support 23 of the mod. deleting Item 11. Item 24 was also clarified to address the same issue for Uhit 1 and Unit 2.

Item S2-27 was revised to The Fire PRA model was refined to credit hot short duration remove isolation of excess for letdown, excess letdown, head vents, and pressurizer 24 letdown, head vents, and vents. The letdown and excess letdown isolation valves are pressurizer vents under air operated valves with a solenoid valve that fails closed

'Proposed Modification'. upon loss of power and loss of air to these valves causes them to fail closed. The head vents and pressurizer vents are solenoid operated valves that fail closed upon loss of power .

to the solenoid. If a hot short caused these valves to spuriously energize and open the flow diversion pathway the flow path is. reshicted to limit the flow rate. The risk of the hot short being maintained long enough to cause a significant enough flow diversion is low and the risk benefit of providing isolation switches in the control room was no longer significant for letdown, excess letdown, head vents, and pressurizer vents. Item #27 will still provide isolation switches for Pressurizer Heaters and Pressurizer PORVs.

Page 70of74

L-Pl-16-005 NSPM Summary of Revisions for Attachment S I I Item Attachmerit-S Revision Reason for Change .,

Item S2-28 was removed as The Fire PRA model was refined to locate some risk .;

the modification was significant cables and conduits that were conservatively 25 deternjined to no longer be assumed to be within the Zone of Influence of all fire ignition required.* sources in the fire compartment. After the conduit locations were refined to specific fire scenarios, the risk benefit.of these cable protection modifications was no longer needed to meet Regulatory Guide 1.174 criteria. The Fire PRA model

- I no longer credits these cables being protected from fif,e damage in their applicable scenarios.

Item S2-29 was removed as The Fire PRA model was refined to locate some risk the modification was significant cables and conduits that were conservatively 26 determined to no longer be assumed to be within the Zone of Influence of all fire ignition required. sources in the fire compartment. After the conduit locations were refined to specific fire scenarios, the risk benefit of these cable protection modifications was no longer needed to meet Regulatory Guide 1.174 criteria. The Fire PRA model no longer credits these cables being protected from fire damaqe in their aoolicable scenarios.

Item S2-30 scope was The Fire PRA model was refined to locate some risk reduced to remove Fire Area significant cables and conduits that were conservatively 27 32 and cables 2DCA-105, assumed to be within the Zone of Influence of all fire ignition 2DCA-87. sources in the fire compartment. After the conduit locations were refined to specific fire scenarios, the risk benefit of these cable protection modifications.was no longer needed to meet Regulatory Guide 1.174 criteria. The Fire PRA model no longer credits these cables being protected from fire

damage in their applicable scenarios.

Item S2-31 was removed as The Fire PRA model was refined to locate some risk the modification was significant cables and conduits that were conservatively 28 determined to no longer be assumed to be within the Zone of Influence of all fire ignition required. sources in the fire compartment. After the conduit locations were refined to specific fire scenarios, the risk benefit of these cable protection modifications was no longer needed to meet Regulatory Guide 1.174 criteria. The Fire PRA model no longer credits these cables being protected from fire damaqe in their applicable scenarios.

Item S2-32 was revised to This item was revised to clarify the modification statement.

remove 'Bus 23' and add in 29

'21 Motor Driven Cooling Water Pump' under

'Proposed Modification' Item S2-34 was revised for SSA RAI 10 provided clarification on this modification. After clarity under 'Problem further review, this modification was further revised for clarity 30 Statement' and 'Proposed and to remove unnecessary level of detail.

Modification' Item S2-36 was removed as SSA RAI 07 indicated that the Fire PRA model was changed the modification was to no longer credit recovery action to manually operate MV-31 determined to no longer be 32085 and MV-32188. Since the Fire PRA no longer credits required. these recovery actions to locally operate the MOV, it is no longer required to modify these MOV to allow local operation.

Page 71 of 74

L-Pl-16-005 NSPM Summary of Revisions for Attachment S Item Attachment S Revision Reason for Change '. 11 Item 82-37 was deleted. This modification has been deleted as it is not needed for Fire PRA or for Deterministic reasons.

32 Item 82-38 was added It was identified that some control cables for the main turbine emergency oil pump lacked appropriate over-current 33 protection and require smaller control power fuses to protect the cables from over-current conditions.

Item 82-39 was added It was identified that the 121 Motor Driven Fire Pump loss of power alarm is local to the pump and does not meet NFPA 34 20 code requirements for the loss of power alarm to alarm in

' .. i.,il",

the main control room.

Item 82-40 was added It was identified that fire hose station WF-9 has insufficient pipe hangers/bracing and does not meet NFPA 14, Section 35 651.

Item 82-41 was added After updating the Motor Operated Valve (MOV) weak link calculation, it was identified that some MOVs credited to be 36 locally operated after a fire could be damaged if the fire induced cable failure bypassed the torque and limit switches, therefore a modification was required.

Item 82-42 was added per This modification was determined necessary per response response to FPE RAI 07.c. FPE RAI 07.c.

37 Item 82-43 was added Revised/New FPEEs determined need for upgraded Fire Protection Barriers.

38 Page S Table S-3 NSPM requested a change to the implementation period for Introduction - Implementation the Implementation Items listed in Table S-3 from 6 months 39 timing was changed from 6 to 12 months per letter dated June 19, 2015.

months to 12 months.

Page S Table S-3 Item 83-66 is tied to the modification timeline.

Introduction - Item 66 was 40 added to the last sentence.

Item 83-7, Item 83-8, Item S3- This level of detail is not necessary.

9 were revised to remove the 41 specific identifiers for the Fire Brigade Lesson Plans.

Item 83-19 was deleted. This item is no longer required in Table B-2.

42 Item 83-20 was revised to Revised per response to PRA RAI 15.a submitted per letter include more specific detail dated May 28, 2015.

43 per PRA RAI 15.a.

Item 83-25 was revised to Revised per response to PRA RAI 03.b.

include peer reviews for PRA 44 Upgrades.

Page 72 of 74

L-Pl-16-005 NSPM Summary of Revisions for Attachment S Item Attachment S Revision Reason for Change Item S3-30 was deleted. Deleted per License Identified Issue #2 submitted per letter dated May 28, 2015.

45 Item S3-32 was deleted. Deleted per License Identified Issue #1 submitted per letter dated June 19, 2015.

46 S3-41 was deleted. This item is no longer required to support NPO.

47 S3-42 was deleted. This item is no longer required to support NPO.

48 S3-51 was revised. Revised per response to SSA RAI 03 submitted per letter dated May 28, 2015.

49 S3-53 was reinstated and Reinstated and revised per response to SSA RAI 02 & SSA revised. RAI 04.f.

50 S3-57 was revised. NSPM determined that additional changes were needed to F5, App B.

51 S3-61 was revised. Attachment L was added under 'LAR Section/Source'.

52 S3-63 was revised. Revised per response to SSA RAI 04.

53 S3-64 was added. 83-64 was added per FPE RAI 06.

54 S3-65 was added. 83-65 was added per RR RAI 02. This item has been further clarified to include 'Develop procedural guidance'.

55 S3-66 was added. 83-66 was added per PRA RAI 15.c and further clarified in Licensee Identified Issue #1.

56 S3-67 was added per letter 83-67 was added per letter dated October 6, 2015 in dated October 6, 2015, Licensee Identified Issue #1, Addition of Attachment L 57 however, NSPM is deleting Request #2. NSPM plans to implement the EPRI Technical S3-67. Report TR-1006756 separate from the NFPA 805 implementation timeline.

S3-68 was added. 83-68 was added per FPE RAI 07.

58 S3-69 was added. 83-69 was added after determining that a formal Internal Seal Program was needed.

59 Editorial corrections made Editorial corrections.

throughout Attachment S.

60 Page 73 of 74

L-Pl-16-005 NSPM Licensee Identified Issue #6: Correction to PRA RAI 14.a.ii

'i1'1 During internal reviews of the revised Attachment W, NSPM identified the need to correct the response to PRA RAI 14.a.ii, submitted per letter dated:,May 28, 2015.

NRC Request (PRA RAI 14.a.ii)

(ii} In Table W-7, Unit 2 Fire Areas 1and20 are indicated as having no VFDRs {i.e.

there is a "No" under the "VFDR" column),'. however, there is an "E," or epsilon in the column for !iCDF/!iLERF.

CORRECTED NSPM Response (PRA RAI 14.a.ii):

(ii) This is a typo; VFbRs exist for Fire Areas 1 and 20 in Unit 1 (Table W-6), but not Unit 2 (Table W-7). Attachment W has been updated to include "N/A" in the columns for !iCDFl!iLERF in Table W-7 for Fire Areas 1 and 20; the "No" in the VFDR column for these fire areas is correct. A revision to Attachment W is provided In Enclosure 5.

Page 74of74

L-Pl-16-005 NSPM Enclosure 3 ,,,

Revised Insert A for License Condition 2.C.(4) for both Units 1 and 2 Page 1 of 4

L-Pl-16-005 NSPM Insert A for License Condition 2.C.(4) for both Units 1 and 2:

Fire Protection Northern States Power Company, shall implement and maintain in effect all *provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10*8FR 50.48(c), as specified in the licensee amendment request dated September 28~.*2012 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, and , and as approved in the safety evaluation dated . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied. *

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, m_ethods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC throu.gh a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly

. result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate Page 2of4

L-Pl-16-005 NSPM for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functi.onality of the component, system; procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

"Fire Alarm and Detection Systems" (Section 3.8);

"Automatic and Manua! Water-Based Fire Suppression Systems"

'(Section 3.9);

"Gaseous Fire Suppression Systems" (Section 3.1 O); and *

"Passive Fire Protection Features" (Section 3.11 ).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk

, Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated , to determine that certain fire protection program changes meet the minimal

. *criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program .

.Cc) Transition License Conditions

1. Before achieving fuli' compliance with 10 CFR 50.48(c), as specified by 2.

and 3. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

Page 3 of 4

L-Pl-16-005 NSPM

2. The licensee shall implement the modifications to its facility, as described in Attachment S,,Table S-2, "Plant Modifications Committed," in Northern States Power - Minnesota letter U-Pl-16-XXX, dated , to complete the transition to full compliance with 10 CFR 50.48(c}, before the end of the second full operating cycle for each unit after approval of the LAR. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Attachment S, Table S-3, "lmplementationi Items," of Northern States Power - Minnesota letter L-Pl-16-XXX, dated . , within twelve months after NRC approval, with the exception of Implementation Item 20 and 66 which are associated with. modifications and will be completed 180 days after modifications are complete.

Page 4of4

L-Pl-16-005 NSPM

"'i"*

Enclosur:e 4 Attachment S - Plant Modification~ and Implementation Items, Revisior,1,,3 33 Pages Follow

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items S. Modifications and Implementation Items 1',*

32 Pages Attached I ~ '

. *i Attachment S, Revision 2, supersedes Attachment S, Revision 1, provided in the NFPA 805 LAR Supplement dated April 30, 2015 PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items .

Tables S-1, Plant Modifications Completed, and S-2, Plant Modifications Committed, provided below, include a description of the modifications along with the following information:

A problem statement,

Risk ranking of the modification,

An indication if the modification is currently included in the FPRA,

Compensatory Measure in place if non-compliant with the Current Licensing Basis, and

A risk-informed characterization of the modification and compensatory measure.

The following legend should be used when reviewing the Risk Rank in Tables S-1 and S-2:

o High= Modification would have an appreciable impact on reducing overall fire CDF.

o Medium =Modification would have a measurable impact on reducing overall fire GDF.

o Low= Modification would have either an insignificant or no impact on reducing overall fire CDF.

o NIA= Not modeled in the FPRA, therefore a risk ranking is not provided.

NSPM is requesting two full refueling cycles beyond SE issuance t9 fully implement modifications. This is, in part, due to the c:iutage strategies implemented at PINGP where only one train is removed from service per outage, per unit. Due to the s*ignificant modifications required to transition PINGP to NFPA 805, additional time is necessary to fully implement modifications described in Table S-2.

The Proposed Modification statements in Table S-2 provide a conceptual design to address the Problem Statement. The final design and installation to resolve the Problem Statement will be developed and approved in accordance with Xcel Engineering processes, hence implementation details may vary.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 9 Low 1,2 Fire Suppression required for Modified fire suppression No N/A The proposed the Fire PRA was not code systems in the following fire modification reduced risk compliant, as required by areasto resolve NFPA by allowing the Fire PRA NFPA 805, for the following Suppression code deviations to credit fire suppression Fire Areas: FA-18, ~18, 31, & as follows: systems in the listed Fi.re 32 . . Areas. Per the 2009 FA 18: Installed an odorizer for ASME PRA Standard, fire the Cardox System. suppression systems must be code compliant if FA 31: Resolved non- they are credited in the compliances wi,th pendant Fire PRA.

sprinkler heads.

FA 32: Resolved non-compliances with pendant sprinkler heads.

FA41B: Installed missing Sprinkler #229.

FA41B: Installed Heat Activated Detector (HAD) in the enclosure for the 121 Motor Driven Fire Pump.

FA 41 B: Installed a sprinkler head above the Diesel Driven Fire Pump because of a large obstruction.

(Ref: EC 21578)

From Table S-2, Item 9 PINGP Page S Revision 2

Northern States Power* Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 12 Medium 1,2 A fire in Fire Area 29 could Installed a rated fire barrier Yes N/A Thi$ modification reduced damage cables required for between Fire Area 29 ,and Fire fire risk by providing a operation of Train A Cooling Area 69. rated fire barrier between Water Pumps which supply risk significant cables and cooling water to D1 (Ref: EC 21574) fire initiators.

Emergency Diesel Generator which powers Train A From Table S-2, Item 12 safeguards Bus 15.

A fire in Fire Area 69 could damage cables that supply power to ventilation fans for D2 Emergency Diesel Generator supply to Train B safeguards Bus 16. A fire in Fire Area 69 could also damage cables required for Offsite power to Bus 15 and Bus 16.

Fire Area 29 and 69 were defined as separate areas in the 1977 Fire Hazards Analysis that was submitted to the NRC and accepted.

There is an open pathway between Fire Area 29 and 69; therefore the Fire PRA Plant Partitioning combined Fire Area 29 and 69 (along with 8, 14, 27, and 70) into Fire Compartment 8GRP. Risk for Fire Compartment 8GRP was high when all of these areas were combined.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table 5-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 13 Medium 1 A fire in the control room or Wired additional relay contacts Yes N/A This modification reduced relay room could have from the low speed relay in risk by eliminating the caused hot shorts on cables series with indicating light in possibility that a hot short that could spuriously start D1 the control room so that once on a cable in the Control and close the cooling water D1 speed was greater than and Relay Room could supply valve. This condition 250 RPM, the potential hot isolate cooling water to resulted in unrecoverable short on the indicating light in D1 Emergency Diesel damage to the credited the control room is cleared. Generator Emergency Diesel Generator during a fire indu.ced control (Ref: EC 18746) room evacuation.

From Table S-2, Item 13 16 N/A 1,2 The supply ventilation duct* Installed a fire damper in the No N/A Not modeled in the between Fire Areas 32 and supply ventilation duct FPRA, therefore a risk 37 did not have a fire damper between FA 32 and 3.7. ranking was not provided.

and was not code compliant for the Fire PRA, as required (Ref: EC 21572) by NFPA 805.

From Table S-2, Item 16 PINGP Page S Revision 2 ...

Nori.hem States Power - Minnesota Attachment S- Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure

Characterization 1 High 1 A fire in Fire Area 31 could Modify equipment in FA 31 to .Yes Yes The *modifications proposed damage Train B 12 Motor ensure that Train "A" by Items 1-4 will reduce Driven Auxiliary Feedwater equipment is available for fire risk by modifying FAs 31 Pump (MDAFWP) and the safe shutdown. and 32 to ensure that each control switches for the 11 The controls and associated FA has either A-train or S-Turbine Driven Auxiliary cables for the Unit 1 Train "A"

train related equipment Feedwater Pump AFWP discharge valves will be unaffected by a fire. This (TDAFWP) discharge moved to Fire Area 32 so they will limit the number of fire valves (MV-32238 & MV- are not damaged by a fire in scenarios that could 32239). Fire damage to Fire Area 31. damage both trains of CS-51003 could cause equipment.

spurious closure of MV-32238 which would isolate Compensatory measures in the 11 TDAFWP flow to the accordance with the credited 11 Steam Current Fire Protection Generator. Fire damage to . Licensing Basis are being control switch CS-51005 maintained.

could prevent closing MV- * *-

32239 which could divert Compensatory measures the 11 TDAFWP flow to the will continue to remain in non-credited 12 Steam effect after the NFPA 805 Generator. The NFPA 805 fire protection program Nuclear Safety becomes effective until this Performance Goal Criteria modification is complete.

is not met for Decay Heat Removal.

PINGP

Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and implementation liems Table 5-2 Plant Modifications Committed In Comp Risk Informed Item Rank. *Unit Problem Statement Proposed Modification FPRA Measure Characterization 2 High 2 A fire in FA 31 could Modify equipment in FA 31 to Yes Yes The modifications proposed damage the 22 TDAFWP ensure that Train "A" by Items 1-4 will reduce - *,

(Train B) and damage the equipment is available for fire risk by modifying FAs 3f circuits for the Train A 2t safe shutdown. and 32 to ensure that each MDAFWP (MV-32383 & The controls; MCC power FA has either A-train or S-MV-32384). Fire damage supply, arid associated cables train related equipment at the Train A Hot for the Unit 2 Train "A" AFWP unaffected by a fire. This Shutdown Panel or MCC discharge and suCtion valves will limit the number of fire 2A1 could affect MV-32383 will be moved out of Fire Area scenarios that. could (21 MDAFWP to 21 SG) or 31 so thew are not damaged by damage both trains of MV-32384 (21 MDAFWP to a fire in Fire Area 31. The

equipment.

22 SG). A fire at MCC 2A 1 cables going to Unit 2 Train "A" could affect MV-32026 (21 AFW discharge valves (MV- Compensatory measures in MDAFWP suction from 32383 and MV-32384) will be accordance with the Cooling Water), MV-32336 *modifiecl so that MOV will not Current Fire Protection (21 MDAFWP suction from spuriously close due to a fire in Licensing Basis are being CST), MV-32383 (21 Fire Area 31. maintained.

MDAFWP to 21 SG) and MV-32384 (21 MDAFWP to* Compensatory measures 22 SG). The NFPA 805 will continue to remain in Nuclear Safety effect after the NFPA-805 Performance Goal Criteria .fire protection program is not met for Decay Heat becomes effective until this Removal. modificc:ltion is complete,_

~ *. ... *:- T PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 3 High 1 A fire in Fire Area 32 could Modify equipment in FA 32 to Yes .Yes The modifications proposed damage the 11 TDAFWP ensure that Train "B" by Items 1-4 will reduce (Train A) and the control equipment is available for fire risk by modifying FAs 31 switches for the 12 safe shutdown. and 32 Jo ensure that each MDAFWP discharge valves . The controls, MCC power FA has e*ither A-train or S-(MV-32381 & MV-32382). supply, and associated cables train related equipment Fire damage at the Train B for the Unit 1 "B" AFWP unaffected by a fire. This Hot Shutdown Panel or discharge and suction valves will limit the numb~r of fire MCC 1A2 could affect MV- will be moved out of Fire Area scenarios that could 32381 (12 MDAFWP to 11 32 so they are not damaged by damage both trains of SG) or MV-32382 (12 a fire in Fire Area 32. The equipment.

MDAFWP to12 SG). A fire cables going to Unit 1 Train "B" at MCC 1A2 could affect AFW discharge valves (MV- Compensatory measures in MV-32027 (12 MDAFWP 32381 and MV-32382) will be accordance with the suction from Cooling modified so that the MOV will Current Fire Protection Water), MV-32335 (12 not spuriously close due to a Licensing Basis are being MDAFWP suction from fire in Fire Area 32. maintained.

CST), MV-32381 (12 MDAFWP to 11 SG) and Compensatory measures MV-32382 (12 MDAFWP to will continue to remain in 12 SG). The NFPA 805 effect after the NFPA 805 Nuclear Safety

fire protection program Performance Goal Criteria becomes effective until this is not met for Decay Heat modification is complete.

Removal.

~\ .

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank. Unit Problem Statement Proposed Modification FPRA Measure Characterization 4 High 2 A fire in Fire Area 32 could Modify equipment in FA 32 to Yes Yes The modifications proposed damage the 21 MDAFWP ensure that Train "B" by Items 1-4 will reduce (Train A) and the control equipment is available for fire risk by modifying FAs 31 switches for the 22 safe shutdown. and 32 to ensure that each TDAFWP discharge valves. The controls and associated FA has either A-train or S-Fire damage to CS-51605 cables for the Unit 2 Train "B" train related equipment could cause spurious AFWP discharge valves will be unaffected by a fire. This closure of MV-32247 which moved to Fire Area 31 so they will limit the number of fire would isolate the 22 are not damaged by a fire in scenarios that could TDAFWP flow to the Fire Area 32. damage both trains of'- '

credited 22 Steam equipment.

Generator. Fire damage to control switch CS-51603 Compensatory measures in could prevent closing MV- accordance with the 32246 which could divert Current Fire Protection the 22 TDAFWP flow to the Licensing Basis are being non-credited 21 Steam maintained.

Generator. The NFPA 805 Nuclear Safety Compensatory measures Performance Goal Criteria will continue to remain in is not met for Decay Heat effect after the NFPA 805 Removal. fire protection program becomes effective until this modification is complete.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 5 High 1,2 A fire in FA 18, Relay Install Incipient Detection Yes Yes The proposed modification Room could damage both System in the Relay Room that will reduce risk by installing trains of safe shutdown. will continuously sample the an incipient detection Since the risk of Recovery Relay Room air inside the risk system that will notify Actions taken in procedure significant cabinets to identify operators of fires in their F5 App B, Control Room fires based on the detection of incipient state. This Evacuation (Fire) are high, the presence of small amounts reduces the significance of installing a Very Early of products of combustion and, the fire scenarios that could Warning Fire Detection if detected, will sound an alarm lead to control room System (VEWFDS) or in the MCR. abandonment.

Incipient Detection is needed to reduce risk in Compensatory measures in the relay room. accordance with the Current Fire Protection Licensing Basis are being maintained. *

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed*

Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 Medium 1, 2 Fire damage to cable 1CX- Reroute the following cables Yes Yes The proposed modification 99 in FA 20 could cause a through FA 58 along the "G" will reduce risk because it loss of the normal power line between 8 and 9 and out of will reroute cables feed from 13 Inverter to FA20: associated with the 120VAC Panel 113. Loss of -1CX-99 (Instrument Bus Ill opposite train of equipment Panel 113 causes CV- (Blue) Panel 113 Normal to another FA. This will .

31198 (Charging Line to 11 Power Feed) limit the number of fire Regenerative Heat - 1CW-99 (Instrument Bus II scenarios that could Exchanger CV) to fail open (White) Panel 111 Normal damage both trains of causing diversion of flow Power Feed) equipment.

from RCP seal injection to charging. Loss of Panel Install cable Compensatory measures in 113 causes loss of Control - 1 DCA-133 (DC Power supply accordance with the Room indication for to BUS 15 Load Sequencer) . Current Fire Protection instrument Loops 1N51. from PNL-11 in FA 33 to BUS- Licensing Basis being (Unit 1 Excore Detection 15 Load Sequencer in FA 81 maintained.

Train A), 1T-450A (Unit 1 that is not routed through Fire RCS Loop A Hot Leg Area 20. Compensatory measures Temperature) and 1T-450B will continue to remain in (Unit 1 RCS Loop A Cold effect after the NFPA 805 Leg Temperature). fire protection program becomes~effective until this Modification is needed to modification is complete.

protect 1CX-99 from fire damage in Fire Area 20 to maintain Process Monitoring indication in the control room.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 Fire damage to cable 1CW-Cont 99 in FA 20 could cause a loss of the normal power feed from 11 Inverter to Panel 111. Loss of Panel 111 results in the loss of Control Room indication for instrument Loop 1L-487 (11 SG Wide Range Level) displayed on Level Recorder 1LR-470.

Modification is needed to protect 1CW-99 (Instrument Bus II (White)

Panel 111 Normal Power Feed).

Fire damage to cable 1CF-35 in FA 20 could cause a loss of Control Room indication for Loop 1L-433 (Unit 1 Pressurizer Level).

Modification to protect

. cable 1CW-99 from fire damage in FA 20 will ensure Pressurizer Level Indication LOOP 1L-427 remains available in the control room.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 A fire in FA 20 could Re-route conductors from 1C-Cont damage cable 1C-419 419(Breaker15-3, Bus 15 which could affect the Offsite Source from 1 R ability of BKR 15-3, 1 RY Transformer) to cable 15403-B source to Bus 15, to clear which is not routed in Fire Area from the potentially faulted 20.

1RY source to Bus 15.

Local manual action is required to open BKR 15-3 so that Bus 15 can be repowered from the 01 Emergency Diesel Generator.

A fire in FA 32 or 58 could Re-route affected conductors damage cable 1C-333 of cable 1C-333 out of FA 32 affecting the 1RY source to and FA 58 so the 1RY offsite Bus 16, and could damage power supply will be available cable 16408-1, CT11 in FA 32 and FA 58.

source to Bus 16, and cables 1DCB-2 and 1DCB-95 which support the 02 source to Bus 16. A modification to route affected conductors of cable 1C-333 out of fire area 32 and 58 is needed to protect the 1RY source to Bus 16 in fire area 32.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6

Cont A fire in FA 058/073; 695' Modify cable elevation of the Aux 2DCA-105 (DC Power Cable Building could damage from 21 Battery 125V DC cable 2DCA-105 which Panel 27 Train A) from fire provides DC control power induced failure in Fire Area to PNL 27 which provides 058/073.

DC control power to Bus 25 to trip 4 KV breakers.

7 DELETED DELETED DELETED PINGP Page S-14-.Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp* Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 8 Low 1, 2 Fire Detection required for Install New Fire Detectors per Yes Yes The proposed the Fire PRA is not code NFPA 72 (Detection) to modification reduces risk compliant, as required by resolve NFPA 72 code by allowing the Fire PRA NFPA 805, for the following deviations in the following to credit fire deteCtion Fire Areas: FA-18, 418, areas: systems in the listed Fire 58/73, 59/74 Areas. Per the 2009 FA 18: Modify the Ionization ASME PRA Standard, fire Fire Detection system to detection systems must provide two zones of coverage be code compliant if they in the Relay Room and P250 are credited in the Fire Computer Room. Modify the PRA.

C02 fire suppression system to actuate if both Ionization Compensatory measures zones detect a fire in lieu of in accordance with the heat detectors. Current Fire-Protection Licensing Basis are being FA 41 B: Relocate detector maintained.

from the exhaust stream of a ventilation duct. Compensatory measures will continue to remain in FA 58/73: Resolve various effect after the NFPA 805 detector code issues based on fire protection program S&L Fire Detector Study, Rev becomes effective until 0, PINGP, Project No: 111973- this modification is 055, 12/20/2008 complete.

FA 59/74:Resolve various detector code issues based on S&L Fire Detector Study., Rev 0, PINGP, Project No: 111973-055, 12/20/2008.

9 COMPLETED COMPLETED COMPLETED PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Mpdifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 10 High 1,2 A fire could damage DC Modify 4160 volt switchgear Yes Yes The FPRA assumes control cables for 4 KV control circuits so that faults on coordination of credited breakers which could the control cables will not buses.

cause the tripping control prevent the over-current trip power fuses to clear which relay from protecting the cable This modification ensures would prevent the breaker from over-current conditions there are no secondary from tripping on over- that could lead to cable fires.

current. The fire could then damage and SE:JGOndary fires or damage the 4 KV power loss of bus coordination. Compensatory measures in cable, but since the breaker accordance with the can't trip, the cable would Current Fire Protection be subjected to an over- Licensing Basis are being current condition up to the maintained.

full fault current available to the bus. If the cable is not Compensatory measures sized large enough to carry will continue to remain in this amount of current, the effect after the NFPA 805 cable could be damaged fire protection prog*ram and start a fire in other fire becomes effective until this areas where it is routed. modification is .complete.

- I *, .

Affected Breakers:

BKR 15-1, BKR 15-4, BKR 15-5, BKR 15-9, BKR 16-1, BKR 16-5, BKR 16-6, BKR 16-7, BKR 16-10, BKR 16-12, BKR 25-7, BKR 25-8, BKR 25-9, BKR 25-10,BKR 25-13, BKR 26-5, BKR 26-9, BKR 26-11 11 DELETED DELETED DELETED 12 COMPLETED COMPLETED COMPLETED 13 COMPLETED COMPLETED COMPLETED PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 14 Medium 1,2 A fire in FA 13/18 could . Modify control circuits for the Yes No This modification will damage cables causing Diesel Driven Cooling Water reduce risk by simplifying multiple spurious Pump to eliminate the current restoration of Cooling

operations that could required recovery action of Water to provide cooling to damage D1 Emergency sending an operator to the D1 D1 Emergency Diesel Diesel Generator. If fire Room and Screenhouse. Generator and a backup induced cable damage water supply to the Aux caused multiple spurious

Feedwater Pumps.

operations that caused D1 (034-011) to spuriously start with no cooling water (11 MDCLP MTR 13-8, 12 DDCLP 145-392, 21 MDCLP MTR 23-4, 22 DDCLP 245-392) then the EDG could be damaged.

PINGP Page S-17 -.Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 15 Medium 1, 2 Fire-induced damage that Install suction pressure Yes Yes The proposed modification could damage cables protection for all the cha.rging will reduce risk by installing causing multiple spurious pumps to ensure adequate Net suction pressure protection operations resulting in Positive Suction Head (NPSH). that will protect the damage to the charging exists to prevent damage to the charging pumps against pumps. If fire induced charging pumps. fires that involve spurious cable damage caused valve closure and other spurious isolation of failures that impact NPSH letdown to the VCT (CV- forthe charging pumps.

31226 and CV-31255) and failure to open the RWST Compensatory measures in supply (MV-32060) and accordance with the failure to trip the charging Current Fire Protection pumps, the 11, 12, 13, 21, Licensing Basis are being 22 and 23 positive maintained.

displacement charging pumps (MTR 111 J-1) and Compensatory measures MTR 211J-1 could be will continue to remain in damaged due to lack of Net effect after the NFPA 805 Positive Suction Head fire protection program (NPSH). Need to prevent becomes effective until this unrecoverable damage to modification is complete.

credited charging pump due to fire in FA 13/18 to resolve MSO issue.

16 COMPLETED COMPLETED COMPLETED 17 DELETED DELETED DELETED PINGP Page S-18-Revision *2

Northern States Power - Minnesota Attachment S -- Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 18 High 1, 2 A fire in Fire Area 1, 13, 18, Install new RCP seals that *Yes Yes The proposed modification 59, and 71 could cause a would not be subject to will reduce risk by installing loss of all Reactor Coolant excessive leakage if all seal a shutdown RCP Seal Pump (RCP) seal cooling cooling is lost. package. The new seal will by damaging RCP seal have the ability to preclude injection from charging and larger seal leakage rates Component Cooling (CC) during loss of seal cooling water to the Thermal scenarios: *

Barrier Heat Exchanger (TBHX). Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being

. maintained.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

19 DELETED DELETED DELETED 20 Low 1,2 The current Fire PRA Install the appropriate fuses Yes No The Fire PRA assumes Model assumes proper and/or breakers to establish proper coordination of coordination exists for all proper selective coordination these power supplies*

credited power supplies. for panels 136, 137, and 217 Per Fire PRA credited credited to be coordinated power supplies lack selective coordination.

21 DELETED DELETED DELETED 22 DELETED DELETED DELETED PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure

Characterization 23 Medium 2 A fire in Bus 27 room (Fire Install fuses to provide Yes Yes The Fire PRA assumes Area 127) could damage coordination so that a fire in the proper coordination of DC control power to Bus 25

Bus 27 room will not affect DC these power supplies or Bus 26. control power to Bus 25 or Bus 26.

24 High 1, 2 A fire in the Bus 15 (Fire

Provide fuse/breaker Yes No The proposed modification Area 81) or Bus 16 (Fire coordination for the CT11 will reduce risk by ensuring Area 20) room could supply to Bus 15 and Bus 16 one off-site power source damage the cables and bus so that the CT11 source to the safeguards 4 kV Bus duct that supply off-site remains available to Bus 15 if a remains unaffected by a power (CT11 and 1R fire damages Bus 16 or to Bus fire in the event of a fire in transformers) to Bus 15 16 if a fire damages Bus 15. the opposite train and Bus 16 due to common safeguards 4 kV: Bus room.

power supply. The Provide fuse/breaker redundant diesel generator coordination for the CT12 remains unaffected by a supply to Bus 25 and Bus 26 fire to re-power the so that the CT12 source unaffected 4 kv safeguards remains available to Bus 25 if a bus (Bus 15 or Bus 16), but fire damages Bus 26 or to Bus risk is higher than desired. 26 if a fire damages Bus 25.

Modify associated control Unit 2 is similar to Unit 1. A cables (1CS-1, 1CS-2, 1CS-3, fire iii Fire Area 117, BUS and 1CS-4) so the CT11/CT12 25 or Fire Area 118, BUS source remains available for 26, could damage cables the opposite Bus room.

for both off-site power sources (2RY and CT12 transformer). The redundant Emergency Diesel Generator (D5/D6) remains unaffected by a fire, but the risk is higher than desired.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment .S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Mea~ure Characterization 25 Medium 1 A fire in Fire Area 32 could Re-power MV-32078 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 32 open MV-32077 and MV- Area 32 to re-gain the ability to does not damage the ability 32078 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

26 Medium 2 A fire in Fire Area 31 could Re-power MV-32180 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 31 open MV-32180 and MV- Area 31 to re-gain the ability to does not damage the ability 32181 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

27 High 1, 2 A fire in the Control Room Install switches in the Control Yes No This will reduce risk by (Fire Area 13) or the Relay Room to isolate Pressurizer providing an additional way and Cable Spreading PORV, and Pressurizer to isolate Pressurizer Room (Fire Area 18) could Heaters. PORV, and isolating cause spurious opening of Pressurizer Heaters from valves that could lead to a the control room.

loss of inventory.

28 DELETED DELETED DELETED 29 DELETED DELETED DELETED 30 Medium 2 A fire in Fire Area 31 could Modify risk significant cable Yes No This will reduce risk by damage cables that provide (2DCA-10) from risk significant ensuring DC power DC power to vital fire initiators in Fire Areas 31. remains available for auxiliaries which impacts control and instrumentation risk. for fire in FA 31.

31 DELETED DELETED DELETED 32 Medium 2 A fire in Fire Area 32 could Modify cable 1C-2278 from Yes No. This will reduce risk by damage cable 1C-2278 failing 21 Motor Driven Cooling ensuring the availability of which could affect control Water Pump in Fire Area 32. the 21 MDCLP for a fire in for BKR-'23-4 which powers FA32.

the 21 Motor Driven Cooling Water Pump (21 MDCLP).

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 33 1 A fire in Fire Area 32 could Modify cable 1DCB-18 from fire Yes No This will reduce risk by Medium damage the cable that damage in Fire Area 32. ensuring the availability of provides DC control power DC power to PNL-16 to to PNL-16 which supports provide vital Instrumentation. instrumentation.

34 Medium 1, 2 A fire in FA 13, 18, 32 or 58 Modify cables to prevent Yes No This will reduce risk by could damage cables and spurious closure from risk making modifications to cause spurious closure of significant fire initiators. reduce the number of fire the Emergency Diesel scenarios that could cause Generator output breaker. fire damage to a 4kV This could cause a lockout safeguards bus.

of the 4kv safeguards Bus which powers one train of safeguards equipment.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 35 Medium 1 A fire in Fire Area 32 or 58 Modify cable 1C-332 from fire Yes Yes The proposed modification could damage cables which damage in Fire Area 32 and 58 will reduce risk because it support operation of the to ensure BUS 16 can be will reroute cables 1RY offsite power sources powered from the 1RY associated with the to BUS 15 (BKR-15-3) and transformer. opposite train of equipment BUS 16 (BKR-16-2). to another FA This will limit the number of fire

scenarios that could damage both trains of equipment.

Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being maintained.

Compensatory measures will c:ontinue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

36 DELETED DELETED DELETED 37 DELETED DELETED DELETED PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table 5-2 Plant. Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement .Proposed Modification FPRA Measure Characterization 38 N/A 1, 2 A fire in Fire Areas 31, 32, Install control power fuses for No Yes This modification does not 58/73, 18, or 13 could the control circuits to provide have a significant impact damage control cables for over-current protection for the on the. Fire PRA model the 11 or 21 DC

DC Emergency Turbine because the 11 and 21 Emergency Turbine Bearing Oil Pumps. Emergency Oil Pumps are Bearing Oil Pump that are not credited. The Fire PRA not adequately fused to model does not directly protect from over-current model common enclosure conditions. The control concerns.

cables could over-heat due to excessive current flow.

Since the cables are routed in multiple fire areas, this is a common enclosure concern.

39 N/A 1, 2 The 121 Motor Driven Fire Modify the Fire Pump alarm in No No This modification does not Pump (MDFP) loss of the control room to include the have an impact on the Fire power alarm is local at the loss of power alarm. PRA because the loss of pump in the screen house power alarm does not and does not currently affect functionality of the alarm to the con~rol room. 121 MDFP. It is an NFPA This does not meet NFPA 805 code compliance 20 requirements. concern.

40 N/A 1, 2 There is a fire protection Add a restrai.nt for fire No No This modification does not hose station with protection hose station WF-9 have an impact on the Fire insufficient pipe hangers where the pipe comes through PRA because the hose that does not meet the the floor of the Turbine station is still functional.

requirements of NFPA 14, Building.

Standpipes and Hose Systems.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and lmpleinentation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 41 Medium 1, 2 A fire in Fire Area 13 or 18 Re-wire the torque and limit Yes Yes The proposed modification could damage cables that switches so fire induced will allow the valve to be could over-torque motor damage to cables in FA 13 and locally operated to credit operated valves; MV-

18 cannot bypass the torque this recovery action in the 32006, MV-32010, MV- and limit switches and PRA.

32021, MV-32022, MV- subsequently over-torque the 32238, and MV-32246 MOV. Compensatory measures in which are credited in the accordance with the current Fire PRA to be locally Fire Protection Licensing operated to perform

Basis are being Recovery Actions. maint;;iined.

Compensatory measures will continue to remain in effect after the NFPA 805 fire. protection program becomes effective until this modification is complete.

42 N/A 1 Wiring above suspended Bring Fire Area 8 Locker No Yes This modification will ceilings in Fire Area 8 Room, Unit 1, 715' in the restore compliance with Locker Room, Unit 1, 715' southeast corner into NFPA805 requirements. It in the southeast corner is compliance with NFPA 805, is not modeled in the Fire not in compliance with the Section 3.3,5.1. PRA for risk significance.

requirements of NFPA 805.

Compensatory measures in accordance with the fire protec:tion licensing basis will be maintain~d until the modification is complete.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 43 N/A 1, 2 Fire Protection Barriers Upgrade Fire Protection No Yes This modification will required by NFPA 805 not Barriers required by NFPA 805 restore compliance with in compliance with the to meet the requirements of NFPA 805 requirements. It requirements of NFPA 805. NFPA 805, Section 3.11. is not modeled in the Fire PRA for risk significance.

Compensatory measures in accordance with the fire protection licensing basis will be maintained until the modification is complete.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3, Implementation Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to implementation of the new NFPA 805 fi~e protection program. This will occur within the later of twelve (12) months after NRC approval, or twelve months after a refueling outage if one is in progress at the time of approval. Note that Item 20 and Item 66 are associated with modifications described in Table S-2 and will be completed as part of the modification process in accordance with the timetable provided in Section 5.5.

Table S-3 Implementation Items

. Item Unit Description LAR Section I Source 1 1, 2 Implement monitoring program required by NFPA 805 Section 2.6 4.6.2, Attachment A Section 3.2.3(3) in accordance with NFPA 805 FAQ 10-0059, including a process that reviews the FPP performance ~nd trends in performance.

.2 1, 2 Revise plant procedure 5AWI 3.13.3, "Hot Work," to address the Attachment A Section 3.3.1.3.1 following: Attachment A Section 3.3.1.3.3 Attachment D

- Address the requirements for hot tapping. (NFPA 51 B-1999, Section 3-5)

- Address the requirements for a fire watch where torch-applied roofing hot work operations are in effect. (NFPA 241-1999, Section 5.1.3.2)

-Address the requirement that open flames or combustion-generated smoke shall not be permitted for leak or air flow testing.

- Consider delaying hot work in the vicinity of risk significant components during High Risk Evolutions .

3 1, 2 Revise procedure F5 App J, "Fire Drills," to require that fire Attachment A, Section 3.4.3 (C)(3) brigade drills be conducted in various plant areas .

4 1,2 Perform a calculation to demonstrate that the fire water supply is Attachment A Section 3.5.1 capable of delivering the largest design demand with the hydraulically least demanding portion of fire main loop out of service in accordance with NFPA 805 requirements.

5 N/A DELETED N/A 6 1, 2 Revise procedure F5, "Firefighting," Section 7, to include a Section Attachment E 7.5, Control of Spread of Contamination, to address ventilation, floor drains, opening walkways or stairs between areas, and salvage/overhaul activities.

. PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR *sectiontSource*- - - - *--

7 1, 2 Revise Fire Brigade Training Lesson Plans to address the spread Attachment E of contamination during firefighting activities.

8 1, 2 Revise Fire Brigade Training Lesson Plans to identify the Attachment E responsibilities of each brigade member relative to limiting the spread of cross contamination when fighting fires in radiologically controlled areas.

9 1, 2 Revise Fire -Brigade Training Lesson Plans to provide sufficient Attachment E details on the impact of fire fighting activities on the potential spread of contamination, and the methods available for mitigating such cross contamination via ventilation and drainage control.

10 1, 2 Revise procedure F5 App A, "Fire Strategies", to include Attachment E information on potential cross-contamination for each fire area.

11 1, 2 Revise procedure F5, "Firefighting", Section 2.7 to address Attachment E potential access requirements for the Duty RP Tech or Chemist.

12 1, 2 Revise Radiation Protection Continuing Training to address Attachment E control of contamination during firefighting activities.

13 1, 2 Revise procedure F5, App A, "Fire Strategies" to address the Attachment E ability to utilize the Auxiliary Building Special Ventilation, Containment Internal Cleanup Subsystem, Containment Purge, Containment-In-Service Purge, and Shield Building Ventilation System for the removal of potentially contaminated smoke in fire areas identified in Attachment E.

14 N/A DELETED N/A 15 1, 2 Provide a container with booms, portable filtered ventilation, and Attachment E other appropriate equipment for the containment of water in the Low Level Rad Waste Enclosure.

16 1, 2 Provide procedures to utilize a combination of containerization and Attachment E administrative controls to ensure that exposed contaminated waste in the Low Level Rad Waste Enclosure are kept as low as reasonably achievable.

17 1, 2 Revise F5 App F, "Fire Hazards Analysis" to align with the Jire Attachment I area descriptions listed in Attachment I.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section I Source 18 N/A

DELETED N/A 19 N/A DELETED . N/A 20 1, 2 Update the Fire PRA Model, as necessary, after all modifications, 4.8.2 procedure changes, and other risk-relevant items identified in PRARAI 15.a . - - - - - -

Tables S-1, S-2, and S-3 are. complete and as-built. If the revised Fire PRA indicates an increase in risk metrics such that the RG 1.205 acceptance guidelines are not met, changes will be made such that the Fire PRA results will fall within the acceptance guidelines. These changes may include additional analysis, procedure enhancements, plant modifications, or other changes determined necessary to reduce the overall risk metrics to within the acceptance guidelines.

21 N/A DELETED N/A 22 1, 2 Create new Fire Protection Design Basis Document to reflect . 4.7.1 content requirements of NFPA 805.

23 N/A DELETED N/A 24 N/A DELETED N/A 25 1, 2 Provide a Change Evaluation Process procedure in accordance 4.7.2 with the requirem~nts of NFPA 805. Ensure the process includes.. PRA RAI 03.b peer reviews to be performed on changes that are PRA upgrades, as defined in the PRA standard.

26 1, 2 Develop qualification requirements and position-specific training 4.7.3 for personnel involved with the Fire PRA.

27 1, 2 Revise procedure 5AWI 3.13.0, "Fire Protection Program,",to add 4.3.2 and Attachment D Non Power Operations (NP.O) overview, definitions; road map; and risk reduction-requirements for all NPO, and High Risk Evolutions (HRE).

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section I Source 28 1, 2 Revise GEN-Pl-059, "10CFR50, App R, Safe Shutdown Database 4.7.2 Data Verification"' and other configuration control procedures which govern the various PINGP documents and databases that currently exist (or develop new procedures/processes) to reflect the new NFPA 805 licensing bases requirements.

29 1, 2 Revise system level design basis documents to reflect NFPA 805 4.7.2 requirements and superseding of the old fire protection licensing

.basis.

30 N/A DELETED N/A 31 N/A DELETED N/A - - .

32 N/A DELETED N/A 33 N/A DELETED N/A 34 1, 2 Revise Design Calculations ENG-EE-177, 194401-2.3-008, 4.5 and Attachment B 12911.6214-E-01 and ENG-EE-013 to support the Fire PRA credited power supply breaker - fuse coordination. Additionally, revise Design Calculation ENG.:EE-177 per AR 01342798-02 to support the Loss of DC Control Power Analysis.

35 1, 2 Revise FP-OP-ROM-01, "Refueling Outage Management" 4.3.2 and Attachment D procedure for inclusion of NPO requirements.

36 N/A DELETED N/A 37 N/A Revise 5AWI 3.13.3, Hot Work to avoid hot work in certain areas N/A during high risk evolutions.

38 1,2 Revise F5 App K, "Fire Protection Systems Functional 4.3.2 and Attachment D Requirements" to contain the compensatory actions to be implemented .should. a fire protection system required to be operable during HRE periods be found to be impaired.

39 1,2 Revise EM 3.4.1, "Review of Proposed Changes to the Fire 4.3.2 and Attachment D Protection Program" to contain guidance to ensure that changes to the fire protection program are reviewed for impact to fhe NPO requirements and risk reduction actions.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Oescription LAR Section I Source 40 1,2 Revise 5AWI 15.6.1, "Shutdown Safety Assessment" to contain 4.3.2 and Attachment D discussion on HRE, risk due to fire, NFPA 805 and the NPO requirements as part of risk management.

41 N/A . DELETED N/A 42 N/A DELETED NIA 43 N/A DELETED N/A 44 N/A DELETED N/A 45 1 Revise 1C1.6, "Shutdown Operations - Unit 1" to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

46 2 Revise 2C1 .6, "Shutdown Operations - Unit 2" to contain a 4.3.2 and Attachment D requirement to maintain a continuOU$ action to monitor T-Boil until the HRE can be exited then an HRE:: Risk Reduction Actions exit check list is provided.

47 1 Revise 1C4.1, "RCS Inventory Control Pre-refueling" to contain _a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

48 2 Revise 2C4.1, "RCS Inventory Control Pre-refueling" to contain a 4.3.2 and Attachment D requirement to* maintain a continuous action to monitqr T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

49 1 Revise 1C4.2, "RCS Inventory Control - Post Refueling" to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

50 2 Revise 2C4.2, "RCS Inventory Control - Post Refueling" to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

PINGP Page S Revision 2

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section I Source 51 1, 2 Revise EM 3.4.3, "Safe Shutdown Circuit Analysis" to incorporate 4.3.2 and Attachment B applicable details of vendor document EPM-DP-EP-004, as well SSA RAI 03 as the methodology for analyzing twisted pair instrumentation and controls circuits as referenced in EC 20612, "PINGP Non-Power/NSCA Operations Review for NFPA 805."

52 1, 2 Develop a calculation titled "Nuclear Safety Capability Assessment Attachment B (NSCA) Analysis for Compliance with NFPA 805," to establish a design basis for the NSCA model and supporting analyses.

53 1, 2 Update GEN-Pl-055, "10CFR50 Appendix R Manual Action 4.2.1.2 and Attachment T Feasibility Study," to reflect PINGP's transition to NFPA 805, SSA RAI 02 & SSA RAI 04. f

including addition of new recovery actions, actions to maintain safe and stable conditions, and to document how the criteria, as defined by FAQ 07-0030, are met.

54 NIA DELETED *NIA 55 NIA DELETED NIA 56 NIA DELETED NIA 57 1, 2 Revise procedure F5 App B "Control Room Evacuation (Fire)" to Attachment G direct the isolation of containment prior to leaving the control Attachment W room, add an optional attachment cross-tie power from opposite Unit if one Unit is in a Station Blackout, and to incorporate credited Recovery Actions.

58 1, 2 Revise F5 App D, "Impact of Fire Outside Control/Relay Room" as Attachment G and W required to include fire response HFEs in the Fire PRA Model and credited .recovery actions from Attachment G.

59 NIA DELETED NIA 60 1, 2 Revise ENG-ME-353, "Mechanical MOV Analysis to Support Attachment B IN 92-18 Response" to incorporate updated vendor information as identified in AR 01422482.

61 1, 2 Verify that site procedures and compensatory measures for Generic RAI 32, Attachment L control of combustibles agree with assumptions in the Fire PRA.

PINGP Page s. 32 - Revision 2

Northern States Power - Minnesota Attachment S- Modifications and Implementation Items Table S-3 Implementation Items - ---*---*- -- -- -*-- --- - -----~ *- -*-

Item Unit Description LAR Section I Source 62 1, 2 Perform an Evaluation for PNL 117 and PN L 217 to confirm the Attachment D and G loading capacity to supply more than one Instrument Bus.

63 1, 2 Provide procedural guidance to connect a die~el powered portable 4.2.1.2 generator located outside the power block to power.a temporary SSA RAI 04 fan for the Main Control Room to maintain safe and stable conditions. Additionally, procedural guidance shall be provided for the operation, maintenance, storage, and refueling of the portable generator and for training and drills.

64 1,2 Update code compliance reviews to document resolution of FPE RAl-06 identified open items.

65 1,2 *Develop procedural guidance to provide portable HEPA filters RRRAl-02 strategically located in the Radiological Controlled Area (RCA) that will be available for use based on radiological conditions as monitored by radiation protection personnel and as communicated to the fire brigade leader during fire events.

66 1,2 The PINGP Fire PRA model shall be reviewed using an NRC Updated PRA RAl-15 approved RCP seal model, as well as any exceptions/clarifications included in the NRC approval, to determine if the internal events and Fire PRA require a revision. The Prairie Island internal events and Fire PRA will be updated, if applicable, with the latest RCP seal information. If the updates result in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results.

Compensatory measures established prior to the RCP seal replacement shall remain in place l!ntil the calculated risk increase is within RG 1.174 limits.

67 NIA DELETED NIA 68 1, 2 Revise plant procedures to ensure that future Wiring installation Attachment L above suspended ceilings in Power Block Areas will conform to FPE RAI 07 NFPA 805 Section 3.3.5.1.

69 1, 2 Enhance the Internal Penetration Seal Program Attachment A PINGP Page S Revision 2

v t e Letter Sequence Response to RAI
TAC:ME9734, (Approved, Closed) TAC:ME9735, (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement, Supplement, Supplement Administration Questions 3 March 2015 30 March 2015 28 August 2015 28 August 2015 Answers 28 May 2015 19 June 2015 20 January 2016 24 May 2016 Results Approval Other:
MONTHYEAR2015-10-22 [Table View]

L-PI-16-005, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information

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