ML25307A098
Text
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 1 of 6 NOTE:
This data sheet aids the Fire Protection Reviewer in determining whether the Change Driver requires a risk-informed change evaluation in accordance with 12-FPE-2270-RICE-001, NFPA 805 Fire Protection Program Risk Informed Change Evaluation.
- 1. Change Driver:
GT 2023-2569-1__________________________________
FPCE No.:
2023-0002
- 2. Pending Change:
Yes. Ensure creation of tracking item (document OIC, AR, GT tracking number)
No SCREENING:
- 3. Provide a brief description of what is being changed and why:
EEE-11-59, Engineering Equivalency Evaluation for Unit 1 Turbine Building below Elevation 633-0 Water Fire Suppression System Sprinkler Head Deviations Fire Zones 90, 91, 92 & 93 (AA2), and EEE-12-24, Engineering Equivalency Evaluation for NFPA 24
- Listed Valve Deviation 12-ZMO-400 & 401, have been voided. These EEEs do not document a deviation from NFPA code and were not required to support compliance with the Fire Protection License Basis.
This FPCE will remove EEE-12-24 from the NFPA 805 Fire Protection Program Manual, NFPA 805 Chapter 3 Fundamental FP Program and Design Elements, and, NFPA Codes of Record Summary.
Note: EEE-11-59 is not currently listed in the NFPPM or any other Fire Protection documents.
See Attachment 1 for a mark-up to the NFPPM.
Documentation updates for voiding EEE-11-59 per GT 2023-2569. EEE-11-59 evaluated rotation of closed water spray heads installed to protect cable tray routing in the Turbine Building. The slight rotation of sprinkler branch lines associated with cable rack sprinklers in the Turbine Building do not deviate from NFPA 805 or other NFPA code requirements.
Installed sprinklers are closed head directional spray nozzles intended to spray over the top of the cable trays. In some cases, the sprinkler heads are rotated on purpose to account for changing elevations/directions of the cable trays, in others, the branch line or sprinkler head may have drifted from the horizontal plane, but still maintain appropriate coverage of the cables trays as required by NFPA code. The original deviation that was evaluated appeared to be for the installation of upright/pendant type sprinklers which are not the installed type of sprinkler in these locations. Additionally, the condition at G-20A, EL 623'-0 was corrected per AR 2022-3744 and WO 10022141.
Documentation updates for voiding EEE-12-24 per GT 2023-2908. EEE-12-24 evaluated the use of unlisted valves for the township water supply to the Fire Protection Water Storage Tanks. 12-ZMO-400 and 401 are not within the scope of NFPA 24 and are not a deviation to NFPA code. Per drawing 12-5254 Section B-9, these valves are included in piping material specification for FB-32, Fire Protection Above Ground Distribution piping.
FPCE-2023-0002 Rev. 0 Page 1 of 13
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 2 of 6 This specification does require Listed valves. The information in this evaluation provided justification for the Engineering Change to deviate from the piping specification, DCC-PV-110-QCF. The location of the valves in question though, are not in the scope of NFPA 24.
The scope of NFPA 24 is distribution piping downstream of the Fire Protection Water Supply. These valves provide the public water fill to the Fire Water Storage Tanks (FPWST). The FWSTs are the start of the Fire Protection Water Supply and all piping beyond the downstream of the tanks are governed by NFPA code. 12-ZMO-400 and 401 are upstream of the FWSTs and are not governed by NFPA code. This is confirmed in NFPA 22, Water Tanks for Private Fire Protection, where no specific requirements are identified related to valves in the fill line for the tanks if separate from the Fire Protection System under city or fire pump pressure. Only the regulations of the local health authority are required when connecting a public drinking water supply to the Fire Water Storage Tanks (Ref. NFPA 22-1987, sec. 8-4.2.)
- 4. Based on review of the Change Driver and all supporting documentation, determine if additional Program Document are impacts:
Y N
(Check if Yes [Y] or No [N])
- a.
Is the UFSAR (Sections 9.8.1, 15.1.13 or 15.1.14) affected by the proposed Change Driver? IF Yes, THEN perform a review in accordance with procedure PMP-2350-SAR-001, UFSAR Update Process.
- b.
Is the TRM affected by the proposed Change Driver? IF Yes, THEN perform a review in accordance with procedure PMP-2300-RAP-002, Routine Licensing Documents Change Requests.
- 5. Based on review of the Change Driver and all supporting documentation, determine if additional evaluation is needed:
No Further Review Necessary:
Change is editorial or trivial (within program allowances or administrative in nature).
Continue to Item No. 10 to document conclusion.
- 6. Preform Preliminary Risk Screening.
Evaluate each section that the FPP change applies to:
Does the change affect compliance with NFPA 805 Chapter 2, Methodology/Process Changes?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal FPCE-2023-0002 Rev. 0 Page 2 of 13
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 3 of 6 Evaluate each section that the FPP change applies to:
Does the change affect compliance with NFPA 805 Chapter 3, Fundamental Fire Protection and Design Elements (including combustible loading)?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal Does the change affect the Non-Power Operational (NPO) modes analysis?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal Does the change affect compliance with the Radiological Release Criteria of NFPA 805 as defined in the CLB?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal Does the change affect compliance with the Nuclear Safety Criteria of NFPA 805 as defined in CLB?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal Does the change affect Fire Modeling and the Fire PRA analysis?
Enter evaluation here No Impact Minimal Impact Potentially Greater than Minimal FPCE-2023-0002 Rev. 0 Page 3 of 13
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 4 of 6
- 7. Are any questions in Item No. 6 answered Potentially greater than minimal impact?
Yes. The Change is not acceptable without a Detailed Risk Evaluation in accordance with 12-FPE-2270-RICE-001, NFPA 805 Fire Protection Program Risk Informed Change Evaluation. Either the change must be revised OR a Detailed Risk Evaluation must be prepared for determination if the change can be approved without prior NRC approval. Include completed 12-FPE-2270-RICE-001, Data Sheet 1 with this data sheet and continue to Item No. 8.
No. Continue to Item No. 8.
Note:
IF the change clearly results in a decrease in risk, THEN PRA should consider a revision to the model by performing a model impact assessment in accordance with 12-EHP-9010-PRA-001, PRA Model Update.
- 8. Does the preliminary risk review or detailed risk evaluation (RICE) demonstrate that defense-in-depth is maintained?
Yes. Continue to Item No. 9.
No. A License Amendment is required.
- 9. Does the preliminary risk review or detailed risk evaluation (RICE) demonstrate that safety margins are maintained?
Yes. Continue to Item No. 10.
No. A License Amendment is required.
CONCLUSION
- 10. Is a License Amendment required?
Yes. DO NOT implement the change driver until a License Amendment has been obtained by the NRC. Continue to Item No. 11.
No. Continue to Item No. 11.
- 11. Document the basis for the conclusion.
Basis:
The NFPA 805 License Condition allows for alternatives to NFPA 805, Chapter 3 that have been evaluated to be functionally equivalent or adequate for the hazard, depending on the section of Chapter 3 that is deviated from. The conditions/components evaluated in EEE-11-59 and EEE-12-24 do not deviate from NFPA 805, Chapter 3 requirements as discussed in the Description Section, thus no documented Engineering Equivalency Evaluation is required.
This removal of the EEEs from the Fire Protection Program documentation is found to be FPCE-2023-0002 Rev. 0 Page 4 of 13
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 5 of 6 an editorial change and no further evaluation is required.
All changes included in the attachments have been incorporated into the TDAC master files for issuance with the next periodic revision of the NFPPM.
- 12. List of Applicable Reference Documents:
DC Cook NFPA 805 SE, Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance Of Amendments Regarding Transition To A Risk-Informed, Performance-Based Fire Protection Program In Accordance With 10 CFR 50.48(c), (ML13140A398)
FSA, Rev. 5, Fire Safety Analysis NFPPM, Rev. 6, NFPA 805 Fire Protection Program Manual ITSA-U1/U2, Unit 1/Unit 2 Technical Specification Amendments NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances NFPA 13, Standard for the Installation of Sprinkler Systems, 1971 Edition NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 1973 Edition EEE-11-59, Rev. 1, Engineering Equivalency Evaluation for Unit 1 Turbine Building below Elevation 633-0 Water Fire Suppression System Sprinkler Head Deviations Fire Zones 90, 91, 92 & 93 (AA2)
EEE-12-24, Rev. 1, Engineering Equivalency Evaluation for NFPA 24 - Listed Valve Deviation 12-ZMO-400 & 401 GT 2023-2569, Complete FPCE to Remove EEE-11-59 from FPP Documentation GT 2023-2908, Complete FPCE to Remove EEE-12-24 from FPP Documentation
- 13. Configuration Document Impacts:
CDI Not Required/performed as part of Change Driver (Trivial/Administrative)
CDI NO. ______________________________________
- 14. Compensatory Actions Required:
Yes. Describe Necessary Actions:
No. There are no compensatory actions required for this Change.
FPCE-2023-0002 Rev. 0 Page 5 of 13
SIGNIFICANCE OF FIRE PROTECTION PROGRAM CHANGE EVALUATION This form is derived from the information in12-FPE-2270-FPCE-001, Rev. 10, Fire Protection Program Change Evaluation (FPCE), Data Sheet 1, Significance of Fire Protection Program Change Evaluation Page 6 of 6 15.
Does the Change Driver require an Applicability Determination review under 10 CFR 50.59 in accordance with PMP-2350-SES-001, 10 CFR 50.59 Reviews? IF a review is required, THEN arrange for a review under the 10 CFR 50.59 Reviews procedure.
Yes. Provide a cross reference to completed 50.59 product(s) below.
No. Editorial program change, no configuration changes.
Applicable 50.59 Products:
FPCE Preparer:
Matt Goddard Printed Name/Signature (Qualified FPE)
Date FPCE Reviewer:
Rod Pletz Printed Name/Signature (Qualified FPE)
Date Management Approval:
Bob May Printed Name/Signature Date Transmittal of Completed FPCE Package FPCE Transmitted to NDM Signature:
Date:
NFPPM FSA NSCA FPCE-2023-0002 Rev. 0 Page 6 of 13 Name/Signature (Qualified FPE) 5/10/2023 Name/Signature (Qualified FPE) 5/10/2023 Printed Name/Signature 5/11/2023 Signature:
FSA 5/11/2023
American Electric Power NFPA 805 Fire Protection Program Manual D. C. Cook Nuclear Plant Rev. 6 NFPPM Page 1 COOK NUCLEAR PLANT NFPA 805 FIRE PROTECTION PROGRAM MANUAL (NFPPM)
Rev. 6 Preparer:
Matt Goddard Signature Print Date Reviewer:
Rod Pletz Signature Print Date
- Supervisor\\
Manager Approval:
Bob May Signature Print Date
- The Supervisor/ Manager, responsible for the oversight of Fire Protection Engineering, approval signature serves to signify that the qualifications of the individual(s) assigned as Preparer and Reviewer were verified in the Plant Qualification Matrix.
Page 1 of 299 Signature 2/20/2023 Signature 2/21/2023 Signature 2/21/2023 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 7 of 13
Compliance Statement NFPA 805 Ch. 3 Ref Requirements/Guidance Compliance Basis Reference Document American Electric Power D. C. Cook Nuclear Plant NFPPM - Attachment 1 NFPA 805 Chapter 3 Fundamental FP Program and Design Elements - Appendix A Page 1A-77 Revision 6 The primary fire pumps can take suction from either of the tanks.
The two tanks are isolated by valves so that the failure of one tank will not affect the other tank.
The tanks have been designed in accordance with NFPA 22, as specified in DCC-CE-185-QCF.
Complies 3.5.2 [Water Supply Tank Code Requirements]
The tanks shall be interconnected such that fire pumps can take suction from either or both. A failure in one tank or its piping shall not allow both tanks to drain.
The tanks shall be designed in accordance with NFPA 22, "Standard for Water Tanks for Private Fire Protection."
Exception No. 1: Water storage tanks shall not be required when fire pumps are able to take suction from a large body of water (such as a lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated.
Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.
DCC-CE-185-QCF, Design, Fabrication, and Erection of the Dedicated Fire Protection Water Supply Storage Tanks OP-12-5152S, Fire Protection Water Piping at N & S Storage Tanks Units 1 & 2 Non-listed valves are installed in some portions of the fire protection system. These valves have been evaluated to be equivalent to NFPA requirements by Engineering Equivalency Evaluation 12.24.
Complies with Use of EEEEs Engineering Equivalency Evaluation 12-24, NFPA 24 -
Listed Valve Deviation 12-ZMO-400 & 401 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 125 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 8 of 13
Compliance Statement NFPA 805 Ch. 3 Ref Requirements/Guidance Compliance Basis Reference Document American Electric Power D. C. Cook Nuclear Plant NFPPM - Attachment 1 NFPA 805 Chapter 3 Fundamental FP Program and Design Elements - Appendix A Page 1A-81 Revision 6 Control room signals will alarm when fire pumps are operated.
Complies 3.5.9 [Water Supply Pump Operation Notification]
Means shall be provided to immediately notify the control room, or other suitable constantly attended location, of operation of fire pumps.
1-OHP-4024-101, Annunciator
- 101 Response: Plant Fire System
/ Drops 34, 44, and 54 2-OHP-4024-201, Annunciator
- 201 Response: Plant Fire System
/ Drops 34, 44, and 54 Plant Procedure 12-PPP-4030-066-006, Three Year Fire Protection Water System Unobstructed Flow Test An underground yard fire main loop is installed in accordance with NFPA 24.
Complies 3.5.10 [Water Supply Yard Main Code Requirements]
An underground yard fire main loop, designed and installed in accordance with NFPA 24, "Standard for the Installation of Private Fire Service Mains and Their Appurtenances," shall be installed to furnish anticipated water requirements.
Flow Diagram 12-5152 Series DCC-PV-108-QCS, Installation of Underground Piping RFC-12-3065, Installation of Dedicated Water Supply Transition Document Access Code - D.C. Cook Version 2.4.3 Page 129 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 9 of 13
Compliance Statement NFPA 805 Ch. 3 Ref Requirements/Guidance Compliance Basis Reference Document American Electric Power D. C. Cook Nuclear Plant NFPPM - Attachment 1 NFPA 805 Chapter 3 Fundamental FP Program and Design Elements - Appendix A Page 1A-82 Revision 6 Non-listed valves are installed in some portion of the fire protection system. These valves have been evaluated to meet the NFPA requirements by Engineering Equivalency Evaluation 12.24.
Complies with Use of EEEEs Engineering Equivalency Evaluation 12-24, NFPA 24 -
Listed Valve Deviation 12-ZMO-400 & 401 Isolating valves with post indicators or curb boxes are installed in the fire protection header so that the entire loop is not disabled should maintenance be required on a small section.
Complies 3.5.11 [Water Supply Yard Main Maintenance Issues]
Means shall be provided to isolate portions of the yard fire main loop for maintenance or repair without simultaneously shutting off the supply to both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.
RFC-12-3003 Flow Diagram 12-5152 Series Transition Document Access Code - D.C. Cook Version 2.4.3 Page 130 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 10 of 13
Compliance Statement NFPA 805 Ch. 3 Ref Requirements/Guidance Compliance Basis Reference Document American Electric Power D. C. Cook Nuclear Plant NFPPM - Attachment 1 NFPA 805 Chapter 3 Fundamental FP Program and Design Elements - Appendix A Page 1A-117 Revision 6 Refer to CNP "NFPA Code Deviations and Justifications" for NFPA 72D-1967 and NFPA 14-1971 for justifications to deviations related to this requirement.
Complies with Use of EEEEs CNP "NFPA Code Deviations and Justifications" The fire pump house structure is protected by a dry pilot preaction sprinkler system. Sprinklers are provided in each primary fire pump room.
Complies 3.9.4 [Fire Suppression System Diesel Pump Sprinkler Protection]
Diesel-driven fire pumps shall be protected by automatic sprinklers.
FSA, D. C. Cook Fire Safety Analysis All sprinkler systems are equipped with isolation valves.
Complies 3.9.5 [Fire Suppression System Shutoff Controls]
Each system shall be equipped with an OS&Y gate valve or other approved shutoff valve.
Flow Diagrams 5152 Series Transition Document Access Code - D.C. Cook Version 2.4.3 Page 165 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 11 of 13
Compliance Statement NFPA 805 Ch. 3 Ref Requirements/Guidance Compliance Basis Reference Document American Electric Power D. C. Cook Nuclear Plant NFPPM - Attachment 1 NFPA 805 Chapter 3 Fundamental FP Program and Design Elements - Appendix A Page 1A-118 Revision 6 Non-listed valves are installed in some portion of the fire protection system. These valves have been evaluated to meet the intent of the NFPA requirements by Engineering Equivalency Evaluation 12.26.
Complies with Use of EEEEs Engineering Equivalency Evaluation 12-24, NFPA 24 -
Listed Valve Deviation 12-ZMO-400 & 401 Engineering Equivalency Evaluation 12-26, NFPA 13 -
"NON-LISTED" & "NON-RISING STEM" VALVE DEVIATION 12-FP-389, 12-FP-493 AND 12-FP-494 Valves are supervised as required.
Valve positions are inspected on a monthly basis.
Complies with Clarification 3.9.6 [Fire Suppression System Valve Supervision]
All valves controlling water-based fire suppression systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.
1-OHP-4024-101, Annunciator
- 101 Response: Plant Fire System 1-OHP-4024-102, Annunciator
- 102 Response: Miscellaneous Areas Fire System 2-OHP-4024-201, Annunciator
- 201 Response: Plant Fire System 2-OHP-4024-202, Annunciator
- 202 Response: Miscellaneous Areas Fire System Procedure 12-FPP-4030-066-011, FIRE PROTECTION VALVE LINEUP VERIFICATION Transition Document Access Code - D.C. Cook Version 2.4.3 Page 166 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 12 of 13
American Electric Power NFPA Codes of Record Summary D. C. Cook Nuclear Plant Rev. 6 NFPPM - Attachment 2 Page 2-2
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- 1971, 1978, 1986 Standard for the Installation of Standpipe, Private Hydrant and Hose Systems Report 09-0120-0123 Report 09-0120-0381 Report 0120-108-005 Report 0120-164-003 Report 0120-164-007 Donald C. Cook Nuclear Plant NFPA Code Deviations and Justifications NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to License No.
DPR-58 and DPR-74, dated July 31, 1979 I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977 EEE-12-34, Evaluation of Deviation from NFPA 14, Chapter 4 NFPA 15 1973 Standard for Water Spray Fixed Systems for Fire Protection Report 09-0120-0123 Report 09-0120-0381 Report 0120-108-1375 Report 0120-164-004 Report 0120-164-007 EEE-11-41 EEE-12-20 EEE-12-22 Donald C. Cook Nuclear Plant NFPA Code Deviations and Justifications NFPA 16 N/A Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems N/A - No such systems at CNP NFPA 20 1990 Standard for the Installation of Stationary Pumps for Fire Protection EEE-11-62Donald C Cook Nuclear Plant NFPA Code Deviations and Justifications NFPA 22 1987 Standard for Water Tanks for Private Fire Protection EEE-11-77DCC-CE-185-QCF NFPA 24 1987 Standard for the Installation of Private Fire Service Mains and their Appurtenances EEE-11-78 EEE-12-24 DCC-PM-108-QCS RFC-12-3065 NFPA 27 1986 Private Fire Brigades N/A - NFPA 600 reviewed NFPA 30 1987 Flammable and Combustible Liquids Code NFPA 30 Code Compliance Evaluation for Donald C. Cook Nuclear Plant Unit 1 and 2 Donald C. Cook Nuclear Plant NFPA Code Deviations and Justifications Page 229 of 299 FPCE-2023-0002 Attachment 1 FPCE-2023-0002 Rev. 0 Page 13 of 13