View source for L-PI-14-045, Enclosure to L-PI-14-045, Transition Report, Revision 1

{{Adams
| number = ML14125A149
| issue date = 04/30/2014
| title = Enclosure to L-PI-14-045, Transition Report, Revision 1
| author name = 
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name = 
| addressee affiliation = NRC/NRR
| docket = 05000282, 05000306
| license number = DPR-042, DPR-060
| contact person = 
| case reference number = L-PI-14-045
| package number = ML14125A146
| document type = Report, Technical
| page count = 921
}}

=Text=
{{#Wiki_filter:Attachment W to this Enclosure contains Security-Related Information to be Withheld from Public Disclosure In Accordance with 10 CFR 2.390(d)(1)
Enclosure to L-PI-14-045 Northern States Power - Minnesota Prairie Island Nuclear Generating Plant Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants 2001 Edition Transition Report Revision 1 - April 2014 Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390(d)(1)
Upon removal of Attachment W, this Enclosure is uncontrolled.

Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390 Northern States Power - Minnesota Prairie Island Nuclear Generating Plant Units 1 & 2 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Transition Report Revision 1 April 2014 Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390 Upon removal of Attachment W, this Enclosure is uncontrolled

Northern States Power - Minnesota                                                        NFPA 805 Transition Report TABLE OF CONTENTS Revision Status ............................................................................................................ iv Summary of Changes .................................................................................................. vi Executive Summary ..................................................................................................... ix Acronym List ................................................................................................................ xi

==1.0 INTRODUCTION==
 ..................................................................................................... 1 1.1 Background........................................................................................................ 2 1.1.1 NFPA 805 - Requirements and Guidance ................................................. 2 1.1.2 Transition to 10 CFR 50.48(c).................................................................... 3 1.2 Purpose ............................................................................................................. 4 2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM ................................ 5 2.1 Current Fire Protection Licensing Basis ............................................................. 5 2.2 NRC Acceptance of the Fire Protection Licensing Basis ................................... 5 3.0 TRANSITION PROCESS ........................................................................................ 9 3.1 Background........................................................................................................ 9 3.2 NFPA 805 Process ............................................................................................ 9 3.3 NEI 04 NFPA 805 Transition Process...................................................... 10 3.4 NFPA 805 Frequently Asked Questions (FAQs) .............................................. 11 4.0 COMPLIANCE WITH NFPA 805 REQUIREMENTS............................................. 13 4.1 Fundamental Fire Protection Program and Design Elements .......................... 13 4.1.1 Overview of Evaluation Process .............................................................. 13 4.1.2 Results of the Evaluation Process ........................................................... 15 4.1.3 Definition of Power Block and Plant ......................................................... 15 4.2 Nuclear Safety Performance Criteria ............................................................... 16 4.2.1 Nuclear Safety Capability Assessment Methodology ............................... 16 4.2.2 Existing Engineering Equivalency Evaluation Transition.......................... 24 4.2.3 Licensing Action Transition ...................................................................... 25 4.2.4 Fire Area Transition ................................................................................. 27 4.3 Non-Power Operational Modes ........................................................................ 30 4.3.1 Overview of Evaluation Process .............................................................. 30 4.3.2 Results of the Evaluation Process ........................................................... 33 4.4 Radioactive Release Performance Criteria ...................................................... 34 4.4.1 Overview of Evaluation Process .............................................................. 34 4.4.2 Results of the Evaluation Process ........................................................... 34 PINGP                                                                                                 Page i - Revision 1

Northern States Power - Minnesota                                                          NFPA 805 Transition Report 4.5 Fire PRA and Performance-Based Approaches .............................................. 35 4.5.1 Fire PRA Development and Assessment ................................................. 35 4.5.2 Performance-Based Approaches ............................................................. 38 4.6 Monitoring Program ......................................................................................... 43 4.6.1 Overview of NFPA 805 Requirements for the NFPA 805 Monitoring Program ................................................................................................... 43 4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program ................... 44 4.7 Program Documentation, Configuration Control, and Quality Assurance ........ 49 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 ........................................................................................................... 49 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 ................................................................................... 51 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 .... 55 4.8 Summary of Results......................................................................................... 56 4.8.1 Results of the Fire Area Review .............................................................. 56 4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase....................................................................................................... 57 4.8.3 Supplemental Information -Other Licensee Specific Issues .................... 57

==5.0 REGULATORY EVALUATION==
 ............................................................................. 58 5.1 Introduction - 10 CFR 50.48 ............................................................................ 58 5.2 Regulatory Topics ............................................................................................ 64 5.2.1 License Condition Changes ..................................................................... 64 5.2.2 Technical Specifications .......................................................................... 64 5.2.3 Orders and Exemptions ........................................................................... 64 5.3 Regulatory Evaluations .................................................................................... 64 5.3.1 No Significant Hazards Consideration ..................................................... 64 5.3.2 Environmental Consideration ................................................................... 64 5.4 Revision to USAR ............................................................................................ 65 5.5 Transition Implementation Schedule ................................................................ 65

==6.0 REFERENCES==
 ...................................................................................................... 66 ATTACHMENTS ........................................................................................................... 72 A. NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program &
Design Elements ............................................................................................... A-1 B. NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review ................................................................................................................ B-1 C. NEI 04-02 Table B Fire Area Transition ..................................................... C-1 D. NEI 04-02 Non-Power Operational Modes Transition ..................................... D-1 PINGP                                                                                                  Page ii - Revision 1

Northern States Power - Minnesota                                                    NFPA 805 Transition Report E. NEI 04-02 Radioactive Release Transition ....................................................... E-1 F. Fire-Induced Multiple Spurious Operations Resolution ................................. F-1 G. Recovery Actions Transition............................................................................ G-1 H. NFPA 805 Frequently Asked Question Summary Table ................................ H-1 I. Definition of Power Block ................................................................................... I-1 J. Fire Modeling V&V ............................................................................................. J-1 K. Existing Licensing Action Transition .............................................................. K-1 L. NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) ... L-1 M. License Condition Changes ............................................................................. M-1 N. Technical Specification Changes .................................................................... N-1 O. Orders and Exemptions .................................................................................... O-1 P. RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) ........................................ P-1 Q. No Significant Hazards Evaluations ................................................................ Q-1 R. Environmental Considerations Evaluation ..................................................... R-1 S. Plant Modifications and Items for Implementation.......................................... S-1 T. Clarification of Prior NRC Approvals................................................................ T-1 U. Internal Events PRA Quality ............................................................................. U-1 V. Fire PRA Quality ................................................................................................. V-1 W. Fire PRA Insights .............................................................................................. W-1 PINGP                                                                                           Page iii - Revision 1

Northern States Power - Minnesota                                  NFPA 805 Transition Report Revision Status The following table lists sections of the PINGP NFPA 805 Transition Report and Attachments and identifies their current revision status. This Revision Status section was added to the Transition Report in Revision 1.
Pages designated Revision 0 were included in the September 28, 2012 submittal and have not been changed.
Pages designated Revision 1 have been updated for the May 1, 2014 Supplement and supersede the following:
* Pages in the September 28, 2012 submittal,
* Pages in Attachment U previously marked Revised that were included in the November 8, 2012 submittal addressing the Internal Flooding PRA peer review (ADAMS Accession No. ML12314A144), and
* Pages in Attachment W previously marked Revised that were included in the December 18, 2012 submittal that responded to NRC questions in support of Acceptance (ADAMS Accession No. ML12354A464).
Revised text is identified by a vertical bar in the right-hand margin except for Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, changes in format or pagination), which are not marked.
Section                            Revision Table of Contents                                             1 Revision Status                                               1 Summary of Changes                                            1 Executive Summary                                             1 Acronym List                                                  1 1.0 Introduction                                              1 2.0 Overview of Existing Fire Protection Programs             0 3.0 Transition Process                                        0 4.0 Compliance with NFPA 805 Requirements                     1 5.0 Regulatory Evaluation                                     1 6.0 References                                                1 Attachment A, NEI 04-02 Table B-1                             1 Attachment B, NEI 04-02 Table B-2                             1 Attachment C, NEI 04-02 Table B-3                             1 Attachment D, Non Power Operational Modes                     1 PINGP                                                                    Page iv - Revision 1

Northern States Power - Minnesota                             NFPA 805 Transition Report Section                       Revision Transition Attachment E, Radioactive Release Transition              1 Attachment F, Fire-Induced Multiple Spurious              1 Operations Resolution Attachment G, Recovery Actions Transition                 1 Attachment H, NFPA 805 Frequently Asked                   1 Questions Summary Table Attachment I, Definition of Power Block                   1 Attachment J, Fire Modeling V&V                           1 Attachment K, Existing Licensing Actions Transition       0 Attachment L, NFPA 805 Chapter 3 Requirements             0 for Approval Attachment M, License Condition Changes                   1 Attachment N, Technical Specification Changes             0 Attachment O, Orders and Exemptions                       0 Attachment P, RI-PB Alternatives to NFPA 805 10           0 CFR 50.48(c)(4)
Attachment Q, No Significant Hazards Evaluation           0 Attachment R, Environmental Considerations                0 Evaluation Attachment S, Plant Modifications                         1 Attachment T, Clarification of Prior NRC Approvals        0 Attachment U, Internal Events PRA Quality                 1 Attachment V, Fire PRA Quality                            1 Attachment W, Fire PRA Insights                           1 PINGP                                                                Page v - Revision 1

Northern States Power - Minnesota                              NFPA 805 Transition Report Summary of Changes This Summary of Changes section was added to the Transition Report in Revision 1.
Revision           Affected Section                        Change 0                     All        Initial submittal, September 2012 Revised       Attachment U, pages U- Updated to address final peer review of (November       18, U-19               Internal Flooding PRA, including closure of 8, 2012)                             Findings in Table U-2 Revised       Attachment W           Revised to correct errors (December 18, 2012) 1         Revision Status        Added Summary of Changes     Added Executive Summary      Described Supplement Acronym List           Updated list 1.0, Introduction      Described Supplement 4.1.1, Overview of     Revised EC number Evaluation Process 4.2.1.1, Compliance    Revised to clarify gap analysis between NEI with NFPA Section      00-01, Revision 1 and Revision 2; revised EC 2.4.2                  numbers 4.2.1.2, Safe and      Revised to delete references to PRISM, Stable Conditions for  added control room HVAC discussion the Plant 4.2.1.3, Establishing  Revised EC number; editorial correction Recovery Actions 4.2.1.4, Evaluation of Editorial correction Multiple Spurious Operations 4.3.2, Non-Power       Revised EC number Operational Modes 4.4.2, Radioactive     Revised EC number; deleted discussion about Release Performance    preparation of a fire strategy for the Criteria, Results of   Containment Access Facility Evaluation Process PINGP                                                                 Page vi - Revision 1

Northern States Power - Minnesota                                 NFPA 805 Transition Report Revision           Affected Section                          Change 4.5, Fire PRA and        Described revision to Fire PRA and focused Performance Based        Peer Review for Hot Gas Layer methodology; Approaches               also updated the Internal Flooding Peer Review and made an editorial correction 4.6.2, Overview of Post- Revised to clarify that 10 CFR 20 limits will Transition NFPA 805      not be exceeded during radioactive releases Monitoring Program 4.8.2, Plant             Revised EC number for Attachment S, and Modifications and Items  clarified that there are no outstanding plant to be Completed During   modifications with respect to the Fire PRA Implementation           model other than items in Attachment S; also revised reference to Table S-1 to refer to a completed modification 5.2.1, License           Revise to note that the RG 1.205 license Condition Changes        condition was modified 5.5, Transition          Added sentence to indicate that Table S-3, Implementation           item 20 will be completed after completion of Schedule                 the modifications in Table S-2 6.0, References          Added correspondence subsequent to the September 28, 2012 submittal, including additional information to support NRC acceptance, the acceptance letter, and letters discussing the May 1, 2014 supplement; also updated Engineering Change (EC) list for the Supplement Attachment A             Added verification of technical bases for Complies by Previous NRC Approval statements; also, revised the Compliance Statements for sections 3.3.7, 3.4.3(a)(2),
3.5.6, 3.9.4, and 3.10.9 Attachment B             Deleted references to PRISM and added references to Genesis; also updated references and Alignment Basis statements to reflect the revised NSCA model Attachment C             Updated for revised Fire PRA, VFDRs, FREs, recovery actions and modifications Attachment D             Revised EC number and updated to reflect revised NPO model PINGP                                                                   Page vii - Revision 1

Northern States Power - Minnesota                           NFPA 805 Transition Report Revision          Affected Section                      Change Attachment E        Removed Fire Area (FA) 40, Maintenance Storage Shed, from radiologically controlled areas; also added FA 9 and incorporated several clarifications Attachment F        Updated to reflect additional expert panel review of electrical systems and to identify revised notebooks Attachment G        Revised to state that PINGP does not have a primary control station that meets RG 1.205; also revised Recovery Actions for revised Fire PRA, including new actions Attachment H        Updated FAQ list to add items 12-0063 and 12-0067 Attachment I        Revised FA 40 description, deleted YARD items, and revised EC number Attachment J        Updated Fire Modeling V&V Attachment M        Revised License Condition to clarify that it does not apply to equivalency evaluations Attachment S        Revised Modifications for revised Fire PRA and additional fire modeling; added item to Table S-1, revised Table S-2, and revised Table S-3 Attachment U        Revised for closure of Finding, and added discussion of planned focused-scope peer review for the new reactor coolant pump seal model Attachment V        Revised for closure of F&Os; deleted PRISM; added focused peer review of HGL methodology Attachment W        Revised Fire PRA results PINGP                                                             Page viii - Revision 1

Northern States Power - Minnesota                                          Executive Summary Executive Summary Northern States Power Company, a Minnesota corporation (NSPM) doing business as Xcel Energy, will transition the fire protection program for Prairie Island Nuclear Generating Plant Units 1 & 2 (PINGP) to a new Risk-Informed, Performance-Based (RI-PB) alternative per 10 CFR 50.48(c) which incorporates by reference National Fire Protection Association Standard 805 (NFPA 805). The licensing basis per 10 CFR 50.48(b) and 10 CFR 50, Appendix R, will be superseded.
The voluntary adoption of 10 CFR 50.48(c) by PINGP does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, General Design Criteria (GDC) 3, Fire Protection. However, compliance with the new rule establishes compliance with these sections. By letter dated June 22, 2011 (ADAMS Accession No. ML111740866), NSPM committed to submit a license amendment request by September 30, 2012, for PINGP to transition to 10 CFR 50.48(c).
The transition process consisted of a review and update of PINGP documentation, including the development of a Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850 as guidance. This Transition Report summarizes the transition process and results. This Transition Report contains information:
* Required by 10 CFR 50.48(c).
* Recommended by guidance document Nuclear Energy Institute (NEI) 04-02 Revision 2 and appropriate Frequently Asked Questions (FAQs).
* Recommended by guidance document Regulatory Guide 1.205 Revision 1.
Section 4 of the Transition Report provides a summary of compliance with the following NFPA 805 requirements:
* Fundamental Fire Protection Program Elements and Minimum Design Requirements.
* Nuclear Safety Performance Criteria, including:
o Nuclear Safety Capability Assessment, Safe and Stable Conditions for the Plant, Establishing Recovery Actions, Evaluation of Multiple Spurious Operations, o Existing Engineering Equivalency Evaluations, o Licensing Actions, and o Fire Area Transitions.
* Non-Power Operational Modes.
* Radioactive Release Performance Criteria.
* Fire PRA and Performance-Based Approaches.
* Monitoring Program.
* Program Documentation, Configuration Control, and Quality Assurance.
PINGP                                                                      Page ix - Revision 1

Northern States Power - Minnesota                                         Executive Summary Section 5 of the Transition Report provides regulatory evaluations and associated attachments, including:
* Changes to the Fire Protection License Condition.
* Changes to Technical Specifications, Orders, and Exemptions.
* Determination of No Significant Hazards and evaluation of Environmental Considerations.
The attachments to the Transition Report include details to support the transition process and results.
Attachment H contains the approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this License Amendment Request.
Revision 1 to this Transition Report includes the following:
* Changes to reflect a revision to the Fire PRA, including changes in fire modeling, modifications, recovery actions, and calculated risk values,
* Changes to reflect revisions to the Nuclear Safety Capability Assessment (NSCA) and Non-Power Operations (NPO) models to replace PRISM software,
* Changes to the lists of modifications and implementation items based on additional fire modeling and engineering evaluations, and
* Changes to address generic industry issues addressed in Generic Requests for Additional Information (RAIs) and in revisions to the NEI 04-02 template that were more recent than Revision 1L used in the original submittal.
The entire PINGP NFPA 805 Transition Report document is included with this supplement, to simplify the review effort. Sections and Attachments to the original 2012 Transition Report that have been changed are identified in the Revision Status table, and are briefly described in the Summary of Changes. Revision 1 is not a complete revision to the Transition Report and many attachments have not been changed.
Where changes in text or content have been made, the entire section or attachment is marked Revision 1 in the footer and the affected text is identified by a vertical bar in the right-hand margin. Exceptions include Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, format or pagination changes), which are not marked. Sections or attachments that have not been changed are marked Revision 0.
PINGP                                                                     Page x - Revision 1

Northern States Power - Minnesota                                   Acronym List Acronym List AC            Alternating Current ACUBE         Advanced Cutset Upper Bound Estimator ADAMS         Agencywide Documents Access and Management System ADS           Automatic Depressurization System AEC           Atomic Energy Commission AF            Auxiliary Feedwater AFP           Area Fire Plan AFW           Auxiliary Feedwater System AHJ           Authority Having Jurisdiction ANS           American Nuclear Society ANSI          American National Standards Institute APCSB         Auxiliary Power Conversion Systems Branch AR            Action Request ARP           Alarm Response Procedure ASD           Atmospheric Steam Dump ASEP          Accident Sequence Evaluation Program ASME          American Society of Mechanical Engineers ASTM          American Society for Testing and Materials BE            Basic Event BKR           Breaker BTP           Branch Technical Position BTU           British Thermal Unit BWROG         Boiling Water Reactor Owners Group CAAB          Common Area of the Auxiliary Building CAF           Containment Access Facility CAFTA         Computer Aided Fault Tree Analysis CAS           Central Alarm Station CB            Control Building (Fire Area)
CCDP          Conditional Core Damage Probability CC            Capability Category CC            Component Cooling System CD            Condensate System CD            Control Damper CCF           Common Cause Failure CCW           Component Cooling Water CDF           Core Damage Frequency CFAST         Consolidated Fire and Smoke Transport CFCU          Containment Fan Cooler Units CFR           Code of Federal Regulations CL            Cooling Water CLB           Current Licensing Basis CLERP         Conditional Large Early Release Probability CO2           Carbon Dioxide PINGP                                                         Page xi - Revision 1

Northern States Power - Minnesota                                Acronym List CPS           Common Power Supply CR            Control Room CRD           Control Rod Drive CRDM          Control Rod Drive Mechanism CS            Containment Spray CSD           Cold Shutdown CSR           Cable Spreading Room CST           Condensate Storage Tank CT            Current Transformer CT            External Circulating Water System CTEH          Cooling Tower Equipment House CTPH          Cooling Tower Pump House CV            Control Valve CVCS          Chemical and Volume Control System D(1-6)        Emergency Diesel Generator DA            Deluge Automatic DB            Design Basis DBA           Design Basis Accident DBD           Design Basis Document DC            Direct Current DDCLP         Diesel Driven Cooling Water Pump DDCWP         Diesel Driven Cooling Water pump DDFP          Diesel Driven Fire Pump DID           Defense-in-Depth DH            Decay Heat DG            Diesel Generator DM            Deluge Manual DPS           Dry Pipe System EC            Engineering Change ECCS          Emergency Core Cooling System EDG           Emergency Diesel Generator EDMG          Earthquake Damage Mitigation Guide EEE           Engineering Equivalency Evaluation EEEE          Existing Engineering Equivalency Evaluation EF            Error Factor EL            Elevation EM            Event Monitoring EOF           Emergency Operating Facility EOP           Emergency Operating Procedure EPM           Engineering, Planning, and Management, Inc.
EPRI          Electrical Power Research Institute ERFBS         Electrical Raceway Fire Barrier System ERO           Emergency Response Organization ES            Equipment Selection ESF           Engineered Safety Features ESW           Emergency Service Water PINGP                                                     Page xii - Revision 1

Northern States Power - Minnesota                                             Acronym List EX            Exterior (fire area)
EXC           Excluding
&#xba;F            Degrees Fahrenheit F&O           Fact and Observation FA            Fire Area FAQ           Frequently Asked Question FC            Fire Compartment FDS           Fire Dynamics Simulator FDT           Fire Dynamics Tool FIVE          Fire Induced Vulnerability Evaluation FHA           Fire Hazards Analysis FIF           Fire Ignition Frequency FM            Factory Mutual FO            Fuel Oil FP            Fire Protection FPP           Fire Protection Program FPE           Fire Protection Engineer FPIE          Full Power Internal Events FPRA          Fire Probabilistic Risk Assessment FR            Federal Register FRACQA        Functional Responsibilities, Administrative Controls, and Quality Assurance FRANX         Fire Risk Analysis Software Tool FRE           Fire Risk Evaluation FSAR          Final Safety Analysis Report FSS           Fire Scenario Selection ft            Feet FV            Fussell-Vesely FW            Feedwater gal           Gallon GDC           General Design Criterion GL            U.S. NRC Generic Letter GPM           Gallons Per Minute HAD           Heat Actuated Device HEAF          High Energy Arc Fault HEP           Human Error Probability HEPA          High-Efficiency Particulate Air HFE           Human Failure Event HGL           Hot Gas Layer HLR           High Level Requirement HRA           Human Reliability Analysis HRE           Higher Risk Evolution HRR           Heat Release Rate HSDP          Hot Shutdown Panel HSS           High Safety Significant HVAC          Heating, Ventilation, and Air Conditioning PINGP                                                                 Page xiii - Revision 1

Northern States Power - Minnesota                                      Acronym List HX            Heat Exchanger I&C           Instrumentation and Controls ID            Identification IE            Initiating Event IEEE          Institute of Electrical and Electronic Engineers IF            Ignition Frequency IF            Internal Flooding IN            U.S. NRC Information Notice IPCEA         Insulated Power Cable Engineers Association IPEEE         Individual Plant Examination of External Events IPLD          Integrated Plant Logic Diagram IS            Intake Structure ISDS          Ignition Source Data Sheet ISFSI         Independent Spent Fuel Storage Installation ISLOCA        Interfacing System Loss of Coolant Accident KSF           Key Safety Function KV            kilovolt KW            kilowatt L             Liter LA            Licensing Action LAR           License Amendment Request LCO           Limiting Conditions for Operation LE            LERF LERF          Large Early Release Frequency LFS           Limiting Fire Scenario LLC           Limited Liability Company LLOCA         Large Loss of Coolant Accident LLRW          Low Level Radwaste LOCA          Loss of Coolant Accident LOOP          Loss of Offsite Power LPCI          Low Pressure Coolant Injection LSELS         Load Shed and Emergency Load Sequencer LSS           Low Safety Significant m             meter MAAP          Modular Accident Analysis Program MCA           Multi-Compartment Analysis MCB           Main Control Board MCC           Motor Control Center MCR           Main Control Room MDAFWP        Motor Driven Auxiliary Feedwater Pump MDFP          Motor Driven Fire Pump MEFS          Maximum Expected Fire Scenario MFW           Main Feedwater MG            Motor Generator MHIF          Multiple High Impedance Fault min           minute PINGP                                                          Page xiv - Revision 1

Northern States Power - Minnesota                                        Acronym List MOV           Motor Operated Valve MQH           McCaffrey, Quintiere, and Harkleroad MSIV          Main Steam Isolation Valve MSLB          Main Steam Line Break MSO           Multiple Spurious Operation MTTR          Mean Time To Repair MV            Motor Operated Valve MVSG          Medium Voltage Switchgear N/A           Not Applicable NEI           Nuclear Energy Institute NEIL          Nuclear Electric Insurance Limited NEPIA         Nuclear Energy Property Insurance Association (now NEIL)
NIST          National Institute of Standards and Technology NFPA          National Fire Protection Association NMC           Nuclear Management Company, LLC NPO           Non-Power Operational NPP           Nuclear Power Plant NPSH          Net Positive Suction Head NRC           U.S. Nuclear Regulatory Commission NSCA          Nuclear Safety Capability Assessment NSEL          Nuclear Safety Equipment List NSHC          No Significant Hazards Consideration NSP           Northern States Power NSP           Non-Suppression Probability NSPC          Nuclear Safety Performance Criteria NSPM          Northern States Power - Minnesota NUMARC        Nuclear Management and Resource Council NUREG         US Nuclear Regulatory Commission Publication NUREG/CR      NUREG document prepared by NRC contractors OAB           Old Administration Building OCT           Overcurrent Trip OMA           Operator Manual Action OOS           Out Of Service OPEX          Operating Experience OS&Y          Outside Screw and Yoke P&ID          Piping and Instrumentation Diagram PA            Preaction PA            Public Address PAU           Physical Analysis Unit PB            Performance Based PBX           Private Branch Exchange PC            Primary Containment PCD           PRA Change Database PCS           Power Conversion System PCS           Primary Control Station PDS           Plant Damage State PINGP                                                             Page xv - Revision 1

Northern States Power - Minnesota                                          Acronym List PH            Pumphouse PI            Project Instruction PINGP         Prairie Island Nuclear Generating Plant - Units 1 & 2 PORV          Power Operated Relief Valve POS           Plant Operating State PPE           Personal Protective Equipment PR            Peer Review PRA           Probabilistic Risk Assessment PRISM         Plant Risk-Informed Systems Module PRM           Plant Response Model PSA           Probabilistic Safety Assessment PSF           Performance Shaping Factor PVC           Polyvinyl Chloride PWR           Pressurized Water Reactor PWROG         Pressurized Water Reactor Owners Group QA            Quality Assurance QNS           Quantitative Screening QU            Quantification RA            Risk Assessment RAI           Request for Additional Information RAW           Risk Achievement Worth RC            Reactor Coolant RCA           Radiologically Controlled Area RCP           Reactor Coolant Pump RCS           Reactor Coolant System RES           Nuclear Regulatory Commission - Office of Nuclear Regulatory Research RES           Radiant Energy Shield RG            U.S. NRC Regulatory Guide RH            Residual Heat Removal RHR           Residual Heat Removal RI-PB         Risk-Informed, Performance-Based RIS           Regulatory Issue Summary RPS           Reactor Protection System RPV           Reactor Pressure Vessel RRW           Risk Reduction Worth RSP           Remote Shutdown Panel RW            River Water RWCU          Reactor Water Cleanup RWST          Refueling Water Storage Tank rx-yr         Reactor year SAR           Safety Analysis Report SBO           Station Blackout SBDG          Standby Diesel Generator SC            Success Criteria SCBA          Self-Contained Breathing Apparatus SCP           Security Control Point PINGP                                                               Page xvi - Revision 1

Northern States Power - Minnesota                               Acronym List SDC           Shutdown Cooling SE            Safety Evaluation SECY          Commission Paper (NRC)
SER           Safety Evaluation Report SFP           Spent Fuel Pool SFPE          Society of Fire Protection Engineers SG            Steam Generator SGTR          Steam Generator Tube Rupture SI            Safety Injection SLD           Shutdown Logic Diagram SP            Special Publication sq ft         Square Feet SR            Supporting Requirement SR            Surveillance Requirement SRM           Staff Requirements Memorandum SRV           Safety Relief Valve SSA           Safe Shutdown Analysis SSC           Structures, Systems, and Components SSD           Safe Shutdown SSE           Safe Shutdown Earthquake SSEL          Safe Shutdown Equipment List SSLD          Safe Shutdown Logic Diagram SSO           Single Spurious Operation STA           Shift Technical Advisor SUT           Startup Transformer SW            Service Water SWGR          Switchgear SWP           Stairway Wet Pipe TB            Turbine Building TBHX          Thermal Barrier Heat Exchanger TD            Turbine Driven TDAFP         Turbine Driven Auxiliary Feedwater Pump TDAFW         Turbine Driven Auxiliary Feedwater [Pump]
T-H           Thermal-Hydraulic TM            Testing & Maintenance TSC           Technical Support Center TS            Technical Specification UAM           Unreviewed Analysis Method (for Fire PRA)
UFSAR         Updated Final Safety Analysis Report UL            Underwriters Laboratory USAR          Updated Safety Analysis Report USC           United States Code VAC           Volts Alternating Current VC            Chemical & Volume Control VCT           Volume Control Tank V&V           Verification and Validation PINGP                                                   Page xvii - Revision 1

Northern States Power - Minnesota                              Acronym List VDC           Volts Direct Current VFDR          Variance From Deterministic Requirement WCAP          Westinghouse Commercial Atomic Power WOG           Westinghouse Owners Group WPS           Wet Pipe Sprinkler yr            Year ZOI           Zone Of Influence PINGP                                                 Page xviii - Revision 1

Northern States Power - Minnesota                                            1.0 Introduction

==1.0     INTRODUCTION==

The Nuclear Regulatory Commission (NRC) has promulgated an alternative rule for fire protection requirements at nuclear power plants, 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). NSPM is implementing the Nuclear Energy Institute methodology NEI 04-02, Guidance for Implementing a Risk-informed, Performance-based Fire Protection Program Under 10 CFR 50.48(c) (NEI 04-02), to transition PINGP from its current fire protection licensing basis to the new requirements as outlined in NFPA 805. This report describes the transition methodology utilized and documents how PINGP complies with the new requirements.
Revision 1 to this Transition Report includes changes and corrections that NSPM determined were necessary after the NFPA 805 License Amendment Request (LAR) was submitted. The LAR was submitted for NRC review and approval on September 28, 2012 (ADAMS Accession No. ML12278A405). Additional information was submitted in a letter dated November 8, 2012 (ADAMS Accession No. ML12314A144), to provide final results of the Internal Flooding PRA peer review, and in a letter dated December 18, 2012 (ADAMS Accession No. ML12354A464), to address errors in the Fire PRA.
The NRC subsequently accepted the LAR for review in a letter dated January 2, 2013 (ADAMS Accession No. ML13002A209).
During preparations for the initial NRC audit, NSPM determined that a revision to the Fire PRA was needed and in a letter dated May 3, 2013 (ADAMS Accession No. ML13126A115), committed to provide a supplement to the LAR by May 1, 2014.
Revision 1 to this Transition Report includes the changes that are needed to satisfy this commitment. The revision to the Fire PRA resulted in changes to calculated risk values, fire modeling, recovery actions, and modifications, as provided in this LAR supplement.
In addition, Revision 1 to this Transition Report includes changes to the Nuclear Safety Capability Assessment (NSCA) and Non-Power Operations (NPO) models that resulted from the replacement of PRISM computer software. The modifications and items for implementation were also revised based on additional fire modeling and engineering reviews.
Other reviews were determined to be necessary and are addressed in this supplement.
An additional expert panel review was conducted for electrical systems to identify Multiple Spurious Operations (MSO) concerns. Also, a focused-scope peer review was performed for a hot gas layer (HGL) methodology not previously used.
This supplement also addresses generic industry issues that have been identified since submittal of the LAR. Issues identified as Generic Requests for Additional Information (RAIs) as of January 2014 are addressed. This resulted in a change to the License Condition and a number of other clarifications. Also, changes to the NEI 04-02 template subsequent to Revision 1L, which was the basis for the original LAR submittal, have been considered through Revision 1P.
To simplify the review effort, the entire PINGP NFPA 805 Transition Report document is included with this supplement. Sections and Attachments to the original 2012 Transition Report that have been changed are identified in the Revision Status table, and are briefly described in the Summary of Changes. Revision 1 is not a complete revision to the Transition Report and many attachments have not been changed. Where changes PINGP                                                                     Page 1 - Revision 1

Northern States Power - Minnesota                                                      1.0 Introduction in text or content have been made, the entire section or attachment is marked Revision 1 in the footer and the affected text is identified by a vertical bar in the right-hand margin. Exceptions include Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, changes in format or pagination), which are not marked. Sections or attachments that have not been changed are marked Revision 0.
1.1     Background 1.1.1 NFPA 805 - Requirements and Guidance On July 16, 2004 the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes new Risk-Informed, Performance-Based (RI-PB) fire protection requirements. 10 CFR 50.48(c) incorporates by reference, with exceptions, the National Fire Protection Associations NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition, as a voluntary alternative to 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning.
As stated in 10 CFR 50.48(c)(3)(i), any licensees adoption of a RI-PB program that complies with the rule is voluntary. This rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48(b), for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48(f), plants shutdown in accordance with 10 CFR 50.82(a)(1).
NEI developed NEI 04-02 to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805.
The NRC issued Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants, which endorses NEI 04-02, with exceptions, in December 2009.1 A depiction of the primary document relationships is shown in Figure 1-1:
1 Where referred to in this document NEI 04-02 is Revision 2 and RG 1.205 is Revision 1.
PINGP                                                                              Page 2 - Revision 1

Northern States Power - Minnesota                                             1.0 Introduction Figure 1-1 NFPA 805 Transition - Implementation Requirements/Guidance 1.1.2 Transition to 10 CFR 50.48(c) 1.1.2.1    Start of Transition Nuclear Management Company (NMC) submitted a letter of intent to the NRC on November 30, 2005 (ADAMS Accession No. ML053460342) for PINGP to adopt NFPA 805 in accordance with 10 CFR 50.48(c). NSPM has subsequently assumed responsibility for actions and commitments previously submitted by NMC.
By letter dated September 7, 2006 (ADAMS Accession No. ML061500035), the NRC granted a three year enforcement discretion period. In accordance with NRC Enforcement Policy, the enforcement discretion period will continue until the NRC approval of the license amendment request (LAR) is completed.
In accordance with SECY-11-0061, in a letter dated June 22, 2011 (ADAMS Accession No. ML111740866), NSPM committed to submit a license amendment request no later than September 30, 2012, for PINGP to transition to 10 CFR 50.48(c). By letter dated July 29, 2011, (ADAMS Accession No. ML112010417), the NRC acknowledged the application date for PINGP and granted an extension of enforcement discretion.
PINGP                                                                     Page 3 - Revision 1

Northern States Power - Minnesota                                             1.0 Introduction 1.1.2.2    Transition Process The transition to NFPA 805 includes the following high level activities:
* A new fire safe shutdown analysis;
* A new Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, as guidance and a revision to the Internal Events PRAs to support the Fire PRAs; and
* Completion of activities required to transition the pre-transition Licensing Basis to 10 CFR 50.48(c) as specified in NEI 04-02 and RG 1.205.
1.2    Purpose The purpose of the Transition Report is as follows:
: 1) Describe the process implemented to transition the current fire protection program to compliance with the additional requirements of 10 CFR 50.48(c);
: 2) Summarize the results of the transition process;
: 3) Explain the bases for conclusions that the fire protection program complies with 10 CFR 50.48(c) requirements;
: 4) Describe the new fire protection licensing basis; and
: 5) Describe the configuration management processes used to manage post-transition changes to the plant and the Fire Protection Program, and resulting impact on the Licensing Basis.
PINGP                                                                      Page 4 - Revision 1

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program 2.0     OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1     Current Fire Protection Licensing Basis PINGP Unit 1 was licensed to operate on August 9, 1973 and Unit 2 was licensed to operate on October 29, 1974. As a result, the PINGP fire protection program is based on compliance with 10 CFR 50.48(a), 10 CFR 50.48(b), 10 CFR 50 Appendix R, and the following License Condition:
NSPM, PINGP Renewed Operating Licenses Nos. DPR-42 (Unit 1) and DPR-60 (Unit
: 2) both include License Condition 2.C.(4), Fire Protection, which states:
NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29, 1980, July 28, 1981, October 27, 1989, and October 6, 1995, subject to the following provision:
NSPM 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.
2.2     NRC Acceptance of the Fire Protection Licensing Basis To conform to NRC guidelines issued prior to November 1980, Northern States Power performed a fire hazard analysis which analyzed the PINGP fire protection program against the guidance of Appendix A to Branch Technical Position (BTP) Auxiliary Power Conversion Systems Branch (APCSB) 9.5-1. The results of this analysis, in addition to proposed modifications and additions to the fire protection program, were communicated to the NRC by letters dated March 11, 1977, July 5, 1977, May 18, 1978, June 22, 1978, January 2, 1979, March 9, 1979, and May 2, 1979. Furthermore this analysis served as the basis for the Appendix A to BTP APCSB 9.5-1 safety evaluation dated September 6, 1979, and the associated License Amendment Nos. 39 (Unit 1) and 33 (Unit 2), which implemented fire protection technical specifications and added a license condition for the completion of fire protection modifications, submittal of additional information, and implementation of administrative controls.
The current Fire Protection License Condition quoted above identifies a number of NRC Safety Evaluation Reports (SERs) and approval letters which are briefly summarized below. Any provisions of these documents that are to be transitioned to the NFPA 805 fire protection program are identified in other sections and/or attachments to this Transition Report.
NRC letter dated February 14, 1978 In a letter dated February 14, 1978, the NRC issued License Amendment Nos. 26 (Unit
: 1) and 20 (Unit 2) which revised the PINGP Technical Specifications (TSs) to add Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) for fire protection equipment and instrumentation, and Administrative Controls related to fire protection.
PINGP                                                                         Page 5 - Revision 0

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program NRC SER dated September 6, 1979 In the SER for License Amendment Nos. 39 (Unit 1) and 33 (Unit 2) dated September 6, 1979, the NRC added a license condition relating to the completion of facility modifications and implementation of administrative controls, and approved TS changes regarding detector functional test frequency, valve position verification, fire brigade size, and administrative responsibilities for fire protection and training.
NRC Approval dated April 21, 1980 In a letter dated April 21, 1980, the NRC approved fourteen fire protection modifications that were previously described in the September 6, 1979 SER, and that had been designated as requiring additional information prior to implementation.
NRC Approval dated December 29, 1980 In a letter dated December 29, 1980, the NRC approved additional fire protection modifications that had previously been described in the September 6, 1979 SER, and that had been designated as requiring additional information prior to implementation.
The December 29 NRC letter discussed fire barrier penetration seal upgrades, structural steel member coating in the vicinity of the lube oil reservoir, installation of fire dampers, a fire barrier enclosure for the motor driven fire pump, and fire detector response capabilities.
NRC SER dated July 28, 1981 In the SER for License Amendment Nos. 49 (Unit 1) and 43 (Unit 2) dated July 28, 1981, the NRC approved modifications to the TS LCOs and surveillance requirements for Fire Detection and Protection Systems, and accompanying Bases descriptions.
These changes reflected modifications to fire protection equipment, structures, testing requirements, and administrative controls.
NRC SER dated October 27, 1989 In the SER for License Amendment Nos. 91 (Unit 1) and 84 (Unit 2) dated October 27, 1989, the NRC approved numerous changes throughout the TS in support of a human error reduction program. These changes included the reorganization and standardization of some TS sections, including fire protection program requirements, to achieve consistency and uniformity throughout the TS and minimize the potential for confusion.
NRC SER dated October 6, 1995 In the SER for License Amendment Nos. 120 (Unit 1) and 113 (Unit 2) dated October 6, 1995, the NRC approved TS changes to remove Fire Protection Program requirements from the TS. In accordance with Generic Letter 86-10, fire protection program elements were removed from the TS and the NRC-approved Fire Protection Program and major commitments, including the fire hazards analysis, were incorporated by reference into the USAR. A new fire protection license condition was added.
PINGP                                                                         Page 6 - Revision 0

Northern States Power - Minnesota              2.0 Overview of Existing Fire Protection Program Exemptions The following is a list of the exemptions that have been granted by the NRC from the requirements of Appendix R to 10 CFR 50, Sections III.G, III.J, and III.O:
* An exemption from Section III.G.3.b for lack of a fixed fire suppression system in the Control Room, Units 1 and 2, Fire Area 13 (NRC SER dated February 2, 1983).
* An exemption from Subsection III.G.2 for lack of twenty feet of separation free of intervening combustibles or one hour fire rated barriers between redundant trains needed for safe shutdown in the A Train Hot Shutdown Panel, Instrument Air and Auxiliary Feedwater Pump Rooms, Units 1 and 2, Fire Area 31 (NRC SER dated May 4, 1983).
* An exemption from Subsection III.G.2 for lack of twenty feet of separation free of intervening combustibles or one hour fire rated barriers between redundant trains needed for safe shutdown in the B Train Hot Shutdown Panel, Instrument Air and Auxiliary Feedwater Pump Rooms, Units 1 and 2, Fire Area 32 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Operating Level, Unit 1, Fire Area 60 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Operating Level, Unit 2, Fire Area 75 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Normal Switchgear Room, Unit 1, Fire Area 37 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Ground Floor Level, Unit 1, Fire Area 58 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Ground Floor Level, Unit 2, Fire Area 73 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Mezzanine Level, Unit 1, Fire Area 59 (NRC SER dated January 9, 1984).
PINGP                                                                        Page 7 - Revision 0

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Mezzanine Level, Unit 2, Fire Area 74 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for the lack of twenty feet of separation free of intervening combustibles between redundant trains needed for safe shutdown in the Containment, Units 1 and 2, Fire Areas 1 and 71, including a commitment to install a one-hour fire barrier to protect the cabling for one division of the pressurizer level transmitters in Unit 2 (NRC SER dated July 31, 1984). As described in Attachment K, different methods of protection for this cabling are provided in Unit 1 and Unit 2.
* An exemption from Section III.O for a reactor coolant pump lube oil collection system that does not drain to a vented closed container that can hold the entire lube oil system inventory, but instead is piped to a sump inside Containment and then is pumped to a closed vented container located in the Auxiliary Building; Units 1 and 2, Containment Fire Areas 1 and 71 (NRC SER dated July 31, 1984).
* An exemption from Section III.G.1 to allow operators to remove fuses from Power Operated Relief Valve (PORV) control circuits to preclude inadvertent valve operation in the event of a control room evacuation; this is considered a repair to ensure that one train of safe shutdown equipment remains operable which is contrary to Section III.G.1, Control Room, Units 1 and 2, Fire Area 13 (NRC SER dated February 21, 1995).
PINGP                                                                         Page 8 - Revision 0

Northern States Power - Minnesota                                      3.0 Transition Process 3.0    TRANSITION PROCESS 3.1    Background Section 4.0 of NEI 04-02 describes the process for transitioning from compliance with the current fire protection licensing basis to the new requirements of 10 CFR 50.48(c).
NEI 04-02 contains the following steps:
: 1) Licensee determination to transition the licensing basis and devote the necessary resources to it;
: 2) Submit a Letter of Intent to the NRC stating the licensees intention to transition the licensing basis in accordance with a tentative schedule;
: 3) Conduct the transition process to determine the extent to which the current fire protection licensing basis supports compliance with the new requirements and the extent to which additional analyses, plant and program changes, and alternative methods and analytical approaches are needed;
: 4) Submit a LAR;
: 5) Complete transition activities that can be completed prior to the receipt of the License Amendment;
: 6) Receive a Safety Evaluation; and
: 7) Complete implementation of the new licensing basis, including completion of modifications identified in Attachment S.
3.2    NFPA 805 Process Section 2.2 of NFPA 805 establishes the general process for demonstrating compliance with NFPA 805. This process is illustrated in Figure 3-1. It shows that except for the fundamental fire protection requirements, compliance can be achieved on a fire area basis either by deterministic or RI-PB methods. Consistent with the guidance in NEI 04-02, NSPM has implemented the NFPA 805 Section 2.2 process by first determining the extent to which its current fire protection program supports findings of deterministic compliance with the requirements in NFPA 805. RI-PB methods are being applied to the requirements for which deterministic compliance could not be shown.
PINGP                                                                     Page 9 - Revision 0

Northern States Power - Minnesota                                                  3.0 Transition Process 2
Figure 3-1 NFPA 805 Process [NEI 04-02 Figure 3-1 based on Figure 2-2 of NFPA 805]
3.3      NEI 04 NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a RI-PB fire protection program. NEI 04-02 was developed to provide guidance on the overall process (programmatic, technical, and licensing) for transitioning from a traditional fire protection licensing basis to a new RI-PB method based upon NFPA 805, as shown in Figure 3-2.
2 Note: 10 CFR 50.48(c) does not incorporate by reference Life Safety and Plant Damage/Business Interruption goals, objectives and criteria. See 10 CFR 50.48(c) for specific exceptions to the incorporation by reference of NFPA 805.
PINGP                                                                                Page 10 - Revision 0

Northern States Power - Minnesota                                           3.0 Transition Process Section 4.0 of NEI 04-02 describes the detailed process for assessing a fire protection program for compliance with NFPA 805, as shown in Figure 3-2.
Figure 3-2 Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]
3.4    NFPA 805 Frequently Asked Questions (FAQs)
The NRC has worked with NEI and two Pilot Plants (Oconee Nuclear Station and Harris Nuclear Plant) to define the licensing process for transitioning to a new licensing basis under 10 CFR 50.48(c) and NFPA 805. Both the NRC and the industry recognized the need for additional clarifications to the guidance provided in RG 1.205, NEI 04-02, and the requirements of NFPA 805. The NFPA 805 FAQ process was jointly developed by NEI and NRC to facilitate timely clarifications of NRC positions. This process is described in a letter from the NRC dated July 12, 2006, to NEI (ML061660105) and in Regulatory Issues Summary (RIS) 2007-19, Process for Communicating Clarifications PINGP                                                                         Page 11 - Revision 0

Northern States Power - Minnesota                                    3.0 Transition Process of Staff Positions Provided in RG 1.205 Concerning Issues Identified during the Pilot Application of NFPA Standard 805, dated August 20, 2007 (ML071590227).
Under the FAQ Process, transition issues are submitted to the NEI NFPA 805 Task Force for review, and subsequently presented to the NRC during public FAQ meetings.
Once the NEI NFPA 805 Task Force and NRC reach agreement, the NRC issues a memorandum to indicate that the FAQ is acceptable. NEI 04-02 will be revised to incorporate the approved FAQs. This is an on-going revision process that will continue through the transition of NFPA 805 transition plants. Final closure of the FAQs will occur when future revisions of RG 1.205, endorsing the related revisions of NEI 04-02, are approved by the NRC. It is expected that additional FAQs will be written and existing FAQs will be revised as plants continue NFPA 805 transition after the Pilot Plant Safety Evaluations.
Attachment H contains the list of approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this LAR.
PINGP                                                                   Page 12 - Revision 0

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements 4.0     COMPLIANCE WITH NFPA 805 REQUIREMENTS 4.1     Fundamental Fire Protection Program and Design Elements The Fundamental Fire Protection Program and Design Elements are established in Chapter 3 of NFPA 805. Section 4.3.1 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis and plant configuration meets these criteria and for identifying the fire protection program changes that would be necessary for compliance with NFPA 805. NEI 04-02 Appendix B-1 provides guidance on documenting compliance with the program requirements of NFPA 805 Chapter 3.
4.1.1 Overview of Evaluation Process The comparison of the PINGP Fire Protection Program to the requirements of NFPA 805 Chapter 3 was performed and documented in PINGP Engineering Evaluation EC 23309 entitled NFPA 805 LAR Supplement Attachment A (Table B-1). Engineering Evaluation EC 23309 used the guidance contained in NEI 04-02, Section 4.3.1 and Appendix B-1 (See Figure 4-1).
Each section and subsection of NFPA 805 Chapter 3 was reviewed against the current fire protection program. Upon completion of the activities associated with the review, the following compliance statement(s) was used:
* Complies - For those sections/subsections determined to meet the specific requirements of NFPA 805.
* Complies with Item for Implementation - For those sections/subsections determined to meet the requirements of NFPA 805 upon completion of an item as identified in Attachment S.
* Complies with Clarification - For those sections/subsections determined to meet the requirements of NFPA 805 with clarification.
* Complies by previous NRC approval - For those sections/subsections where the specific NFPA 805 Chapter 3 requirements are not met but previous NRC approval of the configuration exists.
* Complies with use of Existing Engineering Equivalency Evaluations (EEEEs) -
For those sections/subsections determined to be equivalent to the NFPA 805 Chapter 3 requirements as documented by engineering analysis.
* Submit for NRC Approval - For those sections/subsections for which approval is sought in this LAR submittal in accordance with 10 CFR 50.48(c)(2)(vii). A summary of the bases of acceptability is provided (See Attachment L for details).
In some cases multiple compliance statements have been assigned to a specific NFPA 805 Chapter 3 section/subsection. Where this is the case, each compliance/compliance basis statement clearly references the corresponding requirement of NFPA 805 Chapter 3.
PINGP                                                                     Page 13 - Revision 1

Attachment W to this Enclosure contains Security-Related Information to be Withheld from Public Disclosure In Accordance with 10 CFR 2.390(d)(1)
Enclosure to L-PI-14-045 Northern States Power - Minnesota Prairie Island Nuclear Generating Plant Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants 2001 Edition Transition Report Revision 1 - April 2014 Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390(d)(1)
Upon removal of Attachment W, this Enclosure is uncontrolled.

Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390 Northern States Power - Minnesota Prairie Island Nuclear Generating Plant Units 1 & 2 Transition to 10 CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition Transition Report Revision 1 April 2014 Attachment W contains Security-Related Information Withhold Under 10 CFR 2.390 Upon removal of Attachment W, this Enclosure is uncontrolled

Northern States Power - Minnesota                                                        NFPA 805 Transition Report TABLE OF CONTENTS Revision Status ............................................................................................................ iv Summary of Changes .................................................................................................. vi Executive Summary ..................................................................................................... ix Acronym List ................................................................................................................ xi

==1.0 INTRODUCTION==
 ..................................................................................................... 1 1.1 Background........................................................................................................ 2 1.1.1 NFPA 805 - Requirements and Guidance ................................................. 2 1.1.2 Transition to 10 CFR 50.48(c).................................................................... 3 1.2 Purpose ............................................................................................................. 4 2.0 OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM ................................ 5 2.1 Current Fire Protection Licensing Basis ............................................................. 5 2.2 NRC Acceptance of the Fire Protection Licensing Basis ................................... 5 3.0 TRANSITION PROCESS ........................................................................................ 9 3.1 Background........................................................................................................ 9 3.2 NFPA 805 Process ............................................................................................ 9 3.3 NEI 04 NFPA 805 Transition Process...................................................... 10 3.4 NFPA 805 Frequently Asked Questions (FAQs) .............................................. 11 4.0 COMPLIANCE WITH NFPA 805 REQUIREMENTS............................................. 13 4.1 Fundamental Fire Protection Program and Design Elements .......................... 13 4.1.1 Overview of Evaluation Process .............................................................. 13 4.1.2 Results of the Evaluation Process ........................................................... 15 4.1.3 Definition of Power Block and Plant ......................................................... 15 4.2 Nuclear Safety Performance Criteria ............................................................... 16 4.2.1 Nuclear Safety Capability Assessment Methodology ............................... 16 4.2.2 Existing Engineering Equivalency Evaluation Transition.......................... 24 4.2.3 Licensing Action Transition ...................................................................... 25 4.2.4 Fire Area Transition ................................................................................. 27 4.3 Non-Power Operational Modes ........................................................................ 30 4.3.1 Overview of Evaluation Process .............................................................. 30 4.3.2 Results of the Evaluation Process ........................................................... 33 4.4 Radioactive Release Performance Criteria ...................................................... 34 4.4.1 Overview of Evaluation Process .............................................................. 34 4.4.2 Results of the Evaluation Process ........................................................... 34 PINGP                                                                                                 Page i - Revision 1

Northern States Power - Minnesota                                                          NFPA 805 Transition Report 4.5 Fire PRA and Performance-Based Approaches .............................................. 35 4.5.1 Fire PRA Development and Assessment ................................................. 35 4.5.2 Performance-Based Approaches ............................................................. 38 4.6 Monitoring Program ......................................................................................... 43 4.6.1 Overview of NFPA 805 Requirements for the NFPA 805 Monitoring Program ................................................................................................... 43 4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program ................... 44 4.7 Program Documentation, Configuration Control, and Quality Assurance ........ 49 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 ........................................................................................................... 49 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 ................................................................................... 51 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 .... 55 4.8 Summary of Results......................................................................................... 56 4.8.1 Results of the Fire Area Review .............................................................. 56 4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase....................................................................................................... 57 4.8.3 Supplemental Information -Other Licensee Specific Issues .................... 57

==5.0 REGULATORY EVALUATION==
 ............................................................................. 58 5.1 Introduction - 10 CFR 50.48 ............................................................................ 58 5.2 Regulatory Topics ............................................................................................ 64 5.2.1 License Condition Changes ..................................................................... 64 5.2.2 Technical Specifications .......................................................................... 64 5.2.3 Orders and Exemptions ........................................................................... 64 5.3 Regulatory Evaluations .................................................................................... 64 5.3.1 No Significant Hazards Consideration ..................................................... 64 5.3.2 Environmental Consideration ................................................................... 64 5.4 Revision to USAR ............................................................................................ 65 5.5 Transition Implementation Schedule ................................................................ 65

==6.0 REFERENCES==
 ...................................................................................................... 66 ATTACHMENTS ........................................................................................................... 72 A. NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program &
Design Elements ............................................................................................... A-1 B. NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review ................................................................................................................ B-1 C. NEI 04-02 Table B Fire Area Transition ..................................................... C-1 D. NEI 04-02 Non-Power Operational Modes Transition ..................................... D-1 PINGP                                                                                                  Page ii - Revision 1

Northern States Power - Minnesota                                                    NFPA 805 Transition Report E. NEI 04-02 Radioactive Release Transition ....................................................... E-1 F. Fire-Induced Multiple Spurious Operations Resolution ................................. F-1 G. Recovery Actions Transition............................................................................ G-1 H. NFPA 805 Frequently Asked Question Summary Table ................................ H-1 I. Definition of Power Block ................................................................................... I-1 J. Fire Modeling V&V ............................................................................................. J-1 K. Existing Licensing Action Transition .............................................................. K-1 L. NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) ... L-1 M. License Condition Changes ............................................................................. M-1 N. Technical Specification Changes .................................................................... N-1 O. Orders and Exemptions .................................................................................... O-1 P. RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) ........................................ P-1 Q. No Significant Hazards Evaluations ................................................................ Q-1 R. Environmental Considerations Evaluation ..................................................... R-1 S. Plant Modifications and Items for Implementation.......................................... S-1 T. Clarification of Prior NRC Approvals................................................................ T-1 U. Internal Events PRA Quality ............................................................................. U-1 V. Fire PRA Quality ................................................................................................. V-1 W. Fire PRA Insights .............................................................................................. W-1 PINGP                                                                                           Page iii - Revision 1

Northern States Power - Minnesota                                  NFPA 805 Transition Report Revision Status The following table lists sections of the PINGP NFPA 805 Transition Report and Attachments and identifies their current revision status. This Revision Status section was added to the Transition Report in Revision 1.
Pages designated Revision 0 were included in the September 28, 2012 submittal and have not been changed.
Pages designated Revision 1 have been updated for the May 1, 2014 Supplement and supersede the following:
* Pages in the September 28, 2012 submittal,
* Pages in Attachment U previously marked Revised that were included in the November 8, 2012 submittal addressing the Internal Flooding PRA peer review (ADAMS Accession No. ML12314A144), and
* Pages in Attachment W previously marked Revised that were included in the December 18, 2012 submittal that responded to NRC questions in support of Acceptance (ADAMS Accession No. ML12354A464).
Revised text is identified by a vertical bar in the right-hand margin except for Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, changes in format or pagination), which are not marked.
Section                            Revision Table of Contents                                             1 Revision Status                                               1 Summary of Changes                                            1 Executive Summary                                             1 Acronym List                                                  1 1.0 Introduction                                              1 2.0 Overview of Existing Fire Protection Programs             0 3.0 Transition Process                                        0 4.0 Compliance with NFPA 805 Requirements                     1 5.0 Regulatory Evaluation                                     1 6.0 References                                                1 Attachment A, NEI 04-02 Table B-1                             1 Attachment B, NEI 04-02 Table B-2                             1 Attachment C, NEI 04-02 Table B-3                             1 Attachment D, Non Power Operational Modes                     1 PINGP                                                                    Page iv - Revision 1

Northern States Power - Minnesota                             NFPA 805 Transition Report Section                       Revision Transition Attachment E, Radioactive Release Transition              1 Attachment F, Fire-Induced Multiple Spurious              1 Operations Resolution Attachment G, Recovery Actions Transition                 1 Attachment H, NFPA 805 Frequently Asked                   1 Questions Summary Table Attachment I, Definition of Power Block                   1 Attachment J, Fire Modeling V&V                           1 Attachment K, Existing Licensing Actions Transition       0 Attachment L, NFPA 805 Chapter 3 Requirements             0 for Approval Attachment M, License Condition Changes                   1 Attachment N, Technical Specification Changes             0 Attachment O, Orders and Exemptions                       0 Attachment P, RI-PB Alternatives to NFPA 805 10           0 CFR 50.48(c)(4)
Attachment Q, No Significant Hazards Evaluation           0 Attachment R, Environmental Considerations                0 Evaluation Attachment S, Plant Modifications                         1 Attachment T, Clarification of Prior NRC Approvals        0 Attachment U, Internal Events PRA Quality                 1 Attachment V, Fire PRA Quality                            1 Attachment W, Fire PRA Insights                           1 PINGP                                                                Page v - Revision 1

Northern States Power - Minnesota                              NFPA 805 Transition Report Summary of Changes This Summary of Changes section was added to the Transition Report in Revision 1.
Revision           Affected Section                        Change 0                     All        Initial submittal, September 2012 Revised       Attachment U, pages U- Updated to address final peer review of (November       18, U-19               Internal Flooding PRA, including closure of 8, 2012)                             Findings in Table U-2 Revised       Attachment W           Revised to correct errors (December 18, 2012) 1         Revision Status        Added Summary of Changes     Added Executive Summary      Described Supplement Acronym List           Updated list 1.0, Introduction      Described Supplement 4.1.1, Overview of     Revised EC number Evaluation Process 4.2.1.1, Compliance    Revised to clarify gap analysis between NEI with NFPA Section      00-01, Revision 1 and Revision 2; revised EC 2.4.2                  numbers 4.2.1.2, Safe and      Revised to delete references to PRISM, Stable Conditions for  added control room HVAC discussion the Plant 4.2.1.3, Establishing  Revised EC number; editorial correction Recovery Actions 4.2.1.4, Evaluation of Editorial correction Multiple Spurious Operations 4.3.2, Non-Power       Revised EC number Operational Modes 4.4.2, Radioactive     Revised EC number; deleted discussion about Release Performance    preparation of a fire strategy for the Criteria, Results of   Containment Access Facility Evaluation Process PINGP                                                                 Page vi - Revision 1

Northern States Power - Minnesota                                 NFPA 805 Transition Report Revision           Affected Section                          Change 4.5, Fire PRA and        Described revision to Fire PRA and focused Performance Based        Peer Review for Hot Gas Layer methodology; Approaches               also updated the Internal Flooding Peer Review and made an editorial correction 4.6.2, Overview of Post- Revised to clarify that 10 CFR 20 limits will Transition NFPA 805      not be exceeded during radioactive releases Monitoring Program 4.8.2, Plant             Revised EC number for Attachment S, and Modifications and Items  clarified that there are no outstanding plant to be Completed During   modifications with respect to the Fire PRA Implementation           model other than items in Attachment S; also revised reference to Table S-1 to refer to a completed modification 5.2.1, License           Revise to note that the RG 1.205 license Condition Changes        condition was modified 5.5, Transition          Added sentence to indicate that Table S-3, Implementation           item 20 will be completed after completion of Schedule                 the modifications in Table S-2 6.0, References          Added correspondence subsequent to the September 28, 2012 submittal, including additional information to support NRC acceptance, the acceptance letter, and letters discussing the May 1, 2014 supplement; also updated Engineering Change (EC) list for the Supplement Attachment A             Added verification of technical bases for Complies by Previous NRC Approval statements; also, revised the Compliance Statements for sections 3.3.7, 3.4.3(a)(2),
3.5.6, 3.9.4, and 3.10.9 Attachment B             Deleted references to PRISM and added references to Genesis; also updated references and Alignment Basis statements to reflect the revised NSCA model Attachment C             Updated for revised Fire PRA, VFDRs, FREs, recovery actions and modifications Attachment D             Revised EC number and updated to reflect revised NPO model PINGP                                                                   Page vii - Revision 1

Northern States Power - Minnesota                           NFPA 805 Transition Report Revision          Affected Section                      Change Attachment E        Removed Fire Area (FA) 40, Maintenance Storage Shed, from radiologically controlled areas; also added FA 9 and incorporated several clarifications Attachment F        Updated to reflect additional expert panel review of electrical systems and to identify revised notebooks Attachment G        Revised to state that PINGP does not have a primary control station that meets RG 1.205; also revised Recovery Actions for revised Fire PRA, including new actions Attachment H        Updated FAQ list to add items 12-0063 and 12-0067 Attachment I        Revised FA 40 description, deleted YARD items, and revised EC number Attachment J        Updated Fire Modeling V&V Attachment M        Revised License Condition to clarify that it does not apply to equivalency evaluations Attachment S        Revised Modifications for revised Fire PRA and additional fire modeling; added item to Table S-1, revised Table S-2, and revised Table S-3 Attachment U        Revised for closure of Finding, and added discussion of planned focused-scope peer review for the new reactor coolant pump seal model Attachment V        Revised for closure of F&Os; deleted PRISM; added focused peer review of HGL methodology Attachment W        Revised Fire PRA results PINGP                                                             Page viii - Revision 1

Northern States Power - Minnesota                                          Executive Summary Executive Summary Northern States Power Company, a Minnesota corporation (NSPM) doing business as Xcel Energy, will transition the fire protection program for Prairie Island Nuclear Generating Plant Units 1 & 2 (PINGP) to a new Risk-Informed, Performance-Based (RI-PB) alternative per 10 CFR 50.48(c) which incorporates by reference National Fire Protection Association Standard 805 (NFPA 805). The licensing basis per 10 CFR 50.48(b) and 10 CFR 50, Appendix R, will be superseded.
The voluntary adoption of 10 CFR 50.48(c) by PINGP does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, General Design Criteria (GDC) 3, Fire Protection. However, compliance with the new rule establishes compliance with these sections. By letter dated June 22, 2011 (ADAMS Accession No. ML111740866), NSPM committed to submit a license amendment request by September 30, 2012, for PINGP to transition to 10 CFR 50.48(c).
The transition process consisted of a review and update of PINGP documentation, including the development of a Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850 as guidance. This Transition Report summarizes the transition process and results. This Transition Report contains information:
* Required by 10 CFR 50.48(c).
* Recommended by guidance document Nuclear Energy Institute (NEI) 04-02 Revision 2 and appropriate Frequently Asked Questions (FAQs).
* Recommended by guidance document Regulatory Guide 1.205 Revision 1.
Section 4 of the Transition Report provides a summary of compliance with the following NFPA 805 requirements:
* Fundamental Fire Protection Program Elements and Minimum Design Requirements.
* Nuclear Safety Performance Criteria, including:
o Nuclear Safety Capability Assessment, Safe and Stable Conditions for the Plant, Establishing Recovery Actions, Evaluation of Multiple Spurious Operations, o Existing Engineering Equivalency Evaluations, o Licensing Actions, and o Fire Area Transitions.
* Non-Power Operational Modes.
* Radioactive Release Performance Criteria.
* Fire PRA and Performance-Based Approaches.
* Monitoring Program.
* Program Documentation, Configuration Control, and Quality Assurance.
PINGP                                                                      Page ix - Revision 1

Northern States Power - Minnesota                                         Executive Summary Section 5 of the Transition Report provides regulatory evaluations and associated attachments, including:
* Changes to the Fire Protection License Condition.
* Changes to Technical Specifications, Orders, and Exemptions.
* Determination of No Significant Hazards and evaluation of Environmental Considerations.
The attachments to the Transition Report include details to support the transition process and results.
Attachment H contains the approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this License Amendment Request.
Revision 1 to this Transition Report includes the following:
* Changes to reflect a revision to the Fire PRA, including changes in fire modeling, modifications, recovery actions, and calculated risk values,
* Changes to reflect revisions to the Nuclear Safety Capability Assessment (NSCA) and Non-Power Operations (NPO) models to replace PRISM software,
* Changes to the lists of modifications and implementation items based on additional fire modeling and engineering evaluations, and
* Changes to address generic industry issues addressed in Generic Requests for Additional Information (RAIs) and in revisions to the NEI 04-02 template that were more recent than Revision 1L used in the original submittal.
The entire PINGP NFPA 805 Transition Report document is included with this supplement, to simplify the review effort. Sections and Attachments to the original 2012 Transition Report that have been changed are identified in the Revision Status table, and are briefly described in the Summary of Changes. Revision 1 is not a complete revision to the Transition Report and many attachments have not been changed.
Where changes in text or content have been made, the entire section or attachment is marked Revision 1 in the footer and the affected text is identified by a vertical bar in the right-hand margin. Exceptions include Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, format or pagination changes), which are not marked. Sections or attachments that have not been changed are marked Revision 0.
PINGP                                                                     Page x - Revision 1

Northern States Power - Minnesota                                   Acronym List Acronym List AC            Alternating Current ACUBE         Advanced Cutset Upper Bound Estimator ADAMS         Agencywide Documents Access and Management System ADS           Automatic Depressurization System AEC           Atomic Energy Commission AF            Auxiliary Feedwater AFP           Area Fire Plan AFW           Auxiliary Feedwater System AHJ           Authority Having Jurisdiction ANS           American Nuclear Society ANSI          American National Standards Institute APCSB         Auxiliary Power Conversion Systems Branch AR            Action Request ARP           Alarm Response Procedure ASD           Atmospheric Steam Dump ASEP          Accident Sequence Evaluation Program ASME          American Society of Mechanical Engineers ASTM          American Society for Testing and Materials BE            Basic Event BKR           Breaker BTP           Branch Technical Position BTU           British Thermal Unit BWROG         Boiling Water Reactor Owners Group CAAB          Common Area of the Auxiliary Building CAF           Containment Access Facility CAFTA         Computer Aided Fault Tree Analysis CAS           Central Alarm Station CB            Control Building (Fire Area)
CCDP          Conditional Core Damage Probability CC            Capability Category CC            Component Cooling System CD            Condensate System CD            Control Damper CCF           Common Cause Failure CCW           Component Cooling Water CDF           Core Damage Frequency CFAST         Consolidated Fire and Smoke Transport CFCU          Containment Fan Cooler Units CFR           Code of Federal Regulations CL            Cooling Water CLB           Current Licensing Basis CLERP         Conditional Large Early Release Probability CO2           Carbon Dioxide PINGP                                                         Page xi - Revision 1

Northern States Power - Minnesota                                Acronym List CPS           Common Power Supply CR            Control Room CRD           Control Rod Drive CRDM          Control Rod Drive Mechanism CS            Containment Spray CSD           Cold Shutdown CSR           Cable Spreading Room CST           Condensate Storage Tank CT            Current Transformer CT            External Circulating Water System CTEH          Cooling Tower Equipment House CTPH          Cooling Tower Pump House CV            Control Valve CVCS          Chemical and Volume Control System D(1-6)        Emergency Diesel Generator DA            Deluge Automatic DB            Design Basis DBA           Design Basis Accident DBD           Design Basis Document DC            Direct Current DDCLP         Diesel Driven Cooling Water Pump DDCWP         Diesel Driven Cooling Water pump DDFP          Diesel Driven Fire Pump DID           Defense-in-Depth DH            Decay Heat DG            Diesel Generator DM            Deluge Manual DPS           Dry Pipe System EC            Engineering Change ECCS          Emergency Core Cooling System EDG           Emergency Diesel Generator EDMG          Earthquake Damage Mitigation Guide EEE           Engineering Equivalency Evaluation EEEE          Existing Engineering Equivalency Evaluation EF            Error Factor EL            Elevation EM            Event Monitoring EOF           Emergency Operating Facility EOP           Emergency Operating Procedure EPM           Engineering, Planning, and Management, Inc.
EPRI          Electrical Power Research Institute ERFBS         Electrical Raceway Fire Barrier System ERO           Emergency Response Organization ES            Equipment Selection ESF           Engineered Safety Features ESW           Emergency Service Water PINGP                                                     Page xii - Revision 1

Northern States Power - Minnesota                                             Acronym List EX            Exterior (fire area)
EXC           Excluding
&#xba;F            Degrees Fahrenheit F&O           Fact and Observation FA            Fire Area FAQ           Frequently Asked Question FC            Fire Compartment FDS           Fire Dynamics Simulator FDT           Fire Dynamics Tool FIVE          Fire Induced Vulnerability Evaluation FHA           Fire Hazards Analysis FIF           Fire Ignition Frequency FM            Factory Mutual FO            Fuel Oil FP            Fire Protection FPP           Fire Protection Program FPE           Fire Protection Engineer FPIE          Full Power Internal Events FPRA          Fire Probabilistic Risk Assessment FR            Federal Register FRACQA        Functional Responsibilities, Administrative Controls, and Quality Assurance FRANX         Fire Risk Analysis Software Tool FRE           Fire Risk Evaluation FSAR          Final Safety Analysis Report FSS           Fire Scenario Selection ft            Feet FV            Fussell-Vesely FW            Feedwater gal           Gallon GDC           General Design Criterion GL            U.S. NRC Generic Letter GPM           Gallons Per Minute HAD           Heat Actuated Device HEAF          High Energy Arc Fault HEP           Human Error Probability HEPA          High-Efficiency Particulate Air HFE           Human Failure Event HGL           Hot Gas Layer HLR           High Level Requirement HRA           Human Reliability Analysis HRE           Higher Risk Evolution HRR           Heat Release Rate HSDP          Hot Shutdown Panel HSS           High Safety Significant HVAC          Heating, Ventilation, and Air Conditioning PINGP                                                                 Page xiii - Revision 1

Northern States Power - Minnesota                                      Acronym List HX            Heat Exchanger I&C           Instrumentation and Controls ID            Identification IE            Initiating Event IEEE          Institute of Electrical and Electronic Engineers IF            Ignition Frequency IF            Internal Flooding IN            U.S. NRC Information Notice IPCEA         Insulated Power Cable Engineers Association IPEEE         Individual Plant Examination of External Events IPLD          Integrated Plant Logic Diagram IS            Intake Structure ISDS          Ignition Source Data Sheet ISFSI         Independent Spent Fuel Storage Installation ISLOCA        Interfacing System Loss of Coolant Accident KSF           Key Safety Function KV            kilovolt KW            kilowatt L             Liter LA            Licensing Action LAR           License Amendment Request LCO           Limiting Conditions for Operation LE            LERF LERF          Large Early Release Frequency LFS           Limiting Fire Scenario LLC           Limited Liability Company LLOCA         Large Loss of Coolant Accident LLRW          Low Level Radwaste LOCA          Loss of Coolant Accident LOOP          Loss of Offsite Power LPCI          Low Pressure Coolant Injection LSELS         Load Shed and Emergency Load Sequencer LSS           Low Safety Significant m             meter MAAP          Modular Accident Analysis Program MCA           Multi-Compartment Analysis MCB           Main Control Board MCC           Motor Control Center MCR           Main Control Room MDAFWP        Motor Driven Auxiliary Feedwater Pump MDFP          Motor Driven Fire Pump MEFS          Maximum Expected Fire Scenario MFW           Main Feedwater MG            Motor Generator MHIF          Multiple High Impedance Fault min           minute PINGP                                                          Page xiv - Revision 1

Northern States Power - Minnesota                                        Acronym List MOV           Motor Operated Valve MQH           McCaffrey, Quintiere, and Harkleroad MSIV          Main Steam Isolation Valve MSLB          Main Steam Line Break MSO           Multiple Spurious Operation MTTR          Mean Time To Repair MV            Motor Operated Valve MVSG          Medium Voltage Switchgear N/A           Not Applicable NEI           Nuclear Energy Institute NEIL          Nuclear Electric Insurance Limited NEPIA         Nuclear Energy Property Insurance Association (now NEIL)
NIST          National Institute of Standards and Technology NFPA          National Fire Protection Association NMC           Nuclear Management Company, LLC NPO           Non-Power Operational NPP           Nuclear Power Plant NPSH          Net Positive Suction Head NRC           U.S. Nuclear Regulatory Commission NSCA          Nuclear Safety Capability Assessment NSEL          Nuclear Safety Equipment List NSHC          No Significant Hazards Consideration NSP           Northern States Power NSP           Non-Suppression Probability NSPC          Nuclear Safety Performance Criteria NSPM          Northern States Power - Minnesota NUMARC        Nuclear Management and Resource Council NUREG         US Nuclear Regulatory Commission Publication NUREG/CR      NUREG document prepared by NRC contractors OAB           Old Administration Building OCT           Overcurrent Trip OMA           Operator Manual Action OOS           Out Of Service OPEX          Operating Experience OS&Y          Outside Screw and Yoke P&ID          Piping and Instrumentation Diagram PA            Preaction PA            Public Address PAU           Physical Analysis Unit PB            Performance Based PBX           Private Branch Exchange PC            Primary Containment PCD           PRA Change Database PCS           Power Conversion System PCS           Primary Control Station PDS           Plant Damage State PINGP                                                             Page xv - Revision 1

Northern States Power - Minnesota                                          Acronym List PH            Pumphouse PI            Project Instruction PINGP         Prairie Island Nuclear Generating Plant - Units 1 & 2 PORV          Power Operated Relief Valve POS           Plant Operating State PPE           Personal Protective Equipment PR            Peer Review PRA           Probabilistic Risk Assessment PRISM         Plant Risk-Informed Systems Module PRM           Plant Response Model PSA           Probabilistic Safety Assessment PSF           Performance Shaping Factor PVC           Polyvinyl Chloride PWR           Pressurized Water Reactor PWROG         Pressurized Water Reactor Owners Group QA            Quality Assurance QNS           Quantitative Screening QU            Quantification RA            Risk Assessment RAI           Request for Additional Information RAW           Risk Achievement Worth RC            Reactor Coolant RCA           Radiologically Controlled Area RCP           Reactor Coolant Pump RCS           Reactor Coolant System RES           Nuclear Regulatory Commission - Office of Nuclear Regulatory Research RES           Radiant Energy Shield RG            U.S. NRC Regulatory Guide RH            Residual Heat Removal RHR           Residual Heat Removal RI-PB         Risk-Informed, Performance-Based RIS           Regulatory Issue Summary RPS           Reactor Protection System RPV           Reactor Pressure Vessel RRW           Risk Reduction Worth RSP           Remote Shutdown Panel RW            River Water RWCU          Reactor Water Cleanup RWST          Refueling Water Storage Tank rx-yr         Reactor year SAR           Safety Analysis Report SBO           Station Blackout SBDG          Standby Diesel Generator SC            Success Criteria SCBA          Self-Contained Breathing Apparatus SCP           Security Control Point PINGP                                                               Page xvi - Revision 1

Northern States Power - Minnesota                               Acronym List SDC           Shutdown Cooling SE            Safety Evaluation SECY          Commission Paper (NRC)
SER           Safety Evaluation Report SFP           Spent Fuel Pool SFPE          Society of Fire Protection Engineers SG            Steam Generator SGTR          Steam Generator Tube Rupture SI            Safety Injection SLD           Shutdown Logic Diagram SP            Special Publication sq ft         Square Feet SR            Supporting Requirement SR            Surveillance Requirement SRM           Staff Requirements Memorandum SRV           Safety Relief Valve SSA           Safe Shutdown Analysis SSC           Structures, Systems, and Components SSD           Safe Shutdown SSE           Safe Shutdown Earthquake SSEL          Safe Shutdown Equipment List SSLD          Safe Shutdown Logic Diagram SSO           Single Spurious Operation STA           Shift Technical Advisor SUT           Startup Transformer SW            Service Water SWGR          Switchgear SWP           Stairway Wet Pipe TB            Turbine Building TBHX          Thermal Barrier Heat Exchanger TD            Turbine Driven TDAFP         Turbine Driven Auxiliary Feedwater Pump TDAFW         Turbine Driven Auxiliary Feedwater [Pump]
T-H           Thermal-Hydraulic TM            Testing & Maintenance TSC           Technical Support Center TS            Technical Specification UAM           Unreviewed Analysis Method (for Fire PRA)
UFSAR         Updated Final Safety Analysis Report UL            Underwriters Laboratory USAR          Updated Safety Analysis Report USC           United States Code VAC           Volts Alternating Current VC            Chemical & Volume Control VCT           Volume Control Tank V&V           Verification and Validation PINGP                                                   Page xvii - Revision 1

Northern States Power - Minnesota                              Acronym List VDC           Volts Direct Current VFDR          Variance From Deterministic Requirement WCAP          Westinghouse Commercial Atomic Power WOG           Westinghouse Owners Group WPS           Wet Pipe Sprinkler yr            Year ZOI           Zone Of Influence PINGP                                                 Page xviii - Revision 1

Northern States Power - Minnesota                                            1.0 Introduction

==1.0     INTRODUCTION==

The Nuclear Regulatory Commission (NRC) has promulgated an alternative rule for fire protection requirements at nuclear power plants, 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). NSPM is implementing the Nuclear Energy Institute methodology NEI 04-02, Guidance for Implementing a Risk-informed, Performance-based Fire Protection Program Under 10 CFR 50.48(c) (NEI 04-02), to transition PINGP from its current fire protection licensing basis to the new requirements as outlined in NFPA 805. This report describes the transition methodology utilized and documents how PINGP complies with the new requirements.
Revision 1 to this Transition Report includes changes and corrections that NSPM determined were necessary after the NFPA 805 License Amendment Request (LAR) was submitted. The LAR was submitted for NRC review and approval on September 28, 2012 (ADAMS Accession No. ML12278A405). Additional information was submitted in a letter dated November 8, 2012 (ADAMS Accession No. ML12314A144), to provide final results of the Internal Flooding PRA peer review, and in a letter dated December 18, 2012 (ADAMS Accession No. ML12354A464), to address errors in the Fire PRA.
The NRC subsequently accepted the LAR for review in a letter dated January 2, 2013 (ADAMS Accession No. ML13002A209).
During preparations for the initial NRC audit, NSPM determined that a revision to the Fire PRA was needed and in a letter dated May 3, 2013 (ADAMS Accession No. ML13126A115), committed to provide a supplement to the LAR by May 1, 2014.
Revision 1 to this Transition Report includes the changes that are needed to satisfy this commitment. The revision to the Fire PRA resulted in changes to calculated risk values, fire modeling, recovery actions, and modifications, as provided in this LAR supplement.
In addition, Revision 1 to this Transition Report includes changes to the Nuclear Safety Capability Assessment (NSCA) and Non-Power Operations (NPO) models that resulted from the replacement of PRISM computer software. The modifications and items for implementation were also revised based on additional fire modeling and engineering reviews.
Other reviews were determined to be necessary and are addressed in this supplement.
An additional expert panel review was conducted for electrical systems to identify Multiple Spurious Operations (MSO) concerns. Also, a focused-scope peer review was performed for a hot gas layer (HGL) methodology not previously used.
This supplement also addresses generic industry issues that have been identified since submittal of the LAR. Issues identified as Generic Requests for Additional Information (RAIs) as of January 2014 are addressed. This resulted in a change to the License Condition and a number of other clarifications. Also, changes to the NEI 04-02 template subsequent to Revision 1L, which was the basis for the original LAR submittal, have been considered through Revision 1P.
To simplify the review effort, the entire PINGP NFPA 805 Transition Report document is included with this supplement. Sections and Attachments to the original 2012 Transition Report that have been changed are identified in the Revision Status table, and are briefly described in the Summary of Changes. Revision 1 is not a complete revision to the Transition Report and many attachments have not been changed. Where changes PINGP                                                                     Page 1 - Revision 1

Northern States Power - Minnesota                                                      1.0 Introduction in text or content have been made, the entire section or attachment is marked Revision 1 in the footer and the affected text is identified by a vertical bar in the right-hand margin. Exceptions include Attachment W, which has been completely revised and does not include any change markings, and editorial changes (e.g., spelling or grammar corrections, changes in format or pagination), which are not marked. Sections or attachments that have not been changed are marked Revision 0.
1.1     Background 1.1.1 NFPA 805 - Requirements and Guidance On July 16, 2004 the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes new Risk-Informed, Performance-Based (RI-PB) fire protection requirements. 10 CFR 50.48(c) incorporates by reference, with exceptions, the National Fire Protection Associations NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition, as a voluntary alternative to 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning.
As stated in 10 CFR 50.48(c)(3)(i), any licensees adoption of a RI-PB program that complies with the rule is voluntary. This rule may be adopted as an acceptable alternative method for complying with either 10 CFR 50.48(b), for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979, or 10 CFR 50.48(f), plants shutdown in accordance with 10 CFR 50.82(a)(1).
NEI developed NEI 04-02 to assist licensees in adopting NFPA 805 and making the transition from their current fire protection licensing basis to one based on NFPA 805.
The NRC issued Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants, which endorses NEI 04-02, with exceptions, in December 2009.1 A depiction of the primary document relationships is shown in Figure 1-1:
1 Where referred to in this document NEI 04-02 is Revision 2 and RG 1.205 is Revision 1.
PINGP                                                                              Page 2 - Revision 1

Northern States Power - Minnesota                                             1.0 Introduction Figure 1-1 NFPA 805 Transition - Implementation Requirements/Guidance 1.1.2 Transition to 10 CFR 50.48(c) 1.1.2.1    Start of Transition Nuclear Management Company (NMC) submitted a letter of intent to the NRC on November 30, 2005 (ADAMS Accession No. ML053460342) for PINGP to adopt NFPA 805 in accordance with 10 CFR 50.48(c). NSPM has subsequently assumed responsibility for actions and commitments previously submitted by NMC.
By letter dated September 7, 2006 (ADAMS Accession No. ML061500035), the NRC granted a three year enforcement discretion period. In accordance with NRC Enforcement Policy, the enforcement discretion period will continue until the NRC approval of the license amendment request (LAR) is completed.
In accordance with SECY-11-0061, in a letter dated June 22, 2011 (ADAMS Accession No. ML111740866), NSPM committed to submit a license amendment request no later than September 30, 2012, for PINGP to transition to 10 CFR 50.48(c). By letter dated July 29, 2011, (ADAMS Accession No. ML112010417), the NRC acknowledged the application date for PINGP and granted an extension of enforcement discretion.
PINGP                                                                     Page 3 - Revision 1

Northern States Power - Minnesota                                             1.0 Introduction 1.1.2.2    Transition Process The transition to NFPA 805 includes the following high level activities:
* A new fire safe shutdown analysis;
* A new Fire Probabilistic Risk Assessment (PRA) using NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, as guidance and a revision to the Internal Events PRAs to support the Fire PRAs; and
* Completion of activities required to transition the pre-transition Licensing Basis to 10 CFR 50.48(c) as specified in NEI 04-02 and RG 1.205.
1.2    Purpose The purpose of the Transition Report is as follows:
: 1) Describe the process implemented to transition the current fire protection program to compliance with the additional requirements of 10 CFR 50.48(c);
: 2) Summarize the results of the transition process;
: 3) Explain the bases for conclusions that the fire protection program complies with 10 CFR 50.48(c) requirements;
: 4) Describe the new fire protection licensing basis; and
: 5) Describe the configuration management processes used to manage post-transition changes to the plant and the Fire Protection Program, and resulting impact on the Licensing Basis.
PINGP                                                                      Page 4 - Revision 1

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program 2.0     OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM 2.1     Current Fire Protection Licensing Basis PINGP Unit 1 was licensed to operate on August 9, 1973 and Unit 2 was licensed to operate on October 29, 1974. As a result, the PINGP fire protection program is based on compliance with 10 CFR 50.48(a), 10 CFR 50.48(b), 10 CFR 50 Appendix R, and the following License Condition:
NSPM, PINGP Renewed Operating Licenses Nos. DPR-42 (Unit 1) and DPR-60 (Unit
: 2) both include License Condition 2.C.(4), Fire Protection, which states:
NSPM shall implement and maintain in effect all provisions of the approved fire protection program as described and referenced in the Updated Safety Analysis Report for the Prairie Island Nuclear Generating Plant, Units 1 and 2, and as approved in Safety Evaluation Reports dated February 14, 1978, September 6, 1979, April 21, 1980, December 29, 1980, July 28, 1981, October 27, 1989, and October 6, 1995, subject to the following provision:
NSPM 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.
2.2     NRC Acceptance of the Fire Protection Licensing Basis To conform to NRC guidelines issued prior to November 1980, Northern States Power performed a fire hazard analysis which analyzed the PINGP fire protection program against the guidance of Appendix A to Branch Technical Position (BTP) Auxiliary Power Conversion Systems Branch (APCSB) 9.5-1. The results of this analysis, in addition to proposed modifications and additions to the fire protection program, were communicated to the NRC by letters dated March 11, 1977, July 5, 1977, May 18, 1978, June 22, 1978, January 2, 1979, March 9, 1979, and May 2, 1979. Furthermore this analysis served as the basis for the Appendix A to BTP APCSB 9.5-1 safety evaluation dated September 6, 1979, and the associated License Amendment Nos. 39 (Unit 1) and 33 (Unit 2), which implemented fire protection technical specifications and added a license condition for the completion of fire protection modifications, submittal of additional information, and implementation of administrative controls.
The current Fire Protection License Condition quoted above identifies a number of NRC Safety Evaluation Reports (SERs) and approval letters which are briefly summarized below. Any provisions of these documents that are to be transitioned to the NFPA 805 fire protection program are identified in other sections and/or attachments to this Transition Report.
NRC letter dated February 14, 1978 In a letter dated February 14, 1978, the NRC issued License Amendment Nos. 26 (Unit
: 1) and 20 (Unit 2) which revised the PINGP Technical Specifications (TSs) to add Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) for fire protection equipment and instrumentation, and Administrative Controls related to fire protection.
PINGP                                                                         Page 5 - Revision 0

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program NRC SER dated September 6, 1979 In the SER for License Amendment Nos. 39 (Unit 1) and 33 (Unit 2) dated September 6, 1979, the NRC added a license condition relating to the completion of facility modifications and implementation of administrative controls, and approved TS changes regarding detector functional test frequency, valve position verification, fire brigade size, and administrative responsibilities for fire protection and training.
NRC Approval dated April 21, 1980 In a letter dated April 21, 1980, the NRC approved fourteen fire protection modifications that were previously described in the September 6, 1979 SER, and that had been designated as requiring additional information prior to implementation.
NRC Approval dated December 29, 1980 In a letter dated December 29, 1980, the NRC approved additional fire protection modifications that had previously been described in the September 6, 1979 SER, and that had been designated as requiring additional information prior to implementation.
The December 29 NRC letter discussed fire barrier penetration seal upgrades, structural steel member coating in the vicinity of the lube oil reservoir, installation of fire dampers, a fire barrier enclosure for the motor driven fire pump, and fire detector response capabilities.
NRC SER dated July 28, 1981 In the SER for License Amendment Nos. 49 (Unit 1) and 43 (Unit 2) dated July 28, 1981, the NRC approved modifications to the TS LCOs and surveillance requirements for Fire Detection and Protection Systems, and accompanying Bases descriptions.
These changes reflected modifications to fire protection equipment, structures, testing requirements, and administrative controls.
NRC SER dated October 27, 1989 In the SER for License Amendment Nos. 91 (Unit 1) and 84 (Unit 2) dated October 27, 1989, the NRC approved numerous changes throughout the TS in support of a human error reduction program. These changes included the reorganization and standardization of some TS sections, including fire protection program requirements, to achieve consistency and uniformity throughout the TS and minimize the potential for confusion.
NRC SER dated October 6, 1995 In the SER for License Amendment Nos. 120 (Unit 1) and 113 (Unit 2) dated October 6, 1995, the NRC approved TS changes to remove Fire Protection Program requirements from the TS. In accordance with Generic Letter 86-10, fire protection program elements were removed from the TS and the NRC-approved Fire Protection Program and major commitments, including the fire hazards analysis, were incorporated by reference into the USAR. A new fire protection license condition was added.
PINGP                                                                         Page 6 - Revision 0

Northern States Power - Minnesota              2.0 Overview of Existing Fire Protection Program Exemptions The following is a list of the exemptions that have been granted by the NRC from the requirements of Appendix R to 10 CFR 50, Sections III.G, III.J, and III.O:
* An exemption from Section III.G.3.b for lack of a fixed fire suppression system in the Control Room, Units 1 and 2, Fire Area 13 (NRC SER dated February 2, 1983).
* An exemption from Subsection III.G.2 for lack of twenty feet of separation free of intervening combustibles or one hour fire rated barriers between redundant trains needed for safe shutdown in the A Train Hot Shutdown Panel, Instrument Air and Auxiliary Feedwater Pump Rooms, Units 1 and 2, Fire Area 31 (NRC SER dated May 4, 1983).
* An exemption from Subsection III.G.2 for lack of twenty feet of separation free of intervening combustibles or one hour fire rated barriers between redundant trains needed for safe shutdown in the B Train Hot Shutdown Panel, Instrument Air and Auxiliary Feedwater Pump Rooms, Units 1 and 2, Fire Area 32 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Operating Level, Unit 1, Fire Area 60 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Operating Level, Unit 2, Fire Area 75 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Normal Switchgear Room, Unit 1, Fire Area 37 (NRC SER dated May 4, 1983).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Ground Floor Level, Unit 1, Fire Area 58 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Ground Floor Level, Unit 2, Fire Area 73 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Mezzanine Level, Unit 1, Fire Area 59 (NRC SER dated January 9, 1984).
PINGP                                                                        Page 7 - Revision 0

Northern States Power - Minnesota               2.0 Overview of Existing Fire Protection Program
* An exemption from Section III.G.2 for lack of an automatic fire suppression system in the Auxiliary Building Mezzanine Level, Unit 2, Fire Area 74 (NRC SER dated January 9, 1984).
* An exemption from Section III.G.2 for the lack of twenty feet of separation free of intervening combustibles between redundant trains needed for safe shutdown in the Containment, Units 1 and 2, Fire Areas 1 and 71, including a commitment to install a one-hour fire barrier to protect the cabling for one division of the pressurizer level transmitters in Unit 2 (NRC SER dated July 31, 1984). As described in Attachment K, different methods of protection for this cabling are provided in Unit 1 and Unit 2.
* An exemption from Section III.O for a reactor coolant pump lube oil collection system that does not drain to a vented closed container that can hold the entire lube oil system inventory, but instead is piped to a sump inside Containment and then is pumped to a closed vented container located in the Auxiliary Building; Units 1 and 2, Containment Fire Areas 1 and 71 (NRC SER dated July 31, 1984).
* An exemption from Section III.G.1 to allow operators to remove fuses from Power Operated Relief Valve (PORV) control circuits to preclude inadvertent valve operation in the event of a control room evacuation; this is considered a repair to ensure that one train of safe shutdown equipment remains operable which is contrary to Section III.G.1, Control Room, Units 1 and 2, Fire Area 13 (NRC SER dated February 21, 1995).
PINGP                                                                         Page 8 - Revision 0

Northern States Power - Minnesota                                      3.0 Transition Process 3.0    TRANSITION PROCESS 3.1    Background Section 4.0 of NEI 04-02 describes the process for transitioning from compliance with the current fire protection licensing basis to the new requirements of 10 CFR 50.48(c).
NEI 04-02 contains the following steps:
: 1) Licensee determination to transition the licensing basis and devote the necessary resources to it;
: 2) Submit a Letter of Intent to the NRC stating the licensees intention to transition the licensing basis in accordance with a tentative schedule;
: 3) Conduct the transition process to determine the extent to which the current fire protection licensing basis supports compliance with the new requirements and the extent to which additional analyses, plant and program changes, and alternative methods and analytical approaches are needed;
: 4) Submit a LAR;
: 5) Complete transition activities that can be completed prior to the receipt of the License Amendment;
: 6) Receive a Safety Evaluation; and
: 7) Complete implementation of the new licensing basis, including completion of modifications identified in Attachment S.
3.2    NFPA 805 Process Section 2.2 of NFPA 805 establishes the general process for demonstrating compliance with NFPA 805. This process is illustrated in Figure 3-1. It shows that except for the fundamental fire protection requirements, compliance can be achieved on a fire area basis either by deterministic or RI-PB methods. Consistent with the guidance in NEI 04-02, NSPM has implemented the NFPA 805 Section 2.2 process by first determining the extent to which its current fire protection program supports findings of deterministic compliance with the requirements in NFPA 805. RI-PB methods are being applied to the requirements for which deterministic compliance could not be shown.
PINGP                                                                     Page 9 - Revision 0

Northern States Power - Minnesota                                                  3.0 Transition Process 2
Figure 3-1 NFPA 805 Process [NEI 04-02 Figure 3-1 based on Figure 2-2 of NFPA 805]
3.3      NEI 04 NFPA 805 Transition Process NFPA 805 contains technical processes and requirements for a RI-PB fire protection program. NEI 04-02 was developed to provide guidance on the overall process (programmatic, technical, and licensing) for transitioning from a traditional fire protection licensing basis to a new RI-PB method based upon NFPA 805, as shown in Figure 3-2.
2 Note: 10 CFR 50.48(c) does not incorporate by reference Life Safety and Plant Damage/Business Interruption goals, objectives and criteria. See 10 CFR 50.48(c) for specific exceptions to the incorporation by reference of NFPA 805.
PINGP                                                                                Page 10 - Revision 0

Northern States Power - Minnesota                                           3.0 Transition Process Section 4.0 of NEI 04-02 describes the detailed process for assessing a fire protection program for compliance with NFPA 805, as shown in Figure 3-2.
Figure 3-2 Transition Process (Simplified) [based on NEI 04-02 Figure 4-1]
3.4    NFPA 805 Frequently Asked Questions (FAQs)
The NRC has worked with NEI and two Pilot Plants (Oconee Nuclear Station and Harris Nuclear Plant) to define the licensing process for transitioning to a new licensing basis under 10 CFR 50.48(c) and NFPA 805. Both the NRC and the industry recognized the need for additional clarifications to the guidance provided in RG 1.205, NEI 04-02, and the requirements of NFPA 805. The NFPA 805 FAQ process was jointly developed by NEI and NRC to facilitate timely clarifications of NRC positions. This process is described in a letter from the NRC dated July 12, 2006, to NEI (ML061660105) and in Regulatory Issues Summary (RIS) 2007-19, Process for Communicating Clarifications PINGP                                                                         Page 11 - Revision 0

Northern States Power - Minnesota                                    3.0 Transition Process of Staff Positions Provided in RG 1.205 Concerning Issues Identified during the Pilot Application of NFPA Standard 805, dated August 20, 2007 (ML071590227).
Under the FAQ Process, transition issues are submitted to the NEI NFPA 805 Task Force for review, and subsequently presented to the NRC during public FAQ meetings.
Once the NEI NFPA 805 Task Force and NRC reach agreement, the NRC issues a memorandum to indicate that the FAQ is acceptable. NEI 04-02 will be revised to incorporate the approved FAQs. This is an on-going revision process that will continue through the transition of NFPA 805 transition plants. Final closure of the FAQs will occur when future revisions of RG 1.205, endorsing the related revisions of NEI 04-02, are approved by the NRC. It is expected that additional FAQs will be written and existing FAQs will be revised as plants continue NFPA 805 transition after the Pilot Plant Safety Evaluations.
Attachment H contains the list of approved FAQs not yet incorporated into the endorsed revision of NEI 04-02. These FAQs have been used to clarify the guidance in RG 1.205, NEI 04-02, and the requirements of NFPA 805 and in the preparation of this LAR.
PINGP                                                                   Page 12 - Revision 0

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements 4.0     COMPLIANCE WITH NFPA 805 REQUIREMENTS 4.1     Fundamental Fire Protection Program and Design Elements The Fundamental Fire Protection Program and Design Elements are established in Chapter 3 of NFPA 805. Section 4.3.1 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis and plant configuration meets these criteria and for identifying the fire protection program changes that would be necessary for compliance with NFPA 805. NEI 04-02 Appendix B-1 provides guidance on documenting compliance with the program requirements of NFPA 805 Chapter 3.
4.1.1 Overview of Evaluation Process The comparison of the PINGP Fire Protection Program to the requirements of NFPA 805 Chapter 3 was performed and documented in PINGP Engineering Evaluation EC 23309 entitled NFPA 805 LAR Supplement Attachment A (Table B-1). Engineering Evaluation EC 23309 used the guidance contained in NEI 04-02, Section 4.3.1 and Appendix B-1 (See Figure 4-1).
Each section and subsection of NFPA 805 Chapter 3 was reviewed against the current fire protection program. Upon completion of the activities associated with the review, the following compliance statement(s) was used:
* Complies - For those sections/subsections determined to meet the specific requirements of NFPA 805.
* Complies with Item for Implementation - For those sections/subsections determined to meet the requirements of NFPA 805 upon completion of an item as identified in Attachment S.
* Complies with Clarification - For those sections/subsections determined to meet the requirements of NFPA 805 with clarification.
* Complies by previous NRC approval - For those sections/subsections where the specific NFPA 805 Chapter 3 requirements are not met but previous NRC approval of the configuration exists.
* Complies with use of Existing Engineering Equivalency Evaluations (EEEEs) -
For those sections/subsections determined to be equivalent to the NFPA 805 Chapter 3 requirements as documented by engineering analysis.
* Submit for NRC Approval - For those sections/subsections for which approval is sought in this LAR submittal in accordance with 10 CFR 50.48(c)(2)(vii). A summary of the bases of acceptability is provided (See Attachment L for details).
In some cases multiple compliance statements have been assigned to a specific NFPA 805 Chapter 3 section/subsection. Where this is the case, each compliance/compliance basis statement clearly references the corresponding requirement of NFPA 805 Chapter 3.
PINGP                                                                     Page 13 - Revision 1

Northern States Power - Minnesota                                                                             4.0 Compliance with NFPA 805 Requirements Figure 4 Fundamental Fire Protection Program and Design Elements Transition Process
[Based on NEI 04-02 Figure 4-2]3 3
Figure 4-1 depicts the process used during the transition and therefore contains elements (i.e., open items) that represent interim resolutions. Additional detail on the transition of EEEEs is included in Section 4.2.2.
PINGP                                                                                                                                       Page 14 - Revision 1

Northern States Power - Minnesota                     4.0 Compliance with NFPA 805 Requirements 4.1.2 Results of the Evaluation Process 4.1.2.1    NFPA 805 Chapter 3 Requirements Met or Previously Approved by the NRC Attachment A contains the NEI 04-02 Table B-1, Transition of Fundamental Fire Protection Program and Design Elements. This table provides the compliance basis for the requirements in NFPA 805 Chapter 3. Except as identified in Section 4.1.2.3, Attachment A demonstrates that the fire protection program at PINGP either:
* Complies directly with the requirements of NFPA 805 Chapter 3,
* Complies with clarification with the requirements of NFPA 805 Chapter 3,
* Complies through the use of existing engineering equivalency evaluations which are valid and of appropriate quality, or
* Complies with a previously NRC approved alternative to NFPA 805 Chapter 3 and therefore the specific requirement of NFPA 805 Chapter 3 is supplanted.
4.1.2.2    NFPA 805 Chapter 3 Requirements Requiring Clarification of Prior NRC Approval NFPA 805 Section 3.1 states in part, Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein. In some cases prior NRC approval of an NFPA 805 Chapter 3 program attribute may be unclear. NSPM requests that the NRC concur with their finding of prior approval for the following sections of NFPA 805 Chapter 3:
* None.
Although there are no NFPA 805 Chapter 3 requirements requiring clarification, Attachment T includes a request to accept clarification of prior NRC approval of an exemption to an NFPA 805 Chapter 4 requirement (NFPA 805 Section 4.2.3.1).
4.1.2.3    NFPA 805 Chapter 3 Requirements Not Met and Not Previously Approved by NRC The following sections of NFPA 805 Chapter 3 are not specifically met nor do previous NRC approvals of alternatives exist:
* 3.5.16 - Approval is requested for the use of fire protection water for other purposes not related to fire protection.
The specific deviation and a discussion of how the alternative satisfies 10 CFR 50.48(c)(2)(vii) requirements is provided in Attachment L. NSPM requests NRC approval of these performance-based methods.
4.1.3 Definition of Power Block and Plant Where used in NFPA 805 Chapter 3 the terms Power Block and Plant refer to structures that have equipment required for nuclear plant operations, such as Containment, Auxiliary Building, Service Building, Control Building, Fuel Building, Radioactive Waste, Water Treatment, Turbine Building, and intake structures or structures that are identified in the facilitys pre-transition licensing basis.
PINGP                                                                        Page 15 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements All structures within the PINGP Owner Controlled Area were reviewed to determine the potential impact of fire on the nuclear safety and radioactive release criteria described in Section 1.5 of NFPA 805. This was accomplished by identifying the structures that contain either:
* Equipment that could affect o Plant operation for power generation o Equipment important to safety o Ability to maintain nuclear safety performance criteria in the event of a fire OR
* Radioactive materials that could potentially be released in the event of a fire.
The determination of structures defined as the power block was completed in PINGP Engineering Evaluation EC 23946, entitled NFPA 805 LAR Supplement Attachment I -
Power Block Definition.
These structures are listed in Attachment I and define the power block and plant.
4.2     Nuclear Safety Performance Criteria The Nuclear Safety Performance Criteria are established in Section 1.5 of NFPA 805.
Chapter 4 of NFPA 805 provides the methodology to determine the fire protection systems and features required to achieve the performance criteria outlined in Section 1.5. Section 4.3.2 of NEI 04-02 provides a systematic process for determining the extent to which the pre-transition licensing basis meets these criteria and for identifying any necessary fire protection program changes. NEI 04-02, Appendix B-2 provides guidance on documenting the transition of Nuclear Safety Capability Assessment Methodology and the Fire Area compliance strategies.
4.2.1 Nuclear Safety Capability Assessment Methodology The Nuclear Safety Capability Assessment (NSCA) Methodology review consists of four processes:
* Establishing compliance with NFPA 805 Section 2.4.2
* Establishing the Safe and Stable Conditions for the Plant
* Establishing Recovery Actions
* Evaluating Multiple Spurious Operations The methodology for demonstrating reasonable assurance that a fire during non-power operational (NPO) modes will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition is an additional requirement of 10 CFR 50.48(c) and is addressed in Section 4.3.
4.2.1.1    Compliance with NFPA 805 Section 2.4.2 Overview of Process NFPA 805 Section 2.4.2 Nuclear Safety Capability Assessment states:
PINGP                                                                    Page 16 - Revision 1

Northern States Power - Minnesota                    4.0 Compliance with NFPA 805 Requirements The purpose of this section is to define the methodology for performing a nuclear safety capability assessment. The following steps shall be performed:
(1) Selection of systems and equipment and their interrelationships necessary to achieve the nuclear safety performance criteria in Chapter 1 (2) Selection of cables necessary to achieve the nuclear safety performance criteria in Chapter 1 (3) Identification of the location of nuclear safety equipment and cables (4) Assessment of the ability to achieve the nuclear safety performance criteria given a fire in each fire area The NSCA methodology review evaluated PINGPs post-fire safe shutdown analysis (SSA) methodology against the guidance provided in NEI 00-01, Revision 1 (ML050310295), Chapter 3, Deterministic Methodology, as discussed in Appendix B-2 of NEI 04-02. The methodology is depicted in Figure 4-2 and consisted of the following activities:
* Each specific section of NFPA 805 2.4.2 was correlated to the corresponding section of Chapter 3 of NEI 00-01 Revision 1. Based upon the content of the NEI 00-01 methodology statements, a determination was made of the applicability of the section to the station.
* The plant-specific methodology was compared to applicable sections of NEI 00-01 and one of the following alignment statements and its associated basis were assigned to the section:
o Aligns o Aligns with intent o Not in Alignment o Not in Alignment, but Prior NRC Approval o Not in Alignment, but no adverse consequences
* For those sections that do not align, an assessment was made to determine if the failure to maintain strict alignment with the guidance in NEI 00-01 could have adverse consequences. Since NEI 00-01 is a guidance document, portions of its text could be interpreted as good practice or intended as an example of an efficient means of performing the analyses. If the section has no adverse consequences, these sections of NEI 00-01 can be dispositioned without further review.
The comparison of the PINGP post-fire SSA to NEI 00-01, Revision 1, Chapter 3 (NEI 04-02 Table B-2) was performed and documented in PINGP Engineering Evaluation EC 23310, NFPA 805 LAR Supplement Attachment B (Table B-2).
In addition, a review of NEI-00-01, Revision 2 (ML091770265), Chapter 3, was conducted to identify the substantive changes from NEI 00-01, Revision 1 that are applicable to an NFPA 805 fire protection program. This review was performed and documented in PINGP Engineering Evaluation EC 23408, NFPA 805 LAR Supplement NEI 00-01 Gap Analysis.
PINGP                                                                       Page 17 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Results from Evaluation Process The method used to perform the post-fire SSA with respect to selection of systems and equipment, selection of cables, and identification of the location of equipment and cables, either meets the NRC endorsed guidance from NEI 00-01, Revision 1, Chapter 3 (as supplemented by the gap analysis) directly or meets the intent of the endorsed guidance with adequate justification as documented in Attachment B with the following exceptions:
* Attachment B Section 3.1.1.4: As an exception to this section, the PINGP Fire Protection Program is transitioning an existing approved licensing action (exemption). This licensing action allows a repair action to assure isolation of pressurizer PORVs for a fire occurring in the control room or relay room (Fire Areas 13 and 18 respectively), that could cause spurious operation of the PORV isolation valves. Therefore, this section is Not in Alignment, but Prior NRC Approval. The details for this licensing action can be found in Attachments K and T.
* Attachment B Section 3.4.1.6: As an exception to this section, the PINGP Fire Protection Program is transitioning an existing approved licensing action (exemption) for oil collection system variances for Fire Areas 1 and 71 (containment). Therefore, this section is Not in Alignment, but Prior NRC Approval. The details for this existing licensing action can be found in Attachment K.
Figure 4 Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039)
PINGP                                                                     Page 18 - Revision 1

Northern States Power - Minnesota                    4.0 Compliance with NFPA 805 Requirements Comparison to NEI 00-01 Revision 2 An additional review was performed of NEI 00-01, Revision 2, Chapter 3, for specific substantive changes in the guidance from NEI 00-01, Revision 1 that are applicable to an NFPA 805 transition. The results of this review are summarized below:
* Post fire manual operation of rising stem valves in the fire area of concern (NEI 00-01 Section 3.2.1.2)
NSPM has performed reviews of all recovery actions, and has validated that there are no recovery actions requiring the use of rising stem valves where the credited valve has been exposed to the fire.
* Analysis of open circuits on high voltage (e.g., 4.16 kV) ammeter current transformers (NEI 00-01 Section 3.5.2.1)
NSPM Engineering Evaluation EC 20819, Technical Evaluation Associated with Open Circuiting of Current Transformers Contained in 13.8 kV, 4.16 kV, and 480 V Switchgear, demonstrated that although there are current transformers susceptible to fire-induced faults, including the highly unlikely open circuit fault, none of the current transformers are of concern for secondary fires.
* Analysis of control power for switchgear with respect to breaker coordination (NEI 00-01 Section 3.5.2.4)
DC control power required to maintain switchgear breaker coordination was analyzed in PINGP Engineering Evaluation EC 21264, Loss of DC Control Power Common Enclosure Analysis for NFPA 805, for both credited power supplies and non-credited power supplies. The analysis included both the common power supply as well as the common enclosure aspects of the loss of control power. Several modifications have been identified in Attachment S, Table S-2, to preclude coordination and circuit protection concerns resulting from this fire-induced failure sequence.
4.2.1.2      Safe and Stable Conditions for the Plant Overview of Process The nuclear safety goals, objectives and performance criteria of NFPA 805 allow more flexibility than the previous deterministic programs based on 10 CFR 50 Appendix R and NUREG-0800, Section 9.5-1 (and NEI 00-01, Chapter 3) since NFPA 805 only requires the licensee to maintain the fuel in a safe and stable condition rather than achieve and maintain cold shutdown.
NFPA 805, Section 1.6.56, defines Safe and Stable Conditions as follows For fuel in the reactor vessel, head on and tensioned, safe and stable conditions are defined as the ability to maintain Keff <0.99, with a reactor coolant temperature at or below the requirements for hot shutdown for a boiling water reactor and hot standby for a pressurized water reactor. For all other configurations, safe and stable conditions are defined as maintaining Keff <0.99 and fuel coolant temperature below boiling.
The nuclear safety goal of NFPA 805 requires "...reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from PINGP                                                                       Page 19 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements achieving and maintaining the fuel in a safe and stable condition" without a specific reference to a mission time or event coping duration.
For the plant to be in a Safe and Stable condition, it may not be necessary to perform a transition to cold shutdown as currently required under 10 CFR 50, Appendix R.
Therefore, the unit may remain at or below the temperature defined by a hot standby/hot shutdown plant operating state for the event.
Results Demonstration of the Nuclear Safety Performance Criteria for safe and stable conditions was performed in two analyses.
* At-Power analysis, Mode 1 through Mode 3. This analysis is discussed in Section 4.2.4.
* Non-Power analysis, which includes Mode 4 and below. This analysis is discussed in Section 4.3.
The NFPA 805 licensing basis for PINGP for a Safe and Stable condition in the event of a fire starting with the reactor in at-power operating Modes 1, 2, or 3 (Power Operation, Startup, or Hot Standby, respectively) is to maintain Safe and Stable conditions in Hot Standby without Residual Heat Removal (RHR). PINGP will maintain Hot Standby conditions until a decision is made to either place the reactor in a non-power operating mode, i.e., Hot Shutdown (Mode 4) or Cold Shutdown (Mode 5), or to return to power operations. Determination of the final state will be based upon the extent of the fire damage, the inventory remaining in the Refueling Water Storage Tank (RWST), the ability to provide makeup water to the RWST, and the ability to re-establish inventory in the Condensate Storage Tank (CST) or realign Auxiliary Feedwater (AFW) to its alternate source (cooling water system).
Mission Time A PINGP thermal-hydraulic analysis was performed for a mission time of 24 hours to assure that safe and stable conditions can be achieved within that time period. This mission time ensures that sufficient time is available for the Emergency Response Organization to respond to the event, assess the extent of fire damage, and assist the plant operating staff with maintaining Safe and Stable conditions or transitioning the plant to a non-power operating mode.
To sustain Safe and Stable conditions, Key Safety Functions are met as follows:
* Reactivity and Inventory Control The reactor design ensures that Keff < 0.99 can be achieved by use of the control rods from any operating mode. Subsequent injection (using Charging or Safety Injection Pumps) of soluble poison can be used to assure continuation of Mode 3, Hot Standby, under all circumstances. The charging system and the Safety Injection system will remain available beyond the mission time for Safe and Stable. The RWST is the credited source of borated water and is capable of providing water for at least 38 hours, per PINGP Engineering Evaluation EC 20736, Reactivity Control. Operator actions to establish makeup sources of PINGP                                                                      Page 20 - Revision 1

Northern States Power - Minnesota                    4.0 Compliance with NFPA 805 Requirements inventory to the RWST are described in existing plant procedure C12.5, Boron Concentration Control.
* Decay Heat Removal One or both steam generators, as well as a motor driven or turbine driven AFW pump will remain available without additional actions to provide symmetrical or asymmetrical decay heat removal beyond the mission time for Safe and Stable.
The CST is the initial source for the AFW pumps. Per Engineering Evaluation EC 20738, Decay Heat Removal, the CST will provide a continuous water supply for the AFW pumps for 20 hours. Beyond 20 hours, the CST can be refilled or the AFW pumps can be re-aligned to the cooling water system to provide an unlimited water source. This realignment is accomplished through existing plant procedures 1(2)E-1, Loss of Reactor or Secondary Coolant, and C28.1, AOP2, Loss of Condensate Supply to Auxiliary Feedwater Pump Suction.
* Vital Auxiliaries - Power and Support Systems The Emergency Diesel Generators (EDGs) and Diesel Driven Cooling Water Pumps (DDCLPs) have an on-site fuel oil supply that will last for 14 days, assuming one EDG on each unit and one DDCLP, or 7 days if both EDGs are operating for each unit and both DDCLPs are operating. Offsite sources of fuel oil are available to replenish fuel oil levels if needed via established contracts.
Control room heating, ventilating, and air conditioning (HVAC) can be lost in several fire areas due to the loss of instrument air and other fire-induced HVAC component damage. EC 23925, NFPA 805 LAR Supplement - Control Room HVAC Evaluation, demonstrates that control room temperatures will remain below equipment limits for up to 36 hours with actions taken only within the control room itself. However, a portable fan may be installed in the control room prior to 36 hours to allow temperatures to remain below equipment limits indefinitely. If required, the portable fan will normally be powered by a designated welding receptacle or in cases where the welding receptacle power is lost due to the fire, by a 480 VAC portable generator located outside of the building (Reference Attachment S-3, Item 63, for additional details).
If conditions warrant placing the plant in Hot Shutdown (Mode 4) or Cold Shutdown (Mode 5), NSPM will initiate operation of the RHR System. Although the RHR system is not required for maintaining safe and stable conditions, the RHR system is included in the at power Nuclear Safety Capability Assessment (NSCA) Genesis model to demonstrate its availability for transition. Initiation of RHR system operations does not imply that the end state will be Cold Shutdown (Mode 5).
4.2.1.3     Establishing Recovery Actions Overview of Process NEI 04-02 and RG 1.205 suggest that a licensee submit a summary of its approach for addressing the transition of Operator Manual Actions (OMAs) as recovery actions in the LAR (Regulatory Position 2.2.1 and NEI-04-02, Section 4.6). As a minimum, NEI 04-02 PINGP                                                                       Page 21 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensees methodology.
The discussion below provides the methodology used to transition pre-transition OMAs and to determine the population of post-transition recovery actions. This process is based on FAQ 07-0030 (ML110070485) and consists of the following steps:
* Step 1: Clearly define the primary control station(s) and determine which pre-transition OMAs are taken at primary control station(s) (Activities that occur in the Main Control Room are not considered pre-transition OMAs). Activities that take place at primary control station(s) or in the Main Control Room are not recovery actions, by definition.
* Step 2: Determine the population of recovery actions that are required to resolve variances from deterministic requirements (VFDRs) (to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth).
* Step 3: Evaluate the additional risk presented by the use of recovery actions required to demonstrate the availability of a success path.
* Step 4: Evaluate the feasibility of the recovery actions.
* Step 5: Evaluate the reliability of the recovery actions.
Results The review results are documented in PINGP Engineering Evaluation EC 23313, NFPA 805 LAR Supplement Attachment G. Refer to Attachment G for the detailed evaluation process and summary of the results from the process.
4.2.1.4     Evaluation of Multiple Spurious Operations Overview of Process NEI 04-02 suggests that a licensee submit a summary of its approach for addressing potential fire-induced Multiple Spurious Operations (MSOs) for NRC review and approval. As a minimum, NEI 04-02 suggests that the summary contain sufficient information relevant to methods, tools, and acceptance criteria used to enable the NRC to determine the acceptability of the licensees methodology. The methodology utilized to address MSOs for PINGP is summarized below.
As part of the NFPA 805 transition project, a review and evaluation of PINGP susceptibility to fire-induced MSOs was performed. The process was conducted in accordance with NEI 04-02 and RG 1.205, as supplemented by FAQ 07-0038 Revision 3 (ML110140242). The PWR Generic MSO list dated May 2009 was utilized.
The approach outlined in Figure 4-3 (based on Figure XX from FAQ 07-0038) is one acceptable method to address fire-induced MSOs. This method used insights from the PRA developed in support of transition to NFPA 805 and consists of the following:
* Identifying potential MSOs of concern.
* Conducting an expert panel to assess plant specific vulnerabilities (e.g., per NEI 00-01, Rev. 1, Section F.4.2).
* Updating the Fire PRA model and NSCA to include the MSOs of concern.
PINGP                                                                      Page 22 - Revision 1

Northern States Power - Minnesota                                   4.0 Compliance with NFPA 805 Requirements
* Evaluating for NFPA 805 Compliance.
* Documenting Results.
This process is intended to support the transition to a new licensing basis. Post-transition changes would use the RI-PB change process. The post-transition change process for the assessment of a specific MSO would be a simplified version of this process, and may not need the level of detail shown in the following section (e.g., An expert panel may not be necessary to identify and assess a new potential MSO.
Identification of new potential MSOs may be part of the plant change review process and/or inspection process).
Identify Potential MSOs of Concern SSA Step 1                 Generic List of MSOs Self Assessments PRA Insights Operating Experience Expert Panel Step 2             Identify and Document MSOs of Concern Update PRA model & NSCA (as appropriate) to include MSOs of concern Step 3                      ID equipment ID logical relationships ID cables ID cable routing Evaluate for NFPA 805 No Compliance Step 4                                                      Pursue other resolution options Compliant with NFPA 805?
Yes Step 5                    Document Results Figure 4 Multiple Spurious Operations - Transition Resolution Process (Based on FAQ 07-0038)
Results Refer to Attachment F for a description of the process used at PINGP, which is based on the approach outlined in Figure 4-3, and the results from the process.
PINGP                                                                                              Page 23 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements 4.2.2 Existing Engineering Equivalency Evaluation Transition Overview of Evaluation Process The EEEEs that support compliance with NFPA 805 Chapter 3 or Chapter 4 (both those that existed prior to the transition and those that were created during the transition) were reviewed using the methodology contained in NEI 04-02. The methodology for performing the EEEE review included the following determinations:
* The EEEE is not based solely on quantitative risk evaluations,
* The EEEE is an appropriate use of an engineering equivalency evaluation,
* The EEEE is of appropriate quality,
* The standard license condition is met,
* The EEEE is technically adequate,
* The EEEE reflects the plant as-built condition, and
* The basis for acceptability of the EEEE remains valid.
In accordance with the guidance in RG 1.205, Regulatory Position 2.3.2, and NEI 04-02, as clarified by FAQ 07-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs that demonstrate that a fire protection system or feature is adequate for the hazard are summarized in the LAR as follows:
* If not requesting specific approval for adequate for the hazard EEEEs, then the EEEE was referenced where required and a brief description of the evaluated condition was provided.
* If requesting specific NRC approval for adequate for the hazard EEEEs, then EEEE was referenced where required to demonstrate compliance and was included in Attachment L for NRC review and approval.
In all cases, the reliance on EEEEs to demonstrate compliance with NFPA 805 requirements was documented in the LAR.
Results The review results for EEEEs are documented in PINGP Engineering Evaluation EC 20386, NFPA 805 Existing Engineering Equivalency Evaluation Review Report.
In accordance with the guidance provided in RG 1.205, Regulatory Position 2.3.2, and NEI 04-02, as clarified by FAQ 07-0054, Demonstrating Compliance with Chapter 4 of NFPA 805, EEEEs used to demonstrate compliance with Chapters 3 and 4 of NFPA 805 are referenced in Attachments A and C as appropriate.
The EEEE discussions in Attachment C include evaluations of conformance to applicable NFPA codes for the PINGP fire suppression and fire detection system installations. Where detection and suppression systems are required to satisfy NFPA 805 Chapter 4 requirements, any modifications to resolve code deviations identified within the evaluations are included in Attachment S, Table S-2. In cases where systems are not required to satisfy NFPA 805 Chapter 4 requirements, code deviations are resolved through the PINGP corrective action program.
In addition, none of the transitioning EEEEs require NRC approval.
PINGP                                                                     Page 24 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements 4.2.3 Licensing Action Transition Overview of Evaluation Process The existing licensing actions (exemptions) review was performed in accordance with NEI 04-02. The methodology for the licensing action review included the following:
* Determination of the bases for acceptability of the licensing action.
* Determination that these bases for acceptability are still valid and required for NFPA 805.
* In addition, variances from the deterministic requirements were identified in the NEI 04-02 Table B-3 (See Attachment C). Some of these variances were subsequently dispositioned via the use of the performance-based approach. A licensing action summary was completed for each fire area using the performance-based approach.
Results Attachment K contains the detailed results of the Licensing Action Review. Where NRC clarification is needed for the continued acceptability of the exemption, the appropriate request for clarification is included in Attachment T.
The following licensing actions will be transitioned into the NFPA 805 fire protection program as previously approved (NFPA 805 Section 2.2.7). These licensing actions are considered compliant under 10 CFR 50.48(c).
* Appendix R Exemption, RCP Oil Collection, RCP oil collection system not in strict compliance (III.O criteria), Units 1 and 2, Fire Areas 1 and 71 (NRC SER dated July 31, 1984).
* Appendix R Exemption, Control Room, Repair action to remove fuses from PORV control circuits in event of control room evacuation, Units 1 and 2, Fire Area 13 (NRC SER dated February 21, 1995), subject to clarification requested in Attachment T.
The following licensing actions are no longer necessary and will not be transitioned into the NFPA 805 fire protection program:
* Appendix R Exemption, Control Room, Lack of automatic fixed suppression system (III.G.3 criteria), Units 1 and 2, Fire Area 13 (NRC SER dated February 2, 1983).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit a fixed suppression system in the control room.
* Appendix R Exemption, Train "A" Hot Shutdown Panel; Instrument Air Room and Auxiliary Feedwater Pump Room, Lack of 20' separation free of intervening combustibles or lack of a 1-hour fire barrier (III.G.2 criteria), Units 1 and 2, Fire PINGP                                                                       Page 25 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements Area 31 (NRC SER dated May 4, 1983).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit 20 separation with no intervening combustibles.
* Appendix R Exemption, Train "B" Hot Shutdown Panel; Instrument Air Room and Auxiliary Feedwater Pump Room, Lack of 20' separation free of intervening combustibles or lack of a 1-hr fire barrier (III.G.2 criteria), Units 1 and 2, Fire Area 32 (NRC SER dated May 4, 1983).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit 20 separation with no intervening combustibles.
* Appendix R Exemption, Normal Switchgear Room, Lack of automatic fixed suppression system (III.G.2 criteria), Unit 1, Fire Area 37 (NRC SER dated May 4, 1983).
This exemption was previously withdrawn and is no longer required because a facility modification relocated redundant cables outside the fire area.
* Appendix R Exemption, Auxiliary Building, Operating Level, Lack of automatic suppression system (III.G.2 criteria), Unit 1, Fire Area 60 (NRC SER dated May 4, 1983).
This exemption is no longer required because redundant equipment required for safe shutdown is no longer located in this fire area, due to a facility modification that changed power supplies for steam supply valves.
* Appendix R Exemption, Auxiliary Building, Operating Level, Lack of area wide suppression (III.G.2 criteria), Unit 2, Fire Area 75 (NRC SER dated May 4, 1983).
This exemption is no longer required because redundant equipment required for safe shutdown is no longer located in this fire area, due to a facility modification that changed power supplies for steam supply valves.
* Appendix R Exemption, Auxiliary Building, Ground Level, Lack of automatic fire suppression system (III.G.2 criteria), Unit 1, Fire Area 58 (NRC SER dated January 9, 1984).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit an automatic fire suppression system in this fire area.
* Appendix R Exemption, Auxiliary Building, Ground Level, Lack of automatic fire suppression system (III.G.2 criteria), Unit 2, Fire Area 73 (NRC SER dated January 9, 1984).
PINGP                                                                       Page 26 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit an automatic fire suppression system in this fire area.
* Appendix R Exemption, Auxiliary Building, Mezzanine Level, Lack of automatic fixed suppression (III.G.2 criteria), Unit 1, Fire Area 59 (NRC SER dated January 9, 1984).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit an automatic fixed suppression system in this fire area.
* Appendix R Exemption, Auxiliary Building, Mezzanine Level, Lack of automatic fixed suppression (III.G.2 criteria), Unit 2, Fire Area 74 (NRC SER dated January 9, 1984).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit an automatic fixed suppression system in this fire area.
* Appendix R Exemption, Containment, Intervening combustibles between redundant shutdown divisions, Units 1 and 2, Fire Areas 1 and 71 (NRC SER dated July 31, 1984).
This exemption is no longer required because the PINGP NFPA 805 transition compliance strategy is in accordance with NFPA 805 Section 4.2.4, and uses a performance based approach that does not credit 20 separation with no intervening combustibles and takes into account the different fire protection features installed to protect pressurizer level transmitter cables in Unit 1 and Unit 2.
Since the exemptions are either compliant with 10 CFR 50.48(c) or no longer necessary, in accordance with the requirements of 10 CFR 50.48(c)(3)(i), PINGP requests that the exemptions listed in Attachment K be rescinded as part of the LAR process. It is NSPMs understanding that implicit in the superseding of the current license condition, all prior fire protection program Safety Evaluation Reports and commitments will be superseded in their entirety. See Attachment O, Orders and Exemptions.
4.2.4 Fire Area Transition Overview of Evaluation Process The Fire Area Transition (NEI 04-02 Table B-3) was performed using the methodology contained NEI 04-02 and FAQ 07-0054. The methodology for performing the Fire Area Transition, depicted in Figure 4-4, is outlined as follows:
Step 1 - Assembled documentation. Gathered industry and plant-specific fire area analyses and licensing basis documents.
PINGP                                                                      Page 27 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Step 2 - Documented fulfillment of nuclear safety performance criteria.
* Assessed accomplishment of nuclear safety performance goals. Documented the method of accomplishment, in summary level form, for the fire area.
* Documented evaluation of effects of fire suppression activities. Documented the evaluation of the effects of fire suppression activities on the ability to achieve the nuclear safety performance criteria.
* Performed licensing action reviews. Performed a review of the licensing aspects of the selected fire area and documented the results of the review. See Section 4.2.3.
* Performed existing engineering equivalency evaluation reviews. Performed a review of existing engineering equivalency evaluations (or created new evaluations) documenting the basis for acceptability. See Section 4.2.2.
* Pre-transition OMA reviews. Performed a review of pre-transition OMAs to determine those actions taking place outside of the main control room or outside of the primary control station(s). See Section 4.2.1.3.
Step 3 - VFDR Identification and characterization and resolution considerations.
Identified variances from the deterministic requirements of NFPA 805, Section 4.2.3.
Documented variances as either a separation issue or a degraded fire protection system or feature. Developed VFDR problem statements to support resolution and selected an approach in accordance with NFPA 805 Chapter 4.
Step 4 - Performance-Based evaluations (Fire Modeling or Fire Risk Evaluations) See Section 4.5.2 for additional information. Alternatively, as shown in Figure 4-4, the VFDR condition was brought into compliance with Section 4.2.3 of NFPA 805.
Step 5 - Final Disposition.
* Documented final disposition of the VFDRs in Attachment C (NEI 04-02 Table B-3).
* For recovery action compliance strategies, ensured the manual action feasibility analysis of the required recovery actions was completed. Note: if a recovery action cannot meet the feasibility requirements established per NEI 04-02, then alternate means of compliance was considered.
* Documented the post transition NFPA 805 Chapter 4 compliance basis.
Step 6 - Documented required fire protection systems and features. Reviewed the NFPA 805 Section 4.2.3 compliance strategies (including fire area licensing actions and engineering evaluations) and the NFPA 805 Section 4.2.4 compliance strategies (including simplifying deterministic assumptions) to determine the scope of fire protection systems and features required by NFPA 805 Chapter 4. The required fire protection systems and features are subject to the applicable requirements of NFPA 805 Chapter 3.
PINGP                                                                      Page 28 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Figure 4 Summary of Fire Area Review
[Based on FAQ 07-0054 Revision 1]
PINGP                                                                     Page 29 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements Results of the Evaluation Process Attachment C contains the results of the Fire Area Transition review (NEI 04-02 Table B-3). On a fire area basis, Attachment C summarizes compliance with Chapter 4 of NFPA 805.
NEI 04-02 Table B-3 includes the following summary level information for each fire area:
* Regulatory Basis - NFPA 805 post-transition regulatory bases are included.
* Performance Goal Summary - An overview of the method of accomplishment of each of the performance criteria in NFPA 805 Section 1.5 is provided.
* Reference Documents - Specific references to Nuclear Safety Capability Assessment Documents are provided.
* Licensing Actions - Specific references to exemptions that will remain part of the post-transition licensing basis are provided. A brief description of the condition and the basis for acceptability of the licensing action is provided. In addition summaries of Fire Risk Evaluations performed for variances from the deterministic requirements are also provided. Attachment T contains items for which NSPM is requesting concurrence of prior approval.
* EEEE - Specific references to EEEE that rely on determinations of adequate for the hazard that will remain part of the post-transition licensing basis are provided. A brief description of the condition and the basis for acceptability is provided.
* VFDRs - Specific variances from the deterministic requirements of NFPA 805 Section 4.2.3 are identified. Refer to Section 4.5.2 for a discussion of the performance-based approach.
4.3     Non-Power Operational Modes 4.3.1 Overview of Evaluation Process NSPM implemented the process outlined in NEI 04-02 and FAQ 07-0040, Clarification on Non-Power Operations. The goal (as depicted in Figure 4-5) is to ensure that contingency plans are established when the plant is in a Non-Power Operational (NPO) mode where the risk is intrinsically high. During low risk periods, normal risk management controls and fire prevention/protection processes and procedures will be utilized.
The process to demonstrate that the nuclear safety performance criteria are met during NPO modes involved the following steps:
* Reviewed the existing Outage Management Processes.
* Identified Equipment/Cables:
o Reviewed plant systems to determine success paths that support each of the defense-in-depth Key Safety Functions (KSFs), and o Identified cables required for the selected components and determined their routing.
PINGP                                                                      Page 30 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements
* Performed Fire Area Assessments (identify pinch points - plant locations where a single fire may damage all success paths of a KSF).
* Managed pinch-points associated with fire-induced vulnerabilities during the outage.
The process is depicted in Figures 4-5 and 4-6. The results are presented in Section 4.3.2.
Figure 4-5 Review POSs, KSFs, Equipment, and Cables, and Identify Pinch Points PINGP                                                                     Page 31 - Revision 1

Northern States Power - Minnesota                                  4.0 Compliance with NFPA 805 Requirements Equipment Out of Service (OOS)
KSF                 Fire Protection Equipment               Defense-in-No Availability                Depth Changed?                   Actions Yes Fire Protection Higher Risk Evolution as Defined by Plant Specific        Higher Risk               Defense-in-No Outage Risk Criteria for example                          Evolution?                   Depth
: 1) Time to Boil                                                                       Actions
: 2) Reactor Coolant System and Fuel Pool Inventory
: 3) Decay Heat Removal Yes Determine Fire Area Impact based on NPO Fire Area Assessments Fire Protection KSF                  Defense-in-No Lost?                   Depth Actions Yes Implement Contingency Plan for Specific KSF Figure 4-6 Manage Pinch Points PINGP                                                                                         Page 32 - Revision 1

Northern States Power - Minnesota                        4.0 Compliance with NFPA 805 Requirements 4.3.2 Results of the Evaluation Process Based on FAQ 07-0040 Revision 4, the Plant Operating States (POS) considered for equipment and cable selection are defined in PINGP Engineering Evaluation EC 23507, NFPA 805 LAR Supplement Attachment D. Components were identified to support the KSFs of Reactivity, Core Decay Heat Removal, Containment, Inventory, and associated support functions. A model was developed in the NFPA 805 Analysis Database (Genesis Solution Suite, SAFE Module).
Equipment was logically tied to the supported KSF. Power supplies, interlocks, and supporting equipment were logically tied to their parent component.
For those components which had not been previously analyzed in support of the at-power analysis or whose functional requirements may have been different for the NPO analysis, cable selection was performed in accordance with approved project procedures. Cables necessary to support the selected function of a component were selected and analyzed for fire impact.
PINGP Engineering Evaluation, EC 23507, NFPA 805 LAR Supplement Attachment D, references the fire area assessment, the identified pinch points, and general recommendations for administrative controls to reduce fire risk as well as a proposed strategy for recovering the KSF should a fire occur. In accordance with FAQ 07-0040 Revision 4, any area experiencing fire damage which eliminates all success paths for a KSF (without recovery actions outside the main control room) is considered a pinch point. Fire modeling was not used to eliminate any fire area from being a pinch point.
The list of generic recommendations specified in PINGP Engineering Evaluation EC 23507, NFPA 805 LAR Supplement Attachment D, considers the following actions from FAQ 07-0040 Revision 4:
* Prohibition or limitation of hot work in fire areas during periods of increased vulnerability.
* Verification of operable detection and/or suppression in the vulnerable areas.
* Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability.
* Plant configuration changes (e.g., removing power from equipment once it is placed in its desired position).
* Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.
* Use of recovery actions to mitigate potential losses of KSFs.
* Identification and monitoring insitu ignition sources for fire precursors (e.g., equipment temperatures).
* Reschedule the work to a period with lower risk or higher Defense-In-Depth (DID).
Refer to Attachment D for more complete details. Based on consideration of the vulnerable areas and incorporation of generic recommendations from FAQ 07-0040 Revision 4 into appropriate plant procedures and practices, prior to implementation of NFPA 805, the performance goals (KSFs) for NPO will be fulfilled and the requirements of NFPA 805 will be met.
Implementation of the NPO fire area assessment results into the Prairie Island Nuclear Generating Plant outage management processes will be completed as part of LAR implementation. (See Attachment S).
PINGP                                                                             Page 33 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements 4.4    Radioactive Release Performance Criteria 4.4.1 Overview of Evaluation Process The review of the fire protection program against NFPA 805 requirements for fire suppression related radioactive release was performed using the methodology contained in Nuclear Energy Institute (NEI) 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c) and NFPA 805 FAQ 09-0056. The methodology consisted of the following:
* A review of fire pre-plans and fire brigade training materials to identify fire protection program elements (e.g., systems / components / procedural control actions / flow paths, etc.) that are being credited to meet the radioactive release goals, objectives, and performance criteria during all plant operating modes, including full power and non-power conditions.
* A review of engineering controls to ensure containment of gaseous and liquid effluents (e.g., smoke and fire fighting agents). This review included all plant operating modes (including full power and non-power conditions). Otherwise, provided a bounding analysis, quantitative analysis, or other analysis that demonstrates that the limitations for instantaneous release of radioactive effluents specified in the units Technical Specifications or Offsite Dose Calculation Manual are met.
4.4.2 Results of the Evaluation Process The PINGP fire strategies are developed based on the fire detection zone alarms received in the control room and can cover one or more fire areas. The fire strategies were reviewed to screen them for applicability by fire area based on their potential to contain radioactive or contaminated materials. PINGP Engineering Evaluation EC 23734, NFPA 805 LAR Supplement Attachment E, contains detailed evaluation bases and results regarding when a fire area is screened in (affects radioactive release) or screened out (cannot affect radioactive release). The radioactive release review determined the fire protection program will be compliant with the requirements of NFPA 805 and the guidance in NEI 04-02 and RG 1.205 upon completion of the implementation items identified in Attachment S.
The review determined that radioactive release to any unrestricted area due to the direct effects of fire suppression activities (but not involving fuel damage) would be as low as reasonably achievable. The site specific review of associated fire event and fire suppression related radioactive release is summarized in Attachment E of this document, which is based on the NEI 04-02 Table G-1.
As described in Attachment S (Table S-3, item 10), the Fire Strategies (PINGP-version of Pre-Fire Plans) will be revised to identify potential cross-contamination issues for each applicable fire area and fire detection zone. Information will be provided on cross contamination concerns to assist the fire brigade leader and Control Room personnel in determining the best available methods for minimizing cross contamination and radiological release based on the location of the fire.
As described in Attachment S (Table S-3, items 7, 8, 9, and 11), fire fighting instructions and brigade lesson plans will be revised to provide additional instructions on the control PINGP                                                                      Page 34 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements of the spread of contamination as a result of fire fighting activities. The responsibilities of each brigade member relative to limiting the spread of cross contamination when fighting fires in radiologically controlled areas will be incorporated into the instructions and lesson plans. Training materials for radiation protection will be revised as applicable to address their role in controlling the spread of contamination (Table S-3, item 12).
As described in Attachment S (Table S-3, item 13), ventilation and runoff will be addressed with respect to the impact on the spread of contamination to adjacent radiologically controlled areas, radiologically clean areas and release to the exterior.
For those fire areas without installed ventilation controls (and for those time periods where existing ventilation controls are not available), mitigative actions will be taken to utilize a combination of exhausting potentially contaminated smoke through adjacent areas with filtered ventilation or the use of portable filtered ventilation equipment. The mitigative actions will be based on the radiological conditions as monitored by radiation protection personnel and communicated to the fire brigade leader during the event.
Potentially contaminated water will be controlled by the use of booms to limit the spread of contamination to adjacent radiologically controlled areas, radiologically clean areas and to the exterior.
As described in Attachment S (Table S-3, items 15 and 16), a combination of containerization and administrative controls will be used limit the amount of exposed contaminated combustible materials in areas without filtered ventilation or where the spread of contaminated water to adjacent radiologically controlled areas, radiologically clean areas or to the exterior are potential concerns.
4.5     Fire PRA and Performance-Based Approaches RI-PB evaluations are an integral element of an NFPA 805 fire protection program. Key parts of RI-PB evaluations include:
* A Fire PRA (discussed in Section 4.5.1 and Attachments U, V, and W).
* NFPA 805 Performance-Based Approaches (discussed in Section 4.5.2).
4.5.1 Fire PRA Development and Assessment In accordance with the guidance in RG 1.205, a Fire PRA model was developed for PINGP in compliance with the requirements of Part 4 Requirements for Fires At Power PRA, of the ASME and ANS combined PRA Standard, ASME/ANS RA-Sa-2009, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Application, (hereafter referred to as Fire PRA Standard). NSPM conducted a peer review by independent industry analysts in accordance with RG 1.200 prior to a risk-informed submittal. The resulting fire risk assessment model is used as the analytical tool to perform Fire Risk Evaluations during the transition process.
Section 4.5.1.1 describes the Internal Events PRA model. Section 4.5.1.2 describes the Fire PRA model. Section 4.5.1.3 describes the results and resolution of the peer review of the Fire PRA, and Section 4.5.1.4 describes insights gained from the Fire PRA.
PINGP                                                                       Page 35 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements 4.5.1.1    Internal Events PRA The PINGP base internal events PRA, Revision 3.1, was the starting point for the Fire PRA. Previously in 2006, the PINGP PRA underwent a gap assessment against the Capability Category II requirements of ASME RA-S-2002, with ASME RA-Sa-2003 and ASME RA-Sb-2005 Addenda, ASME, 2005. To update the PINGP PRA to Capability Category II of the Standard, a large-effort PRA upgrade was planned and initiated in 2007.
At the conclusion of the PRA upgrade, NSPM completed the Revision 3.0 PRA model.
An independent peer review team evaluated the PINGP Revision 3.0 PRA model against the most current combined PRA Standard, ASME/ANS RA-Sa-2009, and RG 1.200, Revision 2. With the exception of the Internal Flooding analysis which was performed separately as described later, the PINGP Revision 3.0 Level 1 analysis evaluated core damage frequency (CDF) from all internal events and large early release frequency (LERF) utilizing the Westinghouse Owners Group Simplified Level 2 Analysis Approach, WCAP-16341.
Facts and Observations (F&Os) were issued by the peer team as an output of the peer review. NSPM subsequently evaluated these for inclusion into the next revision of the PRA, Revision 3.1, which was used as the starting point for the Fire PRA. Attachment U discusses the peer review findings to illustrate the technical adequacy of the Internal Events PRA supporting the Fire PRA.
In addition, NSPM updated the Internal Flooding analysis. The Internal Flooding analysis was amended to the Revision 3.1 PRA model in a sensitivity analysis to determine the risk contribution of Internal Flooding to overall risk. The analysis was peer reviewed against the most current combined PRA Standard, ASME/ANS RA-Sa-2009, and RG 1.200, Revision 2, during a review performed in September 2012.
Attachment U discusses the peer review findings to illustrate the technical adequacy of the Internal Flooding Analysis and provides a disposition of each finding as to its impact on the Fire PRA.
4.5.1.2    Fire PRA The fire PRA was developed using the internal events PRA as a starting point. The internal events PRA was modified to capture the effects of fire both as an initiator of an event and as a potential failure mode of affected circuits and individual targets. The Fire PRA is a unit-specific analysis that takes into account inter-unit dependencies. The Fire PRA was quantified using the CAFTA and PRAQuant software. A Fire PRA model was developed for NSPM using the guidance provided in NUREG/CR-6850/EPRI TR-1011989, Supplement 1 to NUREG/CR-6850/EPRI 1019259, and draft NUREG-1921.
A Peer Review of the PINGP Fire PRA against the requirements of Section 4 of the combined PRA Standard, ASME/ANS RA-Sa-2009, and RG 1.200, Revision 2, was conducted the week of May 7 through May 11, 2012. There were not any previously un-reviewed methods used to complete the PINGP Fire PRA. The Fire PRA quality and insights are discussed in Attachments V and W, respectively. After the initial submittal PINGP                                                                    Page 36 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements of the PINGP NFPA 805 LAR, NSPM revised the Fire PRA. The results of this Fire PRA revision are discussed in Attachment W, Revision 1.
Fire Model Utilization in the Application Fire modeling was performed as part of the Fire PRA development (NFPA 805 Section 4.2.4.2). RG 1.205, Regulatory Position 4.2 and Section 5.1.2 of NEI 04-02, provide guidance to identify fire models that are acceptable to the NRC for plants implementing a risk-informed, performance-based licensing basis.
The following fire models were used:
* Flame Height (Method of Heskestad)
* Plume Centerline Temperature (Method of Heskestad)
* Radiant Heat Flux (Point Source Method)
* Hot Gas Layer (Method of MQH)
* Hot Gas Layer (Method of Beyler)
* Hot Gas Layer (Method of Foote, Pagni, and Alvares [FPA])
* Ceiling Jet Temperature (Method of Alpert)
* Hot Gas Layer Calculations using Fire Dynamics Simulator (Version 5)
* Hot Gas Layer Calculations using CFAST (Version 6)
* Corner and Wall HRR
* Correlation for Heat Release Rates of Cables (Method of Lee)
* FLASH-CAT The acceptability of the use of these fire models is included in Attachment J.
4.5.1.3    Results of Fire PRA Peer Review The PINGP Fire PRA, Revision 0, was peer reviewed against the requirements of ASME/ANS RA-Sa-2009, Part 4, and in accordance with the peer review guidelines of NEI 07-12. This peer review was conducted the week of May 7 through May 11, 2012.
Section 4 of the ASME/ANS PRA Standard contains a total of 183 Supporting Requirements (SRs) under 13 technical elements, and configuration control from Section 1.5. Of these 183 SRs, eighteen (18) were determined to be not applicable to the PINGP Fire PRA either due to the fact that the requirements were not applicable to the PINGP approach, or the technical element was not used for the PINGP analysis (i.e., quantitative screening, QNS). For the PINGP Fire PRA about 92% of the SRs were assessed at Capability Category II or higher, including 5% of the SRs being assessed at Capability Category III. The PINGP Fire PRA had an additional 3% of the applicable SRs assessed at the CC-I level. The PINGP Fire PRA does not meet 5% of the applicable SRs. There were no SRs Not Reviewed by the Peer Review Team.
There were also no Unreviewed Analysis Methods identified by the Team.
The Peer Review also noted a total of 56 Facts and Observations (F&Os). These included fifteen (15) Suggestions, forty (40) Findings and one (1) Best Practice.
PINGP                                                                    Page 37 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements The Finding F&Os and their disposition with respect to the NFPA 805 License Amendment Request are provided in Table V-1, organized by Technical Element and Supporting Requirement. The Finding F&Os covered a variety of topics, but many dealt with the need to incorporate additional detailed analyses to develop results that are more realistic rather than bounding. Several others were on the need to better identify assumptions and discuss their impact on overall results. Suggestion F&Os largely involve optional clarifications or improvements. The Best Practice F&O was issued for the Seismic Fire Interaction Technical Element.
Subsequent to the May 2012 peer review, updates were made to the Fire PRA. An additional focused peer review was completed in December 2013 to review fire modeling methods that were used to support Hot Gas Layer (HGL) calculations. The analysis was peer reviewed against the most current combined PRA Standard, ASME/ANS RA-Sa-2009, and RG 1.200, Revision 2.
The Focused Peer Review noted a total of five (5) F&Os. These included four (4)
Suggestions, and one (1) Finding. The Finding F&O and its disposition with respect to the NFPA 805 License Amendment Request are provided in Table V-1. One of the four Suggestions provided additional information and was appended to an F&O that had been previously identified during the initial Fire PRA Peer Review.
Attachment V contains a summary of the FPRA peer review F&Os and their disposition by NSPM.
4.5.1.4      Risk Insights Risk insights were documented as part of the development of the Fire PRA. The total plant fire CDF/LERF was derived using the NUREG/CR-6850 methodology for Fire PRA development and is useful in identifying the areas of the plant where fire risk is greatest.
A review of the fire scenarios that individually contribute more than 0.5% of calculated fire risk are included as Attachment W.
4.5.2 Performance-Based Approaches NFPA 805 outlines the approaches for performing performance-based analyses. As specified in Section 4.2.4, there are generally two types of analyses performed for the performance-based approach:
* Fire Modeling (NFPA 805 Section 4.2.4.1).
* Fire Risk Evaluation (FRE, NFPA 805 Section 4.2.4.2).
The PINGP NFPA 805 transition implemented the FRE approach per NFPA 805 Section 4.2.4.2 to evaluate the risk significance and acceptability of the VFDRs.
4.5.2.1      Fire Modeling Approach The fire modeling approach per NFPA 805 Section 4.2.4.1 was not utilized for the PINGP NFPA 805 transition.
PINGP                                                                     Page 38 - Revision 1

Northern States Power - Minnesota                             4.0 Compliance with NFPA 805 Requirements 4.5.2.2      Fire Risk Approach Overview of Evaluation Process The Fire Risk Evaluations were completed as part of the PINGP NFPA 805 transition.
These Fire Risk Evaluations were developed using the process described below. This methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, and RG 1.205. These are summarized in Table 4-1.
Table 4-1 Fire Risk Evaluation Guidance Summary Table Document                         Section(s)                                     Topic NFPA 805                2.2(h), 4.2.4, A.2.2(h), A.2.4.4, D.5     Change Evaluation (2.2(h), 2.2.9, 2.4.4 A.2.2(h), A.2.4.4, D.5)
Risk of Recovery Actions (4.2.4)
Use of Fire Risk Evaluation (4.2.4.2)
NEI 04-02 Revision 2    4.4, 5.3, Appendix B, Appendix I,         Change Evaluation, Change Evaluation Appendix J                                Forms (App. I), No specific discussion of Fire Risk Evaluation RG 1.205 Revision 1     C.2.2.4, C.2.4, C.3.2                     Risk Evaluations (C.2.2.4)
Recovery Actions (C.2.4)
During the transition to NFPA 805, variances from the deterministic approach in Section 4.2.3 of NFPA 805 were evaluated using a Fire Risk Evaluation per Section 4.2.4.2 of NFPA 805. A Fire Risk Evaluation was performed for each fire area containing variances from the deterministic requirements of Section 4.2.3 of NFPA 805 (VFDRs).
If the Fire Risk Evaluation meets the acceptance criteria, this is confirmation that a success path effectively remains free of fire damage and that the performance-based approach is acceptable per Section 4.2.4.2 of NFPA 805.
The Fire Risk Evaluation process consists of the following steps (Figure 4-7 depicts the Fire Risk Evaluation process used during transition. This is generally based on FAQ 07-0054 Revision 1 (ML110140183):
Step 1 - Preparation for the Fire Risk Evaluation.
* Definition of the Variances from the Deterministic Requirements. The definition of the VFDR includes a description of problem statement and the section of NFPA 805 that is not met, type of VFDR (e.g., separation issue or degraded fire protection system), and proposed evaluation per applicable NFPA 805 section.
* Preparatory Evaluation - Fire Risk Evaluation Team Review. Using the information obtained during the development of NEI 04-02, Table B-3 and the Fire PRA, a team review of the VFDR was performed. The FRE review team included a Safe Shutdown/NSCA Engineer, a Fire Protection Engineer, and a Fire PRA Engineer. The purpose and objective of this team review was to address the following:
o Review of the Fire PRA modeling treatment of VFDR o Ensure discrepancies were captured and resolved PINGP                                                                                    Page 39 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements Step 2 - Performed the Fire Risk Evaluation
* The Evaluator coordinated as necessary with the Safe Shutdown/NSCA Engineer, Fire Protection Engineer and Fire PRA Engineer to assess the VFDR using the Fire Risk Evaluation process to perform the following:
o Change in Risk Calculation with consideration for additional risk of recovery actions and required fire protection systems and features due to fire risk.
o Fire area change in risk summary.
Step 3 - Reviewed the Acceptance Criteria
* The acceptance criteria for the Fire Risk Evaluation consist of two parts. One is quantitatively based and the other is qualitatively based. The quantitative figures of merit are CDF and LERF. The qualitative factors are defense-in-depth and safety margin.
o Risk Acceptance Criteria. The transition risk evaluation was measured quantitatively for acceptability using the CDF and LERF criteria from RG 1.174, as clarified in RG 1.205 Regulatory Position 2.2.4.
o Defense-in-Depth. A review of the impact of the change on defense-in-depth was performed, using the guidance from NEI 04-02. NFPA 805 defines defense-in-depth as:
               - Preventing fires from starting
               - Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting damage
               - Providing adequate level of fire protection for structures, systems and components important to safety; so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.
In general, the defense-in-depth requirement was considered to be satisfied if the proposed change does not result in a substantial imbalance among these elements (or echelons).
The review of defense-in-depth was qualitative and addressed each of the elements with respect to the proposed change. Defense-in-depth was performed on a fire area basis.
Fire protection features and systems relied upon to ensure defense-in-depth were identified as a result of the assessment of defense-in-depth.
o Safety Margin Assessment. A review of the impact of the change on safety margin was performed. An acceptable set of guidelines for making that assessment is summarized below. Other equivalent acceptance guidelines may also be used.
               - Codes and standards or their alternatives accepted for use by the NRC are met, and
               - Safety analysis acceptance criteria in the licensing basis (e.g., FSAR, supporting analyses) are met, or provides sufficient margin to account for analysis and data uncertainty.
PINGP                                                                      Page 40 - Revision 1

Northern States Power - Minnesota                4.0 Compliance with NFPA 805 Requirements The requirements related to safety margins for the change analysis are described for each of the specific analysis types used in support of the FRE.
PINGP                                                                   Page 41 - Revision 1

Northern States Power - Minnesota                         4.0 Compliance with NFPA 805 Requirements Prepare for Fire Risk Evaluation Identification of VFDRs (From B-3 Tables)
Discuss and Document in Determine How to Model Fire PRA and Fire Risk the VFDR in the Fire PRA Evaluation Documentation Perform Fire Risk Evaluation Calculate VFDR Delta CDF And Delta LERF Review of Acceptance Criteria Evaluate Delta CDF And Delta LERF Evaluate the Maintenance of                       Discuss and Document in Defense-In-Depth                     Fire Risk Evaluation And                               Calculation Safety Margin Figure 4 Fire Risk Evaluation Process (NFPA 805 Transition)
[Based on FAQ 07-0054 Revision 1]
PINGP                                                                            Page 42 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements Results of Evaluation Process Disposition of VFDRs The PINGP existing post-fire SSA / NSCA and the NFPA 805 transition project activities have identified a number of variances from the deterministic requirements of NFPA 805 Section 4.2.3. These variances were dispositioned using the fire risk evaluation process.
Each variance dispositioned using a Fire Risk Evaluation was assessed against the Fire Risk Evaluation acceptance criteria of CDF and LERF; and maintenance of defense-in-depth and safety margin criteria from Section 5.3.5 of NEI 04-02 and RG 1.205. The results of these calculations are summarized in Attachment C.
Following completion of transition activities and planned modifications and program changes, the plant will be compliant with 10 CFR 50.48(c).
Risk Change Due to NFPA 805 Transition In accordance with the guidance in RG 1.205, Section C.2.2.4, Risk Evaluations, risk increases or decreases for each fire area using Fire Risk Evaluations and the overall plant should be provided. Note that the risk increase due to the use of recovery actions was included in the risk change for transition for each fire area.
RG 1.205, Section C.2.2.4.2 states in part The total increase or decrease in risk associated with the implementation of NFPA 805 for the overall plant should be calculated by summing the risk increases and decreases for each fire area (including any risk increases resulting from previously approved recovery actions). The total risk increase should be consistent with the acceptance guidelines in Regulatory Guide 1.174. Note that the acceptance guidelines of Regulatory Guide 1.174 may require the total CDF, LERF, or both, to evaluate changes where the risk impact exceeds specific guidelines. If the additional risk associated with previously approved recovery actions is greater than the acceptance guidelines in Regulatory Guide 1.174, then the net change in total plant risk incurred by any proposed alternatives to the deterministic criteria in NFPA 805, Chapter 4 (other than the previously approved recovery actions), should be risk neutral or represent a risk decrease.
The risk increases and decreases are provided in Attachment W.
4.6     Monitoring Program 4.6.1 Overview of NFPA 805 Requirements for the NFPA 805 Monitoring Program Section 2.6 of NFPA 805 states:
A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria.
Monitoring shall ensure that the assumptions in the engineering analysis remain valid.
PINGP                                                                      Page 43 - Revision 1

Northern States Power - Minnesota                     4.0 Compliance with NFPA 805 Requirements The intent of the monitoring review is to confirm the adequacy of the existing surveillance, inspection, testing, compensatory measures, and oversight processes for transition to NFPA 805. This review considers the following:
* The adequacy of the scope of structures, systems and components within existing plant programs.
* The performance criteria for the availability and reliability of the required structures, systems and components.
* The adequacy of the plant corrective action program in determining causes of equipment and programmatic failures and in minimizing their recurrence.
4.6.2 Overview of Post-Transition NFPA 805 Monitoring Program This section provides an overview of the post-transition NFPA 805 Monitoring Program process. The Monitoring program will be implemented after the safety evaluation issuance as part of the fire protection program transition to NFPA 805. The monitoring process is comprised of four phases:
* Phase 1 - Scoping
* Phase 2 - Screening Using Risk Criteria
* Phase 3 - Risk Target Value Determination
* Phase 4 - Monitoring Implementation Figure 4-8 provides detail on the Phase 1 and 2 processes.
Phase 1 - Scoping In order to meet the NFPA 805 requirements for monitoring, the following categories of SSCs and programmatic elements will be reviewed during the implementation phase for inclusion in the NFPA 805 monitoring program:
* Structures, Systems, and Components required to comply with NFPA 805, specifically:
o Fire protection systems and features
                     - Required by the Nuclear Safety Capability Assessment
                     - Modeled in the Fire PRA
                     - Required by Chapter 3 of NFPA 805 o Nuclear Safety Capability Assessment equipment4
                     - Nuclear safety equipment
                     - Fire PRA equipment
                     - NPO equipment o SSCs relied upon to meet radioactive release criteria
* Fire Protection Programmatic Elements
* Radioactive Release Engineered Systems and Features 4
For the purpose of the NFPA 805 Monitoring, NSCA equipment is intended to include Nuclear Safety Equipment, Fire PRA equipment, and NPO equipment.
PINGP                                                                            Page 44 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Phase 2 - Screening Using Risk Criteria The equipment from Phase 1 scoping will be screened to determine the appropriate level of NFPA 805 monitoring. As a minimum, the SSCs identified in Phase 1 should be part of an inspection and test program and a system/program health program. If not in the current program, the SSCs will be added in order to assure that the criteria can be met reliably.
The following screening process will be used to determine those SSCs that may require additional monitoring beyond normal surveillance activities.
: 1. Fire Protection Systems and Features Those fire protection systems and features identified in Phase 1 would be candidates for additional monitoring in the NFPA 805 program commensurate with risk significance.
Risk significance may be accomplished at the component, programmatic element, and/or functional level. Since risk is evaluated at the compartment level or fire area level, criteria must be developed to determine those analysis units for which the fire protection SSCs contained within the area are considered risk significant. Screening compartments and fire areas will also include considerations for design/operation/
maintenance limitations. For instance, fire detection should not subdivide systems beyond the system/train/channel level used in normal operation/maintenance.
The Fire PRA is the primary tool used to establish the risk significance criteria and performance bounding guidelines. The screening thresholds used to determine risk significant analysis units are those that meet the following criteria:
Risk Achievement Worth (RAW) of the monitored parameter  2.0 (AND) either Core Damage Frequency (CDF) x (RAW)  1.0E-7 per year (OR)
Large Early Release Frequency (LERF) x (RAW)  1.0E-8 per year CDF, LERF, and RAW (monitored parameter) are calculated for each fire area. The monitored parameter will be established by licensee at a level commensurate with the amenability of the parameter to risk measurement (e.g., a fire barrier may be more conducive to risk measurement than an individual barrier penetration). If compartments are used that are smaller than fire areas, sufficient basis will be documented.
The monitoring program will include the appropriate fire protection program SSCs based on the criteria above. Additional fire protection program SSCs may also be screened in based on plant-specific considerations.
: 2. Nuclear Safety Capability Assessment Equipment NSCA equipment may already be appropriately monitored by the Maintenance Rule. A comparison of NSCA equipment to the SSCs that are monitored in the Maintenance Rule program will be performed to determine what equipment may require additional NFPA 805 Monitoring. For NSCAs SSCs not monitored by the Maintenance Rule, the PINGP                                                                     Page 45 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements basis for inclusion or exclusion of the SSCs in the NFPA 805 monitoring program will be documented, and the process used to make this determination will be fully described.
The Fire PRA will be used to identify high-safety-significant (HSS) NSCA SSCs that require monitoring. The Maintenance Rule guidelines differentiating HSS from low-safety-significant (LSS) SSCs will be used. High-safety-significant NSCA SSCs not currently monitored in Maintenance Rule will be included in the PINGP Maintenance Rule program. Revisions to PINGP Procedure FP-E-MR-01, Maintenance Rule Process, will be completed as an Implementation Item described in Attachment S, Table S-3. All NSCA SSCs that are not HSS should be considered LSS and need not be included in the monitoring program.
For fires originating during non-power operational modes, the qualitative use of fire prevention to manage fire risk during Higher Risk Evolutions does not lend itself to quantitative risk measurement. Therefore, fire risk management effectiveness is monitored programmatically similar to combustible material controls and other fire prevention programs. Additional monitoring beyond inspection and test programs and system/program health programs is not considered necessary.
: 3. SSCs Relied upon for Radioactive Release Criteria The evaluations performed to meet the radioactive release performance criteria are qualitative in nature. The SSCs relied upon to meet the radioactive release performance criteria are not amenable to quantitative risk measurement. Additionally, since 10 CFR Part 20 limits (which are lower than releases due to core damage and containment breach) for radiological effluents are not being exceeded, equipment relied upon to meet the radioactive release performance criteria is considered inherently low risk. Therefore, additional monitoring beyond inspection and test programs and system/program health programs is not considered necessary.
: 4. Monitoring of Fire Protection Programmatic Elements Monitoring of programmatic elements is required in order to assess the performance of the fire protection program in meeting the performance criteria. Programmatic aspects include:
* Transient Combustible Control; Transient Exclusion Zones
* Hot Work Control; Administrative Controls
* Fire Watch Programs; Program compliance and effectiveness
* Fire Brigade Effectiveness Fire protection health reports, self-assessments, regulator and insurance company reports provide inputs to the monitoring program. The monitoring of programmatic elements and program effectiveness will be performed as part of the management of engineering programs. This monitoring is more qualitative in nature since the programs do not lend themselves to the numerical methods of reliability and availability. These programs form the bases for many of the analytical assumptions used to evaluate compliance with NFPA 805 requirements.
PINGP                                                                    Page 46 - Revision 1

Northern States Power - Minnesota                    4.0 Compliance with NFPA 805 Requirements Phase 3 - Risk Target Value Determination Phase 3 consists of using the Fire PRA, or other processes as appropriate, to determine target values of reliability and availability for the HSS fire protection/NSCA SSCs and programmatic elements established in Phase 2 as requiring additional monitoring beyond inspection and test programs, and system/program health programs.
Failure criteria are established by an expert panel or evaluation based on the required fire protection and nuclear safety capability SSCs and programmatic elements assumed level of performance in the supporting analyses. Action levels are established for the SSCs at the component level, program level, or functionally through the use of the pseudo system or performance monitoring group concept. An action level will be developed for the NSCA SSCs that are included in a monitoring program.
Since the HSS SSCs have been identified using the Maintenance Rule guidelines, the associated SSC specific performance criteria will be established as in the Maintenance Rule, provided the criteria are consistent with Fire PRA assumptions. The actual action level is determined based on the number of component, program or functional failures within a sufficiently bounding time period (~2-3 operating cycles). Adverse trends and unacceptable levels of availability, reliability, and performance will be reviewed against established action levels. The Monitoring Program failure criteria and action level targets will be documented.
Phase 4 - Monitoring Implementation Phase 4 is the implementation of the monitoring program, once the monitoring scope and criteria are established. Monitoring consists of periodically gathering, trending, and evaluating information pertinent to the performance, and/or availability of the SSCs and comparing the results with the established goals and performance criteria to verify that the goals are being met. Results of monitoring activities will be analyzed in a timely manner to assure that appropriate action is taken. The corrective action process will be used to address performance of fire protection and nuclear safety SSCs that do not meet performance criteria.
For fire protection and NSCA SSCs that are monitored, unacceptable levels of availability, reliability, and performance will be reviewed against the established action levels. If an action level is triggered, corrective action will be initiated to identify the negative trend. A corrective action plan will then be developed using the appropriate licensee process. Once the plan has been implemented, improved performance should return the SSC back to below the established action level.
A periodic assessment will be performed (e.g., at a frequency of approximately every two to three operating cycles), taking into account, where practical, industry wide operating experience. This will be conducted as part of other established assessment activities. Issues that will be addressed include:
* Review systems with performance criteria. Do performance criteria still effectively monitor the functions of the system? Do the criteria still monitor the effectiveness of the fire protection and nuclear safety capability assessment systems?
PINGP                                                                        Page 47 - Revision 1

Northern States Power - Minnesota                                               4.0 Compliance with NFPA 805 Requirements
* Have the supporting analyses been revised such that the performance criteria are no longer applicable or new fire protection and nuclear safety capability assessment SSCs, programmatic elements and/ or functions need to be in scope?
* Based on the performance during the assessment period, are there any trends in system performance that should be addressed that are not being addressed?
Phase 1 - Scoping                                                                  NSCA Fire Protection     Rad Release Fire Protection Systems Programmatic    Engineered Systems         NPO Components    NSEL Components          FPRA Components and Features Elements         and Features Phase 2 - Screening Function currently in Maintenance Rule?
No Component currently No in FPRA?
High Safety                                                                                              Yes Significance of feature by compartment?
High Risk           Yes Significance?
Yes Yes Include in Maintenance Rule?
No No Yes NFPA 805 Specific                               Normal System &
Monitoring Process                               Program Health Establish targets for                          Monitoring Process or                                 Use Maintenance Rule reliability/unavailability in                         Outage Risk                                           for Monitoring Phase 3                                 Management for NPO
                                                              *Fully describe process used*
No Figure 4 NFPA 805 Monitoring - Scoping and Screening PINGP                                                                                                          Page 48 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements 4.7      Program Documentation, Configuration Control, and Quality Assurance 4.7.1 Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805 In accordance with the requirements and guidance in NFPA 805 Section 2.7.1 and NEI 04-02, PINGP has documented analyses to support compliance with 10 CFR 50.48(c). The analyses are performed in accordance with NSPMs processes for ensuring assumptions are clearly defined, that results are easily understood, that results are clearly and consistently described, and that sufficient detail is provided to allow future review of the entire analyses.
Analyses, as defined by NFPA 805 Section 2.4, performed to demonstrate compliance with 10 CFR 50.48(c) will be maintained for the life of the plant and organized to facilitate review for accuracy and adequacy. Note these analyses do not include items such as periodic tests, hot work permits, fire impairments, etc.
The Fire Protection Design Basis Document described in Section 2.7.1.2 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation. Appropriate cross references will be established to supporting documents as required by NSPM processes. Figure 4-9 depicts the planned post-transition documentation and relationships.
PINGP                                                                    Page 49 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Figure 4 NFPA 805 Planned Post-Transition Documents and Relationships PINGP                                                                     Page 50 - Revision 1

Northern States Power - Minnesota                     4.0 Compliance with NFPA 805 Requirements 4.7.2 Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805 Program documentation established, revised, or utilized in support of compliance with 10 CFR 50.48(c) is subject to NSPM configuration control processes that meet the requirements of Section 2.7.2 of NFPA 805. This includes the appropriate procedures and configuration control processes for ensuring that changes impacting the fire protection program are reviewed appropriately. The RI-PB post transition change process methodology is based upon the requirements of NFPA 805, industry guidance in NEI 04-02, and RG 1.205. These requirements are summarized in Table 4-2.
Table 4-2 Change Evaluation Guidance Summary Table Document                      Section(s)                             Topic NFPA 805           2.2(h), 2.2.9, 2.4.4, A.2.2(h),            Change Evaluation A.2.4.4, D.5 NEI 04-02          5.3, Appendix B, Appendix I,          Change Evaluation, Change Appendix J                  Evaluation Forms (Appendix I)
RG 1.205            C.2.2.4, C.3.1, C.3.2, C.4.3      Risk Evaluation, Standard License Condition, Change Evaluation Process, Fire PRA The Plant Change Evaluation Process consists of the following 4 steps and is depicted in Figure 4-10:
* Defining the Change
* Performing the Preliminary Risk Screening
* Performing the Risk Evaluation
* Evaluating the Acceptance Criteria Change Definition The Change Evaluation process begins by defining the change or altered condition to be examined and the baseline configuration as defined by the Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
: 1. The baseline is defined as that plant condition or configuration that is consistent with the Design Basis and Licensing Basis (NFPA 805 Licensing Basis post-transition).
: 2. The changed or altered condition or configuration that is not consistent with the Design Basis and Licensing Basis is defined as the proposed alternative.
Preliminary Risk Review Once the definition of the change is established, a screening is then performed to identify and resolve minor changes to the fire protection program. This screening is consistent with fire protection regulatory review processes in place at nuclear plants under traditional licensing bases. This screening process is modeled after the NEI 02-PINGP                                                                        Page 51 - Revision 1

Northern States Power - Minnesota                   4.0 Compliance with NFPA 805 Requirements 03 process. This process will address most administrative changes (e.g., changes to the combustible control program, organizational changes, etc.).
The characteristics of an acceptable screening process that meets the assessment of the acceptability of risk requirement of Section 2.4.4 of NFPA 805 are:
* The quality of the screen is sufficient to ensure that potentially greater than minimal risk increases receive detailed risk assessments appropriate to the level of risk.
* The screening process must be documented and be available for inspection by the NRC.
* The screening process does not pose undue evaluation or maintenance burden.
If any of the above is not met, proceed to the Risk Evaluation step.
Risk Evaluation The screening is followed by engineering evaluations that may include fire modeling and risk assessment techniques. The results of these evaluations are then compared to the acceptance criteria. Changes that satisfy the acceptance criteria of NFPA 805, Section 2.4.4, and the license condition can be implemented within the framework provided by NFPA 805. Changes that do not satisfy the acceptance criteria cannot be implemented within this framework. The acceptance criteria require that the resultant change in CDF and LERF be consistent with the license condition. The acceptance criteria also include consideration of defense-in-depth and safety margin, which would typically be qualitative in nature.
The risk evaluation involves the application of fire modeling analyses and risk assessment techniques to obtain a measure of the changes in risk associated with the proposed change. In certain circumstances, an initial evaluation in the development of the risk assessment could be a simplified analysis using bounding assumptions provided the use of such assumptions does not unnecessarily challenge the acceptance criteria discussed below.
Acceptability Determination The Change Evaluations are assessed for acceptability using the CDF (change in core damage frequency) and LERF (change in large early release frequency) criteria from the license condition. The proposed changes are also assessed to ensure they are consistent with the defense-in-depth philosophy and that sufficient safety margins were maintained.
PINGP                                                                      Page 52 - Revision 1

Northern States Power - Minnesota                    4.0 Compliance with NFPA 805 Requirements Figure 4-10 Plant Change Evaluation [NEI 04-02 Figure 5-1]
Note references in Figure refer to NEI 04-02 Sections PINGP                                                                       Page 53 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements The PINGP Fire Protection Program configuration is defined by the program documentation. To the greatest extent possible, the existing configuration control processes for modifications, calculations and analyses, and Fire Protection Program License Basis Reviews will be utilized to maintain configuration control of the Fire Protection program documents. The configuration control procedures which govern the various PINGP documents and databases that currently exist will be revised to reflect the new NFPA 805 licensing bases requirements.
Several NFPA 805 document types such as: NSCA Supporting Information, Non-Power Mode NSCA Treatment, etc., generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be modeled after the existing processes for similar types of documents and databases. System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play.
The process for capturing the impact of proposed changes to the plant on the Fire Protection Program will continue to be a multiple step review. The first step of the review is an initial screening for process users to determine if there is a potential to impact the Fire Protection program as defined under NFPA 805 through a series of screening questions/checklists contained in one or more procedures depending upon the configuration control process being used. Reviews that identify potential Fire Protection program impacts will be sent to qualified individuals (Fire Protection, Safe Shutdown/NSCA, Fire PRA) to ascertain the program impacts, if any. If Fire Protection program impacts are determined to exist as a result of the proposed change, the issue would be resolved by one of the following:
* Deterministic Approach: Comply with NFPA 805 Chapter 3 and 4.2.3 requirements.
* Performance-Based Approach: Utilize the NFPA 805 change process developed in accordance with NEI 04-02, RG 1.205, and the PINGP NFPA 805 fire protection license condition to assess the acceptability of the proposed change.
This process would be used to determine if the proposed change could be implemented "as-is" or whether prior NRC approval of the proposed change is required.
This process follows the requirements in NFPA 805 and the guidance outlined in RG 1.174 which requires the use of qualified individuals, procedures that require calculations be subject to independent review and verification, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered.
Plant procedures will be developed (or existing procedures revised, as appropriate) to govern the configuration control processes required by NFPA 805. See Attachment S, Table S-3, for associated implementation actions.
PINGP                                                                     Page 54 - Revision 1

Northern States Power - Minnesota                 4.0 Compliance with NFPA 805 Requirements 4.7.3 Compliance with Quality Requirements in Section 2.7.3 of NFPA 805 Fire Protection Program Quality NSPM will continue to maintain the existing Fire Protection Quality Assurance program.
During the transition to 10 CFR 50.48(c), NSPM performed work in accordance with the quality requirements of Section 2.7.3 of NFPA 805.
Fire PRA Quality Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the internal events PRA model. This process complies with Section 5 of the ASME Standard for PRA Quality and ensures that NSPM maintains an as-built, as-operated PRA model of the plant. The process has been peer reviewed. Quality assurance of the Fire PRA is assured via the same processes applied to the internal events model.
This process follows the guidance outlined in RG 1.174 which requires the use of qualified individuals, procedures that require calculations be subject to independent review, verification, or checking, record retention, peer review, and a corrective action program that ensures appropriate actions are taken when errors are discovered.
Although the entire scope of the formal 10 CFR 50 Appendix B program is not applied to the PRA models or processes in general, often parts of the program are applied as a convenient method of complying with the requirements of RG 1.174. For instance, the procedures which address software control and the corrective action program for the PINGP 10 CFR 50 Appendix B program are applied to the PRA program.
With respect to Quality Assurance Program requirements for independent reviews of calculations and evaluations, those existing requirements for Fire Protection Program documents will remain unchanged. NSPM specifically requires that the calculations and evaluations in support of the NFPA 805 LAR, exclusive of the Fire PRA, be performed within the scope of the QA program which requires independent review as defined by NSPM procedures. As recommended by NUREG/CR-6850, the sources of uncertainty in the Fire PRA were identified and specific parameters were analyzed in support of the NFPA 805 Fire Risk Evaluation process.
Specifically with regard to uncertainty, uncertainty associated with Fire PRA parameters was qualitatively addressed in Fire PRA Uncertainty Analysis Notebook.
While the removal of conservatism inherent in the Fire PRA is a long-term goal, the Fire PRA results were deemed sufficient for evaluating the risk associated with this application. While NSPM continues to strive toward a more "realistic" estimate of fire risk, use of mean values continues to be the best estimate of fire risk. During the Fire Risk Evaluation process, the uncertainty and sensitivity associated with specific Fire PRA parameters were considerations in the evaluation of the change in risk relative to the applicable acceptance thresholds.
PINGP                                                                    Page 55 - Revision 1

Northern States Power - Minnesota                4.0 Compliance with NFPA 805 Requirements Specific Requirements of NFPA 805 Section 2.7.3 NFPA 805 Section 2.7.3.1 - Review Analyses, calculations, and evaluations performed in support of compliance with 10 CFR 50.48(c) are performed in accordance with NSPM procedures that require independent review.
NFPA 805 Section 2.7.3.2 - Verification and Validation Calculational models and numerical methods used in support of compliance with 10 CFR 50.48(c) were verified and validated as required by Section 2.7.3.2 of NFPA 805.
NFPA 805 Section 2.7.3.3 - Limitations of Use Engineering methods and numerical models used in support of compliance with 10 CFR 50.48(c) are used and were used appropriately as required by Section 2.7.3.3 of NFPA 805.
NFPA 805 Section 2.7.3.4 - Qualification of Users Cognizant personnel who use and apply engineering analysis and numerical methods in support of compliance with 10 CFR 50.48(c) are competent and experienced as required by Section 2.7.3.4 of NFPA 805.
For personnel performing fire modeling or Fire PRA development and evaluation, NSPM will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work. These implementation items are identified in Attachment S-3.
NFPA 805 Section 2.7.3.5 - Uncertainty Analysis Uncertainty analyses were performed as required by 2.7.3.5 of NFPA 805 and the results were considered in the context of the application. This is of particular interest in fire modeling and Fire PRA development.
4.8    Summary of Results 4.8.1 Results of the Fire Area Review A summary of the NFPA 805 compliance basis and the required fire protection systems and features is provided in Attachment C, NEI 04-02, Table B-3, Fire Area Review.
The table provides the following information from NEI 04-02, Table B-3:
* Fire Area / Fire Zone: Fire Area/Zone Identifier.

== Description:==
Fire Area/Zone Description.
* NFPA 805 Regulatory Basis: Post-transition NFPA 805 Chapter 4 compliance basis (Note: Compliance is determined on a Fire Area basis therefore a compliance basis is not provided for individual fire zones.)
* Required Fire Protection System / Feature: Detection / suppression required in the Fire Area based on NFPA 805 Chapter 4 compliance. Other Required PINGP                                                                   Page 56 - Revision 1

Northern States Power - Minnesota                  4.0 Compliance with NFPA 805 Requirements Features may include Electrical Raceway Fire Barrier Systems, fire barriers, etc.
The documentation of required fire protection systems and features does not include the documentation of the fire area boundaries. Fire area boundaries are required and documentation of the fire area boundaries has been performed as part of reviews of engineering evaluations, licensing actions, or as part of the reviews of the NEI 04-02 Table B-1 process. The basis for the requirement of the fire protection system / feature is designated as follows:
o S - Separation Criteria:      Systems/Features required for Chapter 4 Separation Criteria in Section 4.2.3.
o E - EEEE Systems/Features required for acceptability of Existing Engineering Equivalency Evaluations (Section 2.2.7).
o L - Licensing Action Criteria - Systems/Features required for acceptability of NRC approved Licensing Action (i.e., Exemptions) (Section 2.2.7).
o R - Risk Criteria: Systems/Features required to meet the Risk Criteria for the Performance-Based Approach (Section 4.2.4).
o D - Defense-in-depth Criteria: Systems/Features required to maintain adequate balance of Defense-in-Depth for a Performance-Based Approach (Section 4.2.4).
Attachment W contains the results of the Fire Risk Evaluations, additional risk of recovery actions, and the change in risk on a fire area basis.
4.8.2 Plant Modifications and Items to be Completed During the Implementation Phase Planned modifications, studies, and evaluations to comply with NFPA 805 are described in Attachment S. These actions were identified in PINGP Engineering Evaluation EC 23430, NFPA 805 LAR Supplement Attachment S, Planned Modifications. Table S-1 identifies plant modifications associated with the transition to NFPA 805 that have been completed. Table S-2 summarizes plant modifications that are committed for implementation. Table S-3 provides a list of those items (e.g., procedure changes, process updates, and training of affected plant personnel) that will be completed prior to the implementation of the new NFPA 805 Fire Protection Program at PINGP.
The Fire PRA model represents the as-built, as-operated and maintained plant as it will be configured at the completion of the transition to NFPA 805. The Fire PRA model includes credit for the planned implementation of the modifications listed in Attachment S. Following completion of the implementation items listed in Attachment S, such as further development of procedure changes and training, additional refinements may need to be incorporated into the Fire PRA based on industry initiatives. No other significant plant changes are outstanding with respect to their inclusion in the Fire PRA model. See Implementation Item in Attachment S, Table S-3.
4.8.3 Supplemental Information -Other Licensee Specific Issues None.
PINGP                                                                     Page 57 - Revision 1

Northern States Power - Minnesota                                   5.0 Regulatory Evaluation

==5.0     REGULATORY EVALUATION==

5.1     Introduction - 10 CFR 50.48 On July 16, 2004 the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative fire protection requirements.
10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b), Appendix R, and Section (f), Decommissioning.
The voluntary adoption of 10 CFR 50.48(c) by PINGP does not eliminate the need to comply with 10 CFR 50.48(a) and 10 CFR 50, Appendix A, GDC 3, Fire Protection. The NRC addressed the overall adequacy of the regulations during the promulgation of 10 CFR 50.48(c) (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086).
NFPA 805 does not supersede the requirements of GDC 3, 10 CFR 50.48(a), or 10 CFR 50.48(f). Those regulatory requirements continue to apply to licensees that adopt NFPA 805. However, under NFPA 805, the means by which GDC 3 or 10 CFR 50.48(a) requirements may be met is different than under 10 CFR 50.48(b). Specifically, whereas GDC 3 refers to SSCs important to safety, NFPA 805 identifies fire protection systems and features required to meet the Chapter 1 performance criteria through the methodology in Chapter 4 of NFPA 805. Also, under NFPA 805, the 10 CFR 50.48(a)(2)(iii) requirement to limit fire damage to SSCs important to safety so that the capability to safely shut down the plant is ensured is satisfied by meeting the performance criteria in Section 1.5.1 of NFPA 805. The Section 1.5.1 criteria include provisions for ensuring that reactivity control, inventory and pressure control, decay heat removal, vital auxiliaries, and process monitoring are achieved and maintained.
This methodology specifies a process to identify the fire protection systems and features required to achieve the nuclear safety performance criteria in Section 1.5 of NFPA 805. Once a determination has been made that a fire protection system or feature is required to achieve the performance criteria of Section 1.5, its design must meet any applicable requirements of NFPA 805, Chapter 3.
Having identified the required fire protection systems and features, the licensee selects either a deterministic or performance-based approach to demonstrate that the performance criteria are satisfied. This process satisfies the GDC 3 requirement to design and locate SSCs important to safety to minimize the probability and effects of fires and explosions. (Reference FR Notice 69 FR 33536 dated June 16, 2004, ML041340086)
The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a), which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, modify the fire protection plan required by paragraph (a) of that section to reflect the licensees decision to comply with NFPA 805. Therefore, to the extent that the PINGP                                                                    Page 58 - Revision 1

Northern States Power - Minnesota                                                     5.0 Regulatory Evaluation contents of the existing fire protection program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the fire protection program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48 (a) and GDC 3 have corresponding requirements in NFPA 805.
A comparison of the current requirements in Appendix R with the comparable requirements in Section 3 of NFPA 805 shows that the two sets of requirements are consistent in many respects. This was further clarified in FAQ 07-0032, 10 CFR 50.48(a) and GDC 3 clarification (ML081400292). The following tables provide a cross reference of fire protection regulations associated with the post-transition PINGP fire protection program and applicable industry and PINGP documents that address the topic.
10 CFR 50.48(a)
Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s)                         Applicability/Compliance Reference (1) Each holder of an operating license issued under this      See below part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part. This fire protection plan must:
(i) Describe the overall fire protection program for the   NFPA 805 Section 3.2 facility;                                                  NEI 04-02 Table B-1 (ii) Identify the various positions within the licensee's  NFPA 805 Section 3.2.2 organization that are responsible for the program;         NEI 04-02 Table B-1 (iii) State the authorities that are delegated to each of  NFPA 805 Section 3.2.2 these positions to implement those responsibilities; and   NEI 04-02 Table B-1 (iv) Outline the plans for fire protection, fire detection NFPA 805 Section 2.7 and Chapters 3 and 4 and suppression capability, and limitation of fire         NEI 04-02 B-1 and B-3 Tables damage.
(2) The plan must also describe specific features              See below necessary to implement the program described in paragraph (a)(1) of this section such as:
(i) Administrative controls and personnel requirements     NFPA 805 Sections 3.3.1 and 3.4 for fire prevention and manual fire suppression            NEI 04-02 Table B-1 activities; (ii) Automatic and manually operated fire detection and    NFPA 805 Sections 3.5 through 3.10 and suppression systems; and                                   Chapter 4 NEI 04-02 B-1 and B-3 Tables (iii) The means to limit fire damage to structures,        NFPA 805 Section 3.3 and Chapter 4 systems, or components important to safety so that the     NEI 04-02 B-3 Table capability to shut down the plant safely is ensured.
(3) The licensee shall retain the fire protection plan and     NFPA 805 Section 2.7.1.1 requires that each change to the plan as a record until the              documentation (Analyses, as defined by NFPA 805 Commission terminates the reactor license. The             2.4, performed to demonstrate compliance with this licensee shall retain each superseded revision of the      standard) be maintained for the life of the plant.
procedures for 3 years from the date it was                NSPM, Records Management procedure (FG-superseded.                                                NP-RM-10) and Records Retention Schedule (RM-0044).
PINGP                                                                                      Page 59 - Revision 1

Northern States Power - Minnesota                                                       5.0 Regulatory Evaluation Table 5-1 10 CFR 50.48(a) - Applicability/Compliance Reference 10 CFR 50.48(a) Section(s)                           Applicability/Compliance Reference (4) Each applicant for a design approval, design                 Not applicable. PINGP is licensed under certification, or manufacturing license under part 52 of    10 CFR 50.
this chapter must have a description and analysis of the fire protection design features for the standard plant necessary to demonstrate compliance with Criterion 3 of appendix A to this part.
General Design Criterion 3 The PINGP fire protection system was originally designed and constructed in accordance with General Design Criteria 3 as proposed by the Atomic Energy Commission (AEC) and as published in the Federal Register on July 11, 1967. AEC GDC 3 states the following:
The reactor facility shall be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potential effects of such events to safety. Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room, and components of engineered safety features.
Since the construction of the plant was significantly completed prior to the issuance of the February 20, 1971, 10 CFR 50, Appendix A General Design Criteria, the plant was not reanalyzed and the FSAR was not revised to reflect these later criteria. However, the AEC Safety Evaluation Report acknowledged that the AEC staff assessed the plant, as described in the FSAR, against the Appendix A design criteria and ... are satisfied that the plant design generally conforms to the intent of these criteria.
When 10 CFR 50.48 became effective, the NRCs basic criterion for fire protection as set forth in GDC 3, Appendix A to 10 CFR 50 became applicable to PINGP on October 29, 1980. The applicability of GDC 3 in 10 CFR 50 Appendix A to the PINGP NFPA 805 fire protection program is addressed as follows:
Table 5-2 GDC 3 - Applicability/Compliance Reference GDC 3, Fire Protection, Statement                         Applicability/Compliance Reference Structures, systems, and components important to             NFPA 805 Chapters 3 and 4 safety shall be designed and located to minimize,            NEI 04-02 B-1 and B-3 Tables consistent with other safety requirements, the probability and effect of fires and explosions.
Noncombustible and heat resistant materials shall be         NFPA 805 Sections 3.3.2, 3.3.3, 3.3.4, 3.11.4 used wherever practical throughout the unit,                 NEI 04-02 B-1 Table particularly in locations such as the containment and control room.
PINGP                                                                                          Page 60 - Revision 1

Northern States Power - Minnesota                                                   5.0 Regulatory Evaluation Table 5-2 GDC 3 - Applicability/Compliance Reference GDC 3, Fire Protection, Statement                      Applicability/Compliance Reference Fire detection and fighting systems of appropriate        NFPA 805 Chapters 3 and 4 capacity and capability shall be provided and designed    NEI 04-02 B-1 and B-3 Tables to minimize the adverse effects of fires on structures, systems, and components important to safety.
Firefighting systems shall be designed to assure that     NFPA 805 Sections 3.4 through 3.10 and 4.2.1 their rupture or inadvertent operation does not           NEI 04-02 Table B-3 significantly impair the safety capability of these structures, systems, and components PINGP                                                                                    Page 61 - Revision 1

Northern States Power - Minnesota                                                      5.0 Regulatory Evaluation 10 CFR 50.48(c)
Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                                 Applicability/Compliance Reference (1) Approval of incorporation by reference. National Fire Protection Association     General Information. NFPA (NFPA) Standard 805, Performance-Based Standard for Fire Protection for         805 (2001 edition) is the Light Water Reactor Electric Generating Plants, 2001 Edition (NFPA 805),        edition used.
which is referenced in this section, was approved for incorporation by reference by the Director of the Federal Register pursuant to 5 U.S.C. 552(a) and 1 CFR part 51.
(2) Exceptions, modifications, and supplementation of NFPA 805. As used in           General Information. NFPA this section, references to NFPA 805 are to the 2001 Edition, with the           805 (2001 edition) is the following exceptions, modifications, and supplementation:                        edition used.
(i) Life Safety Goal, Objectives, and Criteria. The Life Safety Goal,            The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed.                          Objectives, and Criteria of Chapter 1 of NFPA 805 are not part of the LAR.
(ii) Plant Damage/Business Interruption Goal, Objectives, and Criteria. The      The Plant Damage/Business Plant Damage/Business Interruption Goal, Objectives, and Criteria of             Interruption Goal, Objectives, Chapter 1 are not endorsed.                                                      and Criteria of Chapter 1 of NFPA 805 are not part of the LAR.
(iii) Use of feed-and-bleed. In demonstrating compliance with the                Feed and bleed is not utilized performance criteria of Sections 1.5.1(b) and (c), a high-pressure               as the sole fire-protected safe charging/injection pump coupled with the pressurizer power-operated relief       shutdown methodology.
valves (PORVs) as the sole fire-protected safe shutdown path for maintaining reactor coolant inventory, pressure control, and decay heat removal capability (i.e., feed-and-bleed) for pressurized-water reactors (PWRs) is not permitted.
(iv) Uncertainty analysis. An uncertainty analysis performed in accordance       Uncertainty analysis was not with Section 2.7.3.5 is not required to support deterministic approach           performed for deterministic calculations.                                                                    methodology.
(v) Existing cables. In lieu of installing cables meeting flame propagation      Electrical cable construction tests as required by Section 3.3.5.3, a flame-retardant coating may be           complies with a flame applied to the electric cables, or an automatic fixed fire suppression system    propagation test that was may be installed to provide an equivalent level of protection. In addition, the  found acceptable to the NRC italicized exception to Section 3.3.5.3 is not endorsed.                         as documented in NEI 04-02 Table B-1.
(vi) Water supply and distribution. The italicized exception to Section 3.6.4 is PINGP complies by previous not endorsed. Licensees who wish to use the exception to Section 3.6.4           approval as documented in must submit a request for a license amendment in accordance with                 Attachment A, Table B-1.
paragraph (c)(2)(vii) of this section.
PINGP                                                                                         Page 62 - Revision 1

Northern States Power - Minnesota                                                       5.0 Regulatory Evaluation Table 5-3 10 CFR 50.48(c) - Applicability/Compliance Reference 10 CFR 50.48(c) Section(s)                                 Applicability/Compliance Reference (vii) Performance-based methods. Notwithstanding the prohibition in Section       The use of performance-3.1 against the use of performance-based methods, the fire protection             based methods for NFPA 805 program elements and minimum design requirements of Chapter 3 may be              Chapter 3 is requested. See subject to the performance-based methods permitted elsewhere in the               Attachment L.
standard. Licensees who wish to use performance-based methods for these fire protection program elements and minimum design requirements shall submit a request in the form of an application for license amendment under &sect; 50.90. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
(3) Compliance with NFPA 805.                                                         See below (i) A licensee may maintain a fire protection program that complies with          The LAR was submitted in NFPA 805 as an alternative to complying with paragraph (b) of this section        accordance with for plants licensed to operate before January 1, 1979, or the fire protection     10 CFR 50.90. The LAR license conditions for plants licensed to operate after January 1, 1979. The      included applicable license licensee shall submit a request to comply with NFPA 805 in the form of an         conditions, orders, technical application for license amendment under &sect; 50.90. The application must             specifications/bases that identify any orders and license conditions that must be revised or                needed to be revised and/or superseded, and contain any necessary revisions to the plants technical          superseded.
specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.
(ii) The licensee shall complete its implementation of the methodology in         The LAR and transition report Chapter 2 of NFPA 805 (including all required evaluations and analyses)           summarize the evaluations and, upon completion, modify the fire protection plan required by paragraph       and analyses performed in (a) of this section to reflect the licensees decision to comply with NFPA 805,   accordance with Chapter 2 of before changing its fire protection program or nuclear power plant as             NFPA 805.
permitted by NFPA 805.
(4) Risk-informed or performance-based alternatives to compliance with NFPA           No risk-informed or 805. A licensee may submit a request to use risk-informed or performance-         performance-based based alternatives to compliance with NFPA 805. The request must be in            alternatives to compliance the form of an application for license amendment under &sect; 50.90 of this            with NFPA 805 (per chapter. The Director of the Office of Nuclear Reactor Regulation, or             10 CFR 50.48(c)(4)) were designee of the Director, may approve the application if the Director or          utilized. See Attachment P.
designee determines that the proposed alternatives:
(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
PINGP                                                                                          Page 63 - Revision 1

Northern States Power - Minnesota                                    5.0 Regulatory Evaluation 5.2    Regulatory Topics 5.2.1 License Condition Changes The current PINGP fire protection license condition 2.C.(4) is being replaced with the standard license condition based upon Regulatory Position 3.1 of RG 1.205, modified as shown in Attachment M.
5.2.2 Technical Specifications NSPM conducted a review of the Technical Specifications to determine which Technical Specifications are required to be revised, deleted, or superseded. NSPM determined that the changes to the Technical Specifications and applicable justification listed in Attachment N are adequate for the PINGP adoption of the new fire protection licensing basis.
5.2.3 Orders and Exemptions A review was conducted of the PINGP docketed correspondence to determine if there were any orders or exemptions that needed to be superseded or revised. A review was also performed to ensure that compliance with the physical protection requirements, security orders, and adherence to those commitments applicable to the plant are maintained. A discussion of affected orders and exemptions is included in Attachment O.
5.3    Regulatory Evaluations 5.3.1 No Significant Hazards Consideration A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
* Involve a significant increase in the probability or consequences of an accident previously evaluated; or
* Create the possibility of a new or different kind of accident from any accident previously evaluated; or
* Involve a significant reduction in a margin of safety.
This evaluation is contained in Attachment Q.
Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. NSPM has evaluated the proposed amendment and determined that it involves no significant hazards consideration.
5.3.2 Environmental Consideration Pursuant to 10 CFR 51.22(b), an evaluation of the LAR has been performed to determine whether it meets the criteria for categorical exclusion set forth in 10 CFR PINGP                                                                     Page 64 - Revision 1

Northern States Power - Minnesota                                    5.0 Regulatory Evaluation 51.22(c). That evaluation is discussed in Attachment R. The evaluation confirms that this LAR meets the criteria set forth in 10 CFR 51.22(c)(9) for categorical exclusion from the need for an environmental impact assessment or statement.
5.4     Revision to USAR After the approval of the LAR, the PINGP Updated Safety Analysis Report (USAR) will be revised in accordance with 10 CFR 50.71(e) except as follows. The revised USAR will be submitted in accordance with an exemption from 10 CFR 50.71(e)(4) dated May 22, 2006, which allows periodic updates of the PINGP USAR to be submitted within 6 months after the completion of each Unit 2 refueling outage, not to exceed 24 months from the previous submittal. The format and content will be consistent with FAQ 12-0062.
5.5     Transition Implementation Schedule The following schedule for transitioning PINGP to the new fire protection licensing basis requires NRC approval of the LAR in accordance with the following schedule:
* Implementation of new NFPA 805 fire protection program will include procedure changes, process updates, and training of affected plant personnel.
Implementation will occur within the later of six months after NRC approval, or six months after a refueling outage if in progress at the time of approval. See Attachment S, Table S-3. Note that Implementation Item 20 in Attachment S, Table S-3, is associated with modifications described in Table S-2 and will be completed 180 days after modifications are complete.
* Attachment S, Table S-2, provides a listing of modifications associated with the transition to NFPA 805. NSPM will complete implementation of these modifications at PINGP before the end of the second full operating cycle for each unit after approval of the LAR. Appropriate compensatory measures will be maintained until modifications are complete.
PINGP                                                                     Page 65 - Revision 1

Northern States Power - Minnesota                                             6.0 References

==6.0    REFERENCES==

The following references were used in the development of the TR. Additional references are in the NEI 04-02 Tables in the various Attachments.
6.1    NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition.
6.2    10 CFR 50.48, Fire Protection.
(a) Fire Protection Plans.
(b) Appendix R.
(c) National Fire Protection Association Standard NFPA 805.
(f) Decommissioning.
6.3    Federal Register Notice 69 FR 33536, June 16, 2004 (ADAMS Accession Number ML041340086).
6.4    10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants.
6.5    10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
6.6    10 CFR 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.
6.7    10 CFR 20, Standards for Protection Against Radiation.
6.8    10 CFR 50.71, Maintenance of Records, Making of Reports.
6.9    10 CFR 50.82, Termination of License.
6.10   10 CFR 50.92, Issuance of Amendment.
6.11   10 CFR 51.22, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review.
6.12   NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 2, April 2008.
6.13   NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Revision 1, January 2005.
6.14   NEI 02-03, Guidance for Performing a Regulatory Review of Proposed Changes to the Approved Fire Protection Program, Revision 1, June 2004.
6.15   Branch Technical Position (BTP), Auxiliary Power Conversion Systems Branch (APSCB) 9.5-1, Fire protection.
6.16   SECY 11-0061, A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(C) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48), June 10, 2011.
PINGP                                                                    Page 66 - Revision 1

Northern States Power - Minnesota                                           6.0 References 6.17   Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis.
6.18   Regulatory Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities.
6.19   Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants, Revision 1.
6.20   NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities.
6.21   Renewed Operating License, Prairie Island Nuclear Generating Plant, Unit 1, DPR-42, Docket No.50-282.
6.22   Renewed Operating License, Prairie Island Nuclear Generating Plant, Unit 2, DPR-60, Docket No. 50-306.
6.23   Letter from M.A. Schimmel (NSPM) to NRC Document Control Desk, Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request, June 22, 2011, ADAMS Accession Number ML111740866.
6.24   Letter from J.G. Giitter (NRC) to M.A. Schimmel (NSPM), Commitment to Submit a License Amendment Request to Transition to 10 CFR 50.48(c),
National Fire Protection Association Standard NFPA 805, and Request to Extend Enforcement Discretion - Prairie Island Nuclear Generating Plant, Units 1 and 2 (TAC Nos. ME6675 and ME6676), July 29, 2011, ADAMS Accession Number ML112010417.
6.25   Letter from D. Malone (NMC) to NRC Document Control Desk, Letter of Intent to Transition to 10 CFR 50.48(c) - National Fire Protection Association Standard NFPA 805, Performance-based Standards for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, November 30, 2005.
6.26   Letter from C. Haney (NRC) to M. Redderman (NMC),Letter of Intent to Adopt Title 10 of the Code of Federal Regulations, Part 50.48(c) for Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant, Units 1 &
2, and Prairie Island Nuclear generating Plant, Units 1 and 2 (TAC Nos. MC9289 through MC9294), September 7, 2006.
6.27   Letter from D.K. Davis (NRC) to L.O. Mayer (NSP), Issuance of License Amendment Nos. 26 (Unit 1) and 20 (Unit 2), Fire Protection Technical Specifications, February 14, 1978.
6.28   Letter from A Schwencer (NRC) to L.O. Mayer (NSP), Issuance of License Amendment Nos. 39 (DPR-42, Unit 1) and 33 (DPR-60, Unit 2), and related Fire Protection Safety Evaluation Report, dated September 6, 1979.
6.29   Letter from A. Schwencer (NRC) to L.O. Mayer (NSPM), Approval of Fire Protection Modifications, April 21, 1980.
6.30   Letter, from R.A. Clark (NRC) to L.O. Mayer (NSP), Approval of Fire Protection Modifications, December 29, 1980.
PINGP                                                                  Page 67 - Revision 1

Northern States Power - Minnesota                                           6.0 References 6.31   Letter from R.A. Clark (NRC) to L.O. Mayer (NSP), Issuance of License Amendment Nos. 49 (DPR-42, Unit 1) and 43 (DPR-60, Unit 2), and related Safety Evaluation, July 28, 1981.
6.32   Letter from D.C. Dilanni (NRC) to T.M. Parker (NSP), Amendments Nos. 91 and 84 to Facility Operating Licenses Nos. DPR-42 [Unit 1] and DPR-60 [Unit 2]:
Technical Specification (TS) Upgrade (TAC Nos. 61081 and 61082), October 27, 1989.
6.33   Letter from B.A. Wetzel (NRC) to R.O. Anderson (NSP), Issuance of Amendments [No. 120, Unit 1, and No. 113, Unit 2] Re: Fire Protection and Detection Systems - Limiting Conditions for Operation (TAC Nos. M89962 and M89963), October 6, 1995.
6.34   Letter from L. Mayer (MSP) to V. Stello (NRC), Fire Hazard Analysis Report, March 11, 1977.
6.35   Letter from L. Mayer (NSP) to V. Stello (NRC), Completion of Fire Protection Review, July 5, 1977.
6.36   Letter from L. Mayer (NSP) to Director of NRR, Nuclear Plant Fire Protection Functional Responsibilities, Administrative controls, and Quality Assurance, May 18, 1978.
6.37   Letter from L. Mayer (NSP) to Director of NRR, Nuclear Plant Fire Brigade Requirements, June 22, 1978.
6.38   Letter from L. Mayer (NSP) to Director of NRR, NRC Staff Evaluation of Fire Protection Program, January 2, 1979.
6.39   Letter from L. Mayer (NSP) to Director of NRR, NRC Staff Evaluation of Fire Protection Program, March 9, 1979.
6.40   Letter from L. Mayer (NSP) to Director of NRR, NRC Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance, May 2, 1979.
6.41   Letter from, R.A. Clark (NRC) to D.M. Musolf (NSP), Fire Protection - Request for Exemption from a Requirement of Appendix R to 10 CFR Part 50, Section III. G, February 2, 1983.
6.42   Letter from R.A. Clark (NRC) to D.M. Musolf (NSP), Exemption from Appendix R Subsection III.G.2 for Lack of Separation Between Redundant Safe Shutdown Equipment, Fire Area 31, May 4, 1983.
6.43   Letter from J.R. Miller (NRC) to D.M. Musolf (NSP), Exemption from Appendix R Subsection III.G.2 for Lack of Automatic Fire Suppression System, Unit 1, Fire Area 59, January 9, 1984.
6.44   Letter from J.R. Miller (NRC) to D.M. Musolf (NSP), Exemption from Appendix R Subsection III.G.2 for Lack of Separation Between Redundant Safe Shutdown Equipment, and Subsection III.O for Lube Oil Collection Piping, Fire Areas 1 and 71, July 31, 1984.
PINGP                                                                  Page 68 - Revision 1

Northern States Power - Minnesota                                           6.0 References 6.45   Letter from J.R. Miller (NRC) to D.M. Musolf (NSP), Issuance of Exemption Re:
Certain Technical Requirements of Appendix R to 10 CFR Part 50 (TAC Nos.
M89461 and M89462), February 21, 1995.
6.46   Letter from S. Weerakkody (NRC) to A. Marion (NEI), Process for Frequently Asked Questions for Title 10 of the Code of Federal Regulations, Part 50.48(c)
Transitions, July 12, 2006 (ADAMS Accession No. ML061660105).
6.47   Regulatory Issues Summary (RIS) 2007-19, Process for Communicating Clarifications of Staff Positions Provided in RG 1.205 Concerning Issues Identified during the Pilot Application of NFPA Standard 805, August 20, 2007 (ADAMS Accession Number ML071590227).
6.48   PINGP Engineering Evaluation EC 23309, NFPA 805 LAR Supplement Attachment A (Table B-1). [Fundamental Fire Protection Program and Design Elements Review].
6.49   PINGP Engineering Evaluation EC 23946, NFPA 805 LAR Supplement Attachment I - Power Block Definition.
6.50   PINGP Engineering Evaluation EC 23430, NFPA 805 LAR Supplement Attachment S, Planned Modifications.
6.51   PINGP Engineering Evaluation EC 23734, NFPA 805 LAR Supplement Attachment E.[Radioactive Release].
6.52   PINGP Engineering Evaluation EC 23310, NFPA 805 LAR Supplement Attachment B (Table B-2). [Nuclear Safety Capability Assessment (NSCA)
Methodology Review].
6.53   PINGP Engineering Evaluation EC 23507, NFPA 805 LAR Supplement Attachment D. [Non-Power Operation].
6.54   PINGP Engineering Evaluation EC 23313, NFPA 805 LAR Supplement Attachment G. [Recovery Actions].
6.55   PINGP Engineering Evaluation EC 20386, NFPA 805 Existing Engineering Equivalency Evaluation Review Report.
6.56   PINGP Engineering Evaluation EC 20736, Reactivity Control.
6.57   PINGP Engineering Evaluation EC 20738, Decay Heat Removal.
6.58   PINGP Procedure C12.5, Boron Concentration Control.
6.59   PINGP Procedure 1(2) E-1, Loss of Reactor or Secondary Coolant.
6.60   PINGP Procedure C28.1, AOP2, Loss of Condensate Supply to Auxiliary Feedwater System.
6.61   PINGP Procedure H24, Maintenance Rule Program.
6.62   NSPM Procedure FG-NP-RM-10, Records Management.
6.63   NSPM Procedure RM-0044, Records Retention Schedule.
PINGP                                                                 Page 69 - Revision 1

Northern States Power - Minnesota                                           6.0 References 6.64   PINGP Fire PRA Uncertainty Notebook, FPRA-PI-UNC.
6.65   PINGP Fire PRA Quantification Notebook, FPRA-PI-FQ.
6.66   PRA Standard, ASME/ANS RA-Sa-2009, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Application.
6.67   PRA Standard, ASME RA-S-2002.
6.68   PRA Standard, ASME RA-Sa-2003.
6.69   PRA Standard, ASME RA-Sb-2005, Addenda.
6.70   NUREG/CR-6850/EPRI TR-1011989.
6.71   NUREG/CR-6850/EPRI TR-1019259, Supplement 1.
6.72   WCAP 16341, Westinghouse Owners Group Simplified Level 2 Analysis Approach.
6.73   NUREG-1921, EPRI/NRC-RES Fire Human Reliability Analysis Guidelines, Draft report (final report was published July 2012, after the FPRA Peer Review in June 2012).
6.74   Fire PRA Peer Review of the PINGP Fire Probabilistic Risk Assessment Against the Fire PRA Standard Supporting Requirements from Section 4 of the ASME/ANS Standard, June 2012, attachment to Westinghouse letter to Xcel Energy, LTR-RAM-12-07.
6.75   NRC letter, Point Beach Nuclear Plant, Units 1 and 2, and Prairie Island Nuclear Generating Plant, Units 1 and 2 - Exemption to 10 CFR 50.71(e)(4) (TAC Nos.
MC8654, MC8655, MC8656, and MC8657), dated May 22, 2006 (ADAMS Accession Number ML061110032).
6.76   Letter from J.P. Sorensen (NSPM) to Document Control Desk (NRC), License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-12-089, September 28, 2012 (ADAMS Accession Number ML12278A405).
6.77   Letter from J.E. Lynch (NSPM) to Document Control Desk (NRC), Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Submittal of Internal Flooding Peer Review Final Results and Revised Total Plant Risk Values, L-PI-12-102, November 8, 2012 (ADAMS Accession Number ML12314A144).
6.78   Letter from J.E. Lynch (NSPM) to Document Control Desk (NRC), Supplement to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Acceptance Review Questions (TAC Nos. ME9734 and ME9735), L-PI-12-117, December 18, 2012 (ADAMS Accession No. ML12354A464).
6.79   Letter from T.J. Wengert (NRC) to J.E. Lynch (NSPM), Prairie Island Nuclear Generating Plant, Units 1 and 2 - Acceptance for Review of License Amendment Request for National Fire Protection Association Standard NFPA 805 (TAC Nos.
PINGP                                                                 Page 70 - Revision 1

Northern States Power - Minnesota                                         6.0 References ME9734 and ME9735), January 2, 2013 (ADAMS Accession No. ML13002A209).
6.80   Letter from J.E. Lynch (NSPM) to Document Control Desk (NRC), Commitment to Submit a Supplement to the PINGP NFPA 805 License Amendment Request (TAC Nos. ME9734 and ME9735), L-PI-13-044, May 3, 2013 (ADAMS Accession No. ML13126A115).
6.81   Focused-Scope Fire PRA Peer Review For The Prairie Island Nuclear Generating Plant, February 2014, attached to Westinghouse letter LTR-RAM-II-13-117.
6.82   PINGP Engineering Evaluation EC 20819, Technical Evaluation Associated with Open Circuiting of Current Transformers Contained in 13.8 kV, 4.16 kV, and 480 V Switchgear.
6.83   PINGP Engineering Evaluation EC 21264, Loss of DC Control Power Common Enclosure Analysis for NFPA 805.
6.84   PINGP Engineering Evaluation EC 23408, NFPA 805 LAR Supplement NEI 00-01 Gap Analysis.
PINGP                                                               Page 71 - Revision 1

Northern States Power - Minnesota                    Attachments ATTACHMENTS PINGP                                         Page 72 - Revision 0

Northern States Power - Minnesota         Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program & Design Elements A.      NEI 04-02 Table B Transition of Fundamental Fire Protection Program & Design Elements 166 Pages Attached PINGP                                                                 Page A Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title           Requirement/Guidance       Compliance Statement Compliance Basis 3.1                      General                    This chapter contains      N/A                  10 CFR 50.48(c)(2)(vii) states, "Notwithstanding the fundamental                                 the prohibition in Section 3.1 against the use of elements of the fire                            performance-based methods, the fire protection protection program and                          program elements and minimum design specifies the minimum                           requirements of Chapter 3 may be subject to the design requirements for                         performance-based methods permitted elsewhere fire protection program                         in the standard. Licensees who wish to use elements and minimum                            performance-based methods for these fire design requirements                             protection program elements and minimum design shall not be subject to                         requirements shall submit a request in the form of the performance-based                           an application for license amendment under &sect; methods permitted                               50.90. The Director of the Office of Nuclear elsewhere in this                               Reactor Regulation, or a designee of the Director, standard. Previously                            may approve the application if the Director or approved alternatives                           designee determines that the performance-based from the fundamental                            approach:
protection program attributes of this chapter                      (A) Satisfies the performance goals, performance by the AHJ take                                 objectives, and performance criteria specified in precedence over the                             NFPA 805 related to nuclear safety and requirements contained                          radiological release; herein.
(B) Maintains safety margins; and Plant Documentation None                                                                                                (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, Industry-Related References                                                                         mitigation, and post-fire safe shutdown capability)."
10 CFR 50.48, "Fire Protection," Section (c)(2)(vii), "Performance-based methods" Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                     Summary None Items for Implementation None PINGP                                                                                                                            Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.2.1                    Intent                A site-wide fire           Complies             Procedure 5AWI 3.13.0, "Fire Protection protection plan shall be                        Program," establishes a fire protection program established. This plan                          for the plant. The procedure defines shall document                                  responsibilities of plant personnel, administrative management policy and                           controls, and implementing documents and program direction and                           procedures in place relative to the program.
shall define the responsibilities of those                       Per Section 1.0, "The Fire Protection Program at individuals responsible                         the Prairie Island Nuclear Generating Plant for the plan's                                  (PINGP) has been established to protect the implementation. This                            health and safety of the public and site personnel, section establishes the                         to minimize radioactive release to the environment, criteria for an integrated                      minimize property loss, and assure the capability combination of                                  to achieve and maintain safe shutdown conditions components,                                     in the event of a fire. The Fire Protection Program procedures, and                                 is an integrated process involving design features, personnel to implement                          systems, trained personnel, equipment and all fire protection                             procedures to provide a defense-in-depth program activities.                             approach to fire protection."
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance     Compliance Statement Compliance Basis 3.2.2                    Management            A policy document shall  Complies             Per Section 3.0 of Procedure 5AWI 3.13.0, "Fire Policy Direction      be prepared that defines                      Protection Program," "This Instruction and Responsibility    management authority                          identifies...The licensing basis associated with the and responsibilities and                      various elements of the PINGP Fire Protection establishes the general                       Program...Organizational responsibilities required policy for the site fire                      to maintain the Program in accordance with protection program.                           regulatory requirements and plant commitments[and] Implementing documents associated with program elements.
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                     Page A Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance        Compliance Statement Compliance Basis 3.2.2.1                  Management            The policy document         Complies             Per Section 7.1.1 of Procedure 5AWI 3.13.0, "Fire Policy Direction      shall designate the                              Protection Program," The Site Vice President is and Responsibility    senior management                                responsible for, "Overall implementation of the position with immediate                          Fire Protection Program in accordance with authority and                                    licensing commitments."
responsibility for the fire protection program.
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance     Compliance Statement Compliance Basis 3.2.2.2                  Management            The policy document      Complies             Per Section 7.4 of Procedure 5AWI 3.13.0, "Fire Policy Direction      shall designate a                             Protection Program," "The Fire Protection and Responsibility    position responsible for                      Program Engineer is the overall single point of the daily administration                      contact for the site Fire Protection Program. The and coordination of the                       Fire Protection Program Engineer has primary fire protection program                       responsibility for the program."
and its implementation.
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                     Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.2.2.3                  Management            The policy document        Complies             Section 7.0 of Procedure 5AWI 3.13.0, "Fire Policy Direction      shall define the fire                           Protection Program," outlines the fire protection and Responsibility    protection interfaces with                      organization, which includes 19 positions: Site other organizations and                         Vice President, Engineering Director, Engineering assign responsibilities                         Programs Supervisor, Fire Protection Program for the coordination of                         Engineer, Fire Protection Coordinator, Detection activities. In addition,                        and Alarm Engineer, System Engineer, Design this policy document                            Engineer, Instrument and Control Systems shall identify the various                      Technician, Appendix R Engineer, Operations plant positions having                          Manager, Shift Manager, Shift Supervisors, Work the authority for                               Supervisors, Construction Superintendents, Fire implementing the                                Brigade, Production Planning and Scheduling, various areas of the fire                       Regulatory Compliance, and Training Manager.
protection program.                             These positions are responsible for assuring Plant Documentation                                                                            adequate implementation of the various areas of Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12                        the fire protection program.
Industry-Related References                                                                    Section 7.4.5 states that the Fire Protection Program Engineer is responsible for "Interfacing None with the respective industry organizations Existing Engineering Equivalency Evaluations (EEEEs)                                           concerning Fire Protection Program issues and Identifier                   EEEE Description                 Summary                          operating experience."
None Items for Implementation None PINGP                                                                                                                      Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance      Compliance Statement Compliance Basis 3.2.2.4                  Management            The policy document       Complies             Per Section 5.5 of Procedure 5AWI 3.13.0, "Fire Policy Direction      shall identify the                             Protection Program," "For interpretation and and Responsibility    appropriate AHJ for the                        implementation of NFPA Codes and Standards, various areas of the fire                      both the NRC and NEIL may be considered as the protection program.                            AHJ, dependent upon the situation to which the Plant Documentation                                                                           code is applied."
Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 5.5.1 For application of all Codes of Record to Industry-Related References                                                                   Safety-related areas or other areas under the None                                                                                          NRC jurisdiction (or covered under the Fire Protection Program and various commitments),
Existing Engineering Equivalency Evaluations (EEEEs) the NRC is considered the primary AHJ. In Identifier                   EEEE Description                 Summary                         accordance with the fire protection license None                                                                                          condition, AHJ authority is delegated to the site when evaluation shows a change or condition has Items for Implementation                                                                      no adverse affect on safe shutdown ability.
None 5.5.2 For areas where NRC and NEIL share jurisdiction, either or both may be considered the AHJ, dependent on which organization is enforcing the code in any particular instance. The engineer should be cognizant of any regulatory impacts which may occur as a byproduct of a NEIL-related change or evaluation.
5.5.3 For areas outside of NRC jurisdiction, but within the auspices of NEIL, NEIL is considered to be the AHJ.
PINGP                                                                                                                      Page A Revision 1

Northern States Power - Minnesota                                                                       Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title       Requirement/Guidance Compliance Statement  Compliance Basis 3.2.3                   Procedures             Procedures shall be       Complies         Procedure F5 Appendix K, "Fire Protection Subsection 3.2.3(1)    established for                            Systems Functional Requirements," establishes implementation of the                      requirements for surveillance and testing of fire fire protection program.                   protection equipment. Section 1.0, Rev. 15 states, In addition to procedures                  "This procedure provides a system overview, that could be required by                  functional, requirements, compensatory actions, other sections of the                      surveillance requirements, and reporting standard, the procedures                   requirements of fire protection systems."
to accomplish the following shall be established:
(1) Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.
Plant Documentation Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15 dated 4/11/2012 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                 Page A Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title       Requirement/Guidance Compliance Statement   Compliance Basis 3.2.3                   Procedures             Procedures shall be       Complies          Section 6.1 of Procedure F5 Appendix K, "Fire Subsection 3.2.3(2)    established for                             Protection Systems Functional Requirements,"
implementation of the                       establishes provisions for compensatory fire protection program.                    measures when fire protection systems and In addition to procedures                   equipment are impaired. Specific compensatory that could be required by                   actions are identified for each specific system other sections of the                       discussed within the procedure.
standard, the procedures to accomplish the following shall be established:
(2) Compensatory actions implemented when fire protection systems and other systems credited by the fire protection program and this standard cannot perform their intended function and limits on impairment duration.
Plant Documentation Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                  Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance Compliance Statement        Compliance Basis 3.2.3                      Procedures             Procedures shall be       Complies with Item for Per Section 16.0 of Procedure 5AWI 3.13.0, "Fire Subsection 3.2.3(3)    established for           Implementation         Protection Program," "Fire Protection Program implementation of the                            health is monitored using objective criteria related fire protection program.                         to the program health criteria including, when In addition to procedures                        practical, objective measures for the program that could be required by                        attributes, leading indicators which are identified other sections of the                            and emphasized wherever possible to promote a standard, the                                    proactive approach to program improvement.
procedures to                                    Objective criteria indicating health degradation accomplish the following                         include: Systems performance; Failed PM shall be established:                            component tracking; The performance indicator trends are often just as important as the indicator (3) Reviews of fire                              values in assessing program health, as they may protection program -                             represent potential future vulnerabilities; Industry-related performance and                          identified precursors to declining program trends.                                          performance are also potential sources for leading Plant Documentation                                                                                indicators...Detailed Health Report parameters are Fleet Procedure FP-PA-SA-01, "Focused Self-Assessment Planning, Conduct and Reporting,"            included in FP-PE-PHS-01, Program Health Rev. 13, dated 9/29/11                                                                             Process."
Fleet Procedure FP-PE-PHS-01, "Program Health Process," Rev. 13, dated 1/13/12 Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12                            Per Section 5.2.5.5.e of Fleet Procedure FP-PE-PHS-01, "Program Health Process," "For Industry-Related References                                                                        programs that receive regular major NRC None                                                                                               inspections (App R and Fire Protection), Focused Self-Assessments are conducted per FP-PA-SA-Existing Engineering Equivalency Evaluations (EEEEs) 01, Focused Self-Assessment Planning, Conduct Identifier                     EEEE Description                 Summary                            and Reporting" at least every 36 months, unless None                                                                                               approved by Programs Engineering Director."
Items for Implementation The monitoring program required by NFPA 805 Section 2.6 will be implemented after the LAR          Per Section 1.0 of Fleet Procedure FP-PA-SA-01, approval as part of the FPP transition to NFPA 805, in accordance with NFPA 805 FAQ 10-            "Focused Self-Assessment Planning, Conduct and 0059, and will include a process that reviews the FPP performance and trends in                    Reporting," "This procedure provides the process performance. Refer to Attachment S.                                                                for planning, conducting and reporting the results of a Focused Self-Assessment (FSA)...The objective of a FSA is to verify compliance, improve performance and achieve excellence."
PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance Compliance Statement Compliance Basis 3.2.3                    Procedures             Procedures shall be          Complies     Procedure 5AWI 3.13.1, "Fire Protection Review Subsection 3.2.3(4)    established for                           of Plant Modifications," states, This Instruction implementation of the                     establishes the process for reviewing fire protection program.                  modifications (engineering changes, equivalency In addition to procedures                 changes, design changes, temporary that could be required by                 modifications, etc.) at PINGP. The review ensures other sections of the                     that the fire protection requirements are included.
standard, the procedures                  It also ensures adequate evaluation and to accomplish the                         documentation of the type and quantity of following                                 combustible loading in each fire area.
shall be established:
Section 1.0 of Fleet Procedure FP-G-DOC-04, (4) Reviews of physical                   "Procedure Processing," states, "The purpose of plant modifications and                   this procedure is to establish a common process for procedure changes for                     initiation, revision, review, and approval of the impact on the fire                        following document types (listed according to protection program.                       Document Hierarchy): Corporate Directives; Fleet Plant Documentation                                                                       Program/Process Descriptions, Codes of Conduct; Fleet Procedure FP-E-MOD-02, "Engineering Change Control," Rev. 11, dated 8/4/11          Fleet Procedures; Centralized Department Fleet Procedure FP-E-MOD-04, "Design Inputs," Rev. 8, dated 5/4/11                        Procedures; Corporate Office Procedures; Site Fleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 15, dated 10/28/11              Procedures; Forms (that are independent of Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05 procedures)."
Industry-Related References                                                               Section 1.1 of Fleet Procedure FP-E-MOD-02, None                                                                                      "Engineering Change Control," states, "This procedure provides instruction for the initiation, Existing Engineering Equivalency Evaluations (EEEEs) classification and overall control of all Identifier                   EEEE Description                 Summary                     modifications at facilities owned and operated by None                                                                                      Northern States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy, Items for Implementation                                                                  hereinafter NSPM. This procedure also includes None                                                                                      instructions and reference information for initiation and control of other types of engineering changes."
Section 1.1 of Fleet Procedure FP-E-MOD-04, "Design Inputs," states, "This procedure controls the identification, documentation, and revision of design inputs throughout the modification design process."
PINGP                                                                                                                   Page A Revision 1

Northern States Power - Minnesota                                                                      Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance Compliance Statement Compliance Basis 3.2.3                    Procedures            Procedures shall be       Complies        Section 16.0 of 5AWI-3.13.0, "Fire Protection established for                           Program" states, "It is important that the Fire implementation of the                     Protection Program Engineer includes a strategy fire protection program.                  for updating the program in anticipation of In addition to procedures                 changing requirements and industry standards, or that could be required by                 significant business needs, such as plant license other sections of the                     renewal. The strategy should be supported by a standard, the procedures                  long-term PI plan that ensures resources, cost, to accomplish the                         and upgrades are planned far enough in advance following                                 to minimize the impact on routine operations and shall be established:                     program implementation. The Fire Protection Program should be designed such that the results (5) Long-term                             of health monitoring, benchmarking, self-maintenance and                           assessment, license renewal, and management configuration of the fire                 oversight are also reviewed for potential updates protection program.                       to the long-term plans."
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                         Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance Compliance Statement Compliance Basis 3.2.3                     Procedures              Procedures shall be       Complies        Procedure F5, "Fire Fighting," establishes a Subsection 3.2.3(6)     established for                           procedure for emergency response of the fire implementation of the                     brigade.
fire protection program.
In addition to procedures                 Section 1.0 states, "The purpose of this section is that could be required by                 to provide specific instructions on the organization other sections of the                     of fire brigades, individual responsibilities in standard, the procedures                  regard to fires, and procedures for extinguishing to accomplish the                         fires."
following shall be established:                     Procedure F5 Appendix A, "Fire Strategies" describes the preplanned actions for fighting fires (6) Emergency response                    in each fire area.
procedures for the plant industrial fire brigade Plant Documentation Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Procedure F5 Appendix A, "Fire Strategies", Rev. 27, dated 11/14/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                    Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title      Requirement/Guidance      Compliance Statement Compliance Basis 3.3                     Prevention            A fire prevention         Complies             Procedure FP-PE-CC-01, "Combustible Control" program with the goal of                       establishes specific requirements for the fire preventing a fire from                         prevention program.
starting shall be established,                                   Section 1.0 states, "This instruction establishes documented, and                                combustible controls requirements that are implemented as part of                         consistent with regulatory commitments and the fire protection                            acceptable industry measures to reduce the program. The two basic                         potential for a fire that involves combustible components of the fire                         materials."
prevention program shall consist of both of the following:
(1) Prevention of fires and fire spread by controls on operational                        .
activities (2) Design controls that restrict the use of combustible materials The design control requirement listed in the remainder of this section shall be provided as described.
Plant Documentation Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                      Page A Revision 1

Northern States Power - Minnesota                                                                      Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance Compliance Statement Compliance Basis 3.3.1                    Fire Prevention for   The fire prevention       Complies        Procedure 5AWI 3.13.3, "Hot Work," establishes Operational           program activities shall                  administrative, procedural, and conditional Activities            consist of the necessary                  requirements for hot work and associated fire elements to address the                   watches.
control of ignition sources and the use of                    Section 1.0 states, "This instruction describes transient combustible                     requirements for performing hot work activities materials during all                      during power operations and outages."
aspects of plant operations. The fire                      Section 2.1 of Procedure FP-PE-CC-01, prevention program shall                  "Combustible Control" applies to the use, staging focus on the human and                    and storage of all combustible materials at programmatic elements                     MNGP (Monticello Nuclear Generating Plant) and necessary to prevent                      PINGP (Prairie Island Nuclear Generating Plant) fires from starting or,                   only as identified in Section 2.2.
should a fire start, to keep the fire as small as                 Section 10.0 of Instruction 5AWI 3.13.0, "Fire possible.                                 Protection Program," establishes controls for Plant Documentation                                                                      limiting the spread of fire.
Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 Procedure 5AWI 3.13.3, "Hot Work," Rev. 2, dated 8/19/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                 Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.1                  Fire Prevention for     The fire prevention         Complies             Procedure 5AWI 3.13.0, "Fire Protection Operational             activities shall include                         Program," includes but is not limited to training.
Activities General      but not be limited to the Fire Prevention         following program                                Per Section 8.10 of Procedure 5AWI 3.13.0 Activities,             elements:                                        "Individuals with unescorted access to the plant Subsection                                                               shall be instructed on how to identify adverse 3.3.1.1(1)              (1) Training on fire safety                      conditions and report them to supervisory information for all                              personnel. These instructions shall include:
employees and                                    Housekeeping and cleanliness criteria...Keeping contractors including, as                        access to fire extinguishers and hose stations a minimum,                                       unobstructed...[and] Work management process familiarization with plant                       overview."
fire prevention procedures, fire                                 Per Section 8.11, Level I (A) fire protection reporting, and plant                             training shall be general training given to emergency alarms                                 operations and mechanical maintenance Plant Documentation                                                                               personnel. The training shall include: Basic Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12                           principles of fire chemistry and physics...Fire hazards...Fire detection systems...Types of Industry-Related References                                                                       extinguishing systems...Special fire hazards FAQ 06-0028, "Training Definition and Content," Rev. 2, dated 5/21/07                             associated with nuclear power[and] Emergency planning with emphasis on fire emergency.
Existing Engineering Equivalency Evaluations (EEEEs)
                                                                                                  "Following initial training, Level 1 topics shall be Identifier                   EEEE Description                  Summary                            reviewed annually with required personnel."
None Items for Implementation None PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title      Requirement/Guidance      Compliance Statement Compliance Basis 3.3.1.1                   Fire Prevention for   The fire prevention       Complies             Fleet Procedure FP-PA-ARP-01, "CAP Action Operational           activities shall include                       Request Process," and Procedure 5AWI 8.5.0, Activities            but not be limited to the                      "Housekeeping and Materiel Condition," include General Fire          following program                              but are not limited to processes for documenting Prevention            elements:                                      plant inspections and corrective actions.
Activities, Subsection            (2) Documented plant                           Section 2.1 of Fleet Procedure FP-PA-ARP-01 3.3.1.1(2)            inspections including                          states, "This procedure establishes the process provisions for corrective                      for documenting and tracking the resolution of actions for conditions                         issues at each site. It provides the framework to where unanalyzed fire                          ensure that deviations from performance hazards are identified.                        expectations, including conditions adverse to Plant Documentation                                                                            quality, employee concerns, operability issues, Fleet Procedure FP-PA-ARP-01, "CAP Action Request Process," Rev. 32, dated 9/29/11             functionality issues, and reportability issues are Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev. 10, 2/25/09                  promptly identified, evaluated, and corrected as 5AWI 3.13.0 Fire Protection Program, Rev. 21, dated 1/5/12                                     appropriate."
Industry-Related References                                                                    Per Section 1.0 of Procedure 5AWI 8.5.0, "This None                                                                                           Instruction establishes Housekeeping and Materiel Condition requirements for the control of Existing Engineering Equivalency Evaluations (EEEEs) work activities, conditions and environment that Identifier                    EEEE Description                Summary                          could affect quality. The objective of this program None                                                                                           is to encompass all activities related to the control of cleanliness of facilities, cleanliness of material Items for Implementation                                                                       and equipment and protection of equipment."
None Per Section 6.14.2, "The area owner SHALL walk down each area monthly. Use the normal site processes to document and correct deficiencies; primarily:
* Use a Work Request to initiate action on items requiring maintenance attention;
* Use email or face-to-face communication to initiate general housekeeping improvements requiring Nuclear Plant Service Attendant attention; and
* Use the Corrective Process to address more significant issues, or those worth trending."
5AWI 3.13.0 Fire Protection Program Section 7.11 of procedure 5AWI 3.13.0 states, Operations Manager SHALL be responsible for:
7.11.10 Ensuring required daily fire hazard housekeeping inspections are conducted and documented.
PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance         Compliance Statement Compliance Basis 3.3.1.1                  Fire Prevention for    The fire prevention          Complies             Procedure 5AWI 3.13.1, "Fire Protection Review Operational            activities shall include                          of Plant Modifications" includes but is not limited Activities General     but not be limited to the                         to administrative controls addressing the review of Fire Prevention        following program                                 plant modifications and maintenance.
Activities,            elements:
Subsection                                                               Per Section 1.0 of Procedure 5AWI 3.13.1, This 3.3.1.1(3)             (3) Administrative                                Instruction establishes the process for reviewing controls addressing the                           modifications (engineering changes, equivalency review of plant                                   changes, design changes, temporary modifications and                                 modifications, etc.) at PINGP. The review ensures maintenance to ensure                             that the fire protection requirements are included. It that both fire hazards                            also ensures adequate evaluation and and the impact on plant                           documentation of the type and quantity of fire protection systems                           combustible loading in each fire area.
and features are minimized.
Plant Documentation Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.2                   Fire Prevention for     Procedures for the          Complies             Procedure FP-PE-CC-01, "Combustible Control" Operational             control of general                               includes but is not limited to procedures on the Activities Control of   housekeeping practices                           control of wood within the plant. The procedure Combustible             and the control of                               specifically requires that any wood in the plant Materials,              transient combustibles                           shall be coated, treated or covered with a fire Subsection              shall be developed and                           retardant material and listed on a Combustible 3.3.1.2(1)              implemented. These                               Control Permit.
procedures shall include but not be limited to the following program elements:
(1) Wood used within the power block shall be listed pressure-impregnated or coated with a listed fire-retardant application.
Exception: Cribbing timbers 6 in. by 6 in.
(15.2 cm by 15.2 cm) or larger shall not be required to be fire-retardant treated.
Plant Documentation Procedure FP-PE-CC-01, "Combustible Control" Rev. 1, dated 1/17/14 Industry-Related References FAQ 06-0019, "Definition of 'Power Block' and 'Plant'," Rev. 4, dated 9/28/07 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.3.1.2                 Fire Prevention for     Procedures for the         Complies             Procedure FP-PE-CC-01, "Combustible Control" Operational             control of general                              includes but is not limited to procedures on the Activities Control of   housekeeping practices                          control of plastic sheeting.
Combustible             and the control of Materials,              transient combustibles                          Per Section 5.1.6 of Procedure FP-PE-CC-01, Subsection              shall be developed and                          "Combustible Control", "Plastic sheeting procured 3.3.1.2(2)              implemented. These                              for and used in the plant shall be fire retardant procedures shall include                        unless evaluated by the Fire Marshal (MNGP)/Fire but not be limited to the                       Protection Coordinator (PINGP) and documented following program                               in a CCP."
elements:
(2) Plastic sheeting materials used in the power block shall be fire-retardant types that have passed NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, large-scale tests, or equivalent.
Plant Documentation Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 Industry-Related References NFPA 701, "Standard Methods of Fire Tests for Flame Propagation of Textiles and Films" Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title          Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.2                 Fire Prevention for       Procedures for the          Complies             Procedure FP-PE-CC-01, "Combustible Control" Operational               control of general                               includes but is not limited to procedures on the Activities Control of     housekeeping practices                           control of waste, debris, scrap, packing materials, Combustible               and the control of                               or other combustibles resulting from an activity.
Materials,                transient combustibles Subsection                shall be developed and                           Per Section 5.1.10 of Procedure FP-PE-CC-01, 3.3.1.2(3)                implemented. These                               "Combustible Control", "Combustible packing procedures shall include                         material or shipping containers SHALL be but not be limited to the                        removed from the area immediately following the following program                                unpacking."
elements:
Per Section 3.8.5 of Procedure FP-PE-CC-01, (3) Waste, debris, scrap,                        "Combustible Control", "Maintain good packing materials, or                            housekeeping and properly dispose of other combustibles shall                         combustible materials immediately after use or at be removed from an                               the end of each shift that are not identified on an area immediately                                 approved CCP."
following the completion of work or at the end of                         Per Section 6.6.3 of Procedure 5AWI 8.2.0, the shift, whatever                              "Material Identification and Inventory Control,"
comes first.                                     "Housekeeping shall be per 5AWI 8.5.0.
Plant Documentation                                                                                Cleanliness and good housekeeping practices Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14                                shall be enforced at all times in the storage areas.
Procedure 5AWI 8.2.0, "Material Identification and Inventory Control," Rev. 17, dated 6/17/10      Storage areas shall be cleaned as required to avoid the accumulation of trash, discarded Industry-Related References                                                                        packaging materials and other detrimental soil."
None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title          Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.2                 Fire Prevention for       Procedures for the          Complies             Procedure FP-PE-CC-01, "Combustible Control" Operational               control of general                               includes but is not limited to procedures on the Activities Control of     housekeeping practices                           control of combustible storage or staging areas.
Combustible               and the control of                               Section 5.6 of Procedure FP-PE-CC-01, Materials,                transient combustibles                           "Combustible Control" establishes requirements Subsection                shall be developed and                           for the storage of combustibles in designated 3.3.1.2(4)                implemented. These                               areas.
procedures shall include but not be limited to the                        Per Section 6.6.5 of Procedure 5AWI 8.2.0, following program                                "Material Identification and Material Control," "Fire elements:                                        protection for stored materials shall be per 5AWI 3.13.2."
(4) Combustible storage or staging areas shall be                        Per Section 6.8.1 of Procedure 5AWI 8.5.0, designated, and limits                           "Housekeeping and Materiel Condition,"
shall be established on                          "Combustible material (including gases and liquids, the types and quantities                         high efficiency particulate air and charcoal filters, of stored materials.                             dry ion exchange resins, or other combustible Plant Documentation                                                                                supplies) SHALL be stored in approved cabinets Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14                                and containers or in posted areas.
Procedure 5AWI 8.2.0, "Material Identification and Inventory Control," Rev. 17, dated 6/17/10 Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev.10, dated 2/25/09 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.2                    Fire Prevention for    Procedures for the          Complies             Section 5.3 of Procedure FP-PE-CC-01, Operational            control of general                               "Combustible Control" establishes requirements Activities Control of  housekeeping practices                           for the storage of flammable and combustible Combustible            and the control of                               liquids.
Materials,             transient combustibles Subsection             shall be developed and                           The storage of flammable and combustible liquids 3.3.1.2(5)             implemented. These                               has been reviewed against the requirements of procedures shall include                         NFPA 30, as detailed in the NFPA 30-1969 and but not be limited to the                        NFPA 30-1987 code review checklists.
following program elements:
(5) Controls on use and storage of flammable and combustible liquids shall be in accordance with NFPA 30, Flammable and Combustible Liquids Code, or other applicable NFPA standards.
Plant Documentation NRC SER dated 9/6/79 Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1969 Edition, Revision: 1, Date: November 2010 NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1987 Edition, Revision: 1, Date: December 2010 Industry-Related References FAQ 06-0020, "Identification of 'Applicable NFPA Standards'," Rev. 1, dated 2/16/07 NFPA 30, "Flammable and Combustible Liquids Code," 1969 and 1987 Editions "Flammable and Combustible Liquids Code Handbook," Sixth Edition (based on NFPA 30-1996)
NFPA 10 "Standard for the Installation of Portable Fire Extinguishers," 2007 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.3.1.2                    Fire Prevention for    Procedures for the         Complies             Fire Protection Engineering Evaluation FPEE                            Operational            control of general                              018 documents the code compliance review for Activities Control of  housekeeping practices                          National Fire Protection Association 55, (NFPA) -
Combustible            and the control of                              2005, Standard for the Storage, Use, and Handling Materials,             transient combustibles                          of Compressed Gases and Cryogenic Fluids in Subsection             shall be developed and                          Portable and Stationary Containers, Cylinders, and 3.3.1.2(6)             implemented. These                              Tanks. This review concluded that procedures shall include                        the use and storage of flammable gases is but not be limited to the                       compliant with the applicable code requirements.
following program elements:
(6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.
Plant Documentation Fire Protection Engineering Evaluation FPEE-11-018, National Fire Protection Association 55, (NFPA) - 2005, Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks Industry-Related References FAQ 06-0020, "Identification of 'Applicable NFPA Standards'," Rev. 1, dated 2/16/07 NFPA 55, "Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks," 2005 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                     Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title      Requirement/Guidance  Compliance Statement Compliance Basis 3.3.1.3                 Fire Prevention for   Control of Ignition   Covered in the sub-  Covered in the sub-sections below Operational           Sources.              sections below Activities Control of Ignition Sources Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description               Summary N/A Items for Implementation N/A PINGP                                                                                                             Page A Revision 1

Northern States Power - Minnesota                                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance         Compliance Statement   Compliance Basis 3.3.1.3.1                Control of Ignition    A hot work safety            Complies with Item for Procedure 5AWI 3.13.3, "Hot Work," establishes Sources                procedure shall be           Implementation         guidance and requirements for those performing developed,                                          hot work. Section 1.0 states, "This Instruction implemented, and                                    describes requirements for performing hot work periodically updated as                             activities during power operations and outages."
necessary in accordance with NFPA                                Hot work safety procedures have been reviewed 51B, Standard for Fire                              against the requirements of NFPA 51B and NFPA Prevention During                                   241, as detailed in the NFPA 51B-1999 code Welding, Cutting, and                               review checklist and FPEE-11-020.
Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.
Plant Documentation Procedure 5AWI 3.13.3, "Hot Work," Rev 3, dated 1/27/12 FPEE-11-020, "NFPA Codes Referenced in NFPA 805 not addressed by separate code reviews" Industry-Related References NFPA 51B, "Standard for Fire Prevention during Welding, Cutting, and other Hot Work," 1999 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary FPEE-11-020, NFPA            The purpose of this analysis is  The following sections of Codes Referenced in          to document the review of the    NFPA 241 are not applicable NFPA 805 not addressed       NFPA codes referenced in         to PINGP, with the bases by separate code reviews     NFPA 805 that are not            identified:
addressed in separate NFPA code compliance reviews          Section 5.1.2: PINGP does not have gas operated welding and cutting equipment that uses multiple oxygen and fuel gas cylinders.
Section 5.1.3.2 (partial): Per discussions with station personnel, and based on review of recent roofing modifications, torch applied roof coverings have not been used at PINGP.
Section 5.1.4: Thermit welding is not conducted at PINGP.
PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 Chapter 9: Per discussions with station personnel, and based on review of recent roofing modifications, torch applied roof coverings have not been used at PINGP.
Section 5.1.1 of NFPA 241 identifies that hot work shall be in accordance with NFPA 51B. In addition, the fire watch requirement of Section 5.1.3.1 and the partial criteria of Section 5.1.3.2 regarding posting of a fire watch for the duration of the work are also covered in NFPA 51B.
The code compliance review of NFPA 51B is addressed in FPEE-11-021. Only one deviation is identified. Section 5.1 of FPEE-11-021 documents the acceptability of not performing a final check after completion of the work in Designated Hot Work Areas that do not require a fire watch.
As such, NFPA 51B adequately addresses all hot work criteria of NFPA 241 except for torch applied roofing.
Items for Implementation As described in Table S-3, Item #2, revise procedure 5 AWI 3.13.3, Hot Work, to address the following:
- There is no requirement in plant documents that specifically address the requirements for hot tapping. (NFPA 51B-1999, Section 3-5)
- Plant documents do not address the requirements for a fire watch where torch-applied roofing hot work operations are in effect. (NFPA 241-1999, Section 5.1.3.2)
PINGP                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance        Compliance Statement Compliance Basis 3.3.1.3.2                Control of Ignition   Smoking and other           Complies             Per Section 3.15.9 of Procedure CD 5.13, Fire Sources               possible sources of                              Protection Program Standard," - "Designate ignition shall be                                smoking areas and areas where smoking is restricted to properly                           prohibited such as in areas containing safety designated and                                   related/safe shutdown equipment.
supervised safe areas of the plant.
Plant Documentation Procedure CD 5.13, Fire Protection Program Standard, Rev, dated 01/17/14 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                     Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title      Requirement/Guidance        Compliance Statement   Compliance Basis 3.3.1.3.3                 Control of Ignition   Open flames or              Complies with item for Per Item 73 of the table attached to Letter from Sources               combustion-generated        implementation         Mayer (NSP) to Stello (NRC) dated 12/8/76, smoke shall not be                                 "Comparison of Existing Fire Protection Provisions permitted for leak or air                          to the Guidelines Contained in Standard Review flow testing.                                      Plan 9.5.1," "Leak testing is done using only Plant Documentation                                                                                smoke sticks or generators."
Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76 Procedure 5AWI 3.13.2, "Fire Prevention," Rev 19, dated 01/05/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                Summary None Items for Implementation As described in Table S-3, item #2, Procedure 5AWI 3.13.3, "Hot Work," will be revised to require that Open flames or combustion-generated smoke shall not be permitted for leak or air flow testing PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.3.1.3.4                Control of Ignition   Plant administrative       Complies             Section 6.8 of Procedure 5AWI 3.13.3, "Hot Sources               procedure shall control                         Work," provides the requirements that shall apply the use of portable                             to portable space heaters.
electrical heaters in the plant. Portable fuel-fired heaters shall not be permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.
Plant Documentation Procedure 5AWI 3.13.3, "Hot Work," Rev. 7, dated 1/17/14 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                    Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.3.2                   Structural              Walls, floors, and       Complies             Per Section 2.6 of Procedure F5 Appendix F, "Fire components required to                        Hazard Analysis," "Materials of construction are maintain structural                           rated 'Noncombustible' or 'Fire-Resistive' integrity shall be of                         construction in accordance with National Fire noncombustible                                Protection Association (NFPA) No. 2201961.
construction, as defined                      Coating systems applied to structures exhibit in NFPA 220, Standard                         flame spread characteristics which are within the on Types of Building                          limits of the definition for 'Noncombustible' Construction.                                 contained in NFPA No. 220."
Plant Documentation Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Industry-Related References NFPA 220, "Standard on Types of Building Construction," 1961 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.3.3                      Interior Finishes      Interior wall or ceiling    Complies             Per Section 4.2 of Procedure D71.1, "General finish classification shall                      Wall Painting, Concrete Wall, Blockwalls and be in accordance with                            Floor Surfaces," "All coatings shall meet the NFPA 101, Life Safety                           requirements of 'Class A Interior Wall and Ceiling Code, requirements for                          Finish' as defined in the National Fire Code, Class A materials.                               Section 101, 6-5.3.1, 1994 Edition."
Interior floor finishes shall be in accordance                           Per Section 2.6 of Procedure F5 Appendix F, "Fire with NFPA 101                                    Hazard Analysis," "Coating systems applied to requirements for Class 1                         structures exhibit flame spread characteristics interior floor finishes.                         which are within the limits of the definition for Plant Documentation                                                                                'Noncombustible' contained in NFPA No. 220.
Procedure D71, "Nuclear Coating Application," Rev. 21, dated 12/24/09                              Coating systems in the Containment, Safety Procedure D71.1, "General Wall Painting, Concrete Wall, Blockwalls and Floor Surfaces," Rev.       Injection, Containment Spray, and Residual Heat 5, dated 12/24/09                                                                                  Removal pump rooms use Carboline #2 primer Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                            and phenoline 305 which have a flame spread rating of 0-25."
Industry-Related References NFPA 101, "Life Safety Code," 1994 Edition                                                         Per Section 4.1 of Maintenance Procedure D71 NFPA 220, "Standard on Types of Building Construction," 1961 Edition                               "Nuclear Coating Applications," "In containment, ANSI N101.2, "Protective Coatings (Paints) for Light Water Nuclear Reactor                         use only those coating systems qualified Containment Facilities," 1972 Edition                                                              according to ANSI 101.2 and referenced in section 2.8."
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                   Summary                          Per Section 2.8 of Procedure D71, "Nuclear None                                                                                               Coating Application," Qualified Coatings for use Items for Implementation                                                                           on the interior of reactor buildings are Carbo Zinc None                                                                                               11 SG, Carboguard 890N (Formerly called Carboline 890 and Carboguard 890); Phenoline 368 WG; and Carboguard 2011S top coated with Carboguard 890N.
PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.3.4                       Insulation Materials   Thermal insulation         Complies             Per Section 1.1 of Engineering Manual 3.2.1.7, materials, radiation                            "Specification for Thermal Insulation," "The scope shielding materials,                            of this specification shall be to provide the required ventilation duct                                design information as needed for the replacement, materials, and                                  modification, and/or addition of thermal insulation soundproofing materials                         on previously existing plant piping, valves, fittings, shall be noncombustible                         and equipment."
or limited combustible.
Plant Documentation                                                                                Per Section 1.5, "Insulation materials including Engineering Manual 3.2.1.7, "Engineering Design Standard for Specification for Thermal             adhesives, shall be non-combustible and of a fire Insulation," Rev. 1, dated 10/31/2009. Ductwork Construction of Pioneer Services                   resistant application. This application shall be U.L.
&Engineering Co, Std Spec -Mech (SS - 613 (NSP) 9-70, Standard Specification for Sheet            rated with a normal maximum U.L. rating as Metal Ductwork Low Pressure and Medium Pressure, SS 613, Low and Medium Pressure                  follows: Flame spread 25, smoke developed 50, Ductwork, SS 614 (HVAC for Turb, Aux, Screenhouse, Containment and Shield Building), and           fuel contribution 25."
SS 619 for High Pressure Sheet Metal Ductwork.
FPEE (AR# 01163081, Rev. 1) documents the adequacy of the soundproofing material installed         Per Section 4.0, Ductwork Construction of Pioneer in Access Control, the Control Room, and the Cable Spreading Room computer area. Nuclear           Services & Engineering Co, Std Spec -Mech (SS -
Power Outfitters Lead Blanket Specifications                                                       613 (NSP) 9-70), Standard Specification for Sheet Metal Ductwork Low Pressure and Medium Industry-Related References                                                                        Pressure, All ductwork shall be constructed prime California Department of Forestry and Fire Protection, Flame Retardant Fabrics and Chemicals       quality galvanized material except as called out in Program                                                                                            TS - M 614, Technical Specification for Ventilating NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, 2010         Systems. Ductwork shall be inside smooth, air -
Edition                                                                                            tight substantially supported and stayed sufficiently CPAI-84, Industrial Fabrics Association International (formerly the Canvas Products                to avoid reverberations or flutter.
Association), Specification For Flame Resistant Materials Used in Camping Tentage, 1995 Edition                                                                                            The basis for the limited combustible soundproofing material in Access Control is Existing Engineering Equivalency Evaluations (EEEEs)                                               provided in FPEE (AR#01163081). Based on the definition of non-combustible/limited Identifier                     EEEE Description                 Summary                            combustible the fire test performance of the None material used for sound proofing in the Items for Implementation                                                                           Access Control Center is acceptable and None                                                                                               will not impact the ability to achieve and maintain safe shutdown.
Per the Manufacturer (Nuclear Power Outfitters),
the Radiation Shielding material is flame retardant and meets California Fire Marshall requirements, NFPA 701 and CPAI 84.
PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                   Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance Compliance Statement Compliance Basis 3.3.5                   Electrical           Electrical           Covered in the sub-  Covered in the sub-sections below sections below Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description            Summary N/A Items for Implementation None PINGP                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance Compliance Statement  Compliance Basis 3.3.5.1                    Electrical             Wiring above suspended Complies            12/8/1976 Letter, L.O. Mayer (NSP) to V. Stello ceiling shall be kept to a                 (NRC), Comparison of Existing Fire Protection minimum. Where                             Provisions to the Guidelines Contained in Standard installed, electrical wiring               Review Plan 9.5.1, APCSB 9.5-1 IV.B.1 (f ) states shall be listed for plenum                 "Room or areas containing safeguard equipment do use, routed in armored                     not have suspended ceilings. The control room has cable, routed in                           a suspended ceiling of aluminum crate" design".
metallic conduit, or routed in cable trays with                 Updated Safety Analysis Report (USAR) Section solid metal top and                        7, Rev. 31, states "...The control room suspended bottom covers.                             ceiling consists of aluminum louver grids with Plant Documentation                                                                          fluorescent light fixtures mounted above the grids..
Updated Safety Analysis Report (USAR) Section 7, Rev. 31 12/8/1976 Letter, L.O. Mayer (NSP) to V. Stello (NRC) Comparison of Existing Fire Protection Based on this information, there is no wiring Provisions to the Guidelines Contained in Standard Review Plan 9.5.1                         located above solid suspended ceilings.
Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                    Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title      Requirement/Guidance         Compliance Statement Compliance Basis 3.3.5.2                   Electrical            Only metal tray and          Complies             Per Sheet 1 of the Unit 1 & 2 Project Design metal conduits shall be                           Manual, dated 4/1967, Section 4, Index 324.53, used for electrical                               "Electrical Cable Tray Systems," "The cable tray raceways. Thin wall                               system shall be fabricated from aluminum alloys metallic tubing shall not                         throughout, except in the containment vessel. The be used for power,                                use of aluminum is prohibited in the containment instrumentation, or                               vessel, and only galvanized steel materials for this control cables. Flexible                          cable tray system is allowed."
metallic conduits shall only be used in short                             Per Section 9.2.2 of Procedure SWI CON-3, lengths to connect                                "Raceway Installation," cable trays are pan or components.                                       ladder style, and conduits are steel or aluminum.
Plant Documentation Engineering Manual 4.3.1-C.4, "Engineering Design, Fabrication and Installation Summary for       Per Section 4.1.1 of Engineering Manual 4.3.1-Conduit," Rev. 0, dated 6/16/04                                                                   C.4, "Engineering Design, Fabrication and Procedure SWI CON-3, "Raceway Installation," Rev. 2, dated 5/22/05                                Installation Summary for Conduit," "Conduit shall PINGP Unit 1 & 2 Project Design Manual, dated 4/1967                                              be RMC [Rigid Metal Conduit] steel. EMT Updated Safety Analysis Report (USAR) Section 7, Rev. 31                                          [Electrical Metallic Tubing] may be used only for lighting or telephones. Aluminum conduit may be Industry-Related References                                                                       specified by the Engineer for special applications."
FAQ 06-0021, "Cable Air Drops," Rev. 1a, dated 11/13/07 Per Section 4.1.2, "Steel RMC shall be rigid Existing Engineering Equivalency Evaluations (EEEEs) conduit conforming to ANSI Standard C80.1-1966 Identifier                    EEEE Description                Summary                             (Rev. 1971) rigid steel, zinc-coated."
None Per Section 4.1.3, "Aluminum conduit is prohibited Items for Implementation                                                                          for use inside containment."
None Per Section 4.1.4, "All flexible metal conduits for outdoor and high moisture installations shall be liquid tight galvanized steel flexible conduits covered with a synthetic outer jacket such as Anaconda Metal Hose Co., "Sealtight." Sizes 1/2" through 4" will be Anaconda Type "UA"; sizes 5" and 6" shall be Anaconda Type "EF" or approved equal."
Per Section 5.1.4, "Rigid conduits may terminate directly on equipment only when both conduit and equipment are supported on the same wall, column, ceiling, floor, or within five (5) feet of adjoining (corner) walls. Flexible conduit, or armored cable/jacketed cable (with appropriate connector) shall be utilized in all other cases unless specified otherwise.
                                                                                                  "Flexible conduit is required, allowing for two (2) inches of movement, in conduit runs between the Reactor Shield Building and Auxiliary Building Structures."
PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                Attachment A - NEI 04-02 Table B-1 Per Section 5.3.1, "Flexible metal conduit shall be of sufficient length to provide adequate movement due to seismic, vibration, and thermal motions.
The sketches in Engineering Manual 4.3.1-C.4 Sections 4.3.1-C.4.2 through 4.3.1-C.4.7 identify the maximum allowable lengths of flexible conduits for various configurations. These allowable lengths minimize the use of flexible conduits.
Per Section 7.8.4 of the Updated Safety Analysis Report (USAR), "To prevent the spread of fire from the electrical rooms beneath the control room, the following provisions are made:
: a. Cables used throughout the relay room have an exterior jacket that meets the insulated Power Cable Engineer's Association (IPCEA) test requirements. All non-metallic materials in the cable construction and accessory devices have been chosen so that they will not support combustion. Power cables for the 480 volt system are three conductor, insulated with ethylene propylene rubber, with a neoprene-like, or an asbestos braid impregnated with flame retardant compound jacket and interlocked aluminum armor overall.
: b. Cabling and wiring in the relay control room are installed in trays or in metallic conduit."
PINGP                                                         Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance         Compliance Statement Compliance Basis 3.3.5.3                  Electrical             Electric cable              Complies             Per Section 5.2.1 of Procedure F5 Appendix F, construction shall                               "Fire Hazard Analysis," "The majority of cable comply with a flame                              used in the plant was purchased from Kerite propagation test as                              Company. The cable is ethylene propylene rubber acceptable to the AHJ.                           insulated with a chlorosulfated polyethylene jacket Plant Documentation                                                                              and is commonly known as EPR-Hypalon.
Procedure F5 Appendix F, "Fire Hazards Analysis," Rev. 25A, dated 8/8/11                         Laboratory tests showed this cable to be highly resistive to auto-ignition and flame propagation.
Industry-Related References                                                                      This cable has subsequently been qualified in IEEE 383-1974, Standard for Type Test of Class 1E Electric Cables, Field Splices, and            accordance with IEEE 383-1974 flame test. A Connection for Nuclear Power Generating Stations                                                 small amount of cable purchased from Boston Insulated Wire and Cable company was tested in Existing Engineering Equivalency Evaluations (EEEEs) accordance with the Philadelphia flame test which Identifier                   EEEE Description                 Summary                            is a predecessor to the oil soaked rag test of IEEE None                                                                                             383-1974. The cables used in the D5/D6 addition was qualified to IEEE 383-1974 as above."
Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.3.6                     Roofs                  Metal roof deck            Complies with        NFPA 256 was withdrawn at the Annual 2008 construction shall be      Clarification        Meeting with no bases for where equivalent criteria designed and installed                          are addressed. The following documents so the roofing system                           demonstrate compliance that the roofing system will not sustain a self-                        will not sustain a self-propagating fire on the propagating fire on the                         underside of the deck when the deck is heated by underside of the deck                           a fire inside the building.
when the deck is heated by a fire inside the                            Per Section 4, Account No. 321.244 of the PINGP building. Roof coverings                        Project Design Manual, dated April 1967, original shall be Class A as                             specifications for roofing materials identified as determined by tests                             "Insulated flat steel deck with built up roofing described in NFPA 256,                          meeting NBFU requirements for 'Roof Deck Standard Methods of                             Construction No. 1'."
Fire Tests of Roof Coverings.                                      Per Letter from Severson (Howard R. Green Plant Documentation                                                                              Company) to Samson (NSP) dated 5/13/99, PINGP Project Design Manual, dated April 1967, Account No. 321.244                               "According to the Uniform Building Code (UBC),
Design Change 98BM01, "Rad Waste & Service Building Roofs," Rev. 0                               the existing gravel surfaced built-up roof Drawing NF-38385, "Reactor Building Unit 1 Concrete Wall Detail and Dome Plan, Sections &        membrane is considered a Class A roofing Details," Rev. M                                                                                 system. The new proposed system will also be Drawing NF-38513, "Architectural Plant Roof Plan," Rev. T, dated 1/21/05                         Class AAccording to the 'UL Fire Resistance Drawing NF-116987, "D5/D6 Bldg. - Concrete Roof Plan at El. 755'-0"," Rev. A Letter              Directory', the new built-up roof system meets from Severson (Howard R. Green Company) to Samson (NSP) dated 5/13/99                            assembly P#508. This indicates that the new Modification 96BM01, "Ancillary Roof Replacement," Rev. 0, Project Description                   system combined with the existing structure has a Modification 97BM01, "Turbine Roof Replacement," Rev. 0, Project Description                     proper fire rating."
Modification 97BM02, "1998 Reroofing," Rev. 0, Project Description Per Section 6 of Design Change 98BM01, "Rad Industry-Related References                                                                      Waste & Service Building Roofs," "According to the NFPA 256, "Standard Methods of Fire Tests of Roof Coverings," 1998 Edition                       UL Fire Resistance Directory, the new built up roof Underwriters' Laboratories Fire Resistance Directory                                             system meets Assembly No. P508 and No. J928.
This indicates that the new system, combined with Existing Engineering Equivalency Evaluations (EEEEs) the existing structure, has a proper Identifier                     EEEE Description                 Summary                          fire rating."
None Per Page 5 of 6 of the Project Description for Items for Implementation                                                                         Modification 97BM01, "Turbine Roof None                                                                                             Replacement," "According to the UL Fire Resistance Directory, the new built up roof system meets Assembly No. P508. This indicates that the new system, combined with the existing structure, has a proper fire rating."
Per Pages 1 of 7 and 2 of 7 of the Project Description for Modification 97BM02, "1998 Reroofing," "The purpose of this modification is to remove the existing Aux Building high roof, Old Admin Bldg and Rad Monitoring Station roofing and replace it with new, in accordance with the PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota               Attachment A - NEI 04-02 Table B-1 original design specificationAccording to the UL Fire Resistance Directory, the new built up roof system meets Assembly No. P508 and J928. This indicates that the new systems, combined with the existing structure, have an appropriate fire rating."
Per Pages 1 of 7 and 5 of 7 of the Project Description for Modification 96BM01, "Ancillary Roof Replacement," "The scope of the project includes removal and replacement of the following roof and roof systems: High roof of the old Screenhouse; Trash Basket roof; Chlorine House roofs; Maintenance Building Roof; Unit 1 and Unit 2 Condensate Polishing roofThe new proposed roof system, consisting of a ballasted 60 mil EPDM single ply membrane, expanded polystyrene and rigid insulation, is also considered to be a Class A roofing systemAccording to the UL Fire Resistance Directory, a ballasted single ply assembly system by Carlisle Syntec Systems meets Assembly Number P213. This indicates that the new system, combined with the existing structure, has a proper fire rating."
Per Drawing NF-116987, "D5/D6 Bldg. - Concrete Roof Plan at El. 755'-0"," the D5/D6 Building roof is 18" concrete slab over metal decking.
Per Drawing NF-38385, "Reactor Building Unit 1 Concrete Wall Detail and Dome Plan, Sections &
Details," the Shield Building dome roof is of 24" reinforced concrete.
Per Drawing NF-38513, "Architectural Plant Roof Plan," "All roofs as shown & noted shall carry a 20 year bond & shall be UL rated Class A Type III construction, unless otherwise noted."
PINGP                                                         Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.3.7                    Bulk Flammable         Bulk compressed or           Complies            Per Section 6.2 of Procedure 5AWI 3.13.1, "Fire Gas Storage            cryogenic flammable                              Protection Review of Modifications," the plant fire gas storage shall not be                         protection engineer is responsible to ensure that permitted inside                                 plant modifications, including storage of structures housing                               flammable gases, are in compliance with the systems, equipment, or                           plant's fire protection program.
components important to nuclear safety.                                  There is no bulk storage of flammable gases Plant Documentation                                                                              inside structures with SSCs important to nuclear safety.
Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05 Industry-Related References NFPA 58, Liquefied Petroleum Gas Code Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance      Compliance Statement Compliance Basis 3.3.7.1                    Bulk Flammable         Storage of flammable      Complies with        Section 3.1.6 of Attachment to Letter from Gas Storage            gas shall be located      Clarification        Schwencer (NRC) to Mayer (NSP), dated 4/21/80, outdoors, or in separate                       states, "The licensee has shown to our detached buildings, so                         satisfaction that the combustible gas cylinders will that a fire or explosion                       be stored in locations separated from safety will not adversely impact                      related areas by three hour fire rated barriers. The systems, equipment, or                         piping and cylinder installation will be in components important to                        accordance with NFPA No. 58. Based on our nuclear safety. NFPA                           review, we find the licensee's method of storing 50A, Standard for                              combustible gas cylinders acceptable."
Gaseous Hydrogen Systems at Consumer                            The requirement guidance cites NFPA 50A, Sites, shall be followed                       Standard for Gaseous Hydrogen Systems at for hydrogen storage.                          Consumer Sites; however this standard has been Plant Documentation                                                                              withdrawn and not superseded. NFPA 55, 2005, Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80                                         Standard for the Storage, Use, and Handling of Drawing NF-38225, Turbine Room - Concrete Hydrogen House, Rev. F, dated 12/26/74               Compressed Gases and Cryogenic Fluids in Drawing NF-38504, Architectural Power Plant Sections, Rev. F, dated 12/10/81                   Portable and Stationary Containers, Cylinders, Procedure C40.1, H2/O2 Gas Systems, Rev. 9, dated 8/31/09                                      and Tanks (Code of Record) has been used as Procedure F5 Appendix A, Fire Strategies, Rev. 27, dated 11/17/11                              the design basis for the bulk hydrogen storage System Description B40, Miscellaneous Gas Systems, Rev. 7, dated 5/27/09                       system.
PINGP Unit 1 & 2 Project Desigccn Manual, dated 4/1967 FPEE-11-018, NFPA 55 - 2005, Standard for the Storage, Use, and Handling ff Com Pressed          Hydrogen storage has been reviewed against the Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks           requirements of NFPA 55, as detailed in the NFPA Contract No. 00027187 between PINGP and Praxair Distribution, Inc.                               55-2005 code compliance report, FPEE-11-018.
Industry-Related References                                                                      Contract No. 00027187 between PINGP and NFPA 55 Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic            Praxair Distribution includes an annual system Fluids in Portable and Stationary Containers, Cylinders, and Tanks-2005                          inspection.
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance     Compliance Statement Compliance Basis 3.3.7.2                 Bulk Flammable       Outdoor high-pressure    Complies             Per Engineering Change 12191 close out Gas Storage          flammable gas storage                         package (EC-0441), The three tube banks will be containers shall be                           positioned side by side with the valving facing located so that the long                      east. In the event a nozzle break occurs, the axis is not pointed at                        projectile generated would be propelled to the buildings.                                    east, away from the power block. The individual Plant Documentation                                                                        tubes were not considered as missiles because Engineering Change 12191 close out package (EC-0441)                                       they are fastened to their support structure and are considered too heavy to act as missiles.
Industry-Related References                                                                Additionally, there are no safety related SSCs in NFPA 55, Compressed Gases and Cryogenic Fluids Code                                        the travel path for the tube path. These tubes also would be unable to achieve the same level of Existing Engineering Equivalency Evaluations (EEEEs) penetration compared to smaller missiles Identifier                  EEEE Description               Summary                         considered in the USAR due to their large weight None                                                                                       and size.
Items for Implementation None PINGP                                                                                                                  Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.3.7.3                  Bulk Flammable        Flammable gas storage      Complies             Per Table 2 of Procedure 5AWI 8.5.0, Gas Storage           cylinders not required for                      "Housekeeping and Material Condition," it is normal operation shall                          expected that "All gas cylinders are secured be isolated from the                            appropriately."
system.
Plant Documentation                                                                            Per Section 6.8.1, "Combustible material Procedure 5AWI3.13.3, "Hot Work," Rev 3, dated 1/27/12                                         (including gases and liquids) shall be stored in Procedure 5AWI 8.5.0, "Housekeeping and Material Condition," Rev. 10, 2/25/09                  approved cabinets and containers or in posted System Description B40, "Miscellaneous Gas Systems," Rev. 7, dated 5/27/09                     areas.
Industry-Related References                                                                    Per Section 10.0 of Procedure 5AWI 3.13.3, "Hot None                                                                                           Work," "Cylinder use and storage shall be in accordance with applicable site safety policies."
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None                                                                                           Per the Nuclear Plant Pocket Safety Guide, compressed gas cylinder valve protection caps Items for Implementation                                                                       shall be in place at all times except when None                                                                                           regulators are attached (when cylinders are in use).
PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title     Requirement/Guidance      Compliance Statement Compliance Basis 3.3.8                      Bulk Storage of      Bulk storage of           Complies             Section 5.1.2 (b) of Procedure FP-PE-CC-01, Flammable and        flammable and                                  "Combustible Control" establishes requirements Combustible          combustible liquids shall                      for the storage of flammable and combustible Liquids              not be permitted inside                        liquids.
structures containing systems, equipment, or                         Bulk storage of flammable and combustible liquids components important to                        has been reviewed against the requirements of nuclear safety. As a                           NFPA 30, as detailed in the NFPA 30-1969 and minimum, storage and                           NFPA 30-1987 code review checklists.
use shall comply with NFPA 30, Flammable and Combustible Liquids Code.
Plant Documentation NRC SER dated 9/6/79 Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1969 Edition, Revision: 1, Date: November 2010 NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1987 Edition, Revision: 1, Date: December 2010 Industry-Related References NFPA 30, "Flammable and Combustible Liquids Code," 1969 and 1987 Editions "Flammable and Combustible Liquids Code Handbook," Sixth Edition (based on NFPA 30-1996)
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description              Summary None Items for Implementation None PINGP                                                                                                                    Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.3.9                   Transformers            Where provided,             Complies             Per Table 1 of Procedure 5AWI 8.5.0, transformer oil collection                       "Housekeeping and Materiel Condition," all plant basins and drain paths                           transformers are included in the plant's inspection shall be periodically                            zone program. Per Table 2, this inspection inspected to ensure that                         program includes ensuring that drains are not they are free of debris                          clogged. Per Section 6.14.2, these inspections are and capable of                                   performed monthly.
performing their design function.                                        Per Section 10.2 of Procedure D14.6, "Storm Plant Documentation                                                                              Water Pollution Prevention Plan":
Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev. 10, dated 2/25/10              "The preventative maintenance program consists Procedure D14.6, "Storm Water Pollution Prevention Plan," Rev. 5, dated 3/22/06                  of various actions taken on a routine basis, i.e.,
NF-39320-1, Transformer Oil Drain Piping Unit 1                                                  checking transformers, changing oil absorbents, NF-39321-1, Transformer Oil Drain Piping Unit 2                                                  and pumping berms, inspections by the environmental group.
Industry-Related References FAQ 12-0067, "Transformer Oil Collection Drain Basin Inspections," Revision 1, February 12,      10.2.1 The oil demister (roof of Auxiliary Building) 2013                                                                                             has its oil absorbents changed on a computer Existing Engineering Equivalency Evaluations (EEEEs)                                             generated schedule.
Identifier                  EEEE Description                  Summary                            10.2.2 The berms surrounding the above ground None                                                                                             storage tanks are inspected weekly. A written log Items for Implementation                                                                         entry is completed which documents that, if the None                                                                                             berm contained water, it was inspected for oil residue before it was pumped or drained. This includes the large berm pits for the plant transformers which are also inspected for oil residue before pumping.
10.2.3 The plant transformers have a continuing leakage problem due to their large size. The various types of oil absorbents placed under them are routinely inspected and changed as necessary.
This minimizes the chance of oil reaching the berm pits."
PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.3.10                  Hot Pipes and         Combustible liquids,       Complies             Per Section 5.3.6 of Procedure FP-PE-CC-01, Surfaces              including high flashpoint                       "Combustible Control", "Liquids, including oils, lubricating oils, shall be                      SHALL be cleaned in a timely manner when kept from coming in                             spilled onto insulation."
contact with hot pipes and surfaces, including insulated pipes and surfaces. Administrative controls shall require the prompt cleanup of oil on insulation.
Plant Documentation Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                   Page A Revision 1

Northern States Power - Minnesota                                                                    Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title      Requirement/Guidance  Compliance Statement Compliance Basis 3.3.11                  Electrical            Adequate clearance,   Complies             Per Section 5.1.12 of Procedure FP-PE-CC-01, Equipment             free of combustible                        "Combustible Control" - "Combustible materials material, shall be                         SHALL NOT be stored within three (3) feet of maintained around                          energized electrical cabinets."
energized electrical equipment.
Plant Documentation Procedure FP-PE-CC-01, "Combustible Control", Rev. 1, dated 1/17/14 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description               Summary None Items for Implementation None PINGP                                                                                                              Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title      Requirement/Guidance     Compliance Statement  Compliance Basis 3.3.12(1)                  Reactor Coolant       For facilities with non- Complies via Previous Per Section 4.0 of Procedure F5 Appendix E, "The Pumps                 inerted containments,    Approval              Reactor Coolant Pump Lube Oil Collection System reactor coolant pumps                          is piped to sump A inside containment. The with an external                               contents of the sump can be pumped to closed lubrication system shall                       vented tank(s) inside the Auxiliary Building via two be provided with an oil                        (2) alternative flow pathsThe sump in collection system. The                         the basement of containment is a concrete pit oil collection system                          having a capacity of 990 gallons. This is more than shall be designed and                          the capacity needed to contain the total inventory installed such that                            of lube oil (410 gallons) for the two (2) reactor leakage from the oil                           coolant pumps for each unitThe sump is system is safely                               designed to automatically pump down at a contained for off normal                       prescribed sump level and an alarm will sound in conditions such as                             the Control Room if this level is exceeded. The accident conditions or                         operator can initiate manual control of the sump earthquakes. All of the                        pump(s) at any time by overriding the automatic following shall apply.                         control of sump level."
(1) The oil collection                         Per Page 2 of Attachment 1 of Letter from Musolf system for each reactor                        (NSP) to Director (NRC) dated 4/5/84, "In support coolant pump shall be                          of the system as is currently installed it should be capable of collecting                          notedthe lube oil collection system is seismically lubricating oil from all                       designed." Per Page 2 of Attachment potential pressurized                          1 of Letter from NSP to NRC dated 4/5/84, "In and nonpressurized                             summary, Northern States Power has made an leakage sites in each                          extensive effort to comply with the requirements of reactor coolant pump oil                       Appendix R. In comparing the lube oil collection system.                                        system to the requirements of Section III.0 [of Plant Documentation                                                                             Appendix R], concerns were voiced over the use Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84                                          of a closed vented container inside containment Letter from Musolf (NSP) to Director (NRC) dated 4/5/84                                         because of the need for it to also act as a Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated       collection point for seal leakage. Northern States 4/29/10                                                                                         Power believes that the existing configuration meets the intent of Appendix R in that all lube oil Industry-Related References                                                                     is collected to a common point which will prevent None                                                                                            its contact with hot piping in the area and is isolated from electrical power cable which might Existing Engineering Equivalency Evaluations (EEEEs) cause ignition."
Identifier                    EEEE Description                  Summary None                                                                                            Per Page 5 of Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84, "the pipe from the sump to Items for Implementation                                                                        the vented container in the auxiliary building has None                                                                                            been designed to seismic category Class III which meets the requirement of Regulatory Guide 1.29, paragraph C-2. If failure of this pipe were to occur during a seismic event, the functions of plant features described in paragraph 1 (a through q) of Regulatory Guide 1.29 will not be affected and the plant can be brought to cold shutdown." Per Page PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                Attachment A - NEI 04-02 Table B-1 6 of Letter from NRC to NSP dated 7/31/84, "We agree with the licensee that, although lube oil leakage is collected in the sump before it is pumped to a vented container, the sump design at this plant assures us that oil collected there will not lead to fire during normal or design basis accident conditions. The capacity of the sump and the vented containers is adequate to safely contain any anticipated lube oil leakage and the controls provide reasonable assurance that any lube oil collected in the sump can be safely pumped to the vented container in the auxiliary building. Based on our evaluation, the existing lube oil collection system for reactor coolant pumps provides a level of protection equivalent to the requirements specified in Subsection III.0 of Appendix R. Therefore, the exemption from the requirements specified in Subsection III.0 for the lube oil collection system is granted."
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                         Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title      Requirement/Guidance     Compliance Statement  Compliance Basis 3.3.12(2)                  Reactor Coolant       For facilities with non- Complies via Previous Per Section 4.0 of Procedure F5 Appendix E, "The Pumps                 inerted containments,    Approval              Reactor Coolant Pump Lube Oil Collection System reactor coolant pumps                          is piped to sump A inside containment. The with an external                               contents of the sump can be pumped to closed lubrication system shall                       vented tank(s) inside the Auxiliary Building via two be provided with an oil                        (2) alternative flow pathsThe sump in collection system shall                        the basement of containment is a concrete pit be designed and                                having a capacity of 990 gallons. This is more than installed such that                            the capacity needed to contain the total inventory leakage from the oil                           of lube oil (410 gallons) for the two (2) reactor systems is safely                              coolant pumps for each unitThe sump is contained for off normal                       designed to automatically pump down at a conditions such as                             prescribed sump level and an alarm will sound in accident conditions or                         the Control Room if this level is exceeded. The earthquakes. All of the                        operator can initiate manual control of the sump following shall apply.                         pump(s) at any time by overriding the automatic control of sump level."
(2) Leakage shall be collected and drained to                       Per Page 2 of Attachment 1 of Letter from Musolf a vented closed                                (NSP) to Director (NRC) dated 4/5/84, "In support container that can hold                        of the system as is currently installed it should be the inventory of the                           notedthe lube oil collection system is seismically reactor coolant pump                           designed." Per Page 2 of Attachment lubricating oil system.                        1 of Letter from NSP to NRC dated 4/5/84, "In Plant Documentation                                                                             summary, Northern States Power has made an Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84                                          extensive effort to comply with the requirements of Letter from Musolf (NSP) to Director (NRC) dated 4/5/84                                         Appendix R. In comparing the lube oil collection Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated       system to the requirements of Section III.0 [of 4/29/10                                                                                         Appendix R], concerns were voiced over the use of a closed vented container inside containment Industry-Related References                                                                     because of the need for it to also act as a None                                                                                            collection point for seal leakage. Northern States Power believes that the existing configuration Existing Engineering Equivalency Evaluations (EEEEs)                                            meets the intent of Appendix R in that all lube oil Identifier                    EEEE Description                  Summary                         is collected to a common point which will prevent None                                                                                            its contact with hot piping in the area and is Items for Implementation                                                                        isolated from electrical power cable which might None                                                                                            cause ignition."
Per Page 5 of Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84, "the pipe from the sump to the vented container in the auxiliary building has been designed to seismic category Class III which meets the requirement of Regulatory Guide 1.29, paragraph C-2. If failure of this pipe were to occur during a seismic event, the functions of plant features described in paragraph 1 (a through q) of Regulatory Guide 1.29 will not be affected and the plant can be brought to cold shutdown."
PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota               Attachment A - NEI 04-02 Table B-1 Per Page 6 of Letter from NRC to NSP dated 7/31/84, "We agree with the licensee that, although lube oil leakage is collected in the sump before it is pumped to a vented container, the sump design at this plant assures us that oil collected there will not lead to fire during normal or design basis accident conditions. The capacity of the sump and the vented containers is adequate to safely contain any anticipated lube oil leakage and the controls provide reasonable assurance that any lube oil collected in the sump can be safely pumped to the vented container in the auxiliary building. Based on our evaluation, the existing lube oil collection system for reactor coolant pumps provides a level of protection equivalent to the requirements specified in Subsection III.0 of Appendix R. Therefore, the exemption from the requirements specified in Subsection III.0 for the lube oil collection system is granted."
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.3.12(3)                  Reactor Coolant        For facilities with non-    Complies             Per Procedure D18, Equipment Lubrication, the oil Pumps                  inerted containments,                            in the Reactor Coolant Pumps is Mobil SHC 824.
reactor coolant pumps                            This oil has a flash point of 248&deg;C (478&deg;F),
with an external                                 therefore, a flame arrestor is not needed for this lubrication system shall                         system.
be provided with an oil collection system. The oil collection system shall be designed and installed such that leakage from the oil system is safely contained for off normal conditions such as accident conditions or earthquakes. All of the following shall apply.
(3) A flame arrestor is required in the vent if the flash point characteristics of the oil present the hazard of a fire flashback.
Plant Documentation Procedure D18, "Equipment Lubrication", Rev. 84, dated 12/21/11 Mobil Oil specification sheet, Mobil SHC 824 (http://www.mobil.com/USA-English/Lubes/PDS/GLXXENINDMOMobil_SHC_800.aspx)
Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                      EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title      Requirement/Guidance        Compliance Statement  Compliance Basis 3.3.12(4)                  Reactor Coolant       For facilities with non-    Complies via Previous Per Section 4.0 of Procedure F5 Appendix E, "The Pumps                 inerted containments,       Approval              Reactor Coolant Pump Lube Oil Collection System reactor coolant pumps                             is piped to sump A inside containment. The with an external                                  contents of the sump can be pumped to closed lubrication system shall                          vented tank(s) inside the Auxiliary Building via two be provided with an oil                           (2) alternative flow pathsThe sump in collection system. The                            the basement of containment is a concrete pit oil collection system                             having a capacity of 990 gallons. This is more than shall be designed and                             the capacity needed to contain the total inventory installed such that                               of lube oil (410 gallons) for the two (2) reactor leakage from the oil                              coolant pumps for each unitThe sump is system is safely                                  designed to automatically pump down at a contained for off normal                          prescribed sump level and an alarm will sound in conditions such as                                the Control Room if this level is exceeded. The accident conditions or                            operator can initiate manual control of the sump earthquakes. All of the                           pump(s) at any time by overriding the automatic following shall apply.                            control of sump level."
(4) Leakage points on a                           Per Page 2 of Attachment 1 of Letter from Musolf reactor coolant pump                              (NSP) to Director (NRC) dated 4/5/84, "In support motor to be protected                             of the system as is currently installed it should be shall include but not be                          notedthe lube oil collection system is seismically limited to the lift pump                          designed." Per Page 2 of Attachment and piping, overflow                              1 of Letter from NSP to NRC dated 4/5/84, "In lines, oil cooler, oil fill                       summary, Northern States Power has made an and drain lines and                               extensive effort to comply with the requirements of plugs, flanged                                    Appendix R. In comparing the lube oil collection connections on oil lines,                         system to the requirements of Section III.0 [of and the oil reservoirs,                           Appendix R], concerns were voiced over the use where such features                               of a closed vented container inside containment exist on the reactor                              because of the need for it to also act as a coolant pumps.                                    collection point for seal leakage. Northern States Plant Documentation                                                                                Power believes that the existing configuration Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84                                             meets the intent of Appendix R in that all lube oil Letter from Musolf (NSP) to Director (NRC) dated 4/5/84                                            is collected to a common point which will prevent Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated          its contact with hot piping in the area and is 4/29/10                                                                                            isolated from electrical power cable which might cause ignition."
Industry-Related References None                                                                                               Per Page 5 of Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84, "the pipe from the sump to Existing Engineering Equivalency Evaluations (EEEEs) the vented container in the auxiliary building has Identifier                    EEEE Description                  Summary                            been designed to seismic category Class III which None                                                                                               meets the requirement of Regulatory Guide 1.29, PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                Attachment A - NEI 04-02 Table B-1 Items for Implementation          paragraph C-2. If failure of this pipe were to occur None                              during a seismic event, the functions of plant features described in paragraph 1 (a through q) of Regulatory Guide 1.29 will not be affected and the plant can be brought to cold shutdown." Per Page 6 of Letter from NRC to NSP dated 7/31/84, "We agree with the licensee that, although lube oil leakage is collected in the sump before it is pumped to a vented container, the sump design at this plant assures us that oil collected there will not lead to fire during normal or design basis accident conditions. The capacity of the sump and the vented containers is adequate to safely contain any anticipated lube oil leakage and the controls provide reasonable assurance that any lube oil collected in the sump can be safely pumped to the vented container in the auxiliary building. Based on our evaluation, the existing lube oil collection system for reactor coolant pumps provides a level of protection equivalent to the requirements specified in Subsection III.0 of Appendix R. Therefore, the exemption from the requirements specified in Subsection III.0 for the lube oil collection system is granted."
The RCP Lube Oil Collection System was designed and installed to consider potential leakage points and this design was specifically approved in the NRC SER.
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                         Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title      Requirement/Guidance       Compliance Statement  Compliance Basis 3.3.12(5)                  Reactor Coolant       For facilities with non-   Complies via Previous Per Section 4.0 of Procedure F5 Appendix E, "The Pumps                 inerted containments,      Approval              Reactor Coolant Pump Lube Oil Collection System reactor coolant pumps                            is piped to sump A inside containment. The with an external                                 contents of the sump can be pumped to closed lubrication system shall                         vented tank(s) inside the Auxiliary Building via two be provided with an oil                          (2) alternative flow pathsThe sump in collection system. The                           the basement of containment is a concrete pit oil collection system                            having a capacity of 990 gallons. This is more than shall be designed and                            the capacity needed to contain the total inventory installed such that                              of lube oil (410 gallons) for the two (2) reactor leakage from the oil                             coolant pumps for each unitThe sump is system is safely                                 designed to automatically pump down at a contained for off normal                         prescribed sump level and an alarm will sound in condtions such as                                the Control Room if this level is exceeded. The accident conditions or                           operator can initiate manual control of the sump earthquakes. All of the                          pump(s) at any time by overriding the automatic following shall apply.                           control of sump level."
(5) The collection basin                         Per Page 2 of Attachment 1 of Letter from Musolf drain line to the                                (NSP) to Director (NRC) dated 4/5/84, "In support collection tank shall be                         of the system as is currently installed it should be large enough to                                  notedthe lube oil collection system is seismically accommodate the                                  designed." Per Page 2 of Attachment largest potential oil leak                       1 of Letter from NSP to NRC dated 4/5/84, "In such that oil leakage                            summary, Northern States Power has made an does not overflow the                            extensive effort to comply with the requirements of basin.                                           Appendix R. In comparing the lube oil collection Plant Documentation                                                                               system to the requirements of Section III.0 [of Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84                                            Appendix R], concerns were voiced over the use Letter from Musolf (NSP) to Director (NRC) dated 4/5/84                                           of a closed vented container inside containment Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated         because of the need for it to also act as a 4/29/10                                                                                           collection point for seal leakage. Northern States Power believes that the existing configuration Industry-Related References                                                                       meets the intent of Appendix R in that all lube oil None                                                                                              is collected to a common point which will prevent its contact with hot piping in the area and is Existing Engineering Equivalency Evaluations (EEEEs) isolated from electrical power cable which might Identifier                    EEEE Description                  Summary                           cause ignition."
None Per Page 5 of Letter from Miller (NRC) to Musolf Items for Implementation                                                                          (NSP) dated 7/31/84, "the pipe from the sump to None                                                                                              the vented container in the auxiliary building has been designed to seismic category Class III which meets the requirement of Regulatory Guide 1.29, paragraph C-2. If failure of this pipe were to occur during a seismic event, the functions of plant features described in paragraph 1 (a through q) of Regulatory Guide 1.29 will not be affected and the plant can be brought to cold shutdown." Per Page PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                Attachment A - NEI 04-02 Table B-1 6 of Letter from NRC to NSP dated 7/31/84, "We agree with the licensee that, although lube oil leakage is collected in the sump before it is pumped to a vented container, the sump design at this plant assures us that oil collected there will not lead to fire during normal or design basis accident conditions. The capacity of the sump and the vented containers is adequate to safely contain any anticipated lube oil leakage and the controls provide reasonable assurance that any lube oil collected in the sump can be safely pumped to the vented container in the auxiliary building. Based on our evaluation, the existing lube oil collection system for reactor coolant pumps provides a level of protection equivalent to the requirements specified in Subsection III.0 of Appendix R. Therefore, the exemption from the requirements specified in Subsection III.0 for the lube oil collection system is granted."
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                         Page A Revision 1

Northern States Power - Minnesota                                                                       Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance     Compliance Statement Compliance Basis 3.4                     Industrial Fire      Industrial Fire Brigade. Covered in the sub-  Covered in the sub-sections below Brigade                                       sections below Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description               Summary N/A Items for Implementation None PINGP                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance       Compliance Statement   Compliance Basis 3.4.1                     On-Site Fire-           (a) A fully staffed,        Complies via Previous Per Section 7.16 of Procedure 5AWI 3.13.0, "Fire Fighting Capability     trained, and equipped       Approval              Protection Program," "A plant Fire Brigade shall be Subsection              fire-fighting force shall                         established to provide initial responses to fires 3.4.1(a)                be available at all times                         identified in or threatening main plant structures. A to control and extinguish                         Fire Brigade of five persons shall be on-site at all all fires on site. This                           times in addition to the minimum shift crew force shall have a                                complement needed to safely shut down the minimum complement of                             unit(s)."
five persons on duty and shall conform with the                            Per Technical Specification 6.1-1 (Amendment 39, following NFPA                                    Unit 1; Amendment 33, Unit 2), as identified in standards as                                      Section 6.1.C.6 of letter from Schwencer (NRC) to applicable:                                       Mayer (NSP) dated 9/6/79, "A fire brigade of at least five members shall be maintained on site at (1) NFPA 600, Standard                            all times. Fire brigade composition may be less on Industrial Fire                                than the minimum requirements for a period of Brigades (interior                                time not to exceed 2 hours in order to structural fire fighting)                         accommodate unexpected absence of fire brigade (2) NFPA 1500,                                    members provided immediate action is taken to Standard on Fire                                  restore the fire brigade to within the minimum Department                                        requirements." (This Technical Specification Occupational Safety and                           requirement has since been relocated to Heath Program                                     Procedure 5AWI 3.13.0 as part of the removal of (3) NFPA 1582,                                    fire protection requirements from the Technical Standard on Medical                               Specifications.)
Requirements for Fire Fighters and Information                          The fire brigade has been reviewed against the for Fire Department                               requirements of NFPA 600, as detailed in Fire Physicians.                                       Protection Engineering Evaluation (FPEE) 11-031.
Plant Documentation Letter from Schwencer (NRC) to Mayer (NSP) dated 9/6/79                                             (NFPA 1500 and NFPA 1582 do not apply as the Fleet Procedure FP-G-DOC-04, Procedure Processing, Rev. 9, dated 10/8/09                          plant operates a fire brigade, not a fire Fleet Procedure FP-G-RM-01, Records Management, Rev. 10, dated 2/12/10                            department.)
Fleet Procedure QF-1720, Fitness for Duty Handbook, Rev. 9, dated 2/12/10 Procedure 5AWI 3.11.0, Site Training and Staff Selection, Rev. 29, dated 5/20/11                  The basis for approval has been reviewed. There Procedure 5AWI 3.13.0, Fire Protection Program, Rev. 21, dated 01/05/12                           have been no plant modifications or other changes Procedure 5AWI 10.2.0, Emergency Preparedness, Rev. 18, dated 2/22/10                             that would invalidate the basis for approval.
Procedure 5AWI 10.2.1, Emergency Response Organization, Rev. 1, dated 8/16/07 Procedure F5, Fire Fighting, Rev. 33, dated 4/12/11 Procedure F5 Appendix A, Fire Strategies, Rev. 27, dated 11/17/11 Procedure F5 Appendix F, Fire Hazard Analysis, Rev. 25A, dated 8/8/11 Procedure F5 Appendix J, Fire Drills, Rev. 14, dated 9/13/10 Technical Training R7600W-0501, Nuclear Fire Brigade Practical, Rev. 0, dated 12/19/07 FPEE-11-031, NFPA 600, Standard on Industrial Fire Brigades, 2000, Revision 1 Industry-Related References FAQ 06-0007, "NFPA 805 Section 3.4.1, Specific Clarification," Rev. 2, dated 5/21/07 NFPA 600, "Standard on Industrial Fire Brigades," 2000 Edition FAQ 12-0063, "Fire Brigade Makeup," Revision 1, July 31, 2012 PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                            Attachment A - NEI 04-02 Table B-1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description          Summary None Items for Implementation None PINGP                                                                   Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.4.1                    On-Site Fire-          (b) Industrial fire brigade Complies             Per Section 7.16 of Procedure 5AWI 3.13.0, "Fire Fighting Capability    members shall have no                            Protection Program," fire brigade members are not Subsection 3.4.1(b)    other assigned normal                            required to perform safe shutdown activities.
plant duties that would                          The section states, "A Fire Brigade of five persons prevent immediate                                shall be on-site at all times in addition to the response to a fire or                            minimum shift crew complement needed to safely other emergency as                               shut down the unit(s)."
required.
Plant Documentation                                                                              Per Section 5.5.1(c)(2) of Fleet Procedure CD Fleet Procedure CD 5.13, "Fire Protection Program Standard," Rev. 3, dated 2/4/09                5.13, "Fire Protection Program Standard,"
Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12                        "Industrial Fire Brigade members shall have no other assigned normal plant duties that would Industry-Related References                                                                      prevent immediate response to a fire or other FAQ 12-0063, "Fire Brigade Makeup," Revision 1, July 31, 2012                                    emergency as required."
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.4.1                     On-Site Fire-           (c) During every shift,   Complies             Per Section 5.5.1(c)(3) of Fleet Procedure CD Fighting Capability     the brigade leader and                         5.13, "Fire Protection Program Standard," "During Subsection 3.4.1 (c)    at least two brigade                           every shift, the Fire Brigade leader and at least members shall have                             two brigade members shall have sufficient training sufficient training and                        and knowledge of nuclear safety systems to knowledge of nuclear                           understand the effects of fire and fire safety systems to                              suppressants on those systems."
understand the effects of fire and fire                                  Per Section 7.16 of Procedure 5AWI 3.13.0, "Fire suppressants on nuclear                        Protection Program," "The Fire Brigade leader safety performance                             shall be competent to assess the potential safety criteria.                                      consequences of a fire and advise Control Room personnel. Such competence by the Fire Brigade Exception to (c):                              leader may be evidenced by possession of an Sufficient training and                        Operators license or equivalent knowledge of knowledge shall be                             plant safety related systems."
permitted to be provided by an operations advisor                       Sections 4.8.3(A) and 4.8.3(B) of Procedure F5, dedicated to industrial                        "Fire Fighting," details the training requirements fire brigade support.                          for all fire brigade members, which includes the Plant Documentation                                                                              identification and location of fire hazards Fleet Procedure CD 5.13, "Fire Protection Program Standard," Rev. 3, dated 2/4/09                throughout the plant, as well as the various Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12                        methods for fighting fires.
Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.4.1                     On-Site Fire-           (d) The industrial fire   Complies             Per Section 4.6 of Procedure F5, "Fire Fighting,"
Fighting Capability     brigade shall be notified                      the fire brigade members are notified of a fire Subsection 3.4.1(d)     immediately upon                               incident via a "Fire Alarm page" which is sent by verification of a fire.                        the Control Room Operator. Per Section 1.2.6 of Plant Documentation                                                                              Procedure F5, the Fire Brigade Auto Paging Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                            system automatically pages all required fire brigade responders and support personnel for fire Industry-Related References                                                                      scene command and control. The auto paging None                                                                                             system would be actuated immediately from the Unit 1 Lead, Unit 2 Lead, Unit 1 Shift Supervisor, Existing Engineering Equivalency Evaluations (EEEEs) and/or Unit 2 Shift Supervisor telephones upon Identifier                     EEEE Description                  Summary                         verification of a fire in the plant.
None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.4.1                     On-Site Fire-           (e) Each industrial fire Complies             Per Section 4.8.1 of Procedure F5, "Fire Fighting,"
Fighting Capability     brigade member shall                          "All new members of the Fire Brigades shall have Subsection 3.4.1(e)     pass an annual physical                       an initial physical examination for strenuous examination to                                physical activity as experienced in fire determine that he or she                      fighting...Follow-up physical examinations shall be can perform the                               conducted annually for all Fire Brigade members strenuous activity                            (i.e., every 9 to 15 months, provided that three required during manual                        consecutive exams do not exceed 39 firefighting operations.                      months)...Initial and follow-up physical The physical                                  examinations shall include respiratory protection examination shall                             qualification testing which screens all respirator determine the ability of                      users (including Fire Brigade members for each member to use                            cardiopulmonary deficiencies)...Physical respiratory protection                        examinations shall be conducted by a physician."
equipment.
Plant Documentation Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                       Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title         Requirement/Guidance Compliance Statement Compliance Basis 3.4.2                   Pre-Fire Plans           Current and detailed pre- Complies        Procedure F5 Appendix A, "Fire Strategies,"
fire plans shall be                       details each area's layout, hazards, fire protection available to the industrial               features, communications capability, and fire brigade for all areas                equipment control in its pre-fire plan.
in which a fire could jeopardize the ability to meet the performance criteria described in Section 1.5.
Plant Documentation Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                 Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title         Requirement/Guidance    Compliance Statement Compliance Basis 3.4.2.1                 Pre-Fire Plans           The plans shall detail  Complies             Procedure F5 Appendix A, "Fire Strategies,"
the fire area                                details each area's layout, hazards, fire protection configuration and fire                       features, communications capability, and hazards to be                                equipment control in its pre-fire plan.
encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are Plant Documentation                              present.
Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                    Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.4.2.2                  Pre-Fire Plans          Pre-fire plans shall be     Complies             Section 1.0 of Procedure 5AWI 3.13.1, "Fire reviewed and updated                             Protection Review of Modifications," states, "This as necessary.                                    Instruction establishes the process for reviewing Plant Documentation                                                                               modifications (engineering changes, equivalency Fleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 9, dated 10/8/09.                       changes, design changes, temporary Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05         modifications, etc.) at PINGP. The review ensures Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11                               that the fire protection requirements are included.
It also ensures adequate evaluation and Industry-Related References                                                                       documentation of the type and quantity of None                                                                                              combustible loading in each fire area."
Existing Engineering Equivalency Evaluations (EEEEs)
Section 1.1 of Fleet Procedure FP-G-DOC-04, Identifier                   EEEE Description                  Summary                            "Procedure Processing," states "The purpose of None                                                                                              this procedure is to establish a common process for Items for Implementation                                                                          initiation, revision, review, and approval of the None                                                                                              following document types (listed according to Document Hierarchy): Corporate Directives; Fleet Program/Process Descriptions, Codes of Conduct; Fleet Procedures; Centralized Department Procedures, Corporate Office Procedures; Site Procedures; Forms (that are independent of procedures)"
The Pre-Fire Plans are maintained in Procedure F5 Appendix A, "Fire Strategies." This document is controlled, reviewed, and revised through Procedure FP-G-DOC-04 or as required by Procedure 5AWI 3.13.1.
PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title       Requirement/Guidance     Compliance Statement Compliance Basis 3.4.2.3                     Pre-Fire Plans         Pre-fire plans shall be  Complies             Per Section 5.20 of Fleet Procedure FP-G-CD-01, available in the control                      "Controlled Documents," distribution of controlled room and made                                 documents is performed using the PASSPORT available to the plant                        computer module. Procedure F5 Appendix A, "Fire industrial fire brigade.                      Strategies," is distributed to the Control Room Plant Documentation                                                                              through this computer module.
PINGP 1676, Fire Drill Critique Report Rev 1,                                                  Per Section 4.3.3 of F5 Appendix J, PINGP 1676 F5 Appendix J, Fire Drills, Rev 16, dated 7/29/13                                              SHALL be used as the drill report and as an Procedure FP-G-CD-01, "Controlled Documents," Rev. 4, dated 2/27/09                              objective evaluation checklist for all fire drills that are conducted.
Industry-Related References None                                                                                             PINGP 1676, Fire Drill Critique Report Rev 1, states Was a copy of Fire Strategies information available and utilized?
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                      EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.4.2.4                   Pre-Fire Plans          Pre-fire plans shall     Complies             Fire brigade coordination with other plant groups address coordination                          during fire emergencies is not addressed in with other plant groups                       individual pre-fire plans. However, Procedure F5, during fire emergencies.                      "Fire Fighting," the parent document to Procedure Plant Documentation                                                                             F5 Appendix A, "Fire Strategies," addresses Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                           coordination with non-fire brigade groups (e.g.,
Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11                             security, operations) during fire events. Per Section 1.0, "The purpose of this section is to Industry-Related References                                                                     provide specific instructions on the organization of None                                                                                            fire brigades, individual responsibilities in regard to fires, and procedures for extinguishing fires."
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.4.3                      Training and Drills    Industrial fire brigade     Complies            The fire brigade has been reviewed against the Subsection             members and other                               requirements of NFPA 600, as detailed in Fire 3.4.3(a), "Plant       plant personnel who                             Protection Engineering Evaluation (FPEE) 11-031.
Industrial Fire        would respond to a fire                         (NFPA 1500 does not apply as the plant operates a Brigade Training,"     in conjunction with the                         fire brigade, not a fire department.)
Section (1)            brigade shall be provided with training commensurate with their emergency responsibilities.
(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply:
(1) Plant industrial fire brigade members shall receive training consistent with the requirements contained in NFPA 600, Standard on Industrial Fire Brigades, or NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, as appropriate.
Plant Documentation Fleet Procedure FP-G-DOC-04, Procedure Processing, Rev. 9, dated 10/8/09.
Fleet Procedure FP-G-RM-01, Records Management, Rev. 10, dated 2/12/10 Fleet Procedure QF-1720, Fitness for Duty Handbook, Rev. 9, dated 2/12/10 Procedure 5AWI 3.11.0, Site Training and Staff Selection, Rev. 29, dated 5/20/11 Procedure 5AWI 3.13.0, Fire Protection Program, Rev. 21, dated 01/05/12 Procedure 5AWI 10.2.0, Emergency Preparedness, Rev. 18, dated 2/22/10 Procedure 5AWI 10.2.1, Emergency Response Organization, Rev. 1, dated 8/16/07 Procedure F5, Fire Fighting, Rev. 33, dated 4/12/11 Procedure F5 Appendix A, Fire Strategies, Rev. 27, dated 11/17/11 Procedure F5 Appendix F, Fire Hazard Analysis, Rev. 25A, dated 8/8/11 Procedure F5 Appendix J, Fire Drills, Rev. 14, dated 9/13/10 Technical Training R7600W-0501, Nuclear Fire Brigade Practical, Rev. 0, dated 12/19/07 FPEE-11-031, Revision 1 Industry-Related References FAQ 06-0007, "NFPA 805 Section 3.4.1, Specific Clarification," Rev. 2, dated 5/21/07 NFPA 600, "Standard on Industrial Fire Brigades," 2000 Edition PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                            Attachment A - NEI 04-02 Table B-1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description          Summary None Items for Implementation None PINGP                                                                   Page A Revision 1

Northern States Power - Minnesota                                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance       Compliance Statement  Compliance Basis 3.4.3                      Training and Drills    Industrial fire brigade    Complies via Previous Per Section 4.8.3 of Procedure F5, "Fire Fighting,"
Subsection             members and other          Approval              the fire brigade training program includes 3.4.3(a), "Plant       plant personnel who                              instruction on general plant access, fire fighting Industrial Fire        would respond to a fire                          tactics and hazards, use of fire fighting equipment, Brigade Training,"     in conjunction with the                          and radiation and contamination considerations.
Section (2)            brigade shall be provided with training                           Per Section 1.2.1 of Procedure F5 Appendix J, commensurate with their                          "Fire Drills," "Fire drills shall be scheduled so that emergency                                        each Fire Brigade participates in at least four (4) responsibilities.                                fire drills per year. Drills should be performed at regular intervals with one (1) drill per calendar (a) Plant Industrial Fire                        quarter for each Fire Brigade."
Brigade Training. All of the following                                    NSP letter dated 5/2/1979, Section 4.1 states that requirements shall                               "Drills will be scheduled so that each fire brigade apply. (2) Industrial fire                       member will participate in at least two drills per brigade members shall                            year."
be given quarterly training and practice in                         NRC SER dated 9/6/1979 references the 5/2/1979 fire fighting, including                         NSP letter and concludes per Section 6.2 that "the radioactivity and health                         fire brigade training program conforms to the physics considerations,                          provisions of Appendix A to BTP 9.5-1 and is, to ensure that each                              therefore, acceptable."
member is thoroughly familiar with the steps to                       The basis for approval has been reviewed. There be taken in the event of                         have been no plant modifications or other changes a fire.                                          that would invalidate the basis for approval.
Plant Documentation Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 NSP letter dated 5/2/1979, "Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls, and Quality Assurance" NRC SER dated 9/6/1979, "Fire Protection Safety Evaluation Report" Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                             Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.4.3                     Training and Drills     Industrial fire brigade   Complies             Section 4.8.3 of Procedure F5, "Fire Fighting,"
Subsection              members and other                              details the industrial fire brigade training program.
3.4.3(a), "Plant        plant personnel who Industrial Fire         would respond to a fire Brigade Training,"      in conjunction with the Section (3)             brigade shall be provided with training commensurate with their emergency responsibilities.
(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply. (3) A written program shall detail the industrial fire brigade training program.
Plant Documentation Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.4.3                    Training and Drills   Industrial fire brigade    Complies             Per Section 8.8 of Procedure 5AWI 3.13.0, "Fire Subsection            members and other                               Protection Program," "Classroom training 3.4.3(a), "Plant      plant personnel who                             sessions, practice sessions, and drills for the Industrial Fire       would respond to a fire                         brigade shall be documented" Brigade Training,"    in conjunction with the Section (4)           brigade shall be                                Per Section 17.5, individual fire brigade training provided with training                          records, drills, practices, and critiques are commensurate with their                         maintained in accordance with Fleet Procedure emergency                                       FP-G-RM-01, Records Management.
responsibilities.
(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply. (4) Written records that include but are not limited to initial industrial fire brigade classroom and hands-on training, refresher training, special training schools attended, drill attendance records, and leadership training for industrial fire brigades shall be maintained for each industrial fire brigade member.
Plant Documentation Fleet Procedure FP-G-RM-01, "Records Management," Rev. 9, dated 2/12/10 Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.4.3                     Training and Drills     Industrial fire brigade     Complies             Per Section 8.11 of Procedure 5AW I 3.13.0, "Fire Subsection              members and other                                Protection Program," "Level I (A) fire protection 3.4.3(b), "Training     plant personnel who                              training shall be general training given to for Non-Industrial      would respond to a fire                          operations and mechanical maintenance Fire Brigade            in conjunction with the                          personnel. The training shall include:...Basic Personnel"              brigade shall be                                 principles of fire chemistry and physics...Fire provided with training                           hazards...Fire detection systems...Types of commensurate with their                          extinguishing systems...Special fire hazards emergency                                        associated with nuclear power[and] Emergency responsibilities.                                planning with emphasis on fire emergency" (b) Training for Non-                            Section 2.7 of Procedure F5, "Fire Fighting,"
Industrial Fire Brigade                          provides a description of the responsibilities of Personnel. Plant                                 non-operations personnel, such as radiation personnel who respond                            protection, security, and nuclear plant service with the industrial fire                         personnel, when responding to fires with the fire brigade shall be trained                         brigade.
as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12 Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                    Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title          Requirement/Guidance          Compliance Statement Compliance Basis 3.4.3                   Training and Drills       Industrial fire brigade       Complies             Per Section 1.2.1 of Procedure F5 Appendix J, Subsection                members and other                                  "Fire Drills," "Fire drills shall be scheduled so that 3.4.3(c), "Drills,"       plant personnel who                                each Fire Brigade participates in at least four (4)
Section (1)               would respond to a fire                            fire drills per year...Drills should be performed at in conjunction with the                            regular intervals with one (1) drill per calendar brigade shall be                                   quarter for each Fire Brigade."
provided with training commensurate with their emergency responsibilities.
(c) Drills. All of the following requirements shall apply. (1) Drills shall be conducted quarterly for each shift to test the response capability of the industrial fire brigade.
Plant Documentation Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                     Summary None Items for Implementation None PINGP                                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title      Requirement/Guidance        Compliance Statement Compliance Basis 3.4.3                       Training and Drills   Industrial fire brigade     Complies             Per Section 8.8 of Procedure 5AW I 3.13.0, "Fire Subsection            members and other                                Protection Program," fire drills are used to 3.4.3(c), "Drills,"   plant personnel who                              determine the fire brigade's ability to "operate as a Section (2)           would respond to a fire                          team."
in conjunction with the brigade shall be                                 Per Section 1.2.3 of Procedure F5 Appendix J, provided with training                           "Fire Drills," "To the extent practical, Fire Brigade commensurate with their                          members shall use protective equipment, emergency                                        suppression systems, and other equipment used responsibilities.                                to fight an actual fire during the drills."
(c) Drills. All of the                           Per Section 4.2.1, "The drill should be conducted following requirements                           with as much realism as possible. Fire Brigade shall apply.                                     members should respond as expeditiously as they would in the event of an actual fire."
(2) Industrial fire brigade drills shall be developed                        Per Section 4.2.2, "The scenario used for the drill to test and challenge                            shall be included in the fire drill report."
industrial fire brigade response, including                              Per Section 4.2.3, "PINGP 1676 shall be used as brigade performance as                           the drill objectives and as an objective evaluation a team, proper use of                            checklist for all fire drills that are conducted."
equipment, effective use of pre-fire plans, and                           Per Section 4.2.5, "A critique shall be conducted coordination with other                          as soon as possible after the fire drill is terminated.
groups. These drills                             All items discussed during the critique shall be shall evaluate the                               included in the fire drill report."
industrial fire brigade's abilities to react,                              PINGP 1676, "Fire Drill Critique Report" respond, and                                     specifically includes an evaluation/critique of demonstrate proper fire-                         brigade performance as a team, proper use of fighting techniques to                           equipment, effective use of pre-fire plans, and control and extinguish                           coordination with other groups.
the fire and smoke conditions being simulated by the drill scenario.
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12 Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 PING 1676, "Fire Drill Critique Report" Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                      EEEE Description                  Summary None PINGP                                                                                                                              Page A Revision 1

Northern States Power - Minnesota Attachment A - NEI 04-02 Table B-1 Items for Implementation None PINGP                                        Page A Revision 1

Northern States Power - Minnesota                                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance         Compliance Statement          Compliance Basis 3.4.3                     Training and Drills     Industrial fire brigade      Complies with Item for        Procedure F5 Appendix J, "Fire Drills will be Subsection              members and other            Implementation                revised to include that fire drills will be conducted in 3.4.3(c), "Drills,"     plant personnel who                                        various plant areas.
Section (3)             would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.
(c) Drills. All of the following requirements shall apply.
(3) Industrial fire brigade drills shall be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards.
Plant Documentation Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                    Summary None Items for Implementation As described in Table S-3, item #3, Procedure F5 Appendix J, "Fire Drills," will be revised to require that fire brigade drills be conducted in various plant areas.
PINGP                                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.4.3                     Training and Drills     Industrial fire brigade     Complies             Details of the drill are recorded per PINGP 1676, Subsection              members and other                                "Fire Drill Critique Report".
3.4.3(c), "Drills,"     plant personnel who Section (4)             would respond to a fire                          Per Section 5.1 of Procedure F5 Appendix J, "Fire in conjunction with the                          Drills," "Documentation of drills and practices shall brigade shall be                                 be maintained in accordance with FP-G-RM-01, provided with training                           Records Management, for two (2) years."
commensurate with their emergency responsibilities.
(c) Drills. All of the following requirements shall apply.
(4) Drill records shall be maintained detailing the drill scenario, industrial fire brigade member response, and ability of the industrial fire brigade to perform as a team.
Plant Documentation Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 PINGP 1676, "Fire Drill Critique Report" Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance    Compliance Statement Compliance Basis 3.4.3                     Training and Drills     Industrial fire brigade Complies             Per Section 4.2.5 of Procedure F5 Appendix J, Subsection              members and other                            "Fire Drills," "A critique shall be conducted as 3.4.3(c), "Drills,"     plant personnel who                          soon as possible after the fire drill is terminated.
Section (5)             would respond to a fire                      All items discussed during the critique shall be in conjunction with the                      included in the fire drill report."
brigade shall be provided with training                       PINGP 1676, "Fire Drill Critique Report", includes commensurate with their                      the fire drill scenario and fire drill critique.
emergency responsibilities.
(c) Drills. All of the following requirements shall apply. (5) A critique shall be held and documented after each drill.
Plant Documentation PINGP 1676, "Fire Drill Critique Report" Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                   Summary None Items for Implementation None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.4.4                     Fire-Fighting           Protective clothing,     Complies             Table 1 of Procedure F5, "Fire Fighting,"
Equipment               respiratory protective                        establishes a list of personal protective clothing equipment, radiation                          and equipment which are available for the fire monitoring equipment,                         brigade at several locations throughout the plant.
personal dosimeters,                          The equipment includes SCBA, turnout gear, fire and fire suppression                          hose and nozzles, smoke ejectors, emergency equipment such as                             lighting, communications equipment, spanner hoses, nozzles, fire                          wrenches, and other such tools.
extinguishers, and other needed equipment shall                        Per Section 7.2.2, in the event of a radioactive fire be provided for the                           incident, fire brigade members are required to industrial fire brigade.                      "Obtain a dosimeter."
This equipment shall conform with the                              Per Section 6.1 of Procedure RPIP 1101, "TLD applicable NFPA                               Issue," a TLD is issued "to any worker entering standards.                                    the Radiologically Controlled Area (RCA)"
Plant Documentation Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12                       Per Section 7.5.9 of Procedure 5AWI 3.13.0, "Fire Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                           Protection Program," the fire protection Procedure RPIP 1101, "TLD Issue," Rev. 20, dated 2/6/09                                         coordinator is responsible for "procuring, FP-RP-DP-0, Rev. 4, "Dosimetry Program"                                                         inspecting, and maintaining fire brigade equipment in accordance with applicable NFPA Industry-Related References                                                                     requirements."
NFPA 600, "Standard on Industrial Fire Brigades," 2000 Edition FP-RP-DP-01, "Dosimetry Program", Section 3.5.
Existing Engineering Equivalency Evaluations (EEEEs) lists the responsibilities of personnel issued a Identifier                     EEEE Description                  Summary                        TLD. PINGP General Employee Training instructs None                                                                                            employees to wear their TLDs at all times when on site.
Items for Implementation None                                                                                            Per Section 1.2.5 of procedure F5, Fire Fighting, All SCBA devices SHALL be approved by NIOSH and MSHA with a minimum duration of 30 minutes.
PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                       Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance     Compliance Statement Compliance Basis 3.4.5                   Off-Site Fire        Off-Site Fire Department Covered in the sub-  Covered in the sub-sections below Department           Interface.               sections below Interface Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description              Summary N/A Items for Implementation N/A PINGP                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.4.5.1                   Off-Site Fire           Off-site fire authorities  Complies             Per Section 6.1 of Procedure F5, "Fire Fighting,"
Department              shall be offered a plan                         "The primary off site fire department (Red W ing Interface               for their interface during                      Fire Department) shall provide emergency Mutual Aid              fires and related                               assistance and shall be called immediately on Agreement               emergencies on site.                            report of fire."
Plant Documentation Procedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010                                      Per Section 6.2, "Upon arrival, the RWFD shall Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                             have primary responsibility for extinguishing the fire...The RWFD may call other mutual aid Industry-Related References                                                                       Departments in the local area for assistance, if None                                                                                              necessary."
Existing Engineering Equivalency Evaluations (EEEEs)
Per Section 5.6.4.A of Procedure E-PLAN, Identifier                     EEEE Description                  Summary                          "Emergency Plan," "The Red Wing Fire None                                                                                              Department will provide assistance in the event of Items for Implementation                                                                          a fire occurring at the plant."
None PINGP                                                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title          Requirement/Guidance Compliance Statement Compliance Basis 3.4.5.2                 Off-Site Fire             Fire fighters from the off- Complies      Per Section 6.4.1 of Procedure 5AWI 3.11.0, "Site Department                site fire authorities who                 Training and Staff Selection," "The Emergency Interface                 are expected to respond                   Preparedness (EP) Manager maintains and Site-Specific             to a fire at the plant shall              implements an emergency preparedness training Training                  be offered site-specific                  plan for...local fire departments...that provide training and shall be                     primary support services to the site and its invited to participate in a               personnel."
drill at least annually.
Plant Documentation                                                                         Per Section 1.2.1.C of Procedure F5 Appendix J, Procedure 5AWI 3.11.0, "Site Training and Staff Selection," Rev. 29, dated 5/20/11          "Fire Drills," "A drill involving the local on-duty fire Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12                   department shall be done at least once per year.
Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10                              Credit may be taken for the annual drill if the local fire department responds to a site fire emergency Industry-Related References                                                                 or participates in training at PINGP or with the fire None                                                                                        brigade."
Existing Engineering Equivalency Evaluations (EEEEs)
Per Section 7.5.6 of Procedure 5AWI 3.13.0, "Fire Identifier                   EEEE Description                     Summary                   Protection Program," The site Fire Protection None                                                                                        Coordinator establishes "coordination with the Items for Implementation                                                                    local fire department, including joint drill and None                                                                                        training sessions to familiarize fire department personnel with plant access routes, layout, equipment and special hazards.
PINGP                                                                                                                      Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.4.5.3                   Off-Site Fire           Plant security and       Complies             Per Section 2.7 of Procedure F5, "Fire Fighting,"
Department              radiation protection                          "Security is responsible to escort the off-site Fire Interface               plans shall address off-                      Department personnel and vehicle on to plant Security and            site fire authority                           property, through the security gate to the building Radiation Protection    response.                                     door selected by brigade chief for entry."
Plant Documentation Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                           Per Section 6.2, "Upon arrival, the RWFD Shall have primary responsibility for extinguishing the Industry-Related References                                                                     fire...Anti-C clothing should be provided by None                                                                                            radiation protection personnel, if required.
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title     Requirement/Guidance     Compliance Statement Compliance Basis 3.4.6                    Communications       An effective emergency   Complies             Per Section 10.3.8 of the USAR, "A fixed public communications                                address system interfaced with a UPS powered capability shall be                           Private Branch Exchange (PBX) telephone system provided for the                              provide normal and emergency communications.
industrial fire brigade.                      In the event of a PBX failure, power fail telephone Plant Documentation                                                                         stations from the local telephone office and Procedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010                                extensions operating on the Xcel Energy Sherco Updated Safety Analysis Report (USAR) Section 10, Rev. 32P                                  Plant Telephone Switch could be utilized to conduct emergency communications. In addition, Industry-Related References                                                                 a sound powered communications system is None                                                                                        installed with communications jacks located throughout the plant. The sound powered system Existing Engineering Equivalency Evaluations (EEEEs) requires no external power, and headsets for use Identifier                  EEEE Description                 Summary                        with the system are readily available.
None                                                                                        ...The site radio system utilizes hand-held portable radios, mobile radios, and stationary radio consoles Items for Implementation                                                                    to facilitate two way communications None                                                                                        between out-plant personnel and control points such as the Control Room, Central Alarm Station, or Technical Support Center. The radio transmitters and the radio system controller are powered by the interruptible a-c system with backup transmitters located outside the plant in the Guardhouse and Microwave building."
Per Sections 7.2.1 and 7.2.2 of Procedure E-PLAN, "Emergency Plan," "All emergency operating facilities have at least two means of communications: (1) portable or installed radio systems; and (2) normal telephone communications.
                                                                                            ...The normal onsite communications during an emergency will be made via the plant telephone system with a public address system option. The telephone system is powered by non-interruptible power. The public address system includes about 175 loudspeakers located throughout the entire plant area.
A separate paging system has 20 handsets located at strategic plant areas.
                                                                                            ...Designated members of the sites emergency organization carry personal pagers which can be activated from the Technical Support Center. A special emergency code is displayed on the pager."
PINGP                                                                                                                   Page A Revision 1

Northern States Power - Minnesota                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance Compliance Statement Compliance Basis 3.5                     Water Supply        Water Supply.        Covered in the sub-  Covered in the sub-sections below sections below Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description            Summary N/A Items for Implementation N/A PINGP                                                                                                          Page A Revision 1

Northern States Power - Minnesota                                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance        Compliance Statement    Compliance Basis 3.5.1                   Water Supply            A fire protection water     Complies via Previous   The Mississippi River is capable of supplying a supply of adequate          Approval; Complies with virtually unlimited amount of water. Per Section reliability, quantity, and                          4.3.1.1 of NRC SER dated 9/6/79, "Water for fire Item for Implementation protection is from the Mississippi River through the duration shall be                                   intake canal. The water is drawn by fire pumps provided by one of the                              located in the screen house. A secondary water two following methods.                              supply is available through the cooling water system emergency intake pipe via crossovers to the fire (a) Provide a fire                                  mains.
protection water supply                             "We find the water supply meets the objectives of not less than two                                identified in Section 2.2 of this report and is, separate 300,000-gal                                therefore, acceptable."
(1,135,500-L) supplies.                             Per Section 4.1 of Plant Procedure F5 Appendix F, "Fire Hazard Analysis," "Water for fire protection (b) Calculate the fire flow                         system is from the Mississippi River through the rate for 2 hours. This                              intake canal. The water is drawn by two horizontal fire flow rate shall be                             shaft centrifugal fire pumps each with a design based on 500 gpm                                    capacity of 2,000 gpm at a pressure (1892.5 L/min) for                                  125 psi."
manual hose streams                                 Per Section 7.3 of Procedure F5 Appendix K, "Fire plus the largest design                             Protection Systems Functional Requirements," "The demand of any sprinkler                             fire protection water system is supplied from the or fixed water spray                                Mississippi River by two horizontal centrifugal fire system(s) in the power                              pumps rated at 2,000 gpm at 125 psig."
block as determined in accordance with NFPA                                As stated in Section 3.5.3, of this attachment, the 13, Standard for the                                largest design demand of any sprinkler or fixed water spray system determined in accordance with Installation of the                                 NFPA 13 and NFPA 15 is a transformer system with Sprinkler Systems, or                               a demand of 1534 gpm (including a hose allowance NFPA 15, Standard for                               of 500 gpm). Therefore, water quantity required for 2 Water Spray Fixed                                   hour supply is 184,080 gallons. The Mississippi Systems for Fire                                    River is capable of supplying this water quantity.
Protection. The fire water supply shall be                               A calculation to demonstrate that the fire water supply is capable of delivering the largest design capable of delivering this                          demand with the hydraulically least demanding design demand with the                              portion of fire main loop out of service is an item for hydraulically least                                 implementation and identified in Attachment S, demanding portion of                                Table S-3 item #4.
fire main loop out of Plant Documentation                             service.
NRC SER dated 9/6/79 Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012 Industry-Related References None PINGP                                                                                                                           Page A Revision 1

Northern States Power - Minnesota                                                                                        Attachment A - NEI 04-02 Table B-1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                 Summary None Items for Implementation As described in Table S-3, item #4, a calculation to demonstrate that the fire water supply is capable of delivering the largest design demand with the hydraulically least demanding portion of fire main loop out of service will be performed.
PINGP                                                                                                                               Page A Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.5.2                   Water Supply            The tanks shall be         Complies             Complies with Exception No. 1.
interconnected such that fire pumps can take                             Per Section 4.1 of Procedure F5 Appendix F, suction from either or                          "Fire Hazard Analysis," Water for fire both. A failure in one                          protection system is from the Mississippi River tank or its piping shall                        through the intake canal.
not allow both tanks to                         "The electric motor-driven fire pump and the drain. The tanks shall                          diesel engine-driven fire pump are located at the be designed in                                  east side of the screenhouse separated by a accordance with NFPA                            distance of approximately 20 feet. A three-hour 22, Standard for Water                          rated fire barrier is provided around the electric Tanks for Private Fire                          motor-driven fire pump."
Protection.
Therefore, PINGP is in compliance with Exception Exception No. 1: Water                          No. 1 to this requirement.
storage tanks shall not be required when fire                           Per Section 7.3 of Procedure F5 Appendix K, "Fire pumps are able to take                          Protection Systems Functional Requirements,"
suction from a large                            "The fire protection water system is supplied from body of water (such as a                        the Mississippi River" lake), provided each fire pump has its own suction and both suctions and pumps are adequately separated.
Exception No. 2: Cooling tower basins shall be an acceptable water source for fire pumps when the volume is sufficient for both purposes and water quality is consistent with the demands of the fire service.
Plant Documentation Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None PINGP                                                                                                                        Page A Revision 1

Northern States Power - Minnesota Attachment A - NEI 04-02 Table B-1 Items for Implementation None PINGP                                        Page A Revision 1

Northern States Power - Minnesota                                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title       Requirement/Guidance            Compliance Statement   Compliance Basis 3.5.3                       Water Supply           Fire pumps, designed            Complies with use of   Per Section 4.1.1 of Procedure F5 Appendix F, and installed in                Existing Engineering   "Fire Hazard Analysis," "W ater for fire protection accordance with NFPA            Equivalency Evaluation system is from the Mississippi River through the 20, Standard for the                                   intake canal. The water is drawn by two horizontal Installation of Stationary                             shaft centrifugal fire pumps each with a design Pumps for Fire                                         capacity of 2,000 gpm at a pressure 125 psi. One Protection, shall be                                   of the fire pumps is diesel engine-driven and the provided to ensure that                                other is electric motor-driven. A third pump, electric 100 percent of the                                     motor-driven also having a capacity of required flow rate and                                 2000 gpm at a pressure of 125 psi normally pressure are available                                 assigned to the screen wash function can be assuming failure of the                                aligned to pump into the fire water system. On largest pump or pump                                   loss of offsite AC power, the diesel driven pump power source.                                          will be available to supply water to the fire Plant Documentation                                                                                       protection system."
Code Compliance Review NFPA 20-1969, "NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1969, Code Compliance Review," Rev. 1 dated 6/1/2010                              Per Section 7.3 of Procedure F5 Appendix K, "Fire Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                                   Protection Systems Functional Requirements," The Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated                fire protection water system is supplied from the 4/11/2012                                                                                                 Mississippi River by two horizontal centrifugal fire Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire                       pumps rated at 2,000 gpm at 125 psig. One pump Protection System," dated 9/15/70                                                                         is motor driven and the other pump is diesel driven.
The 10 fire header is maintained between Industry-Related References                                                                               110 and 113 psig by a jockey pump. The jockey NFPA 20, "Standard for the Installation of Centrifugal Fire Pumps," 1969 Edition                          pump does not supply water to the header. If the water demand is such that the jockey pump Existing Engineering Equivalency Evaluations (EEEEs) cannot maintain the header pressure, the screen Identifier                     EEEE Description                  Summary                                  wash pump will start (if not running). The screen AR 1189183 Fire                Fire pumps are tested every        EEEE Bases for Acceptibility            wash pump, which is rated at 2000 gpm at 125 Protection Engineering         18 months, while NFPA 20           "1. System Design: The                  psig, provides water to the fire header when the Evaluation Code                requires that they be tested       redundancy provided by the              bypass valve opens at 106 psig. However the Compliance Deviations,         annually. Based on the             three pumps will more than              screenwash pump has a bypass line which is Rev. 1, "NFPA 20,              design of the fire pumps and       compensate for the potential            orificed to restrict flow to 450 gpm to the fire Standard for the               the fire water system, the 18      failure of one pump to perform          header. The screen wash pump may be directly Installation of Centrifugal    month test frequency               as intended. If debris caused           aligned to the fire header by a manual action from Fire Pumps, 1969, Code         currently used by PINGP is         one pump to be disabled, two            the Control Room in order to provide the rated Compliance Review,"            deemed adequate. Code              other pumps are available.              2,000 gpm at 125 psig. Due to the required manual dated 6/1/2010.                Compliance                         Since any single pump can               action, this pump can not be credited as a Review                             satisfy the largest demand,             primary fire pump. The motor driven fire pump will sufficient firewater is expected        automatically start at 98 psig. If the header to be available at all times.           pressure to drops to 93 psig, the diesel-driven fire pump will start. The motor and diesel-driven fire
: 2. Additional Tests: In addition        pumps are designed to pump 2,000 gpm and to the 18 month performance             maintain a minimum of 65 psig in the fire header, tests, the fire pumps are also          measured at the highest point in the system. The tested weekly and/or monthly.           motor driven fire pump, diesel-driven fire pump, Performance of these tests              and the manually-aligned screenwash pump can would provide indication of             be used to supply all fire fighting water potential obstructions or               requirements.
PINGP                                                                                                                                   Page A Revision 1

Northern States Power - Minnesota                                                Attachment A - NEI 04-02 Table B-1 degradations in the fire water supply.                        "In the event that the motor driven pump is impaired, the control room may manually align the
: 3. The 18 months test interval screen wash pump directly to the FP header via reflects the testing frequency CV-31055 with unrestricted flow (2,000 GPM).
previously accepted by the NRC. This test frequency was   If all three fire pumps are impaired, or if the fire established under NSP's        suppression water system is incapable of original Technical             supplying water to a safety related area, a backup Specifications. Thus, at the   fire suppression water system must be time PINGP's Fire Protection   established within 24 hours."
Program was established and approved, the NRC              Per Section 3.7 of Pioneer Service & Engineering considered the current 18      Co. System Description 323.6720, "Prairie Island month test interval            Fire Protection System," "Both fire pumps are of acceptable. Eight deviations   bronze-fitted cast iron constructionand conform were dispositioned as          to NFPA Standard 20."
acceptable.
Fire pumps have been reviewed against the requirements of NFPA 20, as detailed in the Fire Protection Engineering Evaluation Code Compliance Deviations, Rev. 1, "NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1969, Code Compliance Review," dated 6/1/2010.
Items for Implementation None PINGP                                                                                         Page A Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.5.4                   Water Supply            At least one diesel        Complies             Per Section 4.1 of Procedure F5 Appendix F, "Fire engine-driven fire pump                         Hazard Analysis," "The water is drawn by two or two more seismic                             horizontal shaft centrifugal fire pumps each with a Category I Class IE                             design capacity of 2,000 gpm at a pressure 125 electric motor-driven fire                      psi. One of the fire pumps is diesel engine-driven pumps connected to                              and the other is electric motor-driven. A third pump, redundant Class IE                              electric motor-driven also having a capacity of emergency power buses                           2000 gpm at a pressure of 125 psi normally capable of providing 100                        assigned to the screen wash function can be percent of the required                         aligned to pump into the fire water system. On flow rate and pressure                          loss of offsite AC power, the diesel driven pump shall be provided.                              will be available to supply water to the fire Plant Documentation                                                                             protection system."
Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance Compliance Statement      Compliance Basis 3.5.5                   Water Supply            Each pump and its driver Complies via Previous Per Section 4.1 of Procedure F5 Appendix F, "Fire and controls shall be    Approval              Hazard Analysis," "The electric motor-driven fire separated from the                             pump and the diesel engine-driven fire pump are remaining fire pumps                           located at the east side of the screenhouse and from the rest of the                       separated by a distance of approximately 20 feet. A plant by rated fire                            three-hour rated fire barrier is provided around the barriers.                                      electric motor-driven fire pump. Electric cables for Plant Documentation                                                                            the electric motor-driven fire pump were re-Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80                                       routed to assure that a diesel fuel fire will not Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                        damage the controls or power source for the electric motor-driven fire pump. The screen wash Industry-Related References                                                                    pump, used as a backup fire pump, is located at None                                                                                           the west side of the screenhouse, well separated from the regular fire pumps."
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                Summary                           Per Section 3.2.6 of Letter from Schwencer (NRC)
None                                                                                           to Mayer (NSP) dated 4/21/80, "We concur with the Items for Implementation                                                                       licensee's conclusion that the control cable for the None                                                                                           motor driven fire pump does not need to be relocated or protected. Further, the licensee's proposal to relocate or protect the motor driven fire pump power cabling and provide a fire barrier to enclose the motor driven fire pump will assure that a fire would not cause the loss of both fire pumps. Based on our review, we find the licensee's proposed modifications to assure adequate separation of the fire pumps acceptable."
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                                                                                      Page A Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title      Requirement/Guidance        Compliance Statement Compliance Basis 3.5.6                     Water Supply          Fire pumps shall be         Complies             Per Section 7.3 of Procedure F5 Appendix K, "Fire provided with automatic                          Protection Systems Functional Requirements,"
start and manual stop                            "The motor driven fire pump will automatically start only.                                            at 98 psig. If the header pressure to drops to 93 Plant Documentation                                                                              psig, the diesel-driven fire pump will start."
Procedure C31, "Fire Protection & Detection Systems," Rev. 38, dated 5/11/07 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated       Per Sections 5.2 and 5.4 of Procedure C31, "Fire 4/11/2012                                                                                        Protection & Detection Systems," both the motor Fire Protection Engineering Evaluation, NFPA 20 - 1969, Standard for Centrifugal Fire Pumps,     and diesel fire pumps are shut off manually at Code Compliance Deviations, Rev. 1                                                               local pump panels.
Industry-Related References                                                                      Fire Protection Engineering Evaluation, NFPA 20 -
NFPA 20 - 1969, Standard for Centrifugal Fire Pumps,                                             1969, Standard for Centrifugal Fire Pumps, Code Compliance Deviations, Rev. 1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description               Summary None Items for Implementation None PINGP                                                                                                                       Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title       Requirement/Guidance     Compliance Statement Compliance Basis 3.5.7                   Water Supply           Individual fire pump     Complies             Per Drawing NF-39228-1, fire pump connections to connections to the yard                       the yard main fire loop are provided with fire main loop shall be                       sectionalizing valves between connections. Valves provided and separated                        FP-30-1 and FP-30-2 are provided for the motor with sectionalizing                           driven fire pump; valves FP-30-4 and FP-30-5 are valves between                                provided for the diesel driven fire pump; and valve connections.                                  FP-21-1 is provided for the jockey pump.
Plant Documentation Drawing NF-39228-1, "Flow Diagram Fire Protection and Screen W ash System - Unit 1 and 2, Rev. 77, dated 8-09 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                  Page A Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.5.8                   Water Supply            A method of automatic     Complies             Per Section 4.1 of Procedure F5 Appendix F, "Fire pressure maintenance of                        Hazard Analysis," "Pressurization of the fire water the fire protection water                      system is maintained by an electric motor-driven system shall be provided                       jockey pump.
independent of the fire pumps.
Plant Documentation Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                  Page A-100 - Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.5.9                   Water Supply            Means shall be provided   Complies             Per Section 4.1.3 (C) of Procedure F5 Appendix F, to immediately notify the                      "Fire Hazard Analysis," " Flows from manual hose control room, or other                         stations are not annunciated, but they will cause suitable constantly                            the fire pump to start, thereby transmitting a "fire attended location, of                          pump running" signal to the Control Room."
operation of fire pumps.
Plant Documentation Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25 A, dated 8/8/11 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                     Page A-101 - Revision 1

Northern States Power - Minnesota                                                                                   Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance           Compliance Statement   Compliance Basis 3.5.10                  Water Supply            An underground yard fire       Complies with use of   Per Section 4.3.1.3 of NRC SER dated 9/6/79, main loop, designed and        Existing Engineering   "Separate 10-inch supply lines to the 10-inch installed in accordance        Equivalency Evaluation underground yard main encircling the plant are with NFPA 24, Standard                                provided from the fire pump header in the screen for the Installation of                               house. Valving is provided so a single break in the Private Fire Service                                  discharge piping will not remove both fire pumps Mains and Their                                       from service. A backup supply of water to the yard Appurtenances, shall be                               fire main loop is provided by eight crossovers installed to furnish                                  between the cooling water system and the fire anticipated water                                     water system."
requirements.
Per Drawing NF-39256-1, "Yard Fire Protection Piping," the plant is surrounded by a 10-inch Plant Documentation                                                                                   underground fire main loop.
NRC SER dated 9/6/79 Code Compliance Review - NFPA 24, Standard for Outside Protection, 1969 ed., Rev 1, 12/2010 Industry-Related References NFPA 24, "Standard for Outside Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary Code Compliance Review -          All code deviations have been NFPA 24, Standard for             justified as acceptable.
Outside Protection, 1969 ed.,     Reference individual reports Rev 1, 12/2010                    for basis descriptions.
Items for Implementation None PINGP                                                                                                                            Page A-102 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance       Compliance Statement  Compliance Basis 3.5.11                  Water Supply            Means shall be provided    Complies via Previous Per Section 4.3.1.3 of NRC SER dated 9/6/79, to isolate portions of the Approval              "Separate 10-inch supply lines to the 10-inch yard fire main loop for                          underground yard main encircling the plant are maintenance or repair                            provided from the fire pump header in the screen without simultaneously                           house. Valving is provided so a single break in the shutting off the supply to                       discharge piping will not remove both fire pumps both fixed fire                                  from serviceSectionalizing valves with post suppression systems                              indicators subdivide the loop into a number of and fire hose stations                           sections enabling a single section to be isolated provided for manual                              without impairing the entire loop...The isolation backup. Sprinkler                                valves in the interior fire header in the turbine systems and manual                               building and auxiliary building are of the butterfly hose station standpipes                          valve type with chain operators. Because of this shall be connected to                            arrangement, the necessity of isolating a portion the plant fire protection                        of the underground yard loop to repair a hydrant water main so that a                             or leaking main will not result in shutting off the single active failure or a                       supply of water to systems protecting safety-crack to the water supply                        related equipment or areas...We find that...fire piping to these systems                          water piping systems satisfy the objectives can be isolated so as                            identified in Section 2.2 of this report and are, not to impair both the                           therefore, acceptable."
primary and backup fire suppression systems.                             The basis for approval has been reviewed. There Plant Documentation                                                                              have been no plant modifications or other changes NRC SER dated 9/6/79                                                                             that would invalidate the basis for approval.
Industry-Related References NFPA 24, "Standard for Outside Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                        Page A-103 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title         Requirement/Guidance      Compliance Statement Compliance Basis 3.5.12                   Water Supply             Threads compatible with   Complies             Per Section 4.3.1.3 of NRC SER dated 9/6/79, those used by local fire                       "Threads on hydrant outlets and hose couplings departments shall be                           are compatible with those of fire departments provided on all hydrants,                      which serve the plant."
hose couplings, and standpipe risers.                              Per Section 1.2.1.C of Procedure F5 Appendix J, Plant Documentation                                                                              "Fire Drills," "A drill involving the local on-duty fire NRC SER dated 9/6/79                                                                             department shall be done at least once per year."
Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10 NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1969 Code                  The NFPA 14 code compliance reviews (Section Compliance Review, Revision 1                                                                    444 of NFPA 14-1969; Section 4-1.3 of NFPA 14-FPEE-11-050, Code Compliance Review, NFPA 14-1986, Standard for the Installation of              1986) confirmed that the threads are compatible Standpipe and Hose Systems, D5/D6 Building, Revision 1                                           by those by the Red W ing Fire Department. Per General Note 5 on NF-39300-1 and NF-39301-1, Industry-Related References                                                                      all hose threads to be National Standard hose NFPA 24, "Standard for Outside Protection," 1969 Edition                                         threads at both ends.
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None Items for Implementation None PINGP                                                                                                                         Page A-104 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.5.13                    Water Supply          Headers fed from each       Complies             The hose standpipe system is not seismically end shall be permitted                           designed, but the system meets the requirements inside buildings to                              of NFPA 805. See Section 3.6.4 below. As a supply both sprinkler                            result, the requirements of ANSI B31.1 are not and standpipe systems,                           applicable.
provided steel piping and fittings meeting the                         The hose stations and standpipes provided for requirements for ANSI                            PINGP are in accordance with the requirements of B31.1, Code for Power                            BTP 9.5-1, Appendix A for plants which received a Piping, are used for the                         construction permit before July 1, 1976 which do headers (up to and                               not require a seismic category I water system.
including the first valve) supplying the sprinkler                          Provisions to supply water to standpipes and hose systems where such                               stations for manual fire suppression in the event headers are part of the                          of a safe shutdown earthquake are outlined in seismically anlayzed                             EDMG-2, Guideline for Damage Mitigation hose standpipe system.                           Strategies (Attachment B - Fire System Where provided, such                             Management and Attachment L - Establishing headers shall be                                 Emergency Water Supply).
considered an extension of the yard main                                 Per Section 4.3.4 of Pioneer Service &
system. Each sprinkler                           Engineering Co. System Description 323.6720, and standpipe system                             "Prairie Island Fire Protection System," "The shall be equipped with                           sprinkler system shut-off valves are 150 lb.
an outside screw and                             position indicating, outside screw and yoke gate yoke (OS&Y) gate valve                           valves, flanged ends."
or other approved shutoff valve.
Plant Documentation Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76 NRC SER dated 9/6/79 Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70 PINGP Unit 1 & 2 Project Design Manual, dated 4/1967 EDMG-2, Guideline for Damage Mitigation Strategies (Attachment B - Fire System Management and Attachment L - Establishing Emergency Water Supply).
Industry-Related References NFPA 24, "Standard for Outside Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None PINGP                                                                                                                       Page A-105 - Revision 1

Northern States Power - Minnesota Attachment A - NEI 04-02 Table B-1 Items for Implementation None PINGP                                      Page A-106 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.5.14                   Water Supply           All fire protection water  Complies             Per Section 8.5.11 of Procedure F5 Appendix K, supply and fire                                 "Fire Protection Systems Functional suppression system                              Requirements," "Each valve (manual, power control valves shall be                         operated or automatic) in the flow path for safety-under a periodic                                related areas and areas posing a fire hazard to inspection program and                          safety-related areas shall be verified to be in the shall be supervised by                          correct position and secured to prevent one of the following                            inadvertent misalignment every month."
methods.
Per Section 1.1 of Procedure SP 1200, "Fire (a) Electrical supervision                      Protection System Supply to Safety Related Areas with audible and visual                         Valve Check," "The purpose of this surveillance is signals in the main                             to verify that fire protection valves supplying safety control room or other                           related areas, and areas posing a fire hazard to suitable constantly                             safety related areas, are in the correct position attended location.                              and secured."
(b) Locking valves in                           Per Section 1.5.1, the acceptance criteria for all their normal position.                          water supply and fire suppression system control Keys shall be made                              valves is "Valve verified open per 5AWI 3.10.1 available to authorized                         Appendix E" and "Block Wire in place."
personnel.
Per Section 5.1, "Block W ire is required to prevent (c) Sealing valves in                           inadvertent mispositioning of valves."
their normal positions.
This option shall be                            Appendix E of Procedure 5AWI 3.10.1, "Methods utilized only where                             of Performing Verifications," provides instructions valves are located within                       for inspecting valves to ensure they are fenced areas or under                           adequately locked.
the direct control of the owner/operator.
Plant Documentation Procedure 5AWI 3.10.1, "Methods of Performing Verifications," Rev. 16, dated 6/30/10 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012 Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check,"
Rev. 32, dated 11/20/08 Industry-Related References NFPA 24, "Standard for Outside Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                  Summary None PINGP                                                                                                                       Page A-107 - Revision 1

Northern States Power - Minnesota Attachment A - NEI 04-02 Table B-1 Items for Implementation None PINGP                                      Page A-108 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title      Requirement/Guidance        Compliance Statement  Compliance Basis 3.5.15                    Water Supply          Hydrants shall be           Complies via Previous Per Section 4.3.1.3 of NRC SER dated 9/6/79, installed approximately     Approval              "Eight hydrants are provided in the yard spaced every 250 ft (76 m) apart                         from 180 to 300 feet apart. The hydrants are on the yard main                                  supplied from the underground fire loop although system. A hose house                              the laterals feeding the hydrant are not provided equipped with hose and                            with isolation valvesEach of the hydrants is combination nozzle and                            provided with a well maintained corrugated metal other auxiliary                                   hose house containing: 100 feet of 1 1/2-inch and equipment specified in                            200 feet of 2 1/2-inch single jacket lined hose, one NFPA 24, Standard for                             2 1/2-inch and one 1 1/2-inch fog nozzle and the Installation of Private                       various other items of fire fighting equipment. The Fire Service Mains and                            inventory of equipment in the hose houses requires Their Appuretenances,                             upgrading to include additional 1 1/2-inch shall be provided at                              hose, hose gaskets and a gated wye to allow intervals of not more                             connecting two 1 1/2-inch hose lines to a 2 1/2-than 1000 ft (305 m)                              inch hose line."
along the yard main                               "We find that, subject to implementation of the system.                                           above listed modifications, fire water piping systems satisfy the objectives identified in Section Exception: Mobile                                 2.2 of this report and are, therefore, acceptable."
means of providing hose and associated                                    Per Section 7.14 of Procedure F5 Appendix K, equipment, such as                                "Fire Protection Systems Functional hose carts or trucks,                             Requirements," "Thirty two (32) hydrant units are shall be permitted in lieu                        located around the plant, warehouses, cooling of hose houses. Where                             towers, and in the switch yard. Each house provided, such mobile                             contains 200 feet of 2 1/2" fire hose with a nozzle, equipment shall be                                200 feet of 1 1/2" fire hose with a nozzle, adaptors equivalent to the                                 for various size hose, spanner wrenches, a 2 1/2" equipment supplied by                             hose control unit, gated wye, hydrant wrench, and three hose houses.                                hose gaskets."
Plant Documentation Per Drawing NF-39256-1, "Yard Fire Protection NRC SER dated 9/6/79 Code Compliance Review NFPA 24-1969, "Code Compliance Review - NFPA 24-1969,                      Piping," the fire hydrants are located along the 10 Standard for Outside Protection," dated 12/2010                                                   inch fire main and are approximately 180 feet to Drawing NF-38201, "Outdoor Hose House Fire Protection," Rev. E, dated 3/1/73                      300 feet apart.
Drawing NF-39256-1, "Yard Fire Protection Piping," Rev. AG, dated 2/7/92 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated        Drawing NF-38201, "Outdoor Hose House Fire 4/11/2012                                                                                         Protection," details the materials required to furnish the hose houses, which include spanner Industry-Related References                                                                       wrenches, hoses, hose couplings, fog nozzles, etc.
NFPA 24, "Standard for Outside Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)                                              Hose house equipment has been reviewed against the requirements of NFPA 24, as detailed Identifier                    EEEE Description                 Summary                            in the Code Compliance Review Code None                                                                                              Compliance Review - NFPA 24-1969, Standard PINGP                                                                                                                        Page A-109 - Revision 1

Northern States Power - Minnesota              Attachment A - NEI 04-02 Table B-1 Items for Implementation          for Outside Protection," dated 12/2001.
None The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                       Page A-110 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.5.16                   Water Supply           The fire protection water  Submit for NRC       Per Section 1.2 of System Description B31A, "Fire supply system shall be     Approval             Protection System," "The motor-driven fire pump dedicated for fire                              can be aligned to provide a backup water supply protection use only.                            to the Screenhouse screenwash system in the event of a screenwash pump failure."
Exception No. 1: Fire protection water supply                         Per Section 3.1.C, "If the fire pump is required to systems shall be                                supplement the screenwash header flow, the permitted to be used to                         pump must be started manually either locally or provide backup to                               remotely. Once the pump is operating and no auto nuclear safety systems,                         start signal exists, the discharge to the provided the fire                               screenwash header valve opens automatically protection water supply                         and maintains the screenwash header pressure at systems are designed                            approximately 90 psig."
and maintained to deliver the combined fire                       Per Drawing NF-39228-1, "Fire Protection and and nuclear safety flow                         Screen W ash System - Unit 1 and 2," valve FP                                                 demands for the                                 10 ties the fire protection water system to the duration specified by the                       screenwash header.
applicable analysis.
Since the fire water system can be aligned for Exception No. 2: Fire                           screenwash system use and such use does not protection water storage                        meet the requirement or allowed exceptions to the can be provided by plant                        requirement, this configuration is included in systems serving other                           Attachment L and NRC approval is being functions, provided the                         requested.
storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section.
Plant Documentation Drawing NF-39228-1, "Fire Protection and Screen W ash System - Unit 1 and 2," Rev. 77, dated 8/09 System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11 Code Compliance Review, NFPA 24-1969, Standard for Outside Protection Revision 1, December 2010 Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                   EEEE Description                 Summary None PINGP                                                                                                                       Page A-111 - Revision 1

Northern States Power - Minnesota Attachment A - NEI 04-02 Table B-1 Items for Implementation None PINGP                                      Page A-112 - Revision 1

Northern States Power - Minnesota                                                                   Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance Compliance Statement Compliance Basis 3.6                     Standpipe and        Standpipe and Hose   Covered in the sub-  Covered in the sub-sections below Hose Stations        Stations.            sections below Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description             Summary N/A Items for Implementation N/A PINGP                                                                                                          Page A-113 - Revision 1

Northern States Power - Minnesota                                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title         Requirement/Guidance            Compliance Statement    Compliance Basis 3.6.1                       Standpipe and            For all power block             Complies by Previous    Per Item 125 of the table attached to Letter from Hose Stations            buildings, Class III            NRC Approval;           Mayer (NSP) to Stello (NRC) dated 12/8/76, standpipe and hose              Complies with Use of    "Comparison of Existing Fire Protection Provisions systems shall be                Existing Engineering    to the Guidelines Contained in Standard Review installed in accordance         Equivalency Evaluations Plan 9.5.1," "The classification of the fire system is with NFPA 14, Standard                                  QA Type III. Design of hose stations to QA Type I for the Installation of                                 in safeguards areas is not required in operating Standpipe, Private                                      plants in accordance with Appendix A to APCSB Hydrant, and Hose                                       9.5-1. The system is built to power piping ANSI Systems.                                                B31.1 code. Crossover lines from the Cooling Plant Documentation                                                                                          Water system and valves are QA Type I to the Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76                                                        check valves."
Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80 NRC SER dated 9/6/79                                                                                         Per Section 4.3.1.4 of NRC SER dated 9/6/79, Code Compliance Review NFPA 14-1969, "Code Compliance Review - NFPA 14-1969,                                 "Interior hose stations are provided throughout Standard for the Installation of Standpipe and Hose Systems," dated 2/15/2011                                most areas of the plant connected to the fire water Code Compliance Review NFPA 14-1986, FPEE-11-050, "Code Compliance Review - NFPA                             header. Most hose stations consist of a pin lug type 14-1986, Standard for the Installation of Standpipe and Hose Systems," dated 3/9/2011                        hose rack, 300 psi hose valve with drip vent and 50 Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire                          to 100 feet of 1 1/2-inch unlined linen hose coupled Protection System," dated 9/15/70                                                                            to an all fog type nozzle with a ball shut System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                                    off feature. The provision of unlined linen hose is considered unsatisfactory in an industrial Industry-Related References                                                                                  application since it cannot be practically tested, FAQ 06-0019, "Definition of 'Power Block' and 'Plant'," Rev. 4, dated 9/28/07                                deteriorates readily when subjected to moisture, NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986                        and is more subject to failure from abrasion and Editions                                                                                                     cuts than hose with synthetic lining and jacketing.
                                                                                                             "All interior unlined linen fire hose will be Existing Engineering Equivalency Evaluations (EEEEs) replaced with 100% synthetic material fire hose Identifier                      EEEE Description                    Summary                                  (300 psi test pressure) FM or UL labelled, that is Code Compliance                 Document the review of the          Four deviations have been                suitable for pin rack storage.
Review NFPA 14-1986,            standpipe and hose station          found acceptable based on the            "We find that, subject to implementation of the FPEE-11-050, "Code              systems for compliance with         justification provided. One              above described modifications, interior fire hose Compliance Review -             the applicable requirements         deviation has been found to be           stations satisfy the objectives identified in Section NFPA 14-1986,                   cited in National Fire              unacceptable and will require            2.2 of this report and are, therefore, acceptable."
Standard for the                Protection Association              the performance of hydraulic Installation of Standpipe       (NFPA) 14 -1986                     calculations to verify the               Per Section 3.8.A of System Description B31A, and Hose Systems,"                                                  design bases of the standpipe            "Fire Protection System," "Each hose station is dated 3/9/2011                                                      and hose station system.                 equipped with 50; 75' or 100' of 1-1/2" E-Z off, GAR 01183456-01, Perform                 lightweight, synthetic jacket lined fire hose with an Hydraulic Calculations for FP            adjustable spray nozzle."
Systems, is tracking resolution of this issue.                           Per Page 5 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, "By letter dated NFPA 14, Standard for           Document the review of the          Eleven deviations to the code            December 26, 1979, the licensee provided design the Installation of             stand pipe and hose systems         requirements have been                   details regarding a more timely method of Standpipe and Hose              for compliance with the             identified, nine of which are            providing fire suppression water for the Systems, 1969 Code              applicable requirements cited                                                containment standpipes. Originally, fire Compliance Review,                                                                                           suppression water would not be available for a period of 6 to 8 hours following the detection of a PINGP                                                                                                                                   Page A-114 - Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 Revision 1                 in National Fire Protection      identified as acceptable and   fire in containment. The licensee has proposed a Association (NFPA) 14-1969,      two with action requests (ARs) design modification in which the existing Standard for the Installation of to address resolutions to the  containment fire line will be supplied by a four-Stand Pipe and Hose Systems      identified issues.             inch cross-connect from the four-inch supply to the CRDM Shroud Cooling Coils. The cross- connect Items for Implementation None                                                                                       will have a capacity of approximately 350 gpm and will be available during plant operations. The cross-connect will include two manually operated four inch gate valves located within six feet of the personnel access air-lock. The limiting time in pressurizing a containment fire line will be only that time required for personnel entry.
                                                                                           "The licensee's proposed design will result in a more timely method of charging the standpipes in containment. Based on our review, we find the licensee's method of charging the standpipes within containment acceptable."
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
Per Section 3.1 of Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," "All fire protection system components are QA type IIB and are in accordance with the National Fire Protection Association (NFPA) Standards."
Per Section 3.3 "Standpipe and fire hose stations conforming to NFPA 14 are located on the roofs of the turbine room and the auxiliary building and on the fan deck of each cooling tower."
Per Section 3.4, "Standpipe and water fog hose stations conforming to NFPA Standard #14 are located on all floors of the service, auxiliary, and reactor buildings. These stations are so located that all areas are protected by a fog nozzle when attached to one 75 ft. length of fire hose."
Standpipes, hydrants, and hose systems have been reviewed against the requirements of NFPA 14, as detailed in the Code Compliance Review "Code Compliance Review - NFPA 14-1969, Standard for the Installation of Standpipe and Hose Systems," dated 2/15/2011 and "Code Compliance Review - NFPA 14-1986, Standard PINGP                                                                                                                 Page A-115 - Revision 1

Northern States Power - Minnesota              Attachment A - NEI 04-02 Table B-1 for the Installation of Standpipe and Hose Systems," dated 3/9/2011.
PINGP                                                        Page A-116 - Revision 1

Northern States Power - Minnesota                                                                                   Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #          Subsection Title        Requirement/Guidance       Compliance Statement Compliance Basis 3.6.2                       Standpipe and           A capability shall be      Complies             Per the NFPA 14-1969 Code Compliance Review, Hose Stations           provided to ensure an                           Rev 1 table dated 2/15/2011, "The Mississippi adequate water flow rate                        River and the fire pumps can provide adequate and nozzle pressure for                         water volume and pressure for the most remote all hose stations. This                         hose stations."
capability includes the provision of hose station                       Per the NFPA 14-1986 Code Compliance pressure reducers where                         Review, Rev. 1 table dated 3/9/2011, "The two fire necessary for the safety                        pumps can provide adequate pressure for the of plant industrial fire                        most remote hose stations."
brigade members and off-site fire department                        Pressure reducers are not required on standpipe personnel.                                      outlets for 2-1/2 inch hose because it is assumed Plant Documentation                                                                                 2-1/2 inch hose will be attached only when the NFPA 14-1969 Code Compliance Review Rev. 1, dated 2/15/2011                                         persons likely to use it are trained in handling NFPA 14-1986 Code Compliance Review Rev. 1, FPEE-11-019, dated 3/9/2011                             large streams. Since the brigade is qualified to City of Red W ing Job Description, Firefighter/Paramedic:                                           use large hose streams, they are also qualified to City of Red W ing Job Description, Paid On Call Firefighter,                                        use 1-1/2 inch hose at higher pressures. Training F5, Firefighting, Rev 33.                                                                           on the use of large hose is conducted annually at F5 Appendix J, Fire Drills, Rev 14                                                                  the live fire training session.
Industry-Related References                                                                         City of Red W ing Job Description, NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986               Firefighter/Paramedic: Minimum Qualifications:
Editions Minnesota Fire Service Certification, Fire Fighter II Skills Testing NFPA 1001 Fire Fighter II,     The job requires two years of formal training 2008 Edition                                                                                        beyond high school diploma, 1 year of related experience, and Firefighter II certification.
Existing Engineering Equivalency Evaluations (EEEEs)
National Registry EMT-Paramedic Certification Identifier                      EEEE Description                   Summary                          required.
None City of Red W ing Job Description, Paid On Call Items for Implementation                                                                            Firefighter, The job requires a high school diploma None                                                                                                or equivalent and the ability to obtain Fire Fighter II and First Responder certifications. Must obtain a valid Minnesota Class B driver's license with airbrake endorsement or equivalent within 3 years of employment, and have a good driving record.
Demonstrated proficiency on personal computers with word processing is desired.
PINGP                                                                                                                           Page A-117 - Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title         Requirement/Guidance Compliance Statement Compliance Basis 3.6.3                     Standpipe and           The proper type of hose     Complies      Per Section 3.8 of System Description B31A, "Fire Hose Stations           nozzle to be supplied to                  Protection System," "Six low gallonage hose each power block area                     stations are located in the plant. Each of the hose shall be based on the                     stations is equipped with a continuous flow reel, area fire hazards. The                    100' of 1" solid rubber hose, and a 1" low usual combination                         gallonage fog nozzle. The hose stations are spray/straight stream                     located along the 'G' wall on the 715' and 735' nozzle shall not be used                  levels of the Turbine Building for use in the Relay in areas where the                        and Cable Spreading Room, the Unit 1 & Unit 2 straight stream can                       480V & 4.16KV Safeguards Switchgear Rooms, cause unacceptable                        and the Control Room. The low gallonage hose damage or present an                      stations are designed to prevent the extensive electrical hazard to fire-                damage which could occur in the rooms from the fighting personnel.                       use of the existing 1-1/2" hose stations."
Listed electrically safe fixed fog nozzles shall                   Per Section 7.10 of Procedure F5 Appendix K, be provided at locations                  "Fire Protection Systems Functional where high-voltage                        Requirements," "All fire hose stations are shock hazards exist. All                  equipped with adjustable fog nozzles (95 gpm) hose nozzles shall have                   and 75 or 100 feet of 1 1/2" fire hose. They can be shutoff capability and be                 used on all types of fires."
able to control water flow from full open to full                    Per Section 3.4 of Pioneer Service & Engineering closed.                                   Co. System Description 323.6720, "Prairie Island Plant Documentation                                                                         Fire Protection System," "Standpipe and water fog NRC SER dated 9/6/79                                                                        hose stations conforming to NFPA Standard #14 Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire         are located on all floors of the service, auxiliary, and Protection System," dated 9/15/70                                                           reactor buildings. These stations are so located that Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated  all areas are protected by a fog nozzle when 4/11/2012                                                                                   attached to one 75 ft. length of fire hose.
System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11 Per Section 4.3.1.4 of NRC SER dated 9/6/79, Industry-Related References                                                                 "Interior hose stations are provided throughout FAQ 06-0019, "Definition of 'Power Block' and 'Plant'," Rev. 4, dated 9/28/07               most areas of the plant connected to the fire water NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986       header. Most hose stations consist of a pin lug type Editions                                                                                    hose rack, 300 psi hose valve with drip vent and 50 to 100 feet of 1 1/2-inch unlined linen hose Existing Engineering Equivalency Evaluations (EEEEs)                                        coupled to an all fog type nozzle with a ball shut Identifier                    EEEE Description                  Summary                     off feature The licensee has agreed to improve None                                                                                        the interior fire hose stations by providing the following modifications: (3) A one-inch booster Items for Implementation                                                                    hose with variable gallonage nozzle with shut off None                                                                                        will be provided adjacent to the existing hose stations numbers 21, 23, 24, 64, 69 and 70..."
These six low gallonage hose stations have been installed for use in the Relay and Cable Spreading Room, the Unit 1 & Unit 2 480V & 4.16KV Safeguards Switchgear Rooms, and the Control Room.
PINGP                                                                                                                   Page A-118 - Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement  Compliance Basis 3.6.4                     Standpipe and           Provisions shall be made Complies via Previous Per Item No. 9 of Letter from Mayer (NSP) to Hose Stations           to supply water at least Approval              Stello (NRC) dated 12/8/76, "As permitted in to standpipes and hose                         Appendix A to APCSB 9.5-1, the system has not stations for manual fire                       been analyzed to withstand the SSE. The system suppression in all areas                       can function under all expected natural containing                                     phenomena characteristic of the region. The systems and                                    system is not subject to man-created site related components needed to                           event damage."
perform the nuclear safety functions in the                        Per Section 4.3.1.4 of NRC SER dated 9/6/79, event of a safe                                "interior fire hose stations satisfy the objectives shutdown earthquake                            identified inthis report and are, therefore, (SSE).                                         acceptable."
Plant Documentation Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76                                            The hose stations and standpipes provided for NRC SER dated 9/6/79                                                                             PINGP are in accordance with the requirements of EDMG-2, Guideline for Damage Mitigation Strategies, Rev. 8                                       BTP 9.5-1, Appendix A for plants which received a construction permit before July 1, 1976 which do Industry-Related References                                                                      not require a seismic category I water system.
NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 Editions                                                                                         Provisions to supply water to standpipes and hose stations for manual fire suppression in the event Existing Engineering Equivalency Evaluations (EEEEs) of a safe shutdown earthquake are outlined in Identifier                    EEEE Description                  Summary                          EDMG-2, Guideline for Damage Mitigation None                                                                                             Strategies (Attachment B - Fire System Items for Implementation                                                                         Management and Attachment L - Establishing None                                                                                             Emergency Water Supply).
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                                                                                       Page A-119 - Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title         Requirement/Guidance     Compliance Statement Compliance Basis 3.6.5                    Standpipe and            Where the seismic        Complies             Per Section 10.3.1.2.1 of the Updated Safety Hose Stations            required hose stations                        Analysis Report (USAR), "In addition to the two are cross-connected to                        dedicated fire pumps, a third pump, electric motor-essential seismic non-                        driven and having a capacity of 2000 gpm at a fire protection water                         pressure of 125 psi, normally assigned to the supply systems, the fire                      screen wash function, can be aligned to pump into flow shall not degrade                        the fire water system. The cooling water system the essential water                           provides a backup source of water for the fire system requirement.                           protection headers. Via normally closed valves, Plant Documentation                                                                             the cooling water system can provide a backup Calculation ENG-ME-160, "Aux Bldg Fire Protection to Cooling Water Header Cross Tie             water supply for the following safeguards Hydraulic Calc," Rev. 2                                                                         equipment fire protection spray and sprinkler Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                         systems: auxiliary feedwater pumps, diesel System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                       generators, containment cable penetrations, and Updated Safety Analysis Report (USAR) Section 10, Rev. 32P                                      safeguards cooling water pumps."
Industry-Related References                                                                     Per Section 10.4.1.2.2, "Upon occurrence of the NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986           design basis seismic event, the cooling water Editions                                                                                        system flow demand is approximately 36,691 gpm This is with the two diesel driven Existing Engineering Equivalency Evaluations (EEEEs) safeguards cooling water pumps operating, since Identifier                   EEEE Description                   Summary                         this creates the highest demand on the suction None                                                                                            supply. There is an additional 2000 gpm demand from the diesel fire pump. Initially, the supply to Items for Implementation                                                                        the safeguards cooling water pumps is from both None                                                                                            the intake canal and the emergency intake line.
The stability of the intake canal banks has been evaluated The evaluations demonstrate that the intake canal will support the safeguards function of the cooling water system. The volume in the intake canal provides approximately 4 hours for a flow demand of 38,691 gpm" Per Section 4.1.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "One of the fire pumps is diesel engine-driven and the other is electric motor-driven. A third pump, electric motor-driven also having a capacity of 2000 gpm at a pressure of 125 psi normally assigned to the screen wash function can be aligned to pump into the fire water system The screen wash pump [is] used as a backup fire pump A back-up supply of water to the fire header system is provided by manually-operated crossovers between the Cooling W ater System and the main loop and sprinklers within the Fire Protection System. The Cooling W ater System and Fire Protection System normally are isolated from each other. At the crossovers, isolation is provided by a normally closed stop PINGP                                                                                                                      Page A-120 - Revision 1

Northern States Power - Minnesota               Attachment A - NEI 04-02 Table B-1 valve and a check valve."
Per Section 2 of System Description B31A, "Fire Protection System," "The Cooling W ater System also acts as a backup water supply for the fire protection header through 9 separate cross-connects between the two systems. A manual isolation valve and a check valve are installed on each cross-connect to ensure the direction of flow is from the Cooling W ater System to the Fire Protection System."
Per the Purpose and Section 5.0 of Calculation ENG-ME-160, "Aux Bldg Fire Protection to Cooling Water Header Cross Tie Hydraulic Calc,"
                                  "The purpose of this hydraulic calculation is to determine the configuration of cooling water (CL) to fire protection (FP) cross-ties required to supply the Auxiliary Building FP sprinkler header...Based on the results of this analysis, the cooling water system is capable of providing 85% of design flow to DM-7 and 100% of design flow to WPS-22 while meeting the design constraints outlined in this calculation. These flows are adequate to provide auxiliary building fire protection sprinkler systems during those situations where the normal supply must be isolated.
PINGP                                                        Page A-121 - Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance        Compliance Statement Compliance Basis 3.7                        Fire Extinguishers     Where provided, fire         Complies            Per Section 4.2 of Procedure F5 Appendix F, "Fire extinguishers of the                             Hazard Analysis," "Portable and wheeled fire appropriate number,                              extinguishers are provided throughout the plant.
size, and type shall be                          Most of the extinguishers are of the CO2 to dry provided in accordance                           chemical type." Table 6-1 of Procedure F5 with NFPA 10, Standard                           Appendix F establishes the location and type of for Portable Fire                                each fire extinguisher in the plant.
Extinguishers.
Extinguishers shall be                           Fire extinguishers have been reviewed against the permitted to be                                  requirements of NFPA 10, as detailed in the Code positioned outside of fire                       Compliance Review "Code Compliance Review -
areas due to radiological                        NFPA 10-1969, Standard for Portable Fire conditions.                                      Extinguishers, Code Compliance Deviations" Rev Plant Documentation                                                                                1, dated 3/26/2010 and "Code Compliance Code Compliance Review NFPA 10-1969, "Code Compliance Review - NFPA 10-1969,                       Review - NFPA 10-1986, Standard for Portable Standard for Portable Fire Extinguishers, Code Compliance Deviations" Rev 1, dated                 Fire Extinguishers," dated 8/16/07.
3/26/2010 Code Compliance Review NFPA 10-1986, "Code Compliance Review - NFPA 10-1986, Standard for Portable Fire Extinguishers," dated 8/16/07 Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Industry-Related References NFPA 10, "Standard for the Installation of Portable Fire Extinguishers," 1969 Edition NFPA 10, "Standard for Portable Fire Extinguishers," 1986 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                         Page A-122 - Revision 1

Northern States Power - Minnesota                                                                      Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance Compliance Statement    Compliance Basis 3.8                     Fire Alarm and       Fire Alarm and Detection Covered in the sub- Covered in the sub-sections below Detection Systems    Systems.                 sections below Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description             Summary N/A Items for Implementation N/A PINGP                                                                                                             Page A-123 - Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title       Requirement/Guidance      Compliance Statement    Compliance Basis 3.8.1                     Fire Alarm             Alarm initiating devices  Complies with use of    Per Section 3.0 of Procedure F5 Appendix F, "Fire shall be installed in     Existing Engineering    Hazard Analysis," "Fire Detection Systems (FDS) accordance with NFPA      Equivalency Evaluations are provided throughout the plant. The fire 72, National Fire Alarm                           detectors are connected to an alarm which Code . Alarm                                     annunciates either in the Control Room or at local annunciation shall allow                          panels, which in turn alarms in the Control Room, the proprietary alarm                             thus providing the Control Room operator with an system to transmit fire-                          indication of system operation, tampering or related alarms,                                   malfunction. In addition to handling fire detector supervisory signals, and                          signals, the system transmits indication of water trouble signals to the                            flow from the sprinkler and deluge extinguishing control room or other                             systems. In all cases, the zone from which the constantly attended                               alarm or signal is initiated is indicated. Indication location from which                               of operation of the CO2 extinguishing system is required notifications                            indicated on a separate panel. The fire detection and response can be                               system is powered from an emergency source of initiated. Personnel                              power and all circuits from local control panel to assigned to the                                   Control Room are electrically supervised."
proprietary alarm station shall be permitted to                             Per Section 3.0, "The Fire Detection System have other duties. The                            meets the requirements established by following fire-related                            Underwriters Laboratories and Factory Mutual.
signals shall be                                  These requirements comply with National Fire transmitted:                                      Protection Association (NFPA) recommendations (1) Actuation of any                              in effect when the plant was constructed (1969)."
fire detection device (2) Actuation of any                              Per Technical Specification 3.14.A, identified in fixed fire suppression                            letter from Davis (NRC) to Mayer (NSP) dated system                                            2/14/78, "The minimum number of fire detection (3) Actuation of any                              instruments for each fire zone specified in Table manual fire alarm                                 TS.3.14-1 shall be operable."
station (4) Starting of any fire                          Fire alarm systems have been reviewed against pump                                              the requirements of NFPA 72D, as detailed in the (5) Actuation of any                              NFPA 72D-1967 and NFPA 72D-1986 code fire protection                                   review checklists.
supervisory device (6) Indication of alarm Plant Documentation                              system trouble condition Letter from Mayer (NSP) to Director (NRC) dated 11/30/79 Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80 Letter from NSP to Director of Nuclear Reactor Regulation (NRC) dated 10/24/80 Letter from Schwencer (NRC) to Mayer (NSP), dated 4/21/80 Letter from Long (NRC) to Parker (NSP) dated 4/28/92 NRC SER dated 9/6/79 NFPA 72D Code Conformance Review Checklist Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service, 1967 Edition, Rev. 1 2/4/2011.
PINGP                                                                                                                         Page A-124 - Revision 1

Northern States Power - Minnesota                                                            Attachment A - NEI 04-02 Table B-1 Design Basis Document DBD-TOP-06, Fire Protection/Appendix R Design Basis Document, Rev. 5, dated 10/8/09 Drawing NE-40007-127.1, 0.480Kv Bus 160 Motor Control Center IE Bus 1, Rev. DB, dated 5/5/79 Drawing NE-40009 Sheet 63, 208/120AC VAC Panel 116, Rev. BF, dated 10/7/99 Drawing NE-40011 Sheet 36, BOP Annunciator Point Schematic Diagram Field TB 131-140, SER Points 131-140, Rev. PS, dated 5/5/00 Drawing NE-40011 Sheet 37, Rev. AV, dated 8/1/05 Drawing NE-40011 Sheet 40, BOP Annunciator Point Schematic Diagram Field TB 171-180, SER Points 171-180, Rev. TU, dated 7/27/94 Drawing NE-40011 Sheet 105, BOP Annunciator Point Schematic Diagram Field TB 821-830, SER Points 821-839, Rev. G, dated 5/4/00 Drawing NE-40014 Sheet 6, Fire Detection Control Panel Power Supply, Rev. R, dated 3/23/94 Drawing NE-40014 Sheet 7, Fire Detection Control Panel, Rev. R, dated 6/29/84 Drawing NE-40014 Sheet 8, Fire Detection Control Panel, Rev. T, dated 10/13/95 Drawing NE-40014 Sheet 9, Fire Detection Control Panel, Rev. R, dated 11/13/87 Drawing NE-40014 Sheet 10, Fire Detection Control Panel, Rev. P, dated 9/14/88 Drawing NE-40014 Sheet 11, Fire Detection Control Panel, Rev. Q, dated 9/8/05 Drawing NE-40014 Sheet 12, Fire Detection Control Panel, Rev. 76, dated 5/6/06 Drawing NE-40014 Sheet 13, Fire Detection Control Panel, Rev. 76, dated 5/09 Drawing NE-40014 Sheet 14, Fire Detection Control Panel, Rev. W , dated 4/17/03 Drawing NE-40014 Sheet 15, Fire Detection Control Panel, Rev. W , dated 4/22/03 Drawing NE-40014 Sheet 16, Zones 5 & 7, Rev. M, dated 11/1/74 Drawing NE-40014 Sheet 17, Zones 9, 13, & 16, Rev. C, dated 7/2/84 Drawing NE-40014 Sheet 18, Zones 18 & 22, Rev. G, dated 9/25/95 Drawing NE-40014 Sheet 19, Zones 38, 41, & 45, Rev. D, dated 12/13/72 Drawing NE-40014 Sheet 20, Zones 48, 58, 59, & 49, Rev. G, dated 5/9/96 Drawing NE-40014 Sheet 21, Zones 60, 61, 62, & 63, Rev. F, dated 8/16/23 Drawing NE-40014 Sheet 22, Zones 76, 77, 78, 79, 80, 95, & 96, Rev. G, dated 11/29/92 Drawing NE-40014 Sheet 23, Local Red W arning Lights-Low Air Pressure in H.A.D., Rev. G Drawing NE-40014 Sheet 24, Deluge Valve Control, Rev. K, dated 3/7/95 Drawing NE-40014 Sheet 25, Transformer Deluge Valve Control and Indication Panel, Rev.
E, dated 8/3/88 Drawing NE-40014 Sheet 26, II Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit I, Rev. H, dated 12/20/73 Drawing NE-40014 Sheet 27, II Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -
5 Unit-1, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 28, II Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -
8 Unit-1, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 29, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit-2, Rev. H, dated 12/20/73 Drawing NE-40014 Sheet 30, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -5 Unit-2, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 31, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -8 Unit-2, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 32, Relay & Computer Room Fire Protection System, Rev. 76, dated 12/08 Drawing NE-40014 Sheet 33, Relay & Computer Room Fire Protection System, Rev. 76, dated 12/08 PINGP                                                                                                 Page A-125 - Revision 1

Northern States Power - Minnesota                                                            Attachment A - NEI 04-02 Table B-1 Drawing NE-40014 Sheet 36, Fire Detection Control Panel 70466, Rev. B, dated 5/5/00 Drawing NE-40014 Sheet 37, Zone 1, Rev. C, dated 5/5/00 Drawing NE-40014 Sheet 38, Zone 1, Rev. C, dated 5/8/00 Drawing NE-40014 Sheet 39, Zone 2, Rev. C, dated 5/8/00 Drawing NE-40014 Sheet 40, Zone 2, Rev. C, dated 5/8/00 Drawing NE-40014 Sheet 41, Zone 4 & 22, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 42, Zone 3 & 21, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 43, Zone 5, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 44, Zone 6, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 45, Zones 8, 10, 14 & 19 Flow Switch 2FS-6057, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 46, Zones 7, 9, & 13 & Flow Switch 2FS-5057, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 47, Zones 11, 15, & 17, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 48, Zones 12, 16 & 18, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 49, Pre-Action & Sprinkler System, Rev. D, dated 5/8/00 Drawing NE-40014 Sheet 50, Zone 20, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 51, D5/D6 Pre-Action Valves, Rev. B, dated 5/9/00 Drawing NE-40014 Sheet 52, Fire Detection Control Panel, Rev. B, dated 5/9/00 Drawing NF-40250-1, Wiring Diagram - Fire Detection Protection Panels 121 & 122, Rev. N, dated 10/26/00 Drawing NF-40250-2, Wiring Diagram Fire Detection Protection Panels 123 and 124, Rev. 76, dated 5/5/06 Drawing NF-40250-3, Wiring Diagram Fire Detection Protection Panels 125 and 126, Rev. T, dated 4/24/03 Drawing NF-40302-2, Wiring Diagram AC Distribution Panels 112, 1112, 114, 1114, 116 (B Train), Rev. 76, dated 5/08 Drawing NF-40889-10, W iring Diagram -11 Turbine Bearing Fire Protection Panel - Unit 1 Rev. C, dated 10/12/95 Drawings NF-40889-14, Wiring Diagram -21 Turbine Bearing Fire Protection Panel - Unit 2, Rev. A, dated 7/23/96 Drawings NF-40889-15, Transformer Fire Detection System Layout and Details Unit 1 & 2, Rev. 76, dated 12/13/05 Drawing NF-74564-4, 120/208V AC Distribution Panels 3135, 3145, 4135, and 4145 One Line Diagrams, Rev. 78, dated 11/16/09 Drawing NF-85593-1, Wiring Diagram - Fire Detection, Rev. E, dated 1/12/93 Drawing NF-85599, W iring Diagram AC Distribution Panels 236, 237, 238, & 240, Rev. 77, dated 12/08 Drawing NF-93024, Service Bldg. Lighting Details & Fixture List, Rev. 76, dated 2/1/10 Drawing NF-93025-2, Wiring Diagram - Service Building Control Panel 70456, Rev. B, dated 8/11/87 Drawings NF-116700, Fire Detection Plan - D5/D6 Bldg. Ground Floor Plan, Rev. B, dated 5/9/00 Drawing NF-111629, Schedules, Rev. 76, dated 5/5/06 Drawing NF-116701, Fire Detection Plan - D5/D6 Bldg. Grd. Fl. & Upper Deck, Rev. B, dated 10/2/92 Drawing NF-116702, Fire Detection Plan - D5/D6 Bldg Mezzanine Floor, Rev. B, dated 10/2/92 Drawing NF-116703, Fire Detection Plan - D5/D6 Bldg. Operating Floor, Rev. C, dated 5/8/00 Drawing NF-116709, Fire Detection Plan - D5/D6 Basement Floor, Rev. B, dated 10/2/92 Drawing NF-172049, FACP 70466 Control Room W iring diagram, Rev. 76, dated 1/26/05 PINGP                                                                                                 Page A-126 - Revision 1

Northern States Power - Minnesota                                                              Attachment A - NEI 04-02 Table B-1 Drawing NF-172049-1, W iring diagram FAIP 70467 & Assoc. Term. Boxes Unit 1 &2, Rev. 76, dated 1/26/05 Drawing NH-50383, NPD-SBO Fire Alarm System, Rev. B, dated 10/1/91 Drawing NX-48389-1, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-2, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-3, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-4, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-5, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-6, Fire Alarm System, Rev. 76, dated 3/21/05 Drawing NX-48389-7, Fire Alarm System, Rev. 76, dated 3/21/06 Drawing NX-48389-8, Building Monitor Annunciator, Rev. A, dated 10/30/90 Drawing NX-48389-9, NSP Administration Bldg Fire Protection System, Rev. A, dated 12/19/90 Drawing NX-48389-10, NSP Administration Bldg Fire Protection System, Rev. A, dated 12/19/90 Fleet Procedure FP-G-RM-01, Records Management, Rev. 10, dated 2/12/10 Procedure 5AWI 3.13.0, Fire Protection Program, Rev. 19, dated 3/16/09 Procedure 5AWI 3.15.0, Plant Operation, Rev. 30, dated 10/9/09 Procedure C31, Fire Protection & Detection Systems, Rev. 43, dated 4/17/09 Procedure C47022, Alarm Response Procedure, Rev. 47, dated 2/19/10 Procedure F5, Fire Fighting, Rev. 32, dated 9/9/09 Procedure F5 Appendix F, Fire Hazard Analysis, Rev. 20, dated 5/3/05 Procedure F5 Appendix K, Fire Protection Systems Functional Requirements, Rev. 15, dated 04/11/2012 Procedure ICPM 0-046, Fire Protection Sprinkler Flow Switch Test, Rev. 0, dated 1/17/06 Procedure SP 1200, Fire Protection System Supply to Safety Related Areas Valve Check, Rev. 32, dated 11/20/08 Procedure SP 1524, 122 Diesel Fire Pump Weekly Test, Rev. 37, dated 9/2/09 Procedure SP 1715, Fire Protection Panel Annual Functional Test, Rev. 8, dated 12/5/03 Procedure SP 2106, Fire Panel 70466 Detector Sensitivity Check, Rev. 7, dated 2/18/01 Industry-Related References NFPA 72D, "Proprietary Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service," 1967 Edition NFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems," 1986 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description              Summary FPEE-11-034                    NFPA 72D, 1967 Code           Each deviation has a separate Compliance Deviations.        justification, see evaluation for detailed bases.
FPEE-11-036                    NFPA 72D, 1986 Code           Each deviation has a separate Compliance Deviations         justification, see evaluation for detailed bases.
Items for Implementation None PINGP                                                                                                   Page A-127 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance     Compliance Statement Compliance Basis 3.8.1.1                   Fire Alarm              Means shall be provided  Complies             Per Section 2.1 of Procedure F5, "Fire Fighting,"
to allow a person                             the "Individual discovering a fire shall immediately observing a fire at any                       report it to the Control Room (CR) using the location in the plant to                      emergency numbers listed on the telephone, quickly and reliably                          (4911) giving location, type and intensity."
communicate to the control room or other                         Per Section 10.3.8 of the Updated Safety Analysis suitable constantly                           Report (USAR), "A fixed public address system attended location.                            interfaced with UPS powered Private Branch Plant Documentation                                                                             Exchange (PBX) telephone system provide Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                           normal and emergency communications. In the Updated Safety Analysis Report (USAR) Section 10, Rev. 32P                                      event of a PBX failure, power fail telephone stations from the local telephone office and Industry-Related References                                                                     extensions operating on the Xcel Energy Sherco None                                                                                            Plant Telephone Switch could be utilized to conduct emergency communications. In addition, Existing Engineering Equivalency Evaluations (EEEEs) a sound powered communications system is Identifier                     EEEE Description                 Summary                         installed with communications jacks located None                                                                                            throughout the plant. The sound powered system requires no external power, and headsets for use Items for Implementation                                                                        with the system are readily available."
None PINGP                                                                                                                      Page A-128 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.8.1.2                   Fire Alarm              Means shall be provided   Complies             (1) Per Sections 2.1 and 2.2 of Procedure F5, to promptly notify the                         "Fire Fighting," the individual discovering the fire following of any fire                          is required to notify the Control Room via an emergency in such a                            emergency telephone. "The Control Room way as to allow them to                        Operator shall respond as directed in the determine an                                   Annunciator Response Procedure for a fire appropriate course of                          detection panel alarm."
action:
Per Section 4.6, a "Fire Alarm page" is sent by the (1) General site                               Control Room Operator to notify plant occupants population in all                              of a fire alarm condition.
occupied areas Per Section 7.2.1 of Procedure E-PLAN, (2) Members of the                             "Emergency Plan," All emergency operating industrial fire brigade                        facilities have at least two means of and other groups                               communications: (1) portable or installed radio supporting fire                                systems; and (2) normal telephone emergency response                             communications. The normal onsite communications during an emergency will be (3) Off-site fire                              made via the plant telephone system with a public emergency response                             address system option. The telephone system is agencies. Two                                  powered by non-interruptible power. The public independent means                              address system includes about 175 loudspeakers shall be available (e.g.,                      located throughout the entire plant areaThe plant telephone and radio) for                       evacuation alarm consists of a 125 VDC operated notification of off-site                       siren, manually started from the Control Room.
emergency services.                            This tone consists of a signal starting at Plant Documentation                                                                              approximately 600 cycles per second rising to a Procedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010                                     peak of approximately 1450 cycles per second, Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11                                            then returning slowly to the low value of 600 cycles per second and repeating. The Control Industry-Related References                                                                      Room operator can remove the siren tone for None                                                                                             emergency voice communication over the loudspeaker PA system.
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                   Summary                        (2) Per Section 4.6 of Procedure F5, "Fire None                                                                                             Fighting," the fire brigade members are notified of Items for Implementation                                                                         a fire incident via a "Fire Alarm page" which is sent None                                                                                             by the Control Room Operator. Per Section 1.2.6, fire brigade members are equipped with a pager that can be activated from specified telephones.
(3) Per Section 6.1 of Procedure F5, "Fire Fighting," the primary off site fire department (Red Wing Fire Department) is available via telephone.
Per E-Plan Rev. 41, 3/29/2010 Section 7.2.2 Offsite Communications, Both normal and PINGP                                                                                                                        Page A-129 - Revision 1

Northern States Power - Minnesota                Attachment A - NEI 04-02 Table B-1 alternate communication links are provided to offsite agencies. The Xcel Energy telephone network provides normal communications to offsite agencies through telephone lines via the Red Wing US West telephone Exchange, or via Xcel Energy fiber optic SONET communications network. The Control Room, Technical Support Center and Near-Site EOF have a dedicated Xcel Energy radio channel link to the Xcel Energy System Control Center, the Backup EOF, and the Minnesota HSEM Emergency Operating Center in St. Paul, Minnesota. The Technical Support Center and Near-Site EOF have a National Warning System (NAWAS) extension to the Wisconsin Emergency Management EOC at Madison, the Regional W arning Center at Eau Claire and the Pierce County EOC at Ellsworth, Wisconsin. The Control Room, Technical Support Center and EOF each have a portable cellular phone for emergency communication use, as necessary. The Technical Support Center has access to a computerized auto dial system used for notification of the sites Emergency Response Organization (ERO). This system consists of a telephone network of several outgoing telephone lines. The Control Room, Technical Support Center and Near-Site EOF have multi-channel radio system for communication with all Plant Radiation Survey Teams, Plant Operations Personnel, Plant Security Areas, county sheriffs, county EOCs, and Treasure Island Casino (Prairie Island Indian Tribe).
PINGP                                                         Page A-130 - Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title       Requirement/Guidance        Compliance Statement   Compliance Basis 3.8.2                     Detection              If automatic fire detection Complies with Item for Automatic fire detection systems have been is required to meet the     Implementation         reviewed against the requirements of NFPA 72E, performance or                                     as detailed in "FPP-5 R2, NFPA 72E Code deterministic                                      Compliance Evaluation", dated 4/21/04.
requirements of Chapter Subsequent analysis of identified code deviations 4, then these devices was completed and required modifications have shall be installed in been captured in Attachment S, Table S-2.
accordance with NFPA 72, National Fire Alarm Code, and its applicable appendixes.
Plant Documentation Letter from Mayer (NSP) to Director (NRC) dated 11/30/79 Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80 Letter from NSP to Director of Nuclear Reactor Regulation (NRC) dated 10/24/80 Letter from Schwencer (NRC) to Mayer (NSP), dated 4/21/80 Letter from Long (NRC) to Parker (NSP) dated 4/28/92 NRC SER dated 9/6/79 Prairie Island Nuclear Generating Plant Appendix 7- NFPA 72E Code Compliance Review FPP-5 NFPA 72, Rev.2 April 21, 2004 NFPA 72E Code Compliance Deviations, FPEE for AR01003334 Design Basis Document DBD-TOP-06, Fire Protection/Appendix R Design Basis Document, Rev. 5, dated 10/8/09 Drawing NE-40007-127.1, 0.480Kv Bus 160 Motor Control Center IE Bus 1, Rev. DB, dated 5/5/79 Drawing NE-40009 Sheet 63, 208/120AC VAC Panel 116, Rev. BF, dated 10/7/99 Drawing NE-40011 Sheet 36, BOP Annunciator Point Schematic Diagram Field TB 131-140, SER Points 131-140, Rev. PS, dated 5/5/00 Drawing NE-40011 Sheet 37, Rev. AV, dated 8/1/05 Drawing NE-40011 Sheet 40, BOP Annunciator Point Schematic Diagram Field TB 171-180, SER Points 171-180, Rev. TU, dated 7/27/94 Drawing NE-40011 Sheet 105, BOP Annunciator Point Schematic Diagram Field TB 821-830, SER Points 821-839, Rev. G, dated 5/4/00 Drawing NE-40014 Sheet 6, Fire Detection Control Panel Power Supply, Rev. R, dated 3/23/94 Drawing NE-40014 Sheet 7, Fire Detection Control Panel, Rev. 76, dated 5/09 Drawing NE-40014 Sheet 8, Fire Detection Control Panel, Rev. 76, dated 5/09 Drawing NE-40014 Sheet 9, Fire Detection Control Panel, Rev. R, dated 11/13/87 Drawing NE-40014 Sheet 10, Fire Detection Control Panel, Rev. P, dated 9/14/88 Drawing NE-40014 Sheet 11, Fire Detection Control Panel, Rev. Q, dated 9/8/05 Drawing NE-40014 Sheet 12, Fire Detection Control Panel, Rev. 76, dated 5/6/06 Drawing NE-40014 Sheet 13, Fire Detection Control Panel, Rev. 76, dated 5/09 Drawing NE-40014 Sheet 14, Fire Detection Control Panel, Rev. W , dated 4/17/03 Drawing NE-40014 Sheet 15, Fire Detection Control Panel, Rev. W , dated 4/22/03 Drawing NE-40014 Sheet 16, Zones 5 & 7, Rev. M, dated 11/1/74 Drawing NE-40014 Sheet 17, Zones 9, 13, & 16, Rev. C, dated 7/2/84 Drawing NE-40014 Sheet 18, Zones 18 & 22, Rev. G, dated 9/25/95 Drawing NE-40014 Sheet 19, Zones 38, 41, & 45, Rev. D, dated 12/13/72 PINGP                                                                                                                        Page A-131 - Revision 1

Northern States Power - Minnesota                                                              Attachment A - NEI 04-02 Table B-1 Drawing NE-40014 Sheet 20, Zones 48, 58, 59, & 49, Rev. G, dated 5/9/96 Drawing NE-40014 Sheet 21, Zones 60, 61, 62, & 63, Rev. F, dated 8/16/23                   .
Drawing NE-40014 Sheet 22, Zones 76, 77, 78, 79, 80, 95, & 96, Rev. G, dated 11/29/92 Drawing NE-40014 Sheet 23, Local Red W arning Lights-Low Air Pressure in H.A.D., Rev. G Drawing NE-40014 Sheet 24, Deluge Valve Control, Rev. K, dated 3/7/95 Drawing NE-40014 Sheet 25, Transformer Deluge Valve Control and Indication Panel, Rev.
E, dated 8/3/88 Drawing NE-40014 Sheet 26, II Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit I, Rev. H, dated 12/20/73 Drawing NE-40014 Sheet 27, II Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -
5 Unit-1, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 28, II Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -
8 Unit-1, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 29, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit-2, Rev. H, dated 12/20/73 Drawing NE-40014 Sheet 30, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -5 Unit-2, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 31, 21 Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -8 Unit-2, Rev. F, dated 8/14/73 Drawing NE-40014 Sheet 32, Relay & Computer Room Fire Protection System, Rev. 76, dated 12/08/00 Drawing NE-40014 Sheet 42, Zone 3 & 21, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 43, Zone 5, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 44, Zone 6, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 45, Zones 8, 10, 14 & 19 Flow Switch 2FS-6057, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 46, Zones 7, 9, & 13 & Flow Switch 2FS-5057, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 47, Zones 11, 15, & 17, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 48, Zones 12, 16 & 18, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 49, Pre-Action & Sprinkler System, Rev. D, dated 5/8/00 Drawing NE-40014 Sheet 50, Zone 20, Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 51, D5/D6 Pre-Action Valves, Rev. B, dated 5/9/00 Drawing NE-40014 Sheet 52, Fire Detection Control Panel, Rev. B, dated 5/9/00 Drawing NF-40250-1, Wiring Diagram - Fire Detection Protection Panels 121 & 122, Rev. N, dated 10/26/00 Drawing NF-40250-2, Wiring Diagram Fire Detection Protection Panels 123 and 124, Rev. 76, dated 5/5/06 Drawing NF-40250-3, Wiring Diagram Fire Detection Protection Panels 125 and 126, Rev. T, dated 4/24/03 Drawing NF-40302-2, Wiring Diagram AC Distribution Panels 112, 1112, 114, 1114, 116 (B Train), Rev. 76, dated 4/2/2008 Drawing NF-40889-10, W iring Diagram -11 Turbine Bearing Fire Protection Panel - Unit 1 Rev. C, dated 10/12/95 Drawings NF-40889-14, Wiring Diagram -21 Turbine Bearing Fire Protection Panel - Unit 2, Rev. A, dated 7/23/96 Drawings NF-40889-15, Transformer Fire Detection System Layout and Details Unit 1 & 2, Rev. 76, dated 12/13/05 Drawing NF-74564-4, 120/208V AC Distribution Panels 3135, 3145, 4135, and 4145 One Line Diagrams, Rev. 78, dated 11/16/09 PINGP                                                                                                   Page A-132 - Revision 1

Northern States Power - Minnesota                                                            Attachment A - NEI 04-02 Table B-1 Drawing NF-85593-1, Wiring Diagram - Fire Detection, Rev. E, dated 1/12/93 Drawing NF-85599, W iring Diagram AC Distribution Panels 236, 237, 238, & 240, Rev. 79, dated 4/16/2012 Drawing NF-93024, Service Bldg. Lighting Details & Fixture List, Rev. 76, dated 2/1/10 Drawing NF-93025-2, Wiring Diagram - Service Building Control Panel 70456, Rev. B, dated 8/11/87 Drawings NF-116700, Fire Detection Plan - D5/D6 Bldg. Ground Floor Plan, Rev. B, dated 5/9/00 Drawing NF-111629, Schedules, Rev. 76, dated 5/5/06 Drawing NF-116701, Fire Detection Plan - D5/D6 Bldg. Grd. Fl. & Upper Deck, Rev. B, dated 10/2/92 Drawing NF-116702, Fire Detection Plan - D5/D6 Bldg Mezzanine Floor, Rev. B, dated 10/2/92 Drawing NF-116703, Fire Detection Plan - D5/D6 Bldg. Operating Floor, Rev. C, dated 5/8/00 Drawing NF-116709, Fire Detection Plan - D5/D6 Basement Floor, Rev. B, dated 10/2/92 Drawing NF-172049, FACP 70466 Control Room W iring diagram, Rev. 76, dated 1/26/05 Drawing NF-172049-1, W iring diagram FAIP 70467 & Assoc. Term. Boxes Unit 1 &2, Rev. 76, dated 1/26/05 Drawing NH-50383, NPD-SBO Fire Alarm System, Rev. B, dated 10/1/91 Drawing NX-48389-1, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-2, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-3, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-4, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-5, Fire Alarm System, Rev. 76, dated 9/8/05 Drawing NX-48389-6, Fire Alarm System, Rev. 76, dated 3/21/05 Drawing NX-48389-7, Fire Alarm System, Rev. 76, dated 3/21/06 Drawing NX-48389-8, Building Monitor Annunciator, Rev. A, dated 10/30/90 Drawing NX-48389-9, NSP Administration Bldg Fire Protection System, Rev. A, dated 12/19/90 Drawing NX-48389-10, NSP Administration Bldg Fire Protection System, Rev. A, dated 12/19/90 Fleet Procedure FP-G-RM-01, Records Management, Rev. 10, dated 2/12/10 Procedure 5AWI 3.13.0, Fire Protection Program, Rev. 21, dated 01/05/12 Procedure 5AWI 3.15.0, Plant Operation, Rev. 32, dated 9/23/11 Procedure C31, Fire Protection & Detection Systems, Rev. 43, 4/17/09 Procedure C47022, Alarm Response Procedure, Rev. 47, dated 2/19/10 Procedure F5, Fire Fighting, Rev. 33, dated 4/12/11 Procedure F5 Appendix F, Fire Hazard Analysis, Rev. 25A, dated 8/8/11 Procedure F5 Appendix K, Fire Protection Systems Functional Requirements, Rev. 15, dated 4/11/2012 Procedure ICPM 0-046, Fire Protection Sprinkler Flow Switch Test, Rev. 0, dated 1/17/06 Procedure SP 1200, Fire Protection System Supply to Safety Related Areas Valve Check, Rev. 32, dated 11/20/08 Procedure SP 1524, 122 Diesel Fire Pump Weekly Test, Rev. 37, dated 9/2/09 Procedure SP 1715, Fire Protection Panel Annual Functional Test, Rev. 8, dated 12/5/03 Procedure SP 2106, Fire Panel 70466 Detector Sensitivity Check, Rev. 7, dated 2/18/01 Industry-Related References NFPA 72E, "Standard on Automatic Fire Detectors" PINGP                                                                                                 Page A-133 - Revision 1

Northern States Power - Minnesota                                                           Attachment A - NEI 04-02 Table B-1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                Summary None Items for Implementation As described in Table S-2, item #8, required modifications have been identified and will be completed in accordance with the associated schedule.
PINGP                                                                                                Page A-134 - Revision 1

Northern States Power - Minnesota                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance Compliance Statement Compliance Basis 3.9                     Automatic and       Automatic and Manual Covered in the sub-  Covered in the sub-sections below Manual Water-       Water-Based Fire     sections below Based Fire          Suppression Systems.
Suppression System Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description             Summary N/A Items for Implementation N/A PINGP                                                                                                         Page A-135 - Revision 1

Northern States Power - Minnesota                                                                                Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title          Requirement/Guidance     Compliance Statement   Compliance Basis 3.9.1                    Automatic and             If an automatic or       Complies with use of   Per Section 4.0 of Procedure F5 Appendix F, "Fire Manual Water-             manual water-based fire  Existing Engineering   Hazard Analysis," "The Fire Protection System Based Fire                suppression system is    Equivalency Evaluation was designed for continuous standby service. The Suppression               required to meet the                            system was designed in accordance with some performance or                                  sections of the standards to the National Fire deterministic                                   Protection Association (NFPA) which were requirements of Chapter                         applicable in 1969 (1989 for D5/D6), except as 4, then the system shall                        identified and justified in the NFPA code be installed in                                 compliance review. The system was also based accordance with the                             on general recommendations of the Nuclear appropriate NFPA                                Energy Property Insurance Association (NEPIA) -
standards including the                         now Nuclear Electric Insurance Limited (NEIL)."
following:
Water mist and foam-water systems are not (1) NFPA 13, Standard                           installed at PINGP.
for the Installation of Sprinkler Systems                               Water-based fire suppression systems have been reviewed against the requirements of NFPA 13 and (2) NFPA 15, Standard                           15, as detailed in the system specific Code for Water Spray Fixed                           Compliance Reviews listed under Existing Systems for Fire                                Engineering Equivalency Evaluations.
Protection (3) NFPA 750, Standard on W ater Mist Fire Protection Systems (4) NFPA 16, Standard for the Installation of Foam-W ater Sprinkler and Foam-W ater Spray Systems Plant Documentation NRC SER dated 9/6/79 Procedure F5 Appendix F, Fire Hazard Analysis, Rev. 25A, dated 8/8/11 Industry-Related References NFPA 13, "Standard for the Installation of Sprinkler Systems," 1969 and 1987 Editions NFPA 15, "Standard for Water Spray Fixed Systems for Fire Protection," 1969 Edition Existing Engineering Equivalency Evaluations (EEEEs)
FPEE-11-009 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1991 PA-14 and PA-15, Automatic Preaction Systems Turbine Generator and Exciter Bearings Revision 0 FPEE-11-052 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1969, 1980, 1989, Stairway Suppression Systems SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, D5/D6 Stair (2FP-92-2) Revision 0 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1989 WPS-32 and 33 D5/D6 Fuel and Lube Oil Storage Tank Room, Code Compliance Review PINGP                                                                                                                          Page A-136 - Revision 1

Northern States Power - Minnesota                                                             Attachment A - NEI 04-02 Table B-1 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1969 PA-1 DG-1 & DG-2 Rooms Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1969, PA-9, Pre-Action Sprinkler System Screenhouse, Revision 1 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1989 D5 PA-12 Code Compliance Review, NFPA 13, Standard for the Installation of Sprinkler Systems, 1989 D6 PA-13 FPEE-11-011 Code Compliance Review NFPA 13, Standard for the Installation of Sprinkler Systems, 1969 WPS-15, WPS-16 and WPS-17, Wet Pipe Sprinkler Systems, Unit 2 Turbine Building 695ft, Revision 0 FPEE-11-042 Code Compliance Review NFPA 13, Standard for the Installation of Sprinkler Systems, 1969, WPS-10, Wet Pipe Sprinkler Systems Auxiliary Feedwater Pump Rooms, Revision 1 FPEE-11-010 Code Compliance Review NFPA 13, Standard for the Installation of Sprinkler Systems, 1969, WPS-7, WPS-8 and WPS-9, Wet Pipe Sprinkler Systems Unit 1 Turbine Building 695ft, Revision 0 FPEE-11-057 Code Compliance Review NFPA 13, Standard for the Installation of Sprinkler Systems, 1969, WPS-23, WPS-24, Wet Pipe Sprinkler Systems OCS Room (Records Room, Hot Instrument Lab) U1 Auxiliary Building 735ft, Revision 0 Code Compliance Review NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 1969, Turbine Oil Reservoir Water Spray Systems 11(DA-3) & 12 (DA-4)
Items for Implementation None PINGP                                                                                                  Page A-137 - Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.9.2                   Automatic and           Each system shall be      Complies             Per Section 4.2 of NRC SER dated September 6, Manual Water-           equipped with a water                          1979, "a fire detection and signaling system is Based Fire              flow alarm.                                    provided throughout many areas of the plant Suppression                                                            which transmits alarm and supervisory signals to Systems                                                                the control room where they are annunciated at Plant Documentation                                                                            the fire panel. In addition to handling fire detector NRC SER dated 9/6/79                                                                           signals, the system transmits indications of water System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                      flow from the sprinkler and deluge extinguishing systems."
Industry-Related References None                                                                                           Per Section 2 of System Description B31A, "Fire Protection System," "Each sprinkler system is Existing Engineering Equivalency Evaluations (EEEEs) equipped with a readily visible, manually operated, Identifier                   EEEE Description                Summary                           shutoff valve to isolate the system and a flow None                                                                                           switch or alarm check valve which activates an alarm upon initiation of water flow."
Items for Implementation None PINGP                                                                                                                     Page A-138 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance        Compliance Statement Compliance Basis 3.9.3                    Automatic and          All alarms from fire        Complies             Per Section 4.2 of NRC SER dated 9/6/79, "A fire Manual Water-          suppression systems                              detection and signaling system is provided Based Fire             shall annunciate in the                          throughout many areas of the plant which Suppression            control room or other                            transmits alarm and supervisory signals to the Systems.               suitable constantly                              control room where they are annunciated at the attended location.                               fire panel. In addition to handling fire detector Plant Documentation                                                                              signals, the system transmits indications of water NRC SER dated 9/6/79                                                                             flow from the sprinkler and deluge extinguishing Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                          systems. The system also indicates the operation Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire              of the carbon dioxide (CO2) extinguishing Protection System," dated 9/15/70                                                                systems. In all cases, the zone from which the alarm or supervisory signal is initiated is Industry-Related References                                                                      indicated."
None Existing Engineering Equivalency Evaluations (EEEEs)                                             Per Section 4.1.3 of Procedure F5 Appendix F, "Fire Hazard Analysis," "W ater flows from the Identifier                   EEEE Description                 Summary                            automatic wet pipe and preaction deluge None                                                                                             suppression systems are annunciated on the fire panel in the Control Room. Flows from manual Items for Implementation                                                                         hose stations are not annunciated, but they will None                                                                                             cause the fire pump to start, thereby transmitting a "fire pump running" signal to the Control Room."
Per Section 2.0 of Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," "The deluge and sprinkler systems contain integral alarm circuits to warn of fire, equipment malfunction, or tampering.
These audio and visual alarms, together with pressure gages and test and reset switches, provide complete monitoring of the fire protection system from the control room.
PINGP                                                                                                                       Page A-139 - Revision 1

Northern States Power - Minnesota                                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title         Requirement/Guidance          Compliance Statement      Compliance Basis 3.9.4                     Automatic and            Diesel-driven fire pumps      Complies with Item for    Per Section 5.19.4 of NRC SER dated 9/6/79, the Manual Water-            shall be protected by         Implementation            electric motor-driven and the diesel engine-driven Based Fire               automatic sprinklers.                                   fire pumps are located in the lower level of the Suppression                                                                      screenhouse. The entire screenhouse is protected Systems.                                                                         by a preaction type automatic sprinkler system.
Plant Documentation Per Table 6-1 of Procedure F5 Appendix F, "Fire NRC SER dated 9/6/79 Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                                    Hazard Analysis," the diesel-driven fire pump is located in Fire Area 41B, and is protected by a full-Industry-Related References                                                                                coverage, pre-action sprinkler system.
None Existing Engineering Equivalency Evaluations (EEEEs)                                                       Attachment S-2 item # 9 will move or install a sprinkler head above the Diesel Driven Fire Pump because of a large obstruction.
Identifier                     EEEE Description                  Summary None Items for Implementation As described in Table S-2, item #9, the modification will move or install a sprinkler head above the Diesel Driven Fire Pump because of a large obstruction.
PINGP                                                                                                                               Page A-140 - Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.9.5                   Automatic and           Each system shall be      Complies             Per Section 7.4.1 of Procedure F5 Appendix K, Manual Water-           equipped with an OS&Y                          "Fire Protection Systems Functional Based Fire              gate valve or other                            Requirements," "The system shall be functional at Suppression             approved shutoff valve.                        all times with a functional flow path capable of Systems.                                                               taking suction from the river and transferring water Plant Documentation                                                                            through distribution piping with functional sectional Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated     control or isolation valves to the yard hydrant 4/11/2012                                                                                      valves and the first isolation valve for each deluge System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                      system, hose station, or sprinkler system."
Industry-Related References                                                                    Per Section 3.9 of System Description B31A, "Fire None                                                                                           Protection System," the wet pipe sprinkler "systems are monitored by alarm valves and flow Existing Engineering Equivalency Evaluations (EEEEs) switches. A readily visible, manually operated Identifier                   EEEE Description                Summary                           shutoff valve is located upstream of each alarm None                                                                                           valve.
Items for Implementation                                                                       Per Section 3.11, the deluge systems are None                                                                                           provided with "A "Suprotex" valve to isolate the sprinklers from the water supply" Per Section 3.12, "All of the [Preaction Deluge Systems] except for PADs 12 and 13 (Unit 2, D5/D6 Diesel Generator Building), are equipped "Suprotex" deluge valves for isolating the system water supply The PAD systems for the D5/D6 Building are equipped with ASCOA "Model F" pre-action valves for isolating the system water supply."
Per Section 3.13, "Manual butterfly isolation valves are provided upstream of the deluge valve" on the Manual Deluge Systems.
PINGP                                                                                                                     Page A-141 - Revision 1

Northern States Power - Minnesota                                                                              Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.9.6                    Automatic and          All valves controlling     Complies             Per Section 8.5.11 of Procedure F5 Appendix K, Manual Water-          water-based fire                                "Fire Protection Systems Functional Based Fire             suppression systems                             Requirements," "Each valve (manual, power Suppression            required to meet the                            operated or automatic) in the flow path for safety-Systems.               performance or                                  related areas and areas posing a fire hazard to deterministic                                   safety-related areas shall be verified to be in the requirements of Chapter                         correct position and secured to prevent 4 shall be supervised as                        inadvertent misalignment every month."
described in 3.5.14.
Plant Documentation                                                                             Per Section 1.1 of Procedure SP 1200, "Fire Procedure 5AWI 3.10.1, "Methods of Performing Verifications," Rev. 16, dated 6/30/10            Protection System Supply to Safety Related Areas Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                         Valve Check," "The purpose of this surveillance is Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated      to verify that fire protection valves supplying safety 4/11/2012                                                                                       related areas, and areas posing a fire hazard to Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check,"         safety related areas, are in the correct position Rev. 32, dated 11/20/08                                                                         and secured."
Industry-Related References                                                                     Per Section 1.5.1, the acceptance criteria for all None                                                                                            water supply and fire suppression system control valves is "Valve verified open per 5AWI 3.10.1 Existing Engineering Equivalency Evaluations (EEEEs)
Appendix E" and "Block Wire in place."
Identifier                   EEEE Description                 Summary None                                                                                            Per Section 5.1, "Block W ire is required to prevent Items for Implementation                                                                        inadvertent mispositioning of valves."
None Appendix E of Procedure 5AWI 3.10.1, "Methods of Performing Verifications," provides instructions for inspecting valves to ensure they are adequately locked.
PINGP                                                                                                                       Page A-142 - Revision 1

Northern States Power - Minnesota                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance Compliance Statement Compliance Basis 3.10                    Gaseous Fire        Gaseous Fire         Covered in the sub-  Covered in the sub-sections below Suppression         Suppression Systems. sections below Systems Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description             Summary N/A Items for Implementation N/A PINGP                                                                                                         Page A-143 - Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #         Subsection Title        Requirement/Guidance      Compliance Statement   Compliance Basis 3.10.1                     Gaseous Fire            If an automatic total     Complies with Item for Per Section 4.0 of Procedure F5 Appendix F, "Fire Suppression             flooding and local        Implementation         Hazard Analysis," The Fire Protection System was Systems                 application gaseous fire                         designed for continuous standby service. The suppression system is                            system was designed in accordance with some required to meet the                             sections of the standards to the National Fire performance or                                   Protection Association (NFPA) which were deterministic                                    applicable in 1969 (1989 for D5/D6), except as requirements of Chapter                          identified and justified in the NFPA code 4, then the system shall                         compliance review. The system was also based be designed and                                  on general recommendations of the Nuclear installed in accordance                          Energy Property Insurance Association (NEPIA) -
with the following NFPA                          now Nuclear Electric Insurance Limited (NEIL)."
codes:
Per Section 4.2.7, "The relay and cable spreading (1) NFPA 12, Standard                            room is protected by an automatic 6 ton carbon on Carbon Dioxide                                dioxide (CO2) suppression system with alarm Extinguishing Systems                            sirens and a sixty-second delay. A detection system and a thermal actuation system is (2) NFPA 12A, Standard                           provided. Products of combustion detectors on Halon 1301 Fire                               provide an early warning alarm to the Control Extinguishing Systems                            Room. The auto action mode is normally bypassed when the room is occupied; however, the carbon (3) NFPA 2001,                                   dioxide system may be manually actuated at any Standard on Clean                                time. The carbon dioxide system is backed up by Agent Fire Extinguishing                         manual hose stations and extinguishers. The Systems                                          system is designed for total flooding application Plant Documentation                                                                                 with a 50 percent concentration for 15 minutes.
Storage tank capacity is adequate for two shots.
NRC SER dated 9/6/79 Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                             The system is actuated by thermal detectors with FPEE-11-038 Code Compliance Review, NFPA 12, Standard on Carbon Dioxide Extinguishing               provisions for manual actuation. The area is also Systems, 1972, Relay and Computer Room, Fire Area 18, 10/4/2011.                                    provided with fire detectors which alarm on the control Room fire panel."
Industry-Related References NFPA 12, "Standard on Carbon Dioxide Extinguishing Systems"                                         Per Section 4.3.2 of NRC SER dated 9/6/79, "A NFPA 12A, "Standard of Halon 1301 Fire Extinguishing Systems"                                       carbon dioxide (CO2) type gas fire suppression Existing Engineering Equivalency Evaluations (EEEEs)                                                system is provided in the cable spreading and relay room. The computer room is located within this Identifier                     EEEE Description                  Summary                            room and is also protected by the CO2 system. The None                                                                                                system is designed for total flooding application with a 50 percent concentration for 15 minutes. Storage Items for Implementation                                                                            tank capacity is adequate for two shots. The system is actuated by thermal detectors with provisions for Resolution of AR01306187 - NFPA Code issue: Thermal detection for actuation of FP                   manual actuation. The area is also provided with System. Identified deviations require a modification to resolve noncompliances associated           early warning detectors which indicate an alarm but with unprotected beam pockets and system supervision. This modification is identified in            does not actuate the CO2 suppression system. We Attachment S, Table S-2.                                                                            find that the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable.
PINGP                                                                                                                           Page A-144 - Revision 1

Northern States Power - Minnesota             Attachment A - NEI 04-02 Table B-1 NFPA 2001 does not apply, as there are no clean agent extinguishing systems at PINGP.
PINGP                                                      Page A-145 - Revision 1

Northern States Power - Minnesota                                                                            Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title        Requirement/Guidance      Compliance Statement Compliance Basis 3.10.2                  Gaseous Fire            Operation of gaseous      Complies             Per Section 3.0 of Procedure F5 Appendix F, " Fire Suppression             fire suppression systems                       Hazard Analysis," "Fire Detection Systems (FDS)
Systems                 shall annunciate and                           are provided throughout the plant. The fire alarm in the control room                      detectors are connected to an alarm which or other constantly                            annunciates either in the Control Room or at local attended location                              panels, which in turn alarms in the Control Room, identified.                                    thus providing the Control Room operator with an Plant Documentation                                                                            indication of system operation, tampering or Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                        malfunction. In addition to handling fire detector System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                      signals, the system transmits indication of water flow from the sprinkler and deluge extinguishing Industry-Related References                                                                    systems. In all cases, the zone from which the None                                                                                           alarm or signal is initiated is indicated. Indication of operation of the CO2 extinguishing system is Existing Engineering Equivalency Evaluations (EEEEs) indicated on a separate panel." Per Table 6-2, the Identifier                   EEEE Description                Summary                           Relay and Cable Spreading Room (Fire Area 18)
None                                                                                           and the Service Building/Computer Room (Fire Area 94) are monitored in the Detection Zone Items for Implementation                                                                       Control Room Circuit.
None Per Section 4.1, "System General Precautions", of System Description B31A, the Cardox suppression system is annunciated in the Control Room and "Upon actuation of the Cardox System, the Control Room operator shall dispatch an operator to clear any personnel from the Relay/Computer Rooms..."
PINGP                                                                                                                     Page A-146 - Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title       Requirement/Guidance      Compliance Statement Compliance Basis 3.10.3                  Gaseous Fire           Ventilation system        Complies             Per DBD-TOP-06, Design Bases Document for Fire Suppression            design shall take into                         Protection / Appendix R, Section 4.4.3 (E) (1) The Systems                account prevention from                        Relay Room penetration seals are protected from over-pressurization                            overpressurization on a Cardox actuation by during agent injection,                        allowing the room doors to open to relieve excess adequate sealing to                            pressure. The Unit 1 Relay Room door latch prevent loss of agent,                         deenergizes after a 50-second time delay, allowing and confinement of                             excess pressure to force the door open. The Unit 2 radioactive                                    Relay Room door latch deenergizes if the room Plant Documentation                            contaminants.                                  pressure exceeds 14 inches water column, allowing the door to open when the pressure becomes excessive.
Design Bases Document for Fire Protection / Appendix R, DBD TOP-06, Revision 5, 10/8/09 SP 1194, Cardox (Carbon Dioxide) 18 Month System Test, Revision 22, dated 7/10/13             Per SP 1194, Cardox (Carbon Dioxide) 18 Month System Test Section 8.0, NOTE: The desired Industry-Related References                                                                   TRIP point for DPS-99753 is 14 inches of H2O, or None                                                                                          0.5 psi.
Existing Engineering Equivalency Evaluations (EEEEs)                                          Confinement of radioactive contaminants is not required as there are no gaseous fire suppression Identifier                  EEEE Description                 Summary                          systems within the radiologically controlled area.
None Items for Implementation None PINGP                                                                                                                  Page A-147 - Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance       Compliance Statement Compliance Basis 3.10.4                  Gaseous Fire        In any area required to    N/A                  Not Applicable. PINGP does not have areas Suppression         be protected by both                            protected by both primary and backup gaseous Systems             primary and backup                              suppression.
gaseous fire suppression systems, a single active failure or a crack in any pipe in the fire suppression system shall not impair both the primary and backup fire suppression capability.
Plant Documentation None Industry-Related References None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description               Summary None Items for Implementation None PINGP                                                                                                               Page A-148 - Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance        Compliance Statement Compliance Basis 3.10.5                  Gaseous Fire        Provisions for locally      Complies             The CO2 suppression system is not provided with Suppression         disarming automatic                              provisions for local disarming. The system is Systems             gaseous suppression                              disarmed in the Control Room.
systems shall be secured and under strict                         Per Section 3.5 from Attachment 7 of Procedure administrative control.                          FP-OP-COO-01, "Conduct of Operations,"
Plant Documentation                                                                          "Equipment configuration shall be controlled such Procedure FP-OP-COO-01, "Conduct of Operations," Rev. 6, dated 07/08/2009                    that status of plant equipment is known at all times."
Industry-Related References None                                                                                         Per Section 3.10, "Repositioning of equipment during the conduct of maintenance and/or testing Existing Engineering Equivalency Evaluations (EEEEs) that is not covered by written instruction may be Identifier                 EEEE Description               Summary                            performed by qualified individuals provided these None                                                                                         manipulations are authorized by shift supervision.
Such manipulations must be formally tracked to Items for Implementation                                                                     ensure proper repositioning."
None PINGP                                                                                                                  Page A-149 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance        Compliance Statement  Compliance Basis 3.10.6                   Gaseous Fire           Total flooding carbon       Complies via Previous Per Section 4.3.2 of NRC SER dated 9/6/79, "A Suppression            dioxide systems shall       Approval              carbon dioxide (CO2) type gas fire suppression Systems                not be used in normally                           system is provided in the cable spreading and occupied areas.                                   relay room. The computer room is located within Plant Documentation                                                                               this room and is also protected by the CO2 NRC SER dated 9/6/79                                                                              system. The system is designed for total flooding Procedure C31, "Fire Protection & Detection Systems," Rev. 40, dated 6/3/09                       application with a 50 percent concentration for 15 System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11                         minutes The area is provided with early warning detectors which indicate an alarm but does not Industry-Related References                                                                       actuate the CO2 suppression system. We find that None                                                                                              the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and Existing Engineering Equivalency Evaluations (EEEEs) is, therefore, acceptable."
Identifier                    EEEE Description                Summary None                                                                                              Per Section 3.18 of System Description B31A, "Fire Protection System," "The Cardox System Items for Implementation                                                                          provides a total flood capability for the None                                                                                              Relay/Computer Room in the event of a fire Upon receipt of either an automatic or a manual signal, an alarm and a 60 second timer are actuated. The timer provides a delay period prior to system actuation to ensure all personnel have adequate time to evacuate the room."
Section 5.14.2 of Procedure C31, "Fire Protection
                                                                                                  & Detection Systems," defines the steps required to bypass the Cardox Dioxide System in the Computer Room.
The Cable Spreading and Relay room and the Computer room are all considered normally unoccupied spaces.
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                                                                                       Page A-150 - Revision 1

Northern States Power - Minnesota                                                                                  Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title        Requirement/Guidance        Compliance Statement   Compliance Basis 3.10.7                     Gaseous Fire           Automatic total flooding    Complies with Item for Per Section 7.8 of Procedure F5 Appendix K, "Fire Suppression            carbon dioxide systems      Implementation         Protection Systems Functional Requirements,"
Systems                shall be equipped with                             "The relay and cable spreading room is protected an audible pre-discharge                           by an automatic 6 ton carbon dioxide (CO2) alarm and discharge                                suppression system with alarm sirens and a sixty-delay sufficient to permit                         second delay. A detection system and a thermal egress of personnel.                               actuation system are provided. Smoke detectors The carbon dioxide                                 provide an early warning alarm to the Control system shall be provided                           Room."
with an odorizer.
Plant Documentation                                                                                  Per Section 3.18.B of System Description B31A, Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated           "Fire Protection System," "Upon receipt of either 4/11/2012                                                                                            an automatic or manual signal, an alarm and a 60 System Description B31A, "Fire Protection System." Rev. 12, dated 9/16/11                            second timer are actuated. The timer provides a FPEE-11-038 Code Compliance Review, NFPA 12, Standard on Carbon Dioxide Extinguishing                delay period prior to system actuation to ensure all Systems, 1972, Relay and Computer Room, Fire Area 18                                                 personnel have adequate time to evacuate the room."
Industry-Related References National Fire Protection Association (NFPA) 12 -1972, Standard on Carbon Dioxide                     The requirement for an odorizer is not in the 1972 Extinguishing Systems.                                                                               version of NFPA 12, Standard on Carbon Dioxide Extinguishing Systems which is the system design Existing Engineering Equivalency Evaluations (EEEEs) code of record. However, an odorizer will be Identifier                     EEEE Description                 Summary                              added to the system as a modification as outlined None                                                                                                 in Attachment S.
Items for Implementation An odorizer will be added to the carbon dioxide system protecting the relay and cable spreading room.
PINGP                                                                                                                          Page A-151 - Revision 1

Northern States Power - Minnesota                                                                             Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance       Compliance Statement Compliance Basis 3.10.8                   Gaseous Fire           Positive mechanical        Complies             Per Section 7.9.1 of Procedure F5 Appendix K, Suppression            means shall be provided                         "Fire Protection Systems Functional Systems                to lock out total flooding                      Requirements," "During those periods when the carbon dioxide systems                          relay and cable spreading room area is occupied, during work in the                              automatic initiation of the CO2 system may be protected space.                                bypassed. During those periods when the area is Plant Documentation                                                                             normally unoccupied, the CO2 system shall be Procedure F5 Appendix K "Fire Protection Systems Functional Requirements," Rev. 15, dated       capable of automatic initiation."
4/11/2012 Procedure C31, "Fire Protection & Detection Systems", Rev 52, dated 1/7/2012                    The mechanical bypass switch (CS-5843001) located in the Control Room disables the Industry-Related References                                                                     automatic function of the CO2 system, thereby None                                                                                            preventing actuation of the system while work is on-going in the area protected by the CO2 system.
Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                Summary None Items for Implementation None PINGP                                                                                                                      Page A-152 - Revision 1

Northern States Power - Minnesota                                                                               Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #        Subsection Title       Requirement/Guidance       Compliance Statement  Compliance Basis 3.10.9                    Gaseous Fire           The possibility of         Complies via Previous Per Item 131 of Letter from Mayer (NSP) to Stello Suppression            secondary thermal          Approval              (NRC) dated 12/8/76, "Comparison of Existing Systems                shock (cooling) damage                           Fire Protection Provisions to the Guidelines shall be considered                              Contained in Standard Review Plan 9.5.1," "CO2 during the design of any                         outlet nozzles are positioned to direct stream gaseous fire                                     away from concentrations of cables or cabinets."
suppression system, but particularly with carbon                         Per NRC SER dated 9/6/79, "We find that the gas dioxide.                                         fire suppression system satisfies the objectives Plant Documentation                                                                               identified in Section 2.2 of this report and is, therefore, acceptable."
NRC SER dated 9/6/79 Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76, "Comparison of Existing Fire Protection Provisions to the Guidelines Contained in Standard Review Plan 9.5.1,"                            Installed Halon 1301 systems are not required to meet the performance-based or deterministic Industry-Related References                                                                       requirements of NFPA 805 Chapter 4.
None Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                    EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                        Page A-153 - Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title      Requirement/Guidance       Compliance Statement Compliance Basis 3.10.10                 Gaseous Fire          Particular attention shall Complies             NFPA 12, Standard on Carbon Dioxide Suppression           be given to corrosive                           Extinguishing Systems, 2008, Annex G, General Systems               characteristics of agent                        Information on Carbon Dioxide decomposition products                          G.1. For fire-extinguishing applications, carbon on safety systems.                              dioxide has a number of desirable properties. It is Plant Documentation                                                                           noncorrosive, non-damaging, and leaves no None                                                                                          residue to clean up after the fire.
Industry-Related References NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2008 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                   Page A-154 - Revision 1

Northern States Power - Minnesota                                                                       Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title     Requirement/Guidance     Compliance Statement Compliance Basis 3.11                    Passive Fire         This section shall be    Covered in the sub-  Covered in the sub-sections below Protection Features  used to determine the    sections below design and installation requirements for passive protection features.
Passive fire protection features include wall, ceiling, and floor assemblies, fire doors, fire dampers, and through fire barrier penetration seals.
Passive fire protection features also include electrical raceway fire barrier systems (ERFBS) that are provided to protect cables and electrical components and equipment from the effects of fire.
Plant Documentation N/A Industry-Related References N/A Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                  EEEE Description                Summary None Items for Implementation None PINGP                                                                                                              Page A-155 - Revision 1

Northern States Power - Minnesota                                                                                 Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title        Requirement/Guidance         Compliance Statement Compliance Basis 3.11.1                   Building Separation     Each major building          Complies             The power block is defined in Attachment I to this within the power block                            Transition Report.
shall be separated from the others by barriers                            Per Section 2.2 of Procedure F5 Appendix F, "Fire having a designated fire                          Hazard Analysis," "Reinforced concrete (Grade B is resistance rating of 3                            used in the construction of structural components) hours or by open space                            requires the following minimum thicknesses to of at least 50 ft (15.2 m)                        provide a fire resistance of three hours, per UBC:
or space that meets the                           Walls - 6 1/2 inches; Floors - 4 1/2 inches; For all requirements of NFPA                              floors, the minimum required concrete (Grade B) 80A, Recommended                                  cover thickness of the reinforcing bars is 1 inch; for Practice for Protection of                        beams and columns the minimum required Buildings from Exterior                           concrete cover thickness is 1 1/2 inches. All PINGP Fire Exposures.                                   reinforced concrete walls supporting fire areas in safety-related structures are at least 12 inches in Exception: W here a                               thickness. All floor slabs between floors are at least performance-based                                 5 1/2 inches in thickness with a concrete covering analysis determines the                           reinforcing steel of at least 1 inch. Two exceptions adequacy of building                              are the 8 inch concrete floors over the OSC room separation, the                                   and the Operators Lounge, which have a concrete requirements of 3.11.1                            cover of 3/4 inch. These two floors, although acting shall not apply.                                  as fire barriers, act only as an enclosing ceiling and Plant Documentation                                                                                support no equipment. The D5/D6 Building three Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                            hour barriers adequately separate redundant trains, fuel oil/lube oil storage, and the stairwell. Concrete Industry-Related References                                                                        beam and column reinforcing steel has at least a FAQ 06-0019, "Definition of 'Power Block' and 'Plant'," Rev. 4, dated 9/28/07                      cover of 1 1/2 inches. In some cases, concrete NFPA 80A, "Recommended Practice for Protection of Buildings from Exterior Fire Exposure,"          masonry units (calcareous or siliceous gravel) are 1967 and 1987 Editions                                                                             used in the construction of fire barrier walls with a minimum thickness of 6 inches. The minimum Existing Engineering Equivalency Evaluations (EEEEs)                                               thickness of these walls required for a fire resistance of three hours is 5.3 inches.
Identifier                    EEEE Description                 Summary None Items for Implementation None PINGP                                                                                                                          Page A-156 - Revision 1

Northern States Power - Minnesota                                                                                    Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #       Subsection Title       Requirement/Guidance           Compliance Statement   Compliance Basis 3.11.2                   Fire Barriers          Fire barriers required by      Complies with use of   Per Section 2.1 of Procedure F5 Appendix F, "Fire Chapter 4 shall include a      Existing Engineering   Hazard Analysis," "Walls that do not protect safe specific fire-resistance       Equivalency Evaluation shutdown equipment are maintained as unrated rating. Fire barriers shall                           barriers. In all cases, good fire prevention be designed and                                       practices are followed."
installed to meet the specific fire resistance                              Per Section 2.2, "Fire Hazard Analysis," "Barriers rating using assemblies                               that must be maintained as three hour rated qualified by fire tests.                              barriers per BTP 9.5-1 or Appendix R are those The qualification fire                                that:
tests shall be in accordance with NFPA                                  A. Separate safety-related systems from any 251, Standard Methods                                 potential fires in non-safety related areas that of Tests of Fire                                      could affect their ability to perform their safety Endurance of Building                                 function; Construction and Materials, or ASTM E                                  B. Separate redundant divisions or trains of safety-119, Standard Test                                    related systems from each other so that both are Methods for Fire Tests of                             not subject to damage from a single fire; or Building Construction and Materials.                                        C. Separate individual units.
Plant Documentation Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                               "All safeguard equipment is located within Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated            structures or compartments designed to seismic 4/11/2012                                                                                             Category 1 requirements which require the use of building materials inherently resistive to structural Industry-Related References                                                                           damage due to fire. Safety-related systems are NFPA 251, "Standard Methods of Tests of Fire Endurance of Building Construction and                   also separated from high concentrations of Materials," 1999 Edition                                                                              combustible material by reinforced concrete or concrete masonry walls. Reinforced concrete Existing Engineering Equivalency Evaluations (EEEEs)
(Grade B is used in the construction of structural Identifier                   EEEE Description                  Summary                                components) requires the following minimum FPEE-12-006                  FA 85 Boundaries and F5           The evaluation assesses the            thicknesses to provide a fire resistance of three Appendix K Barriers               impact of postulated fires on          hours, per UBC: W alls - 6 1/2 inches; Floors - 4 either side of the Fire Area 85        1/2 inches; boundaries that communicate with Fire Areas 60 and 75 on           "For all floors, the minimum required concrete the 715ft elevation and Fire           (Grade B) cover thickness of the reinforcing bars Areas 59 and 74 on the 715ft           is 1 inch; for beams and columns the minimum elevation for impact on fire           required concrete cover thickness is 1 1/2 inches."
safe shutdown capability. The evaluation also assesses the           "All PINGP reinforced concrete walls supporting location of the F5 Appendix K          fire areas in safety-related structures are at least barrier separating Fire Area 85        12 inches in thickness. All floor slabs between and Fire Areas 59 and 74 on            floors are at least 5 1/2 inches in thickness with a the 715ft elevation.                   concrete covering reinforcing steel of at least 1 inch. Two exceptions are the 8 inch concrete Based on the evaluation, there         floors over the OSC room and the Operators is reasonable assurance that           Lounge, which have a concrete cover of 3/4 inch.
PINGP                                                                                                                             Page A-157 - Revision 1

Northern States Power - Minnesota                                                                        Attachment A - NEI 04-02 Table B-1 fire will not spread between       These two floors, although acting as fire barriers, act Fire Area 85 and Fire Areas 60     only as an enclosing ceiling and support no and 75 on the 735ft elevation      equipment.
and between Fire Area 85 and Fire Areas 59 and 74 on the        "Concrete beam and column reinforcing steel has 715ft elevation and adversely      at least a cover of 1 1/2 inches. In some cases, impact fire safe shutdown          concrete masonry units (calcareous or siliceous capability.                        gravel) are used in the construction of fire barrier walls with a minimum thickness of 6 inches. The FPEE-11-020                NFPA Codes Referenced in    The evaluation documents the       minimum thickness of these walls required for a NFPA 805 not addressed by   review of the NFPA codes           fire resistance of three hours is 5.3 inches."
separate code reviews       referenced in NFPA 805 that are not addressed in individual    Per Section 7.16.A of Procedure F5 Appendix K, NFPA code compliance               "Fire Protection Systems Functional reviews.                           Requirements," "The PINGP has been designed generally with physical separation to prevent the A deviation was identified         spread of a postulated fire in safe shutdown regarding the use of a radiant     equipment areas to prevent the loss of both energy shield in Unit 1            Appendix R trains. This separation is maintained Containment that has not been      in part by fire resistive compartment isolation of demonstrated to have a 1/2-          plant safety systems. The walls and ceilings of hour fire rating when subject to   such compartments are rated fire barriers. These testing following ASTM E-119.      walls and ceilings contain penetrations for the AR 01317872 is tracking            passage of pipes and electrical cables from one resolution of this issue.          fire area to another. Therefore, these penetrations are a breach of the fire barriers and must be sealed FPEE-12-010                Fire Area 15 Access Control                                    so as to maintain the integrity of the fire barriers.
The purpose of this evaluation Ceiling, Revision 0                                            PINGP is divided into fire areas based on general is to assess the adequacy of the fire area boundary             plant layout and fire protection equipment. Existing separating Fire Area 15,           barriers, including the containment vessels, were Access Control, from Fire Area     used whenever possible for the fire area 59, Auxiliary Building             boundaries. All safeguards equipment is located Mezzanine Level Unit 1. Both       within structures or compartments designed to fire areas are located on the      seismic Category I requirements 715ft elevation of the Auxiliary   which require the use of building materials Building. Fire Area 15 is part     inherently resistive to structural damage due to height within Fire Area 59, with   fire. Safety-related systems are also separated a ceiling height of 10ft 5-1/2in,  from high concentrations of combustible material while Fire Area 59 extends the     by reinforced concrete or concrete masonry walls."
full height of the 715ft elevation to the underside of the 735ft elevation. The ceiling of Fire Area 15 forms a mezzanine accessible by a ladder within Fire Area 59. The barrier is identified as an F5 Appendix K barrier. The ceiling of Fire Area 15 is constructed of 3in of concrete, and all penetrations are sealed full depth with grout, PINGP                                                                                                                 Page A-158 - Revision 1

Northern States Power - Minnesota                                Attachment A - NEI 04-02 Table B-1 RTV silicone foam, Kaowool, or thermal insulating wool, with damming material and Flamemastic coating on both sides.
Items for Implementation None PINGP                                                                     Page A-159 - Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title Requirement/Guidance         Compliance Statement   Compliance Basis 3.11.3                  Fire Barrier     Penetrations in fire         Complies with use of   Per Section 7.16.1.B of Procedure F5 Appendix K, Penetrations     barriers shall be            Existing Engineering   "Fire Protection Systems Functional provided with listed fire-   Equivalency Evaluation Requirements," "Fire doors and frames in Appendix rated door assemblies or                            R-required fire barriers are rated to the equivalent listed rated fire dampers                           fire resistance duration of three hours, in having a fire resistance                            accordance with the criteria established in rating consistent with the                          NFPA 252, Standard Methods of Fire Tests of designated fire                                     Door Assemblies, 1968, ed."
resistance rating of the barrier as determined by                            Fire doors have been reviewed against the the performance                                     requirements of NFPA 80, as detailed in the Code requirements                                        Compliance Review - NFPA 80, Standard for Fire established by Chapter                              Doors and Windows, 1968 ed.," Rev 1, dated
: 4. (See 3.11.3.4 for                                11/7/11 and "Code Compliance Review - NFPA penetration seals for                               80, Standard for Fire Doors and Windows, 1986 through penetration fire                            ed.," dated 11/7/12) stops.) Passive fire protection devices such                             Per Section 3.2.5 of Letter from Schwencer (NRC) as doors and dampers                                to Mayer (NSP) dated 4/21/80, "the licensee shall conform with the                              proposed to install fire dampers in all ventilation following NFPA                                      ducts which are unprotected and could endanger standards, as                                       areas containing safe shutdown equipment in the applicable:                                         event of a fire. Further, the licensee committed to provide three hour fire dampers in those ducts (1) NFPA 80, Standard                               communicating with the Turbine Building. The for Fire Doors and Fire                             licensee has shown to our satisfaction that all Windows                                             ventilation ducts which could endanger areas containing safe shutdown equipment will be (2) NFPA 90A, Standard                              protected with fire dampers. Based on our review, for the Installation of Air-                        we find the licensee's commitment to provide fire Conditioning and                                    dampers in ventilation ducts in all fire zones Ventilating Systems                                 containing equipment necessary for safe shutdown." Fire dampers have been reviewed (3) NFPA 101, Life                                  against the requirements of NFPA 90A, as Safety Code                                         detailed in the Code Compliance Review - NFPA 90A, Standard for the Installation of Air Exception: W here fire                              Conditioning and Ventilating Systems, 1969 ed.,
area boundaries are not                             dated 9/12/07 and "Code Compliance Review -
wall-to-wall, floor-to-                             NFPA 90A, Standard for the Installation of Air ceiling boundaries with                             Conditioning and Ventilating Systems, 1978 ed.,"
all penetrations sealed                             dated 9/12/07.3) Fire rated door assembly to the fire rating required                         requirements are addressed in Section 8.2.3.2.1 of the boundaries, a                                of NFPA 101 which refers to NFPA 80, and is performance-based                                   evaluated in the Code Compliance Review -
analysis shall be                                   NFPA 80, Standard for Fire Doors and W indows, required to assess the                              1968 ed., Rev 1, dated 11/7/11 and "Code adequacy of fire barrier                            Compliance Review - NFPA 80, Standard for Fire forming the fire                                    Doors and Windows, 1986 ed.," dated 11/7/11.
boundary to determine if                            Rated fire dampers requirements are addressed PINGP                                                                                                                    Page A-160 - Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 the barrier will withstand                 in Section 9.2.1 of NFPA 101 which refers to NFPA the fire effects of the                    90A, and is evaluated in the Code Compliance hazards in the area.                       Review - NFPA 90A, Standard for the Installation Plant Documentation                                                                          of Air Conditioning and Ventilating Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80; Fire Protection Engineering        Systems, 1969 ed., dated 9/12/07 and "Code Evaluation FPEE-12-003, CA-01311055-01, Fire Door Frames, Revision 0, 4/5/2012; Fire         Compliance Review - NFPA 90A, Standard for the Protection Engineering Evaluation, FPEE-CA124448-02, Revision 0, 1/20/2012; Code             Installation of Air Conditioning and Ventilating Compliance Review NFPA 80-1968, FPEE-11-049, "Code Compliance Review - NFPA 80,              Systems, 1978 ed.," dated 9/12/07 Standard for Fire Doors and Windows, 1968 ed.," Rev 1, dated 11/7/11,Code Compliance Review NFPA 80-1986, FPEE-11-019, "Code Compliance Review - NFPA 80, Standard for Fire Doors and W indows, 1986 ed.," dated 11/7/11, FPEE-11-022 Code Compliance Review NFPA 90A-1969, "Code Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, Code Compliance Review NFPA 90A-1978, "Code Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, 1978 ed.," dated 11/29/2011Procedure F5 Appendix F "Fire Hazard Analysis," Rev. 25A, dated 8/8/11; Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012 Industry-Related References NFPA 80, "Standard for Fire Doors and Fire W indows," 1968 and 1986 Editions NFPA 90A, "Installation of Air Conditioning and Ventilating Systems," 1969 and 1978 Editions NFPA 101, "Life Safety Code," 2000 Edition Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                     EEEE Description                  Summary CE0112159401                   Engineering evaluations can       See individual evaluation FPEE 0113625201                be found in the SharePoint CA 0124445802                  Portal.
CA 0131104601 CA 0131105701 FPEE 0124191701 FPEE 10-006AR 117907003 FPEE 11001 FPEE 11019 FPEE 11021 FPEE 11022 FPEE 11049 FPEE 12002 CA 013274301 FPEE 12003 CA 0131105501 FPEE 12004 CA 0131380801 Items for Implementation None PINGP                                                                                                                   Page A-161 - Revision 1

Northern States Power - Minnesota                                                                          Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title Requirement/Guidance         Compliance Statement  Compliance Basis 3.11.4                  Through          Through penetration fire     Complies via Previous Per Section 2.4 of Procedure F5 Appendix F, "Fire Penetration Fire stops for penetrations       Approval              Hazard Analysis," "All (cable) penetration seals Stops            such as pipes, conduits,                           passed the criteria of no flame passage, bus ducts, cables, wires,                          temperature, and hose stream test of IEEE 634.
pneumatic tubes and                                Fire stops are not provided at intermediate points ducts, and similar                                 in vertical or horizontal cable spans. Penetrations building service                                   are sealed with packed thermal fiber or foam and equipment that pass                                covered with thermal board and approximately 1/8 through fire barriers                              in. coat of thermal mastic. W here the penetration shall be protected as                              is through a structure forming the boundary follows.                                           between ventilation zones, fire dampers have been installed except where determined (a) The annular space                              unnecessary by evaluation. Conduit penetrations between the penetrating                            through walls, floors, and ceilings of the relay/cable item and the through                               spreading rooms are provided with fire stops."
opening in the fire barrier shall be filled with                       Per Section 2.5, "Most piping penetrations in walls a qualified fire-resistive                         and floors, in safety-related areas of the plant, are penetration seal                                   sealed. In those instances where seals are not assembly capable of                                provided, evaluations exist to justify conditions. The maintaining the fire                               small area surrounding pipe is sealed with a resistance of the fire                             qualified penetration seal, designed for the barrier. The assembly                              maximum fire severity on either side of the barrier, shall be qualified by tests                        and to allow for thermal movement. In all cases, in accordance with a fire                          when new penetrations are sealed, the sealing test protocol acceptable                           material is noncombustible, or, as in the case of to the AHJ or                                      silicone foam, has been reviewed and found be protected by a listed                           acceptable by the NRC."
fire-rated device for the specified fire-resistive                           Per Enclosure 1 to Letter from Clark (NRC) to period.                                            Mayer (NSP) dated 12/29/80, "The test slab containing the penetrations was placed on a (b) Conduits shall be                              horizontal furnace and exposed to the ASTM E119 provided with an internal                          time/temperature curve for 3-hours. The ASTM fire seal that has an                              E119 time/temperature curve is the standard equivalent fire-resistive                          time/temperature curve used for fire endurance rating to that of the fire                         tests. After three hours the test slab was lifted in a barrier through opening                            horizontal position and subjected to a hose stream fire stop and shall be                             test. The hose stream test was performed in permitted to be installed                          accordance with the recommendations of IEEE on either side of the                              634-1978, "Standard Cable Fire Stop Qualification barrier in a location that                         Test," which is an acceptable method. The is as close to the barrier                         acceptance criteria for the fire stops was based on as possible.                                       the acceptance criteria in IEEE 634-1978. W e find the acceptance criteria for the test provide Exception: Openings                                reasonable assurance that the penetration seals inside conduit 4 in (10.2                          will be capable of preventing a fire from spreading cm) or less in diameter                            from one fire area to another. All of the tested shall be sealed at the PINGP                                                                                                                  Page A-162 - Revision 1

Northern States Power - Minnesota                                                                         Attachment A - NEI 04-02 Table B-1 fire barrier with a fire-                penetration seals qualified as three-hour seals.
rated internal seal                      "Based on our review and the test data, we find unless the conduit                       that the penetration seals are qualified as 3-hour extends greater that 5 fit               fire rated seals. Therefore, we conclude that the (1.5 m) on each side of                  licensee's proposed modification regarding the fire barrier. In this                upgraded penetration firestops is acceptable."
case the conduit opening shall be                         Procedure D52, "Installation Guidelines for the provided with                            Permanent & Temporary Sealing of noncombustible material                  Electrical/Mechanical Openings between to prevent the passage                   Established Fire Areas," provides guidelines and of smoke and hot gases.                  procedures for the installation of penetration The fill depth of the                    seals, including material requirements. Section material packed to a                     1.0 states, "The purpose of this installation depth of 2 in. (5.1 cm)                  guideline is to establish the controls & instructions shall constitute an                      necessary for new, existing and/or temporary acceptable smoke and                     electrical/mechanical openings that will be hot gas seal in this                     constructed or have been breached during application                              construction/maintenance work. These guidelines Plant Documentation                                                                        are designed to meet the conditions set forth by Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80                                      Operations Manual F5 Appendix K (fire Engineering Manual 2.1.14, "Engineering Design, Fabrication, and Installation Summary for  penetrations), T.S.3.7.12 for Aux Building Special Fire Barriers and Penetration Seals," Rev. 1, dated 1/26/00                                Vent Zone and H27 for Steam Exclusion."
Procedure D52, "Installation Guidelines for the Permanent & Temporary Sealing of Electrical/Mechanical Openings between Established Fire Areas," Rev. 13, dated 1/27/09     Per Section 7.16.C of Procedure F5 Appendix K, Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11                    "Fire Protection Systems Functional Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated Requirements," Piping and electrical penetrations 4/11/2012                                                                                  are provided with qualified seals where they penetrate boundaries between fire areas. Seals are Industry-Related References                                                                qualified for the maximum fire severity present on None                                                                                       either side of the barrier. Seals are installed in the annulus with a qualified penetration seal designed Existing Engineering Equivalency Evaluations (EEEEs) to allow for thermal movement.
Identifier                     EEEE Description                  Summary None                                                                                       Operations Manual Section D52, "Installation Guidelines for the Permanent and Temporary Items for Implementation                                                                   Sealing of Electrical/Mechanical Openings Between None                                                                                       Established Fire Areas", provides the overall requirements to be met for the design of seals on the fire barrier penetrations, thus maintaining fire confinement capability and limiting the spread of a potential fire. D52 includes the requirements for internal conduit seals. The original penetration inventory, sketches, and retrofit modifications are located in QUAD-5-80-008, Rev. 6, PI Rev. 0, and are filmed under modification 79Y084 (Film Reel
                                                                                           #0984-0037). The current penetration inventory is maintained in the Penetration Seal Database."
PINGP                                                                                                                 Page A-163 - Revision 1

Northern States Power - Minnesota              Attachment A - NEI 04-02 Table B-1 The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP                                                       Page A-164 - Revision 1

Northern States Power - Minnesota                                                                           Attachment A - NEI 04-02 Table B-1 NFPA 805 Section #      Subsection Title    Requirement/Guidance      Compliance Statement   Compliance Basis 3.11.5                  Electrical Raceway  ERFBS required by         Complies with use of   Electrical raceway fire barrier systems are Fire Barrier System Chapter 4 shall be        Existing Engineering   installed at PINGP.
(ERFBS)             capable of resisting the  Equivalency Evaluation fire effects of the                              Per Section 2.1 of Procedure F5 Appendix E, "Fire hazards in the area.                             Protection Safe Shutdown Analysis Summary,"
ERFBS shall be tested                            "Except as provided for in paragraph G.3 of this in accordance with and                           section, where cables or equipment, including shall be tested in                               associated non-safety circuits that could prevent accordance with and                              operation or cause maloperation due to hot shall meet the                                   shorts, open circuits, or shorts to ground, of acceptable criteria of                           redundant trains of systems necessary to achieve NRC Generic Letter 86-                           and maintain Hot Shutdown conditions are located 10, Supplement 1, "Fire                          within the same fire area outside of primary Endurance Test                                   containment, one (1) of the following means of Acceptance Criteria for                          ensuring that one (1) of the redundant trains is Fire Barrier Systems                             free of fire damage shall be provided: A.
Used to Separate Safe                            Separation of cables and equipment and Shutdown Trains W ithin                          associated non-safety circuits of redundant trains the Same Fire Area".                             by a fire barrier having a 3-hour rating. Structural The ERFBS needs to                               steel forming a part of or supporting such fire adequately address the                           barriers shall be protected to provide fire design requirements and                          resistance equivalent to that required of the limitations of supports                          barrier; B. Separation of cables and equipment and intervening items                            and associated non-safety circuits of redundant and their impact on the                          trains by a horizontal distance of more than 20 fire barrier system                              feet with no intervening combustible or fire rating. The fire barrier                         hazards. In addition, fire detectors and an system's ability to                              automatic fire suppression system shall be maintain the required                            installed in the fire area; or C. Enclosure of cable nuclear safety circuits                          and equipment and associated non-safety circuits free of fire damage for a                        of one (1) redundant train in a fire barrier having a specific thermal                                 one (1) hour rating. In addition, fire detectors and exposure, barrier design,                        an automatic fire suppression system shall be raceway size and type,                           installed in the fire area;"
cable size, fill and type shall be demonstrated.                           Per Section 2.6, "the SBO/ESU Project established and enhanced basic routing paths for trained Exception No. 1: When                            cables. Certain fire areas were designated as the temperatures inside                          basic Train A (or B) routes or areas, meaning that the fire barrier system                          normally Train A (or B) cables would be exceed the maximum                               routed through the area. Thus, in a Train A area, it temperature allowed by                           is expected that Train A systems and components the acceptance criteria                          would be affected by a fire and that Train B would of Generic Letter 86-10,                         be relied on for safe shutdown. This methodology "Fire Endurance                                  allows protecting (wrapping) the least affected Acceptance Test Criteria                         train in each area. (The previous analyses for Fire Barrier Systems                         essentially provided for Train A operation in the Used to Separate                                 event of a control room fire and ensuring that Redundant Safe                                   Train B would be available for other fires.) For the PINGP                                                                                                                    Page A-165 - Revision 1

Northern States Power - Minnesota                                                                         Attachment A - NEI 04-02 Table B-1 Shutdown Training                          most part, Train B would be protected and Within the Same Fire                       credited in Train A areas and Train A would be Area," Supplement ,                        protected and credited in Train B areas."
functionality of the cable at these elevated                          Per Section 2.7.2, "All cables and components, temperatures shall be                      identified in the circuit analyses as being required demonstrated.                              for operation, are included in the Safe Shutdown Qualification                              data base along with the cable route and demonstration of these                     component location. Once all cables and cables shall be                            components were entered, reports were generated performed in                               that summarize required information needed for accordance with the                        the overall analysis. A compliance assessment electrical testing                         summary, and a compliance assessment report is requirements of Generic                    included for every fire area that contains required Letter 86-10,                              safe shutdown cables."
Supplement 1, Attachment 1,                              Engineering Manual 4.3.1-E, "Engineering Design, "Attachment Methods for                    Fabrication and Installation Summary for Fire Demonstrating                              Barriers," provides detailed specifications and Functionality of Cables                    installation instructions for electrical raceway fire Protected by Raceway                       barrier systems in accordance with NRC GL 86-10 Fire Barrier Systems                       Supplement 1.
During and After Fire Endurance Test                             FPEE-2005-001 Qualification of PCI PROMATEC Exposure."                                 INTERAM" Flexible Fire Protective System, evaluation performed a detailed comparison and Exception No. 2:                           analysis of the fire wrap design configurations to ERFBS systems                              fire-tested configurations and concluded that the employed prior to the                      system applied to 1CB-31 is considered qualified issuance of Generic                        for a fire endurance rating of 1-hour in accordance Letter 86-10.                              with USNRC GL 86-10 Supplement 1.
Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements as specified by the AHJ at Plant Documentation Engineering Manual EM 4.3.1-E, "Engineering Design, Fabrication and Installation Summary for Fire Barriers," Rev. 2, dated 4/19/01 Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10 FPEE-2005-001 Qualification of PCI PROMATEC INTERAM" Flexible Fire Protective System Industry-Related References USNRC IN-95-52, Supplement Fire Endurance Test Results for Electrical Raceway Fire Barrier Systems Constructed from 3M Company Interam Fire Barrier Materials.
PINGP                                                                                                                  Page A-166 - Revision 1

Northern States Power - Minnesota                                                         Attachment A - NEI 04-02 Table B-1 Existing Engineering Equivalency Evaluations (EEEEs)
Identifier                 EEEE Description              Summary FPEE-2005-001              This Fire Protection          The evaluation performed a Qualification of PCI       Engineering Evaluation        detailed comparison and PROMATEC INTERAM"          (FPEE) is written to          analysis of the fire wrap design Flexible Fire Protective   demonstrate the acceptability configurations to fire-tested System                     of the fire protected conduit configurations and concluded 1CB-31. This protection has   that the system applied to 1CB-been achieved with the 3M     31 is considered qualified for a Interam Flexible Fire W rap   fire endurance rating of 1-hour System as necessary to        in accordance with USNRC GL achieve the required fire     86-10 Supplement 1.
rating of one-hour.
Items for Implementation None PINGP                                                                                              Page A-167 - Revision 1

Northern States Power - Minnesota       Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review B. NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review 97 Pages Attached PINGP                                                                Page B Revision 1

Northern States Power - Minnesota                                                                                                     Attachment B - NEI 04-02 Table B-2 2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection (Taken From NFPA 805, 2001 Edition)
A comprehensive list of systems and equipment and their interrelationships to be analyzed for a fire event shall be developed. The equipment list shall contain an inventory of those critical components required to achieve the nuclear safety performance criteria of Section 1.5. Components required to achieve and maintain the nuclear safety functions and components whose fire-induced failure could prevent the operation or result in the maloperation of those components needed to meet the nuclear safety criteria shall be included. Availability and reliability of equipment selected shall be evaluated.
NEI 00-01 Ref                                            NEI 00-01 Section 3.0 Guidance 3.0            Deterministic Methodology                 This section discusses a generic deterministic methodology and criteria that licensees can use to perform a post-fire safe shutdown analysis to address regulatory requirements. The plant-specific analysis approved by NRC is reflected in the plants licensing basis. The methodology described in this section is also an acceptable method of performing a post-fire safe shutdown analysis. This methodology is indicated in Figure 3-1. Other methods acceptable to NRC may also be used. Regardless of the method selected by an individual licensee, the criteria and assumptions provided in this guidance document may apply. The methodology described in Section 3 is based on a computer database oriented approach, which is utilized by several licensees to model Appendix R data relationships. This guidance document, however, does not require the use of a computer database oriented approach.
The requirements of Appendix R Sections III.G.1, III.G.2 and III.G.3 apply to equipment and cables required for achieving and maintaining safe shutdown in any fire area. Although equipment and cables for fire detection and suppression systems, communications systems and 8-hour emergency lighting systems are important features, this guidance document does not address them.
Applicability                                            Comments Applicable Alignment Statement                                      Alignment Basis                                                                 Reference Documents Aligns with Intent                                       PINGP utilized a deterministic methodology to assess conformance of the         EC 23407 - B2 Methodology Evaluation PINGP SSA with the Nuclear Safety Capability Assessment (NSCA), as              EC 23408 - NEI 00-01 Revision 1 to Revision 2 described in NFPA 805, Section 1.5.1. This assessment evaluated the             Gap Analysis current program for readiness to transition, identified gaps and gap closure    NSCA (Genesis) Model actions, and culminated in the PINGPs safe and stable position with            EC 20612 - Non Power / NSCA Operations respect to the deterministic guidance given in Chapter 3 of NEI 00-01,          Review for NFPA 805 Revision 1, Deterministic Methodology.
Note: A Gap analysis between NEI 00-01 Revision 1 and Revision 2 was performed under EC 23408 and the applicable findings were incorporated in the Nuclear Safety Capability Assessment (NSCA) Genesis model.
The following sections of this analysis (taken from Table B-2 of NEI 04-02) provide a detailed comparison of the PINGP deterministic methodology, against the guidance provided by NEI 00-01 Revision 1, Chapter 3 Deterministic Methodology.
PINGP                                                                                                                                        Page B Revision 1

Northern States Power - Minnesota                                                                          Attachment B - NEI 04-02 Table B-2 The comparison concluded that the PINGP NSCA falls within the following two categories when compared with NEI 00-01 Revision 1, and the NEI 00-01 revision 1 to revision 2 gap analysis conducted under EC23408:
: 1. Aligns or Aligns with Intent
: a. May include open items that are not required to be closed to ensure alignment status.
: b. May include commitments in Attachment S that are being performed to assure alignment status.
: 2. Not in Alignment [but Prior NRC Approval]
: a. PINGP credits two existing licensing actions (exemptions) to meet the criteria of Sections 3.1.1.4 and 3.4.1.6.
The PINGP methodology was used to determine if the Nuclear Safety Performance Criteria are being met for maintaining fuel in a safe and stable condition for all modes and applicable plant configurations.
PINGP                                                                                                           Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                             NEI 00-01 Section 3.0 Guidance 3.1        Safe Shutdown Systems and Path This section discusses the identification of systems available and necessary to perform the required safe shutdown Development                    functions. It also provides information on the process for combining these systems into safe shutdown paths. Appendix R Section III.G.1.a requires that the capability to achieve and maintain hot shutdown be free of fire damage. It is expected that the term free of fire damage will be further clarified in a forthcoming Regulatory Issue Summary. Appendix R Section III.G.1.b requires that repairs to systems and equipment necessary to achieve and maintain cold shutdown be completed within 72 hours. It is the intent of the NRC that requirements related to the use of manual operator actions will be addressed in a forthcoming rulemaking.
The goal of post-fire safe shutdown is to assure that one train of shutdown systems, structures, and components remains free of fire damage for a single fire in any single plant fire area. This goal is accomplished by determining those functions important to achieve and maintain hot shutdown. Safe shutdown systems are selected so that the capability to perform these required functions is a part of each safe shutdown path. The functions important to post-fire safe shutdown generally include, but are not limited to the following:
                                          - Reactivity Control
                                          - Pressure Control Systems
                                          - Inventory Control Systems
                                          - Decay Heat Removal Systems
                                          - Process Monitoring
                                          - Support Systems Electrical systems Cooling systems These functions are of importance because they have a direct bearing on the safe shutdown goal of being able to achieve and maintain hot shutdown which ensures the integrity of the fuel, the reactor pressure vessel, and the primary containment. If these functions are preserved, then the plant will be safe because the fuel, the reactor and the primary containment will not be damaged. By assuring that this equipment is not damaged and remains functional, the protection of the health and safety of the public is assured.
In addition to the above listed functions, Generic Letter 81-12 specifies consideration of associated circuits with the potential for spurious equipment operation and/or loss of power source, and the common enclosure failures. Spurious operations/actuations can affect the accomplishment of the post-fire safe shutdown functions listed above. Typical examples of the effects of the spurious operations of concern are the following:
                                          - A loss of reactor pressure vessel/reactor coolant inventory in excess of the safe shutdown makeup capability
                                          - A flow loss or blockage in the inventory makeup or decay heat removal systems being used for the required safe shutdown path.
Spurious operations are of concern because they have the potential to directly affect the ability to achieve and maintain hot shutdown, which could affect the fuel and cause damage to the reactor pressure vessel or the primary containment.
Common power source and common enclosure concerns could also affect these and must be addressed.
PINGP                                                                                                                            Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                               Reference Documents Aligns with Intent                Systems, functions, equipment, cables and logics required to maintain         EC 23407 - B2 Methodology Evaluation fuel in a safe and stable condition have been identified and are included in  EC 23408 - NEI 00-01 Revision 1 to Revision 2 the NSCA (Genesis) Model.                                                     Gap Analysis NSCA (Genesis) Model Demonstration of the Nuclear Safety Performance Criteria for safe and         EC 20612 - Non Power / NSCA Operations stable conditions was performed in two analyses.                              Review for NFPA 805
                                    At-Power analysis, Mode 1 through Mode 3. This analysis is discussed       EC 23925 - NFPA 805 LAR Supplement -
in Section 4.2.4.                                                             Control Room HVAC Evaluation
                                    Non-Power analysis, which includes Mode 4 and below. This analysis is discussed in Section 4.3.
The NFPA 805 licensing basis for PINGP for a Safe and Stable condition in the event of a fire starting with the reactor in at-power operating Modes 1, 2, or 3 (Power Operation, Startup, or Hot Standby, respectively) is to maintain Safe and Stable conditions in Hot Standby without Residual Heat Removal (RHR). PINGP will maintain Hot Standby conditions until a decision is made to either place the reactor in a non-power operating mode, i.e., Hot Shutdown (Mode 4) or Cold Shutdown (Mode 5), or to return to power operations. Determination of the final state will be based upon the extent of the fire damage, the inventory remaining in the Refueling Water Storage Tank (RWST), the ability to provide makeup water to the RWST, and the ability to re-establish inventory in the Condensate Storage Tank (CST) or realign the CST to an alternate source.
Mission Time A PINGP thermal-hydraulic analysis was performed for a mission time of 24 hours to assure that safe and stable conditions can be achieved within that time period. This mission time ensures that sufficient time is available for the Emergency Response Organization to respond to the event, assess the extent of fire damage, and assist the plant operating staff with maintaining Safe and Stable conditions or transitioning the plant to a non-power operating mode.
To sustain Safe and Stable conditions, Key Safety Functions are met as follows:
                                    Reactivity and Inventory Control The reactor design ensures that Keff < 0.99 can be achieved by use of the control rods from any operating mode. Subsequent injection (using Charging or Safety Injection Pumps) of soluble poison can be used to assure continuation of Mode 3, Hot Standby, under all circumstances.
The charging system and the Safety Injection system will remain available beyond the mission time for Safe and Stable. The RWST is the credited source of borated water and is capable of providing water for at least 38 PINGP                                                                                                               Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 hours, per EC-20736, Reactivity Control. Operator actions to establish makeup sources of inventory to the RWST are described in existing plant procedure C12.5, Boron Concentration Control.
                                    Decay Heat Removal One or both steam generators, as well as a motor driven or turbine driven Auxiliary Feedwater (AFW) pump will remain available without additional actions to provide symmetrical or asymmetrical decay heat removal beyond the mission time for Safe and Stable. The Condensate Storage Tank (CST) is the initial source for the AFW pumps. Per EC-20738, Decay Heat Removal, the CST will provide a continuous water supply for the AFW pumps for 20 hours. Beyond 20 hours, the CST can be refilled or the AFW pumps can be re-aligned to the cooling water system to provide an unlimited water source. This realignment is accomplished through existing plant procedures 1(2)E-1, Loss of Reactor or Secondary Coolant, and C28.1, AOP2, Loss of Condensate Supply to Auxiliary Feedwater Pump Suction.
                                    Vital Auxiliaries - Power and Support Systems The Emergency Diesel Generators (EDGs) and Diesel Driven Cooling Water Pumps (DDCLPs) have an on-site fuel oil supply that will last for 14 days, assuming one EDG on each unit and one DDCLP, or 7 days if both EDGs are operating for each unit and both DDCLPs are operating. .
Offsite sources of fuel oil are available to replenish fuel oil levels if needed via established contracts.
Control room HVAC can be lost in several fire areas due to the loss of instrument air and other fire-induced HVAC component damage. EC 23925, NFPA 805 LAR Supplement - Control Room HVAC Evaluation, demonstrates that control room temperatures will remain below equipment limits for up to 36 hours with actions taken only within the control room itself. However, a portable fan may be installed in the control room prior to 36 hours to allow temperatures to remain below equipment limits indefinitely. If required, the portable fan will normally be powered by a designated welding receptacle or in cases where the welding receptacle power is lost due to the fire, by a 480VAC portable generator located outside of the building [Reference Attachment S-3 for additional details]
If conditions warrant placing the plant in Hot Shutdown (Mode 4) or Cold Shutdown (Mode 5), NSPM will initiate operation of the RHR System.
Although the RHR system is not required for maintaining safe and stable conditions, the RHR system is included in the at power NSCA Genesis model to demonstrate its availability for transition. Initiation of RHR system operations does not imply that the end state will be Cold Shutdown (Mode 5).
The NSCA (Genesis) model is utilized to demonstrate that the Nuclear Safety Performance Criteria is met on a fire-area-by-fire-area basis by logically correlating the Nuclear Safety Performance Criteria of NFPA 805, Section 1.5.1, to physical plant success paths, equipment, cables, and location (fire areas).
PINGP                                                                                                                   Page B Revision 1

Northern States Power - Minnesota                                                                          Attachment B - NEI 04-02 Table B-2 High/low pressure interfaces have been considered and precluded from spurious operation of the pathway via plant configuration change to operate with 480VAC breakers open for RHR suction valves: MV-32231 (U1), MV-32165 (U1), MV-32233 (U2) and MV-32193 (U2). The series counterparts to these valves already have their 480VAC breakers in the open position during power operations. This configuration change will preclude spurious operation of the high / low interface path by removing motive power from both series valves in each path.
PINGP                                                                                                           Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1        Criteria/Assumptions The following criteria and assumptions may be considered when identifying systems available and necessary to perform the required safe shutdown functions and combining these systems into safe shutdown paths.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                              Reference Documents Generic Guidance Only                                                        EC 23407 - B2 Methodology Evaluation Not Required                                                                                                   EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                              Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.1      Criteria/Assumptions [BWR] GE Report GE-NE-T43-00002-00-01-R01 entitled "Original Safe Shutdown Paths For The BWR" addresses the systems and equipment originally designed into the GE boiling water reactors (BWRs) in the 1960s and 1970s, that can be used to achieve and maintain safe shutdown per Section III.G.1 of 10CFR 50, Appendix R. Any of the shutdown paths (methods) described in this report are considered to be acceptable methods for achieving redundant safe shutdown.
Applicability                     Comments Not Applicable Alignment Statement               Alignment Basis                                                              Reference Documents Not Applicable to PINGP - BWR Specific.                                       EC 23407 - B2 Methodology Evaluation Not Applicable                                                                                                 EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                               Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.2      Criteria/Assumptions [BWR] GE Report GE-NE-T43-00002-00-03-R01 provides a discussion on the BWR Owners' Group (BWROG) position regarding the use of Safety Relief Valves (SRVs) and low pressure systems (LPCI/CS) for safe shutdown. The BWROG position is that the use of SRVs and low pressure systems is an acceptable methodology for achieving redundant safe shutdown in accordance with the requirements of 10CFR50 Appendix R Sections III.G.1 and III.G.2. The NRC has accepted the BWROG position and issued an SER dated Dec. 12, 2000.
Applicability                     Comments Not Applicable Alignment Statement               Alignment Basis                                                             Reference Documents Not Required                      Not Applicable to PINGP - BWR Specific.                                     EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                             Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.3     Criteria/Assumptions  [PWR] Generic Letter 86-10, Enclosure 2, Section 5.3.5 specifies that hot shutdown can be maintained without the use of pressurizer heaters (i.e., pressure control is provided by controlling the makeup/charging pumps). Hot shutdown conditions can be maintained via natural circulation of the RCS through the steam generators. The cooldown rate must be controlled to prevent the formation of a bubble in the reactor head. Therefore, feedwater (either auxiliary or emergency) flow rates as well as steam release must be controlled.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            Safe and stable is defined as Mode 3 Hot Standby for PINGP.                      EC 23407 - B2 Methodology Evaluation Pressurizer heaters are not credited for increasing RCS pressure, but can        EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis be utilized if the circuits are not affected in a particular fire area.
NSCA (Genesis) Model Pressurizer heaters are primarily evaluated for spurious operation EC 20612 - Non Power / NSCA Operations concerns. If a pressurizer heater is not available, RCS pressure can be Review for NFPA 805 increased by utilizing a water solid pressurizer and controlling RCS EC 20824 - NFPA 805 Thermal Hydraulic makeup and letdown flow."
Calculation for Subcooling Margin, Owners Acceptance of Vendor Calculation Spurious operation of pressurizer heaters has been considered in the safe P2117-2400-06-00 Maintaining Subcooling and stable model.
Margin with Failure of Press Htrs RCS makeup is provided by either charging or SI with suction from the Reactor Water Storage Tank (RWST). The plant is capable of maintaining safe and stable conditions in both a natural or forced circulation mode. See Section 3.1 above for a definition of safe and stable for PINGP.
Feedwater for decay heat removal is provided by auxiliary feedwater (AFW) system (turbine or motor driven). The plant is capable of either symmetrical or asymmetrical cooldown methods. The normal source for AFW is the CST with the cooling water system serving as a source for extended operation. See Section 3.1 above for details.
Adequate cooldown rate is maintained to ensure void formation in the reactor vessel does not occur to ensure performance goals of maintaining pressurizer level within scale and preventing fuel clad damage will be met.
Analysis supporting the assumption that pressurizer heaters are not required when SI is credited for RCS makeup is documented in EC 20824.
PINGP                                                                                                                  Page B Revision 1

Northern States Power - Minnesota                                                                                      Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                             NEI 00-01 Section 3.0 Guidance 3.1.1.4      Criteria/Assumptions         The classification of shutdown capability as alternative shutdown is made independent of the selection of systems used for shutdown. Alternative shutdown capability is determined based on an inability to assure the availability of a redundant safe shutdown path. Compliance to the separation requirements of Sections III.G.1 and III.G.2 may be supplemented by the use of manual actions to the extent allowed by the regulations and the licensing basis of the plant, repairs (cold shutdown only), exemptions, deviations, GL 86-10 fire hazards analyses or fire protection design change evaluations, as appropriate. These may also be used in conjunction with alternative shutdown capability.
Applicability                             Comments Applicable Alignment Statement                       Alignment Basis                                                                Reference Documents Not in Alignment [but Prior NRC Approval]  Fire areas 13 and 18 (Control Room and Relay Room) were defined as Alternative / Dedicated Shutdown areas under 10CFR50 Appendix R.            EC 23407 - B2 Methodology Evaluation Unlike 10CFR50 Appendix R, NFPA 805 does not define areas or                  EC 23408 - NEI 00-01 Revision 1 to Revision scenarios as alternative shutdown or dedicated shutdown.                      2 Gap Analysis NSCA (Genesis) Model Fire areas 13 and 18 are being transitioned as risk-informed,                 EC 20612 - Non Power / NSCA performance-based areas with the following high-level details:                Operations Review for NFPA 805 PRA Alternative Shutdown Notebook
* Not all scenarios within fire areas 13 and 18 require control room      Attachment S abandonment.                                                            Attachment K
* Fire PRA employs the use of a hot shutdown panel (HSD) in               Attachment T conjunction with other controls when required to abandon the control room, however, the HSD panels and controls do not meet the definition of a primary control station (PCS) as defined by RG 1.205. Therefore, no credit has been taken for PCS actions in the Fire PRA for these fire areas.
* Actions to enable the HSD panel and establish required controls are listed in the PRA Alternative Shutdown Notebook.
* Just prior to abandoning the control room, control room action is taken on the control board to close the PORV block valves.
Additional control room actions are then taken at a switch panel that is being installed within the control room (see Attachment S Item 27) to isolate excess letdown, head vents, pressurizer vents, pressurizer PORV and the pressurizer heaters.
As an exception to this section, PINGP is transitioning existing approved licensing action for a repair action to assure isolation of pressurizer PORVs for a fire occurring in the control room or relay room (Fire Areas 13 and 18 respectively), that could cause spurious operation of PORV isolation valves. Therefore, this section is Not in Alignment but Prior NRC Approval. The details for this licensing action can be found in Attachments K and T.
PINGP                                                                                                                         Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance At the onset of the postulated fire, all safe shutdown systems (including applicable redundant trains) are assumed 3.1.1.5     Criteria/Assumptions operable and available for post-fire safe shutdown. Systems are assumed to be operational with no repairs, maintenance, testing, Limiting Conditions for Operation, etc. in progress. The units are assumed to be operating at full power under normal conditions and normal lineups.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            The PINGP NFPA-805 safe and stable analysis assumes the availability /          EC 23407 - B2 Methodology Evaluation operability of credited systems at the onset of the fire. This assurance is     EC 23408 - NEI 00-01 Revision 1 to Revision 2 provided by including appropriate systems / components in the PINGP             Gap Analysis monitoring program as defined in LAR Section 4.6.                               NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                                  Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.6     Criteria/Assumptions  No Final Safety Analysis Report accidents or other design basis events (e.g. loss of coolant accident, earthquake), single failures or non-fire induced transients need be considered in conjunction with the fire.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            No accidents or other design basis events, including single failures and        EC 23407 - B2 Methodology Evaluation non-fire induced transients, are considered in conjunction with the fire.       EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model Reference Table B-1 Section 3.6.4 for how PINGP aligns with the EC 20612 - Non Power / NSCA Operations earthquake provisions of NFPA 805.
Review for NFPA 805 PINGP                                                                                                                   Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.7     Criteria/Assumptions  For the case of redundant shutdown, offsite power may be credited if demonstrated to be free of fire damage. Offsite power should be assumed to remain available for those cases where its availability may adversely impact safety (i.e.,
reliance cannot be placed on fire causing a loss of offsite power if the consequences of offsite power availability are more severe than its presumed loss). No credit should be taken for a fire causing a loss of offsite power. For areas where train separation cannot be achieved and alternative shutdown capability is necessary, shutdown must be demonstrated both where offsite power is available and where offsite power is not available for 72 hours.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            Credit is not taken for off-site power in a specific fire area, unless an EC 23407 - B2 Methodology Evaluation analysis is performed to demonstrate the availability of off-site power EC 23408 - NEI 00-01 Revision 1 to following the worst-case postulated fire in the area in which all                Revision 2 Gap Analysis unprotected cables in the area are assumed damaged.                              NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations The NSCA (Genesis) Model does not credit the loss of off-site power due          Review for NFPA 805 to the fire.
Distribution components and cables of the credited plant AC and DC systems are modeled in the NSCA (Genesis) model in a cascading fashion. Within the NSCA (Genesis) model, the distribution equipment, source cables and credited load equipment are combined to form a complete cascading success path from all credited sources to load.
All credited sources are analyzed for availability within the NSCA (Genesis) model for the fire area in which they are credited. Additionally, the ability to trip and close alternate source breakers, including the utilization of the load sequencer when applicable, have been analyzed within the NSCA (Genesis) model.
PINGP                                                                                                                  Page B Revision 1

Northern States Power - Minnesota                                                                          Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.8     Criteria/Assumptions  Post-fire safe shutdown systems and components are not required to be safety-related.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                            Reference Documents Aligns                            PINGP credits both safety-related and non-safety related equipment to EC 23407 - B2 Methodology Evaluation achieve safe and stable conditions.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                             Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.1.1.9       Criteria/Assumptions The post-fire safe shutdown analysis assumes a 72-hour coping period starting with a reactor scram/trip. Fire-induced impacts that provide no adverse consequences to hot shutdown within this 72-hour period need not be included in the post-fire safe shutdown analysis. At least one train can be repaired or made operable within 72 hours using onsite capability to achieve cold shutdown.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                                Reference Documents Aligns with Intent                 NFPA 805 Nuclear Safety Performance Criteria (NSPC) requires the               EC 23407 - B2 Methodology Evaluation licensee to demonstrate that the plant can achieve and maintain a safe        EC 23408 - NEI 00-01 Revision 1 to Revision 2 and stable condition, but it has no explicit requirement to demonstrate       Gap Analysis that cold shutdown can be achieved.                                            NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Equipment required to achieve cold shutdown is included in the NSCA            Review for NFPA 805 (Genesis) model to demonstrate availability / identify fire damage that may require repair should plant operations decide to proceed to non-power operations from a safe and stable condition. There is no time or power supply requirement associated with completion of repairs under NFPA 805.
Reference Section 3.1 above for PINGPs definition of Safe and Stable.
PINGP                                                                                                                 Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.1.1.10      Criteria/Assumptions Manual initiation from the main control room or emergency control stations of systems required to achieve and maintain safe shutdown is acceptable where permitted by current regulations or approved by NRC; automatic initiation of systems selected for safe shutdown is not required but may be included as an option.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                                Reference Documents Aligns with Intent                 Automatic functions (e.g., load sequencer), when credited, have been           EC 23407 - B2 Methodology Evaluation analyzed within the NSCA (Genesis) model for availability and spurious         EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis operation. Manual functions are credited by the analysis and are NSCA (Genesis) Model listed in the fire risk evaluations FREs (Recovery Actions) and in the EC 20612 - Non Power / NSCA Operations non-power operations NPO (manual actions) EC 20612.
Review for NFPA 805 FRE ECs (Many)
PINGP                                                                                                                 Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.1.11    Criteria/Assumptions  Where a single fire can impact more than one unit of a multi-unit plant, the ability to achieve and maintain safe shutdown for each affected unit must be demonstrated.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            The NSCA (Genesis) model evaluates the effects on both PINGP units, of EC 23407 - B2 Methodology Evaluation a single fire occurring in a single fire area, for all analyzed areas in the EC 23408 - NEI 00-01 Revision 1 to plant. This methodology assures that fuel in both units is maintained in a       Revision 2 Gap Analysis safe and stable condition.                                                       NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                                    Page B Revision 1

Northern States Power - Minnesota                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2        Shutdown Functions   The following discussion on each of these shutdown functions provides guidance for selecting the systems and equipment required for safe shutdown. For additional information on BWR system selection, refer to GE Report GENE-T43-00002                                   01-R01 entitled "Original Safe Shutdown Paths for the BWR."
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                              Reference Documents Not Required                      Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP                                                                                                              Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.1       Reactivity Control  [BWR] Control Rod Drive System The safe shutdown performance and design requirements for the reactivity control function can be met without automatic scram/trip capability. Manual scram/reactor trip is credited. The post-fire safe shutdown analysis must only provide the capability to manually scram/trip the reactor.
[PWR] Makeup/Charging There must be a method for ensuring that adequate shutdown margin is maintained by ensuring borated water is utilized for RCS makeup/charging.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                   Reference Documents Aligns with Intent                Long-term reactivity control is accomplished by adding borated water from EC 23407 - B2 Methodology Evaluation the refueling Water Storage Tank (RWST) to ensure reactivity margin EC 23408 - NEI 00-01 Revision 1 to throughout safe and stable.                                                       Revision 2 Gap Analysis NSCA (Genesis) Model RWST is supplied to the RCS through either the Chemical and Volume                EC 20612 - Non Power / NSCA Operations Control System (CVCS) or the Safety Injection System (SI).                        Review for NFPA 805 The NSCA (Genesis) model has shown that the credible boron dilution event (MSO) is only possible for fires occurring in Fire Areas 13 and 18.
This event will be addressed as part of the RI / PB methods for these areas.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                        NEI 00-01 Section 3.0 Guidance 3.1.2.2     Pressure Control Systems [BWR] Safety Relief Valves (SRVs)
The SRVs are opened to maintain hot shutdown conditions or to depressurize the vessel to allow injection using low pressure systems. These are operated manually. Automatic initiation of the Automatic Depressurization System is not a required function.
[PWR] Makeup/Charging RCS pressure is controlled by controlling the rate of charging/makeup to the RCS. Although utilization of the pressurizer heaters and/or auxiliary spray reduces operator burden, neither component is required to provide adequate pressure control. Pressure reductions are made by allowing the RCS to cool/shrink, thus reducing pressurizer level/pressure.
Pressure increases are made by initiating charging/makeup to maintain pressurizer level/pressure. Manual control of the related pumps is acceptable.
Applicability                        Comments Applicable Alignment Statement                  Alignment Basis                                                               Reference Documents Aligns                               RCS Pressure Control is necessary to prevent exceeding RCS design             EC 23407 - B2 Methodology Evaluation pressure-temperature limits and to minimize void formation in the reactor. EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis RCS pressure control is also necessary to control high/low pressure NSCA (Genesis) Model interfaces and to prevent rupture of any primary coolant boundary. Some EC 20612 - Non Power / NSCA Operations key goals of pressure control are:
Review for NFPA 805
* Preventing a LOCA due to spurious operation of high/low pressure interface components
* Isolating Normal Pressurizer and Auxiliary Spray
* Closing or isolating the Pressurizer Power-Operated Relief Valves (PORVs)
* Isolating RCS head vent flowpaths
* Control of Normal and Excess Letdown flowpaths
* Securing the Pressurizer Heaters when spuriously operating Over-pressure protection of the RCS is mainly provided by the pressurizer safety valves (RC-10-1, RC-10-2, 2RC-10-1, 2RC-10-2). The power-operated relief valves and associated block valve, RCS head vent valves, and Pressurizer vent valves can be used for over-pressure protection. Low temperature overpressure protection mitigates an overpressure event during low temperature operation. The reactor head vent valves are credited for low temperature overpressure protection.
Normal pressurizer spray and auxiliary spray are also methods used to depressurize the RCS; however, these flow paths are not credited for safe PINGP Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 and stable and are only evaluated for spurious operation concerns.
Safe and stable conditions can be achieved and maintained by controlling the RCS makeup through the charging path (charging pumps or safety injection pumps) and letdown/leakage flows. Because normal and excess letdown flowpaths may not be available, the RCS head vents or pressurizer head vents can be throttled for letdown. In addition, RCP seal leakage flow is also another means for letdown but is not explicitly credited by the safe and stable analysis.
In addition to controlling the rate of charging/makeup for pressure increases, PINGP safe and stable credits cooling and shrinking of the RCS through steam heat removal; this is accomplished by controlling the flow of auxiliary feedwater to the steam generators and discharging the volume as steam via the safety valves, steam diversion flow paths and the steam generator power-operated relief valves (PORVs).
Pressurizer heaters and sprays have been analyzed for spurious operation in the NSCA (Genesis) model.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.3       Inventory Control   [BWR] Systems selected for the inventory control function should be capable of supplying sufficient reactor coolant to achieve and maintain hot shutdown. Manual initiation of these systems is acceptable. Automatic initiation functions are not required.
[PWR] Systems selected for the inventory control function should be capable of maintaining level to achieve and maintain hot shutdown. Typically, the same components providing inventory control are capable of providing pressure control.
Manual initiation of these systems is acceptable. Automatic initiation functions are not required.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns with Intent                To ensure fuel is maintained in a safe and stable condition, RCS makeup          EC 23407 - B2 Methodology Evaluation is required for maintenance of RCS integrity (isolating flow diversion paths     EC 23408 - NEI 00-01 Revision 1 to Revision 2 and maintaining the pressurizer level within the indicating range), and to       Gap Analysis compensate for RCS inventory losses due to seal leakoff and shrinkage            NSCA (Genesis) Model during cooldown. RCS makeup is provided by the Chemical and Volume               EC 20612 - Non Power / NSCA Operations Control System (CVCS) or the Safety Injection System (SI). Typically, the        Review for NFPA 805 CVCS system is credited if Train A systems are available, and the SI system is credited if Train B systems are available. As an example, the NSCA (Genesis) model includes analysis of the following in support of inventory control:
* Isolation of the Reactor Coolant System diversion flowpaths.
* Alignment of RWST to either charging pump suction or SI Pump suction.
* Ensuring RCP seal cooling to prevent a small break LOCA (Reference Attachment S Tables S-1, S-2 for seal modification).
* Operation of the charging system or SI system.
* Maintaining Reactor Coolant Pump seal return flowpath.
* Isolating RWST diversion flowpaths to the Containment Spray and RHR system.
* De-energizing non-credited components that may affect safe and stable.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.4       Decay Heat Removal  [BWR] Systems selected for the decay heat removal function(s) should be capable of:
                                  - Removing sufficient decay heat from primary containment, to prevent containment over-pressurization and failure.
                                  - Satisfying the net positive suction head requirements of any safe shutdown systems taking suction from the containment (suppression pool).
                                  - Removing sufficient decay heat from the reactor to achieve cold shutdown.
This does not restrict the use of other systems.
[PWR] Systems selected for the decay heat removal function(s) should be capable of:
                                  - Removing sufficient decay heat from the reactor to reach hot shutdown conditions. Typically, this entails utilizing natural circulation in lieu of forced circulation via the reactor coolant pumps and controlling steam release via the Atmospheric Dump valves.
                                  - Removing sufficient decay heat from the reactor to reach cold shutdown conditions.
This does not restrict the use of other systems.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                   Reference Documents EC 23407 - B2 Methodology Evaluation EC Aligns with Intent                Following a reactor trip, decay heat is removed via the steam generators          23408 - NEI 00-01 Revision 1 to Revision 2 by natural or forced circulation within the reactor coolant loops.                Gap Analysis Feedwater is supplied to the steam generators by the Auxiliary Feedwater          NSCA (Genesis) Model (AFW) System. At a minimum, one AFW pump and one steam generator                  EC 20612 - Non Power / NSCA Operations is required for removal of decay heat from the RCS.                               Review for NFPA 805 Removing sufficient decay heat to reach cold shutdown conditions is not a requirement for PINGP to maintain fuel in a safe and stable condition.
PINGP defines safe and stable as Mode 3 (reference section 3.1 above for further details of PINGP safe and stable).
Decay heat safety function has been incorporated in the NSCA (Genesis) model with all available success paths. The NSCA (Genesis) model analyzes for availability as well as spurious operation.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.5       Process Monitoring  The process monitoring function is provided for all safe shutdown paths. IN 84-09, Attachment 1, Section IX "Lessons Learned from NRC Inspections of Fire Protection Safe Shutdown Systems (10CFR50 Appendix R)" provides guidance on the instrumentation acceptable to and preferred by the NRC for meeting the process monitoring function. This instrumentation is that which monitors the process variables necessary to perform and control the functions specified in Appendix R Section III.L.1. Such instrumentation must be demonstrated to remain unaffected by the fire. The IN 84-09 list of process monitoring is applied to alternative shutdown (III.G.3). IN 84-09 did not identify specific instruments for process monitoring to be applied to redundant shutdown (III.G.1 and III.G.2). In general, process monitoring instruments similar to those listed below are needed to successfully use existing operating procedures (including Abnormal Operating Procedures).
PWR:
                                  - Reactor coolant temperature (hot leg / cold leg)
                                  - Pressurizer pressure and level
                                  - Neutron flux monitoring (source range)
                                  - Level indication for tanks needed for safe shutdown
                                  - Steam generator level and pressure
                                  - Diagnostic instrumentation for safe shutdown systems The specific instruments required may be based on operator preference, safe shutdown procedural guidance strategy (symptomatic vs. prescriptive), and systems and paths selected for safe shutdown.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns with Intent                PINGP has modeled the required process monitoring functions in the NSCA (Genesis) model.                                                            EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to The performance of the primary system (RCS) is monitored by RCS                  Revision 2 Gap Analysis pressure, pressurizer level, and RCS Hot Leg and Cold Leg                        NSCA (Genesis) Model Temperatures.                                                                    EC 20612 - Non Power / NSCA Operations The secondary system (AFW) is monitored by the SG level indicators.              Review for NFPA 805 Reactivity is monitored by the neutron source range flux monitors.
When utilizing the hot shutdown panels (HSD), steam generator pressure is available via local mechanical (remote from HSD panel) indicators.
Additionally, when controlling charging from the HSD panel, local pressure indication is credited (Unit 1: 1LI-433C Unit 2: 2LI-433C).
Additional tank level monitoring is provided by local mechanical level PINGP Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 indicators. Local tank level indicators include:
Unit 1 and Unit 2 Refueling Water Storage Tanks Unit 1 and Unit 2 Condensate Storage Tanks 12 and 22 Diesel Driven Cooling Water Pump Fuel Oil Day Tank Diagnostic instrumentation is generally provided by local devices that do not require power to operate. If power or control was required for the diagnostic instrument, it was included in the model for analysis purposes.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.6.1   Electrical Systems    AC Distribution System Power for the Appendix R safe shutdown equipment is typically provided by a medium voltage system such as 4.16 KV Class 1E buses either directly from the buses or through step down transformers/ load centers/ distribution panels for 600, 480 or 120 VAC loads.
For redundant safe shutdown performed in accordance with the requirements of Appendix R Section III.G.1 and 2, power may be supplied from either offsite power sources or the emergency diesel generator depending on which has been demonstrated to be free of fire damage. No credit should be taken for a fire causing a loss of offsite power. Refer to Section 3.1.1.7.
DC Distribution System Typically, the 125VDC distribution system supplies DC control power to various 125VDC control panels including switchgear breaker controls. The 125VDC distribution panels may also supply power to the 120VAC distribution panels via static inverters. These distribution panels typically supply power for instrumentation necessary to complete the process monitoring functions.
For fire events that result in an interruption of power to the AC electrical bus, the station batteries are necessary to supply any required control power during the interim time period required for the diesel generators to become operational.
Once the diesels are operational, the 125 VDC distribution system can be powered from the diesels through the battery chargers.
The DC control centers may also supply power to various small horsepower Appendix R safe shutdown system valves and pumps. If the DC system is relied upon to support safe shutdown without battery chargers being available, it must be verified that sufficient battery capacity exists to support the necessary loads for sufficient time (either until power is restored, or the loads are no longer required to operate).
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                     Reference Documents Aligns                            Distribution components of the credited plant AC and DC systems are EC 23407 - B2 Methodology Evaluation modeled in the NSCA (Genesis) model in a cascading fashion. Within the              EC 23408 - NEI 00-01 Revision 1 to NSCA (Genesis) model, individual source cables and equipment are                    Revision 2 Gap Analysis combined to form a complete cascading success path from source to                   NSCA (Genesis) Model load. Additionally, the NSCA (Genesis) model provides the means to                  EC 20612 - Non Power / NSCA Operations analyze a loss of DC control power to the credited AC buses.                        Review for NFPA 805 Upon loss of AC power to the battery chargers, the batteries are credited to supply power to interim loads, including diesel generator startup loads, until an AC source is re-established to the credited chargers.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.1.2.6.2   Cooling Systems       Various cooling water systems may be required to support safe shutdown system operation, based on plant-specific considerations. Typical uses include:
                                  - RHR/SDC/DH Heat Exchanger cooling water
                                  - Safe shutdown pump cooling (seal coolers, oil coolers)
                                  - Diesel generator cooling
                                  - HVAC system cooling water.
HVAC Systems may be required to assure that safe shutdown equipment remains within its operating temperature range, as specified in manufacturers literature or demonstrated by suitable test methods, and to assure protection for plant operations staff from the effects of fire (smoke, heat, toxic gases, and gaseous fire suppression agents). HVAC systems may be required to support safe shutdown system operation, based on plant-specific configurations. Typical uses include:
                                  - Main control room, cable spreading room, relay room
                                  - ECCS pump compartments
                                  - Diesel generator rooms
                                  - Switchgear rooms Plant-specific evaluations are necessary to determine which HVAC systems are essential to safe shutdown equipment operation.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            HVAC Systems have been demonstrated to be not required to support               EC 23407 - B2 Methodology Evaluation EC the Nuclear Safety Performance Criteria in the NSCA (Genesis) model.            23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis Component Cooling, seal injection, seal barrier cooling, cooling to heat NSCA (Genesis) Model exchangers as well as HVAC cooling of components have been EC 20612 - Non Power / NSCA Operations considered for safe and stable.
Review for NFPA 805 EC 23925 - NFPA 805 LAR Supplement -
Control Room HVAC Evaluation PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.1.3        Methodology for Shutdown System Refer to NEI-00-01 Rev 1 Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe shutdown Selection                       systems and developing the shutdown paths.
The following methodology may be used to define the safe shutdown systems and paths for an Appendix R analysis:
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                  Reference Documents Not Required                                 Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                       Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.1.3.1     Identify Safe Shutdown Functions Review available documentation to obtain an understanding of the available plant systems and the functions required to achieve and maintain safe shutdown.
Documents such as the following may be reviewed:
                                             - Operating Procedures (Normal, Emergency, Abnormal)
                                             - System descriptions
                                             - Fire Hazard Analysis
                                             - Single-line electrical diagrams
                                             - Piping and Instrumentation Diagrams (P&IDs)
                                             - [BWR] GE Report GE-NE-T43-00002-00-01-R02 entitled "Original Shutdown Paths for the BWR" Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                              Reference Documents Aligns                                       Consistent with the guidance of this section of NEI 00-01, Revision 1, the EC 23407 - B2 Methodology Evaluation following input documents were utilized in the development of the PINGP EC 23408 - NEI 00-01 Revision 1 to NSCA (Genesis) model:                                                        Revision 2 Gap Analysis NSCA (Genesis) Model
* Updated Safety Analysis Report                                             EC 20612 - Non Power / NSCA Operations
* Fire Hazards Analysis                                                     Review for NFPA 805
* Piping and Instrumentation Diagrams (P&IDs)
* System description (B procedures)
* Design Basis Documents
* Design Basis Evaluations
* Operating Procedures (C Procedures)
* Electrical Single Lines
* Electrical Schematics
* Instrument Loop Diagrams
* Design Calculations
* Conduit and Tray Plans
* Genesis PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.1.3.2     Identify Combinations of Systems Given the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of That Satisfy Each Safe Shutdown  achieving the safe shutdown functions of reactivity control, pressure control, inventory control, decay heat removal, Function                         process monitoring and support systems such as electrical and cooling systems (refer to Section 3.1.2). This selection process does not restrict the use of other systems. In addition to achieving the required safe shutdown functions, consider spurious operations and power supply issues that could impact the required safe shutdown function.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                  Reference Documents Aligns                                       PINGP utilized the methodology of NEI 00-01 Revision 1, Section 3.1.1 EC 23407 - B2 Methodology Evaluation and Section 3.1.2, coupled with procedure EM 3.4.3, Safe Shutdown EC 23408 - NEI 00-01 Revision 1 to Circuit Analysis to establish the systems, components, cables and Revision 2 Gap Analysis functions to satisfy the Nuclear Safety Performance Criteria NSPC as NSCA (Genesis) Model defined in NFPA 805 Section 1.5.1.
EC 20612 - Non Power / NSCA Operations Review for NFPA 805 The NSCA (Genesis) model is used to analyze the post-fire impact of EM 3.4.3 spurious operations and power supply issues that can affect the safe and S-3 Item 51 stable conditions of the plant. Additionally, the NSCA (Genesis) model presents the combination of systems and paths in a logic tree fashion.
Attachment S, Table S-3, Item 51 identifies an implementation action to incorporate the applicable details of the vendor cable selection / circuit analysis procedure (EPM-DP-EP-004) into the plant circuit analysis procedure EM 3.4.3. This action will enhance the plant documentation.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                 NEI 00-01 Section 3.0 Guidance 3.1.3.3     Define Combination of Systems for Select combinations of systems with the capability of performing all of the required safe shutdown functions and designate Each Safe Shutdown Path           this set of systems as a safe shutdown path. In many cases, paths may be defined on a divisional basis since the availability of electrical power and other support systems must be demonstrated for each path. During the equipment selection phase, identify any additional support systems and list them for the appropriate path.
Applicability                                 Comments Applicable Alignment Statement                           Alignment Basis                                                                 Reference Documents Aligns                                        PINGP utilizes the NSCA (Genesis) model to maintain the logical EC 23407 - B2 Methodology Evaluation relationships between the components and paths that make up the EC 23408 - NEI 00-01 Revision 1 to required NSPC function. Additionally, supporting systems were identified        Revision 2 Gap Analysis and included in the logical relationship when required. Power supplies are      NSCA (Genesis) Model modeled in a cascading fashion such that a loss of an upstream supply           EC 20612 - Non Power / NSCA Operations will affect all downstream supplies and credited equipment serviced by          Review for NFPA 805 those supplies.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                      Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                             NEI 00-01 Section 3.0 Guidance 3.1.3.4     Assign Shutdown Paths to Each Assign a path designation to each combination of systems. The path will serve to document the combination of systems Combination of Systems        relied upon for safe shutdown in each fire area. Refer to Attachment 1 to this document for an example of a table illustrating how to document the various combinations of systems for selected shutdown paths.
Applicability                             Comments Applicable Alignment Statement                       Alignment Basis                                                                 Reference Documents Aligns                                    The NSCA (Genesis) model assigns identifiers to each success path.
The success paths are grouped by NSPC function within each analysis             EC 23407 - B2 Methodology Evaluation area within the model.                                                          EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                        NEI 00-01 Section 3.0 Guidance 3.2          Safe Shutdown Equipment The previous section described the methodology for selecting the systems and paths necessary to achieve and maintain Selection               safe shutdown for an exposure fire event (see Section 5.0 DEFINITIONS for "Exposure Fire"). This section describes the criteria/assumptions and selection methodology for identifying the specific safe shutdown equipment necessary for the systems to perform their Appendix R function.
The selected equipment should be related back to the safe shutdown systems that they support and be assigned to the same safe shutdown path as that system. The list of safe shutdown equipment will then form the basis for identifying the cables necessary for the operation or that can cause the maloperation of the safe shutdown systems.
Applicability                        Comments Applicable Alignment Statement                  Alignment Basis Reference Documents Not Required                         Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1        Criteria/Assumptions Consider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                              Reference Documents Not Required                      Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.2.1.1       Criteria/Assumptions Safe shutdown equipment can be divided into two categories. Equipment may be categorized as (1) primary components or (2) secondary components. Typically, the following types of equipment are considered to be primary components:
                                   - Pumps, motor operated valves, solenoid valves, fans, gas bottles, dampers, unit coolers, etc.
                                   - All necessary process indicators and recorders (i.e., flow indicator, temperature indicator, turbine speed indicator, pressure indicator, level recorder)
                                   - Power supplies or other electrical components that support operation of primary components (i.e., diesel generators, switchgear, motor control centers, load centers, power supplies, distribution panels, etc.).
Secondary components are typically items found within the circuitry for a primary component. These provide a supporting role to the overall circuit function. Some secondary components may provide an isolation function or a signal to a primary component via either an interlock or input signal processor. Examples of secondary components include flow switches, pressure switches, temperature switches, level switches, temperature elements, speed elements, transmitters, converters, controllers, transducers, signal conditioners, hand switches, relays, fuses and various instrumentation devices.
Determine which equipment should be included on the Safe Shutdown Equipment List (SSEL). As an option, include secondary components with a primary component(s) that would be affected by fire damage to the secondary component.
By doing this, the SSEL can be kept to a manageable size and the equipment included on the SSEL can be readily related to required post-fire safe shutdown systems and functions.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                                  Reference Documents Aligns with Intent                 PINGP did not differentiate between primary and secondary components EC 23407 - B2 Methodology Evaluation within the NSCA (Genesis) model however, all analysis performed in EC 23408 - NEI 00-01 Revision 1 to support of added equipment for NFPA 805 included the secondary Revision 2 Gap Analysis components, or at a minimum, the function of the secondary components NSCA (Genesis) Model within the model.
EC 20612 - Non Power / NSCA Operations Review for NFPA 805 For example: a pump that is required to meet a NSPC, would appear as a component on the logic path for that function. However, the mechanical oil pressure switch that stops the pump on low oil pressure may not appear on the logic path, but the function of the pressure switch would be included in the circuit analysis considerations for the pump.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1.2     Criteria/Assumptions  Assume that exposure fire damage to manual valves and piping does not adversely impact their ability to perform their pressure boundary or safe shutdown function (heat sensitive piping materials, including tubing with brazed or soldered joints, are not included in this assumption). Fire damage should be evaluated with respect to the ability to manually open or close the valve should this be necessary as a part of the post-fire safe shutdown scenario.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            PINGP assumes no fire-induced damage to manual valves or piping.
Additionally, NSPM determined that no valves are subject to the rising           EC 23407 - B2 Methodology Evaluation stem concern as described in NEI 00-01 Revision 2 (reference EC 23408,           EC 23408 - NEI 00-01 Revision 1 to NEI 00-01 gap analysis).                                                         Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                          Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1.3     Criteria/Assumptions  Assume that manual valves are in their normal position as shown on P&IDs or in the plant operating procedures.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                              Reference Documents Aligns                            For safe and stable, manual valves are assumed to be in their normal EC 23407 - B2 Methodology Evaluation operating positions per their respective plant documentation.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1.4     Criteria/Assumptions  Assume that a check valve closes in the direction of potential flow diversion and seats properly with sufficient leak tightness to prevent flow diversion. Therefore, check valves do not adversely affect the flow rate capability of the safe shutdown systems being used for inventory control, decay heat removal, equipment cooling or other related safe shutdown functions.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            PINGP assumes check valves are installed properly in that they will prevent reversal of flow. PINGP also assumes that the check valves             EC 23407 - B2 Methodology Evaluation integrity is such that they will not produce a leak rate that is other than     EC 23408 - NEI 00-01 Revision 1 to inconsequential.                                                                Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.2.1.5       Criteria/Assumptions Instruments (e.g., resistance temperature detectors, thermocouples, pressure transmitters, and flow transmitters) are assumed to fail upscale, midscale, or downscale as a result of fire damage, whichever is worse. An instrument performing a control function is assumed to provide an undesired signal to the control circuit.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                                   Reference Documents Aligns with Intent                 PINGP assumes that instrumentation circuits fail in their worst-case EC 23407 - B2 Methodology Evaluation positions when damaged by the fire unless analysis was performed to EC 23408 - NEI 00-01 Revision 1 to show that the failure mode is incredible.
Revision 2 Gap Analysis Credited instrumentation circuits are modeled in the NSCA (Genesis)               NSCA (Genesis) Model model.                                                                            EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1.6     Criteria/Assumptions  Identify equipment that could spuriously operate or mal-operate and impact the performance of equipment on a required safe shutdown path during the equipment selection phase. Consider Bin 1 of RIS 2004-03 during the equipment identification process.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                               Reference Documents Aligns                            Spurious operation was considered in the selection of components as well EC 23407 - B2 Methodology Evaluation as cable selection. The selected components (including logical EC 23408 - NEI 00-01 Revision 1 to relationships) and cables are maintained in the NSCA (Genesis) model.         Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.2.1.7     Criteria/Assumptions  Identify instrument tubing that may cause subsequent effects on instrument readings or signals as a result of fire.
Determine and consider the fire area location of the instrument tubing when evaluating the effects of fire damage to circuits and equipment in the fire area.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                               Reference Documents Aligns                            An instrument tubing analysis has been performed for credited EC 23407 - B2 Methodology Evaluation instrumentation along the credited success paths (including credited EC 23408 - NEI 00-01 Revision 1 to process monitoring). The analysis did not identify any impacts to the safe    Revision 2 Gap Analysis and stable model resulting from fire-induced effects on liquid-filled         NSCA (Genesis) Model instrument tubing.                                                            EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                     Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                          NEI 00-01 Section 3.0 Guidance 3.2.2        Methodology for Equipment Refer to NEI-00-01 Rev 1 Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown Selection                 equipment.
Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:
Applicability                          Comments Applicable Alignment Statement                    Alignment Basis Reference Documents Not Required                           Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.2.2.1       Identify the System Flow Path for Mark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path. Refer Each Shutdown Path                to Attachment 2 for an example of an annotated P&ID illustrating this concept.
Applicability                                   Comments Applicable Alignment Statement                             Alignment Basis                                                                Reference Documents Aligns with Intent                              PINGP utilized marked-up P&IDs to identify both required flow paths as EC 23407 - B2 Methodology Evaluation well as diversion flow paths. This information was used as a basis for the EC 23408 - NEI 00-01 Revision 1 to safe and stable logic trees and equipment listings that are contained in the Revision 2 Gap Analysis NSCA (Genesis) model. The marked up P&IDs are not required to be NSCA (Genesis) Model retained as the logic trees within the NSCA (Genesis) model are sufficient EC 20612 - Non Power / NSCA Operations to show flowpaths with credited components.
Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                              NEI 00-01 Section 3.0 Guidance 3.2.2.2     Identify the Equipment in Each Review the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all Safe Shutdown System Flow Path equipment in each systems flow path has been identified. Assure that any equipment that could spuriously operate and Including Equipment That May   adversely affect the desired system function(s) is also identified. If additional systems are identified which are necessary Spuriously Operate and Affect  for the operation of the safe shutdown system under review, include these as systems required for safe shutdown.
System Operation               Designate these new systems with the same safe shutdown path as the primary safe shutdown system under review (Refer to Figure 3-1).
Applicability                              Comments Applicable Alignment Statement                        Alignment Basis                                                                     Reference Documents Aligns                                     PINGP utilized P&IDs, single line diagrams, loop diagrams, connection EC 23407 - B2 Methodology Evaluation diagrams and procedures to identify equipment required to meet NSPC.
EC 23408 - NEI 00-01 Revision 1 to Spurious operation of equipment that could affect the NSPC was                      Revision 2 Gap Analysis considered in the selection process.                                                NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                        Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                               NEI 00-01 Section 3.0 Guidance 3.2.2.3     Develop a List of Safe Shutdown Prepare a table listing the equipment identified for each system and the shutdown path that it supports. Identify any valves Equipment and Assign the        or other equipment that could spuriously operate and impact the operation of that safe shutdown system.
corresponding System and Safe Shutdown Path(s) Designation to Assign the safe shutdown path for the affected system to this equipment. During the cable selection phase, identify Each                            additional equipment required to support the safe shutdown function of the path (e.g., electrical distribution system equipment). Include this additional equipment in the safe shutdown equipment list. Attachment 3 to this document provides an example of a (SSEL). The SSEL identifies the list of equipment within the plant considered for safe shutdown and it documents various equipment-related attributes used in the analysis.
Applicability                               Comments Applicable Alignment Statement                         Alignment Basis                                                                Reference Documents Aligns                                      The NSCA (Genesis) model contains the listing of the components that EC 23407 - B2 Methodology Evaluation were identified as being required to meet the NSPC.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis In addition to the equipment listing, shutdown paths are displayed logically   NSCA (Genesis) Model within the model. Electrical distribution equipment is logically arranged in   EC 20612 - Non Power / NSCA Operations a cascading manner such that a failure of an upstream component will           Review for NFPA 805 cascade down to show a loss of the downstream components. Other supporting equipment is logically tied to the component(s) or functions which it supports.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.2.2.4       Identify Equipment Information Collect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for the Required for the Safe Shutdown equipment. In order to facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer to Analysis                       Attachment 3 to this document for an example of a SSEL. Examples of related equipment data should include the equipment type, equipment description, safe shutdown system, safe shutdown path, drawing reference, fire area, fire zone, and room location of equipment. Other information such as the following may be useful in performing the safe shutdown analysis: normal position, hot shutdown position, cold shutdown position, failed air position, failed electrical position, high/low pressure interface concern, and spurious operation concern.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                    Reference Documents Aligns with Intent                           PINGP has identified and recorded similar data to that given in this EC 23407 - B2 Methodology Evaluation guidance. PINGP maintains the NSCA equipment listing and analysis EC 23408 - NEI 00-01 Revision 1 to data within the NSCA (Genesis) model.                                              Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                         Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.2.2.5     Identify Dependencies Between    In the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as Equipment, Supporting Equipment, electrical power and interlocked equipment. As an aid in assessing identified impacts to safe shutdown, consider modeling Safe Shutdown Systems and Safe   the dependency between equipment within each safe shutdown path either in a relational database or in the form of a Shutdown Paths                   Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an example of a SSLD that may be developed to document these relationships.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                Reference Documents Aligns                                       PINGP utilizes the NSCA (Genesis) model to provide logical relationships EC 23407 - B2 Methodology Evaluation between equipment, cables, power supplies and supporting equipment, to EC 23408 - NEI 00-01 Revision 1 to the fire areas in which they are located. The NSCA (Genesis) model             Revision 2 Gap Analysis provides the necessary logical relationships to allow analysis of              NSCA (Genesis) Model fire- induced failures on a fire-area-by-fire-area basis. The logical          EC 20612 - Non Power / NSCA Operations relationships provide for proper cascading of equipment losses from an         Review for NFPA 805 upstream component to the downstream components.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                                        Attachment B - NEI 04-02 Table B-2 2.4.2.2 Nuclear Safety Capability Circuit Analysis (Taken From NFPA 805, 2001 Edition) 2.4.2.2.1 Circuits Required in Nuclear Safety Functions. Circuits required for the nuclear safety functions shall be identified. This includes circuits that are required for operation, that could prevent the operation, or that result in the maloperation of the equipment identified in 2.4.2.1. This evaluation shall consider fire-induced failure modes such as hot shorts (external and internal), open circuits, and shorts-to-ground, to identify circuits that are required to support the proper operation of components required to achieve the nuclear safety performance criteria, including spurious operation and signals. This will ensure that a comprehensive population of circuitry is evaluated.
2.4.2.2.2 Other Required Circuits. Other circuits that share common power supply and/or common enclosure with circuits required to achieve nuclear safety performance criteria shall be evaluated for their impact on the ability to achieve nuclear safety performance criteria.
(a) Common Power Supply Circuits. Those circuits whose fire induced failure could cause the loss of a power supply required to achieve the nuclear safety performance criteria shall be identified. This situation could occur if the upstream protection device (i.e. breaker or fuse) is not properly coordinated with the downstream protection device.
(b) Common Enclosure Circuits. Those circuits that share enclosures with circuits required to achieve the nuclear safety performance criteria and whose fire-induced failure could cause the loss of the required components shall be identified. The concern is that the effects of a fire can extend outside of the immediate fire area due to fire-induced electrical faults on inadequately protected cables or via inadequately sealed fire area boundaries.
NEI 00-01 Ref                                             NEI 00-01 Section 3.0 Guidance 3.3             Safe Shutdown Cable Selection             This section provides industry guidance on the recommended methodology and criteria for selecting safe shutdown cables and Location                              and determining their potential impact on equipment required for achieving and maintaining safe shutdown of an operating nuclear power plant for the condition of an exposure fire. The Appendix R safe shutdown cable selection criteria are developed to ensure that all cables that could affect the proper operation or that could cause the maloperation of safe shutdown equipment are identified and that these cables are properly related to the safe shutdown equipment whose functionality they could affect. Through this cable-to-equipment relationship, cables become part of the safe shutdown path assigned to the equipment affected by the cable.
Applicability                                             Comments Applicable Alignment Statement                                       Alignment Basis                                                                   Reference Documents Not Required                                              Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance To identify an impact to safe shutdown equipment based on cable routing, the equipment must have cables that affect it 3.3.1        Criteria/Assumptions identified. Carefully consider how cables are related to safe shutdown equipment so that impacts from these cables can be properly assessed in terms of their ultimate impact on safe shutdown system equipment.
Consider the following criteria when selecting cables that impact safe shutdown equipment:
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                Reference Documents Not Required                      Generic Guidance Only EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.1     Criteria/Assumptions  The list of cables whose failure could impact the operation of a piece of safe shutdown equipment includes more than those cables connected to the equipment. The relationship between cable and affected equipment is based on a review of the electrical or elementary wiring diagrams. To assure that all cables that could affect the operation of the safe shutdown equipment are identified, investigate the power, control, instrumentation, interlock, and equipment status indication cables related to the equipment. Consider reviewing additional schematic diagrams to identify additional cables for interlocked circuits that also need to be considered for their impact on the ability of the equipment to operate as required in support of post-fire safe shutdown. As an option, consider applying the screening criteria from Section 3.5 as a part of this section.
For an example of this see Section 3.3.1.4.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                    Reference Documents Aligns                            PINGP utilized schematic and connection diagrams to identify all cables EC 23407 - B2 Methodology Evaluation associated with the component being analyzed. The analysis included EC 23408 - NEI 00-01 Revision 1 to cables from both on-scheme and off-scheme categories when adequate                 Revision 2 Gap Analysis circuit isolation could not be shown to exist.                                     NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.2     Criteria/Assumptions  In cases where the failure (including spurious actuations) of a single cable could impact more than one piece of safe shutdown equipment, include the cable with each piece of safe shutdown equipment.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            The NSCA (Genesis) model maintains cable to equipment relationships EC 23407 - B2 Methodology Evaluation with the ability to have a one-to-many relationship. In other words, cables EC 23408 - NEI 00-01 Revision 1 to appearing in more than one components schematic are captured by the Revision 2 Gap Analysis circuit analysis, and are included in the NSCA (Genesis) model under NSCA (Genesis) Model each component that may be affected by the potential fault on that cable.
EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.3     Criteria/Assumptions  Electrical devices such as relays, switches and signal resistor units are considered to be acceptable isolation devices. In the case of instrument loops, review the isolation capabilities of the devices in the loop to determine that an acceptable isolation device has been installed at each point where the loop must be isolated so that a fault would not impact the performance of the safe shutdown instrument function.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                    Reference Documents Aligns                            The NSCA (Genesis) model credits only acceptable (positive) isolation EC 23407 - B2 Methodology Evaluation devices including isolation devices for instrumentation signals that are EC 23408 - NEI 00-01 Revision 1 to credited for use in multiple locations of the plant.                               Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.4     Criteria/Assumptions  Screen out cables for circuits that do not impact the safe shutdown function of a component (i.e., annunciator circuits, space heater circuits and computer input circuits) unless some reliance on these circuits is necessary. However, they must be isolated from the components control scheme in such a way that a cable fault would not impact the performance of the circuit.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            Cables were only excluded when proper isolation existed, and reliance on EC 23407 - B2 Methodology Evaluation the excluded circuit(s) was not required by the analysis.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.5     Criteria/Assumptions  For each circuit requiring power to perform its safe shutdown function, identify the cable supplying power to each safe shutdown and/or required interlock component. Initially, identify only the power cables from the immediate upstream power source for these interlocked circuits and components (i.e., the closest power supply, load center or motor control center). Review further the electrical distribution system to capture the remaining equipment from the electrical power distribution system necessary to support delivery of power from either the offsite power source or the emergency diesel generators (i.e., onsite power source) to the safe shutdown equipment. Add this equipment to the safe shutdown equipment list. Evaluate the power cables for this additional equipment for associated circuits concerns.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                   Reference Documents Aligns                            Power supply logics have been created within the NSCA (Genesis) model EC 23407 - B2 Methodology Evaluation to identify the cascading effects of a loss of upstream power supplies.
EC 23408 - NEI 00-01 Revision 1 to Power supplies are cascaded from the offsite power sources and / or the           Revision 2 Gap Analysis emergency diesel generator. The effects of loss of DC control power               NSCA (Genesis) Model (common power supply, common enclosure) have also been incorporated               EC 20612 - Non Power / NSCA Operations into the analysis for the applicable buses. Discrepancies identified during       Review for NFPA 805 the model strategy reviews were dispositioned via the VFDR process.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                   Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.6     Criteria/Assumptions  The automatic initiation logics for the credited post-fire safe shutdown systems are not required to support safe shutdown.
Each system can be controlled manually by operator actuation in the main control room or emergency control station. If operator actions outside the MCR are necessary, those actions must conform to the regulatory requirements on manual actions. However, if not protected from the effects of fire, the fire-induced failure of automatic initiation logic circuits must not adversely affect any post-fire safe shutdown system function.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                     Reference Documents Aligns                            For safe and stable, PINGP does not credit automatic functions unless EC 23407 - B2 Methodology Evaluation circuit analysis supports the availability of the function, along with the EC 23408 - NEI 00-01 Revision 1 to required supporting equipment and power.                                            Revision 2 Gap Analysis NSCA (Genesis) Model The NSCA (Genesis) model was utilized to determine the effects of the               EC 20612 - Non Power / NSCA Operations fire on automatic functions for both availability (when credited) and for           Review for NFPA 805 effects of spurious operation. Discrepancies identified during the model strategy reviews were dispositioned via the VFDR process.
Operator actions taken outside of the control room are addressed in LAR Attachment G. The VFDR process was used to identify those actions that are not allowed under the deterministic methodology of NFPA 805.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.3.1.7     Criteria/Assumptions  Cabling for the electrical distribution system is a concern for those breakers that feed associated circuits and are not fully coordinated with upstream breakers. With respect to electrical distribution cabling, two types of cable associations exist.
For safe shutdown considerations, the direct power feed to a primary safe shutdown component is associated with the primary component. For example, the power feed to a pump is necessary to support the pump. Similarly, the power feed from the load center to an MCC supports the MCC. However, for cases where sufficient branch-circuit coordination is not provided, the same cables discussed above would also support the power supply. For example, the power feed to the pump discussed above would support the bus from which it is fed because, for the case of a common power source analysis, the concern is the loss of the upstream power source and not the connected load. Similarly, the cable feeding the MCC from the load center would also be necessary to support the load center.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                   Reference Documents Aligns                            Loss of DC control power to NFPA 805 credited plant buses is EC 23407 - B2 Methodology Evaluation incorporated in the NSCA (Genesis) model, and the impact of secondary EC 23408 - NEI 00-01 Revision 1 to fires and loss of power supply have been considered (common power                Revision 2 Gap Analysis supply, common enclosure). Logics contained in the NSCA (Genesis)                 NSCA (Genesis) Model model detail the cascading effects of power supply losses when they               EC 20612 - Non Power / NSCA Operations occur as a result of fire-induced damage. Additionally, coordination              Review for NFPA 805 concerns identified during the coordination review were incorporated in the       ENG-EE-177 NSCA (Genesis) model. Discrepancies identified during the model                   Attachment S Table S-3 strategy reviews were dispositioned via the VFDR process.                         AR 01342798 An update to Attachment S Table S-3 was added to track the results of AR 01342798 that identified the need to modify the 4kV fault current study ENG-EE-177 to properly reflect the plant lineups to meet NFPA 805. AR 01342798 identifies that ENG-EE-177 is overly conservative with respect to NFPA 805 requirements. This pending change to ENG-EE-177 only impacts the NFPA 805 analysis for buses 11, 12, 21 and 22; none of which are credited by the NSCA or PRA models for powering equipment.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                        Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                         NEI 00-01 Section 3.0 Guidance 3.3.2       Associated Circuit Cables Associated Circuit Cables Appendix R, Section III.G.2, requires that separation features be provided for equipment and cables, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts-to-ground, of redundant trains of systems necessary to achieve hot shutdown. The three types of associated circuits were identified in Reference 6.1.5 and further clarified in a NRC memorandum dated March 22, 1982 from R. Mattson to D. Eisenhut, Reference 6.1.6. They are as follows:
                                      - Spurious actuations
                                      - Common power source
                                      - Common enclosure Cables Whose Failure May Cause Spurious Actuations Safe shutdown system spurious actuation concerns can result from fire damage to a cable whose failure could cause the spurious actuation/ maloperation of equipment whose operation could affect safe shutdown. These cables are identified in Section 3.3.3 together with the remaining safe shutdown cables required to support control and operation of the equipment.
Common Power Source Cables The concern for the common power source associated circuits is the loss of a safe shutdown power source due to inadequate breaker/fuse coordination. In the case of a fire-induced cable failure on a non-safe shutdown load circuit supplied from the safe shutdown power source, a lack of coordination between the upstream supply breaker/fuse feeding the safe shutdown power source and the load breaker/fuse supplying the non-safe shutdown faulted circuit can result in loss of the safe shutdown bus. This would result in the loss of power to the safe shutdown equipment supplied from that power source preventing the safe shutdown equipment from performing its required safe shutdown function. Identify these cables together with the remaining safe shutdown cables required to support control and operation of the equipment.
Refer to Section 3.5.2.4 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
Common Enclosure Cables The concern with common enclosure associated circuits is fire damage to a cable whose failure could propagate to other safe shutdown cables in the same enclosure either because the circuit is not properly protected by an isolation device (breaker/fuse) such that a fire-induced fault could result in ignition along its length, or by the fire propagating along the cable and into an adjacent fire area. This fire spread to an adjacent fire area could impact safe shutdown equipment in that fire area, thereby resulting in a condition that exceeds the criteria and assumptions of this methodology (i.e., multiple fires).
Refer to Section 3.5.2.5 for an acceptable methodology for analyzing the impact of these cables on post-fire safe shutdown.
Applicability                         Comments Applicable PINGP Page B Revision 1

Northern States Power - Minnesota                       Attachment B - NEI 04-02 Table B-2 Alignment Statement               Alignment Basis        Reference Documents Not Required                      Generic Guidance Only  EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                            Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.3.3        Methodology for Cable Selection Refer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for performing a and Location                    post-fire safe shutdown analysis. Use the following methodology to define the cables required for safe shutdown including cables that may cause associated circuits concerns for a post-fire safe shutdown analysis:
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                   Reference Documents Not Required                                 Generic Guidance Only                                                             EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                  NEI 00-01 Section 3.0 Guidance 3.3.3.1     Identify Circuits Required for the For each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including the Operation of the Safe Shutdown     following documentation to identify the circuits (power, control, instrumentation) required for operation or whose failure Equipment                          may impact the operation of each piece of equipment:
                                               - Single-line electrical diagrams
                                               - Elementary wiring diagrams
                                               - Electrical connection diagrams
                                               - Instrument loop diagrams.
For electrical power distribution equipment such as power supplies, identify any circuits whose failure may cause a coordination concern for the bus under evaluation. If power is required for the equipment, include the closest upstream power distribution source on the safe shutdown equipment list. Through the iterative process described in Figures 3-2 and 3-3, include the additional upstream power sources up to either the offsite or the emergency power source.
Applicability                                  Comments Applicable Alignment Statement                            Alignment Basis                                                                   Reference Documents Aligns                                         PINGP safe and stable circuits were identified using schematics, EC 23407 - B2 Methodology Evaluation connection diagrams, single lines and loop diagrams. Logic diagrams EC 23408 - NEI 00-01 Revision 1 to detailing the cascade power sources to equipment are included in the              Revision 2 Gap Analysis NSCA (Genesis) model. Loss of DC control power to power operated                  NSCA (Genesis) Model circuit breakers is addressed via the OCT analysis in the NSCA (Genesis)          EC 20612 - Non Power / NSCA Operations model. Discrepancies identified during the model strategy reviews were            Review for NFPA 805 dispositioned via the VFDR process.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                 NEI 00-01 Section 3.0 Guidance 3.3.3.2     Identify Interlocked Circuits and In reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and equipment.
Cables Whose Spurious Operation   Assign to the equipment any cables for interlocked circuits that can affect the equipment.
or Maloperation Could Affect Shutdown                          While investigating the interlocked circuits, additional equipment or power sources may be discovered. Include these interlocked equipment or power sources in the safe shutdown equipment list (refer to NEI-00-01 Rev 1 Figure 3-3) if they can impact the operation of the equipment under consideration.
Applicability                                 Comments Applicable Alignment Statement                           Alignment Basis                                                                    Reference Documents Aligns                                        PINGP circuit analysis considered interlocked, and required supporting EC 23407 - B2 Methodology Evaluation equipment.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                     Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                         NEI 00-01 Section 3.0 Guidance 3.3.3.3     Assign Cables to the Safe Given the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in Shutdown Equipment        maloperation of each piece of safe shutdown equipment.
Tabulate the list of cables potentially affecting each piece of equipment in a relational database including the respective drawing numbers, their revision and any interlocks that are investigated to determine their impact on the operation of the equipment. In certain cases, the same cable may support multiple pieces of equipment. Relate the cables to each piece of equipment, but not necessarily to each supporting secondary component.
If adequate coordination does not exist for a particular circuit, relate the power cable to the power source. This will ensure that the power source is identified as affected equipment in the fire areas where the cable may be damaged.
Applicability                         Comments Applicable Alignment Statement                   Alignment Basis                                                                    Reference Documents Aligns                                A listing of required cables from the existing Appendix R model was EC 23407 - B2 Methodology Evaluation obtained and combined with circuit analysis that was created in support of EC 23408 - NEI 00-01 Revision 1 to NFPA-805. This information was entered into the NSCA (Genesis) model               Revision 2 Gap Analysis for analysis of safe and stable conditions under NFPA-805. The NSCA                NSCA (Genesis) Model (Genesis) model relates cable to equipment, cable to raceway, and                  EC 20612 - Non Power / NSCA Operations raceway to location for analysis purposes. Power supplies are modeled in           Review for NFPA 805 the NSCA (Genesis) model in cascading fashion. Logic diagrams within the model display the potential success paths. All discrepancies identified during the strategy reviews performed using the model, were dispositioned via the VFDR process.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                                  Attachment B - NEI 04-02 Table B-2 2.4.2.3 Nuclear Safety Equipment and Cable Location (Taken From NFPA 805, 2001 Edition)
Physical location of equipment and cables shall be identified.
NEI 00-01 Ref                                        NEI 00-01 Section 3.0 Guidance 3.3.3.4       Identify Routing of Cables             Identify the routing for each cable including all raceway and cable endpoints. Typically, this information is obtained from joining the list of safe shutdown cables with an existing cable and raceway database.
Applicability                                        Comments Applicable Alignment Statement                                  Alignment Basis                                                                 Reference Documents Aligns                                               Cable routing information was obtained from the plant Passport database EC 23407 - B2 Methodology Evaluation system. This information was entered into the NSCA (Genesis) model in EC 23408 - NEI 00-01 Revision 1 to support of the safe and stable analysis under NFPA-805. Discrepancies           Revision 2 Gap Analysis discovered during the transition process were corrected using the               NSCA (Genesis) Model established plant processes.                                                    EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.3.3.5     Identify Location of Raceway and Identify the fire area location of each raceway and cable endpoint identified in the previous step and join this information Cables by Fire Area              with the cable routing data. In addition, identify the location of field-routed cable by fire area. This produces a database containing all of the cables requiring fire area analysis, their locations by fire area, and their raceway.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                      Reference Documents Aligns                                       PINGP utilizes the Genesis database to track cable to equipment, cable to EC 23407 - B2 Methodology Evaluation raceway, and raceway to location information. As stated above, the EC 23408 - NEI 00-01 Revision 1 to routing information was obtained from the Passport system. When                      Revision 2 Gap Analysis routing was determined to be missing or inadequate, raceway drawings                 NSCA (Genesis) Model and walkdowns were utilized to generate the correct information.                     EC 20612 - Non Power / NSCA Operations The information tracked by Genesis is consistent with the guidance of NEI            Review for NFPA 805 00-01, Revision 1 for safe and stable and is utilized by the NSCA (Genesis) model to provide logic diagrams demonstrating success paths for each fire area.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                                     Attachment B - NEI 04-02 Table B-2 2.4.2.4 Fire Area Assessment (Taken From NFPA 805, 2001 Edition)
Fire Area Assessment. An engineering analysis shall be performed in accordance with the requirements of Section 2.3 for each fire area to determine the effects of fire or fire suppression activities on the ability to achieve the nuclear safety performance criteria of Section 1.5. [See Chapter 4 for methods of achieving these performance criteria (performance-based or deterministic)].
NEI 00-01 Ref                                          NEI 00-01 Section 3.0 Guidance 3.4           Fire Area Assessment and                 By determining the location of each component and cable by fire area and using the cable to equipment relationships Compliance Strategies                    described above, the affected safe shutdown equipment in each fire area can be determined. Using the list of affected equipment in each fire area, the impacts to safe shutdown systems, paths and functions can be determined. Based on an assessment of the number and types of these impacts, the required safe shutdown path for each fire area can be determined. The specific impacts to the selected safe shutdown path can be evaluated using the circuit analysis and evaluation criteria contained in Section 3.5 of this document. Having identified all impacts to the required safe shutdown path in a particular fire area, this section provides guidance on the techniques available for individually mitigating the effects of each of the potential impacts.
Applicability                                          Comments Applicable Alignment Statement                                    Alignment Basis                                                                   Reference Documents Not Required                                           Generic Guidance EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1        Criteria/Assumptions The following criteria and assumptions apply when performing fire area compliance assessment to mitigate the consequences of the circuit failures identified in the previous sections for the required safe shutdown path in each fire area.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                    Reference Documents Not Required                      Generic Guidance EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                       Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.1     Criteria/Assumptions  Assume only one fire in any single fire area at a time.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                        Reference Documents Aligns                            The PINGP safe and stable analysis under NFPA-805 considers only one EC 23407 - B2 Methodology Evaluation fire occurring in one area at a time.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis Common enclosure concerns, common enclosure caused by loss of DC       NSCA (Genesis) Model control power have been considered in the model and by other analysis  EC 20612 - Non Power / NSCA Operations (Reference Section 3.3.1.7 above).                                     Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.2     Criteria/Assumptions  Assume that the fire may affect all unprotected cables and equipment within the fire area. This assumes that neither the fire size nor the fire intensity is known. This is conservative and bounds the exposure fire that is required by the regulation.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                 Reference Documents Aligns                            PINGP assumed that a fire could affect all unprotected equipment and EC 23407 - B2 Methodology Evaluation cables in the fire area. PINGP did not credit fire dynamics (intensity or EC 23408 - NEI 00-01 Revision 1 to size) when analyzing the deterministic areas for fire-induced damage. For       Revision 2 Gap Analysis areas utilizing RI / PB methodology, fire modeling was often employed to        NSCA (Genesis) Model demonstrate that success paths would remain available.                          EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.3     Criteria/Assumptions  Address all cable and equipment impacts affecting the required safe shutdown path in the fire area. All potential impacts within the fire area must be addressed. The focus of this section is to determine and assess the potential impacts to the required safe shutdown path selected for achieving post-fire safe shutdown and to assure that the required safe shutdown path for a given fire area is properly protected.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            The PINGP analysis considered all cable and equipment impacts as a EC 23407 - B2 Methodology Evaluation result of the fire and addressed the impacts to achieve success paths for EC 23408 - NEI 00-01 Revision 1 to each NSPC within the NSCA (Genesis) model.                                       Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                              Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.4.1.4       Criteria/Assumptions Use manual actions where appropriate to achieve and maintain post-fire safe shutdown conditions in accordance with NRC requirements.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                              Reference Documents Aligns with Intent                 To achieve and maintain safe and stable conditions, and to minimize the EC 23407 - B2 Methodology Evaluation use of recovery actions, the least fire-impacted success path was credited EC 23408 - NEI 00-01 Revision 1 to for each fire area.                                                          Revision 2 Gap Analysis NSCA (Genesis) Model All recovery actions that varied from the deterministic requirements were    EC 20612 - Non Power / NSCA Operations addressed via the VFDR process. Areas with VFDRs that were not solved        Review for NFPA 805 by a modification utilized the RI / PB methodology.                          Attachment G Attachment S, Table S-3, Items 57, 58, and 62 Feasibility and / or Reliability of the recovery actions is being addressed as part of the NFPA 805 process as described in LAR Attachment G and Attachment S, Table S-3, Items 57, 58, and 62.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.5     Criteria/Assumptions  Where appropriate to achieve and maintain cold shutdown within 72 hours, use repairs to equipment required in support of post-fire shutdown.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                             Reference Documents Aligns                            The 10CFR50 Appendix R requirement to achieve and maintain cold EC 23407 - B2 Methodology Evaluation shutdown within 72 hours is not a requirement of NFPA 805; NFPA 805 EC 23408 - NEI 00-01 Revision 1 to requires maintaining fuel in a safe and stable condition. PINGP achieves    Revision 2 Gap Analysis safe and stable conditions at Mode 3. Reference Section 3.1 (above) for     NSCA (Genesis) Model additional information regarding PINGPs safe and stable conditions.        EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.6     Criteria/Assumptions  Appendix R compliance requires that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free of fire damage (III.G.1.a). When cables or equipment, including associated circuits, are within the same fire area outside primary containment and separation does not already exist, provide one of the following means of separation for the required safe shutdown path(s):
                                  - Separation of cables and equipment and associated non-safety circuits of redundant trains within the same fire area by a fire barrier having a 3-hour rating (III.G.2.a)
                                  - Separation of cables and equipment and associated non-safety circuits of redundant trains within the same fire area by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (III.G.2.b).
                                  - Enclosure of cable and equipment and associated non-safety circuits of one redundant train within a fire area in a fire barrier having a one-hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area (III.G.2.c).
For fire areas inside non-inerted containments, the following additional options are also available:
                                  - Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards (III.G.2.d);
                                  - Installation of fire detectors and an automatic fire suppression system in the fire area (III.G.2.e); or
                                  - Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield (III.G.2.f).
Use exemptions, deviations and licensing change processes to satisfy the requirements mentioned above and to demonstrate equivalency depending upon the plant's license requirements.
Applicability                     Comments Applicable PINGP Page B Revision 1

Northern States Power - Minnesota                                                                   Attachment B - NEI 04-02 Table B-2 Alignment Statement                       Alignment Basis                                              Reference Documents Not in Alignment [but Prior NRC Approval] Areas crediting methods or mitigating strategies that        EC 23407 - B2 Methodology Evaluation varied from the deterministic requirements were              EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis addressed through the VFDR process.
NSCA (Genesis) Model In each case, a success path was assured for each            EC 20612 - Non Power / NSCA Operations performance goal within each fire area.                      Review for NFPA 805 Areas with VFDRs that could not be solved by a modification, were addressed using the RI / PB methods and not the deterministic methods.
As an exception to this section, PINGP is transitioning existing approved licensing action for the oil collection system in Fire Areas 1 and 71 (containment).
Additionally, as an exception to this section, PINGP is transitioning existing approved licensing action for a repair action to assure isolation of pressurizer PORVs for a fire occurring in the cable spreading room or relay room (Fire Areas 13 and 18 respectively) that could cause spurious operation of PORV isolation valves.
Therefore, this section is Not in Alignment but Prior NRC Approval. The details for this licensing action can be found in Attachments K and T.
All fire areas utilizing these transitioning licensing actions (exemptions) are evaluated using the RI / PB methodology.
The basis for approval has been reviewed. There have been no plant modifications or other changes that would invalidate the basis for approval.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.7     Criteria/Assumptions  Consider selecting other equipment that can perform the same safe shutdown function as the impacted equipment. In addressing this situation, each equipment impact, including spurious operations, is to be addressed in accordance with regulatory requirements and the NPPs current licensing basis.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                               Reference Documents Aligns                            PINGP considered multiple success paths and alternative equipment EC 23407 - B2 Methodology Evaluation when deciding on how to best meet the NSPC. In each case, a success EC 23408 - NEI 00-01 Revision 1 to path was assured for each performance goal within each fire area by            Revision 2 Gap Analysis choosing the path least impacted by the fire, so as to minimize the            NSCA (Genesis) Model reliance upon recovery actions. Spurious operations were addressed as          EC 20612 - Non Power / NSCA Operations detailed in the applicable sections of this document.                          Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.4.1.8     Criteria/Assumptions  Consider the effects of the fire on the density of the fluid in instrument tubing and any subsequent effects on instrument readings or signals associated with the protected safe shutdown path in evaluating post-fire safe shutdown capability. This can be done systematically or via procedures such as Emergency Operating Procedures.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                    Reference Documents Aligns                            PINGP considered multiple success paths and alternative equipment EC 23407 - B2 Methodology Evaluation when deciding on how to best meet the NSPC. In each case, a success EC 23408 - NEI 00-01 Revision 1 to path was assured for each performance goal within each fire area by                Revision 2 Gap Analysis choosing the path least impacted by the fire, so as to minimize the                NSCA (Genesis) Model reliance upon recovery actions. Spurious operations were addressed as              EC 20612 - Non Power / NSCA Operations detailed in the applicable sections of this document. The impact of fire-          Review for NFPA 805 induced effects on instrument tubing was addressed by EC 19988. This               EC 19988, NFPA 805 LAR Attachment B- RIS included process instrumentation as well as credited flowpath                      04-003 (Updated) Analysis, B-2 Table Support instrumentation.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                       Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                          NEI 00-01 Section 3.0 Guidance 3.4.2        Methodology for Fire Area Refer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.
Assessment Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:
Applicability                          Comments Applicable Alignment Statement                    Alignment Basis                                                                     Reference Documents Not Required                           Generic Guidance EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                  NEI 00-01 Section 3.0 Guidance 3.4.2.1     Identify the Affected Equipment by Identify the safe shutdown cables, equipment and systems located in each fire area that may be potentially damaged by Fire Area                          the fire. Provide this information in a report format. The report may be sorted by fire area and by system in order to understand the impact to each safe shutdown path within each fire area (see Attachment 5 for an example of an Affected Equipment Report).
Applicability                                  Comments Applicable Alignment Statement                            Alignment Basis                                                                   Reference Documents Aligns                                         The NSCA (Genesis) model provides a listing of equipment and EC 23407 - B2 Methodology Evaluation associated cables, as well as a logical relationship for meeting NSPC EC 23408 - NEI 00-01 Revision 1 to requirements used to identify success paths for each fire area under the          Revision 2 Gap Analysis safe and stable analysis for NFPA 805. Support systems and interfaces             NSCA (Genesis) Model were also identified on the logic trees within the NSCA (Genesis) model.          EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.4.2.2     Determine the Shutdown Paths     Based on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are Least Impacted By a Fire in Each either unaffected or least impacted by a postulated fire within the fire area. Typically, the safe shutdown path with the least Fire Area                        number of cables and equipment in the fire area would be selected as the required safe shutdown path. Consider the circuit failure criteria and the possible mitigating strategies, however, in selecting the required safe shutdown path in a particular fire area. Review support systems as a part of this assessment since their availability will be important to the ability to achieve and maintain safe shutdown. For example, impacts to the electric power distribution system for a particular safe shutdown path could present a major impediment to using a particular path for safe shutdown. By identifying this early in the assessment process, an unnecessary amount of time is not spent assessing impacts to the frontline systems that will require this power to support their operation.
Based on an assessment as described above, designate the required safe shutdown path(s) for the fire area. Identify all equipment not in the safe shutdown path whose spurious operation or maloperation could affect the shutdown function.
Include these cables in the shutdown function list. For each of the safe shutdown cables (located in the fire area) that are part of the required safe shutdown path in the fire area, perform an evaluation to determine the impact of a fire-induced cable failure on the corresponding safe shutdown equipment and, ultimately, on the required safe shutdown path.
When evaluating the safe shutdown mode for a particular piece of equipment, it is important to consider the equipments position for the specific safe shutdown scenario for the full duration of the shutdown scenario. It is possible for a piece of equipment to be in two different states depending on the shutdown scenario or the stage of shutdown within a particular shutdown scenario. Document information related to the normal and shutdown positions of equipment on the safe shutdown equipment list.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                     Reference Documents Aligns                                       The NSCA (Genesis) model was utilized to identify the NSPC paths least EC 23407 - B2 Methodology Evaluation affected by the fire occurring in each fire area. The NSCA (Genesis)
EC 23408 - NEI 00-01 Revision 1 to model identifies, and logically relates the NSPC components to their Revision 2 Gap Analysis support equipment, such that a fire-induced failure of the support NSCA (Genesis) Model equipment will cascade as a loss of the NSPC component, and its path EC 20612 - Non Power / NSCA Operations when applicable.
Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                       NEI 00-01 Section 3.0 Guidance 3.4.2.3     Determine Safe Shutdown Using the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment that Equipment Impacts       can impact safe shutdown and that can potentially be impacted by a fire in the fire area, and what those possible impacts are.
Applicability                       Comments Applicable Alignment Statement                 Alignment Basis                                                                  Reference Documents Aligns                              The NSCA (Genesis) model generates reports (in logic tree format) of all EC 23407 - B2 Methodology Evaluation affected equipment and cables within the fire area of concern. These EC 23408 - NEI 00-01 Revision 1 to reports include a listing of cascaded losses of support equipment. The           Revision 2 Gap Analysis circuit analysis tied to the cables within the model describes the potential     NSCA (Genesis) Model impacts due to the fire.                                                         EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.4.2.4     Develop a Compliance Strategy or    The available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Figure 1-2):
Disposition to Mitigate the Effects Due to Fire Damage to Each          - Provide a qualified 3-fire rated barrier.
Required Component or Cable         - Provide a 1-hour fire rated barrier with automatic suppression and detection.
                                                - Provide separation of 20 feet or greater with automatic suppression and detection and demonstrate that there are no intervening combustibles within the 20 foot separation distance.
                                                - Reroute or relocate the circuit/equipment, or perform other modifications to resolve vulnerability.
                                                - Provide a procedural action in accordance with regulatory requirements.
                                                - Perform a cold shutdown repair in accordance with regulatory requirements.
                                                - Identify other equipment not affected by the fire capable of performing the same safe shutdown function.
                                                - Develop exemptions, deviations, Generic Letter 86-10 evaluation or fire protection design change evaluations with a licensing change process.
Additional options are available for non-inerted containments as described in 10 CFR 50 Appendix R section III.G.2.d, e and f.
Applicability                                   Comments Applicable Alignment Statement                             Alignment Basis                                                                    Reference Documents Aligns                                          PINGP fire areas that are remaining deterministic, utilize one of the EC 23407 - B2 Methodology Evaluation options listed in NFPA 805 Section 4.2.3 to assure success paths. For EC 23408 - NEI 00-01 Revision 1 to those areas differing from the deterministic requirements, VFDRs were              Revision 2 Gap Analysis created and resolved via the non-deterministic (RI / PB) methodology or            NSCA (Genesis) Model through the modification process for areas remaining deterministic.                EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.4.2.5     Document the Compliance Strategy Assign compliance strategy statements or codes to components or cables to identify the justification or mitigating actions or Disposition Determined to     proposed for achieving safe shutdown. The justification should address the cumulative effect of the actions relied upon by Mitigate the Effects Due to Fire the licensee to mitigate a fire in the area. Provide each piece of safe shutdown equipment, equipment not in the path Damage to Each Required          whose spurious operation or maloperation could affect safe shutdown, and/or cable for the required safe shutdown path Component or Cable               with a specific compliance strategy or disposition. Refer to Attachment 6 for an example of a Fire Area Assessment Report documenting each cable disposition.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis                                                                  Reference Documents Aligns                                       PINGPs safe and stable model incorporates the resolution (compliance EC 23407 - B2 Methodology Evaluation strategy) for components and cables affected by the fire (reference LAR EC 23408 - NEI 00-01 Revision 1 to Attachment C). The overall effect of recovery actions (mitigation                Revision 2 Gap Analysis activities), has been considered via the VFDR and FRE processes for RI /         NSCA (Genesis) Model PB areas. For deterministic areas, VFDRs were resolved via the                   EC 20612 - Non Power / NSCA Operations modification process. The NSCA (Genesis) model was utilized to develop           Review for NFPA 805 input for the NSCA strategy reviews, which facilitated the process of generating the appropriate VFDRs.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                NEI 00-01 Section 3.0 Guidance 3.5          Circuit Analysis and Evaluation This section on circuit analysis provides information on the potential impact of fire on circuits used to monitor, control and power safe shutdown equipment. Applying the circuit analysis criteria will lead to an understanding of how fire damage to the cables may affect the ability to achieve and maintain post-fire safe shutdown in a particular fire area. This section should be used in conjunction with Section 3.4, to evaluate the potential fire-induced impacts that require mitigation.
Appendix R Section III.G.2 identifies the fire-induced circuit failure types that are to be evaluated for impact from exposure fires on safe shutdown equipment. Section III.G.2 of Appendix R requires consideration of hot shorts, shorts-to-ground and open circuits.
Applicability                                Comments Applicable Alignment Statement                          Alignment Basis Reference Documents Not Required                                 Generic Guidance                                                                    EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.5.1        Criteria/Assumptions Apply the following criteria/assumptions when performing fire-induced circuit failure evaluations.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis Reference Documents Not Required                      Generic Guidance                                                                 EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.5.1.1     Criteria/Assumptions  Consider the following circuit failure types on each conductor of each unprotected safe shutdown cable to determine the potential impact of a fire on the safe shutdown equipment associated with that conductor.
                                  - A hot short may result from a fire-induced insulation breakdown between conductors of the same cable, a different cable or from some other external source resulting in a compatible but undesired impressed voltage or signal on a specific conductor. A hot short may cause a spurious operation of safe shutdown equipment.
                                  - An open circuit may result from a fire-induced break in a conductor resulting in the loss of circuit continuity. An open circuit may prevent the ability to control or power the affected equipment. An open circuit may also result in a change of state for normally energized equipment. (e.g. [for BWRs] loss of power to the Main Steam Isolation Valve (MSIV) solenoid valves due to an open circuit will result in the closure of the MSIVs). Note that RIS 2004-03 indicates that open circuits, as an initial mode of cable failures, are considered to be of very low likelihood. The risk-informed inspection process will focus on failures with relatively high probabilities.
                                  - A short-to-ground may result from a fire-induced breakdown of a cable insulation system, resulting in the potential on the conductor being applied to ground potential. A short-to-ground may have all of the same effects as an open circuit and, in addition, a short-to-ground may also cause an impact to the control circuit or power train of which it is a part.
Consider the three types of circuit failures identified above to occur individually on each conductor of each safe shutdown cable on the required safe shutdown path in the fire area.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                     Reference Documents Aligns                            For safe and stable, PINGP considers hot shorts, open circuits and shorts-EC 23407 - B2 Methodology Evaluation to-ground in alignment with NEI 00-01 Revision 1 as detailed in the EC 23408 - NEI 00-01 Revision 1 to following sections of this document.                                                Revision 2 Gap Analysis NSCA (Genesis) Model Refer to Section 3.5.2.1 for discussion of open circuits.                           EC 20612 - Non Power / NSCA Operations Review for NFPA 805 Refer to Section 3.5.2.2 for discussion of shorts-to-ground.
Refer to Section 3.5.2.3 for discussion of hot shorts and wire-to wire shorts.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.5.1.2     Criteria/Assumptions  Assume that circuit contacts are positioned (i.e., open or closed) consistent with the normal mode/position of the safe shutdown equipment as shown on the schematic drawings. The analyst must consider the position of the safe shutdown equipment for each specific shutdown scenario when determining the impact that fire damage to a particular circuit may have on the operation of the safe shutdown equipment.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                  Reference Documents Aligns                            PINGP circuit analysis assumes that the initial contact and operational EC 23407 - B2 Methodology Evaluation positions are per normal lineup as described in plant documentation.
EC 23408 - NEI 00-01 Revision 1 to Cable selection included components that require repositioning to achieve        Revision 2 Gap Analysis and maintain safe and stable conditions. All logical relationships and           NSCA (Genesis) Model applicable cable selection is maintained in the NSCA (Genesis) model.            EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.5.1.3     Criteria/Assumptions  Assume that circuit failure types resulting in spurious operations exist until action has been taken to isolate the given circuit from the fire area, or other actions have been taken to negate the effects of circuit failure that is causing the spurious actuation. The fire is not assumed to eventually clear the circuit fault. Note that RIS 2004-03 indicates that fire-induced hot shorts typically self-mitigate after a limited period of time.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                     Reference Documents Aligns                            PINGP does not credit self-mitigation of hot shorts in its safe and stable EC 23407 - B2 Methodology Evaluation analysis.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                      NEI 00-01 Section 3.0 Guidance 3.5.1.4       Criteria/Assumptions When both trains are in the same fire area outside of primary containment, all cables that do not meet the separation requirements of Section III.G.2 are assumed to fail in their worst case configuration.
Applicability                      Comments Applicable Alignment Statement                Alignment Basis                                                                  Reference Documents Aligns with Intent                 All unprotected cables, and equipment within the analysis area, that did EC 23407 - B2 Methodology Evaluation not meet the separation requirements of NFPA 805 Section 4.2.3 were EC 23408 - NEI 00-01 Revision 1 to identified and the appropriate failure modes were considered and                 Revision 2 Gap Analysis addressed through either deterministic or RI / PB methods.                       NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                  Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                     NEI 00-01 Section 3.0 Guidance 3.5.1.5    Criteria/Assumptions   The following guidance provides the NRC inspection focus from Bin 1 of RIS 2004-03 in order to identify any potential combinations of spurious operations with higher risk significance. Bin 1 failures should also be the focus of the analysis; however, NRC has indicated that other types of failures required by the regulations for analysis should not be disregarded even if in Bin 2 or 3. If Bin 1 changes in subsequent revisions of RIS 2004-03, the guidelines in the revised RIS should be followed.
Cable Failure Modes.
For multiconductor cables testing has demonstrated that conductor-to-conductor shorting within the same cable is the most common mode of failure. This is often referred to as "intra-cable shorting." It is reasonable to assume that given damage, more than one conductor-to-conductor short will occur in a given cable. A second primary mode of cable failure is conductor-to-conductor shorting between separate cables, commonly referred to as "inter-cable shorting." Inter-cable shorting is less likely than intra-cable shorting. Consistent with the current knowledge of fire-induced cable failures, the following configurations should be considered:
A. For any individual multiconductor cable (thermoset or thermoplastic), any and all potential spurious actuations that may result from intra-cable shorting, including any possible combination of conductors within the cable, may be postulated to occur concurrently regardless of number. However, as a practical matter, the number of combinations of potential hot shorts increases rapidly with the number of conductors within a given cable. For example, a multiconductor cable with three conductors (3C) has 3 possible combinations of two (including desired combinations), while a five conductor cable (5C) has 10 possible combinations of two (including desired combinations), and a seven conductor cable (7C) has 21 possible combinations of two (including desired combinations). To facilitate an inspection that considers most of the risk presented by postulated hot shorts within a multiconductor cable, inspectors should consider only a few (three or four) of the most critical postulated combinations.
B. For any thermoplastic cable, any and all potential spurious actuations that may result from intra-cable and inter-cable shorting with other thermoplastic cables, including any possible combination of conductors within or between the cables, may be postulated to occur concurrently regardless of number. (The consideration of thermoset cable inter-cable shorts is deferred pending additional research.)
C. For cases involving the potential damage of more than one multiconductor cable, a maximum of two cables should be assumed to be damaged concurrently. The spurious actuations should be evaluated as previously described. The consideration of more than two cables being damaged (and subsequent spurious actuations) is deferred pending additional research.
D. For cases involving direct current (DC) circuits, the potential spurious operation due to failures of the associated control cables (even if the spurious operation requires two concurrent hot shorts of the proper polarity, e.g., plus-to-plus and minus-to-minus) should be considered when the required source and target conductors are each located within the same multiconductor cable.
E. Instrumentation Circuits. Required instrumentation circuits are beyond the scope of this associated circuit approach and must meet the same requirements as required power and control circuits. There is one case where an instrument circuit could potentially be considered an associated circuit. If fire-induced damage of an instrument circuit could prevent operation (e.g., lockout permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                   Attachment B - NEI 04-02 Table B-2 necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly.
Likelihood of Undesired Consequences Determination of the potential consequence of the damaged associated circuits is based on the examination of specific NPP piping and instrumentation diagrams (P&IDs) and review of components that could prevent operation or cause maloperation such as flow diversions, loss of coolant, or other scenarios that could significantly impair the NPPs ability to achieve and maintain hot shutdown. When considering the potential consequence of such failures, the [analyst] should also consider the time at which the prevented operation or maloperation occurs. Failures that impede hot shutdown within the first hour of the fire tend to be most risk significant in a first-order evaluation. Consideration of cold-shutdown circuits is deferred pending additional research.
Applicability                     Comments Applicable Alignment Statement               Alignment Basis                                                                      Reference Documents Aligns                            For cable selection and circuit analysis purposes, PINGP did not EC 23407 - B2 Methodology Evaluation differentiate or pre-screen cables based upon cable type / insulation EC 23408 - NEI 00-01 Revision 1 to material (e.g., thermoset and thermoplastic cables). Additionally, where             Revision 2 Gap Analysis applicable, the guidance of RIS 2004-03 was considered and incorporated              NSCA (Genesis) Model into the NSCA (Genesis) model.                                                       EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                        Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                          NEI 00-01 Section 3.0 Guidance 3.5.2        Types of Circuit Failures Appendix R requires that nuclear power plants must be designed to prevent exposure fires from defeating the ability to achieve and maintain post-fire safe shutdown. Fire damage to circuits that provide control and power to equipment on the required safe shutdown path and any other equipment whose spurious operation/ maloperation could affect shutdown in each fire area must be evaluated for the effects of a fire in that fire area. Only one fire at a time is assumed to occur. The extent of fire damage is assumed to be limited by the boundaries of the fire area. Given this set of conditions, it must be assured that one redundant train of equipment capable of achieving hot shutdown is free of fire damage for fires in every plant location. To provide this assurance, Appendix R requires that equipment and circuits required for safe shutdown be free of fire damage and that these circuits be designed for the fire-induced effects of a hot short, short-to-ground, and open circuit. With respect to the electrical distribution system, the issue of breaker coordination must also be addressed.
This section will discuss specific examples of each of the following types of circuit failures:
                                       - Open circuit
                                       - Short-to-ground
                                       - Hot short.
Applicability                          Comments Applicable Alignment Statement                    Alignment Basis                                                                     Reference Documents Not Required                           Generic Guidance EC 23407 - B2 Methodology Evaluation EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                             Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                               NEI 00-01 Section 3.0 Guidance 3.5.2.1     Circuit Failures Due to an Open This section provides guidance for addressing the effects of an open circuit for safe shutdown equipment. An open circuit Circuit                         is a fire-induced break in a conductor resulting in the loss of circuit continuity. An open circuit will typically prevent the ability to control or power the affected equipment. An open circuit can also result in a change of state for normally energized equipment. For example, a loss of power to the main steam isolation valve (MSIV) solenoid valves [for BWRs]
due to an open circuit will result in the closure of the MSIV.
NOTE: The EPRI circuit failure testing indicated that open circuits are not likely to be the initial fire-induced circuit failure mode. Consideration of this may be helpful within the safe shutdown analysis. Consider the following consequences in the safe shutdown circuit analysis when determining the effects of open circuits:
                                            - Loss of electrical continuity may occur within a conductor resulting in de-energizing the circuit and causing a loss of power to, or control of, the required safe shutdown equipment.
                                            - In selected cases, a loss of electrical continuity may result in loss of power to an interlocked relay or other device. This loss of power may change the state of the equipment. Evaluate this to determine if equipment fails safe.
                                            - Open circuit on a high voltage (e.g., 4.16 kV) ammeter current transformer (CT) circuit may result in secondary damage.
Applicability                               Comments Applicable Alignment Statement                         Alignment Basis                                                                      Reference Documents Aligns                                      Open circuits were considered for all unprotected cables within the fire EC 23407 - B2 Methodology Evaluation area of concern, in keeping with the guidance of this section.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSPM concluded that by using the industry accepted screening criteria;               NSCA (Genesis) Model fire-induced damage to current transformer (CT) circuits would not                   EC 20612 - Non Power / NSCA Operations adversely impact PINGPs ability to achieve and maintain safe and stable             Review for NFPA 805 conditions.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.5.2.2     Circuit Failures Due to a Short-to- This section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment. A Ground                              short-to-ground is a fire-induced breakdown of a cable insulation system resulting in the potential on the conductor being applied to ground potential. A short-to-ground can cause a loss of power to or control of required safe shutdown equipment. In addition, a short-to-ground may affect other equipment in the electrical power distribution system in the cases where proper coordination does not exist. Consider the following consequences in the post-fire safe shutdown analysis when determining the effects of circuit failures related to shorts-to-ground:
                                                - A short to ground in a power or a control circuit may result in tripping one or more isolation devices (i.e. breaker/fuse) and causing a loss of power to or control of required safe shutdown equipment.
                                                - In the case of certain energized equipment such as HVAC dampers, a loss of control power may result in loss of power to an interlocked relay or other device that may cause one or more spurious operations.
Applicability                                   Comments Applicable Alignment Statement                             Alignment Basis                                                                    Reference Documents Aligns                                          PINGP has considered the effects of shorts-to-ground in alignment with EC 23407 - B2 Methodology Evaluation the guidance given in this section to maintain safe and stable conditions.
EC 23408 - NEI 00-01 Revision 1 to Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                                 Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                   NEI 00-01 Section 3.0 Guidance 3.5.2.3     Circuit Failures Due to a Hot Short This section provides guidance for analyzing the effects of a hot short on circuits for required safe shutdown equipment. A hot short is defined as a fire-induced insulation breakdown between conductors of the same cable, a different cable or some other external source resulting in an undesired impressed voltage on a specific conductor. The potential effect of the undesired impressed voltage would be to cause equipment to operate or fail to operate in an undesired manner.
Consider the following specific circuit failures related to hot shorts as part of the post-fire safe shutdown analysis:
                                                - A hot short between an energized conductor and a de-energized conductor within the same cable may cause a spurious actuation of equipment. The spuriously actuated device (e.g., relay) may be interlocked with another circuit that causes the spurious actuation of other equipment. This type of hot short is called a conductor-to-conductor hot short or an internal hot short.
                                                - A hot short between any external energized source such as an energized conductor from another cable (thermoplastic cables only) and a de-energized conductor may also cause a spurious actuation of equipment. This is called a cable-to-cable hot short or an external hot short. Cable-to-cable hot shorts between thermoset cables are not postulated to occur pending additional research.
Applicability                                   Comments Applicable Alignment Statement                             Alignment Basis                                                                      Reference Documents Aligns                                          For safe and stable, PINGP utilizes the hot probe method to determine the effects of hot shorts on the circuits during the initial circuit analysis        EC 23407 - B2 Methodology Evaluation activity. The hot probe method is not dependent upon the source (inter,              EC 23408 - NEI 00-01 Revision 1 to intra or power supply).                                                              Revision 2 Gap Analysis NSCA (Genesis) Model EC 20612 - Non Power / NSCA Operations Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                               Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                                  NEI 00-01 Section 3.0 Guidance 3.5.2.4     Circuit Failures Due to Inadequate The evaluation of associated circuits of a common power source consists of verifying proper coordination between the Circuit Coordination               supply breaker/fuse and the load breakers/fuses for power sources that are required for safe shutdown. The concern is that, for fire damage to a single power cable, lack of coordination between the supply breaker/fuse and the load breakers/fuses can result in the loss of power to a safe shutdown power source that is required to provide power to safe shutdown equipment.
A coordination study should demonstrate the coordination status for each required common power source. For coordination to exist, the time-current curves for the breakers, fuses and/or protective relaying must demonstrate that a fault on the load circuits is isolated before tripping the upstream breaker that supplies the bus. Furthermore, the available short circuit current on the load circuit must be considered to ensure that coordination is demonstrated at the maximum fault level.
The methodology for identifying potential associated circuits of a common power source and evaluating circuit coordination cases of associated circuits on a single circuit fault basis is as follows:
                                               - Identify the power sources required to supply power to safe shutdown equipment.
                                               - For each power source, identify the breaker/fuse ratings, types, trip settings and coordination characteristics for the incoming source breaker supplying the bus and the breakers/fuses feeding the loads supplied by the bus.
                                               - For each power source, demonstrate proper circuit coordination using acceptable industry methods.
                                               - For power sources not properly coordinated, tabulate by fire area the routing of cables whose breaker/fuse is not properly coordinated with the supply breaker/fuse. Evaluate the potential for disabling power to the bus in each of the fire areas in which the associated circuit cables of concern are routed and the power source is required for safe shutdown.
Prepare a list of the following information for each fire area:
                                               - Cables of concern.
                                               - Affected common power source and its path.
                                               - Raceway in which the cable is enclosed.
                                               - Sequence of the raceway in the cable route.
                                               - Fire zone/area in which the raceway is located.
For fire zones/areas in which the power source is disabled, the effects are mitigated by appropriate methods.
                                               - Develop analyzed safe shutdown circuit dispositions for the associated circuit of concern cables routed in an area of the same path as required by the power source. Evaluate adequate separation based upon the criteria in Appendix R, NRC staff guidance, and plant licensing bases.
Applicability                                  Comments Applicable PINGP Page B Revision 1

Northern States Power - Minnesota                                                                             Attachment B - NEI 04-02 Table B-2 Alignment Statement               Alignment Basis                                                              Reference Documents Aligns                            Original installation and subsequent PINGP processes have followed EC 23407 - B2 Methodology Evaluation proper design standards for circuit protection. Engineering manuals, short EC 23408 - NEI 00-01 Revision 1 to circuit evaluations and loading evaluations pertaining to proper circuit     Revision 2 Gap Analysis protection and coordination are in place to maintain circuit protection and  NSCA (Genesis) Model coordination where required.                                                 EC 20612 - Non Power / NSCA Operations Review for NFPA 805 Loss of DC control power has been analyzed in the NSCA (Genesis) model, including common power supply and common enclosure considerations resulting from this fire-induced phenomenon.
PINGP Page B Revision 1

Northern States Power - Minnesota                                                                                           Attachment B - NEI 04-02 Table B-2 NEI 00-01 Ref                              NEI 00-01 Section 3.0 Guidance 3.5.2.5     Circuit Failures Due to Common The common enclosure associated circuit concern deals with the possibility of causing secondary failures due to fire Enclosure Concerns             damage to a circuit either whose isolation device fails to isolate the cable fault or protect the faulted cable from reaching its ignition temperature, or the fire somehow propagates along the cable into adjoining fire areas.
The electrical circuit design for most plants provides proper circuit protection in the form of circuit breakers, fuses and other devices that are designed to isolate cable faults before ignition temperature is reached. Adequate electrical circuit protection and cable sizing are included as part of the original plant electrical design maintained as part of the design change process. Proper protection can be verified by review of as-built drawings and change documentation. Review the fire rated barrier and penetration designs that preclude the propagation of fire from one fire area to the next to demonstrate that adequate measures are in place to alleviate fire propagation concerns.
Applicability                              Comments Applicable Alignment Statement                        Alignment Basis                                                                    Reference Documents Aligns                                     Original installation and subsequent PINGP processes have followed EC 23407 - B2 Methodology Evaluation proper design standards for circuit protection. An analysis of the latest EC 23408 - NEI 00-01 Revision 1 to coordination studies was performed in support of section 3.5.2.4 of the B-         Revision 2 Gap Analysis 2 Table, and can be found in section 3.5.2.4. Credited plant physical              NSCA (Genesis) Model barriers pertaining to the defined NFPA-805 fire areas were verified as            EC 20612 - Non Power / NSCA Operations part of the compartment analysis.                                                  Review for NFPA 805 PINGP Page B Revision 1

Northern States Power - Minnesota    Attachment C - NEI 04-02 Table B-3 Fire Area Transition C. NEI 04-02 Table B Fire Area Transition 315 Pages Attached PINGP                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1            1                 Containment Unit 1 Fire Area 1 includes Fire Area(s):
68       Containment Annulus Unit 1 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.3.4 - Deterministic Approach Performance Goal                           Method of Accomplishment                                                       Comments Decay Heat Removal (HSB)                 Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Note: Unit 1, one SG could be affected but the redundant SG remains available.
PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition If Unit 1 Process Monitoring Train A is not available, use Train B Process Monitoring                                                                                                  VFDR-001-01 RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control   Unit 1 - Charging System (Train A) or Safety Injection System (Train B)            VFDR001-01-02 Unit 2 - Charging System (Train A) or Safety Injection System (Train B)            VFDR001-01-03 PINGP                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Reactivity Control                          Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST.
Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST.
Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC23621, Fire Risk Evaluation, Fire Area 01, Unit 1 Containment, Rev. 1, March 2014 Licensing Actions Appendix R Exemption, Containment, RCP oil collection system not in strict compliance (III.O criteria), Units 1 and 2, Fire Areas 1 and 71 Reference Attachment K - Existing Licensing Action Transition for details Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   FPEE 2011-003, Fire Protection Engineering Evaluation of Appendix R Compliance with Section III.G.2.D Since Containment Annulus Pre-Action Sprinkler System PA-3, PA-4, PA-6, and PA-7 May Not Actuate Summary     The purpose of this evaluation is to justify the treatment of the containment annulus in the same way the containment is treated in 10 CFR 50 Appendix R. Revision 1 to this FPEE evaluates the functional requirements for the existing pre-action fire suppression systems inside the containment annulus. FA 68 and 72 are in compliance with Appendix R, Section III.G.2.d, because redundant trains of equipment required for safe shutdown are separated by greater than 20 feet free of intervening combustibles. Although the Annulus is not inside the containment pressure boundary, it is inside the Reactor Containment Building and it qualifies to be treated like an area inside containment because access to the area is restricted in the same way access is restricted to containment during power operation. Reference 4.15 supports this position that the annulus is inside the Reactor Containment Building. Since FA 68 and FA 72 can be treated like areas inside containment, the partial area fire detection and automatic fire suppression in the Annulus do not need to be credited to meet the requirements of Appendix R, Section III.G.2. In addition, the functional requirements and surveillances required to ensure operability are not required for the cable tray sprinkler systems in the annulus of either unit, FA 68 and FA 72.
EEEE Title   97FP02-DOC-01 R0, RCP Lube Oil Compliance Review, 97FP02-DOC-01 R0 Add 1 App R RCP LO Sys Compliance Review Summary     The purpose of this compliance review is to evaluate the as-built Reactor Coolant Pump (RCP) Lube Oil Collection System (LOCS) at PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Prairie Island Nuclear Generating Plant (PINGP) with respect to the licensing and design basis commitments relative to the requirements of 10 CFR 50, Section 111.0, "Reactor Coolant Pump Lube Oil Collection Systems". Based on the installation of a metal shroud around the oil lift pump and piping, the RCP lube oil collection system at Prairie Island for Units 1 and 2 would adequately collect oil from postulated pressurized and unpressurized leak sites.
Variances from Deterministic Requirements (VFDR)
VFDR-001-1-01           This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of LOOP 1L-433, Pressurizer Level Cold Calibration Instrument and LOOP 1L-426-RP, Pressurizer Level Red Channel. This could result in the loss of the ability to observe adequate RCS Inventory.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3.4.b, due to lack of separation between redundant trains of Pressurizer Level Indication.
Components and Cables:
Pressurizer Level Cold Calibration Instrument, LOOP 1L-433 (1CF-31)
Pressurizer Level Red Channel, LOOP 1L-426RP (1CR-36)
Compliant Case:
One train of Pressurizer Level Indication (LOOP 1L-433) should remain unaffected by a fire in this area.
Disposition             Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes risk is low for a fire to cause concurrent damage to redundant Pressurizer Level Indication.
This VFDR has been evaluated and it was determined to meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-001-1-02           This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31245 (11 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX)) and CV-31335 (11 RCP Seal Injection). This could cause a loss of all RCP seal cooling to 11 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3.4.b, due to lack of separation between redundant trains of RCP seal cooling.
PINGP                                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Components and Cables:
11 REAC CLNT PMP SL WTR OUTL ISOL ,CV-31335 ( 1C-1080, 1C-1076, 1C-1075) 11 RCP TBHX CC, CV-31245 (1C-2163, 1C-2178, 1C-2179, 1C-2180, 1C-4641, 1C-4643)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.
Disposition          Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-001-1-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31246 (12 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX) and CV-31336 (12 RCP Seal Injection). This could cause a loss of all RCP seal cooling to 12 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3.4.b, due to lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
12 RCP seal injection outlet valve, CV-31336 (1C-1081, 1C-1082, 1C-1086) 12 RCP TBHX CC, CV-31246 (1C-2162, 1C-2174, 1C-2175, 1C-2176, 1C-4640, 1C-4642)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.
Disposition          Recovery Action:
No recovery actions credited.
Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
PINGP                                                                                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                         Required?
Category           ID           Type                                                                    Notes Area                                                     S L E R            D 1          Detection          10, 20,     Ionization       N N N Y N 29, 32 Suppression        -           -                -   -   -    -    -
Feature            1CV-        RES              N   N   N    Y    N     Raceway 1CV-T42I is wrapped with a radiant energy shield T42I 68         Detection          21          Ionization       N   N   N    Y    N Suppression        PA-3        Pre-Action       N   N   N    N    N     This suppression system is in the Annulus.
Suppression        PA-4        Pre-Action       N   N   N    N    N     This suppression system is in the Annulus.
Feature            -           -                -   -   -    -    -
1          Feature            N/A         Lube Oil         N   Y   N    N    N Collection System Hose Station                                    N   N   N    Y    N Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There are automatic fire suppression systems in the Annulus portion of the fire area. Water will drain via grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 1 now includes the Unit 1 Annulus, which was Fire Area 68 prior to the transition to NFPA 805.
PINGP                                                                                                                                       Page C Revision 1

Northern States Power - Minnesota                                                       Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1            2                 Ventilation Fan Room Unit 1 & 2 Fire Area 2 includes Fire Area(s):
76       Vent and Fan Room Unit 2 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                    Comments Decay Heat Removal (HSB)                  Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG PINGP                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE-12-001, CA-01314253-01, VFD-63 & VFD-64 Summary          The purpose of this evaluation is to assess VFD-63 and VFD-64, located on the 755ft elevation of the Auxiliary Building in Fire Area 2 and Fire Area 76, respectively. Exposure fires in Fire Area 8, Fire Area 2, and Fire Area 76 would not be expected to cause failure of the 6 inch diameter 14 gauge steel duct pipe between the fire damper in the 1ft x 2ft steel enclosure and G-wall. The duct pipes are securely attached with bolts to both sides of the steel enclosures. The construction of the steel enclosures and duct pipes, along with method of attachment, are capable of withstanding the impact of postulated exposure fires to which they could be exposed. Fire Area 8, Fire Area 2, and Fire Area 76 are in compliance with Appendix R since all required safe shutdown functions are available from the control room, with manual actions following C37.9 AOP1 and C37.9 AOP2 credited in Fire Area 2 to establish temporary Control Room and Relay Room HVAC. As such, fires in Fire Area 8, Fire Area 2, and Fire Area 76 that spread through G-wall due to failure of 6 inch diameter 14 gauge steel pipe between G-wall and VFD-63 and VFD-64 will not impact safe shutdown capability.
EEEE Title       CA-01311057-01, Fire Doors 146/181 and 147/273 Summary          The purpose of this evaluation is to assess two pairs of fire doors in series, Fire Doors 181/146 and 147/273. Each door in the series pairs has a 1-1/2hr fire rating, providing 3-hr fire rated protection for the barriers in which they are located. Each pair of doors in series is on opposite ends of an airlock. The door pairs are required for steam exclusion and High Energy Line Break (HELB), along with Appendix R, necessitating that the pair of doors can both open at the same time. As such, the doors are not provided with positive latching mechanisms. The doors swing into Fire Area 61A from Fire Area 2 and Fire Area 76. A fire in Fire Area 61A will not spread into Fire Area 2 or Fire Area 76 even though the doors are not provided with positive latching because any increase in pressure due to a fire in Fire Area 61A will push the doors back onto their door stops, preventing them from opening. Fire Area 61A is in compliance with Appendix R since all required safe shutdown functions are available from the control room. As such, fire spreading through the doors due to postulated fires in either Fire Area 2 or Fire Area 76 will not impact on fire safe shutdown capability.
EEEE Title       FPEE 01086132-01, Condition/Fire Protection Evaluation Adequacy of the fire boundary between Fire Area 76 (Vent and Fan Room, Unit 2, 755' Auxiliary Building) and Fire Area 92 (Water Chiller Room, Unit 2, 755' Auxiliary Building) without an installed three-hour fire damper PINGP                                                                                                                                        Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Summary           The purpose of this evaluation is to address the adequacy of the fire boundary between Fire Area 76 (Vent and Fan Room, Unit 2, 755' Auxiliary Building) and Fire Area 92 (Water Chiller Room, Unit 2, 755' Auxiliary Building) without an installed three-hour fire damper in a duct transversing the barrier. Although the duct work is not in a fire-tested configuration, the construction of the duct itself provides a one-hour measure of fire protection. Additionally, a lack of combustibles and ignition sources in the vicinity of the duct, as well as control of transient combustibles, minimizes the risk of fire. Should a fire occur, area-wide detection would quickly alert operators to the presence of products of combustion. The existing duct configuration (without damper) provides adequate protection from a fire in Fire Area 76 propagating into Fire Area 92.
EEEE Title         AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary           This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                            Required?
Category            ID          Type                                                                      Notes Area                                                       S L E           R     D 2          Detection            30, 108    Ionization        N N Y Y               N Suppression          -          Deluge            N N N N               N Filter system Feature              -          -                 -   -    -    -       -
76         Detection            53         Ionization        N N N Y               N Suppression          -          Deluge            N N N N               N Filter system Feature              -          -                 -   -    -    -       -
Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water from all sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing PINGP                                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                                Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1           3                 Water Chiller Room Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                               Comments Decay Heat Removal (HSB)                  Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Reactivity Control               Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                    Page C Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                             Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area       Category          ID             Type                                                                 Notes S L E R D 3             Detection        31           Ionization          N N N N N Suppression      -            -                   -   -   -   -    -
Feature          -            -                   -   -   -   -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                               Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1, 2         4                 Fuel Handling Area Fire Area 4 includes Fire Area(s):
39       Radwaste Building 40       Maintenance Storage Shed 61A      Aux Building Hatch Area 62       Spent Fuel Pool Area 67       Resin Disposal Building 93       Drum Storage/Low Level Rad Waste Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                           Method of Accomplishment                                             Comments Decay Heat Removal (HSB)                  Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                    Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (1R) supplying Electrical Distribution Trains A or B Vital Auxiliaries                          Unit 2 - Offsite Power (2RY) supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       CA-01244458-02, Fire Doors 94 & 95 Summary          The purpose of this evaluation is to assess the unrated penetrations through the transoms and the unrated 1/4-in checker steel plates and tray/conduit penetrations above Doors 94 and 95 for impact on the fire area boundaries separating Fire Areas 73 and 58 from Fire Area 4.
This evaluation also assesses the adequacy of the assemblies to provide adequate protection for the 3-hour barrier in which they are located.
The bases for this conclusion include the following: Postulated fires north of Unit 1 Door 95 and Unit 2 Door 94 would not adversely impact on redundant safe shutdown capability in Fire Area 58 and Fire Area 73 based on approved exemption requests for lack of automatic suppression that rely on enclosing Division B safe shutdown cable in one hour rated fire barriers, enclosing Division A safe shutdown cable trays in the vicinity of MCCs and at specified coordinates in one hour rated fire barriers, low combustible loading, automatic detection, and fire brigade response. Postulated fire spread south through the unrated penetrations and 1/4-in checker steel plate from Fire Area 58 or Fire Area 73 to Fire Area 4 will not impact on safe shutdown capability since the only cables of concern for safe shutdown in the event of a fire in Fire Area 4 are 1CT-1, 16408-1, and 15407-3. These cables provide offsite power from the CT transformer to Bus 15 and Bus 16 and run from FA 4 to FA 58/73. The 1R transformer remains available to provide offsite power to Bus 15 and Bus 16 in these areas. Since these cables are also routed in Fire Areas 58 and 73, Doors 95 and 94 do not separate redundant trains of safe shutdown equipment. A minimum of 50% of the combustible loading is associated with Kerite cables in the overhead trays that pass through the unrated penetration seals in the 1/4-in checker steel plate. Kerite cable is of thermoset construction and will not result in a fire without an external fire source. Trash receptacle and transient combustible fires that also involve the racks of plastic rolls and material in the metal enclosed cabinets south of Unit 1 Door 95 or the 8.5% hydrogen cylinders south of Unit 2 Door 94 could generate enough energy to ignite the cables in the cable trays. Flame propagation along thermoset cables is about 3mm per second or 3-1/2ft per hour. Due to the swing of Unit 1 Door 95 and Unit 2 Door 94 into the corridor portions of Fire Area 4, the trash receptacle and transient combustible fire would be at least 4ft away from the unrated penetrations and 1/4-in checker steel plate, with a burn time of upwards of one hour required before a cable tray fire would impact on the barrier. Automatic detection in the corridors on both sides of Unit 1 Door 95 and Unit 2 Door 94 would actuate early in the fire. Detection alarms would result in prompt response by the fire brigade. Hose stations are available on both sides of Unit 1 Door 95 and Unit 2 Door 94 for fire PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition fighting purposes. Fire brigade response would be effective in controlling and extinguishing postulated fires prior to the fire spreading through the unrated penetrations and impacting on fire safe shutdown capability on the north sides of Unit 1 Door 95 and Unit 2 Door
: 94. The main open area of Fire Area 4 extends up to the 755ft elevation. The minimal continuity of intervening combustibles (although some combustible materials may be present in the intervening space) combined with the open area above the location of combustible materials in this location effectively ensures that a fire in one corridor of Fire Area 4 will not spread across the open area and back into the opposite corridor. As such, a fire in one corridor in Fire Area 4 will not result in a simultaneous fire in the opposite corridor, and the unsealed penetrations and 1/4-in checker steel plates above Unit 1 Door 95 and Unit 2 Door 94 will not be challenged by the same fire simultaneously.
EEEE Title     CA-01311057-01, Fire Doors 146/181 and 147/273 Summary        The purpose of this evaluation is to assess two pairs of fire doors in series, Fire Doors 181/146 and 147/273. Each door in the series pairs has a 1-1/2hr fire rating, providing 3-hr fire rated protection for the barriers in which they are located. Each pair of doors in series is on opposite ends of an airlock. The door pairs are required for steam exclusion and High Energy Line Break (HELB), along with Appendix R, necessitating that the pair of doors can both open at the same time. As such, the doors are not provided with positive latching mechanisms. The doors swing into Fire Area 61A from Fire Area 2 and Fire Area 76. A fire in Fire Area 61A will not spread into Fire Area 2 or Fire Area 76 even though the doors are not provided with positive latching because any increase in pressure due to a fire in Fire Area 61A will push the doors back onto their door stops, preventing them from opening. Fire Area 61A is in compliance with Appendix R since all required safe shutdown functions are available from the control room. As such, fire spreading through the doors due to postulated fires in either Fire Area 2 or Fire Area 76 will not impact on fire safe shutdown capability.
EEEE Title     FPEE 01121594-01, Basis for the use of (2) 1 1/2 Hour Rated Fire Doors in a (3) Hour Fire Rated Barrier Summary        The purpose of this evaluation is to address the adequacy of Class B (1.5 hour) fire doors in Appendix R-required fire barriers. This evaluation, through the use of a bounding condition, finds that the lesser-rated doors, where used in PINGP, are acceptable given the combustible loading and available suppression systems of the areas.
EEEE Title     FPEE-11-049, NFPA 80, 1968 Code Compliance Deviations Summary        The purpose of this analysis is to document the review of required fire doors in F5 Appendix K fire barriers for compliance with the requirements of National Fire Protection Association (NFPA) 80 -1968, Standard for Fire Doors and Windows (Code of Record). Six deviations have been justified as acceptable; therefore, no further action is necessary. Eight deviations require additional actions to resolve the noncompliance associated with use of gates not doors in required fire barriers, insulation attached to the inside of a required door, access openings through three doors, four doors for which a fire rating could not be determined (two of which include transoms), the qualification of frames in fire door assemblies, transoms with penetrations above two rated doors, doors that would not close under airflow, and two sets of door combinations without positive latching. Each item is being tracked in the corrective action program.
EEEE Title     FPEE-12-005, CA-01311402-03, Fire Doors 136 & 139 Summary        The purpose of this analysis is to document the review of required fire doors in F5 Appendix K fire barriers for compliance with the requirements of National Fire Protection Association (NFPA) 80 -1968, Standard for Fire Doors and Windows (Code of Record). Six deviations have been justified as acceptable; therefore, no further action is necessary. Eight deviations require additional actions to resolve the noncompliance associated with use of gates not doors in required fire barriers, insulation attached to the inside of a required door, access openings through three doors, four doors for which a fire rating could not be determined (two of which include transoms), the qualification of frames in fire door assemblies, transoms with penetrations above two rated doors, doors that would not close under airflow, and two sets of door combinations without positive latching. Each item is being tracked in the corrective action program.
PINGP                                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                        Required?
Category          ID            Type                                                          Notes Area                                                   S L E R D 4         Detection          8, 30,      Ionization      N N Y N N 33 Suppression        SWP-1       Wet Pipe        N    N  N    N   N  Stairwell Feature                -              -        -     -  -    -   -
39        Detection          34, 81      Ionization,     N    N  N    N   N Thermal, Smoke Suppression        SWP-1       Wet Pipe        N    N  N    N   N  Stairwell System Feature                -              -        -     -  -    -   -
40        Detection          -           -               -    -  -    -   -
Suppression        -           -               -    -  -    -   -
Feature            -           -               -    -  -    -   -
61A       Detection          30          Ionization      N    N  N    N   N Detection          53          Ionization      N    N  N    N   N Suppression        -           -               -    -  -    -   -
Feature            -           -               -    -  -    -   -
62        Detection          30          Ionization      N    N  N    N   N Suppression        -           -               -    -  -    -   -
Feature            -           -               -    -  -    -   -
67        Detection          34          Ionization,     N    N  N    N   N Smoke Detection          81          Ionization      N    N  N    N   N Suppression        SWP-1       Wet Pipe        N    N  N    N   N  Stairwell System Feature            -           -               -    -  -    -   -
93        Detection          104         Thermal,        N    N  N    N   N Flame Suppression        DM-7        Deluge          N    N  N    N   N Feature            -           -               -    -  -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                        Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria There is an automatic fire suppression system in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                            Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1, 2         8                 Turbine Building Fire Area 8 includes Fire Area(s):
9        Maintenance Shops 14       Working Material Lunch Room 21       Unit 1 4.16 KV Normal Switchgear, (Bus 13, 14) 23       Unit 2 4.16 KV Normal Switchgear (Bus 23, 24) 27       Water Conditioning Equpiment Area 69       Turbine Building Ground Floor & Mezzanine Floors Unit 1 70       Turbine Building Ground Floor & Mezzanine Floors Unit 2 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                             Method of Accomplishment                          Comments Hot:
Decay Heat Removal (HSB)                                                                     VFDR-008-1-01 Unit 1 - 11 TDAFW Pump to 11 SG Unit 2 - 21 MDAFW Pump to 21 SG PINGP                                                                                              Page C Revision 1

Northern States Power - Minnesota                                                                 Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-427) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Unit 1 - Charging System (Train A)
Inventory and Pressure Control   Unit 2 - Charging System (Train A)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject Reactivity Control               borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Unit 1 - D5 supplying Electrical Distribution Train A from Bus 25 via 4KV bus cross-Vital Auxiliaries                connect breakers (BKR-15-8, BKR-25-17)
Unit 2 - D5 supplying Electrical Distribution Train A Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 PINGP                                                                                                                   Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title      FPEE-12-002; CA-01327430-1, Steam Line Pipe Penetrations without Penetration Seals PENF-1526, PENF-1528, PENF-1689, & PENF-1692 Summary         The purpose of this evaluation is to assess the impact on fire safe shutdown capability of four main steam line penetrations that are not provided with 3-hour fire rated penetration seals in G wall separating the Turbine Operating Deck from the 735ft elevation of the Auxiliary Building. The types, quantities, and continuity of combustible materials in Fire Area 60 or Fire Area 75 would not result in a sufficient heat release rate or fire to spread to, or spread through, the main steam line penetrations into Fire Area 8. The Turbine Stop Valves in Fire Area 8 are between 50ft and 70ft from the main steam line penetrations through G-wall. The only postulated fires that could result in damage to the Turbine Stop Valves and be large enough to potentially spread to the main steam line penetrations would involve either a turbine bearing oil fire or a catastrophic failure of the turbine oil system. The turbine bearings are protected by an automatically-actuated preaction sprinkler system that will respond to postulated turbine bearing oil fires and result in prompt fire brigade response. Postulated catastrophic turbine oil system failures could result in very severe fires; however, the area where oil piping runs and oil can spread are protected by automatic wet pipe sprinkler systems. Postulated turbine bearing oil fires and postulated catastrophic turbine oil system failure fires would result in significant heat release rates and smoke production; however, the large volume of the turbine building combined with the existing roof exhaust fans and smoke hatches that are fitted with automatic releases would release smoke and hot gas to the environment and delay the effects of such fires from banking down to the level of the main steam line penetrations located 50ft below the roof. The main steam line penetrations have limited annular gaps, 10in, for passage of fire effects to Fire Area 60 and Fire Area 75. There is very limited continuity of combustible materials in Fire Areas 60 and Fire Area 75 for fire to spread from Fire Area 8 to the vicinity of the MSlVs and solenoid valves. Postulated fires in Fire Area 8, Fire Area 60, and Fire Area 75 would not adversely impact redundant safe shutdown capability consisting of the Turbine Stop Valves in Fire Area 8 and the MSIVs and solenoid valves in Fire Area 60 and Fire Area 75.
EEEE Title      FPEE-12-001, CA-01314253-01, VFD-63 & VFD-64 Summary         The purpose of this evaluation is to assess VFD-63 and VFD-64, located on the 755ft elevation of the Auxiliary Building in Fire Area 2 and Fire Area 76, respectively. Exposure fires in Fire Area 8, Fire Area 2, and Fire Area 76 would not be expected to cause failure of the 6 inch diameter 14 gauge steel duct pipe between the fire damper in the 1ft x 2ft steel enclosure and G-wall. The duct pipes are securely attached with bolts to both sides of the steel enclosures. The construction of the steel enclosures and duct pipes, along with method of attachment, are capable of withstanding the impact of postulated exposure fires to which they could be exposed. Fire Area 8, Fire Area 2, and Fire Area 76 are in compliance with Appendix R since all required safe shutdown functions are available from the control room, with manual actions following C37.9 AOP1 and C37.9 AOP2 credited in Fire Area 2 to establish temporary Control Room and Relay Room HVAC. As such, fires in Fire Area 8, Fire Area 2, and Fire Area 76 that spread through G-wall due to failure of 6 inch diameter 14 gauge steel pipe between G-wall and VFD-63 and VFD-64 will not impact safe shutdown capability.
EEEE Title      FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary         The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-008-1-01            This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of the steam supply valve (CV-31998) to 11 Turbine Driven Aux Feedwater Pump or spurious closure of CV-31153, 11 TDAFWP recirculation and lube oil cooling. 12 MDAFWP is failed due to loss of power to BUS-16. This could prevent the credited 11 TDAFWP from providing AFW flow to the Steam Generators to support Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, lack of separation between redundant trains of Decay Heat Removal.
Components and Cables:
11 Turbine Driven AFW Pump Main Steam Supply, CV-31998 (1CA-1109, 1CA-1111, 1CA-1248) 11 Turbine Driven AFW Pump Recirc. Lube Oil CLG Control Valve, CV-31153 (1CA-1111, 1CA-1248)
Compliant Case:
The 11 TDAFWP (CV-31998 and CV-31153) should remain unaffected by a fire to provide AFW to 11 Steam Generator.
Disposition            Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #11 will re-wire and re-route cables 1CA-1109, 1CA-1111, and 1CA-1248 so a fire in FA 8 cannot cause spurious closure of CV-31998 and CV-31153.
This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.3 with a plant modification credited.
PINGP                                                                                                                                   Page C Revision 1

Northern States Power - Minnesota                                                          Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area             Category                  ID              Type                                            Notes S  L  E R D 8              Detection                   24, 49        Heat                 N  N Y N N Detection                   107           Heat, Smoke          N  N N N N         Smoke detector in Elevator Machine room Detection                   27            Ionization, Thermal. N  N   N    N   N Heat Detection                   107           Smoke                N  N   N    N   N  Smoke detector in Elevator Machine room Suppression                 PA-14         Pre-Action           N  N   Y    Y   N  Unit 1 Generator and Exciter Suppression                 PA-15         Pre-Action           N  N   Y    Y   N  Unit 2 Generator and Exciter Suppression                 WPS-9         Wet Pipe             N  N   Y    N   N  Protects Elevator Machine room and pit Suppression                 SWP-6         Wet Pipe             N  N   Y    N   N  Stairway System Feature                     -             -                    -  -   -    -    -
9              Detection                   27            Ionization, Thermal, N  N   N    N   N Heat Detection                   107           Smoke                N  N   N    N   N  Smoke detector in elevator Machine room Suppression                 SWP-6         Wet Pipe             N  N   N    N   N  Stairway System Feature                     -             -                    -  -   -    -   -
14             Detection                   15            Ionization           N  N   N    N   N Suppression                 WPS-25        Wet Pipe             N  N   N    N   N Feature                     -             -                    -  -   -    -   -
21             Detection                   84            Ionization           N  N   N    Y   N Suppression                 -             -                    -  -   -    -   -
Feature                     -             -                    -  -   -    -   -
23             Detection                   86            Ionization           N  N   N    Y   N Suppression                 -             -                    -  -   -    -   -
Feature                     -             -                    -  -   -    -   -
27             Detection                   4             Ionization           N  N   N    N   N Suppression                 SWP-6         Wet Pipe             N  N   N    N   N Feature                     -             -                    -  -   -    -   -
69             Detection                   3             Ionization           N  N   N    Y   N Detection                   4             Ionization, Heat,    N  N   N    Y   N Smoke Detection                   15            Ionization, Flame    N  N   N    Y   N Detection                   107           Heat, Smoke          N  N   N    Y   N  Smoke detector in elevator Machine room Suppression                 WPS-7         Wet Pipe             N  N   N    N   N Suppression                 WPS-8         Wet Pipe             N  N   N    Y   N Suppression                 WPS-9         Wet Pipe             N  N   N    N   N PINGP                                                                                                              Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Suppression                   WPS-18              Wet Pipe                  N     N    N    N   N Suppression                   DA-1                Deluge                    N     N    N    N   N Suppression                   DA-3                Deluge                    N     N    N    Y   N Suppression                   PA-14               Pre-Action                N     N    N    N   N Suppression                   SWP-3               Wet Pipe                  N     N    N    Y   N     Stairwell system Suppression                   SWP-5               Wet Pipe                  N     N    N    N   N     Stairwell system Feature                       -                   -                         -     -    -    -   -
70              Detection                      36               Ionization                   N     N    N    Y  N Detection                      37               Ionization, Heat, Smoke      N     N    N    Y  N Detection                      44               Ionization, Thermal          N     N    N    Y  N Suppression                    WPS-15           Wet Pipe                     N     N    N    N  N Suppression                    WPS-16           Wet Pipe                     N     N    N    Y  N Suppression                    WPS-17           Wet Pipe                     N     N    N    N  N Suppression                    WPS-21           Wet Pipe                     N     N    N    N  N Suppression                    DA-4             Deluge                       N     N    N    Y  N Suppression                    DA-5             Deluge                       N     N    N    N  N Suppression                    PA-15            Pre-Action                   N     N    N    N  N Suppression                    SWP-13           Wet Pipe                     N     N    N    N  N       Stairwell System Suppression                    SWP-14           Wet Pipe                     N     N    N    N  N       Stairwell System Feature                        -                -                            N     N    N    N  N Legend:
Required?
S         - Required for Chapter 4 Separation Criteria L         - Required for NRC-Approved Licensing Action E         - Required for Existing Engineering Equivalency Evaluation R         - Required for Risk Significance D         - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There are automatic fire suppression systems in the fire area. Safety related electrical equipment is mounted on pedestals above the floor level minimizing the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                       Page C Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1            10                Train A Event Monitoring Equipment Room Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                           Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 22 SG RCS Pressure Process Monitoring                       (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control           Unit 2 - Charging System (Train A) or Safety Injection (Train B)
PINGP                                                                                                                             Page C Revision 1

Northern States Power - Minnesota                                                                         Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control                    Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                     Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                  Notes S L E        R    D 10            Detection        26            Ionization        N N N N           N Suppression      -             -                 -   -    -   -    -
Feature          -             -                 -   -    -   -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1           11                Unit 1 Normal Switchgear & Control Rod Drive Room Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room or use Alternate Rod Insertion. Use Reactivity Control               Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                    Page C Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                             Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID              Type                                                               Notes S L E R D 11              Detection        87            Ionization          N N N N N Suppression      -             -                   -   -    -   -    -
Feature          -             -                   -   -    -   -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                   Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Unit          Fire Area        Description 1             12               OSC Room Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                                          Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Reactivity Control                      Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or PINGP                                                                                                                             Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                           Unit 1 - Offsite Power supplying Electrical Distribution Trains A and B Unit 2 - Offsite Power supplying Electrical Distribution Trains A and B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title         AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary            This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category          ID            Type                                      Notes S L E R D 12             Detection         25            Ionization         N N N N N Suppression       WPS-23,       Wet Pipe           N N N Y N 24 Feature           -             -                  -   -    -   -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                    Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria There are automatic fire suppression systems in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        13                Control Room Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Note: One train may be affected but the redundant train is likely to remain available.
Performance Goal                          Method of Accomplishment                                                          Comments Decay Heat Removal (HSB)                  Hot:                                                                              VFDR-013-1-03 VFDR-013-2-03 Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                        Note: Unit 1 and 2, one train of process monitoring could be affected but the     VFDR-013-1-05 redundant train remains available.                                                VFDR-013-2-05 RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp PINGP                                                                                                                              Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control            Unit 1 - Charging System (Train A) or Safety Injection (Train B)                    VFDR-013-1-02 Train A or B RCS Head Vents or Pressurizer Vents                                    VFDR-013-1-07 VFDR-013-1-02 Unit 2 - Charging System (Train A) or Safety Injection (Train B)                    VFDR-013-2-07 Train A or B RCS Head Vents or Pressurizer Vents Reactivity Control                        Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or         VFDR-013-1-01 Safety Injection Pump (Train B) to inject borated water from the RWST               VFDR-013-2-01 Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                         Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B, or D1       VFDR-013-0-01 Emergency Diesel Generator supplying Electrical Distribution Train A                VFDR-013-1-04 Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B, or D5       VFDR-013-1-06 Emergency Diesel Generators supplying Electrical Distribution Train A               VFDR-013-2-04 VFDR-013-2-06 Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 23605, Fire Risk Evaluation, Fire Area 13, Control Room, Rev. 1, March 2014.
Procedure F5 Appendix B, Control Room Evacuation (Fire), Rev. 45 Licensing Actions Appendix R Exemption, Control Room, Allowance for removal of fuses, Units 1 and 2, Fire Area 13 Reference Attachment K - Existing Licensing Action Transition for details Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary          This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
VFDR-013-0-01                This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Critera is not met for Vital Auxiliary Systems.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many Compliant Case:
Train A and Train B Cooling Water Strainers (CV-31652, CV-31653, CV-31654, CV-31655, MTR-111C-21, MTR-111C-22, MTR-121C-21 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition                Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix B.
Modification identified in Table S-2, Item #20 to correct fuse/breaker coordination on PNL-137.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification and recovery actions credited.
VFDR-013-1-01                This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Reactivity Control. This could cause a loss of Reactivity Control.
The Nuclear Safety Performance Criteria is not met for Reactivity Control.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.
Components and Cables:
Many PINGP                                                                                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Compliant Case:
The ability to maintain Reactivity Control should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment C) to manually trip Unit 1 Turbine at the Front Standard and close MV-32006 and MV-32010 (Attachment B).
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-1-02    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain RCS Inventory Control. This could cause a loss of Inventory Control.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Inventory and Pressure Control.
Components and Cables:
Many Compliant Case:
The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate Recovery Actions performed in F5 Appendix B [Reference 15] (Attachments A, B, E and F) to isolate Letdown, Excess Letdown, Head vents, Pressurizer vents, de-energize Sump B valves, de-energize the Containment Spray Pump, locally trip the Reactor Coolant Pumps at the Bus, and actions to re-align 12 Charging Pump suction to the RWST and restart a charging pump. Evaluate Recovery Actions to de-energize and manually close MV-32084 and MV-32085.
Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and plant modifications credited.
PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition VFDR-013-1-03    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Decay Heat Removal. This could cause a loss of Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.
Components and Cables:
Many Compliant Case:
The ability to maintain Decay Heat Removal should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment E) to ensure steam supply valve from 11 SG is open and (Attachment I) to manually start the 11 TDAFWP and align to 11 SG.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-1-04    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to support Post Fire Safe Shutdown. This could cause a loss of Cooling Water.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many Compliant Case:
The ability to maintain Vital Auxiliaries should remain available from the Control Room.
Disposition     Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #13 will ensure hot shorts on cables for CV-31505 which supplies cooling water to D1 Emergency Diesel Generator are isolated when the control switch is placed in local.
Modification identified in Table S-2, Item #14 will ensure the Diesel Driven Cooling Water Pumps remain available to provide cooling water to D1 Emergency Diesel Generator and AFW pumps.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-013-1-05    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Process Monitoring.
Steam Generator Level, Pressurizer Level, RCS Pressure, RCS Hot Leg and Cold Leg temperature, and Source Range Neutron Flux This represents a loss of Process Monitoring indication in the Control Room and would require abandonment of the Control Room and Alternate Shutdown.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Process Monitoring.
Compliant Case:
One train of Process Monitoring indication should remain available in the Control Room.
Disposition     Recovery Action Evaluate risk of recovery actions to locally read indication at Hot Shutdown Panels for RCS Pressure, Hot/Cold leg Temperature, Pressurizer Level, SG Level, and Source Range Neutron Flux.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-1-06    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of vital AC Power from Bus 15 and Bus 16. This could cause a loss of Vital AC Power.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power.
PINGP                                                                                                                            Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Components and Cables:
Many Compliant Case:
The ability to maintain Vital AC Power should remain available from the Control Room.
Dispostion      Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment F) to locally start D1 Emergency Diesel Generator and manually align to BUS 15 to restore Vital AC Power.
Modification identified in Table S-2, Item #34 will install a synchronization relay that will prevent non-synchronous parallels in all fire areas with exception to areas the gear is located in for the normal, alternate, and diesel generator source breakers for BUS 15, BUS 16, BUS 25, and BUS 26.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-013-1-07    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of the 11 Component Cooling Water Pumps.
Components and Cables:
Many Compliant Case:
Cooling to the RCP seals should remain unaffected by a fire in this area.
Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-013-2-01    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Reactivity Control. This could cause a loss of Reactivity Control.
PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition The Nuclear Safety Performance Criteria is not met for Reactivity Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.
Components and Cables:
Many Compliant Case:
The ability to maintain Reactivity Control should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment C) to manually trip Unit 2 Turbine at the Front Standard, and close steam valves MV-32021 and MV-32022, Attachment B.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-2-02    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain RCS Inventory Control. This could cause a loss of Inventory Control.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control.
Components and Cables:
Many Compliant Case:
The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate Recovery Actions performed in F5 Appendix B [Reference 15] (Attachments A, B, D and G) to isolateLetdown, Excess Letdown, Head vents, de-energize Sump B valves, de-energize the Containment Spray Pumps, locally trip the Reactor Coolant Pumps, and actions to re-align 22 Charging Pump suction to the RWST and restart a charging pump. Evaluate Recovery Actions to de-energize and manually close MV-32178 and MV-32179.
PINGP                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and plant modifications credited.
VFDR-013-2-03    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Decay Heat Removal. This could cause a loss of Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a Lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.
Components and Cables:
Many Compliant Case:
The ability to maintain Decay Heat Removal should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate Recovery Actions performed in F5 Appendix B (Attachment I) to manually start the 22 TDAFWP and align to 21 Steam Generator.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-2-04    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to support Post Fire Safe Shutdown. This could cause a loss of Cooling Water. The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Compliant Case:
The ability to maintain Vital Auxiliaries should remain available from the Control Room.
Disposition     Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #14 will ensure the Diesel Driven Cooling Water Pumps remain available to provide cooling water to D1 Emergency Diesel Generator and AFW pumps.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-013-2-05    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Process Monitoring.
Steam Generator Level, Pressurizer Level, RCS Pressure, RCS Hot Leg and Cold Leg temperature, and Source Range Neutron Flux This represents a loss of Process Monitoring IndicationProcess Monitoring indication in the Control Room and would require abandonment of the Control Room and Alternate Shutdown.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Process Monitoring.
Compliant Case:
One train of Process Monitoring indication should remain available in the Control Room.
Disposition     Recovery Action:
Evaluate risk of recovery actions to locally read indication at Hot Shutdown Panels for RCS Pressure, Hot/Cold leg Temperature, Pressurizer Level, SG Level, and Source Range Neutron Flux.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-013-2-06    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of vital AC Power from Bus 25 and Bus 26. This could cause a loss of Vital AC Power.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between PINGP                                                                                                                            Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power.
Components and Cables:
Many Compliant Case:
The ability to maintain Vital AC Power should remain available from the Control Room.
Disposition     Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment G) to locally start D5 Emergency Diesel Generator and manually align to BUS 25 to restore Vital AC Power.
Modification identified in Table S-2, Item #34 will install a synchronization relay that will prevent non-synchronous parallels in all fire areas with exception to areas the gear is located in for the normal, alternate, bus tie, and diesel generator source breakers for BUS 15, BUS 16, BUS 25, and BUS 26.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-013-2-07    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of the 21 Component Cooling Water Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliaries Components and Cables:
None Compliant Case:
Cooling to the RCP seals should remain unaffected by a fire in this area.
Disposition     Recovery Action(s):
None Modification identified in Table S-1, Item #1 has installed new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a modification credited.
PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category         ID           Type                                     Notes S L E R           D 13           Detection        57           Ionization        N N N Y N              Area wide and under raised floor Suppression      -            -                 -   -   -    -   -
Hose Station     -            -                 N N N Y N Legend:
Required?
S   - Required for Chapter 4 Separation Criteria L   - Required for NRC-Approved Licensing Action E   - Required for Existing Engineering Equivalency Evaluation R   - Required for Risk Significance D   - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                         Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1            14              Working Material, Lunch Room Note: Fire Area 14 is now combined into Fire Area 8.
PINGP                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit           Fire Area        Description 1              15               Access Control Regulatory Basis Unit 1    4.2.3.2 - Deterministic Approach Unit 2    4.2.3.2 - Deterministic Approach Performance Goal                         Method of Accomplishment                                                            Comments Decay Heat Removal (HSB)                 Hot:
Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 22 SG Process Monitoring                       RCS Pressure (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Generator Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control           Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                       Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                        Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B PINGP                                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary          This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area   Category           ID            Type                                    Notes S L E R D 15          Detection          17            Ionization         N N N N N Suppression        WPS-20        Wet Pipe           N N N N N Feature            -             -                  -  -   -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                       Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit           Fire Area        Description 2              16               Train B Event Monitoring Equipment Room Regulatory Basis Unit 1    4.2.3.2 - Deterministic Approach Unit 2    4.2.3.2 - Deterministic Approach Performance Goal                         Method of Accomplishment                                                            Comments Decay Heat Removal (HSB)                 Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG Process Monitoring                       Train B could be affected, the following Train A Process Monitoring is credited RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Generator Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Inventory and Pressure Control           Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                       Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                        Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B PINGP                                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area   Category         ID            Type                                       Notes S L E R D 16          Detection        50            Ionization          N N N N N Suppression      -             -                   -   -    -   -    -
Feature          -             -                   -   -    -   -    -
Legend:
Required?
S   - Required for Chapter 4 Separation Criteria L   - Required for NRC-Approved Licensing Action E   - Required for Existing Engineering Equivalency Evaluation R   - Required for Risk Significance D   - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            17                Unit 2 Normal Switchgear Room & Control Rod Drive Room Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                          Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to SG-11 or 12 Unit 2 - 21 MDAFW Pump to SG-21 or SG-22 Process Monitoring*                     RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level PINGP                                                                                                             Page C Revision 1

Northern States Power - Minnesota                                                                         Attachment C - Table B-3 Fire Area Transition (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control       Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                   Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room or use Alternate Rod Insertion. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                    Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area     Category         ID            Type                                    Notes S L E R D 17            Detection        88            Ionization         N N N N N Suppression      -             -                  -   -   -    -   -
Feature          -             -                  -   -   -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        18                Relay and Cable Spreading Room Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Note: One train may be affected but the redundant train is likely to remain available.
Performance Goal                          Method of Accomplishment                                                          Comments Decay Heat Removal (HSB)                  Hot:                                                                              VFDR-018-1-03 VFDR-018-2-03 Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                        Note: Unit 1 and 2, one train of process monitoring could be affected but the     VFDR-018-1-05 redundant train remains available.                                                VFDR-018-2-05 RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp PINGP                                                                                                                              Page C Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control           Unit 1 - Charging System (Train A) or Safety Injection (Train B)                    VFDR-018-0-02 Train A or B RCS Head Vents or Pressurizer Vents.                                   VFDR-018-1-07 Unit 2 - Charging System (Train A) or Safety Injection (Train B)                    VFDR-018-2-02 Train A or B RCS Head Vents or Pressurizer Vents.                                   VFDR-018-2-07 Reactivity Control                       Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety           VFDR-018-1-01 Injection Pump (Train B) to inject borated water from the RWST                      VFDR-018-2-01 Vital Auxiliaries                        Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B, or D1       VFDR-018-0-01 Emergency Diesel Generator supplying Electrical Distribution Train A                VFDR-018-1-04 Unit 2 - Offsite Power or supplying Electrical Distribution Trains A or B, or D5    VFDR-018-1-06 Emergency Diesel Generators supplying Electrical Distribution Train A               VFDR-018-2-04 VFDR-018-2-06 Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 23606, Fire Risk Evaluation, Fire Area 18, Relay & Cable Spreading Room, Unit 1 & 2, Rev 1, March 2014.
Procedure F5 Appendix B, Control Room Evacuation (Fire), Rev. 45 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Variances from Deterministic Requirements (VFDR)
VFDR-018-0-01         This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliary Systems.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many Compliant Case:
Train A and Train B Cooling Water Strainers (CV-31652, CV-31653, CV-31654, CV-31655, MTR-111C-21, MTR-111C-22, MTR-121C-21 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition           Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix B.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-137.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-018-1-01         This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Reactivity Control. This could cause a loss of Reactivity Control.
The Nuclear Safety Performance Criteria is not met for Reactivity Control.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.
Components and Cables:
Many PINGP                                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Compliant Case:
The ability to maintain Reactivity Control should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment C) to manually trip Unit 1 Turbine at the Front Standard and close MV-32006 and MV-32010 (Attachment B).
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-018-1-02       This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain RCS Inventory Control. This could cause a loss of Inventory Control.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Inventory and Pressure Control.
Components and Cables:
Many Compliant Case:
The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate Recovery Actions performed in F5 Appendix B (Attachments A, B, E, and F) to isolate Letdown, de-energize Sump B valves, de-energize the Containment Spray Pump, locally trip the Reactor Coolant and actions to re-align 12 Charging Pump suction to the RWST and restart a charging pump. Evaluate Recovery Actions to de-energize and manually close MV-32084 and MV-32085.
Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.
Modification identified in Table S-2, Item #27 will provide a means to isolate Pressurizer PORVs, Excess Letdown, Head Vents, Pressurizer Vents, and Pressurizer Heaters prior to room evacuation.
PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and plant modifications credited.
VFDR-018-1-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Decay Heat Removal. This could cause a loss of Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.
Components and Cables:
Many Compliant Case:
The ability to maintain Decay Heat Removal should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment I) to manually to start the 11 TDAFWP and align to 11 SG.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-018-1-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to support Post Fire Safe Shutdown. This could cause a loss of Cooling Water.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many Compliant Case:
The ability to maintain Vital Auxiliaries should remain available from the Control Room.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #13 will ensure hot shorts on cables for CV-31505 which supplies cooling water to D1 Emergency Diesel Generator are isolated when the control switch is placed in local.
Modification identified in Table S-2, Item #14 will ensure the Diesel Driven Cooling Water Pumps remain available to provide cooling water to D1 Emergency Diesel Generator and AFW pumps.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-018-1-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Process Monitoring.
Steam Generator Level, Pressurizer Level, RCS Pressure, RCS Hot Leg and Cold Leg temperature, and Source Range Neutron Flux This represents a loss of Process Monitoring IndicationProcess Monitoring indication in the Control Room and would require abandonment of the Control Room and Alternate Shutdown.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Process Monitoring.
Compliant Case:
One train of Process Monitoring indication should remain available in the Control Room.
Disposition        Recovery Action Evaluate risk of recovery actions to locally read indication at Hot Shutdown Panels for RCS Pressure, Hot/Cold leg Temperature, Pressurizer Level, SG Level, and Source Range Neutron Flux.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-018-1-06       This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of vital AC Power from Bus 15 and Bus 16. This could cause a loss of Vital AC Power.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power.
PINGP                                                                                                                            Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Components and Cables:
Many Compliant Case:
The ability to maintain Vital AC Power should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment F) to locally start D1 Emergency Diesel Generator and manually align to BUS 15 to restore Vital AC Power.
Modification identified in Table S-2, Item #34 will install a synchronization relay that will prevent non-synchronous parallels in all fire areas with exception to areas the gear is located in for the normal, alternate, bus tie, and diesel generator source breakers for BUS 15, BUS 16, BUS 25 and BUS 26.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-018-1-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of the 11 and 12 Component Cooling Water Pumps. This could impact the ability to cool the RCP seals. The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
Components and Cables:
None Compliant Case:
Cooling to the RCP seals should remain unaffected by a fire in this area.
Disposition         Recovery Action(s):
None Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-018-2-01        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Reactivity Control. This could cause a loss of Reactivity Control.
PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition The Nuclear Safety Performance Criteria is not met for Reactivity Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.
Components and Cables:
Many Compliant Case:
The ability to maintain Reactivity Control should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment B and C) to manually trip Unit 2 Turbine at the Front Standard, and close steam valves MV-32021 and MV-32022.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-018-2-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain RCS Inventory Control. This could cause a loss of Inventory Control.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control.
Components and Cables:
Many Compliant Case:
The ability to maintain RCS Inventory and Pressure Control should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate Recovery Actions performed in F5 Appendix B (Attachments A, B, D, and G) to isolate Letdown, de-energize Sump B Valves, de-energize Containment Spray Pump, locally trip the Reactor Coolant Pumps and actions to re-align 22 Charging PINGP                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Pump suction to the RWST and restart a charging pump. Evaluate Recovery Actions to de-energize and manually close MV-32178 and MV-32179.
Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.
Modification identified in Table S-2, Item #27 will provide a means to isolate Pressurizer PORVs, Excess Letdown, Head Vents, Pressurizer Vents, and Pressurizer Heaters prior to room evacuation.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and plant modifications credited.
VFDR-018-2-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to maintain Decay Heat Removal. This could cause a loss of Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a Lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal.
Components and Cables:
Many Compliant Case:
The ability to maintain Decay Heat Removal should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate Recovery Actions performed in procedure F5 Appendix B (Attachment D) to manually start the 22 TDAFWP and align to 21 Steam Generator.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-018-2-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of equipment required to support Post Fire Safe Shutdown. This could cause a loss of Cooling Water. The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems.
Components and Cables:
Many Compliant Case:
The ability to maintain Vital Auxiliaries should remain available from the Control Room.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #14 will ensure the Diesel Driven Cooling Water Pumps remain available to provide cooling water to D1 Emergency Diesel Generator and AFW pumps.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-018-2-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Process Monitoring.
Steam Generator Level, Pressurizer Level, RCS Pressure, RCS Hot Leg and Cold Leg temperature, and Source Range Neutron Flux This represents a loss of Process Monitoring IndicationProcess Monitoring indication in the Control Room and would require abandonment of the Control Room and Alternate Shutdown.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Process Monitoring.
Compliant Case:
One train of Process Monitoring indication should remain available in the Control Room.
Disposition        Recovery Action:
Evaluate risk of recovery actions to locally read indication at Hot Shutdown Panels for RCS Pressure, Hot/Cold leg Temperature, Pressurizer Level, SG Level, and Source Range Neutron Flux.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
PINGP                                                                                                                            Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition VFDR-018-2-06        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of vital AC Power from Bus 25 and Bus 26. This could cause a loss of Vital AC Power.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power.
Components and Cables:
Many Compliant Case:
The ability to maintain Vital AC Power should remain available from the Control Room.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions performed in procedure F5 Appendix B (Attachment G) to locally start D5 Emergency Diesel Generator and manually align to BUS 25 to restore Vital AC Power.
Modification identified in Table S-2, Item #34 will install a synchronization relay that will prevent non-synchronous parallels in all fire areas with exception to areas the gear is located in for the normal, alternate, bus tie, and diesel generator source breakers for BUS 15, BUS 16, BUS 25, and BUS 26 This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-18-2-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of the 21 and 22 Component Cooling Water Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxilliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3. due to a lack of separation between redundant equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxilliaries.
Components and Cables:
None Compliant Case:
Cooling to the RCP seals should remain unaffected by a fire in this area.
PINGP                                                                                                                                  Page C Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Disposition              Recovery Action (s):
None Modification identified in Table S-1, Item #1 has installed new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a modification credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area     Category           ID           Type                                        Notes S L E R           D 18            Detection          12, 14       Ionization          N N N Y N Detection                       VEWSD               N N N Y N               Modification identified in Table S-2, Item #5 will install a Very Early Warning Smoke Detection System (Incipient)
Suppression                     CO2                 N N N Y N               Total Flooding Hose Station       -            -                   N N N Y N Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic CO2 fire suppression system is installed in the fire area. The CO2 system was designed and installed in accordance with NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 1972. Chapter 1123. states Some of the more important types of hazards and equipment that carbon dioxide systems may satisfactorily protect include:
: 1. Gaseous and liquid flammable materials.
: 2. Electrical hazards such as transformers, oil switches and circuit breakers, and rotating equipment.
: 3. Engines utilizing gasoline and other flammable fuels.
: 4. Ordinary combustibles such as paper, wood and textiles.
: 5. Hazardous solids.
Fire Area 18 contains predominantly cable insulation, plastic, and ordinary combustibles, therefore, no damage to equipment relied on to achieve the Nuclear Safety Performance Criteria goals from the discharge of the system is expected.
PINGP                                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Firefighting water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit           Fire Area        Description 1              20               Unit 1, 4.16 kV Safeguards Switchgear (Bus 16)
Regulatory Basis Unit 1    4.2.4.2 - Performance Based Approach Unit 2    4.2.3.2 - Deterministic Approach Performance Goal                           Method of Accomplishment                                                           Comments Decay Heat Removal (HSB)                   Hot:                                                                                    See VFDR020-1-07 Unit 1 - 11 TDAFW Pump to 11 SG Unit 2 - 21 MDAFW Pump to 21 SG Process Monitoring                         RCS Pressure                                                                            See VFDR020-1-03 (LOOP 1P-709) U1 Loop A RCS Wide Range Press                                            See VFDR020-1-05 (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-427) Pressurizer Level (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Inventory and Pressure Control             Unit 1 - Charging System (Train A)                                                      See VFDR020-1-02 Unit 2 - Charging System (Train A)
Reactivity Control                         Unit 1 - Trip reactor from the Control Room. Use Charging Pump to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump to inject borated water from the RWST Vital Auxiliaries                          Unit 1 - D1 supplying Electrical Distribution Train A                                   See VFDR020-1-01 Unit 2 - Offsite Power (2RY) supplying Electrical Distribution Train A PINGP                                                                                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit 1 - CC Train A Unit 2 - CC Train A CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 23581, Fire Risk Evaluation, Fire Area 20, Unit 1, 4.16kV Safeguards Switchgear (Bus 16), Rev. 1, March 2014 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
VFDR-020-1-01            This Variance From Deterministic Requirements (VFDR) is due to fire damage that could cause a loss of power to Bus 16, a loss of power from the offsite power sources (CT11 and 1RY), and spurious operation of BKR 15-3 which could prevent Bus 15 from being powered by BKR 15-2 (D1 Emergency Diesel Generator).
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due to lack of separation between redundant trains of safeguards AC power.
Components and Cables:
Bus 15 Source from 1R XFMR, BKR-15-3 (1C-419)
Bus 16 4.16KV Switchgear, Bus 16 (Many)
Compliant Case:
BKR-15-3, 1RY source to BUS-15, should remain available from the control room.
Disposition             Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                                 Page C Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #6 will re-wire cable 1C-419 so that fire damage to cable 1C-419 will not spuriously operate, spurious opening, BKR 15-3.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-020-1-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of power to PNL 113 which powers CV-31198, charging line to 11 Regenerative Heat Exchanger, which would cause CV-31198 to fail open. If CV-31198 failed open, it could cause a flow diversion away from the RCP seals. A fire in this area could also affect train B Safeguards Bus 16 power supply to the 12 Component Cooling Water Pump, could impact cable 1C-419 which could impact the Train A Safeguards Bus 15 power supply to the 11 Component cooling Water Pump which provides cooling to the RCP TBHX. Loss of all seal cooling to the RCP seals could lead to increased leakage from the RCP seals.
The Nuclear Safety Performance Criteria is not met for Inventory Control.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due to lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
Instrument Bus III (Blue) Panel 113, PNL-113 (1CX-99)
Bus 16 4.16KV Switchgear, Bus 16 (Many)
Bus 15 Source from 1R XFMR, BKR-15-3 (1C-419)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #6 will re-route cable 1CX-99 out of Fire Area 20 and into Fire Area 58 so PNL 113 will remain available to support safe shutdown.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-020-1-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of power to Train B Bus 16 and loss of power from 13 Inverter to Train A PNL 113 which powers control room indication for 1N51 Source Range Monitor, 1T-450A and 1T-450B for RCS Hot and Cold Leg Temperature Indication. This could cause a loss of indication for Source Range Neutron Flux Monitoring, and RCS Hot and Cold Leg Temperature Indication in the Control Room.
PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due to lack of separation between redundant trains of process monitoring.
Components and Cables:
Instrument Bus III (Blue) Panel 113, PNL-113 (1CX-99)
Instrument Bus IV (Yellow), PNL-114 (1CY-99)
Compliant Case:
Process Monitoring indication for RCS Hot and Cold Leg, and Source Range should remain available from the Control Room.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #6 will re-route cable 1CX-99 out of Fire Area 20 and into 58 so PNL 113 will remain available to support Safe Shutdown Process Monitoring.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-020-1-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of power to Train B Bus 16 and loss of power from 11 Inverter to Train A PNL 111 which powers control room indication for 1L-487, 11 SG Wide Range Level indication. This could cause a loss of indication for 11 Steam Generator Level Indication in the Control Room.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due to lack of separation between redundant trains of process monitoring.
Components and Cables:
Instrument Bus II (White) Panel 111, PNL-111 (1CW-99)
Instrument Bus I (Red) Panel 112, PNL-112 (1CR-99)
Compliant Case:
Process Monitoring indication for 11 Steam Generator Level Indication should remain available from the Control Room.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                               Page C Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #6 will re-route cable 1CW-99 out of Fire Area 20 and into 58 so PNL 111 will remain available to support Safe Shutdown Process Monitoring.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-020-1-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            3, 12 MDAFWP, and loss of power to BUS-121 which powers MCC-1A2 which powers MV-32381 and MV-32382. A loss of power to MV-32381 and MV-32382 would prevent remote closure of the valves and the inability to isolate spurious AFW flow.
This could eventually lead to an over-fill of the Steam Generator which would challenge the Decay Heat Removal Nuclear Safety Performance Criteria.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due to lack of separation between redundant trains of decay heat removal due to over-fill of steam generator.
Components and Cables:
12 MDAFW Pump, MTR 16-3 (16403-A, 16403-C, 16403-D, 16403-E)
Bus 121 480V Switchgear, BUS-121 (16404-1, 16404-A, 16404-C)
Compliant Case:
MTR-16-3, 12 MDAFWP should not spuriously start and over-fill the 11 and 12 Steam Generators.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of over-filling the Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
PINGP                                                                                                                              Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area     Category         ID            Type                                      Notes S L E        R    D 20            Detection        11            Ionization        N N N Y           N Suppression      -             -                 -   -    -   -    -
Hose Station     -             -                 N N N Y           N Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1            21              Unit 1, 4.16 kV Normal Switchgear (Bus 13, 14)
Note: Fire Area 21 is now combined into Fire Area 8.
PINGP                                                                                             Page C Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit           Fire Area       Description 1              22              480 V Safeguards Switchgear (Bus 121)
Regulatory Basis Unit 1    4.2.4.2 - Performance Based Approach Unit 2    4.2.4.2 - Performance Based Approach Performance Goal                        Method of Accomplishment                                                         Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW Pump to 11 SG Unit 2 - 21 MDAFW Pump to 21 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Charging System (Train A)
Unit 2 - Charging System (Train A)
Reactivity Control                      Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Vital Auxiliaries                       Unit 1 - Offsite Power supplying Electrical Distribution Train A                 VFDR-22-0-01 Unit 2 - Offsite Power supplying Electrical Distribution Train A PINGP                                                                                                                            Page C Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 EC 23582, Fire Risk Evaluation, Fire Area 22, 480V Safeguards Switchgear (Bus 121), Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
VFDR-022-0-01                   This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 cooling water strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect that function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3, due a lack of separation between redundant trains of cooling water strainers.
Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CB-374) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CB-374) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CB-374) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CB-374) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CB-374) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CB-374) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CB-374) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CB-374)
AC Distribution Panel 136, PNL-136 (1CB-374)
PINGP                                                                                                                                   Page C Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Compliant Case:
Train A, 11 Cooling Water Strainer (CV-31652 and MTR-111C-21) should remain unaffected by a fire in this area.
Disposition             Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area     Category         ID            Type                                          Notes S L E         R      D 22            Detection        43            Ionization         N N N Y             N Suppression      -             -                  -    -   -   -      -
Hose Station     -             -                  N N N Y             N Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition Fire Area Comments None PINGP                                                   Page C Revision 1

Northern States Power - Minnesota                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            23              Unit 2, 4.16 KV Normal Switchgear (Bus 23, 24)
Note: Fire Area 23 is now combined into Fire Area 8.
PINGP                                                                                             Page C Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        24                Oil Storage Area Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                         Method of Accomplishment                                             Comments Decay Heat Removal (HSB)                 Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                       RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level PINGP                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                         Attachment C - Table B-3 Fire Area Transition (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control       Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                   Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                    Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category         ID            Type                                     Notes S L E R D 24           Detection        4             Ionization,        N N N N N Flame, Heat Suppression      DA-2          Deluge             N N N N N Feature          -             -                  -   -   -     -  -
Legend:
Required?
S   - Required for Chapter 4 Separation Criteria L   - Required for NRC-Approved Licensing Action E   - Required for Existing Engineering Equivalency Evaluation R   - Required for Risk Significance D   - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There is an automatic fire suppression system in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C Revision 1

Northern States Power - Minnesota                                                                         Attachment C - Table B-3 Fire Area Transition Unit          Fire Area       Description 1             25              Diesel Generator 1 Room Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                       Method of Accomplishment                                                         Comments Decay Heat Removal (HSB)               Hot:
Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 21 SG or 22 SG Process Monitoring                     RCS Pressure (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control         Unit 1 - Safety Injection (Train B)
Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Reactivity Control                     Unit 1 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B)
PINGP                                                                                                                           Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                          Unit 1 - Offsite Power supplying Electrical Distribution Train B                      VFDR-025-0-01 Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train B Unit 2 - CC Train A or B CL Train B Reference Documents EC 23583, Fire Risk Evaluation, Fire Area 25, Diesel Generator 1 Room, Rev. 1, March 2014.
Safe/Genesis V 4.0.2 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-025-0-01                   This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious close of BKR 15-2 and parallel D1 to Bus 15 out of phase. This could cause a lockout of Bus 15 which powers PNL 136 which powers the Cooling Water Strainers backwash central control panel for 11, 12, 21, and 22 CL Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
PINGP                                                                                                                                    Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers. This is a separation issue for Vital Auxiliaries.
Components and Cables:
BKR 15-2, (15402-G, 15402-K, 1CA-1140, 1CA-1142)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition            Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 82.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category           ID          Type                                         Notes S L E           R    D 25           Detection          82          Ionization,         N N Y N              Y Heat, Flame Suppression        PA-1        Pre-Action          N N Y Y              N Feature            -           -                   -    -   -    -      -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will exit through the floor drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
PINGP                                                                                                                                        Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1            26                Diesel Generator 2 Room Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                             Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level PINGP                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control       Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                   Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                    Unit 1 - Offsite Power supplying Electrical Distribution Trains A and B Unit 2 - Offsite Power supplying Electrical Distribution Trains A and B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area   Category            ID           Type                                       Notes S L E R D 26          Detection           6            Ionization, Heat, N N N N N Flame Suppression         PA-1         Pre-Action         N N N Y N Feature             -            -                  -    -    -    -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will exit through the floor drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                        Page C Revision 1

Northern States Power - Minnesota                                 Attachment C - Table B-3 Fire Area Transition Unit         Fire Area          Description 1            27                 Water Conditioning Equipment Area Note: Fire Area 27 is now combined into Fire Area 8.
PINGP                                                                                   Page C Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1,2          28                Transformers Fire Area 28 includes Fire Area(s):
28a      Main Transformer (Unit 1) 28b      Main Transformer (Unit 2) 28c      1R Transformer 28d      1M Transformer 28e      2M Transformer 28f      2RX/Y Transformer Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                         Method of Accomplishment                                             Comments Decay Heat Removal (HSB)                 Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                       RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp PINGP                                                                                                                Page C Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control       Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                   Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                    Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train A or B Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A or B Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                          Page C Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                                     Required?
Category             ID         Type                                                 Notes Area                                                                S     L     E   R      D 28a       Detection            58         HAD                     N      N N        Y     N Suppression          DM-1       Deluge                  N      N N        N N        Manual Actuation Feature              -          -                       -      -    -     -     -
28b       Detection            60         HAD                     N      N N        Y     N Suppression          DM-5       Deluge                  N      N N        N N        Manual actuation Feature              -          -                       -      -    -     -     -
28c       Detection            62         HAD                     N      N N        Y     N Suppression          DM-3       Deluge                  N      N N        N N        Manual activation Feature              -          -                       -      -    -     -     -
28d       Detection            59         HAD                     N      N N        Y     N Suppression          DM-2       Deluge                  N      N N        N N        Manual activation Feature                 -                  -              -     -     -    -      -
28e       Detection            61         HAD                     N      N N        Y     N Suppression          DM-4       Deluge                  N      N N        N N        Manual activation Feature              -          -                       -      -    -     -     -
28f       Detection            96         HAD                     N      N N        Y     N Suppression          DM-6       Deluge                  N      N N        N N Feature              -                                  -      -    -     -     -
Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria A fire suppression system is installed in the fire area. The area around each transformer is diked, with drainage to nearby pits. The only electrical equipment is the transformers, which are mounted on pedestals. However, the main source of fire, and consequently either manual suppression system actuation or hose stream application, is the transformers and water would be applied to the fire. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
PINGP                                                                                                                                       Page C Revision 1

Northern States Power - Minnesota                           Attachment C - Table B-3 Fire Area Transition Fire Area Comments Note: Fire Area 28 a - f is now combined into Fire Area 28.
PINGP                                                                            Page C- 100- Revision 1

Northern States Power - Minnesota                                                        Attachment C - Table B-3 Fire Area Transition Unit         Fire Area        Description 1                   29        Administration Building Elect & Piping Room #1 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                        Method of Accomplishment                                       Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW Pump to 21 SG or 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level PINGP                                                                                                         Page C- 101- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control             Unit 1 - Charging System (Train A) or Safety Injection System (Train B)
Unit 2 - Charging System (Train A) or Safety Injection System (Train B)
Reactivity Control                         Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                          Unit 1 - Offsite Power supplying Electrical Distribution Trains A and B               VFDR-029-0-01 Unit 2 - Offsite Power supplying Electrical Distribution Trains A and B Unit 1 - CC Train B Unit 2 - CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23584, Fire Risk Evaluation, Fire Area 29, Administration Building Elect & Piping Room # 1, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-029-0-01                   This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which PINGP                                                                                                                                  Page C- 102- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pump.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers.
Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CA-529) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CA-529) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CA-529) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CA-529) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CA-529) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CA-529) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CA-529) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CA-529)
Motor Control Center 1AB, Bus 1, (111C-4, 111C-5)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 4.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
PINGP                                                                                                                            Page C- 103- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category         ID           Type                                      Notes S L E R           D 29           Detection        4            Ionization          N N Y N N Suppression      -            -                   -   -   -    -   -
Feature          -            -                   -   -   -    -   -
Legend:
Required?
S   - Required for Chapter 4 Separation Criteria L   - Required for NRC-Approved Licensing Action E   - Required for Existing Engineering Equivalency Evaluation R   - Required for Risk Significance D   - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 29 extends over Fire Area 24.
PINGP                                                                                                                                    Page C- 104- Revision 1

Northern States Power - Minnesota                                                        Attachment C - Table B-3 Fire Area Transition Unit         Fire Area        Description 2            30               Administration Building Elect & Piping Room #2 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                        Method of Accomplishment                                       Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW Pump to 11 SG or 12 SG Unit 2 - 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level PINGP                                                                                                         Page C- 105- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control             Unit 1 - Charging System (Train A)
Unit 2 - Charging System (Train A)
Reactivity Control                         Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Vital Auxiliaries                          Unit 1 - Offsite Power supplying Electrical Distribution Trains A and B               VFDR-030-0-01 Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Trains A and B Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 EC 23585, Fire Risk Evaluation, Fire Area 30, Administration Building Elect & Piping Room # 2, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-030-0-01                   This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pump.
PINGP                                                                                                                                  Page C- 106- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers.
Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CB-370) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CB-370) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CB-370) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CB-370) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CB-370) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CB-370) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CB-370) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CB-370)
AC Distribution Panel 136, PNL-136 (1CB-370)
Motor Control Center 1AB Bus 2, MCC-1AB2 (221C-4)
Compliant Case:
Train A, 11 Cooling Water Strainer (CV-31652 and MTR-111C-21) should remain unaffected by a fire in this area.
Disposition               Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 4.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
PINGP                                                                                                                          Page C- 107- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category            ID           Type                                     Notes S L E R           D 30           Detection           40           Ionization        N N Y N N Suppression         -            -                 -   -    -   -   -
Feature             -            -                 -   -    -   -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 30 extends over the Oil Storage Room (FA 24)
PINGP                                                                                                                                    Page C- 108- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit          Fire Area       Description 1, 2          31              A Train Hot Shutdown Panel & Air Compressor/Aux. Feedwater Pump Room Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                         Method of Accomplishment                                                            Comments Decay Heat Removal (HSB)                 Hot:                                                                                VFDR-031-0-03 Unit 1 - 11 TDAFW Pump to 11 SG                                                     VFDR-031-1-02 Unit 2 - 21 MDAFW Pump to 21 SG                                                     VFDR-031-2-01 VFDR-031-2-01 Process Monitoring                       RCS Pressure                                                                        VFDR-031-2-02 (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-427) Pressurizer Level (LOOP 2L-427) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Inventory and Pressure Control           Unit 1 - Charging System (Train A)
Unit 2 - Charging System (Train A)
Reactivity Control                       Unit 1 - Trip reactor from the Control Room. Use Charging to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Vital Auxiliaries                        Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A and portions VFDR-031-1-03 PINGP                                                                                                                             Page C- 109- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition of Train B                                                                            VFDR-031-2-03 Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A and portions of Train B Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 EC 23586, Fire Risk Evaluation, Fire Area 31, A Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE-12-004, CA-01313808-01, AFW Pump Room Ducts without Fire Dampers Summary          The purpose of this evaluation is to assess the impact on fire safe shutdown capability of four exhaust ducts and one supply duct that are not provided with 3-hour rated fire dampers in the boundaries of the Auxiliary Feedwater Pump Rooms, Fire Areas 31 and 32. The lack of fire dampers in the ductwork penetrations of the common barrier between the AFW Pump Rooms and the 480V Normal Switchgear Rooms, and between the 480V Normal Switchgear Rooms to the Turbine Buildings, has no impact on safe shutdown capability and is acceptable as is.
EEEE Title       CA-01040686 (Attachment), NFPA 72E Requirement for Non-Restorable Heat Detectors Evaluation Summary          The 2006 NFPA 72E, 1974 edition, code compliance review identified that nonrestorable spot type thermal detectors were not being tested in accordance with the code. Based on the type of fire expected in these fire areas, the generation of smoke will exceed the generation of heat during the incipient stage of a fire. Therefore, the area smoke detection will provide the early warning of a fire. The heat detectors are not credited in the USAR by reference to F5 Appendix K, but will provide a secondary level of automatic detection.
Based on the lack of credit given to the heat detectors, the requirements of NFPA 72E are not mandatory and the functional testing for the rate of rise function is adequate. The additional testing of the fixed temperature function through destructive testing at a nationally recognized laboratory is not cost justified for the minor benefit. The lack of meeting the full code requirement for non-restorable heat detection testing will not have adverse effect on safe shutdown for any of the affected fire areas.
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the PINGP                                                                                                                                    Page C- 110- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-031-0-01                This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function and loss of power to PNL-136 due to lack of coordination. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect that function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to the lack of separation between redundant trains of cooling water strainers.
Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CB-370, 1CB-374) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CB-370, 1CB-374) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CB-370, 1CB-374) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CB-370, 1CB-374) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CB-370, 1CB-374) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CB-370, 1CB-374) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CB-370, 1CB-374) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CB-370, 1CB-374)
AC Distribution Panel 136, PNL-136 (1CB-370, 1CB-374)
Motor Control Center 1AB Bus 2, MCC-1AB2 (221C-4)
Compliant Case:
Train A, 11 Cooling Water Strainer (CV-31652 and MTR-111C-21) should remain unaffected by a fire.
Disposition                  Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 2.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-031-0-03                This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of both trains of AFW.
An automatic wet pipe suppression system is installed in the general area of the AFW pump room, but does not provide full area wide coverage in the mezzanine area above the battery rooms. There are no fixed fire initiators in the mezzanine area PINGP                                                                                                                                Page C- 111- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition above the battery rooms. There are some Fire PRA cables in the mezzanine area.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of a full area suppression system with credit given to deterministic requirements of section 4.2.3.3 b and c.
Components and Cables:
None Compliant Case:
The automatic wet pipe fire suppression system in the AFW pump room should provide full area wide coverage to meet deterministic requirements.
Disposition               Recovery Action(s):
No recovery actions credited.
This fire area meets the Performance Based requirements of NFPA 805, Section 4.2.4 and only credits the automatic fire suppression system in the general area where it is installed.
VFDR-031-1-01             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 11 TDAFWP (Train A) discharge control valves MV-32238 and MV-32239 and damage 12 MDAFWP (Train B). A fire at the Train A Hot Shutdown Panel could cause spurious closure of MV-32238 or MV-32239 which would prevent 11 TDAFWP from supplying Aux Feedwater to 11 or 12 Steam Generator.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of Aux Feedwater.
Components and Cables:
11 AFW to 11 SG MV, MV-32238 (1CA-115) 11 AFW to 12 SG MV, MV-32239 (1CA-116)
Compliant Case:
Train A, 11 TDAFWP, along with valves MV-32238, and MV-32239 should remain unaffected by a fire to provide AFW to a SG for Decay Heat Removal.
PINGP                                                                                                                         Page C- 112- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #1 will relocate control switches CS-51003 and CS-51005 so that 11 TDAFWP discharge valves are not affected by a fire in FA 31.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-031-1-02             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            3, 12 MDAFWP, and loss of power to MCC-1A2 which powers MV-32381 and MV-32382. A loss of power to MV-32381 and MV-32382 would prevent remote closure of the valves and the inability to isolate spurious AFW flow. This could eventually lead to an over-fill of the Steam Generator which would challenge the Decay Heat Removal Nuclear Safety Performance Criteria.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of Aux Feedwater.
Components and Cables:
12 MDAFW Pump, MTR 16-3 (16403-C, 1CB-31, 1CB-920)
Motor Control Center 1A Bus 2, MCC 1A2 (121E-1)
Compliant Case:
The 12 MDAFWP should not spuriously start and over-fill the 11 and 12 Steam Generators.
Disposition               Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of over-filling the Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-031-1-03             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to Bus 16 and damage to power cables that could over-heat and cause secondary fires. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
PINGP                                                                                                                          Page C- 113- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.
Components and Cables:
12 MDAFW Pump Breaker, BKR-16-3 (16403-1, 16403-C, 1CB-30, 1CB-920)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure protection of the over-current trip function of 4kV breakers and preclude secondary ignition of cables in other fire areas.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-031-2-01             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 21 MDAFWP (Train A) discharge control valves and damage to 22 TDAFWP (Train B). A fire at the Train A Hot Shutdown Panel could cause spurious closure of MV-32383 or MV-32384 which would prevent 21 MDAFWP from supplying Aux Feedwater to 21 or 22 Steam Generator. A fire at MCC-2A1 could cause spurious operation of MV-32383, MV-32384, MV-32026, or MV-32336. The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of Aux Feedwater.
Components and Cables:
Motor Control Center 2A Bus 1, MCC 2A1 (211E-1) 21 MDAFW Pump to 21 SG, MV-32383 (2A1-5, 2A1-5A, 2CA-115, 2CA-116, 2CA-65) 21 MDAFW Pump to 22 SG, MV-32384 (2A1-5A, 2A1-6, 2CA-116, 2CA-117, 2CA-66) 21 MDAFW Pump suction from CL, MV-32026 (2A1-2, 2A1-2A, 2A1-4A, 2CA-30) 21 MDAFW Pump suction from CST, MV-32336 (2A1-4A, 2CA-30)
Compliant Case:
Train A, 21 MDAFWP, along with valves MV-32383, MV-32384, MV-32026, and MV-32336 should remain unaffected by a fire to provide AFW to a Steam Generator for Decay Heat Removal.
PINGP                                                                                                                                Page C- 114- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #2 will ensure that 21 MDAFWP (Train A) remains available to provide AFW to 21 Steam Generator.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a modification credited.
VFDR-031-2-02             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of Pressurizer Level Indication, Steam Generator Level Indication, and Source Range Flux Monitoring from the Control Room. Loss of Pressurizer and Steam Generator Level Indication in the Control Room could lead to SG over-fill and loss of Decay Heat Removal function.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains pressurizer level indication.
Components and Cables:
Pressurizer Level Indication, LOOP 2L-433 (1C-5118, 1CA-1106, 2CF-207, 2CF-214)
Instrument Bus II (White) Panel 211, PNL-211 (2CW-1)
Instrument Bus III (Blue) Panel 213, PNL-213 (2CX-1)
Interruptable Panel 217, PNL-217 (2AC1-5, 2CV-35, 2CV-6)
Motor Control Center 2AC Bus 2, MCC-2AC2 (221F-1)
Instrument Bus I (RED) Panel 212, PNL-212 (2CR-1)
Instrument Bus IV (YELLOW) Panel 214, PNL-214 (2CY-1)
Compliant Case:
Train A Process Monitoring indication should remain available from the Control Room without the need for Recovery Actions.
Disposition               Recovery Action(s):
Evaluate risk of recovery actions to re-power PNL-211 and PNL-213 from PNL-217 to restore Pressurizer Level (2L-427) , 21 SG Level (2L-487) level indication, and source Range Neutron Flux indication from the control room.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-217.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-031-2-03             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to Bus 24 and damage to power cables that could over-heat and cause secondary fires. If the fire damaged DC control power, PINGP                                                                                                                          Page C- 115- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.
Components and Cables:
Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24406-3, 24403-F, 24404-F, 2C-2552, 2C-866, 2DC-5)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure protection of the over-current trip function of 4kV breakers and preclude secondary ignition of cables in other fire areas.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a modification credited.
PINGP                                                                                                                                Page C- 116- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area  Category           ID               Type                                      Notes S   L E       R     D 31         Detection          2                Ionization      N    N Y Y           N Suppression        WPS-10           Wet Pipe        N    N Y Y           N Feature            See Note         ERFBS           N    N N Y           N    Cables 2AC1-5, 1CA-115, 2A1-4A, 2A1-5A, 2CA-30, 2CA-115, 2CA-116, 2CA-117, TB-2390 and 2SG-TA11 Hose Station                                        N    N N Y           N Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments FA 31 extends above Fire Areas 35 and 36 PINGP                                                                                                                                     Page C- 117- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         32              "B" Train Hot Shutdown Panel & Air Compressor/Aux. Feedwater Pump Room Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Performance Goal                        Method of Accomplishment                                                          Comments Decay Heat Removal (HSB)                Hot:                                                                              VFDR-032-0-03 Unit 1 - 12 MDAFW Pump to 12 SG                                                   VFDR-032-1-01 Unit 2 - 22 TDAFW Pump to 22 SG                                                   VFDR-032-2-01 VFDR-032-2-02 Process Monitoring                      RCS Pressure (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Safety Injection (Train B)
Unit 2 - Safety Injection (Train B)
Reactivity Control                      Unit 1 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                           Page C- 118- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Vital Auxiliaries                          Unit 1 - Offsite Power (1 RY) supplying Electrical Distribution Train B               VFDR-032-0-01 Unit 2 - Offsite Power supplying Electrical Distribution Train B                      VFDR-032-1-02 VFDR-032-1-03 Unit 1 - CC Train B                                                                   VFDR-032-2-03 Unit 2 - CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23587, Fire Risk Evaluation, Fire Area 32, B Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE-12-004, CA-01313808-01, AFW Pump Room Ducts without Fire Dampers Summary          The purpose of this evaluation is to assess the impact on fire safe shutdown capability of four exhaust ducts and one supply duct that are not provided with 3-hour rated fire dampers in the boundaries of the Auxiliary Feedwater Pump Rooms, Fire Areas 31 and 32. The lack of fire dampers in the ductwork penetrations of the common barrier between the AFW Pump Rooms and the 480V Normal Switchgear Rooms, and between the 480V Normal Switchgear Rooms to the Turbine Buildings, has no impact on safe shutdown capability and is acceptable as is.
EEEE Title       CA-01040686 (Attachment), NFPA 72E Requirement for Non-Restorable Heat Detectors Evaluation Summary          The 2006 NFPA 72E, 1974 edition, code compliance review identified that nonrestorable spot type thermal detectors were not being tested in accordance with the code. Based on the type of fire expected in these fire areas, the generation of smoke will exceed the generation of heat during the incipient stage of a fire. Therefore, the area smoke detection will provide the early warning of a fire. The heat detectors are not credited in the USAR by reference to F5 Appendix K, but will provide a secondary level of automatic detection.
Based on the lack of credit given to the heat detectors, the requirements of NFPA 72E are not mandatory and the functional testing for the rate of rise function is adequate. The additional testing of the fixed temperature function through destructive testing at a nationally recognized laboratory is not cost justified for the minor benefit. The lack of meeting the full code requirement for non-restorable heat detection testing will not have adverse effect on safe shutdown for any of the affected fire areas.
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, PINGP                                                                                                                                    Page C- 119- Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-032-0-01                 This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to AFWP. The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers.
Components and Cables:
MCC 1AB1 (111C-4) 11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CA-529, 1CA-538) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CA-529, 1CA-538) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CA-529, 1CA-538) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CA-529, 1CA-538) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CA-529, 1CA-538) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CA-529, 1CA-538) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CA-529, 1CA-538) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CA-529, 1CA-538)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
PINGP                                                                                                                                Page C- 120- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition Disposition               Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 2.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-032-0-03             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of both trains of AFW.
An automatic wet pipe suppression system is installed in the general area of the AFW pump room, but does not provide full area wide coverage in the mezzanine area above the battery rooms. There are no fixed fire initiators in the mezzanine area above the battery rooms. There are some Fire PRA cables in the mezzanine area.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of a full area suppression system with credit given to deterministic requirements of section 4.2.3.3 b and c.
Components and Cables:
None Compliant Case:
The automatic wet pipe fire suppression system in the AFW pump room should provide full area wide coverage to meet deterministic requirements.
Disposition               Recovery Action(s):
No recovery actions credited.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with automatic fire suppression system in the general area credited.
VFDR-032-1-01             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 11 TDAFWP (Train A) and damage to circuits for 12 MDAFWP (Train B) suction and discharge valves. A fire at the Train B Hot Shutdown Panel could cause spurious operation of MV-32381 or MV-32382. A fire at MCC-1A2 could cause spurious operation of MV-32381, MV-32382, MV-32027, or MV-32335.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between PINGP                                                                                                                           Page C- 121- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition redundant trains of AFW.
Components and Cables:
12 MDAFW Pump to 11 SG, MV-32381 (1A2-7A, 1CB-52, 1CB-53, 1CB-54, 1A2-7) 12 MDAFW Pump to 12 SGMV-32382 (1A2-8A, 1CB-52, 1CB-55, 1CB-56, 1A2-8) 12 MDAFW Pump suction from Cooling Water, MV-32027 (1A2-3, 1A2-3A, 1A2-6A) 12 MDAFW Pump suction from CST, MV-32335 (1A2-6A)
Motor Control Center 1A, Bus 2, MCC-1A2 (121E-1)
The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal.
Compliant Case:
Train B, 12 MDAFWP, along with valves MV-32381, MV-32382, MV-32027, and MV-32335 should remain unaffected by a fire to provide AFW to a SG for Decay Heat Removal.
Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #3 will ensure that 12 MDAFWP (Train B) remains available to provide AFW to 12 Steam Generator.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-032-1-02             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of power to BUS-15 and BUS-16 from the offsite power sources 1R, CT11 and D1 to BUS-15 and D2 to BUS-16. Loss of power to BUS-15 and BUS-16 could cause a station black-out on Unit 1 and would not meet Vital Auxiliaries Performance Criteria of NFPA 805.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of safeguard power.
Components and Cables:
Bus 16 4.16KV Switchgear, BUS 16 (1DCB-1)
Bus 16 Source from 1R XFMR, BKR 16-2 (1C-332, 1C-333)
Bus 16 Source from Bus CT 11, BKR 16-8 (15407-1, 15407-2, 16408-1)
PINGP                                                                                                                          Page C- 122- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition D2 Diesel Generator, 034-021 (1DCB-2, 1DCB-95)
Bus 15 4.16KV Switchgear, BUS 15 (15406-B, 1DCA-1)
Bus 15 Source from D1 Diesel Generator, BKR 15-2 (15402-G, 15402-K, 15402-1)
Bus 15 Source from 1R XFMR, BKR 15-3 (1C-332, 1C-333, 15403-B)
Bus 15 Source from Bus CT 11, BKR 15-7 (15407-1, 15407-2, 15407-A, 16408-1)
Compliant Case:
BUS-16 should remain energized from 1RY (BKR-16-2) or D2 (BKR-16-9) to provide vital AC power to support safe shutdown.
Disposition Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #6 will re-route cable 1C-333 out of Fire Area 32 so that the 1RY source will remain available to BUS-16.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for the Bus-15 source breakers. If a Bus 15 feeder breaker is faulted the source breakers will remain available to clear the fault and protect the 1RY source.
048 This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with plant modifications credited.
Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-032-1-03             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to BUS-13, 14, 15, and 16, which would preclude operation of the over-current trip relay protection on the following 4 KV breakers: BKR-13-3, BKR-14-3, BKR-15-1, BKR-15-4, BKR-15-5, BKR-15-9, and BKR-16-3. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital and Non-Vital AC power.
PINGP                                                                                                                              Page C- 123- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Components and Cables:
Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR-13-3 (13403-3, 13408-B, 1C-1293, 1C-1295, 1C-4637, 1DC-3) 12 Heater Drain Pump Breaker, BKR-14-3 (14403-1, 14403-D, 1C-1294, 1C-4637, 1DC-4) 11 SI Pump Breaker, BKR-15-1 (15401-1, 15401-B, 15401-C, 15401-E, 15406-B, 1DCA-1) 11 RHR Pump Breaker, BKR-15-4 (15404-1, 15404-C, 15404-E, 15404-B, 15406-B, 1DCA-1) 11 CC Pump Breaker, BKR-15-5 (15405-1, 15405-A, 15405-G, 15406-B, 1DCA-1) 11 CS Pump Breaker, BKR-15-9 (15406-B, 15409-1, 15409-B, 15409-C, 1DCA-1) 12 MDAFW Pump Breaker, BKR 16-3 (16403-1, 16403-C, 1DCB-1)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Dispostion                Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-032-2-01             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 21 MDAFWP (Train A) and damage to circuits for 22 TDAFWP (Train B) suction and discharge valves. A fire at the Train B Hot Shutdown Panel could cause spurious operation of MV-32246 or MV-32247.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of AFW.
Components and Cables:
22 AFW to 21 SG MV, MV-32246 (2CB-164) 22 AFW to 22 SG MV, MV-32247 (2CB-163)
PINGP                                                                                                                             Page C- 124- Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition Compliant Case:
Train B, 22 TDAFWP and discharge valves MV-32246 and MV-32247 should remain unaffected by a fire to provide AFW to a SG for Decay Heat Removal.
Disposition               Recovery Action:
No recovery actions credited.
Modification identified in Table S-2, Item #4 will ensure that 22 TDAFWP (Train B) remains available to provide AFW to 22 Steam Generator.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-032-2-02             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            10, 21 MDAFWP and loss of power MCC-2A1 which powers MV-32383 and MV-32384. A loss of power to MV-32383 and MV-32384 would prevent remote closure of the valves and the inability to isolate spurious AFW flow. This could eventually lead to an over-fill of the Steam Generator which would challenge the Decay Heat Removal Nuclear Safety Performance Criteria.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, lack of separation between redundant trains of decay heat removal due to over-fill of steam generator.
Components and Cables 21 MDAFW Pump, MTR-25-10 (25410-D, 25410-E, 2CA-505, 2CA-506, 2CA-525, 2CA-778)
Motor Control Center 2A Bus 1, MCC-2A1 (211E-1)
Compliant Case:
The 21 MDAFWP should not spuriously start and over-fill the 21 and 22 Steam Generators.
Disposition               Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of over-filling the Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
PINGP                                                                                                                           Page C- 125- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition VFDR-032-2-03             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to BUS-25 which would preclude operation of the over-current trip relay protection on 4 KV breaker BKR-25-10. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital and Non-Vital AC power.
Components and Cables:
21 MDAFW Pump Breaker, BKR-25-10 (25410-1, 25410-E, 2CA-525, 2CA-778)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition               Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure protection of the over-current trip function of 4kV breakers and preclude secondary ignition of cables in other fire areas.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
PINGP                                                                                                                                Page C- 126- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area  Category           ID           Type                                         Notes S   L E       R     D 32         Detection          2            Ionization         N    N Y Y          N Suppression        WPS-10       Wet Pipe           N    N Y Y          N Feature                         ERFBS              N    N N Y          N     Cables and trays 16403-1, 16403-C, 1A2-6A, 1A2-7A, 1A2-8A, 1CB-52, 1CB-53, 1CB-55, 1CB-56, 1CR-99, 1CY-99, 2CB-163, 1CB-164, TB-1263 and 1SG-TA11 have supplemental barriers (ERFBS)
Feature                         RES                N    N N Y          N     Cable 1SG-LB22 has a radiant energy shield (RES), Marinite board Hose Station                                       N    N N Y          N Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments FA 32 extends above Fire Areas 33 and 34 PINGP                                                                                                                                     Page C- 127- Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Unit          Fire Area        Description 1             33               Battery Room 11 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                                          Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Reactivity Control                      Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                            Page C- 128- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Vital Auxiliaries                          Unit 1 - Offsite Power supplying Electrical Distribution Train B and portions of Train A Unit 2 - Offsite Power supplying Electrical Distribution Train B and portions of Train A Unit 1 CC Train B Unit 2 CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category           ID           Type                                       Notes S L E R D 33             Detection          1            Ionization          N N N N N Suppression        -            -                   -   -   -   -     -
Feature            -            -                   -   -   -   -     -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                Page C- 129- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 32 extends above Fire Area 33.
PINGP                                                                                                                                    Page C- 130- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit          Fire Area        Description 1             34               Battery Room 12 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                                         Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW Pump to 11 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Charging System (Train A)
Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Reactivity Control                      Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to PINGP                                                                                                                           Page C- 131- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                          Unit 1 - Offsite Power supplying Electrical Distribution Train A Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary     The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                                  Page C- 132- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area     Category           ID           Type                                    Notes S L E R D 34            Detection          1            Ionization         N N Y N N Suppression        -            -                  -  -    -   -   -
Feature            -            -                  -  -    -   -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 32 extends above Fire Area 34.
PINGP                                                                                                                                    Page C- 133- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            35                Battery Room 21 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                        Method of Accomplishment                                                         Comments Decay Heat Removal (HSB)                Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW Pump to 22 SG Process Monitoring                      RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Inventory and Pressure Control          Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Unit 2 - Safety Injection (Train B)
PINGP                                                                                                                           Page C- 134- Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Reactivity Control                           Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries                            Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Unit 2 - Offsite Power supplying Electrical Distribution Train B Unit 1 - CC Train A or B Unit 2 - CC Train B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area       Category         ID            Type                                       Notes S L E R D 35              Detection        35            Ionization           N N N N N Suppression      -             -                    -   -   -    -   -
Feature          -             -                    -   -   -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                  Page C- 135- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 31 extends above Fire Area 35.
PINGP                                                                                                                                    Page C- 136- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit           Fire Area        Description 2              36               Battery Room 22 Regulatory Basis Unit 1    4.2.3.2 - Deterministic Approach Unit 2    4.2.3.2 - Deterministic Approach Performance Goal                         Method of Accomplishment                                                            Comments Decay Heat Removal (HSB)                 Hot:
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG Unit 2 - 22 TDAFW to 21 SG Process Monitoring                       RCS Pressure (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Inventory and Pressure Control           Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Unit 2 - Charging System (Train A)
Reactivity Control                       Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Vital Auxiliaries                        Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Unit 2 - Offsite Power supplying Electrical Distribution Train A Unit 1 CC Train A or B PINGP                                                                                                                               Page C- 137- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 2 CC Train A CL Train A or B Reference Documents SAFE/GENESIS V 4.0.2 Rev 5 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area    Category           ID           Type                                     Notes S L E R D 36           Detection          35           Ionization           N N N N N Suppression        -            -                    -  -   -    -   -
Feature            -            -                    -  -   -    -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing PINGP                                                                                                                                   Page C- 138- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 31 extends above Fire Area 36.
PINGP                                                                                                                                    Page C- 139- Revision 1

Northern States Power - Minnesota                                                  Attachment C - Table B-3 Fire Area Transition Unit        Fire Area        Description 1           37               Unit 1, 480 V Normal Switchgear Room Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Performance Goal                          Method of Accomplishment                                 Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW Pump to 21 SG or 22 SG PINGP                                                                                                   Page C- 140- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 141- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train A or B        VFDR-037-0-01 Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Train A or B                VFDR-037-1-01 Unit 1 CC Train B Unit 2 CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23588, Fire Risk Evaluation, Fire Area 37, Unit 1 480V Normal Switchgear Room, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary     The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-037-0-01            This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3 due to a lack of PINGP                                                                                                                                  Page C- 142- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition separation between redundant trains of cooling water strainers.
Components and Cables:
Motor Control Center 1AB Bus 1, MCC 1AB1, (111C-4) 11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CA-529) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CA-529) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CA-529) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CA-529) 11 Cooling Water Strainer Motor, MTR-111C-21 (1CA-529) 12 Cooling Water Strainer Motor, MTR-121C-21 (1CA-529) 21 Cooling Water Strainer Motor, MTR-111C-22 (1CA-529) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CA-529)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 83.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
PINGP                                                                                                                          Page C- 143- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition VFDR-037-1-01        This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause a loss of DC control power to BUS-13 which would preclude operation of the over-current trip relay protection on the 4KV breakers. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.
Components and Cables:
Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR-13-3 (13403-2, 13403-3, 13403-4, 13404-B, 13405-B, 13408-B, 1DC-3) 11 Condensate Pump Breaker, BKR-13-7 (13407-1, 13404-B, 13405-B, 13408-B, 1DC-3) 11 Cooling Water Pump Breaker, BKR-13-8 (13408-1, 13404-B, 13405-B, 13408-B, 1DC-3)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
PINGP                                                                                                                             Page C- 144- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID            Type                                                                   Notes S L E         R    D 37           Detection           83          Ionization         N N Y Y           N Suppression         -           -                  -   -   -    -    -
Hose Station        -           -                  N N N Y           N Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 145- Revision 1

Northern States Power - Minnesota                                                  Attachment C - Table B-3 Fire Area Transition Unit        Fire Area        Description 2           38               Unit 2, 480 V Normal Switchgear Room Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Performance Goal                          Method of Accomplishment                                 Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW Pump to 11 SG or 12 SG Unit 2 - 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                   Page C- 146- Revision 1

Northern States Power - Minnesota                                                               Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A)
Inventory and Pressure Control   Unit 2 - Charging System (Train A)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to Reactivity Control               inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST PINGP                                                                                                                Page C- 147- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B                VFDR-038-0-01 Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B                VFDR-038-2-01 Unit 1 CC Train A Unit 2 CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 EC 23590, Fire Risk Evaluation, Fire Area 38, Unit 2 480V Normal Switchgear Room, Rev. 1, March 2014 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title    FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary      The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-038-0-01      This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers.
PINGP                                                                                                                                   Page C- 148- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (1CB-370) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (1CB-370) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (1CB-370) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (1CB-370) 11 Cooling Water Strainer, MTR-111C-21 (1CB-370) 12 Cooling Water Strainer, MTR-121C-21 (1CB-370) 21 Cooling Water Strainer, MTR-111C-22 (1CB-370) 22 Cooling Water Strainer, MTR-121C-22 (1CB-370)
Motor Control Center 1AB Bus 2 (221C-4)
AC Distribution Panel 136, PNL-136 (1CB-370)
Compliant Case:
Train A, 11 Cooling Water Strainer (CV-31652 and MTR-111C-21) should remain unaffected by a fire.
Disposition   Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 85.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-038-2-01  This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause a loss of DC control power to BUS-23 and BUS-24 which would preclude operation of the over-current trip relay protection on the 4KV breakers. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.
Components and Cables:
121 Screenwash Pump Breaker, BKR-23-1 (23401-1, 23401-A, 23401-B, 23405-F, 23406-C, 23407-B, 2DC-4) 21 Cooling Water Pump Breaker, BKR-23-4 (23404-1, 23401-A, 23401-B, 23405-F, 23406-C, 23407-B, 2DC-4)
PINGP                                                                                                                             Page C- 149- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition 21 Condensate Pump Breaker, BKR-23-5 (23405-1, 23401-A, 23401-B, 23405-F, 23406-C, 23407-B, 2DC-4) 22 Circ. Water Pump Breaker, BKR 24-2 (24402-1, 24403-F, 24404-F, 24405-E, 2DC-5) 22 Heater Drain Pump Breaker, BKR-24-5 (24405-1, 24403-F, 24404-F, 24405-E, 2DC-5)
Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24406-2, 24406-3, 24403-F, 24404-F, 24405-E, 2DC-5)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition     Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category          ID              Type                                                                   Notes S L E          R     D 38          Detection        85            Ionization        N N Y Y             N Suppression      -             -                 -    -    -   -     -
Hose Station     -             -                 N N N Y             N Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                  Page C- 150- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 151- Revision 1

Northern States Power - Minnesota                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2               39        Radwaste Building Note: Fire Area 39 is now combined into Fire Area 4.
PINGP                                                                     Page C- 152- Revision 1

Northern States Power - Minnesota                     Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         40              Maintenance Storage Shed Note: Fire Area 40 is now combined into Fire Area 4.
PINGP                                                                      Page C- 153- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        41                Screenhouse (General Area)
Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 154- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 155- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B                VFDR-041-0-01 Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   CA 01241917-01, Fire Protection Engineering Evaluation of Fire Barrier between FA 41A and FA 41 Summary     The purpose of this Fire Protection Engineering Evaluation is to show that there is adequate separation of redundant trains of equipment required to achieve safe shutdown in the event of a fire in the Screenhouse, Fire Areas 41, 41A, and 41B. There are no significant fire hazards in FA 41 or 41B in the vicinity of the ventilation openings above doors 257 and 258. The redundant cooling water pumps and cables are also well separated from the ventilation openings. There is fire detection and an automatic fire suppression system on both sides of the openings. These defense-in depth features provide the justification that the ventilation openings above doors 257 and 258 are acceptable as is.
EEEE Title   CA-01311046-01, Fire Doors 257, 258, 259 & 260 Summary     The purpose of this evaluation is to assess Doors 257, 258, 259 and 260, which do not have an identified fire rating. Doors 257 and 258 also have transoms above the doors that are not fire rated. The doors are in the boundaries between Fire Area 41 and Fire Area 41A on the 695ft elevation of the Screenhouse. Fire Area 41 is open to Fire Area 41B on the 670ft elevation. Fire Area 41A contains safe shutdown capabilities that are redundant to those in Fire Area 41B. Fire Doors 257 and 258, inclusive of the 14ga steel plate transoms, and Fire Doors 259 and 260 provide adequate protection to prevent fire spread that could adversely impact redundant safe shutdown capability. The bases for this conclusion include the following: Fire Doors 257, 258, 259, and 260 are of substantial construction, constructed by the same vendor that built many of the fire doors installed during original plant construction. The doors could be qualified as 1-1/2hr rated fire doors based on the referenced drawings. The transoms above Fire Doors 257 and 258 are 14ga plate steel, securely attached to the openings above the doors. While not fire rated, the transoms will resist the passage of flame, smoke and hot gases. Automatic detection and pre-action sprinklers are provided on both sides of the subject doors in Fire Areas 41A and 41.
Automatic detection and pre-action sprinklers are provided throughout Fire Area 41A and Fire Area 41B, which would control the size of postulated fires in the areas. The automatic detection systems provided throughout Fire Area 41B and Fire Area 41A, and on the south side of Fire Area 41, would also result in prompt fire brigade response. Fire brigade response would be effective in controlling and extinguishing postulated fires prior to the fire impacting on redundant fire safe shutdown capability.
PINGP                                                                                                                                   Page C- 156- Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Variances from Deterministic Requirements (VFDR)
VFDR-041-0-01     This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of coordination of PNL-136 and PNL-137 which supply power to the cooling water strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers. This is a separation issue for Vital Auxiliaries.
Components and Cables:
AC Distribution Panel 136, PNL-136 (1AB1-18)
AC Distribution Panel 137, PNL-137 (1AB2-17)
Compliant Case:
One strainer in each Cooling Water Header (11 or 12 in Train A Header) and (21 or 22 in Train B Header) should remain unaffected by a fire in this area. The Train A and Train B Cooling Water Header need to remain functional because the isolation valves could be affected by the fire.
Dispostion        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-136 and PNL-137.
This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.3 with a plant modification credited.
PINGP                                                                                                                              Page C- 157- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category          ID             Type                                                                    Notes S   L E R         D 41           Detection        75            Ionization        N     N Y Y N Suppression      PA-9          Pre-Action        N     N Y N N Feature          -             -                 -     -    -   -   -
Legend:
Required?
S   - Required for Chapter 4 Separation Criteria L   - Required for NRC-Approved Licensing Action E   - Required for Existing Engineering Equivalency Evaluation R   - Required for Risk Significance D   - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There is an automatic fire suppression system in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 158- Revision 1

Northern States Power - Minnesota                                                             Attachment C - Table B-3 Fire Area Transition Unit        Fire Area        Description 1, 2        41A              Screenhouse (DDCLP Rooms)
Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Performance Goal                         Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                              Page C- 159- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 160- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Trains A or B                VFDR-041A-0-01 Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 23591, Fire Risk Evaluation, Fire Area 41A, Screenhouse (DDCLP Rooms), Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   CA 01241917-01, Fire Protection Engineering Evaluation of Fire Barrier between FA 41A and FA 41 Summary     The purpose of this Fire Protection Engineering Evaluation is to show that there is adequate separation of redundant trains of equipment required to achieve safe shutdown in the event of a fire in the Screenhouse, Fire Areas 41, 41A, and 41B. There are no significant fire hazards in FA 41 or 41B in the vicinity of the ventilation openings above doors 257 and 258. The redundant cooling water pumps and cables are also well separated from the ventilation openings. There is fire detection and an automatic fire suppression system on both sides of the openings. These defense-in depth features provide the justification that the ventilation openings above doors 257 and 258 are acceptable as is.
EEEE Title   CA-01311046-01, Fire Doors 257, 258, 259 & 260 Summary     The purpose of this evaluation is to assess Doors 257, 258, 259 and 260, which do not have an identified fire rating. Doors 257 and 258 also have transoms above the doors that are not fire rated. The doors are in the boundaries between Fire Area 41 and Fire Area 41A on the 695ft elevation of the Screenhouse. Fire Area 41 is open to Fire Area 41B on the 670ft elevation. Fire Area 41A contains safe shutdown capabilities that are redundant to those in Fire Area 41B. Fire Doors 257 and 258, inclusive of the 14ga steel plate transoms, and Fire Doors 259 and 260 provide adequate protection to prevent fire spread that could adversely impact redundant safe shutdown capability. The bases for this conclusion include the following: Fire Doors 257, 258, 259, and 260 are of substantial construction, constructed by the same vendor that built many of the fire doors installed during original plant construction. The doors could be qualified as 1-1/2hr rated fire doors based on the referenced drawings. The transoms above Fire Doors 257 and 258 are 14ga plate steel, securely attached to the openings above the doors. While not fire rated, the transoms will resist the passage of flame, smoke and hot gases.
Automatic detection and pre-action sprinklers are provided on both sides of the subject doors in Fire Areas 41A and 41. Automatic detection and pre-action sprinklers are provided throughout Fire Area 41A and Fire Area 41B, which would control the size of postulated fires in the areas. The automatic detection systems provided throughout Fire Area 41B and Fire Area 41A, and on the south side of Fire PINGP                                                                                                                                   Page C- 161- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Area 41, would also result in prompt fire brigade response. Fire brigade response would be effective in controlling and extinguishing postulated fires prior to the fire impacting on redundant fire safe shutdown capability.
Variances from Deterministic Requirements (VFDR)
VFDR-041A-0-01            This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers. This is a separation issue for Vital Auxiliaries.
Components and Cables:
11 Cooling Water Strainer Backwash Control Valve, CV-31652 (Many) 12 Cooling Water Strainer Backwash Control Valve, CV-31653 (Many) 21 Cooling Water Strainer Backwash Control Valve, CV-31654 (Many) 22 Cooling Water Strainer Backwash Control Valve, CV-31655 (Many) 11 Cooling Water Strainer, MTR-111C-21 (Many) 12 Cooling Water Strainer, MTR-121C-21 (Many) 21 Cooling Water Strainer, MTR-111C-22 (Many) 22 Cooling Water Strainer, MTR-121C-22 (Many)
AC Distribution Panel 136, PNL-136 (Many)
AC Distribution Panel 137, PNL-137 (Many)
Motor Control Center 1AB Bus 1, MCC-1AB1 (111C-5)
Motor Control Center 1AB Bus 2, MCC-1AB2 (221C-4)
Compliant Case:
One strainer in each Cooling Water Header (11 or 12 in Train A Header) and (21 or 22 in Train B Header) should remain unaffected by a fire in this area. The Train A and Train B Cooling Water Header need to remain functional because the isolation valves could be affected by the fire.
Disposition            Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 75.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
PINGP                                                                                                                                  Page C- 162- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category           ID             Type                                                                   Notes S L E R            D 41A         Detection         75           Ionization, Heat    N N Y N N Suppression       PA-9         Wet Pipe            N N Y N N Feature           -            -                   -   -   -    -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 163- Revision 1

Northern States Power - Minnesota                                                             Attachment C - Table B-3 Fire Area Transition Unit        Fire Area        Description 1, 2        41B              Screenhouse Basement Below Grade Regulatory Basis Unit 1  4.2.4.2 - Performance Based Approach Unit 2  4.2.4.2 - Performance Based Approach Performance Goal                         Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                              Page C- 164- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 165- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B                VFDR FA41B-0-02 Vital Auxiliaries                          Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A or B        VFDR-FA41B-0-03 Unit 1 - If CC Train A is not available use CC Train B                               VFDR-FA41B-0-04 Unit 2 - If CC Train A is not available use CC Train B If CL Train A is not available use CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23592, Fire Risk Evaluation, Fire Area 41B, Screenhouse Basement Below Grade, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   CA 01241917-01, Fire Protection Engineering Evaluation of Fire Barrier between FA 41A and FA 41 Summary     The purpose of this Fire Protection Engineering Evaluation is to show that there is adequate separation of redundant trains of equipment required to achieve safe shutdown in the event of a fire in the Screenhouse, Fire Areas 41, 41A, and 41B. There are no significant fire hazards in FA 41 or 41B in the vicinity of the ventilation openings above doors 257 and 258. The redundant cooling water pumps and cables are also well separated from the ventilation openings. There is fire detection and an automatic fire suppression system on both sides of the openings. These defense-in depth features provide the justification that the ventilation openings above doors 257 and 258 are acceptable as is.
Variances from Deterministic Requirements (VFDR)
VFDR-41B-0-02            This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water cables. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries.
Components and Cables:
11 Cooling Water Strainer Backwash Valve, CV-31652, (1CA-529, 1CB-370) 22 Cooling Water Strainer Backwash Valve, CV-31655 (1CA-529, 1CB-370) 12 Cooling Water Strainer Backwash Valve, CV-31653 (1CA-529, 1CB-370) 21 Cooling Water Strainer Backwash Valve, CV-31654 (1CA-529, 1CB-370)
PINGP                                                                                                                                  Page C- 166- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition 11 Cooling Water Strainer Motor, MTR-111C-21 (1CA-529, 1CB-370) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CA-529, 1CB-370) 12 CL Strainer Motor, MTR-121C-21 (1CA-529, 1CB-370) 21 CL Strainer Motor, MTR-111C-22 (1CA-529, 1CB-370)
AC Distribution Panel 136, PNL-136 (1CA-529, 1CB-370)
AC Distribution Panel 137, PNL-137 (1CB-370)
Motor Control Center 1AB Bus 2, MCC-1AB2 (221C-4)
Motor Control Center 1AB Bus 1, MCC-1AB1 (111C-5)
Compliant Case:
Train A, 12 Cooling Water Strainer (CV-31653 and MTR-121C-21) or Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 74.
Modification identified in Table S-2, Item #20 will correct fuse/breaker coordination for PNL-137.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification credited.
VFDR-41B-0-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to Bus 23 and damage to power cables that could over-heat and cause secondary fires. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3.4.b due to a lack of OCT protection for the Power and Control cables for the Screenwash pump.
Components and Cables:
121 Screenwash Pump MTR 23-1 (23401-2, 1C-1550, 1C-1552, 1C-2280, 1C-2285, 1C-4661, 2C-1359) 21 Cooling Water pump, BKR-23-4 (1C-2285, 2C-1359, 23404-2)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
PINGP                                                                                                                          Page C- 167- Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 identifies a modification to resolve VFDR-041B-0-03 by protecting the over-current trip function to protect cables from overheating and secondary fires.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-41B-0-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause failure of redundant cooling water pumps due to deviations in the fire detection and automatic fire suppression systems credited. This could cause a loss of cooling water to support safe shutdown equipment.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
Components and Cables:
None Compliant Case:
The fire detection and automatic fire suppression systems should meet NFPA requirements.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #9 identifies a modification to resolve VFDR-041B-0-04 by installing a missing Sprinkler (#229), and a sprinkler above the 122 Diesel Driven Fire Pump.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
PINGP                                                                                                                            Page C- 168- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category           ID            Type                                                                      Notes S   L E        R     D 41B         Detection         74           Ionization,         Y    N Y Y            N Heat Suppression       PA-9         Pre-Action          Y    N Y N            N Feature                        ERFBS               N    N N Y            N    Cable 221C-4 has a Darmatt 1-hour cable wrap Hose Station                                       N    N N Y            N Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 169- Revision 1

Northern States Power - Minnesota                                                               Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1, 2               46          Cooling Tower Equipment House and Transformers Note Fire Area 46 includes:
Fire Area 46A     Cooling Tower Transformers Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                           Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                Page C- 170- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 171- Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A and B Vital Auxiliaries                     Unit 2 - Offsite Power (2RY) supplying Electrical Distribution Train A and B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                         Page C- 172- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                 Notes S L E R D 46            Detection        71            Ionization         N N N N N Suppression      -             -                  -   -   -    -   -
Feature          -             -                  -   -   -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 173- Revision 1

Northern States Power - Minnesota                       Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         46A             Cooling Tower Transformers Note: Fire Area 46A is now combined into Fire Area 46.
PINGP                                                                        Page C- 174- Revision 1

Northern States Power - Minnesota                                                            Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1,2          58                Auxiliary Building Ground Floor Units 1 and 2 Fire Area 58 includes Fire Area(s):
73 Auxiliary Building Ground Floor Unit 2 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                             Method of Accomplishment                                        Comments Hot:                                                            VFDR-058-1-07 Decay Heat Removal (HSB)                    Unit 1 - 12 MDAFW Pump to 12 SG                                 VFDR-058-2-07 Unit 2 - 22 TDAFW Pump to 22 SG                                 VFDR-058-2-011 RCS Pressure Process Monitoring                          (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level PINGP                                                                                                             Page C- 175- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit 1 - If Charging System (Train A) is not available use Safety Injection (Train  VFDR-058-1-02 Inventory and Pressure Control            B)                                                                                  VFDR-058-1-05 VFDR-058-1-06 Unit 2 - If Charging System (Train A) is not available use Safety Injection (Train  VFDR-058-1-08 B)                                                                                  VFDR-058-2-02 VFDR-058-2-05 VFDR-058-2-06 VFDR-058-2-08 Unit 1 - Trip reactor from the Control Room. If Charging Pump is not available      VFDR-058-1-02 Reactivity Control                        use Safety Injection Pump (Train B) to inject borated water from the RWST           VFDR-058-2-02 Unit 2 - Trip reactor from the Control Room. If Charging Pump is not available      VFDR-058-1-012 use Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A or B.        VFDR-058-0-01 Vital Auxiliaries                         Use train A if B is not available                                                   VFDR-058-0-02 Unit 2 - D5 Emergency Diesel Generator supplying Electrical Distribution Train A    VFDR-058-1-01 or                                                                                  VFDR-058-1-03 Offsite Power (2RY) supplying electrical distribution Train B                       VFDR-058-1-04 Use train A if B is not available                                                   VFDR-058-1-011 Unit 1 - if CC Train B pump is not available use CC Train A pump to supply Train    VFDR-058-2-01 B flow path                                                                         VFDR-058-2-03 Unit 2 - if CC Train B pump is not available use CC Train A pump to supply Train    VFDR-058-2-04 B flow path                                                                         VFDR-058-2-010 CL Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 23593, Fire Risk Evaluation, Fire Area 58, Auxiliary Building Ground Floor Unit 1, Rev. 1, March 2014.
Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   AR 1266236-01, Basis for the use of (2) 1 1/2 Hour Rated Fire Doors in a (3) Hour Fire Rated Barrier Summary     The purpose of this evaluation is to address the adequacy of Class B (1.5 hour) fire doors in Appendix R-required fire barriers. This PINGP                                                                                                                                Page C- 176- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition evaluation, through the use of a bounding condition, finds that the lesser-rated doors, where used in PINGP, are acceptable given the combustible loading and available suppression systems of the areas. No challenges to barrier integrity or safe shutdown will occur as a result of the current barrier configuration, as bound by this evaluation. The doors listed are considered acceptable without modification or further administrative control.
EEEE Title  CA-01244458-02, Fire Doors 94 & 95 Summary    The purpose of this evaluation is to assess the unrated penetrations through the transoms and the unrated 1/4-in checker steel plates and tray/conduit penetrations above Doors 94 and 95 for impact on the fire area boundaries separating Fire Areas 73 and 58 from Fire Area 4.
This evaluation also assesses the adequacy of the assemblies to provide adequate protection for the 3-hour barrier in which they are located.
The bases for this conclusion include the following: Postulated fires north of Unit 1 Door 95 and Unit 2 Door 94 would not adversely impact on redundant safe shutdown capability in Fire Area 58 and Fire Area 73 based on approved exemption requests for lack of automatic suppression that rely on enclosing Division B safe shutdown cable in one hour rated fire barriers, enclosing Division A safe shutdown cable trays in the vicinity of MCCs and at specified coordinates in one hour rated fire barriers, low combustible loading, automatic detection, and fire brigade response. Postulated fire spread south through the unrated penetrations and 1/4-in checker steel plate from Fire Area 58 or Fire Area 73 to Fire Area 4 will not impact on safe shutdown capability since the only cables of concern for safe shutdown in the event of a fire in Fire Area 4 are 1CT-1, 16408-1, and 15407-3. As such, a fire in one corridor in Fire Area 4 will not result in a simultaneous fire in the opposite corridor, and the unsealed penetrations and 1/4-in checker steel plates above Unit 1 Door 95 and Unit 2 Door 94 will not be challenged by the same fire simultaneously.
Variances from Deterministic Requirements (VFDR)
VFDR-058-0-01            This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of automatic cooling water strainer backwash function for 11, 12, 21, and 22 Cooling Water Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to AFWP.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers.
Components and Cables:
11 CL Strainer Backwash CV, CV-31652 (1CA-538) 11 CL Strainer Motor, MTR 111C-21 (1CA-538) 12 CL Strainer Backwash CV, CV-31653 (1CA-538) 12 CL Strainer Motor, MTR 121C-21 (1CA-538) 21 CL Strainer Backwash CV, CV-31654 (1CA-538) 21 CL Strainer Motor, MTR 111C-22 (1CA-538) 22 CL Strainer Backwash CV, CV-31655 (1CA-538) 22 CL Strainer Motor, MTR 121C-22 (1CA-538)
PINGP                                                                                                                                 Page C- 177- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655, and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
Evaluate risk of recovery action to manually backwash the cooling water strainer described in procedure F5 Appendix D, Zone 8.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery action credited.
VFDR-058-1-01         This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of 11 and 12 Component Cooling (CC) water Pumps. Train B CC is credited to cool the RCP TBHX and the 12 Safety Injection Pump.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the area.
Components and Cables; 11 CC Pump, MTR 15-5 (15405-1,15045-A,15405-B,15405-G,1CA-184) 12 CC Pump, MTR 16-5(16405-A , 1CB-181, 1CB-71, 16405-1)
Compliant Case:
The Train B, 12 Component Cooling Water Pump should remain unaffected by a fire. The 12 CC and its support systems should be available to supply Component Cooling water for the plant.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that for fires that affect the 12 CC pump, Train A 11 CC Pump should remain unaffected by a fire.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-058-1-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of 12 Charging Pump (Train A) and the 12 SI Pump (Train B) which are credited to inject borated water into the RCS to support Inventory Control and Reactivity Control. This could result in the loss of the ability to inject borated water into the RCS to maintain Reactivity Control and RCS Inventory.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
PINGP                                                                                                                                Page C- 178- Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Inventory Control.
Components and Cables 12 Charging Pump, MTR 111J-1 ( 1CA-1264, 1CA-1266, 1CA-754, 1CA-91, 1CA-92, 1K1-21, 1K1-21A, 1K1-29, 1K1-30, 1K1-3B),
12 SI Pump, MTR 16-7 (16407-1, 16407-B) 11 RWST to Charging Pump Suction MV, MV-32060 (1K1-14, 1K1-14A, 1K1-14B) 11 VCT Outlet to Charging Pump Suction MV, MV-32061 (1K1-14A, 1K1-3A, 1K1-3B, 1K1-3)
Motor Control Center 1K Bus 1, MCC 1K1 (111J-1)
Compliant Case:
The 12 Safety Injection Pump (MTR-16-7) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of fire affecting both injection pumps is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-058-1-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 11 CC pump and spurious opening of MV-32093 and MV-32094. If only one (11 or 12) CC pump is running and both MV-32093 and MV-32094 open, there could be excessive flow through the CC pump potentially creating a run-out condition.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of Component Cooling Pumps.
Components and Cables 11 CC Pump, MTR 15-5 (15405-1, 15405-A, 15405-B, 15405-G, 1CA-184, 1CA-24) 12 CC Pump, MTR 16-5 (16405-1, 16405-A, 1CB-181, 1CB-71) 11 RHR HX CC Inlet Valve, MV-32093 (15404-A, 1K1-9A, 1K1-9B) 12 RHR HX CC Inlet Valve, MV-32094 (1K2-5A, 1K2-5B) 11 CC HX Outlet Valve, MV-32120 (1K1-4, 1K1-4A, 1K1-4B) 12 CC HX Outlet Valve, MV-32121 (1KA2-7, 1KA2-7A, 1KA2-8B)
Motor Control Center 1K Bus 1, MCC 1K1 (111J-1)
Motor Control Center 1K Bus 2, MCC 1K2 (121J-1, 121J-2)
PINGP                                                                                                                         Page C- 179- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition Motor Control Center 1KA Bus 2, MCC 1K1 (121B-1)
Compliant Case:
If only the 12 CC pump is available, MV-32121 should be able to close or MV-32093 should not spuriously open. If only the 11 CC pump is available, MV-32120 should be able to close or MV-32094 should not spuriously open.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of losing Component Cooling due to run-out is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-058-1-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of DC control power for and damage to power cables for the following 4KV motor breakers: BKR-13-3, BKR-15-1, BKR-15-4, BKR-15-5, BKR-15-9, BKR-16-1, BKR-16-5, BKR-16-6, and BKR-16-7. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of vital buses.
Components and Cables:
Bus 13 Feed Breaker to 103-105-109-301 Transformer, BKR 13-3 (13403-3, 13408-B, 1C-1293, 1C-1295, 1C-4637) 11 SI Pump, MTR 15-1 (15401-1, 15401-B, 15401-C, 15401-E) 11RHR Pump, MTR 15-4, (15404-1, 15404-C, 15404-E, 1CA-753, 1CA-98) 11 CC Pump, MTR 15-5 (15405-1, 15405-A,, 15405-G, 1CA-184) 11 CS Pump, MTR 15-9 (15409-1, 15409-B, 1CA-97) 12 RHR Pump, MTR 16-6 (16406-1, 1CB-36, 1CB-564) 12 CS Pump, MTR 16-1 (16401-1, 16401-B, 1CB-29) 12 SI, MTR 16-7 (16407-1, 16407-B) 12 CC Pump, MTR 16-5 (16405-1, 16405-A,, 1CB-71)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
PINGP                                                                                                                         Page C- 180- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-058-1-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of the 11 Containment Spray Pump and spurious opening of the discharge valve MV-32103. This could cause a drain-down of the RWST which is the credited makeup source for injecting borated water into the RCS.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3.due to lack of suppression with a one hour barrier and detection in the area.
Components and Cables 11 CS Pump, MTR 15-9 (15409-B, 15409-D, 15409-E, or 1CA-97) 11 CS discharge valve, MV-32103 (1K1-10A)
Compliant Case:
No flow diversion is caused by spurious operation of the Containment Spray System, so that RWST Inventory Control is maintained.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of spurious operation of the Containment Spray System is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the e acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-058-1-06        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of the 12 Containment Spray Pump and spurious opening of the discharge valve MV-32105. This could cause a drain-down of the RWST which is the credited makeup source for injecting borated water into the RCS.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of suppression with a one hour barrier and detection in the area.
PINGP                                                                                                                             Page C- 181- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition Components and Cables 12 CS Pump, MTR 16-1 (16401-B, or 1CB-29) 12 CS discharge valve, MV-32105 (1KA2-3A)
Compliant Case:
MV-32105 should not spuriously open concurrently with a spurious start of the 12 CS pump and deplete the RWST.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of spurious operation of the Containment Spray System is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-058-1-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious isolation of 12 MDAFWP flow to 12 Steam Generator. This could prevent adequate AFW flow to the credited Steam Generator. The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation with one hour barrier and detection in the area.
Components and Cables:
12 MDAFW Pump Discharge to 11 Steam Generator Valve, MV-32381 (1CB-52) 12 MDAFW Pump Discharge to 12 Steam Generator Valve, MV-32382 (1CB-52) 12 MDAFW Pump, MTR 16-3 (1CB-31)
Compliant Case:
The 12 MDAFWP, and discharge valves should remain unaffected by a fire to provide AFW flow to 12 Steam Generator.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of spurious FW valve operation is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-058-1-08        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of MV-32202 or MV-32203 which could isolate the Safety Injection (SI) Pump minimum flow recirculation path back to the RWST. If the (11 or 12) Safety Injection Pump started with the RCS at normal operating pressure and the min flow recirc path isolated, PINGP                                                                                                                         Page C- 182- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition the SI Pump would be dead headed and could be damaged.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation with one hour barrier and detection in the area.
Components and Cables:
11 RWST to Charging Pump Suction Valve, MV-32060 (1K1-14,1K1-14A, 1K1-14B)
SI Recirculation Valve SI test to 11 RWST isolation MV Train B, MV-32203 (1KA2-11C)
SI Recirculation Valve SI test to 11 RWST isolation MV Train A, MV-32202 (1K1-15B) 13 Charging Pump, MTR-121J-2 (1CB-567, 1K2-7, 1K2-7A, 1CB-25, 1CB-24, 1CB-27, 1CB-1050)
Compliant Case:
The SI pump min flow recirc valves (MV-32202 or MV-32203) should not spuriously close and dead-head the SI Pumps.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually open VC-1-1, MV-32060 Bypass Charging Pump Suction, and manually close VC-3-8, 11 VCT Outlet Manual Valve Isolation, supply valves to charging pump and re-start MTR-121J-2 (13 Charging Pump).
Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after suction from the RWST is restored to inject borated water into the RCS.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions and a plant modification.
VFDR-058-1-11        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of CT11 and 1R source to BUS-15 and BUS-16 and the D1 source (034-011) to BUS-15 and the D2 source (034-021) to BUS-16. The power sources to safeguards BUS-15 and BUS-16 could be impacted by a fire in this area. BUS-15 and/or BUS-16 are required to power safe shutdown equipment.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the area.
Components and Cables:
Bus 15 Source from D1 Diesel Generator, BKR-15-2 (15402-1, 15402-G, 15402-K, 1CA-1140)
Bus 15 Source from 1R XFMR, BKR-15-3 (1C-332, 1C-333, 15403-B)
Bus 15 Source from CT 11, BKR-15-7 (15407-3, 15407-A, 16408-1)
Bus 16 Source from 1R XFMR, BKR-16-2 (1C-332, 1C-333)
Bus 16 Source from CT 11, BKR-16-8 (15407-3, 16408-1)
PINGP                                                                                                                             Page C- 183- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Bus 16 Source from D2 Diesel Generator, BKR-16-9 (16409-1, 1CB-135)
D2 Diesel Generator, 034-021 (1CB-116, 1CB-117, 1CB-121, 1CB-130, 1CB-133, 1CB-135, 1CB-140, 1CB-526, 1DCB-2)
CT-11 4.16KV CLG TWR Switchgear, BUS-CT11 (1CT-1)
Compliant Case:
BUS-16 should remain powered from either the 1RY or D2 source. BUS-15 should remain powered from the 1RY source for fire scenarios that impact Train B safe shutdown equipment in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #6 will ensure BUS-16 will remain powered from either the 1RY or D2 source.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-058-1-12        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of power to PNL-171 and PNL-181 which power CV-31098 and CV-31099 Main Steam Isolation Valves and prevent remote closure of the MSIVs.
Loss of the ability to close the MSIV could cause excessive steam flow and excessive cool down of the RCS, which could increase Reactivity.
The Nuclear Safety Performance Criteria is not met for Reactivity Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the area.
Components and Cables:
DC Distribution Panel 181, PNL-181 (1DCB-102)
DC Distribution Panel 171, PNL-171 (1DCA-102)
Compliant Case:
PNL-171 (Train A power) or PNL-181 (Train B power) for closing CV-31098 and CV-31099 should remain un-affected by a fire to isolate steam flow to prevent excessive cool down of the RCS.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes risk is low for a fire to cause concurrent damage to Train A cables and Train B cable 1DCB-102 for PNL-181.
PINGP                                                                                                                            Page C- 184- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-058-2-01        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of 21 and 22 Component Cooling (CC) water Pumps. Train B CC is credited to cool the RCP TBHX and the 22 Safety Injection Pump.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of suppression with a one hour barrier and detection in the area.
Components and Cables 21 CC Pump, MTR 25-13 (25413-1, 25413-C, 25413-D, 25413-E, 25413-G, 2CA-4) 22 CC, MTR 26-5 (26405-1, 26405-D, 26405-E, 2CB-7)
Compliant Case:
MTR-26-5, 22 Component Cooling Water Pump (Train B) should remain unaffected by a fire.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that for fires that affect the 22 CC pump, that Train A 21 CC Pump remains unaffected by a fire.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation.
VFDR-058-2-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of 22 Charging Pump (Train A) and the 22 SI Pump (Train B) which are credited to inject borated water into the RCS to support Inventory Control and Reactivity Control. This could result in the loss of the ability to inject borated water into the RCS to maintain Reactivity Control and RCS Inventory.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of Inventory Control.
Components and Cables 22 Charging Pump, MTR 211J-1 (2CA-148, 2CA-162, 2CA-199, 2CA-45, 2CA-624, 2CA-626, 2K1-41, 2K1-42, 2K1-5, 2K1-5A, 2K1-7B)
Motor Control Center 2K Bus 1, MCC 2K1 (211J-1) 22 SI Pump, MTR 26-10 (26410-1, 26410-C)
PINGP                                                                                                                                Page C- 185- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Bus 25 Feed Breaker to 11A Transformer, BKR 25-15 (112A-1, 112A-2, 112A-3, 25415-1, 25410-E, 2CA-750)
Bustie Breaker Bus 25/Bus 15, BKR 25-17 (25417-1, 25417-2, 25410-E, 25417-C, 2CA-749)
Bus 25 Source from D5 Diesel Generator, BKR 25-2 (25402-E, 2CA-751, 2CA-757)
Bus 25 Source from CT-12, BKR 25-5 (25405-C, 2CA-751)
Bus 25 Source from 2RY XFMR, BKR 25-16 (25416-1, 25416-2, 25416-C, 2CA-730, 2CA-751) 21 RWST to Charging Pump Suction MV, MV-32062 (2K1-6, 2K1-6A, 2K1-6B) 21 VCT Outlet to 21 Charging Pump Suction Header MV, MV-32063 (2K1-7, 2K1-7A, 2K1-7B, 2K1-6A)
Compliant Case:
The 22 Safety Injection Pump (MTR-26-10) should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a 1 hour fire barrier or 20 feet of separation is adequate to prevent fire damage to both Trains of injection pumps.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for BKR 25-15 and 25-17.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation and a plant modification credited.
VFDR-058-2-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 21 CC pump and spurious opening of MV-32128 and MV-32129. If only one (21 or 22) CC pump is running and both MV-32128 and MV-32129 open, there could be excessive flow through the CC pump potentially creating a run-out.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of Component Cooling Pumps.
Components and Cables 21 CC Pump, MTR 25-13 (25413-1, 25413-C, 25413-D, 25413-E, 25413-G, 2CA-4) 22 CC Pump, MTR 26-5 (26405-1, 26405-D, 26405-E, 2CB-7) 21 RHR HX CC Inlet Valve, MV-32128 (2K1-3A, 2K1-3B, 25407-D) 22 RHR HX CC Inlet Valve, MV-32129 (2K2-1A, 2K2-1B) 21 CC HX Outlet Valve, MV-32122 (2K1-4, 2K1-4A, 2K1-4B) 22 CC HX Outlet Valve, MV-32123 (2KA2-2, 2KA2-2A, 2KA2-2B)
Motor Control Center MCC 2K2 (221J-1)
Motor Control Center MCC 2KA2 (221B-1)
Motor Control Center MCC 2K1 (211J-1)
PINGP                                                                                                                             Page C- 186- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition Compliant Case:
If only the 22 CC pump is available, MV-32128 should not spuriously open.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of spuriously opening MV-32128 and MV-32129 is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation.
VFDR-058-2-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of DC control power for and damage to power cables for the following 4KV breakers: BKR-24-6, BKR-25-7, BKR-25-8, BKR-25-9, BKR-25-10, BKR                            13, BKR-26-5, BKR-26-9, BKR-26-10, and BKR-26-11. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of Vital Auxiliaries.
Components and Cables Bus 24 Feed Breaker to 204-206-209-402 Transformer, BKR-24-6 (24403-F, 24404-F, 24406-3, 2C-2552, 2C-866) 21 RHR Pump, MTR 25-7, (25407-1, 25407-C, 2CA-8, 25410-E) 21 SI Pump, MTR 25-8 (25408-1, 25408-B, 25408-C, 25410-E),
21 CS Pump, MTR 25-9 (25409-1, 25409-D, 2CA-7, 25410-E),
21 AFW Pump, MTR 25-10 (25410-1, 25410-E, 2CA-778),
21 CC Pump, MTR 25-13 (25413-1, 25413-D, 25413-E, 2CA-4, 25410-E) 22 CC Pmp, MTR 26-5 (26405-1, 26405-D, 2CB-7) 22 CS, MTR 26-9 (26409-1, 26409-E,, 2CB-315) 22 SI Pump, MTR 26-10 (26410-1, 26410-C) 22 RHR Pump, MTR 26-11 (26411-1, 2CB-9)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                         Page C- 187- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-058-2-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of the 21 Containment Spray Pump and spurious opening of the discharge valve MV-32114. This could cause a drain-down of the RWST which is the credited makeup source for injecting borated water into the RCS.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of suppression with a one hour barrier and detection in the area.
Components and Cables:
21 CS Pump, MTR 25-9 (25409-C, 25409-D, 25409-E, 2CA-7) 21 CS Pump Discharge Valve, MV-32114 (2K1-13B)
Compliant Case:
MV-32114 should not spuriously open concurrently with a spurious start of the 21 CS pump and deplete the RWST.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that MV-32114 should not spuriously open concurrently with a spurious start of the 21 CS pump and deplete the RWST.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-058-2-06        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of the 22 Containment Spray Pump and spurious opening of the discharge valve MV-32116. This could cause a drain-down of the RWST which is the credited makeup source for injecting borated water into the RCS.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of suppression with a one hour barrier and detection in the area.
PINGP                                                                                                                             Page C- 188- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition Components and Cables 22 CS Pump, MTR 26-9 (26409-E, 2CB-315) 22 CS Pump Discharge Valve, MV-32116 (2KA2-8C)
Compliant Case:
MV-32116 should not spuriously open concurrently with a spurious start of the 22 CS pump and deplete the RWST.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the spurious opening of MV-32116 is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-058-2-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of MV-32019 and MV-32020 which could isolate the steam supply to the 22 Turbine Driven Auxiliary Feedwater Pump. This could cause a loss of AFW flow to the Steam Generator to provide Decay Heat Removal.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to the lack of separation between redundant trains of decay heat removal.
Components and Cables 21 SG steam supply to 22 TDAFW Pump, MV-32019 (2K1-40A) 22 SG steam supply to 22 TDAFW Pump, MV-32020 (2K2-13A) 21 MDAFW Pump, MTR 25-10 (25410-1, 25410-C, 25410-D, 25410-E, 2CA-778)
Instrument Bus II (White) Panel 211, PNL-211 (2CW-1)
Distirbution Panel 2EMA, PNL-2EMA (2CA-601)
Compliant Case:
MV-32020 should not spuriously close in this area and isolate steam to the 22 Turbine Driven Aux Feedwater Pump.
Disposition        Recovery Action(s):
No recovery actions credited.
Credit Fire Risk Evaluation and spatial separation between MV-32019 and MV-32020 cables so that if a fire causes spurious closure of MV-32020, then MV-32019 and 1L-487, 21 SG level indication would remain available to support DHR.
PINGP                                                                                                                         Page C- 189- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-058-2-08        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of MV-32204 or MV-32205 which could isolate the Safety Injection Pump minimum flow recirculation path back to the RWST. If the (21 or 22) Safety Injection Pump started with the RCS at normal operating pressure and the min flow recirc path isolated, the SI Pump would be dead headed and could be damaged.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
Components and Cables:
21 RWST to Charging Pump Suction Valve, MV-32062 (2K1-6A, 2K1-6B, 2K1-6)
SI Recirculation Valve SI test to 21 RWST isolation MV Train A, MV-32204 (2K1-16B wrapped)
SI Recirculation Valve SI test to 21 RWST isolation MV Train B, MV-32205 (2KA2-20B) 23 Charging Pump, MTR-221J-2 (2CB-178, 2K2-5, 2K2-5A, 2K2-16, 2CB-193, 2CB-574, 2CB-181, 2K2-17)
Compliant Case:
The SI pump min flow recirc. valves (MV-32204 or MV-32205) should not spuriously close and dead-head the SI Pumps.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually open 2VC-1-1, MV-32062 Bypass Charging Pump Suction, manually close 2VC-3-8, 21 VCT Outlet Manual Valve Isolation, supply valves to charging pump and re-start MTR-221J-2 (23 Charging Pump).
Modification identified in Table S-2, Item #15 will provide suction protection to the charging pumps so the charging pump can be restarted after local action to open suction from the RWST is restored to inject borated water into the RCS.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a recovery action and a plant modification credited.
VFDR-058-2-11        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            10, 21 MDAFWP and loss of power MCC-2A1 which powers MV-32383 and MV-32384. A loss of power to MV-32383 and MV-32384 would prevent remote closure of the valves and the inability to isolate spurious AFW flow. This could eventually lead to an over-fill of the Steam Generator which would challenge the Decay Heat Removal Nuclear Safety Performance Criteria.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements (VFDR) of NFPA 805 Section 4.2.3, lack of separation between redundant trains of decay heat removal due to over-fill of steam generator.
Components and Cables:
21 Motor Driven AFW Pump, MTR-25-10 (25410-C, 25410-D, 25410-E, 2CA-778)
PINGP                                                                                                                             Page C- 190- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition 21 MDAFW Pump Discharge to 21 SG MV, MV-32383 (2CA-116) 21 MDAFW Pump Discharge to 22 SG MV, MV-32384 (2CA-116)
Motor Control Center 2A Bus 1, MCC-2A1 (211E-1)
Compliant Case:
One train of AFW should remain unaffected by a fire.
Disposition           Recovery Action(s):
The Fire Risk Evaluation concludes that the risk of over-filling the 21 and 22 Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                           Required?
Category          ID            Type                                                                   Notes Area                                                       S    L E        R     D 58          Detection         8            Ionization,      N    N Y Y            N Heat Detection         40           Ionization       N    N Y Y            N Detection         108          Ionization,      N    N Y Y            N Heat Suppression       SWP-2        Wet Pipe         N    N N N            N      Stairwell System Suppression       SWP-4        Wet Pipe         N    N N N            N      Stairwell System Suppression       WPS-11       Wet Pipe         N    N N N            N      Elevator Machine Room Feature                        ERFBS            N    N N Y            N      1AG-LA12, 1AG-LA30, 1AG-TA1, 1AG-TA2, 1AG-TA3, 1AG-TA4, 1AG-TA5, 1AG-TA14, 1AG-TA18, 1AG-TA19, 1AR-TA1, 1AR-TA4, 1AG-TB1, 1AG-TB2, 1AG-TB3, 1AG-TB5, 1AG-TB7, 1AG-TB12, 1AG-TB19, 1AG-TB20, 1AR-TB2, 1AR-TB3, 121B-1, 121J-1, 121J-2, 16405-A, 16407-1, 16407-B, 1CA-91, 1CA-92, 1CB-52, 1CB-71, 1K1-15B, 1K1-21A, 1K2-4B, 1K2-5A, 1K2-8, 1K2-8A, 1K2-9B, 1KA2-11C, 1KA2-12B Hose Station                                    N    N     N     Y    N Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                  Page C- 191- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria There is an automatic fire suppression system in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 58 now includes the Unit 2 portion of the elevation, which was Fire Area 73 prior to the transition to NFPA 805.
PINGP                                                                                                                                     Page C- 192- Revision 1

Northern States Power - Minnesota                                               Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1, 2         59                Auxiliary Building Mezzanine Level Units 1 and 2 Fire Area 59 includes Fire Area(s) 74 Auxiliary Building Mezzanine Level Unit 2 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                             Method of Accomplishment                           Comments Hot:
Decay Heat Removal (HSB)                    Unit 1 - 12 MDAFW Pump to 12 SG                    VFDR-059-2-010 Unit 2 - 21 MDAFW Pump to 22 SG                    VFDR-059-2-011 PINGP                                                                                                Page C- 193- Revision 1

Northern States Power - Minnesota                                                             Attachment C - Table B-3 Fire Area Transition If Train B Process Monitoring is not available, use Train A Process Monitoring                                                                                           VFDR-059-1-010 RCS Pressure                                                                VFDR-059-2-08 (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level PINGP                                                                                                              Page C- 194- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit 1 - Charging System (Train A)                                                VFDR-059-1-01 Inventory and Pressure Control            Unit 2 - Charging System (Train A)                                                VFDR-059-1-02 VFDR-059-1-03 VFDR-059-1-04 VFDR-059-1-05 VFDR-059-1-06 VFDR-059-1-08 VFDR-059-1-09 VFDR-059-2-01 VFDR-059-2-02 VFDR-059-2-03 VFDR-059-2-04 VFDR-059-2-05 VFDR-059-2-06 VFDR-059-2-07 VFDR-059-2-013 VFDR-059-2-016 VFDR-059-2-017 Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control                        A) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Train A                  VFDR-059-1-011 Vital Auxiliaries                         Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A          VFDR-059-2-012 Unit 1 - CC Train A Unit 2 - CC Train A CL Train A and B Reference Documents Safe/Genesis V 4.0.2 EC 23604, Fire Risk Evaluation, Fire Area 59, Auxiliary Building Mezzanine Level, Rev. 1, March 2014 Licensing Actions None PINGP                                                                                                                             Page C- 195- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title      ENG-ME-048, Appendix R RCS Inventory Control with a SI Pump Summary         During postulated fire scenarios it is expected that at least one charging pump would remain operational. However, in the Auxiliary Building a fire could be postulated to disable all three charging pumps for one unit. If this were to occur, PINGP assumes that the SI System would be used to control RCS inventory. This evaluation demonstrated that the fire protection features provide a level of protection for the existing hazards in the areas.
EEEE Title      AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary         This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
VFDR-059-1-01             This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31245 (11 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX)) and CV-31335 (11 RCP Seal Injection).
This could cause a loss of all RCP seal cooling to 11 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of cooling to RCP seals.
Components and Cables:
11 RCP TBHX, CV-31245 (1C-2221) 11 RCP Seal Injection CV-31335 (1C-1169)
Compliant Case:
CV-31245 should not spuriously close due to a fire in this area Disposition              Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
PINGP                                                                                                                                   Page C- 196- Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-1-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31246 (12 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX)) and CV-31336 (12 RCP Seal Injection).
This could cause a loss of all RCP seal cooling to 12 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of cooling to RCP seals.
Components and Cables:
12 RCP TBHX, CV-31246 (1C-4638) 12 RCP Seal Injection, CV-31336 (1C-1171)
Compliant Case:
CV-31246 should not spuriously close due to a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #18 will install new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-1-03        This VFDR involves a fire in FA 59 which spuriously opens CV-31231 (1 PRZR PORV B CV) and MV-32195 (1 PRZR PORV ISOLATION A MV). If the Power Operated Relief Valve (PORV) spuriously opens and the block valve cannot close, a loss of RCS Inventory could occur. CV-31231 is separated from MV-32195 by a one hour fire barrier or 20 feet with negligible intervening combustibles with automatic fire detection, but an automatic fire suppression system is not installed in the area This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious opening of CV-31231 (1 PRZR PORV B) and loss of ability to close MV-32195 (1PRZR PORV A Isolation Valve). This could a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of PORV isolation.
PINGP                                                                                                                            Page C- 197- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition Components and Cables:
1 PRZR PORV B Control Valve, CV-31231 (1CB-928) 1 PRZR PORV A Isolation MV, MV-32195 (1LA1-11, 1LA1-11A, 1LA1-11B)
Bus 112 Source from 112M XFMR, BKR-112M (1CA-1306) 112M Transformer, 112M/XFMR (15406-1)
Compliant Case:
CV-31231 should not spuriously open and cause a loss of RCS Inventory and Pressure Control.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that spurious operation of CV-31231 is low and therefore will not spuriously operate.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-059-1-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious opening of CV-31232 (1 PRZR PORV A) and loss of ability to close MV-32196 (1PRZR PORV B Isolation Valve). This could a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of PORV isolation.
Components and Cables:
1 PRZR PORV A Control Valve, CV-31232 (1CA-1133) 1 PRZR PORV B Isolation Valve, MV-32196 (1LA2-12, 1LA2-12A, 1LA2-12B)
Motor Control Center 1LA Bus 2, MCC-1LA2 (122L-1)
Bus 122 Source from 122M XFMR, BKR-122M (1CB-1026) 122M Transformer, 122M/XFMR (16411-1)
Compliant Case:
The Fire Risk Evaluation concludes that spurious operation of CV-31232 is low and therefore will not spuriously operate PINGP                                                                                                                         Page C- 198- Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a single fire will not simultaneously affect both the PORV and the block valve This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with credited fire risk evaluation.
VFDR-059-1-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of CV-31226, Unit 1 Letdown Isolation Train A, and spurious opening of CV-31255, Unit 1 Letdown Isolation Train B control valve.
This could a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of letdown isolation.
Components and Cables:
Letdown Isolation Train A, CV-31226 (1CA-291)
Letdown Isolation Train B, CV-31255 (1CB-283)
Compliant Case:
CV-31226 or CV-31255 should remain free of fire damage to isolate the normal letdown path.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a single fire will not simultaneously affect both Train A and Train B letdown isolation valves.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-1-06        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of CV-31330, 11 Excess Letdown Heat Exchanger Inlet Isolation Control Valve, and spurious opening of CV-31210 , 11 Excess Letdown Heat Exchanger Outlet Flow CV. This could a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
PINGP                                                                                                                            Page C- 199- Revision 1

Northern States Power - Minnesota                                                                     Attachment C - Table B-3 Fire Area Transition This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of letdown isolation.
Components and Cables:
Excess Letdown HX Inlet Isolation Valve, CV-31330 (1C-1128)
Excess Letdown HX Outlet Flow Control Valve, CV-31210 (1CF-144)
Compliant Case:
CV-31330 should not spuriously open due to a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a single fire will not simultaneously affect both excess letdown isolation valves.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-1-08        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of MV-32164, 1RCS Loop A Hot Leg RHR Supply (Inside) and MV-32165, 1RCS Loop A Hot Leg RHR Supply (Outside). MV-32164 has its breaker de-energized to preclude spurious opening. If both valves spuriously open, an Interfacing System Loss Of Coolant Accident (ISLOCA) could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant RHR suction valves.
Components and Cables:
1RCS Loop A Hot Leg RHR Supply (Inside), MV-32164 (1LA1-2) 1RCS Loop A Hot Leg RHR Supply (Outside), MV-32165 (1LA1-3, 1LA-3A, 1LA1-3B)
Compliance Case MV-32164 should not spuriously open due to three phase proper polarity hot shorts in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                            Page C- 200- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition The Fire Risk Evaluation concludes that the risk of this VFDR is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-1-09        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of MV-32230, 1RCS Loop B Hot Leg RHR Supply (Inside) and MV-32231, 1RCS Loop B Hot Leg RHR Supply (Outside). MV-32230 has its breaker de-energized to preclude spurious opening. If both valves spuriously open, an Interfacing System Loss Of Coolant Accident (ISLOCA) could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant RHR suction valves.
Components and Cables:
1RCS Loop B Hot Leg RHR Supply (Inside), MV-32230 (1LA2-4) 1RCS Loop B Hot Leg RHR Supply (Outside), MV-32231 (1LA2-11, 1LA2-11A)
Compliance Case MV-32230 should not spuriously open due to three phase proper polarity hot shorts in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of this VFDR is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-1-10        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Train A and Train B Process Monitoring indication. Train B cables are wrapped with a one hour fire barrier, except the following required cables for Breaker 16-10: 26401-1, 26401-2, and 2CB-679. If the fore mentioned Breaker 16-10 cables sustain fire damage and Train A Process Monitoring cables are concurrently damaged both Trains of Process monitoring will be lost. The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of process monitoring.
PINGP                                                                                                                           Page C- 201- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Components and Cables:
Distribution Panel 1EMA, PNL 1EMA (1CA-1228)
Pressurizer Level Cold Cal., LOOP 1L-433 (1CA-1106, 1CF-236) 11 SG Wide Range Level, LOOP 1L-487 (1CX-125)
U1 Excore Detection Train A 1N51, LOOP 1N51 (1CNX-3, 1CNX-4)
U1 Loop A RCS Wide Range Press, LOOP 1P-709 (1CX-119)
U1 RCS Loop A Hot Leg Temp, LOOP 1T-450A (1CX-131)
U1 RCS Loop A Cold Leg Temp, LOOP 1T-450B (1CX-133)
Distribution Panel 1EMB, PNL 1EMB (1CB-981, 2CV-38)
Pressurizer Level Red Channel, LOOP 1L-426RP (1CR-34) 12 SG Wide Range Level, LOOP 1L-488 (1CR-128)
U1 Excore Detection Train B 1N52, LOOP 1N52 (1CNY-3)
U1 Loop B RCS Wide Range Press, LOOP 1P-710 (1CR-122)
U1 RCS Loop B Hot Leg Temp, LOOP 1T-451A (1CR-132)
U1 RCS Loop B Cold Leg Temp, LOOP 1T-451B (1CR-134)
Bustie Bus 16 and Bus 26, BKR 16-10 (26401-1, 26401-2, 2CB-679)
Bustie Bus 26 and Bus 16, BKR 26-1 (26401-1, 26401-2, 2CB-679, 26401-C) 11 SG Wide Range LVL XMTR, 1LT-460, 1LR-460 (1CB-1001)
Compliant Case:
Train B Process Monitoring should remain available in the control room.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that there is a low risk that both trains of Process Monitoring will be impacted by a single fire in this area.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-1-11        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to 4 kV power cables and DC control power which could cause a spurious close of BKR 16-6 which could fault BUS-16. If the fire damaged DC control power, and then damaged 4kV power cables, the faulted power cable could cause the source breaker to BUS-16 to trip.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of Vital Auxiliaries.
PINGP                                                                                                                            Page C- 202- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Components and Cables:
12 RHR Pump Breaker, BKR 16-6 (1CB-564, 16406-1)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition         Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-2-01        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31248 (22 RCP TBHX) and CV-31427 (22 RCP Seal Injection). This could cause a loss of all RCP seal cooling to 22 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
22 RCP TBHX, CV-31248 (2C-2556) 22 RCP Seal Injection, CV-31427 (2C-1455)
Compliant Case:
CV-31248 or CV-31427 should remain free of fire damage to provide cooling to the RCP seals.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-1, Item #1 has installed new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
PINGP                                                                                                                             Page C- 203- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-2-02        This VFDR involves a fire in FA 59, which spuriously opens CV-31233 (2 PRZR PORV B CV) and MV-32197 (2 PRZR PORV ISOLATION A MV). CV-31233 is separated from MV-32197 by a one hour fire barrier or 20 feet with negligible intervening combustibles with automatic fire detection, but an automatic fire suppression system is not installed in the area. If the PORV spuriously opens and the block valve cannot be closed, a loss of RCS inventory could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a VFDR of NFPA 805 Section 4.2.3.4 due to lack of separation between redundant trains of PORV isolation Components and Cables:
2 PRZR PORV B, CV-31233 (2CB-472) 2 PRZR PORV ISOLATION A, MV-32197 (2LA1-23, 2LA1-23A, 2LA1-23B)
Compliant Case:
CV-31233 should not spuriously open due to a fire in the area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of a single fire affecting both the PORV and the block valve is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a fire risk evaluation credited.
VFDR-059-2-03        This VFDR involves a fire in FA 59, which spuriously opens CV-31234 (2 PRZR PORV A CV) and MV-32198 (2 PRZR PORV ISOLATION B MV). CV-31234 is separated from MV-32198 by a one hour fire barrier or 20 feet with negligible intervening combustibles with automatic fire detection, but an automatic fire suppression system is not installed in the area. If the PORV spuriously opens and the block valve cannot be closed, a loss of RCS inventory could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a VFDR of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of PORV isolation.
PINGP                                                                                                                            Page C- 204- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Components and Cables:
2 PRZR PORV A, CV-31234 (2CA-522) 2 PRZR PORV ISOLATION B, MV-32198 (2LA2-20, 2LA2-20A, 2LA-20B)
Motor Control Center 2LA Bus 2, MCC-2LA2 (222L-1)
Compliant Case:
CV-31234 should not spuriously open due to a fire in the area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a single fire should not affect both the PORV and the block valve.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-04        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of CV-31230 (U2 Letdown Isolation Train A) and CV-31279 (U2 Letdown Isolation Train B). CV-31230 is separated from CV-31279 by a one hour fire barrier or 20 feet free of intervening combustibles. This could cause a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of letdown isolation.
Components and Cables:
Letdown Isolation Train A, CV-31230 (2CA-359)
Letdown Isolation Train B, CV-31279 (2CB-350)
Compliant Case:
CV-31230 should remain unaffected by a fire to isolate Normal Letdown flow.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that a single fire should not affect both trains of letdown isolation.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
PINGP                                                                                                                              Page C- 205- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition VFDR-059-2-05        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of CV-31422 (U2 Excess Letdown HX Inlet Isolation) and CV-31222 (U2 Excess Letdown HX Outlet Flow Control Valve). This could cause a loss of RCS Inventory.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a VFDR of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of excess letdown isolation.
Components and Cables:
Excess Letdown HX Inlet Isolation Valve, CV-31422 (2C-1455)
Excess Letdown HX Outlet Flow Control Valve, CV-31222 (2CF-96)
Compliant Case:
CV-31222 should remain unaffected by a fire to isolate Excess Letdown flow.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that one train of excess letdown isolation will remain available.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-06        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of MV-32192, 2RCS Loop A Hot Leg RHR Supply (Inside) and MV-32193, 2RCS Loop A Hot Leg RHR Supply (Outside). MV-32192 has its breaker de-energized to preclude spurious opening. If both valves spuriously open, an Interfacing System Loss Of Coolant Accident (ISLOCA) could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 2.4.2.2 due to a lack of separation between redundant RHR suction valves.
Components and Cables:
2RCS Loop A Hot Leg RHR Supply (Inside), MV-32192 (2LA1-10) 2RCS Loop A Hot Leg RHR Supply (Outside), MV-32193 (2LA1-14, 2LA1-14A, 2LA1-14B)
PINGP                                                                                                                            Page C- 206- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition Compliant Case:
MV-32192 should not spuriously open due to three phase proper polarity hot shorts in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of this VFDR is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-07        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of MV-32232, 2RCS Loop B Hot Leg RHR Supply (Inside) and MV-32233, 2RCS Loop B Hot Leg RHR Supply (Outside). MV-32232 has its breaker de-energized to preclude spurious opening. If both valves spuriously open, an Interfacing System Loss Of Coolant Accident (ISLOCA) could occur.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant RHR suction valves Components and Cables:
2RCS Loop B Hot Leg RHR Supply (Inside), MV-32232 (2LA2-10) 2RCS Loop B Hot Leg RHR Supply (Outside), MV-32233 (2LA2-8, 2LA2-8A, 2LA2-8B)
Compliant Case:
MV-32232 should not spuriously open due to three phase proper polarity hot shorts in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of this VFDR is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-08        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause loss of Train A and Train B Process Monitoring indication. Train B cables are wrapped with a one hour fire barrier, except cable 221F-1 which powers MCC PINGP                                                                                                                          Page C- 207- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition 2AC1 which powers the 22 Battery Charger and PNL-212, PNL-214, and PNL-2EMB. Loss of power to 22 Battery Charger will eventually result in loss of power to Instrument Panels PNL-212, PNL-214, and PNL-2EMB when 22 Battery is depleted. The Instrument Panels are required power supplies for Train B Process Monitoring.
The Nuclear Safety Performance Criteria is not met for Process Monitoring.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to lack of separation between redundant trains of process monitoring.
Components and Cables:
Train A Pressurizer Level Cold Cal., LOOP 2L-433 (1CA-1106, 2CF-207) 21 SG Wide Range Level, LOOP 2L-487 (2CX-70)
U2 Excore Detection Train A 2N51, LOOP 2N51 (2CNX-3, 2CNX-4)
U2 Loop A RCS Wide Range Press, LOOP 2P-709 (2CX-64)
U2 RCS Loop A Hot Leg Temp, LOOP 2T-450A (2CX-76)
U1 RCS Loop A Cold Leg Temp, LOOP 2T-450B (2CX-78)
Train B Pressurizer Level Red Channel, LOOP 2L-426RP (2CR-9) 21 SG Wide Range Level Recorder, 2LR-460 (2CB-551) 22 SG Wide Range Level, LOOP 2L-488 (2CR-74)
U2 Excore Detection Train B 2N52, LOOP 2N52 (2CNY-3)
U2 Loop B RCS Wide Range Press, LOOP 2P-710 (2CR-68)
U2 RCS Loop B Hot Leg Temp, LOOP 2T-451A (2CR-78)
U2 RCS Loop B Cold Leg Temp, LOOP 2T-451B (2CR-80)
Motor Control Center 2AC Bus 2, MCC 2AC2 (221F-1)
Bus 26 4.16KV Switchgear, BUS-26 (Many)
Compliant Case:
Train A Process Monitoring indication from the Control Room should remain unaffected by a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that there is a low risk that both trains of Process Monitoring will not be impacted by a single fire in this area.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
PINGP                                                                                                                            Page C- 208- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition VFDR-059-2-10        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of the ability to trip MTR 21-3 (21 Main Feedwater Pump), and close MV-32028 (21 Main Feedwater Isolation Valve), and close CV-31135 (21 Main Feedwater Regulating Valve). This could cause an over-fill of the 21 Steam Generator.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of process monitoring.
Components and Cables:
21 Main Feedwater Pump, MTR 21-3 (21403-G) 21 Main Feedwater Isolation Valve, MV-32028 (2K1-27, 2K1-27A, 2K1-28) 21 Main Feedwater Regulating Valve, CV-31135 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-364, 2CA-366, 2CB-322, 2CB-325) 21 Main Feedwater Bypass Control Valve, CV-31371 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-363, 2CA-365, 2CB-323, 2CB-324) 22 Main Feedwater Pump, MTR 22-3 (21403-K)
Compliant Case:
The ability to isolate Main Feedwater to prevent over-filling the 21 Steam Generators should not be affected by a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes risk is low for a fire to cause concurrent damage to redundant cables for the Main Feedwater regulating valves so that one train is unaffected by a fire in this area.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-11        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of the ability to trip MTR 22-3 (22 Main Feedwater Pump), and close MV-32029 (22 Main Feedwater Isolation Valve), close CV-31136 (22 Main Feedwater Regulating Valve). This could cause an over-fill of the 22 Steam Generator.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of process monitoring.
Components and Cables:
21 Main Feedwater Pump, MTR 21-3 (21403-G)
PINGP                                                                                                                          Page C- 209- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition 22 Main Feedwater Pump, MTR 22-3 (21403-K) 22 Main Feedwater Isolation Valve, MV-32029 (2KA2-23, 2KA2-23A) 22 Main Feedwater Regulating Valve, CV-31136 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-361, 2CA-367, 2CB-321, 2CB-326) 22 Main Feedwater Bypass Control Valve, CV-31372 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-362, 2CA-368, 2CB-320, 2CB-327)
Motor Control Center 2KA Bus 2, MCC 2KA2 (221B-1)
Compliant Case:
The ability to isolate Main Feedwater to prevent over-filling the 22 Steam Generators should not be affected by a fire in this area.
Disposition        Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes risk is low for a fire to cause concurrent damage to redundant cables for the Main Feedwater regulating valves so that one train is unaffected by a fire in this area.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
VFDR-059-2-12        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to DC control power to Bus 26 tripping circuits and subsequent damage to AC power cables resulting and could fail Bus 26. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between 4KV Breakers.
Components and Cables:
22 CC, MTR 26-5 (26405-1, 26405-D) 22 CS, MTR 26-9 (26409-1, 26409-E) 22 SI, MTR 26-10 (26410-1, 26410-B, 26410-C) 22 RHR, MTR 26-11 (26411-1, 26411-C)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements. Coordination of BUS-26 should remain unaffected by a fire in this area.
PINGP                                                                                                                          Page C- 210- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Disposition        Recovery Action(s):
No Recovery Actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables to preclude secondary fires on power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-2-13        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31247 (21 RCP TBHX) and CV-31426 (21 RCP Seal Injection) which could cause a loss of all seal cooling to the Reactor Coolant Pump. This could cause a loss of all RCP seal cooling to 21 RCP, which could result in increased leakage through the RCP seals. The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
21 RCP TBHX, CV-31247 (2C-2553) 21 RCP Seal Injection, CV-31426 (2C-1455)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-1, Item #1 has installed new Reactor Coolant Pump Seals that will not be susceptible to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-059-2-16        This Variance From Deterministic Requirements is due to fire damage to cable(s) which results in a spurious "P" signal and the inability to trip BKR 26-9. Damage to cables for 2PT-945, 2PT-946, 2PT-947, 2PT-948, 2PT-949, and 2PT-950, Unit 2 Containment Pressure Transmitters. This could cause a flow diversion of the RWST to Containment.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3, due to lack of separation between redundant trains of containment pressure transmitters.
PINGP                                                                                                                             Page C- 211- Revision 1

Northern States Power - Minnesota                                                                      Attachment C - Table B-3 Fire Area Transition Components and Cables:
2 CNTMT PRESS NUM 1 (CHAN I-RED) P XMTR, 2PT-945 (2CR-20) 2 CNTMT PRESS NUM 2 (CHAN II-WHI) P XMTR, 2PT-946 (2CW-19) 2 CNTMT PRESS NUM 3 (CHAN IV-YEL) P XMTR, 2PT-947 (2CY-45) 2 CNTMT PRESS NUM 5 (CHAN III-BLU) P XMTR, 2PT-948 (2CX-21) 2 CNTMT PRESS NUM 4 (CHAN II-WHI) P XMTR, 2PT-949 (2CW-20) 2 CNTMT PRESS NUM 6 (CHAN IV-YEL) P XMTR, 2PT-950 (2CY-18) 22 CONTAINMENT SPRAY PUMP BREAKER, BKR 26-9 (26409-C, 26409-E , 26409-F)
Compliant Case:
The Containment Spray Pump (MTR-26-9) should not spuriously start and deplete the RWST.
Disposition        Recovery Action(s):
Evaluate risk of recovery actions in procedure F5 Appendix D, Zone 46, to manually trip BKR-26-9 at BUS-26 to prevent RWST drain down.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-059-2-17        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious opening of the pressurizer spray valves and loss of the ability to trip the RCP and loss of charging pump speed control. Spurious opening of the pressurizer spray valves would cause a reduction in RCS pressure.
The Nuclear Safety Performance Criteria is not met for RCS Inventory Control and Pressure Control.
Components and Cables:
21 RCP LOOP A PRZR SPRAY CV, CV-31228 (2CF-79) 22 RCP LOOP B PRZR SPRAY CV, CV-31229 (2CF-77) 21 REGEN HX AUX SPRAY TO 21 PRZR CV, CV-31421 (2C-1495) 22 CHARGING PUMP, MTR-211J-1 (2CA-45) 21 RC PMP, MTR-21-2 (21403-G, 21402-C) 22 RC PMP, MTR-22-2 (22402-D)
Compliant Case:
CV-31228, CV-31229, and CV-31421 should not spuriously open causing pressurizer spray to initiate.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                          Page C- 212- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition The Fire Risk Evaluation concludes that the risk of spurious pressurizer spray with a concurrent loss of charging is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                          Required?
Category           ID           Type                                                                   Notes Area                                                     S L E          R       D 59           Detection         19           Ionization    N N Y Y              N Detection         46           Ionization    N N Y Y              N Detection         108          Ionization    N N Y Y              N Suppression       PA-3         Pre-Action    N N N N              N Suppression       PA-4         Pre-Action    N N N N              N Suppression       PA-6         Pre-Action    N N N N              N Suppression       PA-7         Pre-Action    N N N N              N Suppression       WPS-         Wet Pipe      N N Y N              N 12 Suppression       WPS-         Wet Pipe      N    N   Y    N      N 19 Feature                        ERFBS         N    N   Y    Y      N      1AM-TA12, 1AM-TA13, 1AM-TA16, 1AM-TB26I, 1AM TR1, 1CA-1133, 1CB-928, 1CNY-3, 1LA1-1A, 1LA1-3B, 2CF-74 Hose Station                                 N    N   N    Y      N Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There are automatic fire suppression systems in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways or through grating to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
PINGP                                                                                                                                     Page C- 213- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 59 now includes the Unit 2 portion of the elevation, which was Fire Area 74 prior to the transition to NFPA 805.
PINGP                                                                                                                                    Page C- 214- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1            60                Auxiliary Building Operating Level Unit 1 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                             Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)                   Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 22 SG RCS Pressure Process Monitoring                         (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control             Unit 2 - Charging System (Train A) or Safety Injection (Train B)
PINGP                                                                                                                              Page C- 215- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control                          A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE-11-001, Gaps on Doors 278 & 279 Summary          The purpose of this evaluation is to justify that sliding fire Doors 278 and 279 are acceptable as installed. The doors will provide adequate protection against the spread of fire in their current configuration Based on: minimal combustible loading on either side of both doors, the 3' concrete curb which will provide an additional level of protection to prevent flame propagation under the minor door to floor gaps, automatic smoke detection in the walkways, manual firefighting equipment located nearby, the lack of safe shutdown equipment in the area and therefore will not impact the ability to achieve and maintain safe shutdown.
EEEE Title       FPEE-12-002; CA-01327430-1, Steam Line Pipe Penetrations without Penetration Seals PENF-1526, PENF-1528, PENF-1689, & PENF-1692 Summary          The purpose of this evaluation is to assess the impact on fire safe shutdown capability of four main steam line penetrations that are not provided with 3-hour fire rated penetration seals in G wall separating the Turbine Operating Deck from the 735ft elevation of the Auxiliary Building. The types, quantities, and continuity of combustible materials in Fire Area 60 or Fire Area 75 would not result in a sufficient heat release rate or fire to spread to, or spread through, the main steam line penetrations into Fire Area 8. The Turbine Stop Valves in Fire Area 8 are between 50 ft and 70 ft from the main steam line penetrations through G-wall. The only postulated fires that could result in damage to the Turbine Stop Valves and be large enough to potentially spread to the main steam line penetrations would involve either a turbine bearing oil fire or a catastrophic failure of the turbine oil system. The turbine bearings are protected by an automatically-actuated preaction sprinkler system that will respond to postulated turbine bearing oil fires and result in prompt fire brigade response. Postulated catastrophic turbine oil system failures could result in very severe fires; however, the area where oil piping runs and oil can spread are protected by automatic wet pipe sprinkler systems. Postulated turbine bearing oil fires and postulated catastrophic turbine oil system PINGP                                                                                                                                      Page C- 216- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition failure fires would result in significant heat release rates and smoke production; however, the large volume of the turbine building combined with the existing roof exhaust fans and smoke hatches that are fitted with automatic releases would release smoke and hot gas to the environment and delay the effects of such fires from banking down to the level of the main steam line penetrations located 50ft below the roof. The main steam line penetrations have limited annular gaps, 10in, for passage of fire effects to Fire Area 60 and Fire Area 75. There is very limited continuity of combustible materials in Fire Areas 60 and Fire Area 75 for fire to spread from Fire Area 8 to the vicinity of the MSlVs and solenoid valves. Postulated fires in Fire Area 8, Fire Area 60, and Fire Area 75 would not adversely impact redundant safe shutdown capability consisting of the Turbine Stop Valves in Fire Area 8 and the MSIVs and solenoid valves in Fire Area 60 and Fire Area 75.
EEEE Title      Basis for the use of (2) 1 1/2 Hour Rated Fire Doors in a (3) Hour Fire Rated Barrier Summary         The purpose of this evaluation is to address the adequacy of Class B (1.5 hour) fire doors in Appendix R-required fire barriers. This evaluation, through the use of a bounding condition, finds that the lesser-rated doors, where used in PINGP, are acceptable given the combustible loading and available suppression systems of the areas. No challenges to barrier integrity or safe shutdown will occur as a result of the current barrier configuration, as bound by this evaluation. The doors listed are considered acceptable without modification or further administrative control.
EEEE Title      AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary         This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category             ID              Type                                                               Notes S L E R D 60          Detection            28           Ionization, Heat     N N Y N N Detection            108          Ionization, Heat     N N N N N Suppression          SWP-4        Wet Pipe             N N N N N Stairwell System Feature                           -                    -   -    -   -   -
Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                   Page C- 217- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria There is an automatic fire suppression system in the fire area. In most areas, curbs, drains, and the mounting of equipment above the floor level minimizes the potential for flooding damage. Water will drain out doors or via stairways to lower elevations, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 218- Revision 1

Northern States Power - Minnesota                                                                Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        61                Auxiliary Building Anti "C" Clothing Area Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                 Page C- 219- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control               A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 220- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title         AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary           This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category            ID            Type                                                                Notes S L E R D 61            Detection           28           Ionization        N N N N N Suppression         WPS-27       Wet Pipe          N N N N N Suppression         WPS-28       Wet Pipe          N N N N N Feature                          -                 -   -    -   -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                   Page C- 221- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 222- Revision 1

Northern States Power - Minnesota                          Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         61A             Auxiliary Building Hatch Area Note: Fire Area 61A is now combined into Fire Area 4.
PINGP                                                                           Page C- 223- Revision 1

Northern States Power - Minnesota                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         62              Spent Fuel Pool Area Note: Fire Area 62 is now combined into Fire Area 4.
PINGP                                                                     Page C- 224- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        63                Filter Room Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 225- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B);
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B);
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control               A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                    Page C- 226- Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID            Type                                                               Notes S L E R D 63             Detection          -            -                 -   - -     -     -
Suppression        -            -                 -   - -     -     -
Feature            -            -                 -   - -     -     -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing PINGP                                                                                                                                   Page C- 227- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 228- Revision 1

Northern States Power - Minnesota                                                                Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1           64                Auxiliary Building Low Level Decay Area Unit 1 Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                 Page C- 229- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control               A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 230- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (1R) supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                               Notes S L E R D 64             Detection          8           Ionization          N N N N N Suppression        -           -                   -   -   N -       -
Feature            -           -                   -   -   -    -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 231- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 232- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1                 65          Spent Fuel Pool Heat Exchanger & Pumps Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)                Unit 1 - 11 TDAFW or 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 233- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train Reactivity Control               A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 234- Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID            Type                                                               Notes S L E R D 65             Detection          -            -                 -   - -     -     -
Suppression        -            -                 -   - -     -     -
Feature            -            -                 -   - -     -     -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing PINGP                                                                                                                                   Page C- 235- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 236- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit          Fire Area       Description 2             66              D3 Lunch Room Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                          Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)                Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 22 SG RCS Pressure Process Monitoring                      (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Safety Injection (Train B)
Inventory and Pressure Control          Unit 2 - Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Injection Pump (Train B) to Reactivity Control                      inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                           Page C- 237- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train B                VFDR-066-0-01 Vital Auxiliaries                         Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train B                VFDR-066-2-02 Unit 1 - CC Train B                                                                     VFDR-066-2-03 Unit 2 - CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23594, Fire Risk Evaluation, Fire Area 66, D3 Lunch Room, Rev. 1, March 2014 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
VFDR-066-0-01            This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause faults on cables 25417-1 or 25417-2 or 15412-1 and spurious closure of BKR 15-8 or BKR-15-12 which could fault Bus 15 and cause a loss of power to PNL 136 which powers the CL strainer backwash control panel for 11, 12, 21, and 22 CL Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect that function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to Lack of separation between redundant trains of cooling water strainers.
Components and Cables:
Bus Tie Breaker Bus 15/Bus 25, BKR-15-8 (25417-1, 25417-2 and 2CA-749)
Bus Feed Breaker to 21A Transformer, BKR-15-12 (2CA-749, 15412-1) 22 CL Strainer Backwash CB, CV-31655 (none) 22 CL Strainer Motor, MTR-121C-22 (none)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
PINGP                                                                                                                                   Page C- 238- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Disposition        Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 39.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-066-2-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a loss of DC control power to trip breakers on BUS-25 and damage to power cables could allow the cables to over-heat and start on fire. If the fire damaged DC control power, and then damaged 4kV power cables, the excessive current could cause load power cables to over-heat and develop secondary fires in other fire areas which violates common enclosure requirements.
The Nuclear Safety Performance Criteria is not met for Vital AC Power.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant train vital buses.
Components and Cables:
21 SI Pump Breaker, BKR 25-8 (25408-1, 25408-B, 25408-C, 25410-E),
21 RHR Pump Breaker, BKR 25-7 (25407-1, 25407-C, 25410-E) 21 CC Pump Breaker, BKR 25-13 (25413-1, 25413-D, 25413-E, 25410-E) 21 CS Spray Pump Breaker, BKR 25-9 (25409-1, 25409-D, 25410-E) 21 MDAFW Pump Breaker, BKR 25-10 (25410-1, 25410-E)
Compliant Case:
Cable over-current protection should be maintained to protect cables from over-heating and causing secondary fires to meet common enclosure requirements.
Disposition        Recovery Action(s):
No recovery actions credited.
Modification identified in Table S-2, Item #10 will ensure over-current protection is provided for power cables.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with a plant modification credited.
VFDR-066-2-03        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            10, 21 MDAFWP and loss of power MCC-2A1 which powers MV-32383 and MV32384 and would prevent remote closure to PINGP                                                                                                                             Page C- 239- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition isolate spurious AFW flow. This could eventually lead to an over-fill of the Steam Generator which would challenge the Decay Heat Removal Nuclear Safety Performance Criteria.
The Nuclear Safety Performance Criteria is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to the lack of separation between redundant trains of decay heat removal due to over-fill of steam generator.
Components and Cables:
21 MDAFW Pump, MTR-25-10 (25410-C, 25410-D, 25410-E)
Motor Control Center 2A Bus 1, MCC 2A1 (211E-1)
Compliant Case:
The 21 MDAFWP should not spuriously start and over-fill the 21 and 22 Steam Generators.
Disposition            Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes the risk of over-filling the Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category           ID             Type                                                                 Notes S L E R             D 66          Detection        39            Ionization        N N N N N Suppression      WPS-22        Wet Pipe          N N N N N Feature          -             -                 -   -    -     -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                Page C- 240- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments The trench in Fire Area 66 communicates into Fire Area 70 beneath Door 91. The trench has been sealed with concrete and grout and includes a sealed pipe sleeve.
PINGP                                                                                                                                     Page C- 241- Revision 1

Northern States Power - Minnesota                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1, 2         67              Resin Disposal Building Note: Fire Area 67 is now combined into Fire Area 4.
PINGP                                                                     Page C- 242- Revision 1

Northern States Power - Minnesota                                                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 1            69              Turbine Building Ground Floor & Mezzanine Floors Unit 1 Regulatory Basis Note: Fire Area 69 is now combined into Fire Area 8.
PINGP                                                                                                     Page C- 243- Revision 1

Northern States Power - Minnesota                                                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            70              Turbine Building Ground Floor & Mezzanine Floors Unit 2 Note: Fire Area 70 is now combined into Fire Area 8.
PINGP                                                                                                     Page C- 244- Revision 1

Northern States Power - Minnesota                                                                        Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            71                Containment and Containment Annulus Unit 2 Fire Area 71 includes Fire Area(s):
72       Containment Annulus Unit 2 Regulatory Basis Unit 1   4.2.3.2- Deterministic Approach Unit 2   4.2.3.4 - Deterministic Approach Performance Goal                           Method of Accomplishment                                                       Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG Note: Unit 2, one SG could be affected but the redundant SG remains available.
PINGP                                                                                                                         Page C- 245- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Note: Unit 2, one train of process monitoring could be affected but the redundant train remains available.
Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)                  VFDR-071-2-01 VFDR-071-2-02 Trip reactor from the Control Room. Use Charging Pump (Train A) (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 246- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions Appendix R Exemption, Containment, RCP oil collection system not in strict compliance (III.O criteria), Units 1 and 2, Fire Areas 1 and 71 Reference Attachment K - Existing Licensing Action Transition for details Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 2011-003, Fire Protection Engineering Evaluation of Appendix R Compliance with Section III.G.2.D Since Containment Annulus Pre-Action Sprinkler System PA-3, PA-4, PA-6, and PA-7 May Not Actuate Summary          The purpose of this evaluation is to justify the treatment of the containment annulus in the same way the containment is treated in 10 CFR 50 Appendix R. Revision 1 to this FPEE evaluates the functional requirements for the existing pre-action fire suppression systems inside the containment annulus. FA 68 and 72 are in compliance with Appendix R, Section III.G.2.d, because redundant trains of equipment required for safe shutdown are separated by greater than 20 feet free of intervening combustibles. Although the Annulus is not inside the containment pressure boundary, it is inside the Reactor Containment Building and it qualifies to be treated like an area inside containment because access to the area is restricted in the same way access is restricted to containment during power operation. Reference 4.15 supports this position that the annulus is inside the Reactor Containment Building. Since FA 68 and FA 72 can be treated like areas inside containment, the partial area fire detection and automatic fire suppression in the Annulus do not need to be credited to meet the requirements of Appendix R, Section III.G.2. In addition, the functional requirements and surveillances required to ensure operability are not required for the cable tray sprinkler systems in the annulus of either unit, FA 68 and FA 72.
Variances from Deterministic Requirements (VFDR)
VFDR-071-2-01                   This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31247 (21 RCP TBHX) and CV-31426 (21 RCP Seal Injection) which could cause a loss of all seal cooling to the Reactor Coolant Pump. This could cause a loss of all RCP seal cooling to 21 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
PINGP                                                                                                                                   Page C- 247- Revision 1

Northern States Power - Minnesota                                                                    Attachment C - Table B-3 Fire Area Transition This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3 due to a lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
21 RCP TBHX CC, CV-31247 (2C-2555, 2C-2560, 2C-472, 2C-473, 2C-474, 2C-475) 21 RCP seal water outlet isolation CV, CV-31426 (2C-1433, 2C-1434, 2C-1435)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.
Disposition        Recovery Action(s):
No recovery actions credited.
Table S-1, Item #1 has installed new Reactor Coolant Pump (RCP) seals that are not subject to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.3 with a plant modification credited.
VFDR-071-2-02        This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause spurious closure of CV-31248 (22 RCP TBHX) and CV-31427 (22 RCP Seal Injection) which cause a loss of all seal cooling to the Reactor Coolant Pump. This could cause a loss of all RCP seal cooling to 22 RCP, which could result in increased leakage through the RCP seals.
The Nuclear Safety Performance Criteria is not met for Inventory and Pressure Control.
This condition represents a variance from the deterministic requirements of NFPA 805, section 4.2.3 due to a lack of separation between redundant trains of RCP seal cooling.
Components and Cables:
22 RCP TBHX CC, CV-31248 (2C-2558, 2C-2559, 2C-477, 2C-478, 2C-479, 2C-497) 22 RCP seal water outlet isolation CV, CV-31427 (2C-1438, 2C-1439, 2C-1440)
Compliant Case:
RCP seal cooling from either seal injection or TBHX should remain unaffected by a fire in this fire area.
Disposition        Recovery Action(s):
No recovery actions credited.
PINGP                                                                                                                             Page C- 248- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Table S-1, Item #1 has installed new Reactor Coolant Pump (RCP) seals that are not subject to excessive leakage upon loss of all seal cooling.
This VFDR has been evaluated and it has been determined to meet the acceptance criteria of NFPA 805 Section 4.2.3 with a plant modification credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Fire                                                         Required?
Category         ID            Type                                                                     Notes Area                                                    S L E R           D 71         Detection        42          Ionization        N N N Y N Detection        52          Ionization        N N N Y N Detection        54          Ionization        N N N Y N Detection        56          Ionization        N N N Y N Feature          See         ERFBS             N N N Y N              Cable 2CF-74 has 3M Interam wrap Note Feature          N/A         Lube Oil          N    Y   N   N   N Collection System 72 Detection        47          Ionization,       N    N   N   N   N Flame Suppression      PA-5        Pre-Action        N    N   N   N   N Suppression      PA-6        Pre-Action        N    N   N   N   N Feature          -           -                 -    -   -   -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
PINGP                                                                                                                                     Page C- 249- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 71 now includes the Unit 2 Annulus, which was Fire Area 72 prior to the transition to NFPA 805.
PINGP                                                                                                                                    Page C- 250- Revision 1

Northern States Power - Minnesota                       Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            72              Containment Annulus Unit 2 Note: Fire Area 72 is now combined into Fire Area 71.
PINGP                                                                        Page C- 251- Revision 1

Northern States Power - Minnesota                                   Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            73              Auxiliary Building Ground Floor Unit 2 Note: Fire Area 73 is now combined into Fire Area 58.
PINGP                                                                                    Page C- 252- Revision 1

Northern States Power - Minnesota                                      Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            74              Auxiliary Building Mezzanine Floor Unit 2 Note: Fire Area 74 is now combined into Fire Area 59.
PINGP                                                                                       Page C- 253- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            75                Auxiliary Building Operating Level Unit 2 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                             Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG Unit 2 -21 MDAFW Pump to 21 SG RCS Pressure Process Monitoring                         (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 1L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control             Unit 2 - Charging System (Train A) or Safety Injection (Train B)
PINGP                                                                                                                              Page C- 254- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control                         Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       AR 1266236-01, Basis for the use of (2) 1 1/2 Hour Rated Fire Doors in a (3) Hour Fire Rated Barrier Summary          The purpose of this evaluation is to address the adequacy of Class B (1.5 hour) fire doors in Appendix R-required fire barriers. This evaluation, through the use of a bounding condition, finds that the lesser-rated doors, where used in PINGP, are acceptable given the combustible loading and available suppression systems of the areas. No challenges to barrier integrity or safe shutdown will occur as a result of the current barrier configuration, as bound by this evaluation. The doors listed are considered acceptable without modification or further administrative control.
EEEE Title       FPEE-11-001, Gaps on Doors 278 & 279 Summary          The purpose of this evaluation is to justify that sliding fire Doors 278 and 279 are acceptable as installed. The doors will provide adequate protection against the spread of fire in their current configuration Based on: minimal combustible loading on either side of both doors, the 3' concrete curb which will provide an additional level of protection to prevent flame propagation under the minor door to floor gaps, automatic smoke detection in the walkways, manual firefighting equipment located nearby, the lack of safe shutdown equipment in the area and therefore will not impact the ability to achieve and maintain safe shutdown.
EEEE Title       FPEE-12-002; CA-01327430-1, Steam Line Pipe Penetrations without Penetration Seals PENF-1526, PENF-1528, PENF-1689, & PENF-1692 Summary          The purpose of this evaluation is to assess the impact on fire safe shutdown capability of four main steam and four feedwater line penetrations, also referred to in this evaluation as pipe penetrations, that are not provided with 3-hour fire rated penetration seals in G-wall separating the Turbine Operating Deck from the 735ft elevation of the Auxiliary Building. PENF-1526, PENF-1528, PENF 1530, and PENF-1533 contain pipe penetrations through G-wall between the Unit 1 side of the Turbine Operating Deck, Fire Area 8, and Fire Area PINGP                                                                                                                                      Page C- 255- Revision 1

Northern States Power - Minnesota                                                                             Attachment C - Table B-3 Fire Area Transition 60 on the 735ft elevation of the Auxiliary Building. PENF-1686, PENF-1687, PENF-1689, and PENF-1692 contain pipe penetrations through G-wall between the Unit 2 side of the Turbine Operating Deck, Fire Area 8, and Fire Area 75 on the 735R elevation of the Auxiliary Building. Boot seals are provided on the Auxiliary Building side of all eight pipe penetrations, but there is no other seal material in the rest of each penetration through G-wall. The unprotected penetrations represent a path of potential fire spread between the Turbine Operating Deck, Fire Area 8, and Fire Area 60 and Fire Area 75 on the 735ft elevation of the Auxiliary Building. Postulated fires in Fire Area 8, Fire Area 60, and Fire Area 75 would not adversely impact redundant safe shutdown capability consisting of the Turbine Stop Valves in Fire Area 8 and the MSlVs and solenoid valves in Fire Area 60 and Fire Area 75. The bases for this conclusion include the following:
The types, quantities, and continuity of combustible materials in Fire Area 60 or Fire Area 75 would not result in a sufficient heat release rate for fire to spread to, or spread through, the pipe penetrations into Fire Area 8. The Turbine Stop Valves in Fire Area 8 are between 50ff and 70ft from the pipe penetrations through G-wall. The only postulated fires that could result in damage to the Turbine Stop Valves and be large enough to potentially spread to the pipe penetrations would involve either a turbine bearing oil fire or a catastrophic failure of the turbine oil system. The turbine bearings are protected by an automatically-actuated preaction sprinkler system, with that portion protecting the exciter manually-actuated, that will respond to postulated turbine bearing oil fires and result in prompt fire brigade response.
Postulated catastrophic turbine oil system failures could result in very severe fires; however, the areas where oil piping runs and oil can spread are protected by automatic wet pipe sprinkler systems. Postulated turbine bearing oil fires and postulated catastrophic turbine oil system failure fires would result in significant heat release rates and smoke production; however, the large volume of the turbine building combined with the existing smoke hatches that are fitted with automatic releases would release smoke and hot gas tithe environment and delay the effects of such fires from banking down to the level of the pipe penetrations located 50 feet below the roof. The main steam and feedwater line penetrations have limited annular gaps, 10in and 7in respectively, for passage of fire to Fire Area 60 and Fire Area 75.
There is very limited continuity of combustible materials in Fire Areas 60 and Fire Area 75 for fire to spread from Fire Area 8 to the vicinity of the MSlVs and solenoid valves.
Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category             ID             Type                                                                 Notes S L E R D 75          Detection             51          Ionization         N N N N N Suppression           -           -                  -    -    -  -    -
Feature               -           -                  -    -    -  -    -
Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                     Page C- 256- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 257- Revision 1

Northern States Power - Minnesota                    Attachment C - Table B-3 Fire Area Transition Unit         Fire Area       Description 2            76              Vent & Fan Room Unit 2 Note: Fire Area 76 is now combined into Fire Area 2.
PINGP                                                                     Page C- 258- Revision 1

Northern States Power - Minnesota                                                                Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 2           77                Auxiliary Building Low Level Decay Area Unit 2 Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                 Page C- 259- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 260- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID            Type                                                               Notes S L E R D 77             Detection          -            -                 -   - -      -    -
Suppression        -            -                 -   - -      -    -
Feature            -            -                 -   - -      -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                Page C- 261- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 77 does not have a corresponding detection zone in procedure F5 Appendix A.
PINGP                                                                                                                                    Page C- 262- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 2           78                Waste Gas Compressor Area Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 263- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control Unit 2 - Charging System (Train A) or Safety Injection (Train B)
PINGP                                                                                                                   Page C- 264- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control                           Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                Notes S L E R D 78             Detection        33            Ionization           N N N N N Suppression      -             -                    -   -   -   -   -
Feature          -             -                    -   -   -   -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 265- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 266- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1           79                480 V Safeguard Switchgear Room (Bus 112)
Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 267- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 268- Revision 1

Northern States Power - Minnesota                                                                                 Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                Notes S L E R D 79             Detection        26            Ionization         N N N N N Suppression      -             -                  -   -    -   -    -
Feature          -             -                  -   -    -   -    -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing PINGP                                                                                                                                   Page C- 269- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 270- Revision 1

Northern States Power - Minnesota                                                                          Attachment C - Table B-3 Fire Area Transition Unit          Fire Area       Description 1             80              480 V Safeguard Switchgear Room (Bus 111)
Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                          Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)                Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 22 SG RCS Pressure Process Monitoring                      (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Safety Injection (Train B)
Inventory and Pressure Control          Unit 2 - Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B)
Reactivity Control                      to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                           Page C- 271- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train B Vital Auxiliaries                           Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train B             VFDR-080-0-01 Unit 1 CC Train B Unit 2 CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23595, Fire Risk Evaluation, Fire Area 80, 480V Safeguards Switchgear Room (Bus 111), Rev. 1, March 2014 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary          The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-080-0-01                   This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause loss of power to BUS-111 which powers MCC-1AB1 which powers PNL 136 which powers the Cooling Water Strainers backwash central control panel for 11, 12, 21, and 22 CL Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers.
PINGP                                                                                                                                  Page C- 272- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Components and Cables:
22 CL Strainer Backwash CB, CV-31655 (none) 22 CL Strainer Motor, MTR-121C-22 (none)
Bus 111 480V Switchgear, BUS-111 (1DCA-100)
Compliance Case Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition              Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 43.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                                Notes S L E R           D 80            Detection           43           Ionization        N N Y N N Suppression         -            -                 -    -   -   -   -
Feature             -            -                 -    -   -   -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
PINGP                                                                                                                                   Page C- 273- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Mezzanine of FA 80 extends over hallway; is adjacent to FA 23.
PINGP                                                                                                                                    Page C- 274- Revision 1

Northern States Power - Minnesota                                                        Attachment C - Table B-3 Fire Area Transition Unit         Fire Area        Description 1            81               4.16 kV Safeguard Switchgear Room (Bus 15)
Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                          Method of Accomplishment                                       Comments Hot:
Decay Heat Removal (HSB)                Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 22 SG RCS Pressure Process Monitoring                      (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 -Safety Injection (Train B)
Inventory and Pressure Control          Unit 2 -Safety Injection (Train B)
PINGP                                                                                                         Page C- 275- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B)
Reactivity Control                          to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train B Vital Auxiliaries                           Unit 1 - Offsite Power (CT 12) supplying Electrical Distribution Train B             VFDR-081-0-01 Unit 1 CC Train B Unit 2 CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23596, Fire Risk Evaluation, Fire Area 81, 4.16KV Safeguards Switchgear Room (Bus 15), Rev. 1, March 2014 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title   FPEE 01151461, Evaluation of Non-Compliance with Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection Summary     The purpose of this evaluation is to analyze the fire doors that exceed the gap criteria of Preventive Maintenance Procedure PM 3122-3, Shield Building Category 1 Vent Zone, Fire and Security Door Inspection. Twelve of the fourteen doors are acceptable in their current configuration. Door 43 should be replaced due to the skin separation from the door frame. Door 429 should receive field maintenance to adjust the hinges to remove the gap. If this is not successful, the door should be replaced. Doors 34, 54, and 63 should be re-inspected.
The field verification could not determine gaps exceeding the acceptance criteria for these doors. If the re-inspection does determine the gaps are non-compliant, the evaluation of each door as contained in this evaluation is applicable and the doors are acceptable as-is.
Variances from Deterministic Requirements (VFDR)
VFDR-081-0-01            This Variance from Deterministic Requirements (VFDR) is due to fire damage to cable(s) that could cause loss of power to BUS-15 which powers BUS-111 which powers MCC-1AB1 which powers PNL 136 which powers the Cooling Water Strainers backwash central control panel for 11, 12, 21, and 22 CL Strainers. Loss of the cooling water strainer backwash function could eventually lead to reduced cooling water flow and additional pressure loss across the strainers which would affect the function of cooling water to provide cooling to credited loads and backup supply to Aux Feedwater Pumps.
PINGP                                                                                                                                  Page C- 276- Revision 1

Northern States Power - Minnesota                                                                         Attachment C - Table B-3 Fire Area Transition The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of cooling water strainers.
Components and Cables:
Bus 15 4.16 KV Switchgear, BUS 15 (Many) 22 CL Strainer Backwash CB, CV-31655 (none) 22 CL Strainer Motor, MTR-121C-22 (none)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition            Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 43.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category          ID             Type                                                                   Notes S L E         R    D 81          Detection        11           Ionization         N N Y Y           N Suppression      -            -                  -   -   -    -    -
Hose Station     -            -                  N N N Y           N Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                               Page C- 277- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Mezzanine of FA 81 extends over hallway; is adjacent to FA 21.
PINGP                                                                                                                                    Page C- 278- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1           82                480 V Safeguard Switchgear Room (Bus 122)
Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 279- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 280- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                                Notes S L E R D 82             Detection          50           Ionization          N N N N N Suppression        -            -                   -   -   -    -    -
Feature            -            -                   -   -   -    -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 281- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 282- Revision 1

Northern States Power - Minnesota                                                                            Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            83                Operator's Lounge Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                                         Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG RCS Pressure Process Monitoring                        (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control            Unit 2 - Charging System (Train A) or Safety Injection (Train B)
PINGP                                                                                                                             Page C- 283- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control                           Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                                Notes S L E R D 83             Detection          64           Ionization           N N N N N Suppression        -            -                    -   -   -    -   -
Feature            -            -                    -   -   -    -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 284- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments Fire Area 83 is split into two parts (Secondary Alarm Station and Operators Lounge).
PINGP                                                                                                                                    Page C- 285- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        84                Counting Room and Labs Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 286- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 287- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID              Type                                                               Notes S L E R D 84             Detection          -             -                  -   -    -   -    -
Suppression        WPS-19        Wet Pipe           N N N N N Feature            -             -                  -   -    -   -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 288- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 289- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        85                Hold-up Tank Area/Demineralizer Area Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 290- Revision 1

Northern States Power - Minnesota                                                                   Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B);
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B);
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                    Page C- 291- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       CA-01040686 (Attachment), NFPA 72E Requirement for Non-Restorable Heat Detectors Evaluation Summary          The 2006 NFPA 72E, 1974 edition, code compliance review identified that nonrestorable spot type thermal detectors were not being tested in accordance with the code. Based on the type of fire expected in these fire areas, the generation of smoke will exceed the generation of heat during the incipient stage of a fire. Therefore, the area smoke detection will provide the early warning of a fire. The heat detectors are not credited in the USAR by reference to F5 Appendix K, but will provide a secondary level of automatic detection.
Based on the lack of credit given to the heat detectors, the requirements of NFPA 72E are not mandatory and the functional testing for the rate of rise function is adequate. The additional testing of the fixed temperature function through destructive testing at a nationally recognized laboratory is not cost justified for the minor benefit. The lack of meeting the full code requirement for non-restorable heat detection testing will not have adverse effect on safe shutdown for any of the affected fire areas.
EEEE Title       FPEE-12-006, CA-01311038-03, Fire Area 85 Boundaries and F5 Appendix K Barriers Summary          The purpose of this evaluation is to assess two distinct but related issues. One is the impact on fire safe shutdown capability of the fire area boundaries surrounding Fire Area 85. The second is the relocation of the F5 Appendix K barrier on the 715ft elevation. Based on the identified types and locations of combustible materials, the similarity fire safe shutdown impact, and the fire protection features provided, there is reasonable assurance that fire will not spread between Fire Area 85 and Fire Areas 60 and 75 on the 735ft elevation and between Fire Area 85 and Fire Areas 59 and 74 on the 715ft elevation and adversely impact fire safe shutdown capability. The only redundant safe shutdown capability is associated with CV-31742 in Fire Area 85 and CV-31743 in Fire Area 74 which are Train B and Train A, respectively, of the Unit 2 Reactor Building Instrument Air isolation control valves. Based on the large spatial separation between cabling for the components, there is no impact on fire safe shutdown capability should a fire spread between Fire Area 74 and Fire Area 85. As such, the F5 Appendix K fire barrier between the areas can be deleted.
Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                                     Page C- 292- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                                Notes S L E R D 85            Detection          8            Ionization,        N N Y N N Thermal Suppression        -            -                  -   -   -   -   -
Feature            -            -                  -   -   -   -   -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 293- Revision 1

Northern States Power - Minnesota                                                              Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 1, 2        86                Intake Screenhouse Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                               Page C- 294- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 295- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                           Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID            Type                                                               Notes S L E R D 86             Detection          -            -                 -   - -      -    -
Suppression        -            -                 -   - -      -    -
Feature            -            -                 -   - -      -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                Page C- 296- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 297- Revision 1

Northern States Power - Minnesota                                                               Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 2           92                Water Chiller Room Unit 2 Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                           Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                Page C- 298- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 299- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                          Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       AR 1266236-01, Class B (1.5 hour) fire doors in Appendix R-required fire barriers Summary          This evaluation demonstrates that the Class B doors are compliant to the requirements of the SER. The maximum fire exposure duration to a 1.5 hour fire door protecting an Appendix R area, as bound by this evaluation, is 31 minutes. Applying a one-half barrier rating acceptance criteria, the 1.5 hour doors in Appendix R barriers are acceptable due to the maximum exposure being less than one-half of the 1.5 hour rating.
EEEE Title       FPEE 01086132-0, Condition/Fire Protection Evaluation Adequacy of the fire boundary between Fire Area 76 (Vent and Fan Room, Unit 2, 755' Auxiliary Building) and Fire Area 92 (Water Chiller Room, Unit 2, 755' Auxiliary Building) without an installed three-hour fire damper Summary          The Purpose of this evaluation is to address the adequacy of the fire boundary between Fire Area 76 (Vent and Fan Room, Unit 2, 755' Auxiliary Building) and Fire Area 92 (Water Chiller Room, Unit 2, 755' Auxiliary Building) without an installed three-hour fire damper in a duct transversing the barrier. Although the duct work is not in a fire-tested configuration, the construction of the duct itself provides a one-hour measure of fire protection. Additionally, a lack of combustibles and ignition sources in the vicinity of the duct, as well as control of transient combustibles, minimizes the risk of fire. Should a fire occur, area-wide detection would quickly alert operators to the presence of products of combustion. The existing duct configuration (without damper) provides adequate protection from a fire in Fire Area 76 propagating into Fire Area 92.
Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                                     Page C- 300- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                Notes S L E R D 92           Detection         31            Ionization        N N Y N N Suppression       -             -                 -   -   -    -   -
Feature           -             -                 -   -   -    -   -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is not installed in the fire area. Water from other sources will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                    Page C- 301- Revision 1

Northern States Power - Minnesota                                                                Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 1, 2         93                Drum Storage/Low Level Rad Waste Note: Fire Area 93 is now combined into Fire Area 4.
Unit         Fire Area         Description 1, 2         94                Service Building/Computer Room Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                             Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                 Page C- 302- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 303- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area        Category           ID             Type                                                                Notes S L E R D 94             Detection        94            Ionization          N N N N N Suppression      DPS-2         Dry Pipe            N N N N N Truck Aisle system Suppression      SWP-31        Wet Pipe            N N N N N Stairwell system Feature          -             -                   -  -    -   -     -
Legend:
Required?
S    - Required for Chapter 4 Separation Criteria L    - Required for NRC-Approved Licensing Action E    - Required for Existing Engineering Equivalency Evaluation R    - Required for Risk Significance D    - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 304- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 305- Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            97                D5 Diesel Generator Building Note: Fire Area 97 includes Fire Areas: 99, 101, 103, 105, 107, 109, 111, 113, 115, 117, 119, 123, 125, and 127 Regulatory Basis Unit 1   4.2.4.2 - Performance Based Approach Unit 2   4.2.4.2 - Performance Based Approach Performance Goal                             Method of Accomplishment                                                       Comments Hot:
Decay Heat Removal (HSB)                                                                                                  VFDR-097-2-01 Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 22 TDAFW Pump to 22 SG RCS Pressure Process Monitoring                         (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Safety Injection (Train B)
Inventory and Pressure Control             Unit 2 - Safety Injection (Train B)
PINGP                                                                                                                            Page C- 306- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B)
Reactivity Control                          to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Safety Injection Pump (Train B) to inject borated water from the RWST Unit 1 - Offsite Power (CT 11) supplying Electrical Distribution Train B Vital Auxiliaries                           Unit 2 - D6 supplying Electrical Distribution Train B                                VFDR-097-0-01 Unit 1 - CC Train B Unit 2 - CC Train B CL Train B Reference Documents Safe/Genesis V 4.0.2 EC 23597, Fire Risk Evaluation, Fire Area 97, D5 Building, Rev. 1, March 2014 Procedure F5 Appendix D, Impact of Fire Outside Control/Relay Room, Rev. 31 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 01193322-03, D5 Cable Spreading Room Structural Steel Fireproofing Summary          This evaluation will determine the acceptability of the 4-foot section on the underside of the bottom flange of a steel beam in the D5 Cable Spreading Room that is not coated with fireproof material. The condition will be evaluated against the licensing basis. Based on the existing detection, extinguishers, combustible loading, ignition source control, and fire brigade response the evaluation demonstrates that the lack of fire proofing material is acceptable based on defense in depth SSCs which are adequate for the identified hazard, and is therefore acceptable.
Variances from Deterministic Requirements (VFDR)
VFDR-97-0-01                    This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause damage to Bus 25 and cables that could cause a spurious closure of BKR 25-17 and BKR 15-8 which could fault Bus 15 and cause a loss of power to PNL 136 which powers the CL strainer backwash control panel for 11, 12, 21, and 22 CL Strainers.
The Nuclear Safety Performance Criteria is not met for Vital Auxiliaries.
This represents a variance from the deterministic requirements of NFPA 805 Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers.
PINGP                                                                                                                                    Page C- 307- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Components and Cables:
BKR-15-8 (2CA-749, 25417-1, 25417-2) 22 CL Strainer Backwash CB, CV-31655 (none) 22 CL Strainer Motor, MTR-121C-22 (none)
Motor Control Center 2A Bus 1, MCC-2A1 (211E-1)
Compliant Case:
Train B, 22 Cooling Water Strainer (CV-31655 and MTR-121C-22) should remain unaffected by a fire in this area.
Disposition               Recovery Action(s):
Evaluate risk of recovery actions to manually backwash the cooling water strainers described in procedure F5 Appendix D, Zone 97.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with recovery actions credited.
VFDR-97-2-01              This Variance From Deterministic Requirements is due to fire damage to cable(s) that could cause a spurious start of MTR                            10, 21 Motor Driven Aux Feedwater Pump, and a loss of power to MCC 2A1 which is required power to close MV-32383 and MV-32384.
The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal.
This represents a variance from the deterministic requirements (VFDR) of NFPA 805 Section 4.2.3.4.b due to a lack of separation between redundant trains of decay heat removal due to over-fill of steam generator.
Components and Cables:
21 MDAFW Pump, MTR 25-10 (25410-A, 25410-B, 25410-C, 25410-D, 25410-E)
Compliant Case:
The 21 MDAFWP should not spuriously start and over-fill the 21 and 22 Steam Generators.
Disposition               Recovery Action(s):
No recovery actions credited.
The Fire Risk Evaluation concludes that the risk of over-filling the 21 and 22 Steam Generators is low.
This VFDR has been evaluated and it was determined that the risk, safety margin and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4 with fire risk evaluation credited.
PINGP                                                                                                                            Page C- 308- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area      Category             ID             Type                                                                    Notes S L E          R    D 97         Detection          97             Ionization,         N N Y Y             N    Ionization at elevation 718 and at elevation 735 Flame, Thermal Suppression        PA-12          Pre-Action          N N N Y             N    Diesel fuel, large combustible loading.
Suppression        D5             Wet Pipe            N N N N             N    Stairwell system Stairwell Suppression        WPS-32         Wet Pipe            N  N     N   Y      N    Fuel Oil/Lube Oil storage room Feature            Area           Barriers            -  -     -   -      Y    Lube Oil/Fuel Oil Day Tank rooms. Large combustible loading 113/115 Hose Station                                          N  N     N   Y      N Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                      Page C- 309- Revision 1

Northern States Power - Minnesota                                                                           Attachment C - Table B-3 Fire Area Transition Unit         Fire Area         Description 2            98                D6 Diesel Generator Building Note Fire Area 98 includes fire Areas: 102, 104, 106, 108, 110, 112, 114, 116, 118, 120, 122, 124, 126, and 128 Regulatory Basis Unit 1   4.2.3.2 - Deterministic Approach Unit 2   4.2.3.2 - Deterministic Approach Performance Goal                            Method of Accomplishment                                                        Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW Pump to 11 SG Unit 2 - 21 MDAFW Pump to 21 SG RCS Pressure Process Monitoring                        (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 2L-433) Pressurizer Level Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 2N51) U2 Excore Detection Train A 2N51 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level Unit 1 - Charging System (Train A)
Inventory and Pressure Control            Unit 2 - Charging System (Train A)
PINGP                                                                                                                            Page C- 310- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) to Reactivity Control                         inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) to inject borated water from the RWST Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A Vital Auxiliaries                          Unit 2 - D5 supplying Electrical Distribution Train A Unit 1 CC Train A Unit 2 CC Train A CL Train A Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
EEEE Title       FPEE 10-006, AR 1179070-03, Evaluate Impact of Inconsistent Closing of Door 428 between D6 EDG Control Room & D6 Future Battery Room Summary          This evaluation is being performed to evaluate the door between the D6 Emergency Diesel Generator (EDG) Control Room (Fire Area 104) and the D6 Future Battery Room (Fire Area 106) on the 695' elevation of the D51D6 Building (also known as the SBO Building). The door between the two rooms, Door 428, does not consistently close and latch due to ventilation pressure against the door. This evaluation will determine the impact of the door on safe shutdown of the plant. Administrative controls will be established to ensure that the room is only used for spare breaker storage. The fire loading in Fire Area 106, the D6 Future Battery Room, will be revised in the FHA and the Combustible Loading Calculation (Reference 4.2 and 4.6) to reflect the spare breakers and FME covers. The FHA will also document that Door 428 is not required for safe shutdown. The D5 (Train A) portion of the building is adequately separated from the D6 (Train B) portion of the building; as such, a fire in either portion will not have an impact on redundant safe shutdown capability. The separation of redundant safe shutdown capability, combined with the existing negligible combustible loading, minimal ignition sources, and the early warning smoke detection in conjunction with fire brigade response provide assurance that a fire in these fire areas will not result in damage to both trains of electrical components. This door is acceptable in its current configuration and it will not impact the ability to achieve and maintain safe shutdown.
Variances from Deterministic Requirements (VFDR)
None PINGP                                                                                                                                     Page C- 311- Revision 1

Northern States Power - Minnesota                                                                               Attachment C - Table B-3 Fire Area Transition Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area       Category             ID             Type                                                                  Notes S L E R            D 98          Detection           97            Ionization,         N N Y N N              Diesel fuel, large combustible loading Flame. Thermal Suppression         PA-13         Pre-Action          N N N N N              Diesel fuel. Large combustible loading Suppression         WPS-33        Wet Pipe            N N N Y N              Fuel Oil/Lube Oil Storage Room Feature             Area          Barriers            -  -     -   -    Y    Lube Oil/Fuel Oil Day Tank rooms. Large combustible loading 114/116 Legend:
Required?
S      - Required for Chapter 4 Separation Criteria L      - Required for NRC-Approved Licensing Action E      - Required for Existing Engineering Equivalency Evaluation R      - Required for Risk Significance D      - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 312- Revision 1

Northern States Power - Minnesota                                                                       Attachment C - Table B-3 Fire Area Transition Unit        Fire Area         Description 2           100               #21 D5/D6 Fuel Oil Unit: 2 Fire Area: 100 Receiving Tank (South of D6 Room)
Regulatory Basis Unit 1  4.2.3.2 - Deterministic Approach Unit 2  4.2.3.2 - Deterministic Approach Performance Goal                          Method of Accomplishment                                                      Comments Hot:
Decay Heat Removal (HSB)
Unit 1 - 11 TDAFW or 12 MDAFW Pump to 11 SG or 12 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG PINGP                                                                                                                        Page C- 313- Revision 1

Northern States Power - Minnesota                                                                  Attachment C - Table B-3 Fire Area Transition RCS Pressure Process Monitoring               (LOOP 1P-709) U1 Loop A RCS Wide Range Press (LOOP 1P-710) U1 Loop B RCS Wide Range Press (LOOP 2P-709) U2 Loop A RCS Wide Range Press (LOOP 2P-710) U2 Loop B RCS Wide Range Press Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-426-RP) Pressurizer Level Red Channel (LOOP 2L-433) Pressurizer Level (LOOP 2L-426-RP) Pressurizer Level Red Channel Ex-core Neutron Monitoring (Source Range)
(LOOP 1N51) U1 Excore Detection Train A 1N51 (LOOP 1N52) U1 Excore Detection Train B 1N52 (LOOP 2N51) U2 Excore Detection Train A 2N51 (LOOP 2N52) U2 Excore Detection Train B 2N52 RCS Temperature (LOOP 1T-450A) U1 RCS Loop A Hot Leg Temp (LOOP 1T-450B) U1 RCS Loop A Cold Leg Temp (LOOP 1T-451A) U1 RCS Loop B Hot Leg Temp (LOOP 1T-451B) U1 RCS Loop B Cold Leg Temp (LOOP 2T-450A) U2 RCS Loop A Hot Leg Temp (LOOP 2T-450B) U2 RCS Loop A Cold Leg Temp (LOOP 2T-451A) U2 RCS Loop B Hot Leg Temp (LOOP 2T-451B) U2 RCS Loop B Cold Leg Temp Steam Gen. Wide Range Level (LOOP 1L-487) 11 SG Wide Range Level (LOOP 1L-488) 12 SG Wide Range Level (LOOP 2L-487) 21 SG Wide Range Level (LOOP 2L-488) 22 SG Wide Range Level Unit 1 - Charging System (Train A) or Safety Injection (Train B)
Inventory and Pressure Control   Unit 2 - Charging System (Train A) or Safety Injection (Train B)
Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Reactivity Control               Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. Use Charging Pump (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST PINGP                                                                                                                   Page C- 314- Revision 1

Northern States Power - Minnesota                                                                                Attachment C - Table B-3 Fire Area Transition Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Vital Auxiliaries                            Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE)
None Variances from Deterministic Requirements (VFDR)
None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?
Fire Area         Category           ID             Type                                                               Notes S L E R D 100            Detection          97           Thermal             N N N N N Suppression        DA-6         Deluge              N N N N N Deluge system around the circumference of the tank.
Feature            -            -                   -  -    -   -    -
Legend:
Required?
S     - Required for Chapter 4 Separation Criteria L     - Required for NRC-Approved Licensing Action E     - Required for Existing Engineering Equivalency Evaluation R     - Required for Risk Significance D     - Required to Maintain an Adequate Balance of Defense-in-Depth or Fire Risk Evaluation PINGP                                                                                                                                 Page C- 315- Revision 1

Northern States Power - Minnesota                                                                              Attachment C - Table B-3 Fire Area Transition Fire Suppression Effects on Nuclear Safety Performance Criteria An automatic fire suppression system is installed in the fire area. Water will drain out doors and drains which will minimize the potential for flooding damage; such that the standing water would not affect safety related electrical equipment which is mounted on pedestals above the floor level minimizing the potential for flooding damage. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.
The PINGP fire brigade is trained to discharge water in a judicious manner and instructed to direct hose streams and portable extinguishers at the base of the fire to limit the amount of overspray beyond the immediate fire area. For this reason, fire brigade activities are not expected to fail components not already considered damaged.
Fire Area Comments None PINGP                                                                                                                                     Page C- 316- Revision 1

Northern States Power Company   Attachment D - Non-Power Operational Modes Transition D. NEI 04-02 Non-Power Operational Modes Transition 11 Pages Attached PINGP                                                           Page D Revision 1

Northern States Power Company             Attachment D - Non-Power Operational Modes Transition NFPA 805, Section 1.3.1 Nuclear Safety Goal The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
FAQ 07-0040 (Revision 4) Implementing Guidance F.1 - Review Existing Outage Management Processes Define Higher Risk Evolutions (HREs), if not already defined in plant outage management procedures. The HRE definition should consider the following:
* Time to boil
* Reactor coolant system and fuel pool inventory
* Decay heat removal capability In accordance with NUMARC 91-06
* Activities that may impact Key Safety Functions (KSFs) should be limited and strictly controlled during HREs or infrequently performed evolutions.
Review Prairie Island Nuclear Generating Plant (PINGP) Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805, defines Higher Risk Evolutions (HRE) as:
Outage activities, plant configurations, or conditions during shutdown where the plant is more susceptible to an event causing the loss of a key safety function. Outage Management Procedure, 5AWI 15.6.0, Outage Scheduling and Outage Management, implements the PINGP philosophy of outage risk management for Modes 4 through 6, and when the reactor is defueled. Procedure 5AWI 15.6.1, Shutdown Safety Assessment, identifies the KSFs that need to be maintained and provides guidelines for maintaining them. The procedure identifies special requirements for reduced inventory and mid-loop conditions. These conditions are based on short times to boil, limited methods available for decay heat removal (e.g. only the Residual Heat Removal (RHR) system available), and low Reactor Coolant System (RCS) inventory. These conditions are also consistent with FAQ 07-0040 Revision 4 (ML082200528) guidance which considers these conditions to be generally the period of highest risk. The Non-Power Operations (NPO) assessment for PINGP consists of the following higher risk evolutions when the Plant Operating States (POSs) meet the conditions identified immediately below, thus constituting a higher risk condition:
* Fuel is in the reactor vessel, AND
* Thermal margin is low with time to core boil less than or equal to 40 minutes, OR
* The plant is in a reduced inventory condition (i.e. water level is 36 inches below the reactor vessel flange)
PINGP aligns with FAQ 07-0040 (Revision 4) implementing guidance, F.1, Review Existing Outage Management Processes.
PINGP                                                                         Page D Revision 1

Northern States Power Company            Attachment D - Non-Power Operational Modes Transition Reference Documents NEI 04-02, Guidance for Implementing a Risk-Informed, Performance Based Fire Protection Program Under 10 CFR 50.48(c), (Revision 2).
FAQ 07-0040, Non-Power Operations Clarifications, (Revision 4, ML082070249).
EC-20612, Non-Power/NSCA Operations Review for NFPA 805.
5AWI 15.6.0, Outage Scheduling and Outage Management, (Revision 12).
5AWI 15.6.1, Shutdown Safety Assessment, (Revision 26).
NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, dated December 1991.
National Fire Protection Association (NFPA) Standard 805-2001, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
PINGP                                                                    Page D Revision 1

Northern States Power Company              Attachment D - Non-Power Operational Modes Transition F.2 - Identify Components and Cables The identification of systems and components to be included in this NPO Review begins with the identification of the POSs that need to be considered. Identify the various operational states that a plant goes through during NPO, and which ones are the most risk significant.
Review The PINGP NPO Transition Review is documented in PINGP Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805. The following POSs were considered for this review:
POS 1: This POS starts when the RHR system is put into service. The RCS is closed such that a steam generator could be used for decay heat removal, if the secondary side of a steam generator is filled. The RCS may have a bubble in the pressurizer. The POS ends when the RCS is vented such that the steam generators cannot sustain core heat removal. The POS typically includes Mode 4 (Hot Shutdown) and portions of Mode 5 (Cold Shutdown). For the purposes of the NPO assessment this POS has been identified with two variations (configurations POS 1A and POS 1B): one with steam generators available for heat removal, and the other where the steam generators are no longer available.
POS 1A: In this configuration steam generators are available along with the RHR System.
There is sufficient redundancy and diversity to remove core decay heat such that risk to core damage is significantly low and does not warrant further review under this NPO assessment. Therefore, this POS configuration will not be considered for additional engineering analysis for the NFPA 805 transition for PINGP.
POS 1B: In this configuration the steam generators are no longer capable of being used to remove core decay heat and the RHR system is the sole means of maintaining RCS temperature. For the PINGP evaluation this POS considered that the RCS has been cooled to the point where the steam generators are no longer capable of steaming and removing decay heat. At this point the RCS has not yet been vented, and may be in the process of being taken out of solid plant conditions to remove steam and non-condensable gases from the pressurizer. Once this short duration solid plant operation is completed, the RCS will be vented, and the plant will be in POS 2. This POS configuration has been considered in the PINGP Review.
POS 2: This POS begins when the RCS has been vented such that the steam generators cannot sustain core heat removal, and an adequate vent path exists to preclude the RCS from re-pressurizing to a point where the RHR system would need to be isolated and made unavailable. This operational state will include portions of Mode 5 (Cold Shutdown) and Mode 6 (Refueling). This POS includes reduced inventory operations and mid-loop operations with a vented RCS, and has been considered in the PINGP NPO assessment.
POS 3: This POS represents the shutdown condition when the refueling cavity water level is at or above the minimum level required for movement of irradiated fuel assemblies with containment as defined by the PINGP Technical Specifications. This POS occurs during Mode 6, and has been considered in the PINGP NPO assessment.
PINGP Procedure 5AWI 15.6.1 identifies the KSFs that are included in this NPO assessment.
Based upon the POS defined above, it was determined that not all of the KSFs from 5AWI PINGP                                                                           Page D Revision 1

Northern States Power Company               Attachment D - Non-Power Operational Modes Transition 15.6.1 need to be included in this NPO assessment. The KSFs identified in 5AWI 15.6.1, for each unit, are:
* Decay Heat Removal - RCS
* Decay Heat Removal - SFP
* Inventory Control
* Power Availability (4160 Volts, 480 Volts, 120 Volt Instrument Buses, 120 Volt UPS Loads, DC)
* Reactivity Control
* Containment The NPO Model includes the Component Cooling water and the Cooling Water System as a supporting function to the other KSFs. These systems are not specifically identified as unique KSFs in the NPO Model. The systems are included as a supporting function to other NPO systems / functions and/or equipment.
The initial identification of plant equipment required for NPO (i.e., NPO equipment) was performed from a review of the NPO flowpaths / systems / functions and equipment identified in the PINGP Operations Procedures. The NPO equipment was identified primarily from system and paths identified in 5AWI 15.6.1. Additional components were added as needed to support these paths and as necessary to provide success paths for fires occurring during the Higher Risk Evolutions (e.g. reduced inventory).
The identification of NPO equipment also included review of the PINGP Piping and Instrumentation Drawings to select: (1) electrically operated plant equipment whose active function would be required to support the associated NPO flowpaths / systems / functions, and (2) electrically operated plant equipment whose spurious operation could be adverse to the successful performance of the associated NPO flowpaths / systems / functions.
The functional attribute(s) required of each NPO component to support the associated NPO flowpaths / systems / functions were identified (i.e. Valve required to be open, to be closed, to remain operable, Motor Control Center required to be energized, Instrument Loop required available to provide reliable indication, etc.).
Most of the plant equipment that was determined to be required for the NPO Model was already included in the NFPA 805 at-power Nuclear Safety Performance Criteria (NSPC) Model and/or the Fire PRA Model. Furthermore, most of these components were determined to have been analyzed consistently with the functional attributes required for the associated NPO flowpath /
system / function (i.e., valve required to be operable for Fire PRA - same valve required to be operable for NPO). As such, most of the existing circuit analysis/cable selection for the NFPA 805 at-power NSPC Model and the Fire PRA Model was determined to be adequate for use in the NPO Model.
Circuit analysis/cable selection was performed for each NPO only component based on the functional attribute(s) required of each NPO component. The circuit analysis/cable selection identified the plant cable(s) required to remain free of fire damage in order for the NPO component to be credited as available in the subsequent NPO Analysis. The cable to equipment relationships were incorporated into the SAFE database as CABLE LOGIC.
PINGP                                                                         Page D Revision 1

Northern States Power Company            Attachment D - Non-Power Operational Modes Transition Each NPO only component and cable was assigned plant fire zone locations consistent with those already defined for the NFPA 805 at-power NSPC Model and the Fire PRA Model. All of the location information was entered into the SAFE database.
PINGP aligns with FAQ 07-0040 implementing guidance, F.2, Identify Components and Cables.
Reference Documents NEI 04-02, Guidance for Implementing a Risk-Informed, Performance Based Fire Protection Program Under 10 CFR 50.48(c), (Revision 2).
NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, (Revision 1).
FAQ 07-0040, Non-Power Operations Clarifications, (Revision 4, ML082070249).
EC-20612, Non-Power/NSCA Operations Review for NFPA 805.
5AWI 15.6.1, Shutdown Safety Assessment, (Revision 26).
National Fire Protection Association (NFPA) Standard 805-2001, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
PINGP                                                                     Page D Revision 1

Northern States Power Company                Attachment D - Non-Power Operational Modes Transition F.3 - Perform Fire Area Assessments (Identify pinch points)
Identify locations where:
* Fires may cause damage to the equipment (and cabling) credited above, or
* KSFs are achieved solely by crediting recovery actions, e.g., alignment of gravity feed.
Fire modeling may be used to determine if postulated fires in a fire area are expected to damage equipment (and cabling) thereby eliminating a pinch point.
To implement this guidance perform the following tasks:
* Determine if a single fire in the fire area can cause loss of success paths for a KSF.
* Conservatively, assume the entire contents of a fire area are lost. Document the loss of success paths. Specifically identify those areas that cause loss of all success paths for a KSF.
* If fire modeling is used to limit the damage in a fire area, document that fire modeling is credited and ensure the basis for acceptability of that model (location, type, and quantity of combustible, etc.) is documented. These critical design inputs should be maintained during outage modes. Fire modeling treatment should include an assessment of safety margin to account for uncertainties/accuracy of the fire model used.
Review A deterministic fire separation analysis (i.e., assuming full area burn) was performed as documented in PINGP Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805, to identify pinch points (i.e., areas where redundant equipment and cables credited for a given KSF fail due to fire damage). There is a total of fifty-eight (58) fire areas at the PINGP.
* Twenty-six (26) fire areas were found to have an adequate number of KSF success paths to survive the entire contents loss of the fire area.
* Thirty-two (32) fire areas were found to have pinch points resulting in the potential loss of one or more KSFs success paths.
Fire modeling was not utilized to eliminate identification of pinch point fire areas as part of the implementation process for the step F.3 guidance from FAQ 07-0040. PINGP aligns with FAQ 07-0040 implementing guidance, F.3, Perform Fire Area Assessments (Identify pinch points).
Reference Documents NEI 04-02, Guidance for Implementing a Risk-Informed, Performance Based Fire Protection Program Under 10 CFR 50.48(c), (Revision 2).
FAQ 07-0040, Non-Power Operations Clarifications, (Revision 4, ML082070249).
EC-20612, Non-Power/NSCA Operations Review for NFPA 805.
PINGP                                                                           Page D Revision 1

Northern States Power Company            Attachment D - Non-Power Operational Modes Transition NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, dated December 1991.
National Fire Protection Association (NFPA) Standard 805-2001, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants.
PINGP                                                                    Page D Revision 1

Northern States Power Company             Attachment D - Non-Power Operational Modes Transition F.4 - Manage Risks Associated with Fire-Induced Vulnerabilities During the Outage The nuclear safety goal is to provide reasonable assurance that a fire during any operational mode and plant configuration will not prevent the plant from achieving and maintaining the fuel in a safe and stable condition.
During those NPO evolutions where risk is relatively low, the normal fire protection program defense-in-depth actions are credited for addressing the risk impact of those fires that potentially impact one or more trains of equipment that provide a KSF required during non-power operations.
The following actions are considered to be adequate to address minor losses of system capability or redundancy during those NPO evolutions where risk is relatively low:
* Control of Ignition Sources o Hot Work (cutting, welding and/or grinding) o Temporary Electrical Installations o Electric portable space heaters
* Control of Combustibles o Transient fire hazards o Modifications o Flammable and Combustible liquids and gases
* Compensatory Actions for fire protection system impairments o Openings in fire barriers o Inoperable fire detectors or detection systems o Inoperable fire suppression systems o Housekeeping As required by NFPA 805 Chapter 3, the Fire Protection Program defense-in-depth administrative programs described above are in place during all NPO modes.
During those NPO evolutions that are defined as HREs:
Additional fire protection defense in depth measures will be taken during HREs by:
* Managing risk in fire areas that contain known pinch points (all success paths for a KSF subject to damage by a fire).
* Managing risk in fire areas where the pinch points may arise because of equipment taken out of service.
NUMARC 91-06 discusses the development of outage plans and schedules. A key element of that process is to ensure the KSFs perform as needed during the various outage evolutions.
During outage planning, the NPO Fire Area Assessment should be reviewed to identify areas of single-point KSF vulnerability during higher risk evolutions to develop any needed contingency PINGP                                                                        Page D Revision 1

Northern States Power Company               Attachment D - Non-Power Operational Modes Transition plans/actions. For those areas consider combinations of the following options to reduce fire risk, depending upon the significance of the potential damage:
* Prohibition or limitation of hot work in fire areas during periods of increased vulnerability.
* Verification of operable detection and /or suppression in the vulnerable areas.
* Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability.
* Plant configuration changes (e.g., removing power from equipment once it is placed in its desired position).
* Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.
* Use of recovery actions to mitigate potential losses of key safety functions.
* Identification and monitoring in-situ ignition sources for fire precursors (e.g., equipment temperatures).
* Reschedule the work to a period with lower risk or higher DID.
In addition, for KSF Equipment removed from service during the HREs the impact should be evaluated based on KSF equipment status and the NPO Fire Area Assessment to develop needed contingency plans/actions.
Review A KSF pinch point analysis was performed for all PINGP fire areas in accordance with NFPA 805 and NRC FAQ 07-0040 Rev. 4 guidance. For fire areas where the pinch point analysis identified areas of single-point KSF vulnerability and higher risk, combinations of the following options to reduce fire risk were considered, depending upon the significance of the potential damage:
* Prohibition or limitation of hot work in fire areas during periods of increased vulnerability.
* Verification of operable fire detection and /or suppression in the vulnerable areas.
* Prohibition or limitation of combustible materials in fire areas during periods of increased vulnerability.
* Plant configuration changes (e.g., removing power from equipment once it is placed in its desired position).
* Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.
* Use of recovery actions to mitigate potential losses of key safety functions.
* Identification and monitoring in-situ ignition sources for fire precursors (e.g., equipment temperatures).
* Reschedule the work to a period with lower risk or higher DID.
Note: Operator actions taken to mitigate the loss of a KSF are credited in the NPO analysis contained within PINGP Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805, contemporaneous with this LAR submittal.
PINGP                                                                            Page D Revision 1

Northern States Power Company                Attachment D - Non-Power Operational Modes Transition PINGP procedure 5AWI 3.13.0, Fire Protection Program, will be revised to contain an overview of the NPO requirements, the commitments for implementation of the NPO risk reduction actions required by PINGP Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805, and a road map to identify the site specific implementing procedures used to implement the NPO requirements. Additional fire protection procedures that will be revised to implement NPO requirements include the following (See Attachment S):
* 5AWI 3.13.3, Hot Work, contains controls to establish fire watches for the hot work activities including all plant operating states within the NPO.
* F5 Appendix K, Fire Protection Systems Functional Requirements contains the compensatory actions to be implemented should a fire protection system required to be operable during HRE periods be found to be impaired.
* EM 3.4.1, Review of Proposed Changes to the Fire Protection Program contains guidance to ensure that changes to the fire protection program are reviewed for impact to the NPO requirements and risk reduction actions.
* 5AWI 15.6.1, Shutdown Safety Assessment, contains discussion on HREs, NFPA 805 and the NPO requirements as part of risk management.
Guidance is contained within the outage control procedures to ensure that upon entry into the NPO plant operating states the outage roving fire watches are established. No specific requirements are necessary for the hot work controls because they are in place in all plant operating states. Additional guidance and controls are in place to ensure the HRE risk reduction tools are implemented prior to entry into a plant HRE. Guidance is also in place to monitor the plant state (T-Boil Times) to determine when the HRE is exited. PINGP outage procedures that will be revised to implement NPO guidance include the following (see Attachment S):
* 1C1.6, Shutdown Operations - Unit 1, revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
* 2C1.6, Shutdown Operations - Unit 2, revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
* 1C4.1, RCS Inventory Control Pre-refueling, revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
* 2C4.1, RCS Inventory Control Pre-refueling, revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
* 1C4.2, RCS Inventory Control - Post Refueling revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
PINGP                                                                       Page D Revision 1

Northern States Power Company          Attachment D - Non-Power Operational Modes Transition
* 2C4.2, RCS Inventory Control - Post Refueling revise to contain a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.
* H24.1, Assessment and Management of Risk Associated With Maintenance Activities, contains guidance to consider potential system unavailability as a result of a fire when developing a Key Safety Function Availability Checklist for a plant configuration change.
Reference Documents NEI 04-02, Guidance for Implementing a Risk-Informed, Performance Based Fire Protection Program Under 10 CFR 50.48(c). (Revision 2).
FAQ 07-0040, Non-Power Operations Clarifications, (Revision 4, ML082200528).
PINGP 5AWI 3.13.0, Fire Protection Program, (Revision 21).
5AWI 3.13.3, Hot Work, (Revision 3).
F5 Appendix K, Fire Protection Systems Functional Requirements (Revision 15).
EM 3.4.1, Review of Proposed Changes to the Fire Protection Program (Revision 2).
5AWI 15.6.1, Shutdown Safety Assessment, (Revision 26).
1C1.6, Shutdown Operations - Unit 1, (Revision 24).
2C1.6, Shutdown Operations - Unit 2, (Revision 25).
1C4.1, RCS Inventory Control Pre-refueling, (Revision 26).
2C4.1, RCS Inventory Control Pre-refueling, (Revision 31).
1C4.2, RCS Inventory Control - Post Refueling, (Revision 29).
2C4.2, RCS Inventory Control - Post Refueling, (Revision 30).
H24.1, Assessment and Management of Risk Associated With Maintenance Activities, (Revision 15).
PINGP Engineering Evaluation EC-20612, Non-Power/NSCA Operations Review for NFPA 805.
PINGP                                                                      Page D Revision 1

Northern States Power - Minnesota            Attachment E - Radioactive Release Transition E. NEI 04-02 Radioactive Release Transition 36 Pages Attached PINGP                                                                Page E Revision 1

Northern States Power - Minnesota                       Attachment E - Radioactive Release Transition Fire Area Compartmentation and Screening The PINGP Radiation Release evaluation is performed and documented on a Fire Area basis.
This screening step is provided to evaluate each fire area and determine if the fire area is within scope of this evaluation based on the potential for radiological release in the event of a fire within the fire area. A fire area is either screened in when it affects radiological release or is screened out when it cannot affect radiological release. Attachment E identifies the results of the fire area screening.
Attachment E is a combination of Table E-1, Radioactive Release Compartment Review, and Table E-2, Radioactive Release Transition Engineered Controls Review, from the LAR Template. The requisite information and content from LAR Template Tables E-1 and E-2 is provided in Attachment E.
Attachment E provides reference to Attachment S for the implementation items that will result in compliance with the requirements of NFPA 805 and the guidance in NEI 04-02 and RG 1.205.
The implementation items consist of:
* Revisions to the fire fighting strategies to identify potential cross-contamination issues for each applicable fire area and fire detection zone.
* Revisions to the fire fighting strategies and fire brigade lesson plans to provide additional instructions on the control of the spread of contamination as a result of fire fighting activities.
* Revisions to the fire fighting strategies to address control of contaminated smoke and water runoff in areas without installed, or with non-functioning, filtered ventilation controls or filtered drainage using a combination of filtered ventilation in adjacent areas, portable filtered ventilation equipment and booms to contain water spread based on input from radiation protection personnel to the fire brigade personnel.
* A combination of containerization and administrative controls will be used to limit the amount of exposed contaminated combustible materials in areas without filtered ventilation or where the spread of contaminated water to adjacent radiologically controlled areas, radiologically clean areas or to the exterior are potential concerns.
Refer to Section 4.4, Radiological Release Performance Criteria, and Attachment S for details.
PINGP                                                                             Page E Revision 1

Northern States Power - Minnesota                                                                Attachment E - Radioactive Release Transition Fire                         Fire Strategies   Screened Engineering Controls                       Training Review Description                                                                                                       Conclusions Area                         Detection Zones      In?   Liquid             Airborne                Results 1    Containment Unit 1     Det. Zone 10        Yes    Floor drains to    Containment             Upon completion of   Based on use of revised
* U1 Rx Bldg 697          Containment        Internal Cleanup        implementation items fire strategies and training Sump, then         Subsystem               identified in        materials (to be Det. Zone 20               pumped to Aux      recirculates and        Attachment S, fire   completed as identified in
* U1 Rx Bldg 711          Bldg Aerated       filters air for Modes   brigade training     Attachment S), the Drains System. 1, 2, 3, 4.             materials will meet  PINGP approach will Det. Zone 29               Liquid is treated,                         NFPA radioactive     meet NFPA 805
* U1 Rx Bldg 733          filtered,          Containment Purge       release performance  radioactive release processed and      and In-Service          criteria             performance criteria.
Det. Zone 32               sampled before     Purge Systems
* U1 Rx Bldg 755          release.           filter air prior to exhaust through U1 Shield Building Stack for Modes 5 and 6.
Containment Annulus    Det. Zone 21               Liquids drain to Unit 1                 U1 Cntmt Annulus           sumps in floor     Shield Building and transferred    Ventilation System (Previously identified                            to Aux Bldg        recirculates air in as Fire Area 68)                                  Aerated Drain      annulus and System. Liquid     maintains negative is treated,        pressure.
filtered, processed and      In exhaust mode, sampled before     Shield Building release. Under     Ventilation System accident           filters air before conditions,        exhausting through liquids            Shield Building vent transferred to     stack.
Containment Sump.
PINGP                                                                                                                     Page E Revision 1

Northern States Power - Minnesota                                                              Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                       Training Review Description                                                                                                     Conclusions Area                       Detection Zones      In?   Liquid             Airborne                Results 2    Ventilation Fan Room Det. Zone 30        Yes    Floor drains       Auxiliary Building      Upon completion of   Based on use of revised
* Unit 1 Aux Bldg          route to Aerated Ventilation System        implementation items fire strategies and training 755 SFP & Fuel          Drains System. maintains negative      identified in        materials (to be Receipt Area             Liquid is treated, pressure. Air is        Attachment S, fire   completed as identified in filtered,          monitored prior to      brigade training     Attachment S), the Det. Zone 108              processed and      release. The            materials will meet  PINGP approach will
* Aux Bldg                 sampled before     control room can        NFPA radioactive     meet NFPA 805 Elevator                 release.           turn off the            release performance  radioactive release Auxiliary Building      criteria             performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
3    Water Chiller Room,  Det. Zone 31        Yes    Floor drains       Chiller rooms are       Upon completion of   Based on use of revised Unit 1
* 121 & 122 Cont           route to Aerated   part of the Control     implementation items fire strategies and training Rm Chiller Aux           Drains System. Room Habitability       identified in        materials (to be Bldg 755                Liquid is treated, Envelope and have       Attachment S, fire   completed as identified in filtered,          internal air handling   brigade training     Attachment S), the processed and      unit during             materials will meet  PINGP approach will sampled before     operations and a        NFPA radioactive     meet NFPA 805 release.           closed loop             release performance  radioactive release cleanup system          criteria             performance criteria.
during an accident.
PINGP                                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                           Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                    Training Review Description                                                                                                  Conclusions Area                       Detection Zones      In?   Liquid             Airborne             Results 4    Fuel Handling Area   Det. Zone 8         Yes    Floor drains       No ventilation.      Upon completion of   Revised fire strategies (to
* U1 695 Aux              route to Aerated Potential transfer of  implementation items be completed as Bldg                     Drains System. contaminated         identified in        identified in Attachment Liquid is treated, smoke to adjacent    Attachment S, fire   S) will incorporate Det. Zone 33               filtered,          areas and to         brigade training     mitigative actions to filter
* Fuel Loading &           processed and      exterior.            materials will meet  potentially contaminated Spent Fuel Area          sampled before                          NFPA radioactive     smoke based on release.                                release performance  radiological conditions Det. Zone 30                                                       criteria             identified during the
* Unit 1 Aux Bldg                                                                       conduct of fire fighting 755 SFP & Fuel                                                                       activities.
Receipt Area Based on use of revised Waterflow: 9                                                                            fire strategies and training
* Unit 1 695 Aux                                                                       materials (to be Bldg                                                                                  completed as identified in Attachment S), the PINGP approach will meet NFPA 805 radioactive release performance criteria.
PINGP                                                                                                                Page E Revision 1

Northern States Power - Minnesota                                                Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                      Conclusions Area                       Detection Zones     In?   Liquid           Airborne     Results 5    Old Admin Building   Det. Zone 13        No    N/A              N/A          N/A                 This area is outside of the
* Turb Floor                                                                permanent RCA and is Storage &                                                                 not used for permanent or Chem Storage                                                              temporary storage of Room, Halon                                                               radiological materials. A Records Vault                                                             fire in this area will not result in radiological Det. Zone 90                                                                release.
* OAB Floor 1 Det. Zone 91
* OAB West Elevator, Stairwell Det. Zone 93
* OAB Floors 2, 3, 4 Det. Zone 105
* OAB East Elevator Det. Zone 106
* OAB West Elevator 6    Old Admin Bldg       Det. Zone 55        No    N/A              N/A          N/A                 This area is outside of the HVAC Equip Area
* OAB HVAC                                                                  permanent RCA and is Equipment 750                                                            not used for permanent or temporary storage of Det. Zone 66                                                                radiological materials. A
* OAB 735 &                                                                fire in this area will not 750                                                                      result in radiological release.
PINGP                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                  Attachment E - Radioactive Release Transition Fire                        Fire Strategies   Screened Engineering Controls          Training Review Description                                                                                        Conclusions Area                        Detection Zones      In?   Liquid           Airborne     Results 7    Old Admin Bldg Office Det. Zone 23         No    N/A              N/A          N/A                 This area is outside of the Area
* OAB I&C, Tech                                                              permanent RCA and is Support, 735 &                                                            not used for permanent or 750                                                                       temporary storage of radiological materials. A Det. Zone 66                                                                 fire in this area will not OAB 735 &                                                                   result in radiological HVAC Penthouse                                                               release.
750 Det. Zone 91
* OAB West Elevator, Stairwell Det. Zone 105
* OAB East Elevator Det. Zone 106 OAB West Elevator PINGP                                                                                                      Page E Revision 1

Northern States Power - Minnesota                                                            Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                     Training Review Description                                                                                                   Conclusions Area                       Detection Zones      In?   Liquid           Airborne                Results 8    Turbine Deck         Det. Zone 24        Yes    Floor drains to  Turbine Building        Upon completion of   The only contaminated
* U1 Turb Gen              Turbine Building Ventilation System,     implementation items area within Fire Area 8 is Brg Prot Pnl             Sump, part of    which is not filtered. identified in        the location of the spare Waste Liquid                             Attachment S, fire   RCP motor on the 735ft Det. Zone 49               Treatment                                brigade training     elevation of the Unit 2
* Turbine Bearing          System. Liquid                           materials will meet  Turbine Deck. An area of Protection Unit          sampled prior to                         NFPA radioactive     approximately 10ft by 10ft 2 El. 735               release.                                 release performance  around the spare RCP is criteria             marked and barricaded Det. Zone 107                                                                            as a contaminated area.
* Turb/Service Building                                                                               The potential for Elevator                                                                               contaminated smoke or contaminated water due to firefighting activities in this location is considered negligible. However, revised fire strategies will incorporate mitigating actions to utilize booms to contain the flow of potentially contaminated water to balance of the Turbine Deck, and to utilize portable exhaust equipment with HEPA filters to filter potentially contaminated smoke based on radiation protection input to fire brigade on radiological conditions.
Based on use of revised fire strategies and training materials (to be completed as identified in Attachment S), the PINGP approach will meet NFPA 805 radioactive release performance criteria.
PINGP                                                                                                                 Page E Revision 1

Northern States Power - Minnesota                                                Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                      Conclusions Area                       Detection Zones     In?   Liquid           Airborne     Results 9    Maintenance Shops    Det. Zone 107       No    N/A              N/A          N/A                 This area is outside of the
* Turb/Service                                                              permanent RCA and is Building                                                                  not used for permanent or Elevator                                                                  temporary storage of radiological materials. A Det. Zone 27                                                                fire in this area will not
* Machine Shops,                                                            result in radiological 735                                                                      release.
10   A Train Event      Det. Zone 26        No    N/A              N/A          N/A                 This area is outside of the Monitoring Room
* 480V Swgr 112                                                             permanent RCA and is Bus Rm & Trn A                                                            not used for permanent or Em Room                                                                   temporary storage of radiological materials. A fire in this area will not result in radiological release.
11   Unit 1 Normal SWGR   Det. Zone 87        No    N/A              N/A          N/A                 This area is outside of the
        & Control Rod Drive
* U1 Rod Drive                                                              permanent RCA and is Room                   Room                                                                      not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
12   OSC Room             Det. Zone 25        No    N/A              N/A          N/A                 This area is outside of the
* Records Room                                                              permanent RCA and is
                               & Hot Instr                                                               not used for permanent or Shop                                                                      temporary storage of radiological materials. A Waterflow: 18                                                               fire in this area will not
* Lndry, Chem &                                                             result in radiological Inst Labs or                                                              release.
Records Room 13   Control Room         Det. Zone 57        No    N/A              N/A          N/A                 This area is outside of the
* Control Room                                                              permanent RCA and is U1 & U2                                                                   not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                            Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls                      Training Review Description                                                                                                    Conclusions Area                       Detection Zones     In?   Liquid             Airborne               Results 14   Working Material &   Det. Zone 15        No    N/A                N/A                    N/A                   This area is outside of the Lunch Room
* U1 Turb Bldg                                                                            permanent RCA and is 715, Locker                                                                            not used for permanent or Room, Lunch                                                                             temporary storage of Room, Serv                                                                              radiological materials. A Bldg Stairway,                                                                          fire in this area will not Fan Rm, &                                                                               result in radiological Work Area                                                                               release.
15   Access Control       Det. Zone 17       Yes    Floor drains       Auxiliary Building     Upon completion of    Revised fire strategies
* Access Control          route to Aerated   Ventilation System     implementation items  will incorporate mitigative Drains System. maintains negative     identified in         actions to utilize booms to Waterflow: 18             Liquid is treated, pressure. Air is       Attachment S, fire    prevent flow of potentially
* Lndry, Chem &           filtered,          monitored prior to     brigade training      contaminated water Inst Labs or            processed and      release. The           materials will meet   between the potentially Records Room            sampled before     control room can       NFPA radioactive      contaminated and clean release.           turn off the           release performance   portions of Access However, there     Auxiliary Building     criteria              Control.
are no barriers    Exhaust and Make-to water spread    Up Fans from the                             Based on use of revised between the        control room to                              fire strategies and training potentially        prevent gaseous                              materials (to be contaminated       effluent from                                completed as identified in and clean          escaping.                                    Attachment S), the portions of                                                     PINGP approach will Access Control. Auxiliary Building                           meet NFPA 805 Special Ventilation                          radioactive release System Air is                                performance criteria.
filtered prior to release.
16   Train B Event        Det. Zone 50        No    N/A                N/A                    N/A                   This area is outside of the Monitoring Equipment
* 480V Swgr 122                                                                           permanent RCA and is Room                   Bus Rm & Trn A                                                                          not used for permanent or Em Room                                                                                 temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                                 Page E Revision 1

Northern States Power - Minnesota                                                 Attachment E - Radioactive Release Transition Fire                        Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                       Conclusions Area                        Detection Zones     In?   Liquid           Airborne     Results 17   Unit 2 Normal SWGR    Det. Zone 88        No    N/A              N/A          N/A                 This area is outside of the
        & Control Rod Drive
* Rod Control                                                               permanent RCA and is Room                    Room Unit 2                                                               not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
18   Relay & Cable         Det. Zone 12        No    N/A              N/A          N/A                 This area is outside of the Spreading Room
* Relay & Cable                                                             permanent RCA and is Units 1 & 2             Spreading Rm                                                              not used for permanent or Units 1 & 2                                                               temporary storage of radiological materials. A Det. Zone 14                                                                fire in this area will not
* Old Computer                                                              result in radiological Room                                                                      release.
20   Unit 1 4.16 kV        Det. Zone 11        No    N/A              N/A          N/A                 This area is outside of the Safeguards SWGR
* Bus Rms 15 &                                                              permanent RCA and is (Bus 16)                16 Unit 1 715                                                            not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
21   Unit 1 4.16 kV Normal Det. Zone 84        No    N/A              N/A          N/A                 This area is outside of the SWGR (Bus 13, 14)
* Bus Rms 13 &                                                              permanent RCA and is 14 Unit 1 715                                                            not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
22   480 V Safeguards      Det. Zone 43        No    N/A              N/A          N/A                 This area is outside of the SWGR (Bus 121)
* 480V Bus 111                                                              permanent RCA and is and 121 715                                                              not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                 Attachment E - Radioactive Release Transition Fire                        Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                       Conclusions Area                        Detection Zones     In?   Liquid           Airborne     Results 23   Unit 2 4.16 kV Normal Det. Zone 86        No    N/A              N/A          N/A                 This area is outside of the SWGR (Bus 23, 24)
* Normal                                                                    permanent RCA and is Switchgear Bus                                                            not used for permanent or 23 & 24                                                                   temporary storage of radiological materials. A fire in this area will not result in radiological release.
24   Oil Storage Area      Det. Zone 4         No    N/A              N/A          N/A                 This area is outside of the
* U1 695 Turb                                                               permanent RCA and is Bldg                                                                      not used for permanent or temporary storage of Waterflow: 5                                                                radiological materials. A
* U1 695 Turb                                                               fire in this area will not result in radiological Bldg release.
25   Diesel Generator      Det. Zone 82        No    N/A              N/A          N/A                 This area is outside of the Room 1
* D1 Diesel Gen                                                             permanent RCA and is Rm                                                                        not used for permanent or temporary storage of Waterflow: 7                                                                radiological materials. A
* D1 & D2 Rooms                                                             fire in this area will not result in radiological release.
26   Diesel Generator      Det. Zone 6         No    N/A              N/A          N/A                 This area is outside of the Room 2
* D2 Diesel Gen                                                             permanent RCA and is Rm                                                                        not used for permanent or temporary storage of Waterflow: 7                                                                radiological materials. A
* D1 & D2 Rooms                                                             fire in this area will not result in radiological release.
27   Water Conditioning    Det. Zone 4         No    N/A              N/A          N/A                 This area is outside of the Equipment Area
* U1 695 Turb                                                               permanent RCA and is Bldg                                                                      not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                               Attachment E - Radioactive Release Transition Fire                       Fire Strategies Screened Engineering Controls          Training Review Description                                                                                     Conclusions Area                       Detection Zones    In?   Liquid           Airborne     Results 28a   1GT Transformer      Det. Zone 58       No    N/A              N/A          N/A                 This area is outside of the
* 1GT                                                                      permanent RCA and is not used for permanent or Waterflow: 76                                                              temporary storage of
* 1GT                                                                      radiological materials. A fire in this area will not result in radiological release.
28b   2GT Transformer      Det. Zone 60       No    N/A              N/A          N/A                 This area is outside of the
* 2GT                                                                      permanent RCA and is not used for permanent or Waterflow: 78                                                              temporary storage of
* 2GT                                                                      radiological materials. A fire in this area will not result in radiological release.
28c   1R Transformer       Det. Zone 62       No    N/A              N/A          N/A                 This area is outside of the
* 1R                                                                       permanent RCA and is not used for permanent or Waterflow: 80                                                              temporary storage of
* 1R                                                                       radiological materials. A fire in this area will not result in radiological release.
28d   1M Transformer       Det. Zone 59       No    N/A              N/A          N/A                 This area is outside of the
* 1M                                                                       permanent RCA and is not used for permanent or Waterflow: 77                                                              temporary storage of
* 1M                                                                       radiological materials. A fire in this area will not result in radiological release.
28e   2M Transformer       Det. Zone 61       No    N/A              N/A          N/A                 This area is outside of the
* 2M                                                                       permanent RCA and is not used for permanent or Waterflow: 79                                                              temporary storage of
* 2M                                                                       radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                 Page E Revision 1

Northern States Power - Minnesota                                               Attachment E - Radioactive Release Transition Fire                       Fire Strategies Screened Engineering Controls          Training Review Description                                                                                     Conclusions Area                       Detection Zones    In?   Liquid           Airborne     Results 28f  2RX/Y Transformer    Det. Zone 96       No    N/A              N/A          N/A                 This area is outside of the
* 2RX/Y                                                                    permanent RCA and is not used for permanent or Waterflow: 95                                                              temporary storage of
* 2RX/Y                                                                    radiological materials. A fire in this area will not result in radiological release.
29   Admin Bldg Elec. &   Det. Zone 4        No    N/A              N/A          N/A                 This area is outside of the Piping Room 1
* U1 695 Turb                                                              permanent RCA and is Bldg                                                                     not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
30   Admin Bldg Elec. &   Det. Zone 4        No    N/A              N/A          N/A                 This area is outside of the Piping Room 2
* U1 695 Turb                                                              permanent RCA and is Bldg                                                                     not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
31   A Train Hot        Det. Zone 2        No    N/A              N/A          N/A                 This area is outside of the Shutdown Panel & Air
* Air Cmprsr &                                                             permanent RCA and is Compressor /           Aux Feed Pmp                                                             not used for permanent or Auxiliary Feedwater    Room                                                                     temporary storage of Pump Room                                                                                       radiological materials. A fire in this area will not result in radiological release.
32   B Train Hot        Det. Zone 2        No    N/A              N/A          N/A                 This area is outside of the Shutdown Panel & Air
* Air Cmprsr &                                                             permanent RCA and is Compressor /           Aux Feed Pmp                                                             not used for permanent or Auxiliary Feedwater    Room                                                                     temporary storage of Pump Room                                                                                       radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                 Page E Revision 1

Northern States Power - Minnesota                                                 Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls          Training Review Description                                                                                       Conclusions Area                       Detection Zones      In?   Liquid           Airborne     Results 33   Battery Room 11      Det. Zone 1          No    N/A              N/A          N/A                 This area is outside of the
* 11 & 12 Batt                                                               permanent RCA and is Rms Turb Bldg                                                              not used for permanent or 695                                                                       temporary storage of radiological materials. A fire in this area will not result in radiological release.
34   Battery Room 12      Det. Zone 1          No    N/A              N/A          N/A                 This area is outside of the
* 11 & 12 Batt                                                               permanent RCA and is Rms Turb Bldg                                                              not used for permanent or 695                                                                       temporary storage of radiological materials. A fire in this area will not result in radiological release.
35   Battery Room 21      Det. Zone 35         No    N/A              N/A          N/A                 This area is outside of the
* 21 & 22 Battery                                                            permanent RCA and is Rooms                                                                      not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
36   Battery Room 22      Det. Zone 35         No    N/A              N/A          N/A                 This area is outside of the
* 21 & 22 Battery                                                            permanent RCA and is Rooms                                                                      not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
37   480V Normal SWGR     Det. Zone 83         No    N/A              N/A          N/A                 This area is outside of the Room Unit 1
* Bus Rms 150 &                                                              permanent RCA and is 160 Unit 1 695                                                             not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                            Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls                      Training Review Description                                                                                                    Conclusions Area                       Detection Zones     In?   Liquid           Airborne                 Results 38   480V Normal SWGR     Det. Zone 85        No    N/A              N/A                      N/A                   This area is outside of the Room Unit 2
* Normal                                                                                  permanent RCA and is Switchgear Bus                                                                          not used for permanent or 250 & 260                                                                               temporary storage of radiological materials. A fire in this area will not result in radiological release.
39   Rad Waste Building   Det. Zone 34       Yes    Floor drains to  Radwaste Building        Upon completion of    Based on use of revised
* Rad Waste &             Radwaste         Ventilation filters air  implementation items  fire strategies and training Resin Disposal          Building Sumps,  prior to release.        identified in         materials (to be El. 695                collected in                              Attachment S, fire    completed as identified in tanks, filtered,                          brigade training      Attachment S), the Det. Zone 81              processed and                             materials will meet   PINGP approach will
* Rad Waste &             sampled prior to                          NFPA radioactive      meet NFPA 805 Resin Disposal          release.                                  release performance   radioactive release El. 695 & El.                                                    criteria              performance criteria.
715 40   Maintenance Storage    Det. Zone -       No    N/A              N/A                      N/A                   This area is outside of the Shed                   None                                                                                    permanent RCA and is not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                                 Page E Revision 1

Northern States Power - Minnesota                                                   Attachment E - Radioactive Release Transition Fire                        Fire Strategies    Screened Engineering Controls          Training Review Description                                                                                         Conclusions Area                        Detection Zones       In?   Liquid           Airborne     Results 41   Screenhouse           None                  No    N/A              N/A          N/A                 This area is outside of the (General Area)                                                                                      permanent RCA and is not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
41A   Screenhouse           Det. Zone 74          No    N/A              N/A          N/A                 This area is outside of the (DDCWP Rooms)
* Plant Screen                                                                permanent RCA and is House El. 670                                                              not used for permanent or temporary storage of Det. Zone 75                                                                  radiological materials. A
* Plant Screen                                                                fire in this area will not House El. 695                                                              result in radiological release.
Waterflow: 63
* Screen House 41B   Screenhouse           Det. Zone 75          No    N/A              N/A          N/A                 This area is outside of the (Basement)
* Plant Screen                                                                permanent RCA and is House El. 695                                                              not used for permanent or temporary storage of Waterflow: 63                                                                 radiological materials. A
* Screen House                                                                fire in this area will not result in radiological release.
   --   Cooling Tower Pump    Det. Zone 71          No    N/A              N/A          N/A                 This area is outside of the House (CTPH)
* CTPH, CTEH,                                                                 permanent RCA and is Warehouse 1,                                                                not used for permanent or Construction /                                                              temporary storage of Fab Shop                                                                    radiological materials. A fire in this area will not result in radiological release.
   --   Fuel Oil and Transfer Det. Zone 72          No    N/A              N/A          N/A                 This area is outside of the House
* Fuel Oil &                                                                  permanent RCA and is Transfer House                                                              not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                     Page E Revision 1

Northern States Power - Minnesota                                                Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                      Conclusions Area                       Detection Zones     In?   Liquid           Airborne     Results 46   Cooling Tower        Det. Zone 71        No    N/A              N/A          N/A                 This area is outside of the Equipment House
* CTPH, CTEH,                                                               permanent RCA and is (CTEH)                 Warehouse 1,                                                              not used for permanent or Construction /                                                            temporary storage of Fab Shop                                                                  radiological materials. A fire in this area will not result in radiological release.
46A   Cooling Tower        None                No    N/A              N/A          N/A                 This area is outside of the Transformers                                                                                     permanent RCA and is not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
   --   121/122 CLG Tower    Det. Zone 68        No    N/A              N/A          N/A                 This area is outside of the Control House
* Cooling Tower                                                             permanent RCA and is Control House                                                             not used for permanent or 121/122                                                                   temporary storage of radiological materials. A fire in this area will not result in radiological release.
   --   Waste Neutralizing   Det. Zone 92        No    N/A              N/A          N/A                 This area is outside of the Tank Pump House /
* Neut Tk House                                                             permanent RCA and is Warehouse 2            & Whse #2                                                                 not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
   --   123/124 CLG Tower    Det. Zone 69        No    N/A              N/A          N/A                 This area is outside of the Control House
* Cooling Tower                                                             permanent RCA and is Control House                                                             not used for permanent or 123/124                                                                   temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                               Attachment E - Radioactive Release Transition Fire                          Fire Strategies  Screened Engineering Controls                      Training Review Description                                                                                                       Conclusions Area                          Detection Zones     In?   Liquid             Airborne               Results
   --   Main Warehouse 1        Det. Zone 71        No    N/A                N/A                    N/A                   This area is outside of the and Fab Shop
* CTPH, CTEH,                                                                             permanent RCA and is Warehouse 1,                                                                            not used for permanent or Construction /                                                                          temporary storage of Fab Shop                                                                                radiological materials. A fire in this area will not result in radiological release.
57   Hydrogen House          Det. Zone 4         No    N/A                N/A                    N/A                   This area is outside of the
* U1 695 Turb                                                                             permanent RCA and is Bldg                                                                                    not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
58   Aux Building Ground     Det. Zone 8        Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Floor Unit 1 & Unit 2
* U1 695 Aux             route to Aerated   Ventilation System     implementation items  fire strategies and training Bldg                    Drains System. maintains negative     identified in         materials (to be (Unit 2 was previously                            Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in identified as Fire Area Waterflow: 9              filtered,          monitored prior to     brigade training      Attachment S), the
: 73)
* U1 695 Aux             processed and      release. The           materials will meet   PINGP approach will Bldg                    sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Det. Zone 40                                 Auxiliary Building     criteria              performance criteria.
* U2 695 Aux                                Exhaust and Make-Bldg                                       Up Fans from the control room to Det. Zone 108                                prevent gaseous
* Aux Bldg                                   effluent from Elevator                                   escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
PINGP                                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                                 Attachment E - Radioactive Release Transition Fire                          Fire Strategies    Screened Engineering Controls                      Training Review Description                                                                                                         Conclusions Area                          Detection Zones       In?   Liquid             Airborne               Results 59   Aux Building            Det. Zone 19         Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Mezzanine Floor Unit
* U1 715 Aux               route to Aerated Ventilation System       implementation items  fire strategies and training 1 & Unit 2                Bldg                      Drains System. maintains negative     identified in         materials (to be Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in (Unit 2 was previously  Waterflow: 22               filtered,          monitored prior to     brigade training      Attachment S), the identified as Fire Area
* U1 715 Aux               processed and      release. The           materials will meet   PINGP approach will
: 74)                       Bldg                      sampled before     control room can       NFPA radioactive      meet NFPA 805 Penetrations              release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Waterflow: 41                                  Exhaust and Make-
* Auxiliary                                    Up Fans from the Building Unit 2                              control room to
                                  & D-3 Storage                                prevent gaseous Room                                         effluent from escaping.
Det. Zone 46
* Auxiliary                                    Auxiliary Building Building Unit 2                              Special Ventilation El. 715                                     System Air is filtered prior to Waterflow: 48                                  release.
Annulus Penetration Unit 2 Det. Zone 108
* Aux Bldg Elevator PINGP                                                                                                                      Page E Revision 1

Northern States Power - Minnesota                                                             Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                      Training Review Description                                                                                                     Conclusions Area                       Detection Zones      In?   Liquid             Airborne               Results 60   Aux Building         Det. Zone 28        Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Operating Level Unit
* Unit 1 Aux Bldg          route to Aerated Ventilation System       implementation items  fire strategies and training 1                      735                     Drains System. maintains negative     identified in         materials (to be Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in Det. Zone 108              filtered,          monitored prior to     brigade training      Attachment S), the
* Aux Bldg                 processed and      release. The           materials will meet   PINGP approach will Elevator                 sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
61   Aux Bldg Anti C    Det. Zone 28        Yes    Floor drains       Laundry Room           Upon completion of    Revised fire strategies (to Clothing Area
* Unit 1 Aux Bldg          route to Aerated   Filters and Exhaust    implementation items  be completed as 735                     Drains System. Fan can be             identified in         identified in Attachment Liquid is treated, operated locally to    Attachment S, fire    S) will incorporate Waterflow: 103             filtered,          prevent gaseous        brigade training      mitigative actions to filter
* E/W Demin                processed and      effluent from          materials will meet   potentially contaminated Removal Area             sampled before     escaping.              NFPA radioactive      smoke based on release.                                  release performance   radiological conditions criteria              identified during the conduct of fire fighting activities.
Based on use of revised fire strategies and training materials (to be completed as identified in Attachment S), the PINGP approach will meet NFPA 805 radioactive release performance criteria.
PINGP                                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                             Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                      Training Review Description                                                                                                     Conclusions Area                       Detection Zones      In?   Liquid             Airborne               Results 61A   Aux. Bldg Hatch Area Det. Zone 30        Yes    Floor drains       No ventilation.        Upon completion of    Revised fire strategies (to
* Unit 1 Aux Bldg          route to Aerated Potential transfer of    implementation items  be completed as 755 SFP & Fuel          Drains System. contaminated           identified in         identified in Attachment Receipt Area             Liquid is treated, smoke to adjacent      Attachment S, fire    S) will incorporate filtered,          areas and to           brigade training      mitigative actions to filter Det. Zone 53               processed and      exterior.              materials will meet   potentially contaminated
* Auxiliary                sampled before                            NFPA radioactive      smoke based on Building Unit 2          release.                                  release performance   radiological conditions
                               & West Side                                                        criteria              identified during the Fuel Handling                                                                            conduct of fire fighting Area El. 755                                                                            activities.
Based on use of revised fire strategies and training materials (to be completed as identified in Attachment S), the PINGP approach will meet NFPA 805 radioactive release performance criteria.
62   Spent Fuel Pool Area Det. Zone 30        Yes    No drains. Floor   Spent Fuel Pool        Upon completion of    Based on use of revised
* Unit 1 Aux Bldg          drains in          Normal Ventilation     implementation items  fire strategies and training 755 SFP & Fuel          adjacent areas     System filters air     identified in         materials (to be Receipt Area             route to Aerated   prior to release.      Attachment S, fire    completed as identified in Drains System.                            brigade training      Attachment S), the Liquid is treated, Spent Fuel Pool        materials will meet   PINGP approach will filtered,          Special Ventilation    NFPA radioactive      meet NFPA 805 processed and      System filters air     release performance   radioactive release sampled before     before exhausting      criteria              performance criteria.
release.           through Shield Building vent stack.
PINGP                                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                              Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                       Training Review Description                                                                                                      Conclusions Area                       Detection Zones      In?   Liquid             Airborne                Results 63   Filter Room          Det. Zone - None    Yes    Floor drains       Auxiliary Building      Upon completion of    Based on use of revised
* Filter Room              route to Aerated Ventilation System        implementation items  fire strategies and training (Refer to FA 60          Drains System. maintains negative      identified in         materials (to be and FA 75)               Liquid is treated, pressure. Air is        Attachment S, fire    completed as identified in filtered,          monitored prior to      brigade training      Attachment S), the processed and      release. The            materials will meet   PINGP approach will sampled before     control room can        NFPA radioactive      meet NFPA 805 release.           turn off the            release performance   radioactive release Auxiliary Building      criteria              performance criteria.
Make-Up Fans from the control room to prevent gaseous effluent from escaping.
The filter room exhaust fan can be turned off locally.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
PINGP                                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                           Attachment E - Radioactive Release Transition Fire                       Fire Strategies Screened Engineering Controls                      Training Review Description                                                                                                   Conclusions Area                       Detection Zones    In?   Liquid             Airborne               Results 64   Aux Bldg Low Level   Det. Zone 8       Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Decay Area Unit 1
* U1 695 Aux            route to Aerated Ventilation System       implementation items  fire strategies and training Bldg                   Drains System. maintains negative     identified in         materials (to be Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in filtered,          monitored prior to     brigade training      Attachment S), the processed and      release. The           materials will meet   PINGP approach will sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Make-Up Fans from the control room and locally stop the Filter Room Exhaust Fan to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
PINGP                                                                                                                Page E Revision 1

Northern States Power - Minnesota                                                               Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                        Training Review Description                                                                                                       Conclusions Area                       Detection Zones      In?   Liquid             Airborne                 Results 65   Spent Fuel Pool Heat Det. Zone - None    Yes    Floor drains       Auxiliary Building       Upon completion of    Based on use of revised Exchangers & Pumps
* SFP Hx Room              route to Aerated Ventilation System         implementation items  fire strategies and training (Refer to U1             Drains System. maintains negative       identified in         materials (to be 715 Aux Bldg,           Liquid is treated, pressure. Air is         Attachment S, fire    completed as identified in Det. Zone 19 )           filtered,          monitored prior to       brigade training      Attachment S), the processed and      release. The             materials will meet   PINGP approach will sampled before     control room can         NFPA radioactive      meet NFPA 805 release.           turn off the             release performance   radioactive release Auxiliary Building       criteria              performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
66   D3 Lunch Room        Det. Zone 39         No    N/A                N/A                      N/A                   This area is outside of the
* D-3                                                                                        permanent RCA and is Storage/Diesel                                                                             not used for permanent or Room Detection                                                                             temporary storage of radiological materials. A Waterflow: 41                                                                                fire in this area will not
* Auxiliary                                                                                  result in radiological Building Unit 2                                                                            release.
                               & D-3 Storage Room 67   Resin Disposal Area  Det. Zone 34        Yes    Floor drains to    Radwaste Building        Upon completion of    Based on use of revised
* Rad Waste &              Radwaste           Ventilation System       implementation items  fire strategies and training Resin Disposal           Building Sumps,    filters air prior to     identified in         materials (to be El. 695                 collected in       release.                 Attachment S, fire    completed as identified in tanks, filtered,                            brigade training      Attachment S), the Det. Zone 81               processed and                               materials will meet   PINGP approach will
* Rad Waste &              sampled prior to                            NFPA radioactive      meet NFPA 805 Resin Disposal           release.                                    release performance   radioactive release El. 695 & El.                                                       criteria              performance criteria.
715 PINGP                                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                      Conclusions Area                       Detection Zones     In?   Liquid           Airborne     Results 69   Turbine Bldg Ground  Det. Zone 3         No    N/A              N/A          N/A                 This area is outside of the
        & Mezzanine Floors
* FW Pmp Turb                                                               permanent RCA and is Unit 1                 Bldg 695                                                                 not used for permanent or temporary storage of Det. Zone 4                                                                 radiological materials. A
* U1 695 Turb                                                               fire in this area will not result in radiological Bldg release.
Det. Zone 15
* U1 Turb Bldg 715 , Locker Room, Lunch Room, Serv Bldg Stairway, Fan Rm, &
Work Area Det. Zone 107
* Turb/Service Building Elevator Waterflow: 5
* U1 695 Turb Bldg Waterflow: 16
* U1 715 Turb Bldg PINGP                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                  Attachment E - Radioactive Release Transition Fire                       Fire Strategies    Screened Engineering Controls          Training Review Description                                                                                        Conclusions Area                       Detection Zones       In?   Liquid           Airborne     Results 70   Turbine Bldg Ground  Det. Zone 36          No    N/A              N/A          N/A                 This area is outside of the
        & Mezzanine Floors
* Feed Water                                                                  permanent RCA and is Unit 2                 Pump Area Unit                                                              not used for permanent or 2                                                                           temporary storage of radiological materials. A Det. Zone 37                                                                  fire in this area will not
* Turbine Building                                                            result in radiological Unit 2 El. 695                                                             release.
Det. Zone 44
* Turbine Building Unit 2 El. 715 Waterflow: 38
* Turbine Building Unit 2. 695 Waterflow: 45
* Turbine Building Unit 2, 715 PINGP                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                                Attachment E - Radioactive Release Transition Fire                         Fire Strategies   Screened Engineering Controls                       Training Review Description                                                                                                        Conclusions Area                         Detection Zones      In?   Liquid             Airborne                Results 71   Containment Unit 2     Det. Zone 42        Yes    Floor drains to    Containment             Upon completion of    Based on use of revised
* U2 Rx Bldg 697          Containment        Internal Cleanup        implementation items  fire strategies and training Sump, then         Subsystem               identified in         materials (to be Det. Zone 52               pumped to Aux      recirculates and        Attachment S, fire    completed as identified in
* U2 Rx Bldg 733          Bldg Aerated       filters air for Modes   brigade training      Attachment S), the Drains System. 1, 2, 3, 4.             materials will meet   PINGP approach will Det. Zone 54               Liquid is treated,                         NFPA radioactive      meet NFPA 805
* U2 Rx Bldg 755          filtered,          Containment Purge       release performance   radioactive release processed and      and In-Service          criteria              performance criteria.
Det. Zone 56               sampled before     Purge Systems U2 Rx Bldg 711            release.           filter air prior to exhaust through U2 Shield Building Containment Annulus    Det. Zone 47               Liquids drain to   Stack for Modes 5 Unit 2                 U2 Cntmt Annulus           sumps in floor     and 6.
and transferred (Previously identified                            to Aux Bldg as Fire Area 72)                                  Aerated Drain      Shield Building System. Liquid     Ventilation System is treated,        recirculates air in filtered,          annulus and processed and      maintains negative sampled before     pressure.
release. Under accident           In exhaust mode, conditions,        Shield Building liquids            Ventilation System transferred to     filters air before Containment        exhausting through Sump.              Shield Building vent stack.
PINGP                                                                                                                     Page E Revision 1

Northern States Power - Minnesota                                                              Attachment E - Radioactive Release Transition Fire                       Fire Strategies    Screened Engineering Controls                      Training Review Description                                                                                                      Conclusions Area                       Detection Zones       In?   Liquid             Airborne               Results 75   Aux Bldg Operating   Det. Zone 51         Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Level Unit 2
* Auxiliary                 route to Aerated Ventilation System       implementation items  fire strategies and training Building Unit 2           Drains System. maintains negative     identified in         materials (to be El. 735                  Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in filtered,          monitored prior to     brigade training      Attachment S), the processed and      release. The           materials will meet   PINGP approach will sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
76   Vent and Fan Room    Det. Zone 30         Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Unit 2
* Unit 1 Aux Bldg           route to Aerated   Ventilation System     implementation items  fire strategies and training 755    SFP &             Drains System. maintains negative     identified in         materials (to be Fuel Receipt              Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in Area                      filtered,          monitored prior to     brigade training      Attachment S), the processed and      release. The           materials will meet   PINGP approach will Det. Zone 53                sampled before     control room can       NFPA radioactive      meet NFPA 805 Auxiliary Building          release.           turn off the           release performance   radioactive release Unit 2 & West                                  Auxiliary Building     criteria              performance criteria.
Side Fuel                                      Exhaust and Make-
* Handling Area                                Up Fans from the El. 755                                     control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
PINGP                                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                             Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls                      Training Review Description                                                                                                     Conclusions Area                       Detection Zones      In?   Liquid             Airborne               Results 77   Aux Bldg Low Level   None                Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Decay Unit 2                                    route to Aerated Ventilation System       implementation items  fire strategies and training Drains System. maintains negative     identified in         materials (to be Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in filtered,          monitored prior to     brigade training      Attachment S), the processed and      release. The           materials will meet   PINGP approach will sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
78   Waste Gas            Det. Zone 33        Yes    Floor drains       Auxiliary Building     Upon completion of    Based on use of revised Compressor Area
* Fuel Loading &           route to Aerated   Ventilation System     implementation items  fire strategies and training Spent Fuel Area          Drains System. maintains negative     identified in         materials (to be Liquid is treated, pressure. Air is       Attachment S, fire    completed as identified in filtered,          monitored prior to     brigade training      Attachment S), the processed and      release. The           materials will meet   PINGP approach will sampled before     control room can       NFPA radioactive      meet NFPA 805 release.           turn off the           release performance   radioactive release Auxiliary Building     criteria              performance criteria.
Exhaust and Make-Up Fans from the control room to prevent gaseous effluent from escaping.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
PINGP                                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                 Attachment E - Radioactive Release Transition Fire                       Fire Strategies   Screened Engineering Controls          Training Review Description                                                                                       Conclusions Area                       Detection Zones      In?   Liquid           Airborne     Results 79   480 V SFGD SWGR      Det. Zone 26         No    N/A              N/A          N/A                 This area is outside of the Room (Bus 112)
* 480V Swgr 112                                                              permanent RCA and is Bus Rm & Trn A                                                             not used for permanent or Em Room                                                                    temporary storage of radiological materials. A fire in this area will not result in radiological release.
80   480 V SWGR Room      Det. Zone 43         No    N/A              N/A          N/A                 This area is outside of the (Bus 111)
* 480V Switch                                                                permanent RCA and is Gear 111 and                                                               not used for permanent or 121                                                                        temporary storage of radiological materials. A fire in this area will not result in radiological release.
81   4.16kV Safeguard     Det. Zone 11         No    N/A              N/A          N/A                 This area is outside of the SWGR Room (Bus
* Bus Rms 15 &                                                               permanent RCA and is
: 15)                    16 Unit 1 715                                                             not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
82   480 V Safeguard      Det. Zone 50         No    N/A              N/A          N/A                 This area is outside of the SWGR Room (Bus
* 480V Switch                                                                permanent RCA and is 122)                   Gear 122 Bus                                                               not used for permanent or Room & Train B                                                             temporary storage of EM Room                                                                    radiological materials. A fire in this area will not result in radiological release.
83   Operators Lounge     Det. Zone 64         No    N/A              N/A          N/A                 This area is outside of the
* Operators Study                                                            permanent RCA and is Area / Security                                                            not used for permanent or Office                                                                     temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                   Page E Revision 1

Northern States Power - Minnesota                                                               Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls                         Training Review Description                                                                                                       Conclusions Area                       Detection Zones     In?   Liquid             Airborne                  Results 84   Counting Room &      None               Yes    Floor drains       Area is positively        Upon completion of    Based on use of revised Labs                 (FA 59, Zone 19)          route to Aerated pressurized with            implementation items  fire strategies and training Drains System. respect to rest of        identified in         materials (to be Waterflow: 18             Liquid is treated, Auxiliary Building.       Attachment S, fire    completed as identified in
* Lndry, Chem &           filtered,          Additional filters        brigade training      Attachment S), the Inst Labs or            processed and      and exhaust fans          materials will meet   PINGP approach will Records Room            sampled before     are installed, and        NFPA radioactive      meet NFPA 805 release.           air is filtered prior to  release performance   radioactive release discharge.                criteria              performance criteria.
Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release.
PINGP                                                                                                                    Page E Revision 1

Northern States Power - Minnesota                                                           Attachment E - Radioactive Release Transition Fire                       Fire Strategies Screened Engineering Controls                      Training Review Description                                                                                                   Conclusions Area                       Detection Zones    In?   Liquid             Airborne               Results 85   Hold-up Tank Area /  Det. Zone 8       Yes    Floor drains       Auxiliary Building     Upon completion of    Revised fire strategies Demineralizer Area
* U1 695 Aux             route to Aerated Ventilation System       implementation items  will incorporate mitigative Bldg                   Drains System. maintains negative     identified in         actions to utilize Filter Liquid is treated, pressure. Air is       Attachment S, fire    Room Ventilation to filter filtered,          monitored prior to     brigade training      potentially contaminated processed and      release.               materials will meet   smoke occurring from sampled before                            NFPA radioactive      fires on south side of release.           North side 695ft       release performance   695ft elevation based on and entire 715ft       criteria              radiation protection input elevation portions:                          to fire brigade on radiological conditions.
The control room can turn off the                             Based on use of revised Auxiliary Building                           fire strategies and training Exhaust and Make-                            materials (to be Up Fans from the                             completed as identified in control room to                              Attachment S), the prevent gaseous                              PINGP approach will effluent from                                meet NFPA 805 escaping.                                    radioactive release performance criteria.
Auxiliary Building Special Ventilation System Air is filtered prior to release.
South side 695ft portions:
The control room can turn off the Auxiliary Building Make-Up Fans from the control room and turn off the Filter Room Exhaust fan locally to prevent gaseous effluent from escaping.
PINGP                                                                                                                Page E Revision 1

Northern States Power - Minnesota                                                Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls          Training Review Description                                                                                      Conclusions Area                       Detection Zones     In?   Liquid           Airborne     Results 86   Intake Screenhouse   None                No    N/A              N/A          N/A                 This area is outside of the permanent RCA and is not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
   --   Radiation Monitor    Det. Zone 70        No    N/A              N/A          N/A                 This area is outside of the Station
* Radiation                                                                 permanent RCA and is Monitoring                                                                not used for permanent or Station / De-                                                             temporary storage of icing Pump                                                                radiological materials. A House / Envir.                                                            fire in this area will not Lab / Intake                                                              result in radiological Screen House                                                              release.
   --   Deep Well Pump       Det. Zone 73        No    N/A              N/A          N/A                 This area is outside of the House 1 & 2
* Deep Well                                                                 permanent RCA and is Pump House 1                                                              not used for permanent or
                               &2                                                                        temporary storage of radiological materials. A fire in this area will not result in radiological release.
   --   Deep Well Pump       Det. Zone 73        No    N/A              N/A          N/A                 This area is outside of the House 1 & 2
* Deep Well                                                                 permanent RCA and is Pump House 1                                                              not used for permanent or
                               &2                                                                        temporary storage of radiological materials. A fire in this area will not result in radiological release.
89   Guard House          Det. Zone 89        No    N/A              N/A          N/A                 This area is outside of the
* Guard House &                                                             permanent RCA and is Emerg Gen                                                                 not used for permanent or Bldg                                                                      temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                             Attachment E - Radioactive Release Transition Fire                       Fire Strategies  Screened Engineering Controls                       Training Review Description                                                                                                     Conclusions Area                       Detection Zones     In?   Liquid             Airborne                Results 90   Emergency Generator  Det. Zone 89        No    N/A                N/A                     N/A                   This area is outside of the Bldg
* Guard House &                                                                            permanent RCA and is Emerg Gen                                                                                not used for permanent or Bldg                                                                                     temporary storage of radiological materials. A fire in this area will not result in radiological release.
92   Water Chiller Room   Det. Zone 31       Yes    Floor drains       Chiller rooms are       Upon completion of    Based on use of revised Unit 2
* 121 & 122 Cont          route to Aerated   part of the Control     implementation items  fire strategies and training Rm Chiller Aux          Drains System. Room Habitability       identified in         materials (to be Bldg 755               Liquid is treated, Envelope and have       Attachment S, fire    completed as identified in filtered,          internal air handling   brigade training      Attachment S), the processed and      unit during             materials will meet   PINGP approach will sampled before     operations and a        NFPA radioactive      meet NFPA 805 release.           closed loop             release performance   radioactive release cleanup system          criteria              performance criteria.
during an accident.
PINGP                                                                                                                  Page E Revision 1

Northern States Power - Minnesota                                                           Attachment E - Radioactive Release Transition Fire                       Fire Strategies Screened Engineering Controls                      Training Review Description                                                                                                   Conclusions Area                       Detection Zones    In?   Liquid             Airborne               Results 93   Low Level Rad Waste  Det. Zone 104     Yes    Floor drains       No ventilation.        Upon completion of    A combination of Area
* Low Level Rad          route to Aerated Potential transfer of    implementation items  containerization and Waste -                Drains System. contaminated           identified in         administrative controls Building               Liquid is treated, smoke to exterior. Attachment S, fire    will limit the amount of filtered,                                 brigade training      exposed contaminated Waterflow: 101           processed and                             materials will meet   combustible materials.
* Low Level Rad          sampled before                            NFPA radioactive Waste Storage          release.                                  release performance   Revised fire strategies (to Bldg &                                                           criteria              be completed as Warehouse                                                                              identified in Attachment S) will incorporate mitigative actions to filter potentially contaminated smoke based on radiological conditions identified during the conduct of fire fighting activities.
Based on use of revised fire strategies and training materials (to be completed as identified in Attachment S), the PINGP approach will meet NFPA 805 radioactive release performance criteria.
94   Service              Det. Zone 94       No    N/A                N/A                    N/A                   This area is outside of the Building/Computer
* Service Bldg                                                                           permanent RCA and is Room                   695   - 715                                                                          not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                                Page E Revision 1

Northern States Power - Minnesota                                                 Attachment E - Radioactive Release Transition Fire                         Fire Strategies Screened Engineering Controls          Training Review Description                                                                                       Conclusions Area                         Detection Zones    In?   Liquid           Airborne     Results 97   D5 Diesel Generator    Det. Zone 97       No    N/A              N/A          N/A                 This area is outside of the Building
* D5/D6 Diesel                                                             permanent RCA and is Building                                                                 not used for permanent or (Previously identified                                                                            temporary storage of as Fire Areas 97, 99,                                                                             radiological materials. A 101, 103, 105, 107,                                                                               fire in this area will not 109, 111, 113, 115,                                                                               result in radiological 117, 119, 123, 125, &                                                                             release.
127) 98   D6 Diesel Generator    Det. Zone 97       No    N/A              N/A          N/A                 This area is outside of the Building
* D5/D6 Diesel                                                             permanent RCA and is Building                                                                 not used for permanent or (Previously identified                                                                            temporary storage of as Fire Areas 98, 102,                                                                            radiological materials. A 104, 106, 108, 110,                                                                               fire in this area will not 112, 114, 116, 118,                                                                               result in radiological 120, 122, 124, 126 &                                                                              release.
128) 100   D5/D6Fuel Oil          Det. Zone 97       No    N/A              N/A          N/A                 This area is outside of the Receiving Tank 21
* D5/D6 Diesel                                                             permanent RCA and is Building                                                                 not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
131   New Admin Bldg         Det. Zone 99       No    N/A              N/A          N/A                 This area is outside of the
* New Admin                                                                permanent RCA and is Building                                                                 not used for permanent or temporary storage of radiological materials. A fire in this area will not result in radiological release.
PINGP                                                                                                   Page E Revision 1

Northern States Power - Minnesota            Attachment F - Fire-Induced MSOs Resolution F.      Fire-Induced Multiple Spurious Operations Resolution 6 Pages Attached PINGP                                                                Page F Revision 1

Northern States Power - Minnesota                Attachment F - Fire-Induced MSOs Resolution MSO Process Summary The following provides the guidance from FAQ 07-0038, Revision 3, along with the process and results.
Step 1 - Identify potential MSOs of concern Information sources that may be used as input include:
* Post-fire safe shutdown analysis (NEI 00-01, Revision 1, Chapter 3).
* Generic lists of Multiple Spurious Operations (MSOs, e.g., from Owners Groups and/or later versions of NEI 00-01, if endorsed by NRC for use in assessing MSOs).
* Self assessment results (e.g., NEI 04-06 assessments performed to address RIS 2004-03).
* PRA insights (e.g., NEI 00-01 Revision 1, Appendix F).
* Operating Experience (e.g., licensee event reports, NRC Inspection Findings, etc.).
Results of Step 1:
The Prairie Island Nuclear Generating Plant (PINGP) MSO identification process was performed as two complementary tasks. First, a systematic review of plant P&IDs was performed to identify potential spurious operation combinations that can lead to initiating events and that can also impact the function of needed mitigating systems. Second, an Expert Panel was convened to consider potential MSOs from a number of generic and plant specific sources. The sources of information used as inputs for this process are listed below.
* Pressurized Water Reactor (PWR) Generic MSO List, Rev. 1, May 2009, contained in Appendix G of NEI 00-01, Rev. 2, May 2009.
* PINGP Safe Shutdown Analysis, GEN-PI-026.
* PINGP Internal Events PRA Model Revision 3.1.
* System P&IDs and Electrical Drawings.
* PINGP training material for relevant systems.
Step 2 - Conduct an expert panel to assess plant specific vulnerabilities (e.g., per NEI 00-01, Rev. 1 Section F.4.2).
The expert panel should focus on system and component interactions that could impact nuclear safety. This information will be used in later tasks to identify cables and potential locations where vulnerabilities could exist.
The documentation of the results of the expert panel should include how the expert panel was conducted including the members of the expert panel, their experience, education, and areas of expertise. The documentation should include the list of MSOs reviewed as well as the source for each MSO. This documentation should provide a list of the MSOs that were included in the PRA and a separate list of MSOs that were not kept for further analysis (and the reasons for rejecting these MSOs for further analysis).
PINGP                                                                    Page F Revision 1

Northern States Power - Minnesota                  Attachment F - Fire-Induced MSOs Resolution Describe the expert panel process (e.g., when it was held, what training was provided to the panel members, what analyses were reviewed to identify MSOs, how was consensus achieved on which MSOs to keep and any dispute resolution process criteria used in decision process, etc.).
[Note: The physical location of the cables of concern (e.g., fire zone/area routing of the identified MSO cables), if known, may be used at this step in the process to focus the scope of the detailed review in further steps].
Results of Step 2:
An MSO Expert Panel was conducted at the PINGP site in December of 2009. The purpose of the Expert Panel was to review the applicable industry developed Generic Owners Group List of MSOs for applicability to PINGP. The Expert Panel commented on whether or not applicable MSOs were accounted for in the plant PRA and Safe Shutdown Analyses. A training session for the panel members was conducted prior to starting the actual assessment. The results of the MSO Expert Panel were documented in V.SMN.13.001, Fire PRA Multiple Spurious Operations (MSO) Report. The report also includes:
* The presentation that was used as the training materials.
* The areas of expertise for each of the MSO Expert Panel participants.
* A list of the generic MSOs that were reviewed.
In addition to the Expert Panel meeting, a systematic review of system drawings was performed to identify single and multiple spurious operations of components that can lead to initiating events and that can also impact the function of needed mitigating systems. The purpose of this review was to identify relevant combinations of fire induced single spurious operations (SSOs) and MSOs of equipment which could result in a functional failure leading to an increase in core damage frequency or large early release frequency, and ensure they are evaluated within the context of the PINGP Fire PRA. The systematic review scope included all mechanical systems, including water, oil and air, but specifically excluded electrical systems. Spurious operations of electrical systems (i.e., spurious breaker operation) are already evaluated directly in the PRA and are considered, at least in part, in the PWR Owners Groups Generic MSO List. The output from this review includes the following:
* A summary of the systematic review of systems for spurious operations combinations potentially affecting initiating events and mitigating systems.
* A listing of the resulting SSO and MSO combinations identified.
V.SMN.13.001 documents the methodology used for this systematic review and the resulting SSO and MSO combinations.
Another MSO Expert Panel was conducted at the PINGP site in October of 2013. The Expert Panel was conducted to review PWR Owners Groups Generic electrical MSOs as detailed in NEI 00-01, Revision 2, to validate previous disposition efforts, discuss additional related plant-specific MSOs, and provide disposition as required. Training involved Expert Panel members reviewing the previous MSO Expert Panel Overview prior to starting the assessment. The results of the MSO Expert Panel were PINGP                                                                      Page F Revision 1

Northern States Power - Minnesota                  Attachment F - Fire-Induced MSOs Resolution documented in PINGP Engineering Change EC 23660, Focused-Scope Electrical Expert Panel for Addressing Multiple Spurious Operations Related to Generic MSOs 47, 48 and 49. The report includes:
* The presentation that was used as the training materials.
* Fire Induced MSOs related to PWR Owners Groups Generic electrical MSOs.
* The results of the Focused-Scope Expert Panel, including required disposition when necessary.
Step 3 - Update the Fire PRA model and NSCA to include the MSOs of concern.
This includes the:
* Identification of equipment (NUREG/CR-6850 Task 2).
* Identification of cables that, if damaged by fire, could result in the spurious operation (NUREG/CR-6850 Task 3, Task 9).
* Identification of the routing of cables identified above, including associating that routing with fire areas, fire zones and/or Fire PRA physical analysis units, as applicable.
Include the equipment/cables of concern in the Nuclear Safety Capability Assessment (NSCA). Including the equipment and cable information in the NSCA does not necessarily imply that the interaction is possible since separation/protection may exist throughout the plant fire areas such that the interaction is not possible.
Note: Instances may exist where conditions associated with MSOs do not require update of the Fire PRA and NSCA analysis. For example, Fire PRA analysis in NUREG/CR-6850 Task 2, Component Selection, may determine that the particular interaction may not lead to core damage, or pre-existing equipment and cable routing information may determine that the particular MSO interaction is not physically possible.
In other instances, the update of the PRA may not be warranted if the contribution is negligible. The rationale for exclusion of identified MSOs from the Fire PRA and NSCA should be documented and the configuration control mechanisms should be reviewed to provide reasonable confidence that the exclusion basis will remain valid.
Results of Step 3:
The results of the Expert Panel and systematic review were fed into the PINGP Equipment Selection (ES) task (NUREG/CR-6850 Task 2). This task included components susceptible to single and multiple spurious operations identified in the post-fire safe shutdown analysis as well as those from the expert panel and systematic reviews. Cable selection and circuit analysis (NUREG/CR-6850 Tasks 3 and 9) were then performed for those components that did not already have this performed for the current Safe Shutdown Analysis. Components susceptible to spurious operation that were not already included in the PINGP Fire PRA model were added to the model at either the system level or the top logic level representing the probability of proceeding down various event tree paths (NUREG/CR-6850 Task 5). Probabilities for important SSO basic events were generated in the Circuit Failure Mode Likelihood Analysis (NUREG/CR-6850 Task 10). Probabilities for MSO events due to multiple cable hot shorts are also derived from the Circuit Failure Mode Likelihood Analysis results.
PINGP                                                                      Page F Revision 1

Northern States Power - Minnesota                 Attachment F - Fire-Induced MSOs Resolution The results of the Fire PRA model development including the effects of equipment spurious operations are documented in the following PINGP Fire PRA notebooks:
* FPRA-PI-ES, Equipment Selection Notebook.
* FPRA-PI-CS, Cable Selection and Circuit Analysis Notebook.
* FPRA-PI-CF, Circuit Failure Mode Likelihood Analysis Notebook.
* FPRA-PI-PRM, Fire Induced Risk Model Notebook.
* FPRA-PI-MSO, Multiple Spurious Operations Notebook.
The last notebook includes the logic changes made to the Fire PRA model to account for MSO scenarios relevant to fire but not already captured by the Internal Events PRA.
The Fire Induced Risk Model along with the outputs from the cable selection and circuit failure likelihood analyses were then used to evaluate the impact of fire scenarios in individual Fire Areas and Fire Compartments to support the NSCA.
The MSO combinations of components of concern were evaluated as part of the PINGP NSCA. As necessary, components were added to the NSCA Equipment List and Logics (EC 20612, Non-Power/NSCA Operations Review for NFPA 805), and the appropriate circuit analysis and cable routing were performed.
Step 4 - Evaluate for NFPA 805 Compliance The MSO combinations included in the NSCA should be evaluated with respect to compliance with the deterministic requirements of NFPA 805, as discussed in Section 4.2.3 of NFPA 805. For those situations in which the MSO combination does not meet the deterministic requirements of NFPA 805 and therefore represents a variance from deterministic requirements (VFDR), the issue with the components and associated cables should be mitigated by other means (e.g., performance-based approach per Section 4.2.4 of NFPA 805, plant modification, etc.).
The performance-based approach may include the use of feasible and reliable recovery actions. The use of recovery actions to demonstrate the availability of a success path for the nuclear safety performance criteria requires that the additional risk presented by the use of these recovery actions be evaluated (NFPA 805 Section 4.2.4).
Results of Step 4:
The PINGP PRA quantified the fire-induced risk model containing the MSO failure modes. The quantification addressed the specific electrical cables and the failure mode in each fire area and fire zone that was quantified. Thus, the MSO contribution is included in the fire PRA results, and in the fire PRA results associated with evaluation of VFDRs as documented in applicable fire risk evaluations.
The MSO combinations of components of concern were also evaluated as part of the PINGP NSCA. As part of the review of current fire area safe shutdown strategies, components with a potential for a spurious operation were reviewed. During this review process, the systems were reviewed to determine the overall impact. The methodology used in the review process is detailed in Engineering Change Evaluation EC 20612, Non-Power/NSCA Operations Review for NFPA 805.
PINGP                                                                     Page F Revision 1

Northern States Power - Minnesota                Attachment F - Fire-Induced MSOs Resolution For cases where the MSO combination of components did not meet the requirements for deterministic compliance, the MSO combination of components were identified as VFDRs and added to the scope of the fire risk evaluations.
The process and results associated with the performance of fire risk evaluations are summarized in Section 4.5 of the Transition Report.
Step 5 - Document Results The results of the process should be documented. The results should provide a detailed description of the MSO identification, analysis, disposition, and evaluation results (e.g., references used to identify MSOs; the composition of the expert panel, the expert panel process, and the results of the expert panel process; disposition and evaluation results for each MSO, etc.). The high level methodology utilized as part of the transition process should be included in the 10 CFR 50.48(c) License Amendment Request/Transition Report.
Results of Step 5:
The PINGP MSO methodology and results are documented in the following:
* V.SMN.13.001, Fire PRA Multiple Spurious Operations (MSO) Report.
* FPRA-PI-ES, Equipment Selection Notebook.
* FPRA-PI-CS, Cable Selection and Circuit Analysis Notebook.
* FPRA-PI-CF, Circuit Failure Mode Likelihood Analysis Notebook.
* FPRA-PI-PRM, Fire Induced Risk Model Notebook.
* FPRA-PI-MSO, Multiple Spurious Operations Notebook, Revision 0.
* Engineering Change EC 23660, Focused-Scope Electrical Expert Panel for Addressing Multiple Spurious Operations Related to Generic MSOs 47, 48 and 49.
As part of Step 4 of the process outlined above, MSO combinations were reviewed for their impact on deterministic compliance (i.e., fire area reviews to determine if a fire scenario could result in the potential MSO combinations). During this process, VFDRs were identified where the deterministic requirements of NFPA 805 Section 4.2.3 were not met. These VFDRs were addressed by demonstrating compliance with the performance-based approach of Section 4.2.4 of NFPA 805 (See Section 4.5 and Attachment C).
Note that the spurious operations reviewed as part of the process included components that were part of the original PINGP 10 CFR 50 Appendix R post-fire safe shutdown analysis, as well as components and interactions that were added following a plant-specific review of functional failures and evolved industry issues. No specific distinction is made in the program documentation whether the interaction is related to an SSO or MSO since the risk-informed approach using the Fire PRA provides an integrated plant response model.
Fire-induced MSOs are included in the fire PRA model, and their associated risk is included in the quantification of each fire scenario, the total plant fire risk, and PINGP                                                                      Page F Revision 1

Northern States Power - Minnesota              Attachment F - Fire-Induced MSOs Resolution evaluation of each VFDR. The VFDRs are identified in Attachment C and a summary of the Fire PRA results is provided in Attachment W.
PINGP                                                                  Page F Revision 1

Northern States Power Company                   Attachment G - Recovery Action Transition G. Recovery Actions Transition 24 Pages Attached PINGP                                                              Page G Revision 1

Northern States Power Company                       Attachment G - Recovery Action Transition In accordance with the guidance provided in NEI 04-02, FAQ 07-0030, Revision 5, and RG 1.205, the following methodology was used to determine recovery actions required for compliance (i.e., determining the population of post-transition recovery actions). The methodology consisted of the following steps:
Step 1: Define the primary control station(s) and determine which pre-transition Operator Manual Actions (OMAs) are taken at primary control station(s) (Activities that occur in the Main Control Room are not considered pre-transition OMAs). Activities that take place at primary control station(s) or in the Main Control Room are not recovery actions, by definition.
Step 2: Determine the population of recovery actions that are required to resolve VFDRs (to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth).
Step 3: Evaluate the additional risk presented by the use of recovery actions required to demonstrate the availability of a success path.
Step 4: Evaluate the feasibility of the recovery actions.
Step 5: Evaluate the reliability of the recovery actions.
An overview of these steps and the results of their implementation are provided below.
Step 1 - Clearly define the primary control station(s) and determine which pre-transition OMAs are taken at primary control station(s)
The first task in the process of determining the post-transition population of recovery actions was to apply the NFPA 805 definition of recovery action and the RG 1.205 definition of primary control station to determine those activities that are taken at primary control station(s).
Results of Step 1:
PINGP does not have alternate or dedicated shutdown controls that meet the definition of a primary control station (PCS) as defined by RG 1.205. No credit has been taken for PCS actions in the Fire PRA.
Step 2 - Determine the population of recovery actions that are required to resolve VFDRs (to meet the risk or defense-in-depth criteria)
On a fire area basis all VFDRs were identified in the NEI 04-02, Table B-3 (See Attachment C). Each VFDR not brought into compliance with the deterministic approach was evaluated using the performance-based approach of NFPA 805, Section 4.2.4. The performance-based evaluations resulted in the need for recovery actions to meet the risk acceptance criteria or maintain a sufficient level of defense-in-depth.
Results of Step 2:
The final set of recovery actions are provided in Table G Recovery Actions.
Step 3: Evaluate the Additional Risk of the Use of Recovery Actions NFPA 805 Section 4.2.3.1 does not allow recovery actions when using the deterministic approach to meet the nuclear safety performance criteria. However, the use of recovery actions is allowed by NFPA 805 using a risk informed, performance-based approach, PINGP                                                                    Page G Revision 1

Northern States Power Company                       Attachment G - Recovery Action Transition provided that the additional risk presented by the recovery actions is evaluated in accordance with NFPA 805 Section 4.2.4.
Results of Step 3:
The set of recovery actions that are necessary to demonstrate the availability of a success path for the nuclear safety performance criteria (See Table G-1) were evaluated for additional risk using the process described in NEI 04-02, FAQ 07-0030, Revision 5, and RG 1.205 and compared against the guidelines of RG 1.174 and RG 1.205. The additional risk is provided in Attachment W.
All of the recovery actions were reviewed for adverse impact and dispositioned in fire area-specific Fire Risk Evaluation engineering evaluations. None of the recovery actions were found to have an adverse impact on the Fire PRA.
Step 4: Evaluate the Feasibility of Recovery Actions Recovery actions were evaluated against the feasibility criteria provided in the NEI 04-02, FAQ 07-0030, Revision 5, and RG 1.205.
Results of Step 4:
Each of the feasibility criteria in FAQ 07-0030 were assessed for the recovery actions listed in Table G-1 with exception to recovery actions which place more than one instrument bus on its associated alternate source. Control room abandonment was found to be the bounding fire scenario and the results of the assessment are included in Calculation GEN-PI-055 Rev. 1, 10CFR50 Appendix R Manual Action Feasibility Study. This calculation contains the required time constraints in which to perform the recovery actions. Feasibility for recovery actions allowing more than one instrument bus to be placed on its associated alternate source will be assessed by}}