View source for L-PI-15-059, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Information (PRA-Second Round)

{{Adams
| number = ML15296A259
| issue date = 10/22/2015
| title = License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Information (PRA-Second Round)
| author name = Davison K
| author affiliation = Northern States Power Co, Xcel Energy
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000282, 05000306
| license number = DPR-042, DPR-060
| contact person = 
| case reference number = L-PI-15-059, TAC ME9734, TAC ME9735
| document type = Fire Protection Plan, Letter type:L
| page count = 35
| project = TAC:ME9734, TAC:ME9735
| stage = Request
}}

=Text=
{{#Wiki_filter:eel Energy@                                     Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 October 22, 2015                                                           L-PI-15-059 10 CFR 50.90 10 CFR 50.48(c)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Final Request for Additional Information (PRA- Second Round. TAG Nos. ME9734 and ME9735)

==References:==
: 1. NSPM letter, J.P. Sorensen to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, L-PI-12-089, dated September 28, 2012, ADAMS Accession No. ML12278A405.
: 2. NSPM letter, S. Sharp to NRC Document Control Desk, Supplement to License Amendment Request to Adopt NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactors, L-PI-14-045, dated April 30, 2014 (ADAMS Nos. ML14125A106 and ML14125A149).
: 3. NRC email, T. Beltz to S. Chesnutt, Prairie Island Nuclear Generating Plant, Units 1 and 2 - NFPA 805 Requests for Additional Information and Response Time/ine (TAG Nos. ME9734 and ME9735), dated March 30, 2015 (ADAMS Accession No. ML15089A157).
: 4. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors- Response to Request for Additional Information, L-PI-15-041, dated May 28,2015 (ADAMS Nos. ML15153A018).
: 5. NSPM letter, K. Davison to NRC Document Control Desk, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information- 90-Day Responses, L-PI-15-052, dated June 19, 2015 (ADAMS Nos. ML15174A139).

Document Control Desk Page 2
: 6. NRC email, T. Beltz to A. Hazel hoff, Prairie Island Nuclear Generating Plant-Final Requests for Additional Information (Second Round) from APLA re: LAR to Adopt NFPA 805 (TAG Nos. ME9734 and ME9735), dated August 28, 2015 (ADAMS Accession No. ML15243A409).
In Reference 1, the Northern States Power Company, a Minnesota Corporation (NSPM) doing business as Xcel Energy requested approval from the Nuclear Regulatory Commission (NRC) to transition the fire protection licensing basis for the Prairie Island Nuclear Generating Plant (PINGP) to 10 CFR 50.48(c), National Fire Protection Association Standard 805 (NFPA 805). Supplemental information was provided in letters dated November 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12314A144) and December 18, 2012 (ADAMS Accession No. ML12354A464).
In Reference 2, NSPM submitted a revised Fire Probabilistic Risk Assessment (PRA) in a supplement to the subject License Amendment Request (LAR). In Reference 3, the NRC staff provided requests for additional information (RAis) regarding this request and also provided a timeline and due dates for submitting responses within 60, 90, or 120 days after an on-site Audit that was conducted March 23-25, 2015. NSPM letter dated May 28, 2015 (Reference 4) provided responses to the 60-day RAis and one of the 90-day RAis (Fire Protection Engineering RAI 03). NSPM letter dated June 19, 2015 (Reference 5) provided responses to the remaining 90-day RAis.
In Reference 6, the NRC staff provided second round PRA RAis. Enclosure 1 to this letter provides NSPM's responses to the second round PRA RAis which are due by October 23, 2015. Enclosure 2 provides licensee identified LAR changes to:
Attachment A (NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program & Design Elements), Attachment G (Recovery Actions Transition), and Attachment L (NFPA 805 Chapter 3 Requirements for Approval (1 0 CFR 50.48(c)(2)(vii))). This Attachment L request is:
* Attachment L Request #4 -Wires Above Suspended Ceilings This letter is submitted in accordance with 10 CFR 50.90. The additional information provided in this letter does not impact the conclusions of the No Significant Hazards Evaluation or Environmental Considerations Evaluation presented in Reference 2.
In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this additional information by transmitting a copy of this letter to the designated State Official.
If there are any questions or if additional information is needed, please contact Gene Eckholt at 651-267-1742.

Document Control Desk Page 3 Summary of Commitments This letter contains no new commitments and makes no revisions to any existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 22, 2015.
   !0c.:il-~
Kevin Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company- Minnesota Enclosures (2) cc:    Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

L-PI-15-059                                                                          NSPM Enclosure 1 Response to Requests for Additional Information (RAis)
Regarding the License Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805 at Prairie Island Nuclear Generating Plant Units 1 and 2 RAI Responses - PRA NRC Request Probabilistic Risk Assessment (PRA) RAJ 01.d.01 The response to PRA RAJ 01.d (in letter dated May 28, 2015) indicates that general transient fires and transient fires due to hot work are not postulated under the raised floor within the main control room (MCR), further clarifying that hot work in this location while the plant is in operation is unlikely and that fire propagation is unlikely due to suppression. However, the guidance in FAQ 12-0064, "Hot Work/Transient Fire Frequency Influence Factors," requires that transient fires, consisting of fire from transient combustibles and hot work, be assumed to occur in all areas of a plant unless precluded by design and/or operation (e.g., manholes are welded shut, space too small to allow personnel access under any conditions, very high radiation areas, etc.). Note also that in FAQ 12-0064, the likelihood of hot work and maintenance activities is addressed through the use of transient influencing factors. "Strictly controlled" areas, if appropriately justified, may be assigned a ranking of "very low," or in the case of hot work, "extremely low" if plant procedures prohibit hot work in the MCR during power operations.
Please demonstrate that either the guidance in FAQ 12-0064 is inapplicable to the area under the raised floor within the MCR or that transient fires in this area have an insignificant impact on risk results. Alternatively, provide updated risk results as part of the integrated analysis requested in PRA RAt 03, addressing transient fires consistent with guidance in FAQ 12-0064.
NSPM Response (PRA RAI 01.d.01}
The Core Damage Frequency (CDF) and the Large Early Release Frequency (LERF) associated with the transient fires and transient fires due to hotwork in the area under the raised floor in the main control room (MCR) will be quantified using the guidance in FAQ 12-0064 and included in the integrated Fire PRA results in response to PRA RAI 03. The MCR Fire PRA notebook will be updated to include the technical description of the risk quantification for the area under the raised floor in the MCR.

==Reference:==
: 1. FPRA-PI-MCR-2.0, Main Control Room Analysis, Revision 2.
NRC Request PRA RAJ 01.e.01 The responses to PRA RAts 01.e and 12.e (in a letter dated June 19, 2015) indicate that the event tree model developed for main control board (MCB) panel scenarios is also applied to address 1) non-MCB electrical cabinet panel fires within the MCR, and 2) transient fires that may impact the MCB panels, respectively. However, this event tree model generates sequences (i.e., Sequences 1 and 2) in which fire damage is limited to only a single component within a panel. With regard to cabinet fires, Page 11-37 of NUREG/CR-6850, "EPRI-NRCIRES Page 1 of 7

L-PI-15-059                                                                            NSPM Enclosure 1 Fire PRA Methodology for Nuclear Power Facilities," indicates such detailed modeling "is beyond the capabilities of current state-of-the-art analytical tools." Additionally, with regard to transient fires, Section 11. 5. 2. 8 provides alternative damage criteria for open and closed back panels, which seem not to have been applied here.
Please explain how the treatment of 1) non-MCB electrical cabinet panel fires within the MCR, and 2) transient fires that may impact MCB panels, is consistent with accepted methods. If this treatment is not consistent with accepted methods, justify the approach, or replace the current approach with an acceptable approach in the integrated analysis performed in response to PRA RAJ 03.
NSPM Response {PRA RAI 01.e.01)
The risk (i.e., CDF and LERF) associated with fire scenarios generated from Sequences 1 and 2 of the main control room (MCR) event tree model will be re-quantified as follows:
* The Conditional Core Damage Probability (CCDP) and Conditional Large Early Release Probability (CLERP) for scenarios involving non main control board electrical cabinets will be quantified assuming full damage of the corresponding electrical cabinet.
* The CCDP and CLERP associated with transient fires postulated near the main control board will be quantified assuming full damage of the corresponding main control board panel.
The assumption of full electrical cabinet or main control board panel failure due to exposure to fire conditions generated by a transient fire is consistent with the guidance in NUREG/CR-6850.
The results of this quantification will be part of the integrated base Fire PRA model and will be reported as part of the response to PRA RAI 03. In addition, the MCR Fire PRA notebook will be updated to reflect the approach described in this response.

==Reference:==
: 1. FPRA-PI-MCR-2.0, Main Control Room Analysis, Revision 2.
NRC Request PRA RAI 01.f.01 The responses to PRA RAts 01.f and 01.d (in letter dated May 28, 2015) indicate that self-ignited cable fires are not postulated for "low energy" unqualified cables given that self-ignition does not "typically" occur for such cables. However, guidance in NUREG/CR-6850 states that
"[s]e/f[-]ignited cable fires should be postulated in rooms with unqualified cables only or a mix of qualified and unqualified cables." Additionally, neither NUREG/CR-6850 nor FAQ 13-0005, "Cable Fires Special Cases: Self-Ignited and Caused By Welding and Cutting," distinguish cabling by electrical energy or function (i.e., power versus instrumentation and control) in their treatments of self-ignition.
Please provide technical justification for excluding self-ignited cable fires for "low energy" unqualified cables external to conduit, or demonstrate that such fires have an insignificant impact on risk results. Alternatively, provide updated risk results as part of the integrated analysis requested in PRA RAJ 03, addressing these fires consistent with accepted guidance in NUREG/CR-6850 and FAQ 13-0005.
Page 2 of 7

L-PI-15-059                                                                           NSPM Enclosure 1 NSPM Response (PRA RAI 01.f.01}
As stated in the response to PRA RAis 01.f and 01.d, self-ignited cable fires are screened from the Fire PRA for all locations in the plant based on the evaluation documented in the Engineering Change Package 20695 (EC 20695). This evaluation concluded that the percentage of cable with thermoplastic insulation or jacket material is 1) relatively small, and 2) limited to low energy control cables.
The guidance in NUREG-1805 section 7.3, states that "It is common practice to consider only self-ignited cable fires to occur in power cable trays since they carry enough electrical energy for ignition. Control and instrumentation cables typically do not carry enough electrical energy for self-ignition." Engineering Change Evaluation 20695 concluded that the amount of cable with thermoplastic or unknown insulation or jacket is approximately 14%.
The responses to PRA RAis 01.f and 01.d summarized above are expanded in this response to further characterize the cables within the population of those with thermoplastic or unknown insulation or jacket (i.e., the 14%). To do so, the identification of cable type was done on a cable-by-cable basis. A series of filters was applied to the cables with thermoplastic and unknown cable jacket or insulation material in order to assess the cable functions. Cables were filtered to exclude cables in conduits, as self-ignited cable fires occur due to over-heating of cables in trays. The results of the applied filters indicate that all of the thermoplastic cables and cables with unknown jacket or insulation material are routed exclusively in conduits, or are low energy, including:
* Pre-fabricated cables that connect to instruments and controls on the main control board in the main control room, which are low energy cables
* 120 VAC control cables, which are low energy cables
* In-core flux mapping cables, which are low energy cables
* Foxboro racks and instrument signal cables, which are all low energy
* Containment leak rate test cables, which are low energy instrument signal cables
* Radiation monitor cables, which are all low energy cables
* Nuclear instrumentation cables which are low energy instrument cables
* Computer cables which are low energy signal cables
* Substation control and instrument cables which are low energy
* Cooling tower control and instrument cables which are low energy
* Communication (sound powered phone and public address) which are low energy cables
* Fire detection cables which are low energy
* Vibration monitoring circuits which are low energy
* Thermocouple cables which are low energy cables.
* Telephone cables which are low energy circuits.
* Emergency radio cables which are low energy cables
* Control cables, powered from a control power transformer with a limited power capability Page 3 of 7

L-PI-15-059                                                                             NSPM Enclosure 1 In summary, based on a detailed review as described above, the cables within the thermoplastic population, and cables with unknown jacket or insulation material are confirmed to be low energy and therefore, the guidance in NUREG-1805 section 7.3 associated with not postulating self-ignited cable fires for low energy cables is applicable.

==References:==
: 1. Engineering Change Evaluation 20695, "Determination of Thermoplastic and Thermoset Cable Types at PINGP."
: 2. NUREG-1805, "Fire Dynamics Tools Quantitative Fire Hazard Analysis Methods for the U.S. NRC Fire Protection Inspection Program."
: 3. V.SPA.15.014, "Screening Self-Ignited Cable Tray Fires from the PINGP Fire PRA,"
Revision 0.
: 4. PINGP USAR Section 7.8.4- Control Room Fire Prevention Design NRC Request PRA RAJ 07.01 While the response to PRA RAt 07 (in letter dated June 19, 2015) states that the guidance in FA Q 13-0004, "Clarifications on Treatment of Sensitive Electronics," is "applicable," it is not clear that this or other accepted guidance associated with the treatment of sensitive electronics is applied to the fire PRA. In particular, the response:
* indicates that the fire PRA 's treatment of sensitive electronics is only "primarily" based on FAQ 13-0004;
* fails to provide the requested explanation on how several specific configurations that fall outside FAQ 13-0004 guidance will be treated;
* does not appear to address the impact of ignition sources other than electrical cabinets (e.g., transients) on sensitive electronics;
* appears to rely, at least in part, on temperature thresholds (i.e., 95&deg;C for the MCR and 200&deg;C for the relay room) that are above those specified in Section H.2 of NUREG/CR-6850 for sensitive electronic equipment; and
* does not appear to be consistent with Appendix S of NUREG/CR-6850 (see PRA RAt 07.02).
Considering the above, please justify that the fire PRA 's treatment of sensitive electronics is consistent with accepted methods. If this treatment is not consistent with accepted methods, then justify the approach or replace the current approach with an acceptable approach in the integrated analysis performed in response to PRA RAt 03.
NSPM Response (PRA RAJ 07.01)
Consistent with the guidance in Fire PRA FAQ 13-0004, the damage criteria associated with 2
incident heat flux for thermoset targets listed in Appendix H of NUREG/CR-6850 (i.e., 11 kW/m )
can be used as a surrogate for sensitive electronic targets provided that:
: 1. Sensitive electronic targets are inside electrical enclosures (i.e., electrical cabinets),
Page  4 of 7

L-PI-15-059                                                                            NSPM Enclosure 1
: 2. Sensitive electronics inside electrical cabinets are not mounted on the wall internal surfaces of the cabinet walls or near openings (louvers) where they could be exposed to direct fire conditions, and
: 3. The 65&deg;C temperature damage criterion for sensitive electronics listed in Appendix H of NUREG/CR-6850 is assessed for other types of fire exposures (i.e., fire generated conditions).
To evaluate these criteria, a comprehensive assessment of potential damage to sensitive electronic targets was conducted in the twenty-five (25) fire compartments within the PINGP Fire PRA where detailed fire modeling has been implemented. All other fire compartments are treated as full-compartment burn scenarios and therefore, sensitive electronics located in those areas are failed at ignition. This evaluation assumes that sensitive electronics are located in electrical cabinets or racks below 6 feet from the floor.
First, the fire generated conditions from fixed and transient ignition sources at the location of the electrical cabinets were determined. This determination yielded an assessment of the time to failure of sensitive electronics in each scenario. Using these times, those scenarios were evaluated to identify any failures that are not already accounted for in the Fire PRA, as follows:
* Main Control Room (MCR), Fire Compartment 13: The analyses documented in the Fire PRA MCR Notebook indicate that time to abandonment ranges from ten to twenty-five minutes depending on the postulated heat release rate. The analyses show that the temperature in the lower portion of the room (i.e., temperature measured in the FDS simulations 3' above the floor, below the hot gas layer) is predicted to be below 65&deg;C for all scenarios. The analyses also indicate a bounding hot gas layer temperature of 65&deg;C at approximately 18 minutes at a height of 6' above the floor. At this time, the control room abandonment criteria for visibility is met as described in response to FM RAI 04.c.01. Following abandonment, no plant equipment in the MCR is credited. As such, the failure of sensitive electronics in the MCR is bounded by the current analysis as the control room is abandoned before sensitive electronics fail.
* The switchgear/bus rooms (Fire Compartments 20, 21, 22, 23, 31, 32, 37, 38, 80, 81, and 117), the Relay Room (Fire Compartment 18), and the 121 Electric Fire Pump Room (Fire Compartment 41 B-1 ): Hot gas layer scenarios are postulated in the Fire PRA for these fire compartments. Inspection of the fire modeling results for each compartment for heights between 3' and 6' above the floor suggest that the threshold limit of 65&deg;C is either not exceeded or exceeded just prior (3 minutes) to the achievement of compartment-wide damage via the hot gas layer. Although Fire Compartment 2GRP is significantly larger, the conclusions of the assessment are similar. The temperature at the location of the electrical cabinets remains below 65&deg;C before the hot gas layer scenario is postulated.
* Fire Compartments 8GRP (Turbine Building), 58GRP (Auxiliary Building Ground Floor),
59GRP (Auxiliary Building Mezzanine Level), 1 and 71 (Units 1 and 2 Containment, respectively), 66 and 72 (Units 1 and 2 Containment Annulus, respectively), 41GRP (Screenhouse General Area), 101GRP (Diesel Room) and 28GRP (Yard): These compartments are relatively large in volume or are located outdoors. Damage to sensitive electronics in these Fire Compartments is expected to be localized and bounded by the failure of PRA components within the Zone of Influence (ZOI)/Transient zone of the ignition source (additional details are provided later in this response).
Temperatures at the location of the electrical cabinets outside the ZOI are predicted to be below 65&deg;C.
Page 5 of 7

L-PI-15-059                                                                            NSPM Enclosure 1 The evaluation associated with incident temperatures described above focuses on the compartment-wide temperature environment generated by the fire at the location of the electrical cabinets. Further evaluation is also necessary to address localized impact due to flame radiation to nearby cabinets from fixed or transient ignition sources. Regarding incident heat fluxes due to fixed and transient fires, the Fire PRA fails all Fire PRA equipment (i.e.,
electrical cabinets) located within the zone of influence of the ignition source in the first damage state. As described in the response to FM RAI 01.g.01, the Fire PRA implements a zone of influence extending 10' from the ignition source, regardless of peak heat release rate of the source. It should be noted that the incident heat flux at 10' from the ignition source is approximately 3.4 kW/m 2 when using the 98 1h percentile heat release rate for the largest fixed ignition source type (1 002 kW, Radiative Fraction of 0.4 is assumed). Consequently, failure of sensitive electronics is bounded by the detailed scenario analysis in the Fire PRA.
The approach summarized above will be described in detail in the corresponding Fire PRA Notebooks (Single Compartment Analysis and Relay Room Fire PRA Notebooks). Updated risk quantification results based on the response to this RAI will be provided as part of the response to PRA RAI 03.

==References:==
: 1. FPRA-PI-SCA-3.0, Single Compartment Analysis, Revision 3.
: 2. FPRA-PI-RR-1.0, Relay Room Analysis, Revision 1.
NRC Request PRA RAJ 07.02 The response to PRA RAJ 07 (in letter dated June 19, 2015) states that "adjacent cabinets in the same bank as the ignition source are failed at the time of the first cable tray failure above the ignition source, which fails sensitive electronics in the adjacent panel (i.e., fails any cables mapped to basic events in these cabinets)." However, the time at which the first cable tray above an ignited cabinet fails does not appear to be related to the time at which adjacent cabinets, including associated sensitive electronics, are impacted by fire. Additionally, this treatment of fire propagation to adjacent cabinets appears inconsistent with Appendix S to NUREG/CR-6850.
Please clarify the above statement and explain how it is consistent with accepted methods (e.g.,
Appendix S). If the approach is not consistent with accepted methods, then justify the approach or replace it with an acceptable approach in the integrated analysis approach in the integrated analysis performed in response to PRA RAJ 03.
NSPM Response (PRA RAI 07.02)
The approach described in the response to PRA RAI 07 was intended to describe a conservative approach as the damage to the first tray above an ignition source in the Fire Area 18 (i.e., the Relay Room) is predicted to be relatively fast (i.e., before the 10 minutes panel to panel propagation time recommended in Appendix S of NUREG/CR-6850). The approach has been updated as part of this response as follows:
Page 6 of 7

L-PI-15-059                                                                             NSPM "Cabinets adjacent to the ignition source are failed at the time of ignition, which fails relevant sensitive electronics or other components in these adjacent panels (i.e., failure includes any cables mapped to basic events in these cabinets)."
The fire scenarios in the relay room have been revised and re-quantified so that the adjacent panels to the ignition source are failed at the time when the fire starts. The results of this quantification will be part of the integrated base Fire PRA model and will be reported as part of the response to PRA RAI 03. In addition, the Relay Room Fire PRA notebook will be updated to reflect the approach described in this response.

==Reference:==
: 1. FPRA-PI-RR-1.0, Relay Room Analysis, Revision 1.
Page 7 of?

L-PI-15-059                                                                       NSPM Enclosure 2 Licensee Identified Changes This Enclosure identifies changes to LAR sections not directly related to RAI responses, and includes the following:
License                 LAR Section                                  Change Identified Issue Attachment A- NEI 04-02 Table B-1,     Licensee identified changes, 1      Transition of Fundamental Fire         clarifications, and corrections to the Protection Program & Design            information provided in Attachment A.
Elements 2      Attachment G, Table G-1 -Recovery      Licensee identified correction to the Actions                                Operator Recovery Actions in Attachment G, Table G-1 -Recovery Actions.
3      Attachment L- NFPA 805 Chapter 3       Addition of Request #4 -Wires Above Requirements for Approval (1 0 CFR     Suspended Ceilings 50.48(c)(2)(vii))
Page 1 of 25

L-PI-15-059                                                                       NSPM licensee Identified Issue #1: Revisions to Attachment A (Table 8-1)
During internal reviews, NSPM identified a number of changes, clarifications, and corrections to the information provided in Attachment A (NEI 04-02 Table B-1, Transition of Fundamental Fire Protection Program & Design Elements). These changes are described as follows:
AttA      NFPA 805 Page       Section                    Description                                    Change                                Justification A-9       3.2.3(1)      Add an allowance to use                Compliance Statement: Revise from                 This change allows Procedures     performance-based frequencies for      'Complies' to 'Complies with Item for             inspection, testing, and inspection, testing, and maintenance,  Implementation' and 'Submit for NRC               maintenance activities to be as requested in Attachment L. (See     Approval'                                         scheduled using NSPM letter dated October 6, 2015)                                                       performance-based Compliance Basis: Add: "NRC approval is           frequencies, consistent with being requested to use Electric Power             guidance in an EPRI Research Institute (EPRI) Technical Report        Technical Report.
(TR) 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features," to establish performance-based frequencies for inspection, testing, and maintenance. See Attachment L."
Procedures will be revised to allow use of performance-based frequencies for inspection, testing, and maintenance as described in EPRI TR 1006756.
Items for Implementation: Change 'None' to:
                                                                    'As described in Table S-3, item #67, performance-based frequencies for inspection, testing, and maintenance will be established as described in EPRI TR 1006756. The performance-based surveillance frequencies will be evaluated in Page 2 of 25

L-PI-15-059                                                                     NSPM AttA     NFPA 805 Page      Section                  Description                                    Change                               Justification the monitoring program in accordance with NFPA 805 FAQ 10-0059.'
A-20       3.3.1.2   Add an allowance to use                 Compliance Statement: Add: 'Submit for           NFPA 805 does not allow Control of commercially available products         NRC Approval' and 'Complies with Item for        untreated wood products, Combustible  which utilize small quantities of non-   Implementation.'                                except for cribbing materials materials  treated wood; in addition, allow                                                         6" x 6" and larger. This temporary use of untreated wood for      Compliance Basis: Add: "NRC Approval is         change allows Fire Protection material transport (e.g., pallets or    requested to allow use of commercially           Engineers to evaluate use of crates) under administrative controls   available products which utilize small           products containing wood, for quantity, duration, and              quantities of non-treated wood as an integral   and to specify appropriate compensatory measures, as                part of a finished product, such as tools,      controls under which these requested in Attachment L. (See         janitorial supplies, special fixtures, measuring materials may be used.
NSPM letter dated October 6, 2015)       and test equipment, and office-type furniture.
Also, approval is requested to allow use of untreated wood pallets for temporary material/equipment transport (e.g., pallets or crates) provided administrative controls are in place to address the quantity, duration, and compensatory measures/engineering evaluation for this use. See Attachment L."
Add: "Procedure FP-PE-CC-01 will be revised to add an exception to allow small quantities of wood in commercial products, and in temporary uses (e.g., pallets) when the quantity, duration, and compensatory measures are administratively controlled."
Item for Implementation: Add: "As described in Table S-3, item 61, site procedures for control of combustible materials will be revised for consistency with the assumptions Page  3 of 25

L-PI-15-059                                                                  NSPM AttA     NFPA 805 Page       Section               Description                                   Change                                Justification in the Fire PRA. Controls for use of limited quantities of untreated wood will be included in this revision."
A-24      3.3.1.2(5) Change Compliance Statement to        Compliance Statement: Change 'Complies' to       This clarifies that compliance Control of include EEEE, because EEEE            'Complies with use of Existing Engineering       with this NFPA 805 section is Combustible  explains deviations from the subject  Equivalency Evaluation.'                         based on discussions in the materials  NFPA code.                                                                             EEEE, as cited in Plant Compliance Basis: ADD "All sections of the       Documentation.
code have been met or deviations have been justified."
EEEE/Summary: NFPA 30, Code Conformance Review Checklist Flammable and Combustible Liquid Code, 1987, Rev 1, 12/2010

== Description:==
The purpose of this analysis is to document the review of NFPA 30 Flammable and Combustible Liquid Code, for compliance with the applicable requirements.
Summary: All sections of the code have been met or deviations have been justified.
EEEE/Summary: NFPA 30, Code Conformance Review Checklist Flammable and Combustible Liquid Code, 1969.0, Rev 1, 12/2010.

== Description:==
The purpose of this analysis is to document the review of NFPA 30 Flammable and Combustible Liquid Code, for compliance Page 4 of 25

L-PI-15-059                                                                 NSPM AttA     NFPA 805 Page      Section                Description                                    Change                               Justification with the applicable requirements.
Summary:
All sections of the code have been met or deviations have been justified.
Documentation I 

==References:==
for clarity, delete the following documents which are not applicable to this topic:
                                                             - NRC SER dated 9/6/79
                                                             - NFPA 10, "Standard for the Installation of Portable Fire Extinguishers," 2007 Edition.
A-25      3.3.1.2(6) Change Compliance Statement to         Compliance Statement: Change to "Complies       This clarifies that compliance Control of include EEEE, because EEEE            with use of Existing Engineering Equivalence     with this NFPA 805 section is Combustible  explains deviations from the subject   Evaluation."                                    based on discussions in the materials  NFPA standard.                                                                         EEEE, as cited in Plant Compliance Basis: ADD "All sections of the      Documentation.
code have been met or deviations have been justified."
EEEE/Summary: Add "FPEE-11-018, NFPA 55, Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks, Bulk Hydrogen Compressed Gas Storage System.

== Description:==
The purpose of this analysis is to document the review of the bulk hydrogen compressed gas storage system against the requirements of National Fire Protection Page 5 of 25

L-PI-15-059                                                                  NSPM 
 . AttA    NFPA 805
 , Page     Section                Description                                    Change                                Justification
 '                                                           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.
Summary: All sections of the code have been met or deviations have been justified.
A-27     3.3.1.3.1  Change Compliance Statement to        Compliance Statement: Add: 'Complies with         This clarifies that compliance Control of include EEEE, because EEEE             use of Existing Engineering Equivalency          with this NFPA 805 section is Ignition  explains deviations from the subject   Evaluation.'                                     based on discussions in the Sources   NFPA standard.                                                                          EEEE, as cited in Plant EEEE/Summarv: Correct code compliance            Documentation.
review number in the Summary discussion on page A-28 from FPEE-11-021 to FPEE                                                               020 (2 places).
A-36      3.3.5.1   Change to allow minimal wiring         Compliance Statement: Change from                This change will avoid the Electrical above suspended ceilings, as           'Complies' to: 'Submit for NRC Approval.'        need to move or protect requested in Attachment L.                                                              communication wiring and a Compliance Basis: Delete: "Based on this         minimal amount of power information, there is no wiring above solid      cables currently located suspended ceilings."                             above suspended ceilings.
Add: "Suspended ceilings have been identified with cabling that does not meet the requirements of Section 3.3.5.1. Approval to accept the existing installation is requested in Attachment L."
A-43       3.3.7.1   Change Compliance Statement to        Compliance Statement: Add: "Complies with        This clarifies that compliance Page  6 of 25

L-PI-15-059                                                                    NSPM AttA     NFPA 805 Page       Section                Description                                   Change                             Justification Bulk    include EEEE, because EEEE             use of Existing Engineering Equivalence       with this NFPA 805 section is Flammable   explains deviations from the subject    Evaluation."                                 based on discussions in the Gas Storage  NFPA standard.                                                                       EEEE, as cited in Plant Compliance Basis: Add "All sections of the    Documentation.
code have been met or deviations have been justified."
EEEE/Summary: Add FPEE-11-018, NFPA 55 - 2005, Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks

== Description:==
The purpose of this analysis is to document the review of the bulk hydrogen compressed gas storage system against the requirements of NFPA 55, 2005, Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks.
Summary: All sections of the code have been met or deviations have been justified.
A-46         3.3.8    Change Compliance Statement to         Compliance Statement: Change to "Complies    This clarifies that compliance Bulk Storage  include EEEE, because EEEE             with use of Existing Engineering Equivalence with this NFPA 805 section is of Flammable  explains deviations from the subject   Evaluation."                                 based on discussions in the and     NFPA code.                                                                          EEEE, as cited in Plant Combustible                                          Compliance Basis: Add "All sections of the   Documentation.
Liquids                                          code have been dispositioned as acceptable or acceptable as-is with a technical justification."
Page 7 of 25

L-PI-15-059                                                          NSPM AttA     NFPA 805 Page      Section            Description                                Change                               Justification EEEE/Summary: NFPA 30, Code Conformance Review Checklist Flammable and Combustible Liquid Code, 1987, Rev 1, 12/2010.

== Description:==
The purpose of this analysis is to document the review of NFPA 30 Flammable and Combustible Liquid Code, for compliance with the applicable requirements.
Summary: All sections of the code have been met or deviations have been justified.
EEEE/Summary: NFPA 30, Code Conformance Review Checklist Flammable and Combustible Liquid Code, 1969, Rev 1, 12/2010.

== Description:==
The purpose of this analysis is to document the review of NFPA 30 Flammable and Combustible Liquid Code, for compliance with the applicable requirements.
Summary: All sections of the code have been met or deviations have been justified.
Plant Documentation: for clarity, delete NRC SER dated 9/6/79 as this is not applicable to this topic.
A-60      3.4.1 (a) Change Compliance Statement to   Compliance Statement: Add 'Complies with        This clarifies that compliance Page 8 of 25

L-PI-15-059                                                                   NSPM AttA     NFPA 805 Page       Section                 Description                                    Change                              Justification Fire Fighting add EEEE, because EEEE explains       use of Existing Engineering Equivalency          with this NFPA 805 section is deviations from the subject NFPA      Evaluation.'                                     based on discussions in the standard.                                                                              EEEE, as cited in Plant Compliance Basis: Add "The fire brigade has      Documentation.
been reviewed against the requirements of NFPA 600, as detailed in Fire Protection Engineering Evaluation (FPEE) 11-031. No deviations have been identified with the criteria of NFPA 600; therefore, no further action is necessary."
EEEE/Summarv: Add "FPEE-11-031, Code Compliance Review, NFPA 600, Standard on Industrial Fire Brigades, 2000, Revision 1.

== Description:==
The purpose of this analysis is to document the review of the Prairie Island Nuclear Generating Plant Fire Brigade for compliance with the requirements of National Fire Protection Association (NFPA) 600-2000, Standard for Industrial Fire Brigades (Code of Record.) No deviations have been identified with the criteria of NFPA 600.
Summary: No deviations have been identified with the criteria of NFPA 600; therefore, no further action is necessary."
A-71        3.4.3(1)  Change Compliance Statement to         Compliance Statement: Change 'Complies' to      This clarifies that compliance Fire Brigade include EEEE, because EEEE             'Complies with use of Existing Engineering      with this NFPA 805 section is Training   explains deviations from the subject   Equivalency Evaluation.'                        based on discussions in the NFPA standard.                                                                         EEEE, as cited in Plant Comoliance Basis: Add "Deviations from the      Documentation.
Page 9 of 25

L-Pl-15-059                                                                    NSPM AttA     NFPA 805 Page       Section                   Description                                  Change                               Justification standard were determined to be acceptable."
Add clarification: Fire brigade training consists of the following elements:
* Classroom training                                                    i
* Live fire training
* Drills EEEE/Summary: Add "FPEE-11-031, Code Compliance Review, NFPA 600, Standard on Industrial Fire Brigades, 2000, Revision 1.

== Description:==
The purpose of this analysis is to document the review of the Prairie Island Nuclear Generating Plant Fire Brigade for compliance with the requirements of National Fire Protection Association (NFPA) 600-2000, Standard for Industrial Fire Brigades (Code of Record.) No deviations have been identified with the criteria of NFPA 600.
Summary: No deviations have been identified with the criteria of NFPA 600; therefore, no further action is necessary."
A-73      3.4.3(a)(2)  Clarify the Compliance Basis to more  Compliance Basis: Replace existing              This change is provided to Training and   specifically address training.        discussion, which is more applicable to Drills, clarify that the PINGP Fire Drills Section                                       with the following:                             Brigade Training program (2)                                                                                            was previously explained to Per Section 4.8.3 of Procedure F5, "Fire      the NRC and was previously Fighting," the fire brigade training program  approved in an SER.
includes instruction on general plant access, fire fighting tactics and hazards, use of fire fighting equipment, and radiation Page 10 of 25

L-PI-15-059                                                        NSPM AttA     NFPA 805 Page      Section               Description                             Change                           Justification and contamination considerations. "An initial Levell I training program with annual retraining (every 9 to 15 months shall be conducted). Level II retraining shall repeat all subject material over a period of approximately two years."
NSP letter dated 5/2/1979, Section 3.2 describes training for Fire Brigade members and states that "An initial training program with annual retraining will be conducted. Retraining will repeat all Level II subject material over a period of approximately two years."
NRC SER dated 9/6/1979 references the 5/2/1979 NSP letter and concludes per Section 6.2 that "the fire brigade training program conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."
Although the "9 to 15 months" clarification was not included in the 5/2/1979 letter, this
                                                     .+/-25% tolerance is reasonable and is consistent with the intent of the previous approval.
The basis for approval has been reviewed.
There have been no plant modifications or other changes that would invalidate the basis for approval.
A-76      3.4.3(b) Clarify the Compliance Basis   Compliance Basis:                              This change clarifies the Page 11 of 25

L-PI-15-059                                                                       NSPM AttA      NFPA 805 Page       Section                     Description                                    Change                                 Justification Training and     statement regarding training of other   Delete: the second paragraph regarding            section in Procedure F5 that Drills      plant personnel; Section 4.8.5 is a     Section 2. 7 of Procedure F5.                     addresses training for other more appropriate section in the F5                                                        plant personnel who respond procedure to demonstrate                Add: Per Procedure F5, "Fire Fighting,"           a fire.
compliance with the NFPA 805            Section 4.8.5, Other Responding Personnel, Requirements/ Guidance statement.       "Plant and non-plant personnel who respond to a fire scene shall be trained in hazards, responsibilities, and inoperability to the extent required to perform their function. This requirement is met in security and Chemistry/
RP training programs and by annual RWFD training and drill preparation."
A-77    3.4.3(c), Drills Change the Compliance Statement         Compliance Statement: Change 'Complies' to        This change is provided to Section (1)    to reflect previous NRC approval,       'Complies via Previous Approval.'                 clarify that the PINGP Fire and clarify the Compliance Basis.                                                         Brigade Drills program was Compliance Statement: Add:                        previously explained to the NRC and was previously "NSP letter dated 5/2/1979, Section 4.1         approved in an SER.
states that "Drills will be scheduled so that each fire brigade member will participate in at least two drills per year."
                                                                     "NRC SER dated 9/6/1979 references the 5/2/1979 NSP letter and concludes per Section 6.2 that "the fire brigade training program conforms to the provisions of Appendix A to BTP 9.5-1 and is, therefore, acceptable."
                                                                      "The basis for approval has been reviewed.
There have been no plant modifications or other changes that would invalidate the Page 12 of 25

L-PI-15-059                                                                        NSPM AttA      NFPA 805 Page       Section                     Description                                     Change                                 Justification basis for approval."
A-81    3.4.3(c), Drills Correct the Compliance Basis             Compliance Basis: Revise the statement             This change will delete Section (4)    discussion regarding fire brigade        regarding fire brigade record retention to         information that is not needed record retention; the retention period   delete "for at least two (2) years".               to address compliance with is actually 3 years instead of 2 years                                                      the NFPA 805 requirement, as stated, but there is no required                                                         and its deletion from period identified in the NFPA 805                                                           Attachment A will simplify Requirement/ Guidance statement.                                                            future efforts to change or delete this information.
A-         3.5.15       Change Compliance Statement to           Compliance Statement: Add: 'Complies with          This clarifies that compliance 109    Water Supply     also include EEEE, because EEEE          use of Existing Engineering Equivalency            with this NFPA 805 section is explains deviations from the subject     Evaluation.'                                       based on discussions in the NFPA standard.                                                                              EEEE, as cited in Plant Compliance Basis: Add "All sections of the         Documentation.
code have been met or deviations have been justified."
ADD; "EEEE/Summary: FPEE-09-012 Removal and Consolidation of Fire Hose from Fire Hydrant Hose Houses 11 through 26.

== Description:==
The purpose of this evaluation is to determine the acceptability of removing the fire hose from fire hydrant hose houses in the area surrounding the cooling towers (outside the protected area) and storing hose in a readily available mobile trailer for firefighting use.
Summary: The fire hose currently stored in the individual hose houses surrounding the Cooling Towers (HH-11 through 26) may be Page 13 of 25

L-PI-15-059                                                               NSPM AttA     NFPA 805 Page      Section              Description                                    Change                                Justification consolidated and stored in a mobile location readily available for firefighting use. The mobile trailer will provide better protection for fire hose from rodents and the weather. The hose houses will be left in place as they will still house other firefighting equipment.
EEEE/Summary: Add "NFPA 24-1969, Standard for Outside Protection, Revision 1, December 2010.

== Description:==
The purpose of this analysis is to document the review of the yard piping system for compliance with the applicable requirements cited in National Fire Protection Association 24, (NFPA) -1969, Standard for Outside Protection, (Code of Record).
Summary: All sections of the code have been met or deviations have been justified."
A-         3.7   Change Compliance Statement to          Compliance Statement: Change 'Complies'          This clarifies that compliance 122              also include EEEE, because EEEE        to: 'Complies with use of Existing Engineering    with this NFPA 805 section is explains deviations from the subject    Equivalency Evaluation.'                         based on discussions in the NFPA standard.                                                                           EEEE, as cited in Plant Compliance Basis: Add "All sections of the       Documentation.
code have been met or deviations have been justified."
EEEE/Summarv: Fire Protection Engineering Evaluation, NFPA 10- 1969, Standard for Portable Fire Extinguishers Code Compliance Deviations, Rev. 1, AR 01179416-04.
Page 14 of 25

L-PI-15-059                                                              NSPM AttA     NFPA 805 Page      Section               Description                                  Change                             Justification

== Description:==
The purpose of this evaluation is to document the review of the fire extinguishers in safety related areas of the powerblock (excluding the SBO Building) for compliance with applicable requirements cited in National Fire Protection Association NFPA No. 10- 1969, Standard for Portable Fire Extinguishers (Code of Record).
Summary: One deviation has been found against the requirement of NFPA 10. The deviation has been determined to be acceptable as is.
EEEE/Summary: Code Compliance Review NFPA 10 1986, Standard for Portable Fire Extinguishers.

== Description:==
The purpose of this evaluation is to document the review of the fire extinguishers in the SBO Building for compliance with applicable requirements cited in National Fire Protection Association NFPA No. 10- 1986, Standard for Portable Fire Extinguishers (code of record).
Summary: All sections of the code have been met or deviations have been justified.
A-   3.8.2 Detection Change Compliance Statement to    Compliance Statement: Add: 'Complies with      This clarifies that compliance Page 15 of 25

L-PI-15-059                                                                NSPM AttA     NFPA 805 Page      Section              Description                                     Change                              Justification 131              also include EEEE, because EEEE        use of Existing Engineering Equivalency          with this NFPA 805 section is explains deviations from the subject   Evaluation.'                                     based on discussions in the NFPA standard.                                                                          EEEE, as cited in Plant Compliance Basis: Add "Deviations from the       Documentation. Also, it adds code were determined to be acceptable."          a missing FPEE.
EEEE/Summary: FPP-5 (NFPA 72);

== Description:==
The purpose of this analysis is to document the review of Prairie Island Nuclear Generating Plants' Units 1 and 2 power block building areas that contain fire detection systems for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 72E, Standard on Automatic Fire Detection Systems, 1974, 1982 and 1987 Editions. Deviations noted during the performance of the review and their associated resolutions are discussed in detail later in this analysis.
Summary: The analysis of the plant detection systems included the design, physical placement, environmental application, and testing of the fire detection initiating devices installed throughout the plant. The review of the fire detection systems installed in the plant determined that while portions of the systems met the letter of the code requirements, portions met the intent of the code, while others will require further review.
EEEE/Summarv: FPEE-11-048 Code Page 16 of 25

L-PI-15-059                                      NSPM AttA     NFPA 805 Page      Section Description                        Change                      Justification Compliance Review NFPA 72E, Automatic Fire Detectors, 1974, 1982, 1987 Detector* Spacing and Location for Plant Area Systems Not Addressed in FPP-5 R2

== Description:==
The purpose of this analysis is to document the review of automatic fire detectors not previously reviewed in FPP-5 R2, NFPA 72E Code Compliance Evaluation, dated April 21, 2004.
Summary: Several open items have been resolved while the remaining issues will be completed as described in Table S-2, item
                                  #8. Required modifications have been identified and will be completed in accordance with the associated schedule.
EEEE/Summary: FPEE-11-035 Code Compliance Review NFPA 72, Standard For The Installation, Maintenance, And Use Of Protective Signaling Systems, 1990 Turbine Generator Fire Protection System, Revision 0

== Description:==
The purpose of this analysis is to document the review of the fire alarm systems provided as part of the Unit 1 and Unit 2 Turbine Generator fire protection systems. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 72- 1990, Standard for the Installation, Page 17 of 25

L-PI-15-059                                                                  NSPM AttA     NFPA 805 Page      Section                 Description                                   Change                                Justification Maintenance, and Use of Protective Signaling Systems (Code of Record.)
Summary: All four deviations have been justified as "acceptable"; therefore, no further action is necessary.
A-        3.10.1    Change Compliance Statement to         Compliance Statement: Add: 'Complies with        This clarifies that compliance 144    Gaseous Fire also include EEEE, because EEEE        use of Existing Engineering Equivalency          with this NFPA 805 section is Suppression  explains deviations from the subject    Evaluation.'                                    based on discussions in the NFPA standard.                                                                          EEEE, as cited in Plant Compliance Basis: Add "Deviations from the      Documentation.
code were determined to be acceptable."
Add "NFPA 12A does not apply, as halon systems are not credited in the B-3 table".
EEEE/Summary: FPEE-11-038 Code Compliance Review NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 1972 Relay and Computer Room, Fire Area 18, Revision 0.

== Description:==
The purpose of this analysis is to document the review of the automatically-actuated carbon dioxide (C02) suppression system protecting the Relay and Computer Room in Fire Area 18 for compliance with the requirements of National Fire Protection Association (NFPA) 12 -1972, Standard on Carbon Dioxide Extinguishing Systems (Code of Record.)
Page 18 of 25

L-PI-15-059                                                          NSPM AttA     NFPA 805 Page      Section             Description                                Change                              Justification Summary: All sections of the code have been met or deviations have been justified.
EEEE/Summary FPEE-11-048 Code Compliance Review NFPA 72E, Automatic Fire Detectors, 1974, 1982, 1987 Detector* Spacing and Location for Plant Area Systems Not Addressed in FPP-5 R2

== Description:==
The purpose of this analysis is to document the review of automatic fire detectors not previously reviewed in FPP-5 R2, NFPA 72E Code Compliance Evaluation, dated April 21, 2004.
Summary: Several open items have been resolved while the remaining issues will be completed as described in Table S-2, item
                                                      #8. Required modifications have been identified and will be completed in accordance with the associated schedule.
A-        3.11.4 Change Compliance Statement to    ADD "Complies via Previous Approval and         PINGP determined that the 162              include Item for Implementation    Item for Implementation"                       Internal Penetration Seal Program requires Items for lmglementation: Add "Enhance the     enhancement to provide Internal Penetration Seal Program as           additional rigor.
described in Table S-3, Item 69."
Page 19 of 25

L-PI-15-059                                                                           NSPM Licensee Identified Issue #2: Revisions to Attachment G, Table G-1 (Recovery Actions)
During internal reviews, NSPM identified a correction to the Operator Recovery Actions. This correction involves a change to Attachment G, Table G-1, Recovery Actions, to add the following actions: isolate Auxiliary Feedwater from the 22 Steam Generator, de-energize the Bus 15 Load Sequencer, and de-energize the Bus 25 Load Sequencer. This includes:
* Fire Area: 013, 018 o Operated Component: MV-32249 o Component

== Description:==
21/22 AFW to 22 SG ISOL MV o Action: Close MV-32249, 21/22 AFWto 22 SG ISOL MV (in 3" line J.6/12.2).
o VFDR: VFDR-013-2-03, VFDR-018-2-03 o RA/PCS: RA
* Fire Area: 013, 018 o Operated Component: B15/LD SEQ CAB o Component

== Description:==
Bus 15 SFGDS Load Sequencer Cabinet o Action: Place toggle switch on P1 power supply to "OFF" position (located on the right side of enclosure, upper rear corner). This will de-energize the load sequencer.
o VFDR: VFDR-013-1-06, VFDR-018-1-06 o RA/PCS: RA
* Fire Area: 013, 018 o Operated Component: B25/LD SEQ CAB o Component

== Description:==
Bus 25 SFGDS Load Sequencer Cabinet o Action: Place toggle switch on P1 power supply to "OFF" position (located on the right side of enclosure, upper rear corner). This will de-energize the load sequencer.
o VFDR: VFDR-013-2-06, VFDR-018-2-06 o RA/PCS: RA These actions are described in the supporting documentation for the Fire PRA (Alternate Shutdown notebook, FPRA-PI-FASD-2.0, included in the Prairie Island NFPA 805 Online Reference Portal), but were inadvertently not included in the LAR.
Page 20 of 25

L-PI-15-059                                                                               NSPM Enclosure 2 Licensee Identified Issue #3: Addition of Attachment L Request #4 Approval Request 4- Wiring Above Suspended Ceilings NFPA 805 Section 3.3.5.1 states:
         "Wiring above suspended ceiling shall be kept to a minimum. Where installed, electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers."
This approval request has been prepared in two parts. Part 1 addresses the Fire Areas noted below. Part 2 addresses Fire Area 8 Locker Room, Unit 1, 715' Southeast corner, which has a different technical basis than the Fire Areas noted below.
Part 1:
A visual inspection of the spaces above the suspended ceiling in the following fire areas was conducted. The inspection revealed the existence of minimal quantities of wiring (cables) including low voltage video/communication/data cables and power cables that do not meet the criteria of NFPA 805 Section 3.3.5.1:
* Fire Area 8 Lunch Room, Unit 1, 715' in Southeast corner
* Fire Area 8 Locker Room, Unit 2, 715' in Northwest corner
* Fire Area 83 SAS and Operations Lounge
* Fire Area 94 Computer Room NSPM requests approval of the noncompliant cables above suspended ceilings identified above. This is considered to be a deviation from an NFPA 805 element, for which NRC approval is requested.
Basis for Request:
The basis for the approval request of this deviation is:
* The majority of the cables are low voltage video/communication/data cables and are not susceptible to self-ignition and electrical shorts that would result in a fire in the enclosed space.
* There are minimal sections of low voltage power cable (below 480VAC) supplying an emergency lighting unit and a junction box.
* The only potential ignition sources above the suspended ceilings are florescent lighting fixtures and short section of power cables. There are no additional ignition sources in the listed areas above the suspended ceilings.
* The areas above the suspended ceilings are not used as HVAC plenums or as part of a smoke purge system.
* The SAS is continually manned providing early notification and the potential use of a fire extinguisher as early extinguishment prior to brigade arrival.
* Fire Area 8 Locker Room Unit 2, 715' Northeast corner and Fire Area 8 Lunch Room Unit 1, 715' in the Southeast corner are frequently occupied, thereby providing early Page 21 of 25

L-PI-15-059                                                                               NSPM Enclosure 2 notification and the potential use of the fire extinguisher located in the room as early extinguishment prior to brigade arrival.
* The estimated bounding quantity of non-plenum rated cable does not significantly increase combustible loading enough to challenge fire barrier integrity.
* The walls are constructed of concrete/concrete block and although not credited, will mitigate fire propagation into an adjoining fire area until the arrival of the fire brigade.
Plant procedures will be revised to ensure that future wiring installations above suspended ceilings will conform to NFPA 805 Section 3.3.5.1. Attachment S, Table S-3, Item # 68 will be initiated to revise plant procedures.
Estimated Bounding Quantity of Cables (linear feet):
Fire Area   8 Lunch Room, Unit 1, 715' in Southeast corner- 200' Fire Area   8 Locker Room, Unit 2, 715' in Northwest corner- 100' Fire Area   83 SAS and Operations Lounge - 500' (Approximately 120' is power cable below 480VAC)
Fire Area   94 Computer Room -1 ,000' Acceptance Criteria Evaluation Nuclear Safety and Radiological Release Performance Criteria:
The presence of non-rated and non-enclosed wiring above these suspended ceilings in these fire areas does not adversely affect nuclear safety capability. The amount of wiring that is not rated for plenum use and is not located in conduit is minimal. Also, low voltage video/communication/data cabling is not generally susceptible to shorts that would result in a fire. Ignition sources above the suspended ceiling are limited to the florescent lighting fixtures and shorts in the power cables (below 480VAC). Therefore, there is no adverse impact on the nuclear safety performance criteria due to the non-rated plenum cabling in these areas.
The Nuclear Safety Capability Assessment (NSCA) evaluation determined Fire areas 8, 83, and 94 meet the deterministic requirements of NFPA 805, Section 4.2.3. The NSCA impacts for a fire above the suspended ceiling of Fire Area 8 Lunch Room, Unit 1, 715', Southeast corner, Fire Area 8 Locker Room, Unit 2, 715', Northwest corner, Fire Area 83, and Fire Area 94 are as follows:
* Fire Area 8 Lunch Room, Unit 1, 715' in Southeast corner- There are no NSCA cables above the suspended ceiling in this fire area location, therefore, a fire occurring above the suspended ceiling would have no impact on the NSCA.
* Fire Area 8 Locker Room, Unit 2, 715' in Northwest corner- There are no NSCA cables above the suspended ceiling in this fire area location, therefore, a fire occurring above the suspended ceiling would have no impact on the NSCA.
* Fire Area 83: SAS and Operations Lounge - A fire could affect cables involving source range monitoring, RCS pressure, RCS temperature, and steam generator level which could result in the loss of one channel for each unit. The other channel has been Page 22 of 25

L-PI-15-059                                                                             NSPM Enclosure 2 demonstrated to remain available. Therefore, there is no impact on the nuclear safety performance criteria.
* Fire Area 94: Computer Room -There are no NSCA cables above the suspended ceiling in this fire area location, therefore, a fire occurring above the suspended ceiling would have no impact on the NSCA.
The location of non-rated and non-enclosed wiring above these suspended ceilings has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the type of wiring or locations of suspended ceilings. Radiological material is not used or stored in these areas.
Safety Margin and Defense-in-Depth:
The amount of non-rated and non-enclosed wiring above the ceilings in the Power Block is minor and does not present a significant fire hazard. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.
NEI 04-02, Section 5.3.5.2 describes three echelons for defense-in-depth:
: 1) Preventing fires from starting (e.g., combustible/hot work controls),
: 2) Detecting fires quickly and extinguishing those that occur, thereby limiting damage (e.g.,
fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans), and
: 3) 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 (e.g., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).
The introduction of the non-rated and non-enclosed wiring routed above these suspended ceilings does not impact fire protection defense-in-depth. The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability.

==
Conclusion:==

Based on the evaluation of the variance from the requirements of NFPA 805 Chapter 3, PINGP has determined the existing configuration:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release;
* Maintains safety margins; and
* Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
Page 23 of 25

L-PI-15-059                                                                               NSPM Enclosure 2 Part 2:
NSPM requests approval of noncompliant cables above the suspended ceiling in the Fire Area 8 Locker Room, Unit 1, 715' in the Southeast corner.
Based on a review of plant drawings, cable routing, and field walk downs, the area above the suspended ceiling of this fire area location contains several cable trays with multiple types and voltages ranging from free-air run low voltage data/communications and lighting fixture cabling, to open trays containing 120VAC control, and up to 4kV power cabling. These cables do not meet the requirements of NFPA Section 3.3.5.1.
This is considered to be a deviation from this NFPA 805 element, for which NRC approval is requested.
Basis for Request:
This basis for the approval request of this deviation is:
* The area above the suspended ceiling in this location is not used as HVAC plenum or as part of a smoke purge system.
* This location is frequently occupied thereby providing early notification and the potential use of the fire extinguishers which are located in the area as early extinguishment prior to brigade arrival.
* The walls are constructed of concrete/concrete block and although not credited, will mitigate fire propagation into an adjoining fire area until the arrival of the fire brigade.
Estimated Bounding Quantity of Cables (linear feet):
Fire Area 8 Locker Room, Unit 1, 715' in Southeast corner- 3,000' This is primarily low voltage data/communications and lighting fixture cabling. Approximately 120' is 4kV cable.
Acceptance Criteria Evaluation:
Nuclear Safety and Radiological Release Performance Criteria:
The location of non-rated and non-enclosed wiring above the suspended ceiling in the Fire Area 8 Locker Room, Unit 1, 715' Southeast corner has no impact on the radiological release performance criteria. The radiological review was performed based on the potential location of radiological concerns and is not dependent on the type of wiring or location of suspended ceilings. Radiological material is not used or stored in this area.
The Nuclear Safety Capability Assessment (NSCA) evaluation of this fire area location has determined the following:
* Fire Area 8 Locker Room, Unit 1, 715' Southeast corner- A fire occurring in this fire area location could affect cables that supply power to diesel ventilation (support equipment) for diesel generators 01 and 02; however, this equipment is not credited in the NSCA for this area, and therefore, the nuclear safety performance criteria are met.
Page 24 of 25

L-PI-15-059                                                                             NSPM Enclosure 2 Safety Margin and Defense-in-Depth:
NEI 04-02, Section 5.3.5.2 describes three echelons for defense-in-depth:
: 1) Preventing fires from starting (e.g., combustible/hot work controls),
: 2) Detecting fires quickly and extinguishing those that occur, thereby limiting damage (e.g., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans), and
: 3) 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 (e.g., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).
The introduction of the non-rated and non-enclosed wiring routed above the suspended ceiling in this fire area location does not impact fire protection defense-in-depth. The wiring located above the ceilings does not compromise administrative fire prevention controls, and does not challenge automatic fire detection and suppression functions, manual fire suppression functions, or post-fire safe shutdown capability.

==
Conclusion:==

Based on the evaluation of the variance from the requirements of NFPA 805 Chapter 3 PINGP has determined the existing configuration:
* Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release;
* Maintains safety margins; and
* Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
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