ML25307A100
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:
GT 2024-1204-1 FPCE No.:
2024-0006________________
- 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:
Revision 2 of EEE-11-17, Diesel Generator Fuel Oil Day Tank Rooms Barrier Evaluation Within Fire Zones 15 (AA14), 16, (AA15), 18 (AA23), and 19 (AA24), incorporated evaluation of unlabeled dampers in the barriers between the Emergency Diesel Generator Rooms and their Fuel Oil Day Tank Rooms.
This FPCE incorporates editorial updates to the Fire Safety Analysis (FSA) where EEE 17 is credited. This included adding discussion of the unlabeled fire dampers in section 3.1.7, Ventilation, and updating the EEE summaries in Attachment 1 of Analysis Areas AA14, AA15, AA23, and AA24. See attached mark-up of the Fire Safety Analysis.
EEE-11-17 is also added as a reference document to NFPPM Attachment 1 section 3.11.3(2) [NFPA 90A - Fire Damper Requirements], Complies with Use of EEEEs.
- 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.
- 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.
FPCE-2024-0006 Rev. 0 Page 1 of 20
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
- 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 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 FPCE-2024-0006 Rev. 0 Page 2 of 20
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 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.
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.
FPCE-2024-0006 Rev. 0 Page 3 of 20
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
- 11. Document the basis for the conclusion.
Basis:
EEE-11-17, Rev. 2, 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 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 FPCE-2024-0006 Rev. 0 Page 4 of 20
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 2024-1204 - 2______________________________________
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:
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 Name/Signature (Qualified FPE) 3/19/2024 Name/Signature (Qualified FPE) 3/21/2024 Printed Name/Signature 3/26/2024 3/26/2024 FPCE-2024-0006 Rev. 0 Page 5 of 20
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 Signature 8/10/2021 Signature 8/11/2021 Signature 8/11/2021 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 6 of 20
Fire Area AA14 D. C. Cook Fire Safety Analysis (FSA) 3.1.8 Other Features For Fire Zone 15, Electrical Raceway Fire Barrier Systems (ERFBS) with a rating of a 1-hour are provided, where required. Cables inside embedded conduits within a concrete pilaster are provided with an external layer of Thermo-Lag (Engineering Equivalency Evaluation 11-50).
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 the Turbine Building and outdoors. The normal building ventilating systems in the Turbine Building will then exhaust the smoke. This fire area is listed as a non-controlled area in the Fire Pre Plans and therefore there is reasonable assurance that products of combustion will not be contaminated.
Ventilation openings to other fire areas are provided with 3-hour fire dampers.
control room. The automatic detection system alarms in 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 extinguishers are provided in this fire area.
A fire hose standpipe is located in adjacent Fire Area AA2 - Fire Zone 79.
Fire Area AA14 is equipped with floor drains.
3.3 NSCA Compliance Summary Fire Area AA14 contains the Unit 1 Green Train Emergency Diesel Generator as well as associated Green Train EDG support components, 600V MCCs, and 120V power supplies. This fire area also contains both Red and Green train raceways and cables.
Compliance with the nuclear safety performance criteria is achieved using the performance-based approach in accordance with NFPA 805, Section 4.2.4.2.
Safe and stable condition of Unit 1 will be accomplished using Steam Generator 2 and 3 via the Unit 1 Turbine Driven Auxiliary Feedwater Pump, Unit 1 Charging via the West Pump, Process Monitoring/Indication from the Main Control Room, Unit 1 Component Cooling Water via the West Pump and Unit 1 Essential Service Water via the West Pump. Power is credited via the Red Train 3.2 Fire Hazards Identification The fire area contains both ignition sources and combustible fire hazards. The ignition sources consist of the diesel generator, motor control centers, jacket water circulation pumps and the starting air compressors. Combustibles consist primarily of lube oil, diesel fuel oil and exposed electrical cables.
This Fire Area is below grade and any exterior wall penetrations need not be rated based on the protection provided by the ground covering the exterior walls.
The current fire loading classification is considered moderate.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA14-5 FSA Rev. 5 Page 321 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 7 of 20 Ventilation openings to other fire areas are provided with 3-hour fire dampers. Unlabeled fire dampers are provided to the fuel oil day tank room within the fire zone. (Engineering Equivalency Evaluation 11-17)
Fire Area AA14 - Attachment 1 Fire Area AA14 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA14 Unit 1 CD Diesel Generator Room (El. 587 ft.)
1 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations between the DG fuel oil day tank rooms and their respective DG rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread.
The existing fire seals grouted to an unknown depth located within the penetrations between the DG fuel oil day tank rooms and their respective DG rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the areas.
Summary EEEE Title Engineering Equivalency Evaluation 11 Embedded Conduit Fire Wrap Protection (Fire Areas AA14 and AA24)
The purpose of this engineering equivalency evaluation is to document the acceptability of the fire boundary for the conduits that are embedded in a concrete pilaster and covered by an external fire wrap material in both the Unit 1 CD Diesel Generator Room (Fire Area AA14) and the Unit 2 AB Diesel Generator Room (Fire Area AA24).
The fire wrap system over the concrete pilaster was originally installed to provide 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> protection for the embedded conduits for compliance with NFPA 805, Section 4.2.4.2. This engineering equivalency evaluation determined if the current barrier configuration in conjunction with the existing fire detection and fire suppression provides an adequate level of protection based upon the hazards in the area and the embedded conduit configuration for compliance with NFPA 805, Section 4.2.4.2. The engineering equivalency evaluation also determined if this engineering equivalency evaluation has any impact on other evaluations or exemptions.
This engineering equivalency evaluation evaluated the ability of the existing concrete pilaster and external fire wrap system to provide adequate conduit protection against fire in the Unit 1 CD Diesel Generator Room and in the Unit 2 AB Diesel Generator Room.
Reasonable assurance is provided that the embedded conduits within the concrete pilaster will not impair the safe shutdown capability of CNP nor increase the potential for fire to spread to redundant safe shutdown systems. An equivalent level of protection is provided by the combination of concrete and fire wrap such that a minimum of 1-hr fire protection is reasonably achieved. This arrangement in combination with automatic detection and suppression in the area provide a degree of protection equivalent to that specified in NFPA 805 section 4.2.4.2.
The pilasters were evaluated and found to be acceptable based on the fire protection systems and construction features within the evaluated areas.
Summary EEEE Title Page AA14-A1-3 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 328 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 8 of 20 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread of fire.
The existing fire seals grouted to an unknown depth located within the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals grouted penetrations and fire dampers were evaluated and found to be acceptable based on the fire hazards construction of the grouted penetrations and fire dampers, negligible impact to the Nuclear Safety Capability Assessment, and fire protection systems within the areas.
Fire Area AA15 D. C. Cook Fire Safety Analysis (FSA) 3.1.8 Other Features No other fire protection features provided for Fire Area AA15.
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 the Turbine Building and outdoors. The normal building ventilating systems in the Turbine Building will then exhaust the smoke. This fire area is listed as a non-controlled area in the Fire Pre Plans and therefore there is reasonable assurance that products of combustion will not be contaminated.
Ventilation openings to other fire areas are provided with 3-hour fire dampers.
control room. The automatic detection system alarms in 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 extinguishers are provided in this fire area.
A fire hose standpipe is located in adjacent Fire Area AA2 - Fire Zone 79.
Fire Area AA15 is equipped with floor drains.
3.3 NSCA Compliance Summary Fire Area AA15 contains the Unit 1 Red Train Emergency Diesel Generator as well as associated Red Train EDG support components, 600V MCCs, and 120V power supplies. This fire area also contains both Red and Green train raceways and cables.
Compliance with the nuclear safety performance criteria is achieved using the performance-based approach in accordance with NFPA 805, Section 4.2.4.2.
Safe and stable condition for Unit 1 will be accomplished using Stean Generator 2 and 3 via the Unit 1 East Motor Driven Auxiliary Feedwater Pump, Unit 1 Charging via the East Pump, Process Monitoring/Indication from the Main Control Room, Unit 1 Component Cooling Water via the East Pump and Essential Service Water via the East Pump. Power is credited via the Green Train from offsite.
3.2 Fire Hazards Identification The fire area contains both ignition sources and combustible fire hazards. The ignition sources consist of the diesel generator, motor control centers, jacket water circulation pumps and the starting air compressors. Combustibles consist primarily of lube oil, diesel fuel oil and exposed electrical cables.
This Fire Area is below grade and any exterior wall penetrations need not be rated based on the protection provided by the ground covering the exterior walls.
The current fire loading classification is considered moderate.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA15-5 FSA Rev. 5 Page 339 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 9 of 20 Ventilation openings to other fire areas are provided with 3-hour fire dampers. Unlabeled fire dampers are provided to the fuel oil day tank room within the fire zone. (Engineering Equivalency Evaluation 11-17)
Fire Area AA15 - Attachment 1 Fire Area AA15 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA15 Unit 1 AB Diesel Generator Room (El. 587 ft.)
1 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations between the DG fuel oil day tank rooms and their respective DG rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread.
The existing fire seals grouted to an unknown depth located within the penetrations between the DG fuel oil day tank rooms and their respective DG rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the areas.
Summary EEEE Title Engineering Equivalency Evaluation 11 Unit 1 & Unit 2 Diesel Generator Rooms AB/CD Large Bore Pipe Penetrations - Fire Zones 11 (AA10), 16 (AA15), 18 (AA23), and 23 (AA29) Penetration Seals The purpose of this engineering equivalency evaluation is to document the acceptability of fire-rated penetration seals W9171, W9172, W9192, and W9193. The seals are physically located in the east fire-rated walls of the DG Rooms floor elevation 587 ft., Fire Zones 16 (AA15) and 18 (AA23), interfacing with Fire Zones 11 (AA10) and 23 (AA29), respectively.
The existing configuration for the subject fire-rated penetration is suitable to perform their design function, to provide an acceptable level of fire protection, therefore preventing fire propagation between to fire zones. As such, there is no impact on the stations ability to achieve and maintain safe shutdown.
The fire rated penetration seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the evaluated areas.
Summary EEEE Title Page AA15-A1-3 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 346 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 10 of 20 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread of fire.
The existing fire seals grouted to an unknown depth located within the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals grouted penetrations and fire dampers were evaluated and found to be acceptable based on the fire hazards construction of the grouted penetrations and fire dampers, negligible impact to the Nuclear Safety Capability Assessment, and fire protection systems within the areas.
Fire Area AA23 D. C. Cook Fire Safety Analysis (FSA) 3.1.8 Other Features No other fire protection features provided for Fire Area AA23.
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 the Turbine Building and outdoors. The normal building ventilating systems in the Turbine Building will then exhaust the smoke. This fire area is listed as a non-controlled area in the Fire Pre Plans and therefore there is reasonable assurance that products of combustion will not be contaminated.
Fire dampers having a 3-hour rating are provided to adjacent Fire Areas AA29 and AA2 - Fire Zones 23 and 85, respectively.
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 extinguishers are provided in this fire area.
A fire hose standpipe is located in adjacent Fire Area AA2 - Fire Zone 85.
Fire Area AA23 is equipped with floor drains.
3.3 NSCA Compliance Summary Fire Area AA23 contains the Unit 2 Green Train Emergency Diesel Generator as well as associated Green Train EDG support components, 600V MCCs, and 120V power supplies. This fire area also contains both Red and Green train raceways and cables.
Compliance with the nuclear safety performance criteria is achieved using the performance-based approach in accordance with NFPA 805, Section 4.2.4.2.
Safe and stable condition of Unit 2 will be accomplished using Steam Generators 2 and 3 via the Unit 2 Turbine Driven Auxiliary Feedwater Pump, Unit 2 Charging via the West Pump, Process Monitoring/Indication from the Main Control Room, Unit 2 Component Cooling Water via the West Pump and Unit 2 Essential Service Water via the West Pump. Power is credited via the Red Train from offsite, with Red Train EDG also available.
3.2 Fire Hazards Identification The fire area contains both ignition sources and combustible fire hazards. The ignition sources consist of the diesel generator, motor control centers, jacket water circulation pumps and the starting air compressors. Combustibles consist primarily of lube oil, diesel fuel oil and exposed electrical cables.
This Fire Area is below grade and any exterior wall penetrations need not be rated based on the protection provided by the ground covering the exterior walls.
The current fire loading classification is considered moderate.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA23-5 FSA Rev. 5 Page 443 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 11 of 20 Fire dampers having a 3-hour rating are provided to adjacent Fire Areas AA29 and AA2 - Fire Zones 23 and 85, respectively. Unlabeled fire dampers are provided to the fuel oil day tank room within the fire zone. (Engineering Equivalency Evaluation 11-17)
Fire Area AA23 - Attachment 1 Fire Area AA23 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA23 Unit 2 CD Diesel Generator Room (El. 587 ft.)
2 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations between the DG fuel oil day tank rooms and their respective DG rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread.
The existing fire seals grouted to an unknown depth located within the penetrations between the DG fuel oil day tank rooms and their respective DG rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the areas.
Summary EEEE Title Engineering Equivalency Evaluation 11 Unit 1 & Unit 2 Diesel Generator Rooms AB/CD Large Bore Pipe Penetrations - Fire Zones 11 (AA10), 16 (AA15), 18 (AA23), and 23 (AA29) Penetration Seals The purpose of this engineering equivalency evaluation is to document the acceptability of fire-rated penetration seals W9171, W9172, W9192, and W9193. The seals are physically located in the east fire-rated walls of the DG Rooms floor elevation 587 ft., Fire Zones 16 (AA15) and 18 (AA23), interfacing with Fire Zones 11 (AA10) and 23 (AA29), respectively.
The existing configuration for the subject fire-rated penetration is suitable to perform their design function, to provide an acceptable level of fire protection, therefore preventing fire propagation between to fire zones. As such, there is no impact on the stations ability to achieve and maintain safe shutdown.
The fire rated penetration seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the evaluated areas.
Summary EEEE Title Page AA23-A1-3 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 450 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 12 of 20 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread of fire.
The existing fire seals grouted to an unknown depth located within the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals grouted penetrations and fire dampers were evaluated and found to be acceptable based on the fire hazards construction of the grouted penetrations and fire dampers, negligible impact to the Nuclear Safety Capability Assessment, and fire protection systems within the areas.
Fire Area AA24 D. C. Cook Fire Safety Analysis (FSA) 3.1.8 Other Features For Fire Zone 19, Electrical Raceway Fire Barrier Systems (ERFBS) with a rating of a 1-hour rating are provided, where required. Cables inside embedded conduits within a concrete pilaster are provided with an external layer of Thermo-Lag (Engineering Equivalency Evaluation 11-50).
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 the Turbine Building and outdoors. The normal building ventilating systems in the Turbine Building will then exhaust the smoke. This fire area is listed as a non-controlled area in the Fire Pre Plans and therefore there is reasonable assurance that products of combustion will not be contaminated.
Fire dampers having a 3-hour rating are provided to adjacent Fire Area AA2 - Fire Zone 85 and Yard. Additional 3-hour rated dampers are located within the fire zone between the diesel fuel day tank room and the remainder of the area.
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 extinguishers are provided in this fire area.
A fire hose standpipe is located in adjacent Fire Area AA2 - Fire Zone 85.
Fire Area AA24 is equipped with floor drains.
3.3 NSCA Compliance Summary Fire Area AA24 contains the Unit 2 Red Train Emergency Diesel Generator as well as associated Red Train EDG support components, 600V MCCs, and 120V power supplies. This fire area also contains both Red and Green train raceways and cables.
Compliance with the nuclear safety performance criteria is achieved using the performance-based approach in accordance with NFPA 805, Section 4.2.4.2.
Safe and stable condition of Unit 2 will be accomplished using the Steam Generators 2 and 3 via the Unit 2 East Motor Driven Auxiliary Feedwater Pump, Unit 2 Charging via the East Pump, Process Monitoring/Indication from the Main Control Room, Unit 2 Component Cooling Water via the East 3.2 Fire Hazards Identification The fire area contains both ignition sources and combustible fire hazards. The ignition sources consist of the diesel generator, motor control centers, jacket water circulation pumps and the starting air compressors. Combustibles consist primarily of lube oil, diesel fuel oil and exposed electrical cables.
This Fire Area is below grade and any exterior wall penetrations need not be rated based on the protection provided by the ground covering the exterior walls.
The current fire loading classification is considered moderate.
D. C. Cook Nuclear Plant Revision 5 Transition Document Access Code - D.C. Cook Version 2.4.3 Page AA24-5 FSA Rev. 5 Page 461 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 13 of 20 Fire dampers having a 3-hour rating are provided to adjacent Fire Area AA2 - Fire Zone 85 and Yard. Additional 3-hour rated dampers are located within the fire zone between the diesel fuel day tank room and the remainder of the area. Unlabeled fire dampers are provided to the fuel oil day tank room within the fire zone. (Engineering Equivalency Evaluation 11-17)
Fire Area AA24 - Attachment 1 Fire Area AA24 - Attachment 1 - Table B Fire Area Transition D. C. Cook Fire Safety Analysis (FSA)
Unit Fire Area Description AA24 Unit 2 AB Diesel Generator Room (El. 587 ft.)
2 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations between the DG fuel oil day tank rooms and their respective DG rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread.
The existing fire seals grouted to an unknown depth located within the penetrations between the DG fuel oil day tank rooms and their respective DG rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals were evaluated and found to be acceptable based on the fire hazards and fire protection systems within the areas.
Summary EEEE Title Engineering Equivalency Evaluation 11 Embedded Conduit Fire Wrap Protection (Fire Areas AA14 and AA24)
The purpose of this engineering equivalency evaluation is to document the acceptability of the fire boundary for the conduits that are embedded in a concrete pilaster and covered by an external fire wrap material in both the Unit 1 CD Diesel Generator Room (Fire Area AA14) and the Unit 2 AB Diesel Generator Room (Fire Area AA24).
The fire wrap system over the concrete pilaster was originally installed to provide 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> protection for the embedded conduits for compliance with NFPA 805, Section 4.2.4.2. This engineering equivalency evaluation determined if the current barrier configuration in conjunction with the existing fire detection and fire suppression provides an adequate level of protection based upon the hazards in the area and the embedded conduit configuration for compliance with NFPA 805, Section 4.2.4.2. The engineering equivalency evaluation also determined if this engineering equivalency evaluation has any impact on other evaluations or exemptions.
This engineering equivalency evaluation evaluated the ability of the existing concrete pilaster and external fire wrap system to provide adequate conduit protection against fire in the Unit 1 CD Diesel Generator Room and in the Unit 2 AB Diesel Generator Room.
Reasonable assurance is provided that the embedded conduits within the concrete pilaster will not impair the safe shutdown capability of CNP nor increase the potential for fire to spread to redundant safe shutdown systems. An equivalent level of protection is provided by the combination of concrete and fire wrap such that a minimum of 1-hr fire protection is reasonably achieved. This arrangement in combination with automatic detection and suppression in the area provide a degree of protection equivalent to that specified in NFPA 805 section 4.2.4.2.
The pilasters were evaluated and found to be acceptable based on the fire protection systems and construction features within the evaluated areas.
Summary EEEE Title Page AA24-A1-3 Revision 5 D. C. Cook Nuclear Plant Transition Document Access Code - D.C. Cook Version 2.4.3 FSA Rev. 5 Page 468 of 1300 0902969c844a8a2c FPCE-2024-0006 Rev. 0 Page 14 of 20 Engineering Equivalency Evaluation 11 Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) Boundary Evaluation The purpose of this engineering equivalency evaluation is to document the acceptability of the fire seals grouted to an unknown depth protecting the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms in Fire Zones 15 (Fire Area AA14), 16 (Fire Area AA15), 18 (Fire Area AA23) and 19 (Fire Area AA24) for their impact on preventing the spread of fire.
The existing fire seals grouted to an unknown depth located within the penetrations and unlabeled fire dampers between the DG diesel generator fuel oil day tank rooms and their respective DG diesel generator rooms (Fire Zones 15, 16, 18 and 19) are acceptable for maintaining the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rating of the fire boundary. This engineering equivalency evaluation does not impact other engineering equivalency evaluations.
The fire seals grouted penetrations and fire dampers were evaluated and found to be acceptable based on the fire hazards construction of the grouted penetrations and fire dampers, negligible impact to the Nuclear Safety Capability Assessment, and fire protection systems within the 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 Signature 2/20/2023 Signature 2/21/2023 Signature 2/21/2023 FPCE-2024-0006 Rev. 0 Page 15 of 20
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-2024-0006 Rev. 0 Page 16 of 20
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-2024-0006 Rev. 0 Page 17 of 20
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-2024-0006 Rev. 0 Page 18 of 20
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-2024-0006 Rev. 0 Page 19 of 20
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-2024-0006 Rev. 0 Page 20 of 20 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