ML25307A099
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 5 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:
AR 2024-2507 FPCE No.:
FPCE-2024-0012__________
- 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-9-41, Engineering Equivalency Evaluation for Fire Zones 37 (AA36/42) and 51 (AA3)
Barrier Evaluation, Revision 1, incorporated evaluation of non-fire rated brass plugs in penetrations between the hot tool crib and the demineralizer valve gallery.
Revision to EEE-9-41 impacts the Fire Safety Analysis (FSA), the NFPA 805 Fire Protection Program Manual (NFPPM), and the Plant Boundary Definition and Partitioning evaluation (R1900-0041-0001).
Reference to EEE-9-41 will be added to section 3.1.3, Penetrations, in the Fire Safety Analysis for AA3 and AA36/42 and the summary of the EEE will be updated in Attachment 1, Table B Fire Area Transition for AA3 and AA36/42.
EEE-9-41 will be added as a reference to sections 3.11.4 and 3.11.4(a) of the NFPPM for complies with use of EEEEs. The title of EEE-9-41 will also be updated in the references for section 3.11.3(2).
Description of EEE9-41 will be added to the Penetrations section for Boundary AA3 /
AA36/42 in R1900-0041-001.
- 4. Based on review of the Change Driver and all supporting documentation, determine if additional Program Documents are impacted:
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.
FPCE-2024-0012 Rev. 0 Page 1 of 40
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 5
- 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 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 FPCE-2024-0012 Rev. 0 Page 2 of 40
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 5 Evaluate each section that the FPP change applies to:
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
- 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.
FPCE-2024-0012 Rev. 0 Page 3 of 40
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 5 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:
EEE-9-41, Rev. 1, was completed in accordance with the process in 12-FPE-2270-EVL-001, Preparation and Approval of Fire Protection Engineering Equivalency Evaluations.
This EEE falls in the adequate for the hazard evaluation category of self-approval per the license condition and is therefore acceptable without prior NRC review and approval.
All changes included in the FSA and NFPPM attachments have been incorporated into the TDAC master files for issuance with the next periodic revisions of the FSA and 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, Rev. 86, Unit 1 Technical Specification Amendments ITSA-U2, Rev. 82, Unit 2 Technical Specification Amendments 12-FPE-2270-EVL-001, Rev. 5, Preparation and Approval of Fire Protection Engineering Equivalency Evaluations EEE-9-41, Rev. 1, Engineering Equivalency Evaluation for Fire Zones 37 (AA36/42) and 51 (AA3) Barrier Evaluation FPCE-2024-0012 Rev. 0 Page 4 of 40
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 5
- 13. Configuration Document Impacts:
CDI Not Required/performed as part of Change Driver CDI NO. GT 2024-6867__________________________
- 14. Compensatory Actions Required:
Yes. Describe Necessary Actions:
No. There are no compensatory actions required for this Change.
- 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. No plant change is involved with this program change.
Applicable 50.59 Products:
FPCE Preparer:
Matt Goddard Printed Name/Signature (Qualified FPE)
Date FPCE Reviewer:
Ken Housh 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 9/16/2024 9/16/2024 9/16/2024 9/16/2024 FPCE-2024-0012 Rev. 0 Page 5 of 40
D. C. Cook Nuclear Plant Fire Safety Analysis (FSA)
Revision: 5 Prepared by:
Matt Goddard Signature Print Date Reviewed by:
Rod Pletz Signature Print Date Approved by:
Bob May Signature Print Date FSA Rev. 5 Page 1 of 1300 8/10/2021 8/11/2021 8/11/2021 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 6 of 40
Fire Area AA3 D. C. Cook Fire Safety Analysis (FSA)
For Fire Zone 49, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. Additionally, the penetrations in the fire barriers to the N-Train Battery Room (Fire Zone 106) and the east wall to the yard are also sealed. However, barriers between this fire zone and the other adjacent fire zones are not fire sealed. Seismic gaps are sealed with a glass fiber reinforced silicone sheeting. Seismic gap exemption was granted for Fire Zone 49 interface with Fire Areas AA7, AA37, AA3 and AA2 - Fire Zones 7, 38, 69 and 108 (Engineering Equivalency Evaluation 11-46).
For Fire Zone 50, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. Additionally, the penetrations in the fire barriers to the N-Train Battery Room, Fire Zone 107, are also sealed. However, barriers between this fire zone and adjacent fire zones are not fire sealed. Seismic gaps are sealed with a glass fiber reinforced silicone sheeting.
Seismic gap exemption was granted for Fire Zone 50 interface with Fire Zone AA31, AA38, AA3 and AA2 - Fire Zones 27, 39, 69, 108 and 109 (Engineering Equivalency Evaluation 11-46).
For Fire Zone 51, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. Penetrations into the elevator shaft are also sealed. However, barriers between this fire zone and adjacent fire zones are not fire sealed.
For Fire Zone 52, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. Additionally, the penetrations in the fire barriers to the N-Train Battery Room (Fire Zone 106) and the elevator shaft are also sealed. However, barriers between this fire zone and the other adjacent fire zones are not fire sealed.
For Fire Zone 69, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. However, barriers between this fire zone and adjacent fire zones are not fire sealed. Seismic gaps are sealed with a glass fiber reinforced silicone sheeting. Seismic gap exemption was granted for Fire Zone 69 interface with Fire Areas AA7, AA31, AA37, AA38 and AA2 - Fire Zones 7, 27, 38, 39 and 108, 109 respectively.
For Fire Zone 106, penetrations in fire barriers between this fire zone and adjacent fire zones and fire areas are provided with fire seals.
For Fire Zone 107, penetrations in fire barriers between this fire zone and adjacent fire areas and fire zones are provided with fire seals.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA3-7 FSA Rev. 5 Page 109 of 1300 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 7 of 40 For Fire Zone 51, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. Penetrations into the elevator shaft are also sealed. However, barriers between this fire zone and adjacent fire zones are not fire sealed. A boundary evaluation has been performed for unrated brass plugs installed in the floor of the zone interfacing with Fire Zone 37 (Engineering Equivalency Evaluation 9-41).
Fire Area AA3 - Attachment 1 Fire Area AA3 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA3 Unit 1 and Unit 2 Auxiliary Building and Fuel Handling Areas (El. 609 ft., 633 ft. and 650 ft.)
1, 2 Engineering Equivalency Evaluation 9 Fire Zone 69 (Fire Area AA3) to Fire Zones 108 (Fire Area AA2) and 109 (Fire Area AA2)
Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of undampered containment instrumentation room exhaust ductwork that penetrate the barriers separating Fire Zone 69 (Fire Area AA3) from Fire Zones 108 (Fire Area AA2) and 109 (Fire Area AA2). The purpose of this engineering equivalency evaluation is to demonstrate that it does not adversely impact other engineering equivalency evaluations or exemption requests.
The undampered piping/ductwork does not affect safe shutdown due to the low combustible loading, automatic detection in Fire Zone 69, and a lack of credible fire events (based on this and previous engineering equivalency evaluations involving these areas). This engineering equivalency evaluation does not adversely impact other engineering equivalency evaluations or exemption requests.
The penetrations were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the evaluated areas.
Summary EEEE Title Engineering Equivalency Evaluation 9 Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3) HVAC Duct Penetrations The purpose of this engineering equivalency evaluation is to document the acceptability of 15 undampered HVAC penetrations connecting the 617 ft. and 633 ft. elevations of the Auxiliary Building between Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3).
Reasonable assurance is provided that a fire starting from Fire Zones 37 and/or 44N and propagating through the undampered ducts to Fire Zone 51 and 52 will not adversely impact safe shutdown capabilities of CNP. This engineering equivalency evaluation also verifies that there is no adverse impact to other engineering equivalency evaluations.
The HVAC penetrations were evaluated and found to be acceptable based on the fire protection systems and construction features within the evaluated areas.
Summary EEEE Title Page AA3-A1-6 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 135 of 1300 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 8 of 40 Engineering Equivalency Evaluation 9 Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3) Barrier Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of 15 undampered HVAC penetrations and four penetration sleeves sealed with brass plugs connecting the 617 ft. and 633 ft. elevations of the Auxiliary Building between Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3).
Reasonable assurance is provided that the undampered ducts or non-rated sealed brass plugs between Fire Zones 37 and 51 are adequate for the hazards present to prevent a fire starting in Fire Zones 37 and/or 44N from propagating through the unrated features of the barrier and will not adversely impact the ability of CNP achieve and maintain safe and stable condition. This engineering equivalency evaluation also verifies that there is no adverse impact to other engineering equivalency evaluations.
The HVAC penetrations and non-rated brass plugs were evaluated and found to be acceptable based on the fire hazards and construction features within the evaluated areas.
Fire Area AA36/42 D. C. Cook Fire Safety Analysis (FSA) to Fire Zone 39 is held open with a 160°F-165°F fusible link and CO2 pop-off arrangement for HVAC ventilation concerns. This door is to close following a HELB that occurs in Fire Zone 34 or 34A. An open stairway protected by a water curtain connects the 609 ft. elevation of the Auxiliary Building with the 587 ft. elevation (Fire Area AA5/6 - Fire Zone 6S) and the 633 ft. elevation (Fire Area AA3 - Fire Zone 52). A fire area boundary evaluation was performed for the rated and unrated fire barriers of the stairwells and elevators located in the Auxiliary Building (Engineering Equivalency Evaluation 11-12).
3.1.3 Penetrations For Fire Zone 37, penetrations in fire walls between this fire zone and adjacent fire areas are provided with fire seals. Barriers between this fire zone and adjacent fire zones are fire sealed with the exception of the walls between Fire Zone 37 and Fire Zones 44A, 44E and 44N. The penetrations in the floor between this fire zone and adjacent Fire Area 6A are unsealed and covered with lead plates attached to the ceiling of Fire Zone 6A.
For Fire Zone 43, Penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals. However, barriers between this fire zone and adjacent fire zones are not fire sealed with the exception of the barriers to Fire Zone 44N which are sealed for ventilation reasons.
For Fire Zones 44A, 44B, 44C, 44D, 44E, 44F, 44G and 44H, penetrations in fire barriers between this fire zone and adjacent fire areas are provided with fire seals except as noted below. However, barriers between this fire zone and adjacent fire zones are not fire sealed. A fire area boundary evaluation was performed for an open penetration shaft to Fire Area AA1 - Fire Zone 1A and Fire Area AA54 - Fire Zone 62A (Engineering Equivalency Evaluation 9-31).
For Fire Zone 44N, penetrations in fire barriers between this fire zone and adjacent fire areas and the elevator shaft are provided with fire seals except as noted below. However, barriers between this fire zone and adjacent fire zones are not fire sealed with the exception of the barriers to Fire Zone 43 which are sealed for ventilation reasons. A fire area boundary evaluation was performed for unrated 8-inch thick silicone foam fire seals installed between this fire zone and Fire Area AA48 - Fire Zone 56 (Engineering Equivalency Evaluation 11-4).
For Fire Zone 44S, penetrations in fire barriers between this fire zone and adjacent fire areas and the elevator shaft are provided with fire seals except as noted below. However, barriers between this fire zone and adjacent fire zones are not fire sealed.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA36/42-4 FSA Rev. 5 Page 664 of 1300 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 9 of 40 For Fire Zone 37, penetrations in fire walls between this fire zone and adjacent fire areas are provided with fire seals. Barriers between this fire zone and adjacent fire zones are fire sealed with the exception of the walls between Fire Zone 37 and Fire Zones 44A, 44E and 44N. The penetrations in the floor between this fire zone and adjacent Fire Area 6A are unsealed and covered with lead plates attached to the ceiling of Fire Zone 6A. A boundary evaluation has been performed for unrated brass plugs installed in the ceiling of the zone interfacing with Fire Zone 51 (Engineering Equivalency Evaluation 9-41).
Fire Area AA36/42 D. C. Cook Fire Safety Analysis (FSA) 3.1.7 Ventilation A fire in this area will be contained by the fire barriers. Smoke can be removed by portable fans and flexible ducting to other areas of the Auxiliary Building and outdoors if not contaminated.
Contaminated smoke can be removed by portable fans and flexible ducting to other areas of the Auxiliary Building per the Fire Pre-Plans. The normal building ventilating systems in the Auxiliary Building will then exhaust the smoke via filtered monitored pathways.
For Fire Zone 37, there are undampered ventilation penetrations to the adjacent Fire Zone 44N (in the pipe tunnel vertical area).
For Fire Zone 43, fire dampers having a 1 1/2-hour rating are provided to adjacent Fire Area AA48 - Fire Zone 56.
For Fire Zone 44N, There are undampered ventilation penetrations to the adjacent Fire Zones 37 and 43. A fire damper having a 1 1/2-hour rating is provided to adjacent Fire Area AA48 - Fire Zone 56. Fire dampers having a 3-hour rating are provided to adjacent Fire Areas AA37, AA48, AA50 and AA51 - Fire Zones 38, 56, 57 and 58, respectively.
For Fire Zone 44S contains a 3-hour fire damper. This damper is located in the wall separating this fire zone from Fire Zone 39. Fire dampers having a 3-hour rating are provided to adjacent Fire 3.1.6 Manual Suppression / Response Strategy For fire zones within AA36/42 equipped with automatic detection systems, a postulated fire will be identified by early detection using ionization type smoke detection or by plant personnel using plant communication system to notify the control room. The automatic detection system alarms in the control room. For fire zones within AA36/42 which are not equipped with automatic detection systems, a postulated fire will be identified by plant personnel using plant communication system to notify the control room. The Control Room operator will dispatch the fire brigade for initiation of manual fire fighting. A fire in this fire area will be contained by the construction features discussed in Section 3.1.1. Manual suppression is provided by the CNP Fire Brigade.
Fire Zone 43 is equipped with fire extinguishers with fire hose standpipes located in adjacent Fire Zones 44N and 91.
Fire extinguishers and fire hose standpipes are located in Fire Zones 44N and 44S. Fire Zone 44S is equipped with an extra hose reel of 100 ft. The equipment in these fire zones are accessible to other fire zones within this fire area. [Ref. AR 2017-7900]
Floor drains are available in Fire Zones 37, 43, 44N and 44S.
Floor drains are not available in Fire Zones 44A through 44H. A sump in each room drains below to a sump in Fire Zones 1A through 1H, respectively.
Sprinkler protection is provided beneath the wrapped cable trays to assure the 20 ft. combustible free area is maintained and adequate sprinkler coverage is provided as the cable wrapping blocked the overhead sprinklers.
Other fire zones within this fire area are not provided with fixed suppression systems.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA36/42-7 FSA Rev. 5 Page 667 of 1300 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 10 of 40 For Fire Zone 37, there are undampered ventilation penetrations to the adjacent Fire Zone 44N (in the pipe tunnel vertical area). A fire area boundary evaluation was performed for undampered ventilation penetrations to the adjacent Fire Area AA3 - Fire Zone 51 (Engineering Equivalency Evaluation 9-41)
Fire Area AA36/42 - Attachment 1 Fire Area AA36/42 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA36/42 Auxiliary Building (El. 609 ft.)
1, 2 Engineering Equivalency Evaluation 9 Fire Zones 63A, 63B and 63C (Fire Area AA56) Boundary Evaluations The purpose of this engineering equivalency evaluation is to document the acceptability of steel plate covered access openings to vertical chases/leakage detection boxes in Fire Zones 63A, 63B and 63C (all in Fire Area AA56) that connect the RHR and containment spray pumps below with their heat exchangers above.
Reasonable assurance is provided that a fire in the vicinity of the vertical chases/leakage detection boxes passing through Fire Zones 63A, 63B and 63C would not impair safe shutdown capabilities of CNP or impact on the full area suppression exemption request for the 573 ft.
elevation of the Auxiliary Building. This engineering equivalency evaluation does not adversely impact other engineering equivalency evaluations.
The unprotected access opening steel plate covers were evaluated and found to be acceptable based on the fire hazards, fire protection systems and construction features within the evaluated areas.
Summary EEEE Title Engineering Equivalency Evaluation 9 Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3) HVAC Duct Penetrations The purpose of this engineering equivalency evaluation is to document the acceptability of 15 undampered HVAC penetrations connecting the 617 ft. and 633 ft. elevations of the Auxiliary Building between Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3).
Reasonable assurance is provided that a fire starting from Fire Zones 37 and/or 44N and propagating through the undampered ducts to Fire Zone 51 and 52 will not adversely impact safe shutdown capabilities of CNP. This engineering equivalency evaluation also verifies that there is no adverse impact to other engineering equivalency evaluations.
The HVAC penetrations were evaluated and found to be acceptable based on the fire protection systems and construction features within the evaluated areas.
Summary EEEE Title Page AA36/42-A1-11 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 713 of 1300 0902969c844a8a2c FPCE-2024-0012 Rev. 0 Page 11 of 40 Engineering Equivalency Evaluation 9 Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3) Barrier Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of 15 undampered HVAC penetrations and four penetration sleeves sealed with brass plugs connecting the 617 ft. and 633 ft. elevations of the Auxiliary Building between Fire Zones 37 (Fire Area AA36/42) and 51 (Fire Area AA3).
Reasonable assurance is provided that the undampered ducts or non-rated sealed brass plugs between Fire Zones 37 and 51 are adequate for the hazards present to prevent a fire starting in Fire Zones 37 and/or 44N from propagating through the unrated features of the barrier and will not adversely impact the ability of CNP achieve and maintain safe and stable condition. This engineering equivalency evaluation also verifies that there is no adverse impact to other engineering equivalency evaluations.
The HVAC penetrations and non-rated brass plugs were evaluated and found to be acceptable based on the fire hazards and construction features within the evaluated areas.
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 2/20/2023 2/21/2023 2/21/2023 FPCE-2024-0012 Rev. 0 Page 12 of 40
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-145 Revision 6 Engineering Equivalency Evaluation 9-5, Fire Zones 70 (AA57A) and 73 (AA57B) Hatch Evaluations Procedure 12-FPE-2270-FPCE-001, Fire Protection Program Change Evaluation All ventilation dampers carry UL Class A (3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) fire rating or a UL Class B (1-1/2 hour) rating to be commensurate with the severity of the hazard as determined by the performance requirements established by Chapter 4 of NFPA 805. I&M has committed CNP to comply with NFPA 90A.
Modifications to rated fire dampers are made in accordance with NFPA 90A in order to ensure that the fire protection features of the damper are not degraded.
Complies 3.11.3(2) [NFPA 90A - Fire Damper Requirements]
Passive fire protection devices such as doors and dampers shall conform with the following NFPA standards, as applicable:
(2) NFPA 90A, "Standard for the Installation of Air-Conditioning and Ventilating Systems" Procedure 12-FPE-2270-FPCE-001, Fire Protection Program Change Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 193 of 299 FPCE-2024-0012 Rev. 0 Page 13 of 40
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-146 Revision 6 Technical specification-related fire dampers and HVAC system designs have been reviewed by the NRC for damper placement and ratings. These dampers have also been reviewed by I&M for rating and installation.
Per letter from I&M to the NRC dated June 15, 1984:
"In the area of HVAC ductwork, we have recently discovered that technical exemptions are required for 17 ducts which penetrate fire barriers. These areas are typified by low combustible loading, and duct outlets being located in an area sufficiently removed from equipment important to the safe shutdown of the facility. Sound engineering evaluations can be used to justify our request for technical exemption of the requirements for fire dampers.
Per letter from I&M to the NRC dated August 13, 1984:
The evaluation concludes that, because of a low combustible loading of less than 15 minutes in all applicable fire areas/zones, the location of safe shutdown components/circuits and the detection and suppression systems available in the subject fire area/zones, adequate protection from duct related fire damage is Complies by Previous NRC Approval NRC Safety Evaluation of Fire Protection Requests, dated August 27, 1985 / Section 3.4 I&M Letter 0692R, Request for Additional Technical Exemptions to Certain Fire dampers and "Seismic Gaps", dated June 15, 1984 I&M Letter 0692U, Appendix R Technical Exemption for Seismic Gaps and HVAC Duct Penetrations, dated August 13, 1994 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 194 of 299 FPCE-2024-0012 Rev. 0 Page 14 of 40
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-147 Revision 6 provided and safe shutdown capability is ensured. As discussed with your staff, the evaluation includes five additional ventilation duct penetrations without fire dampers, that also require technical exemptions. These duct penetrations listed below were not identified in the June 15, 1984 letter.
The NRC Safety Evaluation, dated August 27, 1985 states:
Based on our evaluation, we conclude that we have reasonable assurance that the 22 Auxiliary Building undampered ventilation duct penetrations will not affect safe-shutdown in the event of a fire in Fire Area A, B, C, D or E. The lack of fire dampers in these 22 ventilation duct penetrations is, therefore, an acceptable deviation from the guidelines of Section D.l.(j) of Appendix A to BTP APCSB 9.5-1.
The 22 undampered ventilation duct penetrations, as approved by the SE Report, still exist at CNP.
There have been no plant modifications or other changes that would invalidate the basis for approval. The justification for the ventilation ducts remains valid and unchanged.
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 195 of 299 FPCE-2024-0012 Rev. 0 Page 15 of 40
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-148 Revision 6 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 196 of 299 FPCE-2024-0012 Rev. 0 Page 16 of 40
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-149 Revision 6 Engineering equivalency evaluations have been performed for any unrated dampers located in fire area boundaries. These engineering equivalency evaluations determined the dampers are equivalent or adequate for the hazard.
Complies with Use of EEEEs Engineering Equivalency Evaluation 11-14, Cable Tunnel and Cable Vault Fire Damper Evaluation (Fire Areas AA8, AA9, AA10, AA29, AA30, AA34, AA35, AA36/42, AA37, AA38, AA48, and AA52)
Engineering Equivalency Evaluation 11-15, Switchgear Room Construction Boundary Room Evaluation Unit 1 Fire Zones 41 and 42A (AA40 and AA41) & Unit 2 Fire Zones 45 and 46A ( AA43 and AA44)
Engineering Equivalency Evaluation 11-16, ENGINEERING EQUIVALENCY EVALUATION FOR LUBE OIL STORAGE ROOMS FIRE ZONES 83, 88, 95 AND 100 (AA2), BOUNDARY EVALUATION Engineering Equivalency Evaluation 11-45, Auxiliary Building HVAC Duct Penetrations Boundary Evaluation Fire Areas AA1, AA3, AA5/6, AA36 and AA42 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 197 of 299 FPCE-2024-0012 Rev. 0 Page 17 of 40
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-150 Revision 6 Engineering Equivalency Evaluation 11-56, Turbine Building Main Steam Access Way Fire Zones 110 to 114, Fire Zones 111 to 115, Fire Zones 112 to 2N, Fire Zones 113 to 2S (Fire Areas AA2A, AA2B, AA2C)
Engineering Equivalency Evaluation 11-8, Engineering Equivalency Evaluation 11-8, Yard to Fire Zones 34 (AA35),
34A (AA35), 90 (AA2), 97 (AA2), 129 (AA2), and 130 (AA2) Boundary Evaluations Engineering Equivalency Evaluation 12-13, Fire Damper Closure Review Engineering Equivalency Evaluation 9-1, Fire Zone 43 (AA36) and 91 (AA2A) Duct Evaluation Engineering Equivalency Evaluation 9-2, Fire Zone 54 (AA47) and Fire Zone 73 (AA57B) Duct Evaluation Engineering Equivalency Evaluation 9-3, CCW Pump Air Supply Duct Evaluation: Fire Zone 44S (AA42)
Engineering Equivalency Evaluation 9-33, Fire Zone 6A (AA5/6) to 138B (AA1)
Boundary Evaluations Transition Document Access Code - D.C. Cook Version 2.4.3 Page 198 of 299 FPCE-2024-0012 Rev. 0 Page 18 of 40
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-151 Revision 6 Engineering Equivalency Evaluation 9-34, Fire Zone 36 (AA3) to Fire Zone 5 (AA5/6)
Boundary Evaluation Engineering Equivalency Evaluation 9-35, Fire Zone 108 (AA2A) to Fire Zone 33A (AA34) Boundary Evaluation Engineering Equivalency Evaluation 9-36, Fire Zone 109 (AA2B) to 34A (AA35)
Boundary Evaluation Engineering Equivalency Evaluation 9-37, Fire Zones 5 (AA5/6) and 32 (AA3) Boundary Evaluations Engineering Equivalency Evaluation 9-38, Fire Zone 69 (AA3) to Fire Zones 108 (AA2A) and 109 (AA2B) Boundary Evaluations Engineering Equivalency Evaluation 9-4, Auxiliary Building Vertical Air Shafts Evaluation: Fire Zones 12 (AA11) and 22 (AA27)
Engineering Equivalency Evaluation 9-40, Fire Zone 7 (AA7) to Fire Zone 61 (AA5/6)
Boundary Elevation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 199 of 299 FPCE-2024-0012 Rev. 0 Page 19 of 40
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-152 Revision 6 Engineering Equivalency Evaluation 9-41, Fire Zones 37 (AA36) and 51(AA3) HVAC Duct Penetrations Engineering Equivalency Evaluation 9-7, Transformer Room Fire Zone 14 (AA13) to Fire Zones 13 (AA12) and 79 (AA2) Fire Damper Evaluation Engineering Equivalency Evaluation 9-8, Transformer Room Fire Zone 20 (AA25) to Fire Zones 21 (AA26) and 85 (AA2) Fire Damper Evaluation CNP complies with clarification with regards to NFPA 101, 2000 Edition. NFPA 101 compliance is achieved through NFPA 80 and NFPA 90A. NFPA 101, 2000 Edition, Section 8.2.3.2.1(a) with regards to rated fire door assemblies refers to NFPA 80.
NFPA 101, 2000 Edition, Section 9.2.1 with regards to rated fire dampers refers to NFPA 90A.
Table B-1, Section 3.11.3(1) and 3.11.3(2) discuss compliance of NFPA 80 and NFPA 90A.
Complies with Clarification 3.11.3(3) [NFPA 101 - Life Safety Code Requirements]
Passive fire protection devices such as doors and dampers shall conform with the following NFPA standards, as applicable:
(3) NFPA 101, "Life Safety Code" NFPA 101, Life Safety Code, 2000 Edition / Sections 8.2.3.2.1(a) and 9.2.1 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 200 of 299 FPCE-2024-0012 Rev. 0 Page 20 of 40 Engineering Equivalency Evaluation 9-41, Fire Zones 37 (AA36) and 51(AA3) Barrier Evaluation
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-153 Revision 6 CNP specification ES-FIRE-0601-QCF details the requirements for the installation and maintenance of fire rated seals and fire stops at CNP. The scope of this specification is for penetration seals that are installed or are being installed at CNP that will function to prevent the spread of fire.
Additionally, per specification ES-FIRE-0601-QCF, CNP allows the use of additional test standards ASTM E-814, MEEB 634 and NFPA 251 for development of standard fire test, and qualification of fire rated penetration seals.
Complies 3.11.4 Through Penetration Fire Stops Through penetration fire stops for penetrations such as pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, and similar building service equipment that pass through fire barriers shall be protected as follows.
Plant Specification ES-FIRE-0601-QCF, Fire Rated Seals Transition Document Access Code - D.C. Cook Version 2.4.3 Page 201 of 299 FPCE-2024-0012 Rev. 0 Page 21 of 40
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-154 Revision 6 By the response to Appendix A to Branch Technical Position APCSB 9.5-1, dated January 31, 1977, item D.1.(j) I&M stated:
"all openings for cable, pipe, and ductwork in these walls, floors, and ceilings have been sealed with foamed in place silicone which was tested in march 1975 for up to five hours fire exposure in an ASTM E 119 wall fire test."
The NRC Safety Evaluation, dated July 31, 1979 states:
"The test report shows that the penetration seal passed a 3-hour E-119 type fire exposure test.
However, the test included only the Unit 2 penetration design. The licensees have provided a comparison between Unit 1 and Unit 2 penetration seal designs to justify that the Unit 2 design is the "worst case" for fire testing. We agree with this evaluation and conclude that the Unit 2 seal tests are acceptable for the Unit 1 seals.
We conclude that the penetration fire stops which are in place provide sufficient protection from the unbounded spread of fire along electrical cables. We base this conclusion on our knowledge of ASTM E-119 fire tests including those cited by the licensees which substantiate the fire resistive ability of penetration fire stops Complies by Previous NRC Approval NRC Safety Evaluation, dated July 31, 1979 / Page 13, Other Items Relating to the Station Fire Prtotection Program, Section A I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977 /
Section D.1.(j)
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 202 of 299 FPCE-2024-0012 Rev. 0 Page 22 of 40
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-155 Revision 6 constructed with silicone foam."
The foamed in place silicone design, as approved by the SE Report, is still in use at CNP.
There have been no plant modifications or other changes that would invalidate the basis for approval. The foamed in place silicone design and the justification of the worst case configuration has not changed.
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 203 of 299 FPCE-2024-0012 Rev. 0 Page 23 of 40
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-156 Revision 6 Where through penetration fire stops are not protected in accordance with Section 3.11.4, these assemblies have been evaluated to be equivalent or adequate for the hazard.
Complies with Use of EEEEs Engineering Equivalency Evaluation 11-15, Switchgear Room Construction Boundary Room Evaluation Unit 1 Fire Zones 41 and 42A (AA40 and AA41) & Unit 2 Fire Zones 45 and 46A ( AA43 and AA44)
Engineering Equivalency Evaluation 11-16, ENGINEERING EQUIVALENCY EVALUATION FOR LUBE OIL STORAGE ROOMS FIRE ZONES 83, 88, 95 AND 100 (AA2), BOUNDARY EVALUATION Engineering Equivalency Evaluation 11-17, Diesel Generator Fuel oil Day Tank Rooms Fire Zones 15 (AA14), 16 (AA15), 18 (AA23) and 19 (AA24) Boundary Evaluation Engineering Equivalency Evaluation 11-2, Fire Zone 7 (AA7) to Fire Zone 38 (AA37)
Boundary Evaluation Engineering Equivalency Evaluation 11-24, Fire Retention Capability of Nonconforming Fire Seals in Fire Zones having a Low Fire Severity Transition Document Access Code - D.C. Cook Version 2.4.3 Page 204 of 299 FPCE-2024-0012 Rev. 0 Page 24 of 40
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-157 Revision 6 Engineering Equivalency Evaluation 11-26, Fire Retention Capability of a HELB 3 Pressure Boundary Seal (Fire Areas AA19, AA20, AA21 and AA22)
Engineering Equivalency Evaluation 11-27, Generic Fire Seal Design 1 Engineering Equivalency Evaluation 11-28, Generic Fire Seal Design 2 (Fire Areas AA7, AA8, AA39A, AA40, AA43, AA45A, AA45B, AA48 and AA52)
Engineering Equivalency Evaluation 11-29, Generic Fire Seal Design 3 in Fire Areas AA2A, AA2B, and AA15 Engineering Equivalency Evaluation 11-3, Fire Zone 27 (AA31) to Fire Zone 39 (AA38)
Engineering Equivalency Evaluation 11-31, Generic Fire Seal Design 5 (Fire Areas AA31 and AA38)
Engineering Equivalency Evaluation 11-33, Generic Fire Seal Design 7 (Fire Areas AA7 and AA37)
Engineering Equivalency Evaluation 11-34, Generic Fire Seal Design 8 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 205 of 299 FPCE-2024-0012 Rev. 0 Page 25 of 40
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-158 Revision 6 Engineering Equivalency Evaluation 11-35, Generic Fire Seal Design 9 Engineering Equivalency Evaluation 11-4, Unit 1 Auxiliary Building Elevation 620 ft.-6 in. to Auxiliary Cable Vault Fire Zone 44n to Fire Zone 56 Engineering Equivalency Evaluation 11-47, Fire Zones 44N (AA36), 44S (AA42) and 52 (AA3) Penetration Seals Engineering Equivalency Evaluation 11-48, Unit 1 & 2 Emergency Diesel Generator Rooms AB/CD Large Bore Pipe Penetrations - Fire Zones 11 (AA10), 16 (AA15) 18 (AA23) and 23 (AA29) Penetration Seals Engineering Equivalency Evaluation 11-5, Unit 1 EPS/4 KV Switchgear Complex Ventilation Shaft Boundary Evaluation (Fire Areas AA39A, AA39B, AA40, AA41 and AA48)
Engineering Equivalency Evaluation 11-50, Embedded Conduit Fire Wrap Protection (Fire Areas AA14 and AA24)
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 206 of 299 FPCE-2024-0012 Rev. 0 Page 26 of 40
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-159 Revision 6 Engineering Equivalency Evaluation 11-51, Screenhouse and Water Intake System Boundary Evaluation Fire Zone 142 (AA2A) to Fire Zone 143 (YD)
Engineering Equivalency Evaluation 11-54, Unit 1 Main Control Room Cable Vault Penetration Seal W5111 Fire Zone 57 and 91 (Fire Areas AA50 and AA2A)
Engineering Equivalency Evaluation 11-56, Turbine Building Main Steam Access Way Fire Zones 110 to 114, Fire Zones 111 to 115, Fire Zones 112 to 2N, Fire Zones 113 to 2S (Fire Areas AA2A, AA2B, AA2C)
Engineering Equivalency Evaluation 11-58, Unit 2 Control Room Fire Rated Floor Penetration Seals Fire Zones 54 (Fire Area AA47) and 58 (Fire Area AA51)
Engineering Equivalency Evaluation 11-6, Fire Zones 45 (AA43), 46A through 46D (AA44), 47A (AA45A), 47B (AA45B) to Fire Zone 60 (AA52)
Shaft Boundary Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 207 of 299 FPCE-2024-0012 Rev. 0 Page 27 of 40
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-160 Revision 6 Engineering Equivalency Evaluation 11-60, Engineering Equivalency Evaluation 11-60, Fire Zone 80/114 and 84/115 (Fire Areas AA2 and AA2C)
Boundary Evaluation Engineering Equivalency Evaluation 11-7, Fire Zone 5 (AA5/6) to Unit 1 Fire Zones 62A, 62B and 62C (AA54) and Unit 2 Fire Zones 63A, 63B and 63C (AA5) Removable Block Walls Engineering Equivalency Evaluation 11-79, Fire Zone 53 (AA46) And Fire Zone 57 (AA50) Fire Barrier Penetration Seals Engineering Equivalency Evaluation 11-8, Engineering Equivalency Evaluation 11-8, Yard to Fire Zones 34 (AA35),
34A (AA35), 90 (AA2), 97 (AA2), 129 (AA2), and 130 (AA2) Boundary Evaluations Engineering Equivalency Evaluation 11-80, Fire Zone 54 (AA47) And Fire Zone 58 (AA51) Fire Barrier Penetration Seals Engineering Equivalency Evaluation 11-83, Unrated Containment Penetrations Transition Document Access Code - D.C. Cook Version 2.4.3 Page 208 of 299 FPCE-2024-0012 Rev. 0 Page 28 of 40
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-161 Revision 6 Engineering Equivalency Evaluation 9-35, Fire Zone 108 (AA2A) to Fire Zone 33A (AA34) Boundary Evaluation Engineering Equivalency Evaluation 9-36, Fire Zone 109 (AA2B) to 34A (AA35)
Boundary Evaluation Engineering Equivalency Evaluation 9-37, Fire Zones 5 (AA5/6) and 32 (AA3) Boundary Evaluations Technical Evaluation-11-20, Narrow Space Openings between Penetrating Items and the Barrier or Between Penetrating Items Boundary Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 209 of 299 FPCE-2024-0012 Rev. 0 Page 29 of 40 Engineering Equivalency Evaluation 9-41, Fire Zones 37 (AA36) and 51(AA3) Barrier Evaluation
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-162 Revision 6 CNP specification ES-FIRE-0601-QCF details the requirements for the installation and maintenance of fire rated seals and fire stops at CNP. The scope of this specification is for penetration seals that are installed or will be installed at CNP that will function to prevent the spread of fire. Per this specification, the contractor installing the fire seals must furnish documentation that the configurations have passed ASTM E-119 fire and hose stream tests that have been performed and documented by an independent laboratory.
Additionally, per specification ES-FIRE-0601-QCF, the standards which can be used for development of standard fire test and qualification of fire rated penetration seals are ASTM E-814, MEEB 634 and NFPA 251.
Complies 3.11.4(a) [Annular Space Requirements]
The annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire-resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. The assembly shall be qualified by tests in accordance with a fire test protocol acceptable to the AHJ or be protected by a listed fire-rated device for the specified fire-resistive period.
Plant Specification ES-FIRE-0601-QCF, Fire Rated Seals /, Typical Details Transition Document Access Code - D.C. Cook Version 2.4.3 Page 210 of 299 FPCE-2024-0012 Rev. 0 Page 30 of 40
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-163 Revision 6 By the response to Appendix A to Branch Technical Position APCSB 9.5-1, dated January 31, 1977, item D.1.(j) I&M stated:
"all openings for cable, pipe, and ductwork in these walls, floors, and ceilings have been sealed with foamed in place silicone which was tested in march 1975 for up to five hours fire exposure in an ASTM E 119 wall fire test."
The NRC Safety Evaluation, dated July 31, 1979 states:
"The test report shows that the penetration seal passed a 3-hour E-119 type fire exposure test.
However, the test included only the Unit 2 penetration design. The licensees have provided a comparison between Unit 1 and Unit 2 penetration seal designs to justify that the Unit 2 design is the "worst case" for fire testing. We agree with this evaluation and conclude that the Unit 2 seal tests are acceptable for the Unit 1 seals.
We conclude that the penetration fire stops which are in place provide sufficient protection from the unbounded spread of fire along electrical cables. We base this conclusion on our knowledge of ASTM E-119 fire tests including those cited by the licensees which substantiate the fire resistive ability of penetration fire stops Complies by Previous NRC Approval NRC Safety Evaluation, dated July 31, 1979 / Other Items Related to the Station Fire Protection Program, Section A I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977 /
Section D.1.(j)
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 211 of 299 FPCE-2024-0012 Rev. 0 Page 31 of 40
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-164 Revision 6 constructed with silicone foam."
The foamed in place silicone design, as approved by the SE Report, is still in use at CNP.
There have been no plant modifications or other changes that would invalidate the basis for approval. The foamed in place silicone design and the justification of the worst case configuration has not changed.
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 212 of 299 FPCE-2024-0012 Rev. 0 Page 32 of 40
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-165 Revision 6 Engineering equivalency evaluations have been performed for any penetrations that do not provide a fire resistance rating at least equal to that of the fire area barrier itself. These engineering equivalency evaluations determined the penetrations are equivalent or adequate for the hazard.
Complies with Use of EEEEs Engineering Equivalency Evaluation 11-15, Switchgear Room Construction Boundary Room Evaluation Unit 1 Fire Zones 41 and 42A (AA40 and AA41) & Unit 2 Fire Zones 45 and 46A ( AA43 and AA44)
Engineering Equivalency Evaluation 11-16, ENGINEERING EQUIVALENCY EVALUATION FOR LUBE OIL STORAGE ROOMS FIRE ZONES 83, 88, 95 AND 100 (AA2), BOUNDARY EVALUATION Engineering Equivalency Evaluation 11-17, Diesel Generator Fuel oil Day Tank Rooms Fire Zones 15 (AA14), 16 (AA15), 18 (AA23) and 19 (AA24) Boundary Evaluation Engineering Equivalency Evaluation 11-2, Fire Zone 7 (AA7) to Fire Zone 38 (AA37)
Boundary Evaluation Engineering Equivalency Evaluation 11-24, Fire Retention Capability of Nonconforming Fire Seals in Fire Zones having a Low Fire Severity Transition Document Access Code - D.C. Cook Version 2.4.3 Page 213 of 299 FPCE-2024-0012 Rev. 0 Page 33 of 40
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-166 Revision 6 Engineering Equivalency Evaluation 11-26, Fire Retention Capability of a HELB 3 Pressure Boundary Seal (Fire Areas AA19, AA20, AA21 and AA22)
Engineering Equivalency Evaluation 11-27, Generic Fire Seal Design 1 Engineering Equivalency Evaluation 11-28, Generic Fire Seal Design 2 (Fire Areas AA7, AA8, AA39A, AA40, AA43, AA45A, AA45B, AA48 and AA52)
Engineering Equivalency Evaluation 11-29, Generic Fire Seal Design 3 in Fire Areas AA2A, AA2B, and AA15 Engineering Equivalency Evaluation 11-3, Fire Zone 27 (AA31) to Fire Zone 39 (AA38)
Engineering Equivalency Evaluation 11-31, Generic Fire Seal Design 5 (Fire Areas AA31 and AA38)
Engineering Equivalency Evaluation 11-33, Generic Fire Seal Design 7 (Fire Areas AA7 and AA37)
Engineering Equivalency Evaluation 11-34, Generic Fire Seal Design 8 Transition Document Access Code - D.C. Cook Version 2.4.3 Page 214 of 299 FPCE-2024-0012 Rev. 0 Page 34 of 40
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-167 Revision 6 Engineering Equivalency Evaluation 11-35, Generic Fire Seal Design 9 Engineering Equivalency Evaluation 11-4, Unit 1 Auxiliary Building Elevation 620 ft.-6 in. to Auxiliary Cable Vault Fire Zone 44n to Fire Zone 56 Engineering Equivalency Evaluation 11-47, Fire Zones 44N (AA36), 44S (AA42) and 52 (AA3) Penetration Seals Engineering Equivalency Evaluation 11-48, Unit 1 & 2 Emergency Diesel Generator Rooms AB/CD Large Bore Pipe Penetrations - Fire Zones 11 (AA10), 16 (AA15) 18 (AA23) and 23 (AA29) Penetration Seals Engineering Equivalency Evaluation 11-5, Unit 1 EPS/4 KV Switchgear Complex Ventilation Shaft Boundary Evaluation (Fire Areas AA39A, AA39B, AA40, AA41 and AA48)
Engineering Equivalency Evaluation 11-50, Embedded Conduit Fire Wrap Protection (Fire Areas AA14 and AA24)
Transition Document Access Code - D.C. Cook Version 2.4.3 Page 215 of 299 FPCE-2024-0012 Rev. 0 Page 35 of 40
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-168 Revision 6 Engineering Equivalency Evaluation 11-51, Screenhouse and Water Intake System Boundary Evaluation Fire Zone 142 (AA2A) to Fire Zone 143 (YD)
Engineering Equivalency Evaluation 11-54, Unit 1 Main Control Room Cable Vault Penetration Seal W5111 Fire Zone 57 and 91 (Fire Areas AA50 and AA2A)
Engineering Equivalency Evaluation 11-56, Turbine Building Main Steam Access Way Fire Zones 110 to 114, Fire Zones 111 to 115, Fire Zones 112 to 2N, Fire Zones 113 to 2S (Fire Areas AA2A, AA2B, AA2C)
Engineering Equivalency Evaluation 11-58, Unit 2 Control Room Fire Rated Floor Penetration Seals Fire Zones 54 (Fire Area AA47) and 58 (Fire Area AA51)
Engineering Equivalency Evaluation 11-6, Fire Zones 45 (AA43), 46A through 46D (AA44), 47A (AA45A), 47B (AA45B) to Fire Zone 60 (AA52)
Shaft Boundary Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 216 of 299 FPCE-2024-0012 Rev. 0 Page 36 of 40
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-169 Revision 6 Engineering Equivalency Evaluation 11-60, Engineering Equivalency Evaluation 11-60, Fire Zone 80/114 and 84/115 (Fire Areas AA2 and AA2C)
Boundary Evaluation Engineering Equivalency Evaluation 11-7, Fire Zone 5 (AA5/6) to Unit 1 Fire Zones 62A, 62B and 62C (AA54) and Unit 2 Fire Zones 63A, 63B and 63C (AA5) Removable Block Walls Engineering Equivalency Evaluation 11-8, Engineering Equivalency Evaluation 11-8, Yard to Fire Zones 34 (AA35),
34A (AA35), 90 (AA2), 97 (AA2), 129 (AA2), and 130 (AA2) Boundary Evaluations Engineering Equivalency Evaluation 11-83, Unrated Containment Penetrations Engineering Equivalency Evaluation 9-35, Fire Zone 108 (AA2A) to Fire Zone 33A (AA34) Boundary Evaluation Engineering Equivalency Evaluation 9-36, Fire Zone 109 (AA2B) to 34A (AA35)
Boundary Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 217 of 299 FPCE-2024-0012 Rev. 0 Page 37 of 40
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-170 Revision 6 Engineering Equivalency Evaluation 9-37, Fire Zones 5 (AA5/6) and 32 (AA3) Boundary Evaluations Technical Evaluation-11-20, Narrow Space Openings between Penetrating Items and the Barrier or Between Penetrating Items Boundary Evaluation Transition Document Access Code - D.C. Cook Version 2.4.3 Page 218 of 299 FPCE-2024-0012 Rev. 0 Page 38 of 40 Engineering Equivalency Evaluation 9-41, Fire Zones 37 (AA36) and 51(AA3) Barrier Evaluation
Page 1 AMERICAN ELECTRIC POWER COOK NUCLEAR PLANT NFPA 805 Transition Project Report No.:
Technical Evaluation R1900-0041-0001
Title:
Plant Boundary Definition and Partitioning Revision:
12 Prepared by Matt Goddard Signature Print Date Reviewed by Rod Pletz Signature Print Date Approved by Bob May Signature Print Date Page 1 of 189 3/6/2023 3/6/2023 Type text here 3/6/2023 FPCE-2024-0012 Rev. 0 Page 39 of 40
Plant Boundary Definition and Partitioning - Technical Evaluation R1900-0041-0001 : Fire Compartment Boundary Information Boundary Identification:
AA3 / AA36/42 Construction:
Reinforced concrete in excess of a 3-hour rating.
Open stairways protected by a water curtain connect the 609 ft. elevation of the Auxiliary Building with the 587 ft. elevation (Fire Zones 5 and 6N) and the 633 ft.
elevation (Fire Zones 51 and 52).
A fire area boundary evaluation was performed for the rated and unrated fire barriers of the stairwells and elevators located in the Auxiliary Building. (Refer to Engineering Equivalency Evaluation 11.12.)
Penetrations located in this boundary are provided with fire rated seals.
Doors / Access Openings:
Fire area boundary evaluation performed for the unrated floor hatch between Fire Zones 44N & 52 (Refer to Engineering Equivalency Evaluation 11.37).
Ventilation Openings:
A fire area boundary evaluation was performed for undampered ventilation penetrations between Fire Zones 37 & 51 (Engineering Equivalency Evaluation 9.41).
An Engineering Equivalency Evaluation was performed for the fire dampers in the cable vaults and tunnels that have a fire resistance rating of less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
(Refer to Engineering Equivalency Evaluation 11-14)
A fire damper exemption was granted for undampered ventilation duct between Fire Zones 44N & 52 (Refer to Engineering Equivalency Evaluation 11.45).
49, 50, 51, 52, 69, 106 37, 44A, 44B, 44C, 44D, 44E, 44F, 44G, 44H, 44N, 44S Drawing
Reference:
12-5974, 12-5975, 12-5976, 12-5980, 12-5982, 12-5983 Adjacent Fire Zones within AA3:
Adjacent Fire Zones within AA36/42:
Notes:
The active fire barrier elements for this boundary have been evaluated in accordance with the criteria described in Section 4.5 of this report. It was confirmed that there are no potential significant high hazard fire events (e.g., HEAFs, transformer or hydrogen explosions) that could affect targets on either side of the active fire barrier element prior to activation, and the element will remain capable of activating as designed.
Door No.
Rating Fire Zones Description Elevation Fire Doors:
Hatch Urtd 44N / 52 Aux Bldg Hatch 633 Damper No.
Rating Fire Zone 1 Fire Zone 2 Fire Dampers:
2-HV-AS-D5 1.5 44S 52 2-HV-AS-D6 3
44S 52 Cook Nuclear Plant, Page 75 of 145 Revision 12 Page 104 of 189 FPCE-2024-0012 Rev. 0 Page 40 of 40 Penetrations located in this boundary are provided with fire rated seals.
A fire area boundary evaluation was performed for unrated brass plug penetration seals between Fire Zones 37 & 51 (Engineering Equivalency Evaluation 9.41).