View source for AEP-NRC-2013-09, Revised Response to First Round Request for Additional Information Re Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805

{{Adams
| number = ML13045A432
| issue date = 02/01/2013
| title = Revised Response to First Round Request for Additional Information Re Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805
| author name = Gebbie J
| author affiliation = Indiana Michigan Power Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000315, 05000316
| license number = DPR-058, DPR-074
| contact person = 
| case reference number = AEP-NRC-2013-09, TAC ME6629, TAC ME6630
| document type = Letter type:AEP
| page count = 27
| project = TAC:ME6629, TAC:ME6630
| stage = Request
}}

=Text=
{{#Wiki_filter:Indiana Michigan Power AII* tI~cL]GU                                                                         Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power                                                       IndianaMichigan Power.corn February 1, 2013                                                                    AEP-NRC-2013-09 10 CFR 50.90 Docket Nos.:          50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Revised Response to a First Round Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos. ME6629 and ME6630)
This letter provides Indiana Michigan Power Company's (l&M's), licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, revised response to a previous Request for Additional Information (RAI) by the U. S. Nuclear Regilatory Commission (NRC) regarding a proposed license amendment to transition CNP, Units 1 and 2, to a new fire protection program based on National Fire Protection Association (NFPA) Standard 805. Documents referenced in this letter are identified in Enclosure 2.
By Reference 1 and 2, I&M proposed to amend CNP Units 1 and 2 Facility Operating Licenses DPR-58 and DPR-74 to adopt a new fire protection program based on NFPA Standard 805, in accordance with 10 CFR 50.48(a) and (c). Reference 1, Enclosure 2, hereafter referred to as the Transition Report, provided information associated with the CNP transition to NFPA 805. By References 3 and 4, the NRC transmitted RAIs regarding the proposed amendment. References 5, 6, and 7 transmitted I&M's responses to the Reference 3 and 4 RAIs. This letter provides I&M's revised response to the Reference 3 RAI-15(b).               The ,original response to RAI-15(b) was transmitted by Reference 7. to this letter provides an affirmation statement. Enclosure 2 identifies documents referenced in this letter and its enclosures. Enclosure 3 provides I&M's revised response to RAI-15(b). Enclosures 4 and 5 provide revisions to Attachments M and S of the Transition Report in support of the revised RAI-15(b) response provided in Enclosure 3.

U. S. Nuclear Regulatory Commission                                              AEP-NRC-2013-09 Page 2 Copies of this letter and its enclosures are being transmitted to the Michigan Public Service Commission and Michigan Department of Environmental Quality, in accordance with the requirements of 10 CFR 50.91. This letter contains one new regulatory commitment provided in . Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Joel P. Gebbie Site Vice President JMT/ssl

==Enclosures:==
: 1. Affirmation
: 2. Identification of documents referenced in this letter and its enclosures
: 3. Revised response to RAI-15(b) regarding license amendment request to adopt NFPA 805
: 4. Revision 3 of Attachment M, "License Condition Changes," to the transition report, provided in support of the revised response to RAI-15(b)
: 5. Revision 4 of Attachment S, "Plant Modifications and Items to be Completed During Implementation," to the transition report, provided in support of the revised response to RAI-15(b)
: 6. Regulatory commitment c:     -C. A. Casto, NRC Region III J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ - RMD/RPS NRC Resident Inspector T.-J. Wengert, NRC Washington, DC

Enclosure 1 to AEP-NRC-2013-09 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President- of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME T"HIS     \    DAY OF                        2013                      DANIELLE BURGOYNE Notary Public, State Of Michigan Co unty of Berrien My Commission Acting            Expires 04-04.2018 In the County     OjC,0   "201-
;My Ccmmmission Expires      ('C, -      " .c-,'

Enclosure 2 to AEP-NRC-2013-09 Identification of Documents Referenced in this Letter and Its Enclosures Reference
: 1. Letter from M. H. Carlson, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket Nos. 50-315 and 50-316, Request for License Amendment to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," AEP-NRC-2011-1, dated July 1, 2011, ADAMS Accession No. ML111188A-145.
: 2. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket Nos. 50-315 and 50-316, Supplement to Request for License Amendment to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," AEP-NRC-2011-62, dated September 2, 2011, ADAMS Accession No. ML11256A030.
: 3. Letter from P. S. Tam, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2
   - Request for Additional Information on the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos. ME6629 AND ME6630)," dated January 27, 2012, ADAMS Accession Nos. M1L113560709, ML12003A186, and ML12017A251.
: 4. E-Mail from P. S. Tam, NRC, to H. L. Etheridge, J. R. Waters, M. K. Scarpello, I&M, et al., "D.C.
Cook - Draft RAI re. Transition to NFPA 805, Questions in Health Physics (TAC ME6629 and ME6630)," dated March 22, 2012, ADAMS Accession No. ML12082A043.
: 5. Letter from M. H. Carlson, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Response to Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805, (TAC Nos. ME6629 AND ME6630)," AEP-NRC-2012-29, dated April 27, 2012, ADAMS Accession No. ML12132A390.
: 6. Letter from J. P Gebbie, I&M, to NRC Document Control Desk, "Response to Second Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos. ME6629 AND ME6630)," AEP-NRC-2012-47, dated June 29, 2012, ADAMS Accession No. ML12195A013.
: 7. Letter from M. H. Carlson, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Response to Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805, (TAC Nos. ME6629 AND ME6630)," AEP-NRC-2012-58, dated August 9, 2012, ADAMS Accession No. ML12242A246.

Enclosure 3 to AEP-NRC-2013-09 Revised Response to RAI-15(b) Re: License Amendment Request to Adopt NFPA 805 Documents referenced in this enclosure are identified in Enclosure 2 to this letter.
This enclosure provides Indiana Michigan Power Company's (l&M's), licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, revised response to Request for Additional Information (RAI) 15(b) from the U. S. Nuclear Regulatory Commission (NRC), transmitted by Reference 7 regarding the CNP transition to National Fire Protection Association Standard 805 (NFPA 805).
RAI-15 Safe Shutdown Analysis, Nuclear Safety Capability Assessment (NSCA)
Capability Methods - Common Power Supply and Enclosure CNP NFPA 805 Transition Report, Table B-2, states that CNP complies with the intent of NEI-O0-01, Revision 1, Sections 3.3.1.7, 3.3.3.3, 3.5.2.4, and 3.5.2.5, with regard to common power supply and common enclosure criteria and the methodologies referenced in D.C. Cook Technical Evaluation 12.5, "AssociatedCircuits by Common Power Supply and Common Enclosure", Revision 0, Technical Evaluation 12.5.1, "Secondary Fire Evaluation," Revision 0, and Engineering Evaluation, Enercon Report AEP-DCC-1 1-001, "AssociatedCircuits by Common power Supply and By Common Enclosure", Revision 0. Please provide the following additional information regarding secondary fires:
RAI-15(b) b) With regard to Technical Evaluation 12.5, deficiencies are identified in protection of 250 VDC cables associated with 1-MCAB, 1-HIV, 1-MCCD, 1-CRCD, 1-MDCD, 1-1 IPHC, 1-1 IPHA, 1-TBV, BuslA, BuslB, BusIC, BuslD, 2-MCCD, 2-HIV and 2-MCAB. Attachments 4 and 5 provide impact statements for these deficiencies for Unit 1 and Unit 2, respectively, that state, "Unless a justification can be provided for accepting the lack of cable protection secondary fires must be assumed." Have the deficiencies identified for the 250 VDC components been justified or have secondary fires been evaluated for these cables? Explain what impact secondary fires will have on the ability to achieve and maintain the nuclear safety performance criteria and provide supporting documentation.
Revised Response to RAI-15(b)
In preparing the original RAI-15(b) response transmitted by Enclosure 2 to Reference 7, I&M utilized undue conservatism in the evaluation of the cable protection requirements. Further review of this issue in accordance with the guidance provided in NEI 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis", Revision 2, has determined that a change in the cable protection strategy is not required.
I&M has determined that CNP has adequate cable protection and coordination, and can justify the conditions identified as deficiencies associated with electrical coordination (i.e. coordination between bus load protective devices and bus supply protective devices) in Technical Evaluation 12.5, "Associated Circuits by Common Power Supply and By Common Enclosure,"
Revision 0. I&M has completed an evaluation of those conditions and determined that there is adequate cable protection and coordination, and that secondary fires are not a concern. Therefore, to AEP-NRC-2013-09                                                                  Page 2 there is no impact on the ability to achieve and maintain the nuclear safety performance criteria, and no impact on the Fire Probability Risk Assessment (PRA).
Technical justification supporting the revised RAI-15(b) response is summarized as follows:
I&M has determined that no deficiencies or technical inadequacies exist with respect to the existing configuration, design basis, and licensing basis for fuse coordination in the 250 Volt Direct Current (DC) power supplies.
The 250 Volt DC coordination information documented in Technical Evaluation 12.5 is based on the evaluation provided in CNP Unit 1 and Unit 2 Calculations 1-E-N-ELCP-250-001, "Unit I 250VDC System Coordination Study," and 2-E-N-ELCP-250-001, "Unit 2 250VDC System Coordination Study." Calculation 1-E-N-ELCP-250-001 states that "Protection of cable against short circuit current is not part of the CNP licensing basis." This has been verified as correct. Per the Safe Shutdown Capability Assessment Manual (SSCA), Revision 15, Section 2.7, cables must be protected against damage that would cause a neighboring cable to ignite. Protection against short circuit current is one tool to assist in meeting this requirement, but is not required as long as the requirement to protect cables against ignition due to failure of a neighboring cable can be met.
The cable damage curve used in Unit 1 Calculation 1-E-N-ELCP-250-001 and Unit 2 Calculation 2-E-N-ELCP-250-001 includes two relevant conservatisms. First, the cable damage curve is based on a short circuit withstand capability temperature of 2500 C, which based on industry referenced values and due to the fact that the cables of concern are thermoset insulated, is conservative with respect to the ignition point of the cable. Second, all cables of concern were found to be four conductor #12 cable, vs. the two conductor #12 cable damage curve used in the calculation. The short circuit withstand capability is therefore much greater than what was used in the calculation.
The currently installed fuses protect against low impedance (high current) faults. NEI 00-01 Revision 2, Appendix B.1, provides technical justification for dismissing high impedance faults as a credible failure mechanism provided that stated conditions are met. CNP meets those conditions.
Therefore, I&M has concluded that, no current technical error exists in the 250 Volt DC calculations, the calculations are conservative with respect to the licensing basis, and the postulated failure mode required to generate a deficient condition (i.e., high impedance fault) is not credible.
Additionally, for completeness, I&M's review also included 600 Volt Alternating Current (AC) and 120 Volt AC circuits.
Consistent with these conclusions, Transition Report Attachment M, "License Condition Changes" Page M-4, Item 2(c), as modified by Enclosure 2 to Reference 7, is being revised to delete the commitment to: "Replace fuses for 250 Volt Direct Current circuits with fuses having lower current ratings as necessary to provide protection from secondary fires. Implement modifications if necessary to provide protection from secondary fires associated with other circuits." The revised Transition Report Attachment M is provided as Enclosure 4 to this letter.
Additionally, Transition Report Attachment S, "Plant Modifications and Items to be Completed during Implementation," Pages S-5 and S-6, Item S-2.3, regarding replacement of 250 Volt DC fuses and maintenance of compensatory measures is being deleted. (Attachment S was most recently revised by Reference 9.) A new Attachment S Implementation Item S-3.23 is being added to AEP-NRC-2013-09                                                                Page 3 to Page S-12 to revise Technical Evaluation 12.5 and update the following documentation to reflect the above identified conclusions:
: 1. Revise Unit 1 and Unit 2 250 Volt DC calculations 1-E-N-ELCP-250-001, "Unit 1 250VDC System Coordination Study" and 2-E-N-ELCP-250-001, "Unit 2 250VDC System Coordination Study." These will be non-technical revisions to provide clarity regarding the CNP Licensing Basis and Design Requirements (specifically, the SSCA and NEI 00-01).
: 2. Revise 600 Volt AC calculation 1-E-N-PROT-BKR-007, "Unit 1 600V Switchgear Breaker 11A6, 11A7, 11B3, 11C3, 11C9, 11C18, 11D9 and 0B2-1 Settings." This will be a non-technical revision to provide clarity regarding the NFPA 805 requirements in the case of a potentially overloaded cable.
Create new Unit 1 and Unit 2 120 Volt AC calculations. A representative sample of cable data from buses identified in Technical Evaluation 12.5 was evaluated for adequate cable protection and coordination. Results of the survey revealed that all cables were acceptable with significant margin to preclude cable damage and secondary fires. The new calculations will document the assembled data for each 120 Volt AC cable and protective device. The new calculations by bounding analysis are to be complete no later than March 28, 2013.
Update Technical Evaluation 12.5. This update will provide justification for resolution of conditions currently identified as deficiencies with 250 Volt DC, 600 Volt AC and 120 Volt AC calculations.
The revised Transition Report Attachment S is provided as Enclosure 5 to this letter. Details of the above described evaluation are documented in the CNP Corrective Action Program in the Condition Evaluation for Action Request 2012-7848.

Enclosure 4 to AEP-NRC-2013-09 Revision 3 of Attachment M, "License Condition Changes," to the Transition Report Provided in Support of Revised Response to RAI-15(b).
Changes are indicated by revision bars in the right margin.

M. License Condition Changes 4 Pages Page M-2 Revision 33                              Page M-2

I&M proposes to replace the current CNP fire protection license conditions 2.C.(4) for Unit 1 and 2.C.(3)(o) for Unit 2 with the standard license condition in Regulatory Position C.3.1 of Regulatory Guide 1.205, Revision 1, as shown below. In support of this change, I&M has developed a Fire PRA which has been reviewed and been found acceptable by a Fire PRA WOG peer review conducted during October 12-16, 2009. Outstanding high level findings from the peer review are included in Attachment V of this TR. Any future changes to the Fire PRA will be subject to peer review in accordance with the guidance provided in NEI 07-12 and applicable ASME/ANS PRA standards.
Indiana Michigan Power shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated                         (and supplements dated           _ ) and as approved in the Safety Evaluation Report dated ....                          _(and supplements dated
                  ). Except where NRC approval for changes or deviations is required by 10CFR50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10CFR50.48(a) and 10CFR50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changqes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
(a)     Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
(b)      Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x 10 /year (yr) for CDF and less than 1x 10-8 /yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changqes that May Be Made Without Prior NRC Approval (1)      Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
Revision 3                                                                               Page M-3

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
         *       "Fire Alarm and Detection Systems" (Section 3.8);
         *       "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);
         *       "Gaseous Fire Suppression Systems" (Section 3.10); and,
         *       "Passive Fire Protection Features" (Section 3.11).
(2)     Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. 'The licensee may use its screening process as approved in the NRC Safety Evaluation Report dated to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions (1)      Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
(2)      The licensee shall implement the following modifications to its facility to complete the transition to full compliance with 10 CFR 50.48(c) by (a)    Modify the CO 2 system from manual to automatic actuation in the following fire areas:
                 "    AA40
                 "    AA43 (b)     Modify motor operated valves to preclude IN 92-18 conditions in which control circuit short circuits can occur between control wiring and power sources leading to spurious operation of the valve, and in which the same postulated short circuit may bypass the torque/limit switches which, combined with the absence or bypass of thermal overload contacts, can result in continuous energization of the valve motor and potential mechanical damage to the valve such that manual operation via handwheel would be inhibited. The affected valves are identified in Attachment S.
(3)     The Licensee shall implement the items listed in Enclosure (2) Table S-3 of the license amendment request within 180 days of issuance of the Safety Evaluation Report.
The license conditions to be replaced are restated below.
License condition 2.C(4) for Unit 1:
Revision 3                                                                               Page M-4

Indiana Michigan Power Company shall implement and maintain, in effect, all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for the facility and as approved in the SERs dated December 12, 1977, July 31, 1979, January 30, 1981, February 7, 1983, November 22, 1983, December 23, 1983, March 16, 1984, August 27, 198:5, June 30, 1986, January 28, 1987, May 26, 1987, June 16, 1988, June 17, 1988, June 7, 1989, February 1, 1990, February 9, 1990, March 26, 1990, April 26, 1990, March 31, 1993, April 8, 1993, December 14, 1994, January 24, 1995, April 19, 1995, June 8, 1995, and March 11, 1996, subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
License condition 2.C(3)(o) for Unit 2:
Indiana Michigan Power Company shall implement and maintain, in effect, all provisions of the approved Fire Protection Program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SERs dated December 12, 1977, July 31, 1979, January 30, 1981, February 7, 198:3, November 22, 1983, December 23, 1983, March 16, 1984, August 27, 1985, June 30, 1986, January 28, 1987, May 26, 1987, June 16, 1988, June 17, 1988, June 7, 1989, February 1, 1990, February 9, 1990, March 26, 1990, April 26, 1990, March 31, 1993, April 8, 1993, December 14, 1994, January 24, 1995, April 19, 1995, June 8, 1995, and March 11, 1996, subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if these changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
It is I&M's understanding that, implicit in the replacement of these license conditions, all prior fire protection program SERs and commitments will be superseded in their entirety by the revised license condition.
No other license conditions need to be replaced or revised.
I&M implemented the following process for determining that these are the only license conditions required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c):
A review was conducted of the I&M Unit 1 Renewed License Number DPR-58, through Amendment No. 313 and Unit 2 Renewed License Number DPR-74, through Amendment No. 297, by the I&M licensing and NFPA 805 Transition Team. Outstanding LARs that have been submitted to the NRC but not yet approved were also reviewed for potential impact on the license conditions.
Revision 3                                                                               Page M-5

Enclosure 5 to AEP-NRC-2013-09 Revision 4 of Attachment S, "Plant Modifications and Items to be Completed During Implementation," to the Transition Report Provided in Support of Revised Response to RAI-15(b).
Changes are indicated by revision bars in the right margin.

Indiana Mich4gan Power Inin Mcka Poe CNP N NFPA   805 Transition Report FA85Tasto                   - Affachment S eot-Atcmn S. Plant Modifications and Items to be Completed during Implementation 12 Pages Revision 4                                                                      Page S-1

Indiana MicNqan Power                             CNP NFPA 805 Transition Report - Attachment S Tables S-1 and S-2, Plant Modifications, include a description of the modifications along with the following information:
      " A problem statement,
      "  Risk ranking of the modification,
      " An indication if the modification is currently included in the Fire PRA,
      " Compensatory Measure in'place, and
* A risk-informed characterization of the modification and compensatory measure.
The following legend applies to the risk ranking indicated in Tables S-1 and S-2:
* High = Modification would have an appreciable impact on reducing overall fire CDF.
* Medium = Modification would have a measurable impact on reducing overall fire CDF.
* Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.
Page S-2 Revision 44                                                                            Page S-2

Indiana Michigan Power                                                               CNP NFPA 805 Transition Report - Attachment S Attachment S - Table S-1 Plant Modifications Completed In     Comp              Risk Informed Item   Rank     Unit     Problem Statement           Proposed Modification          FPRA    Measure         Characterization S-1.1  High    1, 2  Cable in conduit associated    Provide 1-hour ERFBS with      Y       N            Fire PRA credits this with the credited train of dc  automatic suppression &                             modification for electrical electrical power for Fire Area detection for cable of                              power redundancy AA39A and AA45A is             concern in Fire Area AA39A unprotected and routedthrouh   and AA45AtheareaNone;                                Nompensaton modification through the area                                                                   installed.
S-1.2  Low     1,2   Actions identified in safe     Revised safe shutdown          N       N            Fire PRA does not credit shutdown procedure for         procedures to reflect correct                      these actions transferring 600 volt Bus to   actions.                                            Compensatory measure:
alternate source in Fire Areas                                                      None; Pro       meaure :
AA14, AA23, AA39B and                                                              None; Procedures AA45B were not accurately                                                          updated.
identified.
Page S-3 Revision 44 Revision                                                                                                                      Page S-3

Indiana Michigan Power                                                              CNP NFPA 805 Transition Report - Attachment S Attachment S - Table S-2 Plant Modifications Committed Proposed            In      Comp                Risk Informed Item      Rank   Unit   Problem Statement               Modification        FPRA     Measure            Characterization S-2.1    Medium  1,2  Short circuits can occur in  Modify the following ten   Y         N     Circuit failures which result in the the control circuit for      (10) valves to resolve                     inability of operators to perform a motor operated valves        92-18 issue:                               recovery action are significant between control wiring       1(2)-FMO-212                               contributors to both fire risk as well and power sources                                                       as internal events risk. The leading to spurious          1(2)-FMO-222                               proposed modification will improve operation of the valve.      1(2)-FMO-232                               the ability of plant operators to The same postulated                                                     manually align certain motor short circuit may bypass     1(2)-FMO-242                               operated valves if required in order the torque/limit switches
* to maintain the plant in a safe and which, combined with the     1(2)-ICM-250                               stable condition.
absence or bypass of thermal overload                                                        Compensatory measure for NFPA contacts, results in                                                    805: None; This modification will be continuous energization                                                 completed pnorto implementation of the valve motor and                                                  of NFPA 805 FP Program..
potential mechanical                                                    Compensatory measure for&#xfd; damage to the valve such                                                10 CFR 50 Appendix R: None; IN that manual operation via                                               92-18 concerns were addressed by handwheel would be                                                      the current licensing basis, which inhibited. This potential                                               credits the "double break" circuit condition was described                                                 design, as described in NRC SE in Information Notice (IN)                                              dated November 22, 1983.
92-18 Page 3-4 Revision 44 Revision                                                                                                                     Page S-4

Indiana Michigan Power                                                             CNP NFPA 805 Transition Report - Attachment S Attachment S - Table S-2 Plant Modifications Committed Proposed             In      Comp               Risk Informed Item     Rank  Unit    Problem Statement             Modification         FPRA     Measure           Characterization S-2.2   High     1,2 Electrical cabinet fire     Modify the CO 2 system      Y         N     This proposed modification will limit scenarios in fire areas     from manual to                              the extent of damage predicted to AA40 and AA43               automatic actuation in                      occur for fire scenarios within the contribute significantly to the following fire areas:                   subject fire areas.
fire CDFadditional warrant    and LERE and a) AA40                                     Compensatory measure for NFPA mirrntigaddtion al          b805:                                            None; This modification will be mitigation                  b)AA43                                      completed prior to implementation of NFPA 805 FP Program.
Compensatory measure for 10 CFR 50 Appendix R: None; fire areas AA40 and AA43 are deterministically compliant with 10 CFR 50 Appendix R.
Revision 4                                                                                                                 Page S-5

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Table S-3, identifies those implementation items (procedure changes, process updates, and training to affected plant personnel) that will be completed by I&M prior to the implementation of new NFPA 805 FP program. These items will be completed within six (6) months after NRC issuance of the NFPA 805 SE.
Page S-6 Revision 44 Revision                                                                                     .Page S-6

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Indiana Michigan Power                                                                 CNP NFPA 805 Transition Report - Attachment S Attachment S - Table S-3 Implementation Items Item        Unit                                Description                                       LAR Section / Source S-3.10        1, 2  Technical documents and procedures that relate to new Fire               4.7.1, 4.7.2, 4.7.3, and Attachment W Protection (FP) design and licensing basis (e.g., Fire Protection Program Manual (FPPM), Technical Requirements Manual, Design Basis Document, maintenance and surveillance, configuration control, training and qualification guidelines, Quality Assurance Program Document (QAPD), etc.) will be revised as needed for implementation of NFPA 805.
S-3.11        1, 2  A new restoration procedure (1/2-OHP-4025-R-XX series) will be                        Attachment W developed to address re-powering the hydrogen igniters following a fire in Fire Areas AA40, AA43, AA46, AA47, AA48, AA50, AA51 and AA52 S-3.12       1, 2  The current transformer evaluation (Technical Evaluation 12.6) will               4.2.1.1/Attachment B be updated to address those CTs that currently have not screened out as sufficient CT data becomes available.
S-3.13       1, 2   UFSAR Section 9.8.1 will be revised as needed for                                         4.7.1 implementation of NFPA 805.
S-3.14       1,2   Applicable operating procedures will be revised to include the treatment of Fire PRA Actions added to the 'base fire.PRA model' that mitigate 'fire induced failures - but are not.associated with the NSCA success path. This includes isolation of containment purge line isolation valves, and procedure changes for Turbine Driven Auxiliary Feed Water (TDAFW) pump battery charger re-alignment to address uncertainty considerations. This includes procedure changes associated with the NSCA (item S-3.5), field verification walk-throughs (item S-3.8), hydrogen igniters (item S-3.11) and temporary ventilation (item S-3.17)..
Revision 4                                                                                                                     Page S-9

Indiana Michigan Power                                                                CNP NFPA 805 Transition Report - Attachment S Attachment S - Table S-3 Implementation Items Item        Unit                               Description                                      LAR Section ! Source S-3.15        1,2  Revise procedure PMP-2270-WBG-001, 'Welding, Burning and              Response to RAI-09.01 documented in I&M Grinding Activities," and procedure 12-FPP-2270-066-011, "Fire           Letter dated October 15, 2012, and Watch Activities," and conduct training on discontinuing the use of.                Attachment A.
(1) video cameras for fire watch and (2) use of a single fire watch for multiple hot work activities.
S-3.16        1&#xfd;,2 Revise Procedure PMP-2270-CCM-001, "Control of Combustible            Response to RAI-10.01 documented in I&M Materials," and conduct training on the requirements of NFPA 805         Letter dated October 15, 2012, and Section 3.3.1.2(1).                                                                 Attachment A.
S-3.17        1,2  Revise Technical Evaluation R1900-0026-001, Revision 1,               Response to RAI-18.01 documented in I&M "Recovery Action Transition in Support of NFPA 805," and                 Letter dated October 15, 2012, and applicable procedures, to establish temporary MCR ventilation for                   Attachment A.
Recovery Actions associated with VFDRs for AA3-004, AA3-009, AA36/42.42-026, AA57A-001 and AA57B-001. The Implementation Item will also require that training be conducted.
S-3.18        1, 2 Verify MOV circuit changes (Table S-2, Item S-2.1) have been           Response to RAI-44 documented in I&M accomplished as credited in Attachment W and verify the                    Letter dated October 15, 2012.
associated valves are not credited in other areas where spurious operation could occur.
S-3.19        1,2 Update the associated Fire PRA task and revise the Fire PRA            Response to RAI-44 documented in I&M ignition frequency and/or fire modeling to include re-evaluation of        Letter dated October 15, 2012.
procedural actions/controls associated with control of automatic CO2 ac.tuiatinn in certain areas (Tahle S-2 itpem R-2 2) Transipent Combustible Fee Zones (Table S-3, Item S-3.3), establishing certain areas as Hot Work Restriction Zones (Table S-3, Item S-3.4).
Revision 4                                                                                                                 Page S- 10

lnriicinn Mr&#xfd;hiryon t I It4ILEI I~ I VIIS~I On Aar
                        -, I I ~ WV~I flAIP AIFPA Rfl!; Trnnczifmnn Rn~nd  - AftnishmantR.
Attachment S - Table S-3 Implementation Items Item                Unit                                 Description                                           LAR Section 1Source S-3.20               1,2     Upon completion of all Fire PRA credited implementation items in           Response to RAI-44 documented in I&M Transition report Tables S-2 and S-3, verify the validity of the                Letter dated October 15, 2012.
change-in-risk provided in Attachment W. This includes procedure changes affecting the fire PRA (item S-3.14), electrical circuit modifications (item S-3.18), fire ignition and suppression (item S-3.19) and PRA methods (item S-3.21).
Ifthis verification determines that the risk metrics have changed such that the RG 1.205 acceptance guidelines are not met, additional analytical efforts, and/or procedure changes, and/or plant modifications will be implemented to assure the RG 1.205 acceptance criteria are met.
S-3.21               1,2     Conduct a Focused-Scope Peer Review of the PRA upgrade item                Response to RAI-45 documented in I&M related to Reduced Mission Times for cutsets containing a Test                  Letter dated October 15, 2012.
and Maintenance event combined with a running failure.
S-3.22               1,2     Revise program documents and procedures, and conduct                       Response to RAI-60 documented in I&M associated training, as necessary to implement specific                         Letter dated October 15, 2012.
requirements from NFPA 805 Section 2.7.3 as described in Transition Report Section 4.7.3.
Page S-lI Revision 44 Revision                                                                                                                                    Page S- 11

Inrlinnn AAirhirynn Pn onr Inr1i~n~ Mir~hin~an Pnw~r QNP     FPA ~flF flAIP AIFPA  Rn.T-i Trnncifinn          - Att~hm~nt -IQ P~nr~,f - Lftne-hmonf Tmnic~itinn Ponnrt                ~
S-3.23         1,2    Revise Technical Evaluation 12.5 and update the following                 Revised response to RAI-15(b) documented documentation to reflect the revised response to RAI-15(b)                  in l&M Letter dated January 14, 2013.
documented in I&M Letter dated January 14, 2013:
: 1. Revise Unit 1 and Unit 2 250 Volt DC calculations 1-E-N-ELCP-250-001. "Unit 1 25OVDC System Coordination Study."     and 2-E-N-ELCP-250-001. "Unit 2 250VDC System Coordination Study." These will be non-technical revisions to provide clarity regarding the CNP Licensing Basis and Design Requirements (specifically, the SSCA and NEI 00-01).
: 2. Revise 600 Volt AC calculation 1-E-N-PROT-BKR-007, "Unit 1 600V Switchcqear Breaker 11A6, 11A7, 11B3.
11 C3. 11 C9, 11 C1 8. 11 D9 and 0B2-1 Settings." This will be a non-technical revision to provide clarity regarding the NFPA 805 requirements in the case of a potentially overloaded cable.
: 3. Create new Unit 1 and Unit 2 120 Volt AC calculations. A representative sample of cable data from buses identified in Technical Evaluation 12.5 was evaluated for adequate cable protection and coordination. Results of the survey revealed that all cables were acceptable with significant margin to preclude cable damage and secondary fires.
The new calculations will document the assembled data for each 120 Volt AC cable and protective device and be complete by March 28, 2013.
: 4. Update Technical Evaluation 12.5. This update will provide justification for resolution of ronditions currently identified as deficiencies with 250 Volt DC, 600 Volt AC and 120 Volt AC calculations.
Page S-12 Revision 44 Revision                                                                                                                                Page S-12

Enclosure 6 to AEP-NRC-2013-09 REGULATORY COMMITMENT The following table identifies those actions committed to by Indiana Michigan Power Company (I&M) in this document. Any other actions discussed in this submittal represent intended or planned actions by I&M. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments..
Commitment                                         Date A representative sample of cable data from buses identified in- Technical Evaluation 12.5 was evaluated for adequate cable protection and coordination. March 28, 2013 Results of the survey revealed that all cables were acceptable with significant margin to preclude cable damage and secondary fires. New calculations will be performed to document the assembled data for each 120 Volt AC cable and protective device. These'calculations by bounding analysis will be completed by 3/28/13

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