ML12278A405

Prairie Island, Units 1 and 2, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors

ML12278A405
Person / Time
Site:	Prairie Island
Issue date:	09/28/2012
From:	Sorensen J P Northern States Power Co, Xcel Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-PI-12-089, TAC ME6675, TAC ME6676
Download: ML12278A405 (1030)

Text

[[:#Wiki_filter:Xcel EnergyB Prairie lsland Nuclear Generating Plant 171 7 Wakonade Drive East Welch, MN 55089 SEP 2 8 2042 L-PI-12-089 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie lsland 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

References:

1. NSPM letter, M.A. Schimmel 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, dated June 22,201 1, ADAMS Accession No. MLI 11 740866 2. NRC letter, J.G. Giitter to M.A. Schimmel, 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 lsland Nuclear Generating Plant, Units I and 2 (TAC NOS. ME6675 and ME6676), dated July 29,201 1, ADAMS Accession No. MLI 12010417 Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota Corporation (NSPM), doing business as Xcel Energy, hereby requests an amendment to the renewed operating license for the Prairie lsland Nuclear Generating Plant (PINGP). The proposed license amendment request (LAR) requests Nuclear Regulatory Commission (NRC) approval for adoption of a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, Revision 1, "Risk-Informed, Performance Based Fire Protection for Existing Light-Water Nuclear Power Plants." This amendment request also follows the guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2, Document Control Desk Page 2 "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)." Upon approval, the PINGP fire protection program will transition to a new Risk- Informed, Performance-Based (RI-PB) alternative in accordance with 10 CFR 50.48(c), which incorporates by reference National Fire Protection Association Standard 805 (NFPA 805). The NFPA 805 fire protection program will supersede the current fire protection program licensing basis in accordance with 10 CFR 50, Appendix R. In a letter dated June 22, 201 1 (Reference I), NSPM committed to submit a LAR by September 30, 2012 for PINGP to transition to 10 CFR 50.48(c), and requested the continuation of enforcement discretion through the NFPA 805 LAR approval process. By letter dated July 29, 201 1 (Reference 2), the NRC acknowledged the application date for PINGP and provided enforcement discretion in accordance with the Interim Enforcement Policy concerning Enforcement Discretion for Certain Fire Protection Issues as published in the Federal Register on July 12, 201 1 (76 FR 40777). Submittal of this letter satisfies NSPM's commitment and supports continuation of enforcement discretion through the NFPA 805 LAR approval process. Enclosure 1 contains the PINGP Transition Report (TR) and its supporting attachments. The TR provides the required technical and regulatory assessments to enable NRC review and approval of the new licensing basis. The PINGP TR is based on Revision 1 L of the industry template developed by the NEI NFPA 805 Task Force and adopts the resolution of applicable Frequently Asked Questions. Per discussions with NRC staff on August 8, 2012, Attachment U of the enclosed TR provides DRAFT information regarding the internal flooding PRA peer review findings and observations. This information will be provided in final form with dispositions as discussed with the NRC staff and per the commitment below. The transition to the proposed new fire protection licensing basis includes the following high level activities: a new fire safe shutdown analysis, a new Fire Probabilistic Risk Analysis (PRA), and completion of activities required for transitioning the licensing basis to 10 CFR 50.48(c). A Fire PRA to support the RI-PB change evaluations per Regulatory Positions C.2.2 and C.4.3 of RG 1.205 has been completed. The PRA was developed in accordance with NUREGICR-6850 and EPRl TR-1011989 and is discussed in Enclosure I, Section 4.5. In accordance with the guidance in Regulatory Position C.2.2.4.2 of Regulatory Guide 1.205, Revision 1, NSPM has evaluated the total risk change associated with pre-transition fire protection program variances meeting the NFPA 805 performance- based approach (via the fire risk evaluation process). Further, upon completion of the plant modifications, as referenced in section 4.8.2 of the TR, the total change in risk associated with PINGP's transition to NFPA 805 will be consistent with the acceptance guidelines in Regulatory Guide 1 .I 74. Document Control Desk Page 3 As documented in this request, NSPM has met the NRC regulatory requirements for the transition of its fire protection licensing basis, the license amendment does not present a significant hazards consideration, and the criteria for a categorical exclusion from the need for an environmental assessment have been met. NSPM requests approval of this license amendment request within 24 months after the date of this letter, and proposes to implement the new fire protection licensing basis in accordance with the implementation schedule provided in Section 5.5 of the attached TR. Specifically, per the transition license condition, the plant modifications identified in Table S-2 of the TR will be implemented in accordance with the schedule provided in Attachment S of the TR, based on their complexity, risk significance, and need for compliance with code requirements. Implementation of activities listed in Table S-3 of the attached TR, including procedure changes, process updates, and training of affected personnel, will be completed within the later of six months after NRC approval, or six months after a refueling outage if in progress at the time of NRC approval, per the commitment below. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR 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 651-388-1 121 x4137. Summaw of Commitments This letter contains the following new commitments: 1. NSPM will implement procedure changes, process updates, and training of affected personnel as identified in Attachment S, Table S-3, of the TR within the later of six months after NRC approval, or six months after a refueling outage if in progress at the time of NRC approval. 2. NSPM will provide a supplement to the NFPA 805 LAR no later than November 15, 2012, to provide the final findings and observations with dispositions related to the Internal Flooding PRA peer review. Document Control Desk Page 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on SEp 2 8 2012 Joel P. Sorensen Acting Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC NRR Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC Minnesota Department of Commerce 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 September 2012 Northern States Power - Minnesota NFPA 805 Transition Report TABLE OF CONTENTS Executive Summary.....................................................................................................ivAcronym List................................................................................................................vi

1.0INTRODUCTION

.....................................................................................................11.1Background........................................................................................................11.1.1NFPA 805 - Requirements and Guidance.................................................11.1.2Transition to 10 CFR 50.48(c)....................................................................21.2Purpose.............................................................................................................32.0OVERVIEW OF EXISTING FIRE PROTECTION PROGRAM................................42.1Current Fire Protection Licensing Basis.............................................................42.2NRC Acceptance of the Fire Protection Licensing Basis...................................43.0TRANSITION PROCESS........................................................................................83.1Background........................................................................................................83.2NFPA 805 Process............................................................................................83.3NEI 04-02 - NFPA 805 Transition Process........................................................93.4NFPA 805 Frequently Asked Questions (FAQs)..............................................104.0COMPLIANCE WITH NFPA 805 REQUIREMENTS............................................124.1Fundamental Fire Protection Program and Design Elements..........................124.1.1Overview of Evaluation Process..............................................................124.1.2Results of the Evaluation Process...........................................................144.1.3Definition of Power Block and Plant.........................................................144.2Nuclear Safety Performance Criteria...............................................................154.2.1Nuclear Safety Capability Assessment Methodology...............................154.2.2Existing Engineering Equivalency Evaluation Transition.........................234.2.3Licensing Action Transition......................................................................244.2.4Fire Area Transition.................................................................................274.3Non-Power Operational Modes........................................................................304.3.1Overview of Evaluation Process..............................................................304.3.2Results of the Evaluation Process...........................................................334.4Radioactive Release Performance Criteria......................................................344.4.1Overview of Evaluation Process..............................................................344.4.2Results of the Evaluation Process...........................................................344.5Fire PRA and Performance-Based Approaches..............................................354.5.1Fire PRA Development and Assessment.................................................35PINGP Page i Northern States Power - Minnesota NFPA 805 Transition Report 4.5.2Performance-Based Approaches.............................................................384.6Monitoring Program.........................................................................................424.6.1Overview of NFPA 805 Requirements for the NFPA 805 Monitoring Program...................................................................................................424.6.2Overview of Post-Transition NFPA 805 Monitoring Program...................434.7Program Documentation, Configuration Control, and Quality Assurance........484.7.1Compliance with Documentation Requirements in Section 2.7.1 of NFPA 805...........................................................................................................484.7.2Compliance with Configuration Control Requirements in Section 2.7.2 and 2.2.9 of NFPA 805...................................................................................504.7.3Compliance with Quality Requirements in Section 2.7.3 of NFPA 805....544.8Summary of Results.........................................................................................554.8.1Results of the Fire Area Review..............................................................554.8.2Plant Modifications and Items to be Completed During the Implementation Phase.......................................................................................................564.8.3Supplemental Information -Other Licensee Specific Issues....................57

5.0REGULATORY EVALUATION

.............................................................................585.1Introduction - 10 CFR 50.48............................................................................585.2Regulatory Topics............................................................................................645.2.1License Condition Changes.....................................................................645.2.2Technical Specifications..........................................................................645.2.3Orders and Exemptions...........................................................................645.3Regulatory Evaluations....................................................................................645.3.1No Significant Hazards Consideration.....................................................645.3.2Environmental Consideration...................................................................645.4Revision to USAR............................................................................................655.5Transition Implementation Schedule................................................................656.0REFERENCES......................................................................................................66ATTACHMENTS...........................................................................................................71A.NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements...............................................................................................A-1B.NEI 04-02 Table B Nuclear Safety Capability Assessment - Methodology Review................................................................................................................B-1 C.NEI 04-02 Table B Fire Area Transition.....................................................C-1D.NEI 04-02 Non-Power Operational Modes Transition.....................................D-1E.NEI 04-02 Radioactive Release Transition.......................................................E-1PINGP Page ii Northern States Power - Minnesota NFPA 805 Transition Report PINGP Page iii F.Fire-Induced Multiple Spurious Operations Resolution.................................F-1G.Recovery Actions Transition............................................................................G-1H.NFPA 805 Frequently Asked Question Summary Table................................H-1I.Definition of Power Block...................................................................................I-1J.Fire Modeling V&V.............................................................................................J-1K.Existing Licensing Action Transition..............................................................K-1L.NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii))...L-1M.License Condition Changes.............................................................................M-1N.Technical Specification Changes....................................................................N-1O.Orders and Exemptions....................................................................................O-1P.RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4)........................................P-1Q.No Significant Hazards Evaluations................................................................Q-1R.Environmental Considerations Evaluation.....................................................R-1S.Plant Modifications and Items to be Completed During Implementation......S-1T.Clarification of Prior NRC Approvals................................................................T-1U.Internal Events PRA Quality.............................................................................U-1V.Fire PRA Quality.................................................................................................V-1W.Fire PRA Insights..............................................................................................W-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. Section 5 of the Transition Report provides regulatory evaluations and associated attachments, including:
• Changes to the Fire Protection License Condition. PINGP Page iv Northern States Power - Minnesota Executive Summary PINGP Page v
• 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.

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 vi 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 vii Northern States Power - Minnesota Acronym List EX Exterior (fire area) EXC Excluding ºF 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 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 Activated Detector 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 HX Heat Exchanger PINGP Page viii Northern States Power - Minnesota Acronym List 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 MOV Motor Operated Valve PINGP Page ix Northern States Power - Minnesota Acronym List 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 PAD Pre-action Deluge PAU Physical Analysis Unit PB Performance Based PBX Private Branch Exchange PC Primary Containment PCD PRA Change Database PCS Power Conversion System PDS Plant Damage State PH Pumphouse PINGP Page x Northern States Power - Minnesota Acronym List 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 RBCCW Reactor Building Closed Cooling Water RC Reactor Coolant RCA Radiologically Controlled Area RCP Reactor Coolant Pump RCS Reactor Coolant System RES Nuclear Regulatory Commission - Office of Nuclear Regulatory Research RG U.S. NRC Regulatory Guide RH Residual Heat Removal RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water RI-PB Risk-Informed, Performance-Based RIS Regulatory Information 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 xi 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 xii Northern States Power - Minnesota Acronym List PINGP Page xiii 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 Northern States Power - Minnesota 1.0 Introduction PINGP Page 1

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. 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 Association's 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 licensee's 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. 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 2 Northern States Power - Minnesota 1.0 Introduction PINGP Page 3 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.

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 4 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 5 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 10CFR50, 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 6 Northern States Power - Minnesota 2.0 Overview of Existing Fire Protection Program PINGP Page 7
• 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).

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 licensee's 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 8 Northern States Power - Minnesota 3.0 Transition Process PINGP Page 9 Figure 3-1 NFPA 805 Process [NEI 04-02 Figure 3-1 based on Figure 2-2 of NFPA 805]2 3.3 NEI 04-02 - 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.

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 10 Northern States Power - Minnesota 3.0 Transition Process PINGP Page 11 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. 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 19638 entitled "NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review." Engineering Evaluation EC 19638 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 12 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements PINGP Page 13 Figure 4 Fundamental Fire Protection Program and Design Elements Transition Process [Based on NEI 04-02 Figure 4-2] 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.

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 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 facility's pre-transition licensing basis. PINGP Page 14 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 19646, entitled "NFPA 805 LAR 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 15 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 PINGP's post-fire safe shutdown analysis (SSA) methodology against the guidance provided in NEI 00-01, Revision 1 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 Chapter 3 (NEI 04-02 Table B-2) was performed and documented in PINGP Engineering Evaluation EC 19775, "Nuclear Safety Capability Assessment (NSCA) Methodology Review." In addition, a review of NEI-00-01, Revision 2, Chapter 3, was conducted against the following substantive changes applicable to an NFPA 805 fire protection program in the guidance from NEI 00-01, Revision 1:
• Post fire manual operation of rising stem valves in the fire area of concern (NEI 00-01 Section 3.2.1.2)
• Analysis of open circuits on a high voltage (e.g., 4.16 kV) ammeter current transformers (NEI 00-01 Section 3.5.2.1) PINGP Page 16 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements
• Analysis of control power for switchgear with respect to breaker coordination (NEI 00-01 Section 3.5.2.4) This review was performed and documented in Attachment B, "NEI 04-02 Table B-2, Nuclear Safety Capability Assessment - Methodology Review." 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 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. PINGP Page 17 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements Figure 4 Summary of Nuclear Safety Methodology Review Process (FAQ 07-0039) 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 discovered that two rising stem valves, VC 1 and 2VC 1, are required to be manually operated (recovery action) after the valves have potentially been exposed to a fire in Fire Area 58. The post-fire operation of these valves will be addressed in a revision to the PINGP manual action feasibility study as described in Attachment S, Table S-3.* Analysis of open circuits on a high voltage (e.g., 4.16 kV) ammeter current transformers (NEI 00-01 Section 3.5.2.1) NSPM identified PINGP current transformer circuits (CTs) that are susceptible to secondary fires should the secondary of the transformer develop an open circuit as a result of the fire. Disposition of these identified current transformers has been included as a modification in Attachment S, Table S-2.* 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 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 PINGP Page 18 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements identified in Attachment S, Table S-2, to preclude coordination and protection concerns resulting from this fire-induced failure. 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 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 PINGP Page 19 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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 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) have an on-site fuel oil supply that will last for 14 days, assuming one EDG on each unit, or 7 days if both EDGs are operating for each unit. The diesel driven cooling water pumps (DDCLPs) have a separate fuel oil supply that will last for 14 days for one operating pump, or 7 days if two pumps are operating. Offsite sources of fuel oil are available to replenish fuel oil levels if needed via established contracts. 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 PINGP Page 20 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements not required for maintaining safe and stable conditions, the RHR system is included in the "at power" Nuclear Safety Capability Assessment (NSCA) PRISM 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 2.21 and NEI-04-02, Section 4.6). As a minimum, NEI 04-02 suggests that the assumptions, criteria, methodology, and overall results be included for the NRC to determine the acceptability of the licensee's 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 19844, "Operator Manual Actions." 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 licensee's 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 PINGP Page 21 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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 4-8 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.
• 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). PINGP Page 22 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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. 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, PINGP Page 23 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements
• 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. 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. PINGP Page 24 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements
• 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 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 PINGP Page 25 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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 a fixed 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). 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 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 PINGP Page 26 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements performance based approach that does not credit a 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 a 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 NSPM's 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. 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. PINGP Page 27 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements
• 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 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements Use Fire Risk Evaluationsto demonstrate complianceWith NFPA 805 § 4.2.4.2Use Fire Modelingto demonstrate complianceWith NFPA 805 § 4.2.4.1Document Final Disposition of VFDRCompliance options include:-Accept As Is-Require FP systems/features

-Require Recovery Action-Require Programmatic Enhancements-Require Plant Modifications(B-3 Table)NODeltaCDF/LERFAcceptable (on a FA basis) & DID and Safety Margin Maintained?NFPA 805 § 2.4.4Document fulfillment of Nuclear Safety Performance Criteria(B-3 Table)Identify INITIAL VariancesFromDeterministic Requirements of NFPA 805 § 4.2.3(B-3 Table)Guidance from RG 1.174 § 2 & RG 1.205 § 2.2.4YESAssemble DocumentationDocument Required Fire Protection Systems and Features(B-3 and LAR Table 4-3)Select another Compliance OptionSelectApproachNFPA 805 Chapter 4Bring into Compliance with Section 4.2.3 of NFPA 805NFPA 805 § 4.2.4.1Criteria Met?YESNO Figure 4 Summary of Fire Area Review [Based on FAQ 07-0054 Revision 1] PINGP Page 29 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 should be 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 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 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements NoYesKSFEquipmentAvailability Changed?KSFLost?DetermineFire Area Impact based onNPO Fire Area AssessmentsImplement Contingency Plan forSpecific KSFEquipmentOut of Service(OOS)NoFire Protection Defense-in-DepthActionsHigher Risk Evolution as Defined by Plant Specific Outage Risk Criteria for example1) Time to Boil2) Reactor Coolant System and Fuel Pool Inventory3) Decay Heat RemovalFire Protection Defense-in-DepthActionsHigher RiskEvolution?YesYesNoFire Protection Defense-in-DepthActionsFigure 4-6 Manage Pinch Points PINGP Page 32 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 19843, "NFPA 805 LAR Attachment D - Non-Power Operation." 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 19843, "NFPA 805 LAR Attachment D - Non-Power Operation," 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 19843, "NFPA 805 LAR Attachment D - Non-Power Operation," 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 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 Frequently Asked Question (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 unit's 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 19772, "NFPA 805 LAR Attachment E, Radioactive Release," 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, 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. PINGP Page 34 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements As described in Attachment S, fire fighting instructions and brigade lesson plans will be revised to provide additional instructions on the control 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. As described in Attachment S, 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, 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.

As described in Attachment S, a new fire strategy will be prepared to provide instructions for fighting fires in the Maintenance Storage Shed / Containment Access Facility, which is a newly-designated fire area with potentially-contaminated material in sea-land containers. 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 "Internal Fires at Power Probabilistic Risk Assessment Requirements," 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. PINGP Page 35 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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. 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 Owner's 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 recently 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. Due to the timing of this review, peer review findings have not yet been addressed by NSPM. A draft version of the peer review findings is included in Attachment U and NSPM will provide final findings and resolution in a supplement to this LAR. 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 PINGP Page 36 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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. 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])
• Hot Gas Layer (Method of Deal and Beyler)
• Ceiling Jet Temperature (Method of Alpert)
• Hot Gas Layer Calculations using Fire Dynamics Simulator (Version 5)
• Hot Gas Layer Calculations using CFAST (Version 6)
• Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios)
• Heat Detection Actuation Correlation
• Sprinkler Activation Correlation
• Control Room Abandonment Calculation using FDS
• Corner and Wall HRR
• Correlation for Heat Release Rates of Cables (Method of Lee)
• Fire Door Closure Calculation using FDS (Version 5) 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 PINGP Page 37 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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." 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. 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 initiating events that collectively represent 95% of the calculated fire risk is 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. 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. PINGP Page 38 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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, Appendix J Change Evaluation, Change Evaluation 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 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. PINGP Page 39 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements 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. 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 40 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements PINGP Page 41 Figure 4 Fire Risk Evaluation Process (NFPA 805 Transition) [Based on FAQ 07-0054 Revision 1] Identification of VFDRs(From B-3 Tables)Determine How to Modelthe VFDR in the Fire PRADiscuss and Document in Fire PRA and Fire Risk Evaluation DocumentationPrepare for Fire Risk EvaluationPerform Fire Risk EvaluationEvaluate the Maintenance ofDefense-In-DepthAndSafety MarginDiscuss and Document in Fire Risk Evaluation CalculationReview of Acceptance CriteriaEvaluateDelta CDFAndDelta LERF Calculate VFDRDelta CDFAndDelta LERF 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 42 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements PINGP Page 43 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.

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 44 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 H24, "Maintenance Rule Program," 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 radioactive releases due to effluents from fires will be less than releases due to core damage and containment breach, equipment relied upon to keep these releases as low as reasonably achievable 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 45 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 46 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements PINGP Page 47
• 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? Function currently in Maintenance Rule?Component currently in FPRA?Fire Protection Systems and FeaturesNSEL ComponentsRad Release Engineered Systems and FeaturesNoHigh Safety Significance of feature by compartment?NFPA 805 Specific Monitoring ProcessEstablish targets for reliability/unavailability in Phase 3Use Maintenance Rule for MonitoringYesYesNormal System & Program Health Monitoring Process or Outage Risk Management for NPOInclude in Maintenance Rule?High Risk Significance?YesNoYesNoFire Protection Programmatic ElementsYesNoNPO ComponentsFPRA ComponentsNSCANoPhase 1 -ScopingPhase 2 -Screening*Fully describe process used*Figure 4 NFPA 805 Monitoring - Scoping and Screening 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 NSPM's 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 48 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements Figure 4 NFPA 805 Planned Post-Transition Documents and Relationships PINGP Page 49 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), A.2.4.4, D.5 Change Evaluation NEI 04-02 5.3, Appendix B, Appendix I, Appendix J Change Evaluation, Change 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 50 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 51 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 52 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 53 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 10CFR50 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 10CFR50 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 54 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 55 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 19648, "Attachment S - Plant Modifications and Confirmatory Items." Table S-1 identifies that no plant modifications associated with the transition to NFPA 805 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. As of June 2012 when NSPM reviewed outstanding modifications for incorporation into the Fire PRA, no other significant plant changes are outstanding with respect to their inclusion in the Fire PRA model. Additional modifications discussed in Attachment S have no direct impact on the fire risk quantification results. PINGP Page 56 Northern States Power - Minnesota 4.0 Compliance with NFPA 805 Requirements PINGP Page 57 4.8.3 Supplemental Information -Other Licensee Specific Issues None.

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 licensee's decision to comply with NFPA 805." Therefore, to the extent that the PINGP Page 58 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 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: See below (i) Describe the overall fire protection program for the facility; NFPA 805 Section 3.2 NEI 04-02 Table B-1 (ii) Identify the various positions within the licensee's organization that are responsible for the program; NFPA 805 Section 3.2.2 NEI 04-02 Table B-1 (iii) State the authorities that are delegated to each of these positions to implement those responsibilities; and NFPA 805 Section 3.2.2 NEI 04-02 Table B-1 (iv) Outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. NFPA 805 Section 2.7 and Chapters 3 and 4 NEI 04-02 B-1 and B-3 Tables (2) The plan must also describe specific features necessary to implement the program described in paragraph (a)(1) of this section such as: See below (i) Administrative controls and personnel requirements for fire prevention and manual fire suppression activities; NFPA 805 Sections 3.3.1 and 3.4 NEI 04-02 Table B-1 (ii) Automatic and manually operated fire detection and suppression systems; and NFPA 805 Sections 3.5 through 3.10 and Chapter 4 NEI 04-02 B-1 and B-3 Tables (iii) The means to limit fire damage to structures, systems, or components important to safety so that the capability to shut down the plant safely is ensured. NFPA 805 Section 3.3 and Chapter 4 NEI 04-02 B-3 Table (3) The licensee shall retain the fire protection plan and each change to the plan as a record until the Commission terminates the reactor license. The licensee shall retain each superseded revision of the procedures for 3 years from the date it was superseded. NFPA 805 Section 2.7.1.1 requires that documentation (Analyses, as defined by NFPA 805 2.4, performed to demonstrate compliance with this standard) be maintained for the life of the plant. NSPM, "Records Management" procedure (FG-NP-RM-10) and "Records Retention Schedule" (RM-0044). PINGP Page 59 Northern States Power - Minnesota 5.0 Regulatory Evaluation PINGP Page 60 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 certification, or manufacturing license under part 52 of 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. Not applicable. PINGP is licensed under 10 CFR 50. 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, 10CFR50, 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 NRC's 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 safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. NFPA 805 Chapters 3 and 4 NEI 04-02 B-1 and B-3 Tables Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. NFPA 805 Sections 3.3.2, 3.3.3, 3.3.4, 3.11.4 NEI 04-02 B-1 Table Northern States Power - Minnesota 5.0 Regulatory Evaluation PINGP Page 61 Table 5-2 GDC 3 - Applicability/Compliance Reference GDC 3, Fire Protection, Statement Applicability/Compliance Reference Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. NFPA 805 Chapters 3 and 4 NEI 04-02 B-1 and B-3 Tables Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components NFPA 805 Sections 3.4 through 3.10 and 4.2.1 NEI 04-02 Table B-3 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 (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805), 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. General Information. NFPA 805 (2001 edition) is the edition used. (2) Exceptions, modifications, and supplementation of NFPA 805. As used in this section, references to NFPA 805 are to the 2001 Edition, with the following exceptions, modifications, and supplementation: General Information. NFPA 805 (2001 edition) is the edition used. (i) Life Safety Goal, Objectives, and Criteria. The Life Safety Goal, Objectives, and Criteria of Chapter 1 are not endorsed. The Life Safety Goal, 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 Plant Damage/Business Interruption Goal, Objectives, and Criteria of Chapter 1 are not endorsed. The Plant Damage/Business Interruption Goal, Objectives, 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 performance criteria of Sections 1.5.1(b) and (c), a high-pressure charging/injection pump coupled with the pressurizer power-operated relief 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. Feed and bleed is not utilized as the sole fire-protected safe shutdown methodology. (iv) Uncertainty analysis. An uncertainty analysis performed in accordance with Section 2.7.3.5 is not required to support deterministic approach calculations. Uncertainty analysis was not performed for deterministic methodology. (v) Existing cables. In lieu of installing cables meeting flame propagation tests as required by Section 3.3.5.3, a flame-retardant coating may be applied to the electric cables, or an automatic fixed fire suppression system may be installed to provide an equivalent level of protection. In addition, the italicized exception to Section 3.3.5.3 is not endorsed. Electrical cable construction complies with a flame propagation test that was found acceptable to the NRC as documented in NEI 04-02 Table B-1. (vi) Water supply and distribution. The italicized exception to Section 3.6.4 is not endorsed. Licensees who wish to use the exception to Section 3.6.4 must submit a request for a license amendment in accordance with paragraph (c)(2)(vii) of this section. PINGP complies by previous approval as documented in Attachment A, Table B-1. PINGP Page 62 Northern States Power - Minnesota 5.0 Regulatory Evaluation PINGP Page 63 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 3.1 against the use of performance-based methods, the fire protection program elements and minimum design requirements of Chapter 3 may be subject to the performance-based methods permitted elsewhere in the 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 § 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). The use of performance-based methods for NFPA 805 Chapter 3 is requested. See Attachment L. (3) Compliance with NFPA 805. See below (i) A licensee may maintain a fire protection program that complies with NFPA 805 as an alternative to complying with paragraph (b) of this section for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979. The licensee shall submit a request to comply with NFPA 805 in the form of an application for license amendment under § 50.90. The application must identify any orders and license conditions that must be revised or superseded, and contain any necessary revisions to the plant's technical 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. The LAR was submitted in accordance with 10 CFR 50.90. The LAR included applicable license conditions, orders, technical specifications/bases that needed to be revised and/or superseded. (ii) The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensee's decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805. The LAR and transition report summarize the evaluations and analyses performed in accordance with Chapter 2 of NFPA 805. (4) Risk-informed or performance-based alternatives to compliance with NFPA 805. A licensee may submit a request to use risk-informed or performance-based alternatives to compliance with NFPA 805. The request must be in the form of an application for license amendment under § 50.90 of this chapter. The Director of the Office of Nuclear Reactor Regulation, or designee of the Director, may approve the application if the Director or 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). No risk-informed or performance-based alternatives to compliance with NFPA 805 (per 10 CFR 50.48(c)(4)) were utilized. See Attachment P. 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, 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 Commission's 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 Northern States Power - Minnesota 5.0 Regulatory Evaluation PINGP Page 65 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.
• 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.

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 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 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 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 19638, "NFPA 805 Chapter 3 Fundamental Fire Protection Program and Design Elements Review." 6.49 PINGP Engineering Evaluation EC 19646, "NFPA 805 LAR Attachment I - Power Block Definition." 6.50 PINGP Engineering Evaluation EC 19648, "NFPA 805 LAR Attachment S - Plant Modifications and Confirmatory Items." 6.51 PINGP Engineering Evaluation EC 19772, "NFPA 805 LAR Attachment E, Radioactive Release." 6.52 PINGP Engineering Evaluation EC 19775, "Nuclear Safety Capability Assessment (NSCA) Methodology Review." 6.53 PINGP Engineering Evaluation EC 19843, "NFPA 805 LAR Attachment D - Non-Power Operation." 6.54 PINGP Engineering Evaluation EC 19844, "Operator Manual 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. 6.64 PINGP Fire PRA Uncertainty Notebook, FPRA-PI-UNC. 6.65 PINGP Fire PRA Quantification Notebook, FPRA-PI-FQ. PINGP Page 69 Northern States Power - Minnesota 6.0 References PINGP Page 70 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 Owner's 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). Northern States Power - Minnesota Attachments ATTACHMENTS PINGP Page 71 Northern States Power - Minnesota Attachment A - NEI 04-02 Table B Transition of Fundamental Fire Protection Program & Design Elements PINGP Page A-1 A. NEI 04-02 Table B Transition of Fundamental Fire Protection Program & Design Elements 186 Pages Attached Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementN/ACompliance Basis 10 CFR 50.48(c)(2)(vii) states, "Notwithstanding the prohibition in Section 3.1 against the use of performance-based methods, the fire protection program elements and minimum design requirements of Chapter 3 may be subject to the performance-based methods permitted elsewhere in the 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 § 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)."Plant DocumentationNoneIndustry-Related References10 CFR 50.48, "Fire Protection," Section (c)(2)(vii), "Performance-based methods"Existing Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceThis chapter contains the fundamental elements of the fire protection program and specifies the minimum design requirements for fire protection systems and features. These fire protection program elements and minimum design requirements shall not be subject to the performance-based methods permitted elsewhere in this standard. Previously approved alternatives from the fundamental protection program attributes of this chapter by the AHJ take precedence over the requirements contained herein.Subsection TitleGeneralNFPA 805 Section # 3.1EEEE DescriptionSummaryPage A-2PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-3PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.0, "Fire Protection Program," establishes a fire protection program for the plant. The procedure defines responsibilities of plant personnel, administrative controls, and implementing documents and procedures in place relative to the program. Per Section 1.0, "The Fire Protection Program at the Prairie Island Nuclear Generating Plant (PINGP) has been established to protect the health and safety of the public and site personnel, to minimize radioactive release to the environment, minimize property loss, and assure the capability to achieve and maintain safe shutdown conditions in the event of a fire. The Fire Protection Program is an integrated process involving design features, systems, trained personnel, equipment and procedures to provide a defense-in-depth approach to fire protection."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceA site-wide fire protection plan shall be established. This plan shall document management policy and program direction and shall define the responsibilities of those individuals responsible for the plan's implementation. This section establishes the criteria for an integrated combination of components, procedures, and personnel to implement all fire protection program activities.Subsection TitleIntentNFPA 805 Section # 3.2.1EEEE DescriptionSummaryPage A-4PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 3.0 of Procedure 5AWI 3.13.0, "Fire Protection Program," "This Instruction identifies...The licensing basis associated with the various elements of the PINGP Fire Protection Program...Organizational responsibilities required to maintain the Program in accordance with regulatory requirements and plant commitments-[and] Implementing documents associated with program elements."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceA policy document shall be prepared that defines management authority and responsibilities and establishes the general policy for the site fire protection program.Subsection TitleManagement Policy Direction and ResponsibilityNFPA 805 Section #3.2.2EEEE DescriptionSummaryPage A-5PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.1.1 of Procedure 5AWI 3.13.0, "Fire Protection Program," The Site Vice President is responsible for, "Overall implementation of the Fire Protection Program in accordance with licensing commitments."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe policy document shall designate the senior management position with immediate authority and responsibility for the fire protection program.Subsection TitleManagement Policy Direction and ResponsibilityNFPA 805 Section #3.2.2.1EEEE DescriptionSummaryPage A-6PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.4 of Procedure 5AWI 3.13.0, "Fire Protection Program," "The Fire Protection Program Engineer is the overall single point of contact for the site Fire Protection Program. The Fire Protection Program Engineer has primary responsibility for the program."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe policy document shall designate a position responsible for the daily administration and coordination of the fire protection program and its implementation.Subsection TitleManagement Policy Direction and ResponsibilityNFPA 805 Section #3.2.2.2EEEE DescriptionSummaryPage A-7PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 7.0 of Procedure 5AWI 3.13.0, "Fire Protection Program," outlines the fire protection organization, which includes 19 positions: Site Vice President, Engineering Director, Engineering Programs Supervisor, Fire Protection Program Engineer, Fire Protection Coordinator, Detection and Alarm Engineer, System Engineer, Design Engineer, Instrument and Control Systems Technician, Appendix R Engineer, Operations Manager, Shift Manager, Shift Supervisors, Work Supervisors, Construction Superintendents, Fire Brigade, Production Planning and Scheduling, Regulatory Compliance, and Training Manager. These positions are responsible for assuring adequate implementation of the various areas of the fire protection program.Section 7.4.5 states that the Fire Protection Program Engineer is responsible for "Interfacing with the respective industry organizations concerning Fire Protection Program issues and operating experience."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe policy document shall define the fire protection interfaces with other organizations and assign responsibilities for the coordination of activities. In addition, this policy document shall identify the various plant positions having the authority for implementing the various areas of the fire protection program.Subsection TitleManagement Policy Direction and ResponsibilityNFPA 805 Section #3.2.2.3EEEE DescriptionSummaryPage A-8PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 5.5 of Procedure 5AWI 3.13.0, "Fire Protection Program," "For interpretation and implementation of NFPA Codes and Standards, both the NRC and NEIL may be considered as the AHJ, dependant upon the situation to which the code is applied." 5.5.1 For application of all Codes of Record to Safety-related areas or other areas under the NRC jurisdiction (or covered under the Fire Protection Program and various commitments), the NRC is considered the primary AHJ. In accordance with the fire protection license condition, AHJ authority is delegated to the site when evaluation shows a change or condition has no adverse affect on safe shutdown ability.5.5.2 For areas where NRC and NEIL share jurisdiction, either or both may be considered the AHJ, dependant 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.Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe policy document shall identify the appropriate AHJ for the various areas of the fire protection program.Subsection TitleManagement Policy Direction and ResponsibilityNFPA 805 Section #3.2.2.4EEEE DescriptionSummaryPage A-9PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," establishes requirements for surveillance and testing of fire protection equipment. Section 1.0, Rev. 15 states, "This procedure provides a system overview, functional, requirements, compensatory actions, surveillance requirements, and reporting requirements of fire protection systems."Plant DocumentationProcedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15 dated 4/11/2012Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:(1) Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.Subsection TitleProceduresSubsection 3.2.3(1)NFPA 805 Section #3.2.3EEEE DescriptionSummaryPage A-10PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 6.1 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," establishes provisions for compensatory measures when fire protection systems and equipment are impaired. Specific compensatory actions are identified for each specific system discussed within the procedure.Plant DocumentationProcedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the 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 durationSubsection TitleProceduresSubsection 3.2.3(2)NFPA 805 Section #3.2.3EEEE DescriptionSummaryPage A-11PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisPer Section 16.0 of Procedure 5AWI 3.13.0, "Fire Protection Program," "Fire Protection Program health is monitored using objective criteria related to the program health criteria including, when practical, objective measures for the program attributes, leading indicators which are identified and emphasized wherever possible to promote a proactive approach to program improvement.Objective criteria indicating health degradation include: Systems performance; Failed PM component tracking; The performance indicator trends are often just as important as the indicator values in assessing program health, as they may represent potential future vulnerabilities; Industry-identified precursors to declining program performance are also potential sources for leading indicators...Detailed Health Report parameters are included in FP-PE-PHS-01, Program Health Process."Per Section 5.2.5.5.e of Fleet Procedure FP-PE-PHS-01, "Program Health Process," "For programs that receive regular major NRC inspections (App R and Fire Protection), Focused Self-Assessments are conducted per FP-PA-SA-01, Focused Self-Assessment Planning, Conduct and Reporting" at least every 36 months, unless approved by Programs Engineering Director."Per Section 1.0 of Fleet Procedure FP-PA-SA-01, "Focused Self-Assessment Planning, Conduct and Reporting," "This procedure provides the process 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."Plant DocumentationFleet Procedure FP-PA-SA-01, "Focused Self-Assessment Planning, Conduct and Reporting," Rev. 13, dated 9/29/11Fleet Procedure FP-PE-PHS-01, "Program Health Process," Rev. 13, dated 1/13/12Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationThe monitoring program required by NFPA 805 Section 2.6 will be implemented after the LAR approval as part of the FPP transition to NFPA 805, in accordance with NFPA 805 FAQ 10-0059, and will include a process that reviews the FPP performance and trends in performance. Refer to Attachment S.Identifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:(3) Reviews of fire protection program - related performance and trendsSubsection TitleProceduresSubsection 3.2.3(3)NFPA 805 Section #3.2.3EEEE DescriptionSummaryPage A-12PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.1, "Fire Protection Review of Plant Modifications," states, "This Instruction establishes the process for reviewing modifications (engineering changes, equivalency changes, design changes, temporary modifications, etc.) at PINGP. The review ensures that the fire protection requirements are included. It also ensures adequate evaluation and documentation of the type and quantity of combustible loading in each fire area."Section 1.0 of Fleet Procedure FP-G-DOC-04, "Procedure Processing," states, "The purpose of this procedure is to establish a common process for initiation, revision, review, and approval of the 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)."Section 1.1 of Fleet Procedure FP-E-MOD-02, "Engineering Change Control," states, "This procedure provides instruction for the initiation, classification and overall control of all modifications at facilities owned and operated by Northern States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy, hereinafter NSPM. This procedure also includes 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."Plant DocumentationFleet Procedure FP-E-MOD-02, "Engineering Change Control," Rev. 11, dated 8/4/11Fleet Procedure FP-E-MOD-04, "Design Inputs," Rev. 8, dated 5/4/11Fleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 15, dated 10/28/11Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:(4) Reviews of physical plant modifications and procedure changes for impact on the fire protection programSubsection TitleProceduresSubsection 3.2.3(4)NFPA 805 Section #3.2.3EEEE DescriptionSummaryPage A-13PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 16.0 of 5AWI-3.13.0, "Fire Protection Program" states, "It is important that the Fire Protection Program Engineer includes a strategy for updating the program in anticipation of changing requirements and industry standards, or significant business needs, such as plant license renewal. The strategy should be supported by a long-term PI plan that ensures resources, cost, and upgrades are planned far enough in advance to minimize the impact on routine operations and program implementation. The Fire Protection Program should be designed such that the results of health monitoring, benchmarking, self-assessment, license renewal, and management oversight are also reviewed for potential updates to the long-term plans."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:(5) Long-term maintenance and configuration of the fire protection programSubsection TitleProceduresNFPA 805 Section # 3.2.3EEEE DescriptionSummaryPage A-14PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure F5, "Fire Fighting," establishes a procedure for emergency response of the fire brigade. Section 1.0 states, "The purpose of this section is to provide specific instructions on the organization of fire brigades, individual responsibilities in regard to fires, and procedures for extinguishing fires."Procedure F5 Appendix A, "Fire Strategies" describes the preplanned actions for fighting fires in each fire area.Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix A, "Fire Strategies", Rev. 27, dated 11/14/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures shall be established for implementation of the fire protection program. In addition to procedures that could be required by other sections of the standard, the procedures to accomplish the following shall be established:(6) Emergency response procedures for the plant industrial fire brigadeSubsection TitleProceduresSubsection 3.2.3(6)NFPA 805 Section #3.2.3EEEE DescriptionSummaryPage A-15PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention," establishes specific requirements for the fire prevention program. Section 1.0 states, "This Instruction establishes fire prevention requirements that are consistent with regulatory commitments, acceptable industry measures, and PI's Fire Protection Program to reduce the potential for an off site release of radiological material. The basis for a comprehensive fire prevention program is minimization, containerization, elimination, substitution, and separation of combustible materials."Sections 7.0, 10, and 11 control the use of combustible materials.Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceA fire prevention program with the goal of preventing a fire from starting shall be established, documented, and implemented as part of the fire protection program. The two basic components of the fire 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 materialsThe design control requirements listed in the remainder of this section shall be provided as described.Subsection TitlePreventionNFPA 805 Section # 3.3EEEE DescriptionSummaryPage A-16PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-17PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.3, "Hot Work," establishes administrative, procedural, and conditional requirements for hot work and associated fire watches. Section 1.0 states, "This instruction describes requirements for performing hot work activities during power operations and outages."Section 11.0 of Instruction 5AWI 3.13.2, "Fire Prevention," establishes requirements for storage and use of combustible materials.Section 10.0 of Instruction 5AWI 3.13.0, "Fire Protection Program," establishes controls for limiting the spread of fire.Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Procedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Procedure 5AWI 3.13.3, "Hot Work," Rev. 2, dated 8/19/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe fire prevention program activities shall consist of the necessary elements to address the control of ignition sources and the use of transient combustible materials during all aspects of plant operations. The fire prevention program shall focus on the human and programmatic elements necessary to prevent fires from starting or, should a fire start, to keep the fire as small as possible.Subsection TitleFire Prevention for Operational ActivitiesNFPA 805 Section #3.3.1EEEE DescriptionSummaryPage A-18PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.0, "Fire Protection Program," includes but is not limited to training.Per Section 8.10 of Procedure 5AWI 3.13.0 "Individuals with unescorted access to the plant shall be instructed on how to identify adverse conditions and report them to supervisory personnel. These instructions shall include: Housekeeping and cleanliness criteria...Keeping access to fire extinguishers and hose stations unobstructed...[and] Work management process overview."Per Section 8.11, Level I (A) fire protection training shall be general training given to operations and mechanical maintenance personnel. The training shall include: Basic principles of fire chemistry and physics...Fire hazards...Fire detection systems...Types of extinguishing systems...Special fire hazards associated with nuclear power-[and] Emergency planning with emphasis on fire emergency. "Following initial training, Level 1 topics shall be reviewed annually with required personnel."Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Industry-Related ReferencesFAQ 06-0028, "Training Definition and Content," Rev. 2, dated 5/21/07Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe fire prevention activities shall include but not be limited to the following program elements:(1) Training on fire safety information for all employees and contractors including, as a minimum, familiarization with plant fire prevention procedures, fire reporting, and plant emergency alarmsSubsection TitleFire Prevention for Operational ActivitiesGeneral Fire Prevention Activities, Subsection 3.3.1.1(1)NFPA 805 Section #3.3.1.1EEEE DescriptionSummaryPage A-19PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Fleet Procedure FP-PA-ARP-01, "CAP Action Request Process," and Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," include but are not limited to processes for documenting plant inspections and corrective actions.Section 2.1 of Fleet Procedure FP-PA-ARP-01 states, "This procedure establishes the process for documenting and tracking the resolution of issues at each site. It provides the framework to ensure that deviations from performance expectations, including conditions adverse to quality, employee concerns, operability issues, functionality issues, and reportability issues are promptly identified, evaluated, and corrected as appropriate."Per Section 1.0 of Procedure 5AWI 8.5.0, "This Instruction establishes Housekeeping and Materiel Condition requirements for the control of work activities, conditions and environment that could affect quality. The objective of this program is to encompass all activities related to the control of cleanliness of facilities, cleanliness of material and equipment and protection of equipment."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:Plant DocumentationFleet Procedure FP-PA-ARP-01, "CAP Action Request Process," Rev. 32, dated 9/29/11Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev. 10, 2/25/095AWI 3.13.0 Fire Protection Program, Rev. 21, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe fire prevention activities shall include but not be limited to the following program elements:(2) Documented plant inspections including provisions for corrective actions for conditions where unanalyzed fire hazards are identifiedSubsection TitleFire Prevention for Operational ActivitiesGeneral Fire Prevention Activities, Subsection 3.3.1.1(2)NFPA 805 Section #3.3.1.1EEEE DescriptionSummaryPage A-20PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-17.11.10 Ensuring required daily fire hazard housekeeping inspections are conducted and documented."Page A-21PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.1, "Fire Protection Review of Plant Modifications" includes but is not limited to administrative controls addressing the review of plant modifications and maintenance.Per Section 1.0 of Procedure 5AWI 3.13.1, "This Instruction establishes the process for reviewing modifications (engineering changes, equivalency changes, design changes, temporary modifications, etc.) at PINGP. The review ensures that the fire protection requirements are included. It also ensures adequate evaluation and documentation of the type and quantity of combustible loading in each fire area."Plant DocumentationProcedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe fire prevention activities shall include but not be limited to the following program elements:(3) Administrative controls addressing the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimizedSubsection TitleFire Prevention for Operational ActivitiesGeneral Fire Prevention Activities, Subsection 3.3.1.1(3)NFPA 805 Section #3.3.1.1EEEE DescriptionSummaryPage A-22PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention" includes but is not limited to procedures on the control of wood within the plant. The procedure specifically requires that any wood in the plant shall be coated, treated or covered with a fire retardant material and listed on a Combustible Control Permit.Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesFAQ 06-0019, "Definition of ©Power Block© and ©Plant©," Rev. 4, dated 9/28/07Existing Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These 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.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(1)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-23PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-24PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention" includes but is not limited to procedures on the control of plastic sheeting. Per Section 6.1.8 of Procedure 5AWI 3.13.2, "Plastic sheeting procured for and used in the plant shall be fire retardant."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesNFPA 701, "Standard Methods of Fire Tests for Flame Propagation of Textiles and Films"Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program 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.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(2)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-25PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention" includes but is not limited to procedures on the control of waste, debris, scrap, packing materials, or other combustibles resulting from an activity.Per Section 6.1.4 of Procedure 5AWI 3.13.2,"All waste, debris, scrap, or other combustibles resulting from an activity shall be cleaned up, and stored in proper containers or removed from the area upon completing the activity or at the end of each work shift, whichever comes first."Per Section 6.6.3 of Procedure 5AWI 8.2.0, "Material Identification and Inventory Control," "Housekeeping shall be per 5AWI 8.5.0. Cleanliness and good housekeeping practices shall be enforced at all times in the storage areas. Storage areas shall be cleaned as required to avoid the accumulation of trash, discarded packaging materials and other detrimental soil."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Procedure 5AWI 8.2.0, "Material Identification and Inventory Control," Rev. 17, dated 6/17/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:(3) Waste, debris, scrap, packing materials, or other combustibles shall be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(3)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-26PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention" includes but is not limited to procedures on the control of combustible storage or staging areas.Section 11.0 of Procedure 5AWI 3.13.2 establishes requirements for the storage of combustibles in designated areas.Per Section 6.6.5 of Procedure 5AWI 8.2.0, "Material Identification and Material Control," "Fire protection for stored materials shall be per 5AWI 3.13.2."Per Section 6.8.1 of Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," "Combustible material (including gases and liquids, high efficiency particulate air and charcoal filters, dry ion exchange resins, or other combustible supplies) SHALL be stored in approved cabinets and containers or in posted areas. (See AWI 3.13.2, Fire Prevention, for a list of posted areas)."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Procedure 5AWI 8.2.0, "Material Identification and Inventory Control," Rev. 17, dated 6/17/10Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev.10, dated 2/25/09Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:(4) Combustible storage or staging areas shall be designated, and limits shall be established on the types and quantities of stored materials.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(4)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-27PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure 5AWI 3.13.2, "Fire Prevention" includes but is not limited to procedures on the control of flammable and combustible liquids.Section 8.0 of Procedure 5AWI 3.13.2 establishes requirements for the storage of flammable and combustible liquids.The storage of flammable and combustible liquids has been reviewed against the requirements of NFPA 30, as detailed in the NFPA 30-1969 and NFPA 30-1987 code review checklists.Plant DocumentationNRC SER dated 9/6/79Procedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1969 Edition, Revision: 1, Date: November 2010NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1987 Edition, Revision: 1, Date: December 2010Industry-Related ReferencesFAQ 06-0020, "Identification of ©Applicable NFPA Standards©," Rev. 1, dated 2/16/07NFPA 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 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the 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.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(5)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-28PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-29PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Fire Protection Engineering Evaluation FPEE-11-018 documents the code compliance review for 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. This review concluded that the use and storage of flammable gases is compliant with the applicable code requirements.Plant DocumentationFire 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 TanksIndustry-Related ReferencesFAQ 06-0020, "Identification of ©Applicable NFPA Standards©," Rev. 1, dated 2/16/07NFPA 55, "Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks," 2005 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProcedures for the control of general housekeeping practices and the control of transient combustibles shall be developed and implemented. These procedures shall include but not be limited to the following program elements:(6) Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.Subsection TitleFire Prevention for Operational ActivitiesControl of Combustible Materials, Subsection 3.3.1.2(6)NFPA 805 Section #3.3.1.2EEEE DescriptionSummaryPage A-30PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceControl of Ignition Sources.Subsection TitleFire Prevention for Operational ActivitiesControl of Ignition SourcesNFPA 805 Section #3.3.1.3EEEE DescriptionSummaryPage A-31PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisProcedure 5AWI 3.13.3, "Hot Work," establishes guidance and requirements for those performing hot work. Section 1.0 states, "This Instruction describes requirements for performing hot work activities during power operations and outages."Hot work safety procedures have been reviewed against the requirements of NFPA 51B and NFPA 241, as detailed in the NFPA 51B-1999 code review checklist and FPEE-11-020.Plant DocumentationProcedure 5AWI 3.13.3, "Hot Work," Rev 3, dated 1/27/12FPEE-11-020, "NFPA Codes Referenced in NFPA 805 not addressed by separate code reviews"Industry-Related ReferencesNFPA 51B, "Standard for Fire Prevention during Welding, Cutting, and other Hot Work," 1999 EditionExisting Engineering Equivalency Evaluations (EEEEs)FPEE-11-020, NFPA Codes Referenced in NFPA 805 not addressed by separate code reviewsIdentifier:Requirement/GuidanceA hot work safety procedure shall be developed, implemented, and periodically updated as necessary in accordance with NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, and NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.Subsection TitleControl of Ignition SourcesNFPA 805 Section #3.3.1.3.1EEEE DescriptionThe purpose of this analysis is to document the review of the NFPA codes referenced in NFPA 805 that are not addressed in separate NFPA code compliance reviewsSummaryThe following sections of NFPA 241 are not applicable to PINGP, with the bases identified: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 Page A-32PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1discussions 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.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.Page A-33PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationRevise or prepare plant procedures 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)Page A-34PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 6.1.1 of Procedure 5AWI 3.13.2, "Fire Prevention," "Smoking shall be permitted only in designated areas."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev 19, dated 01/05/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceSmoking and other possible sources of ignition shall be restricted to properly designated and supervised safe areas of the plant.Subsection TitleControl of Ignition SourcesNFPA 805 Section #3.3.1.3.2EEEE DescriptionSummaryPage A-35PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Item 73 of the table attached to 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," "Leak testing is done using only smoke sticks or generators."Per Section 7.5 of Procedure 5AWI 3.13.2, "Fire Prevention," "Open flames or combustion generated smoke shall not be used for leak or air flow testing."Plant DocumentationLetter from Mayer (NSP) to Stello (NRC) dated 12/8/76Procedure 5AWI 3.13.2, "Fire Prevention," Rev 19, dated 01/05/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceOpen flames or combustion-generated smoke shall not be permitted for leak or air flow testing.Subsection TitleControl of Ignition SourcesNFPA 805 Section #3.3.1.3.3EEEE DescriptionSummaryPage A-36PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.4 of Procedure 5AWI 3.13.2, "Fire Prevention," "The following requirements shall apply to portable space heaters:7.4.1 Fuel fired space heaters shall not be used within areas containing safety-related equipment or where there is a potential for radiological release resulting from a fire.7.4.2 Observe good housekeeping practices to ensure unnecessary combustibles are removed from the vicinity of space heaters.7.4.3 Direct space heaters away from combustibles, fire detection devices, sprinkler heads, or tanks.7.4.4 Shift Supervisor shall be notified of any space heaters that will remain in operation unattended. Unattended, operating space heaters in safety-related areas shall be logged as an impairment and added to hourly fire watch rounds unless evaluated by the Fire Protection Program Engineer."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePlant administrative procedure shall control the use of portable 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.Subsection TitleControl of Ignition SourcesNFPA 805 Section #3.3.1.3.4EEEE DescriptionSummaryPage A-37PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 2.6 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Materials of construction are rated ©Noncombustible© or ©Fire-Resistive© construction in accordance with National Fire Protection Association (NFPA) No. 220-1961. Coating systems applied to structures exhibit flame spread characteristics which are within the limits of the definition for ©Noncombustible© contained in NFPA No. 220."Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNFPA 220, "Standard on Types of Building Construction," 1961 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceWalls, floors, and components required to maintain structural integrity shall be of noncombustible construction, as defined in NFPA 220, Standard on Types of Building Construction.Subsection TitleStructuralNFPA 805 Section #

3.3.2EEEE DescriptionSummaryPage A-38PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.2 of Procedure D71.1, "General Wall Painting, Concrete Wall, Blockwalls and Floor Surfaces," "All coatings shall meet the requirements of ©Class A Interior Wall and Ceiling Finish© as defined in the National Fire Code, Section 101, 6-5.3.1, 1994 Edition."Per Section 2.6 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Coating systems applied to structures exhibit flame spread characteristics which are within the limits of the definition for ©Noncombustible© contained in NFPA No. 220. Coating systems in the Containment, Safety Injection, Containment Spray, and Residual Heat Removal pump rooms use carboline #2 primer and phenoline 305 which have a flame spread rating of 0-25."Per Section 4.1 of Maintenance Procedure D71 "Nuclear Coating Applications," "In containment, use only those coating systems qualified according to ANSI 101.2 and referenced in section 2.8."Per Section 2.8 of Procedure D71, "Nuclear Coating Application," Qualified Coatings for use on the interior of reactor buildings are Carbo Zinc 11 SG, Carboguard 890N (Formerly called Carboline 890 and Carboguard 890); Phenoline 368 WG; and Carboguard 2011S top coated with Carboguard 890N.Plant DocumentationProcedure D71, "Nuclear Coating Application," Rev. 21, dated 12/24/09Procedure D71.1, "General Wall Painting, Concrete Wall, Blockwalls and Floor Surfaces," Rev. 5, dated 12/24/09Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNFPA 101, "Life Safety Code," 1994 EditionNFPA 220, "Standard on Types of Building Construction," 1961 EditionANSI N101.2, "Protective Coatings (Paints) for Light Water Nuclear ReactorContainment Facilities," 1972 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceInterior wall or ceiling finish classification shall be in accordance with NFPA 101, Life Safety Code, requirements for Class A materials. Interior floor finishes shall be in accordance with NFPA 101 requirements for Class I interior floor finishes.Subsection TitleInterior FinishesNFPA 805 Section # 3.3.3EEEE DescriptionSummaryPage A-39PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 1.1 of Engineering Manual 3.2.1.7, "Specification for Thermal Insulation," "The scope of this specification shall be to provide the required design information as needed for the replacement, modification, and/or addition of thermal insulation on previously existing plant piping, valves, fittings, and equipment."Per Section 1.5, "Insulation materials including adhesives, shall be non-combustible and of a fire resistant application. This application shall be U.L. rated with a normal maximum U.L. rating as follows: Flame spread 25, smoke developed 50, fuel contribution 25."Per Section 4.0, Ductwork Construction of Pioneer Services & Engineering Co, Std Spec -Mech (SS - 613 (NSP) 9-70), "Standard Specification for Sheet Metal Ductwork Low Pressure and Medium Pressure", "All ductwork shall be constructed prime quality galvanized material except as called out in TS - M 614, Technical Specification for Ventilating Systems. Ductwork shall be inside smooth, air - tight substantially supported and stayed sufficiently to avoid reverberations or flutter."The basis for the limited combustible soundproofing material in Acess Control is provided in FPEE (AR# 01163081). "Based on the definition of "non-combustible /limited combustible" the fire test performance of the material used for sound proofing in the Access Control area is acceptable and 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.Plant DocumentationEngineering Manual 3.2.1.7, "Engineering Design Standard for Specification for Thermal Insulation," Rev. 1, dated 10/31/2009. Ductwork Construction of Pioneer Services &Engineering Co, Std Spec -Mech (SS - 613 (NSP) 9-70, "Standard Specification for Sheet Metal Ductwork Low Pressure and Medium Pressure", SS 613, Low and Medium Pressure Ductwork, SS 614 (HVAC for Turb, Aux, Screenhouse, Containment and Shield Building), and SS 619 for High Pressure Sheet Metal Ductwork. FPEE (AR# 01163081, Rev. 1) documents the adequacy of the soundproofing material installed in Access Control, the Control Room, and the Cable Spreading Room computer area.Nuclear Power Outfitters Lead Blanket SpecificationsIndustry-Related ReferencesCalifornia Department of Forestry and Fire Protection, Flame Retardant Fabrics and Chemicals ProgramNFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, 2010 EditionCPAI-84, Industrial Fabrics Association International (formerly the Canvas Products Association), Specification For Flame Resistant Materials Used in Camping Tentage, 1995 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.Subsection TitleInsulation MaterialsNFPA 805 Section # 3.3.4EEEE DescriptionSummaryPage A-40PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceElectrical.Subsection Title ElectricalNFPA 805 Section # 3.3.5EEEE DescriptionSummaryPage A-41PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis 12/8/1976 Letter, L.O. Mayer (NSP) to V. Stello (NRC) Comparison of Existing Fire Protection Provisions to the Guidelines Contained in Standard Review Plan 9.5.1APCSB 9.5-1 IV.B.1 (f ) states " Room or areas containing safeguard equipment do not have suspended ceilings. The control room has a suspended ceiling of "aluminum crate" design".Updated Safety Analysis Report (USAR) Section 7, Rev. 31, states "...The control room suspended ceiling consists of aluminum louver grids with fluorescent light fixtures mounted above the grids..".Based on this information, there is no wiring located above solid suspended ceilings.Plant DocumentationUpdated Safety Analysis Report (USAR) Section 7, Rev. 3112/8/1976 Letter, L.O. Mayer (NSP) to V. Stello (NRC) Comparison of Existing Fire Protection Provisions to the Guidelines Contained in Standard Review Plan 9.5.1Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceWiring 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.Subsection TitleElectricalNFPA 805 Section # 3.3.5.1EEEE DescriptionSummaryPage A-42PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Sheet 1 of the Unit 1 & 2 Project Design Manual, dated 4/1967, Section 4, Index 324.53, "Electrical Cable Tray Systems," "The cable tray system shall be fabricated from aluminum alloys throughout, except in the containment vessel. The use of aluminum is prohibited in the containment vessel, and only galvanized steel materials for this cable tray system is allowed."Per Section 9.2.2 of Procedure SWI CON-3, "Raceway Installation," cable trays are pan or ladder style, and conduits are steel or aluminum.Per Section 4.1.1 of Engineering Manual 4.3.1-C.4, "Engineering Design, Fabrication and Installation Summary for Conduit," "Conduit shall be RMC [Rigid Metal Conduit] steel. EMT [Electrical Metallic Tubing] may be used only for lighting or telephones. Aluminum conduit may be specified by the Engineer for special applications."Per Section 4.1.2, "Steel RMC shall be rigid conduit conforming to ANSI Standard C80.1-1966 (Rev. 1971) rigid steel, zinc-coated."Per Section 4.1.3, "Aluminum conduit is prohibited for use inside containment."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 Plant DocumentationEngineering Manual 4.3.1-C.4, "Engineering Design, Fabrication and Installation Summary for Conduit," Rev. 0, dated 6/16/04Procedure SWI CON-3, "Raceway Installation," Rev. 2, dated 5/22/05PINGP Unit 1 & 2 Project Design Manual, dated 4/1967Updated Safety Analysis Report (USAR) Section 7, Rev. 31Industry-Related ReferencesFAQ 06-0021, "Cable Air Drops," Rev. 1a, dated 11/13/07Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceOnly metal tray and metal conduits shall be used for electrical raceways. Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.Subsection TitleElectricalNFPA 805 Section # 3.3.5.2EEEE DescriptionSummaryPage A-43PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1connector) 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."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."Page A-44PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 5.2.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "The majority of cable used in the plant was purchased from Kerite Company. The cable is ethylene propylene rubber insulated with a chlorosulfated polyethylene jacket and is commonly known as EPR-Hypalon. Laboratory tests showed this cable to be highly resistive to auto-ignition and flame propagation. This cable has subsequently been qualified in accordance with IEEE 383-1974 flame test. A small amount of cable purchased from Boston Insulated Wire and Cable company was tested in accordance with the Philadelphia flame test which is a predecessor to the oil soaked rag test of IEEE 383-1974. The cables used in the D5/D6 addition was qualified to IEEE 383-1974 as above."Plant DocumentationProcedure F5 Appendix F, "Fire Hazards Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesIEEE 383-1974, Standard for Type Test of Class 1E Electric Cables, Field Splices, and Connection for Nuclear Power Generating StationsExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceElectric cable construction shall comply with a flame propagation test as acceptable to the AHJ.Subsection TitleElectricalNFPA 805 Section # 3.3.5.3EEEE DescriptionSummaryPage A-45PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with ClarificationCompliance BasisNFPA 256 was withdrawn at the Annual 2008 Meeting with no bases for where equivalent criteria are addressed. The following documents demonstrate compliance that the roofing system will not sustain a self-propagating fire on the underside of the deck when the deck is heated by a fire inside the building.Per Section 4, Account No. 321.244 of the PINGP Project Design Manual, dated April 1967, original specifications for roofing materials identified as "Insulated flat steel deck with built up roofing meeting NBFU requirements for ©Roof Deck Construction No. 1©."Per Letter from Severson (Howard R. Green Company) to Samson (NSP) dated 5/13/99, "According to the Uniform Building Code (UBC), the existing gravel surfaced built-up roof membrane is considered a Class A roofing system. The new proposed system will also be Class A-According to the ©UL Fire Resistance Directory©, the new built-up roof system meets assembly P#508. This indicates that the new system combined with the existing structure has a proper fire rating."Per Section 6 of Design Change 98BM01, "Rad Waste & Service Building Roofs," "According to the UL Fire Resistance Directory, the new built up roof system meets Assembly No. P508 and No. J928. This indicates that the new system, combined with the existing structure, has a proper fire rating."Per Page 5 of 6 of the Project Description for Modification 97BM01, "Turbine Roof Replacement," "According to the UL Fire Resistance Directory, the new built up roof system Plant DocumentationPINGP Project Design Manual, dated April 1967, Account No. 321.244Design Change 98BM01, "Rad Waste & Service Building Roofs," Rev. 0Drawing NF-38385, "Reactor Building Unit 1 Concrete Wall Detail and Dome Plan, Sections & Details," Rev. MDrawing NF-38513, "Architectural Plant Roof Plan," Rev. T, dated 1/21/05Drawing NF-116987, "D5/D6 Bldg. - Concrete Roof Plan at El. 755©-0"," Rev. ALetter from Severson (Howard R. Green Company) to Samson (NSP) dated 5/13/99Modification 96BM01, "Ancillary Roof Replacement," Rev. 0, Project DescriptionModification 97BM01, "Turbine Roof Replacement," Rev. 0, Project DescriptionModification 97BM02, "1998 Reroofing," Rev. 0, Project DescriptionIndustry-Related ReferencesNFPA 256, "Standard Methods of Fire Tests of Roof Coverings," 1998 EditionUnderwriters© Laboratories Fire Resistance DirectoryExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceMetal roof deck construction shall be designed and installed so the roofing system will not sustain a self-propagating fire on the underside of the deck when the deck is heated by a fire inside the building. Roof coverings shall be Class A as determined by tests described in NFPA 256, Standard Methods of Fire Tests of Roof Coverings.Subsection TitleRoofsNFPA 805 Section # 3.3.6EEEE DescriptionSummaryPage A-46PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1meets 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 original design specification-According 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 roof-The 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 system-According 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 Items for ImplementationNonePage A-47PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Plan," "All roofs as shown & noted shall carry a 20 year bond & shall be UL rated Class A Type III construction, unless otherwise noted."Page A-48PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPage 4 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, states, "By letter dated December 26, 1979, the licensee provided additional information regarding the storage of combustible gas (propane) cylinders in the Auxiliary Building. The licensee has proposed to move the cylinder located outside the Cold Lab to a rack located outside the Turbine Room. Piping, valves, and fittings from the cylinder to the present penetration into the Cold Lab will be welded steel pipe and will be installed in accordance with NFPA 58. The licensee has also reviewed the feasibility of extending the piping to the Hot Lab to replace the cylinder used there. The licensee concluded that this was not an appropriate solution since it would involve routing gas piping through three fire zones containing safe shutdown cabling and equipment. The licensee then proposed to leave the propane gas cylinder in the Hot Lab, which is a separate fire area protected by a wet pipe sprinkler system. No safe shutdown equipment or cables are located in this area."The licensee has shown to our satisfaction that the combustible gas cylinders will be stored in locations separated from safety related areas by three hour fire rated barriers. The piping and cylinder installation will be in accordance with NFPA No. 58. Based on our review, we find the licensee©s method of storing combustible gas cylinders acceptable."The modifications proposed in the 4/21/80 NSP to NRC letter were implemented by Design Change 79Y084, Part 2.Per Section 6.2 of Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," the plant fire protection engineer is responsible to ensure that plant modifications, including storage of flammable gases, are in compliance with the plant©s fire protection program.Plant DocumentationLetter from Schwencer (NRC) to Mayer (NSPC) dated 4/21/80Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05Industry-Related ReferencesNFPA 58, Liquefied Petroleum Gas CodeExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceBulk compressed or cryogenic flammable gas storage shall not be permitted inside structures housing systems, equipment, or components important to nuclear safety.Subsection TitleBulk Flammable Gas StorageNFPA 805 Section #3.3.7EEEE DescriptionSummaryPage A-49PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with ClarificationCompliance BasisSection 3.1.6 of Attachment to Letter from Schwencer (NRC) to Mayer (NSP), dated 4/21/80, states, "The licensee has shown to our satisfaction that the combustible gas cylinders will be stored in locations separated from safety related areas by three hour fire rated barriers. The piping and cylinder installation will be in accordance with NFPA No. 58. Based on our review, we find the licensee©s method of storing combustible gas cylinders acceptable."The requirement guidance cites NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites; however this standard has been withdrawn and not superseded. NFPA 55, 2005, Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks (Code of Record) has been used as the design basis for the bulk hydrogen storage system.Hydrogen storage has been reviewed against the requirements of NFPA 55, as detailed in the NFPA 55-2005 code compliance report, FPEE-11-018.Contract No. 00027187 between PINGP and Praxair Distribution includes an annual system inspection.Plant DocumentationLetter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80Drawing NF-38225, "Turbine Room - Concrete Hydrogen House," Rev. F, dated 12/26/74Drawing NF-38504, "Architectural Power Plant Sections," Rev. F, dated 12/10/81 Procedure C40.1, "H2/O2 Gas Systems," Rev. 9, dated 8/31/09Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11System Description B40, "Miscellaneous Gas Systems," Rev. 7, dated 5/27/09PINGP Unit 1 & 2 Project Design Manual, dated 4/1967FPEE-11-018, NFPA 55 - 2005, Standard for the Storage, Use, and Handling ff Com Pressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and TanksContract No. 00027187 between PINGP and Praxair Distribution, Inc.Industry-Related ReferencesNFPA 55 Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks-2005Existing Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceStorage of flammable gas shall be located outdoors, or in separate detached buildings, so that a fire or explosion will not adversely impact systems, equipment, or components important to nuclear safety. NFPA 50A, Standard for Gaseous Hydrogen Systems at Consumer Sites, shall be followed for hydrogen storage.Subsection TitleBulk Flammable Gas StorageNFPA 805 Section #3.3.7.1EEEE DescriptionSummaryPage A-50PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-51PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Engineering Change 12191 close out package (EC-0441), The three tube banks will be positioned side by side with the valving facing east. In the event a nozzle break occurs, the projectile generated would be propelled to the east, away from the power block. The individual tubes were not considered as missiles because they are fastened to their support structure and are considered too heavy to act as missiles. Additionally, there are no safety related SSCs in the travel path for the tube path. These tubes also would be unable to achieve the same level of penetration compared to smaller missiles considered in the USAR due to their large weight and size.Plant DocumentationEngineering Change 12191 close out package (EC-0441)Industry-Related ReferencesNFPA 55, Compressed Gases and Cryogenic Fluids CodeExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceOutdoor high-pressure flammable gas storage containers shall be located so that the long axis is not pointed at buildings.Subsection TitleBulk Flammable Gas StorageNFPA 805 Section #3.3.7.2EEEE DescriptionSummaryPage A-52PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Table 2 of Procedure 5AWI 8.5.0, "Housekeeping and Material Condition," it is expected that "All gas cylinders are secured appropriately."Per Section 6.8.1, "Combustible material (including gases and liquids-) shall be stored in approved cabinets and containers or in posted areas. (See 5AWI 3.13.2, Fire Prevention, for a list of posted areas)-"Per Section 10.0 of Procedure 5AWI 3.13.3, "Hot Work," "Cylinder use and storage shall be in accordance with applicable site safety policies."Per the Nuclear Plant Pocket Safety Guide, compressed gas cylinder valve protection caps shall be in place at all times except when regulators are attached (when cylinders are in use).Plant DocumentationProcedure 3.13.3, "Hot Work," Rev 3, dated 1/27/12Procedure 5AWI 8.5.0, "Housekeeping and Material Condition," Rev. 10, 2/25/09System Description B40, "Miscellaneous Gas Systems," Rev. 7, dated 5/27/09Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceFlammable gas storage cylinders not required for normal operation shall be isolated from the system.Subsection TitleBulk Flammable Gas StorageNFPA 805 Section #3.3.7.3EEEE DescriptionSummaryPage A-53PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 8.0 of Procedure 5AWI 3.13.2, "Fire Prevention," establishes requirements for the storage of flammable and combustible liquids.Bulk storage of flammable and combustible liquids has been reviewed against the requirements of NFPA 30, as detailed in the NFPA 30-1969 and NFPA 30-1987 code review checklists.Plant DocumentationNRC SER dated 9/6/79NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1969 Edition, Revision: 1, Date: November 2010NFPA 30 Code Conformance Review Checklist Flammable and Combustible Liquids Code, 1987 Edition, Revision: 1, Date: December 2010Industry-Related ReferencesNFPA 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)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceBulk storage of flammable and combustible liquids shall not be permitted inside structures containing systems, equipment, or components important to nuclear safety. As a minimum, storage and use shall comply with NFPA 30, Flammable and Combustible Liquids Code.Subsection TitleBulk Storage of Flammable and Combustible LiquidsNFPA 805 Section #3.3.8EEEE DescriptionSummaryPage A-54PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Table 1 of Procedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," all plant transformers are included in the plant©s inspection zone program. Per Table 2, this inspection program includes ensuring that drains are not clogged. Per Section 6.14.2, these inspections are performed monthly.Per Section 10.2 of Procedure D14.6, "Storm Water Pollution Prevention Plan": "The preventative maintenance program consists of various actions taken on a routine basis, i.e., checking transformers, changing oil absorbents, and pumping berms, inspections by the environmental group.10.2.1 The oil demister (roof of Auxiliary Building) has its' oil absorbents changed on a computer generated schedule. 10.2.2 The berms surrounding the above ground storage tanks are inspected weekly. A written log entry is completed which documents that, if the 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."Plant DocumentationProcedure 5AWI 8.5.0, "Housekeeping and Materiel Condition," Rev. 10, dated 2/25/10Procedure D14.6, "Storm Water Pollution Prevention Plan," Rev. 5, dated 3/22/06NF-39320-1, Transformer Oil Drain Piping Unit 1NF-39321-1, Transformer Oil Drain Piping Unit 2Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceWhere provided, transformer oil collection basins and drain paths shall be periodically inspected to ensure that they are free of debris and capable of performing their design function.Subsection TitleTransformersNFPA 805 Section # 3.3.9EEEE DescriptionSummaryPage A-55PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.6 of Procedure 5AWI 3.13.2, "Fire Prevention," "Combustible liquids shall be handled with care near hot pipes and surfaces." Per Section 8.7, "Liquids, including oils, shall immediately be cleaned when spilled onto insulation."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceCombustible liquids, including high flashpoint lubricating oils, shall be kept from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces. Administrative controls shall require the prompt cleanup of oil on insulation.Subsection TitleHot Pipes and SurfacesNFPA 805 Section #3.3.10EEEE DescriptionSummaryPage A-56PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 11.2 of Procedure 5AWI 3.13.2, "Fire Prevention," "Combustibles shall not be stored within three (3) feet of energized electrical cabinets."Plant DocumentationProcedure 5AWI 3.13.2, "Fire Prevention," Rev. 19, dated 1/5/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceAdequate clearance, free of combustible material, shall be maintained around energized electrical equipment.Subsection TitleElectrical EquipmentNFPA 805 Section #3.3.11EEEE DescriptionSummaryPage A-57PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.0 of Procedure F5 Appendix E, "The Reactor Coolant Pump Lube Oil Collection System is piped to sump "A" inside containment. The contents of the sump can be pumped to closed vented tank(s) inside the Auxiliary Building via two (2) alternative flow paths-The sump in the basement of containment is a concrete pit having a capacity of 990 gallons. This is more than the capacity needed to contain the total inventory of lube oil (410 gallons) for the two (2) reactor coolant pumps for each unit-The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the Control Room if this level is exceeded. The operator can initiate manual control of the sump pump(s) at any time by overriding the automatic control of sump level."Per Page 2 of Attachment 1 of Letter from Musolf (NSP) to Director (NRC) dated 4/5/84, "In support of the system as is currently installed it should be noted-the lube oil collection system is seismically designed." Per Page 2 of Attachment 1 of Letter from NSP to NRC dated 4/5/84, "In summary, Northern States Power has made an extensive effort to comply with the requirements of Appendix R. In comparing the lube oil collection system to the requirements of Section III.0 [of Appendix R], concerns were voiced over the use of a closed vented container inside containment because of the need for it to also act as a collection point for seal leakage. Northern States Power believes that the existing configuration meets the intent of Appendix R in that all lube oil is collected to a common point which will prevent its contact with hot piping in the area and is isolated from electrical power cable which might cause ignition."Per Page 5 of Letter from Miller (NRC) to Musolf (NSP) dated 7/31/84, "the pipe from the sump to Plant DocumentationLetter from Miller (NRC) to Musolf (NSP) dated 7/31/84Letter from Musolf (NSP) to Director (NRC) dated 4/5/84Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)Requirement/GuidanceFor facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall 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.(1) The oil collection system for each reactor coolant pump shall be capable of collecting lubricating oil from all potential pressurized and nonpressurized leakage sites in each reactor coolant pump oil system.Subsection TitleReactor Coolant PumpsNFPA 805 Section #3.3.12(1)Page A-58PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1the 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 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."NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-59PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.0 of Procedure F5 Appendix E, "The Reactor Coolant Pump Lube Oil Collection System is piped to sump "A" inside containment. The contents of the sump can be pumped to closed vented tank(s) inside the Auxiliary Building via two (2) alternative flow paths-The sump in the basement of containment is a concrete pit having a capacity of 990 gallons. This is more than the capacity needed to contain the total inventory of lube oil (410 gallons) for the two (2) reactor coolant pumps for each unit-The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the Control Room if this level is exceeded. The operator can initiate manual control of the sump pump(s) at any time by overriding the automatic control of sump level."Per Page 2 of Attachment 1 of Letter from Musolf (NSP) to Director (NRC) dated 4/5/84, "In support of the system as is currently installed it should be noted-the lube oil collection system is seismically designed." Per Page 2 of Attachment 1 of Letter from NSP to NRC dated 4/5/84, "In summary, Northern States Power has made an extensive effort to comply with the requirements of Appendix R. In comparing the lube oil collection system to the requirements of Section III.0 [of Appendix R], concerns were voiced over the use of a closed vented container inside containment because of the need for it to also act as a collection point for seal leakage. Northern States Power believes that the existing configuration meets the intent of Appendix R in that all lube oil is collected to a common point which will prevent its contact with hot piping in the area and is isolated from electrical power cable which might 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 Plant DocumentationLetter from Miller (NRC) to Musolf (NSP) dated 7/31/84Letter from Musolf (NSP) to Director (NRC) dated 4/5/84Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10Industry-Related ReferencesExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceFor facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall 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.(2) Leakage shall be collected and drained to a vented closed container that can hold the inventory of the reactor coolant pump lubricating oil system.Subsection TitleReactor Coolant PumpsNFPA 805 Section #3.3.12(2)EEEE DescriptionSummaryPage A-60PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1meets 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 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."Items for ImplementationNonePage A-61PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Procedure D18, Equipment Lubrication, the oil in the Reactor Coolant Pumps is Mobil SHC 824. This oil has a flash point of 248°C (478°F), therefore, a flame arrestor is not needed for this system.Plant DocumentationProcedure D18, "Equipment Lubrication", Rev. 84, dated 12/21/11Mobil Oil specification sheet, Mobil SHC 824 (http://www.mobil.com/USA-English/Lubes/PDS/GLXXENINDMOMobil_SHC_800.aspx)Industry-Related ReferencesExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceFor facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall 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.Subsection TitleReactor Coolant PumpsNFPA 805 Section #3.3.12(3)EEEE DescriptionSummaryPage A-62PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-63PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.0 of Procedure F5 Appendix E, "The Reactor Coolant Pump Lube Oil Collection System is piped to sump "A" inside containment. The contents of the sump can be pumped to closed vented tank(s) inside the Auxiliary Building via two (2) alternative flow paths-The sump in the basement of containment is a concrete pit having a capacity of 990 gallons. This is more than the capacity needed to contain the total inventory of lube oil (410 gallons) for the two (2) reactor coolant pumps for each unit-The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the Control Room if this level is exceeded. The operator can initiate manual control of the sump pump(s) at any time by overriding the automatic control of sump level."Per Page 2 of Attachment 1 of Letter from Musolf (NSP) to Director (NRC) dated 4/5/84, "In support of the system as is currently installed it should be noted-the lube oil collection system is seismically designed." Per Page 2 of Attachment 1 of Letter from NSP to NRC dated 4/5/84, "In summary, Northern States Power has made an extensive effort to comply with the requirements of Appendix R. In comparing the lube oil collection system to the requirements of Section III.0 [of Appendix R], concerns were voiced over the use of a closed vented container inside containment because of the need for it to also act as a collection point for seal leakage. Northern States Power believes that the existing configuration meets the intent of Appendix R in that all lube oil is collected to a common point which will prevent its contact with hot piping in the area and is isolated from electrical power cable which might 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, Plant DocumentationLetter from Miller (NRC) to Musolf (NSP) dated 7/31/84Letter from Musolf (NSP) to Director (NRC) dated 4/5/84Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10Industry-Related ReferencesRequirement/GuidanceFor facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall 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.(4) Leakage points on a reactor coolant pump motor to be protected shall include but not be limited to the lift pump and piping, overflow lines, oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and the oil reservoirs, where such features exist on the reactor coolant pumps.Subsection TitleReactor Coolant PumpsNFPA 805 Section #3.3.12(4)Page A-64PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1paragraph 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 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.Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-65PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.0 of Procedure F5 Appendix E, "The Reactor Coolant Pump Lube Oil Collection System is piped to sump "A" inside containment. The contents of the sump can be pumped to closed vented tank(s) inside the Auxiliary Building via two (2) alternative flow paths-The sump in the basement of containment is a concrete pit having a capacity of 990 gallons. This is more than the capacity needed to contain the total inventory of lube oil (410 gallons) for the two (2) reactor coolant pumps for each unit-The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the Control Room if this level is exceeded. The operator can initiate manual control of the sump pump(s) at any time by overriding the automatic control of sump level."Per Page 2 of Attachment 1 of Letter from Musolf (NSP) to Director (NRC) dated 4/5/84, "In support of the system as is currently installed it should be noted-the lube oil collection system is seismically designed." Per Page 2 of Attachment 1 of Letter from NSP to NRC dated 4/5/84, "In summary, Northern States Power has made an extensive effort to comply with the requirements of Appendix R. In comparing the lube oil collection system to the requirements of Section III.0 [of Appendix R], concerns were voiced over the use of a closed vented container inside containment because of the need for it to also act as a collection point for seal leakage. Northern States Power believes that the existing configuration meets the intent of Appendix R in that all lube oil is collected to a common point which will prevent its contact with hot piping in the area and is isolated from electrical power cable which might 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, Plant DocumentationLetter from Miller (NRC) to Musolf (NSP) dated 7/31/84Letter from Musolf (NSP) to Director (NRC) dated 4/5/84Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10Industry-Related ReferencesExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceFor facilities with non-inerted containments, reactor coolant pumps with an external lubrication system shall 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.(5) The collection basin drain line to the collection tank shall be large enough to accommodate the largest potential oil leak such that oil leakage does not overflow the basin.Subsection TitleReactor Coolant PumpsNFPA 805 Section #3.3.12(5)EEEE DescriptionSummaryPage A-66PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1paragraph 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 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."Items for ImplementationNonePage A-67PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationIdentifier:Requirement/GuidanceIndustrial Fire Brigade.Subsection Title Industrial Fire BrigadeNFPA 805 Section #3.4EEEE DescriptionSummaryPage A-68PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 7.16 of Procedure 5AWI 3.13.0, "Fire Protection Program," "A plant Fire Brigade shall be established to provide initial responses to fires identified in or threatening main plant structures. A Fire Brigade of five persons shall be on-site at all times in addition to the minimum shift crew complement needed to safely shut down the unit(s)."Per Technical Specification 6.1-1 (Amendment 39, Unit 1; Amendment 33, Unit 2), as identified in Section 6.1.C.6 of letter from Schwencer (NRC) to Mayer (NSP) dated 9/6/79, "A fire brigade of at least five members shall be maintained on site at all times. Fire brigade composition may be less than the minimum requirements for a period of time not to exceed 2 hours in order to accommodate unexpected absence of fire brigade members provided immediate action is taken to restore the fire brigade to within the minimum requirements." (This Technical Specification requirement has since been relocated to Procedure 5AWI 3.13.0 as part of the removal of fire protection requirements from the Technical Specifications.) The fire brigade has been reviewed against the requirements of NFPA 600, as detailed in Fire Protection Engineering Evaluation (FPEE) 11-031.(NFPA 1500 and NFPA 1582 do not apply as the plant operates a fire brigade, not a fire department.)Plant DocumentationLetter from Schwencer (NRC) to Mayer (NSP) dated 9/6/79Fleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 9, dated 10/8/09Fleet Procedure FP-G-RM-01, "Records Management," Rev. 10, dated 2/12/10Fleet Procedure QF-1720, "Fitness for Duty Handbook," Rev. 9, dated 2/12/10Procedure 5AWI 3.11.0, "Site Training and Staff Selection," Rev. 29, dated 5/20/11Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure 5AWI 10.2.0, "Emergency Preparedness," Rev. 18, dated 2/22/10Procedure 5AWI 10.2.1, "Emergency Response Organization," Rev. 1, dated 8/16/07Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Technical Training R7600W-0501, "Nuclear Fire Brigade Practical," Rev. 0, dated 12/19/07Requirement/Guidance(a) A fully staffed, trained, and equipped fire-fighting force shall be available at all times to control and extinguish all fires on site. This force shall have a minimum complement of five persons on duty and shall conform with the following NFPA standards as applicable:(1) NFPA 600, Standard on Industrial Fire Brigades (interior structural fire fighting)(2) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program(3) NFPA 1582, Standard on Medical Requirements for Fire Fighters and Information for Fire Department PhysiciansSubsection TitleOn-Site Fire-Fighting CapabilitySubsection 3.4.1(a)NFPA 805 Section #3.4.1Page A-69PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1FPEE-11-031, NFPA 600, Standard on Industrial Fire Brigades, 2000, Revision 1Industry-Related ReferencesFAQ 06-0007, "NFPA 805 Section 3.4.1, Specific Clarification," Rev. 2, dated 5/21/07NFPA 600, "Standard on Industrial Fire Brigades," 2000 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-70PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.16 of Procedure 5AWI 3.13.0, "Fire Protection Program," fire brigade members are not required to perform safe shutdown activities. The section states, "A Fire Brigade of five persons shall be on-site at all times in addition to the minimum shift crew complement needed to safely shut down the unit(s)."Per Section 5.5.1(c)(2) of Fleet Procedure CD 5.13, "Fire Protection Program Standard," "Industrial Fire Brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required."Plant DocumentationFleet Procedure CD 5.13, "Fire Protection Program Standard," Rev. 3, dated 2/4/09Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/Guidance(b) Industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.Subsection TitleOn-Site Fire-Fighting CapabilitySubsection 3.4.1(b)NFPA 805 Section #3.4.1EEEE DescriptionSummaryPage A-71PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 5.5.1(c)(3) of Fleet Procedure CD 5.13, "Fire Protection Program Standard," "During every shift, the Fire Brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on those systems."Per Section 7.16 of Procedure 5AWI 3.13.0, "Fire Protection Program," "The Fire Brigade leader shall be competent to assess the potential safety consequences of a fire and advise Control Room personnel. Such competence by the Fire Brigade leader may be evidenced by possession of an Operator's license or equivalent knowledge of plant safety related systems."Sections 4.8.3(A) and 4.8.3(B) of Procedure F5, "Fire Fighting," details the training requirements for all fire brigade members, which includes the identification and location of fire hazards throughout the plant, as well as the various methods for fighting fires.Plant DocumentationFleet Procedure CD 5.13, "Fire Protection Program Standard," Rev. 3, dated 2/4/09Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/Guidance(c) During every shift, the brigade leader and at least two brigade members shall have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria.Exception to (c): Sufficient training and knowledge shall be permitted to be provided by an operations advisor dedicated to industrial fire brigade support.Subsection TitleOn-Site Fire-Fighting CapabilitySubsection 3.4.1(c)NFPA 805 Section #3.4.1EEEE DescriptionSummaryPage A-72PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.6 of Procedure F5, "Fire Fighting," the fire brigade members are notified of a fire incident via a "Fire Alarm page" which is sent by the Control Room Operator. Per Section 1.2.6 of Procedure F5, the Fire Brigade Auto Paging system automatically pages all required fire brigade responders and support personnel for fire scene command and control. The auto paging system would be actuated immediately from the Unit 1 Lead, Unit 2 Lead, Unit 1 Shift Supervisor, and/or Unit 2 Shift Supervisor telephones upon verification of a fire in the plant.Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/Guidance(d) The industrial fire brigade shall be notified immediately upon verification of a fire.Subsection TitleOn-Site Fire-Fighting CapabilitySubsection 3.4.1(d)NFPA 805 Section #3.4.1EEEE DescriptionSummaryPage A-73PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.8.1 of Procedure F5, "Fire Fighting," "All new members of the Fire Brigades shall have an initial physical examination for strenuous physical activity as experienced in fire fighting...Follow-up physical examinations shall be conducted annually for all Fire Brigade members (i.e., every 9 to 15 months, provided that three consecutive exams do not exceed 39 months)...Initial and follow-up physical examinations shall include respiratory protection qualification testing which screens all respirator users (including Fire Brigade members for cardiopulmonary deficiencies)...Physical examinations shall be conducted by a physician."Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/Guidance(e) Each industrial fire brigade member shall pass an annual physical examination to determine that he or she can perform the strenuous activity required during manual firefighting operations. The physical examination shall determine the ability of each member to use respiratory protection equipment.Subsection TitleOn-Site Fire-Fighting CapabilitySubsection 3.4.1(e)NFPA 805 Section #3.4.1EEEE DescriptionSummaryPage A-74PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure F5 Appendix A, "Fire Strategies," details each area©s layout, hazards, fire protection features, communications capability, and equipment control in its pre-fire plan.Plant DocumentationProcedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceCurrent and detailed pre-fire plans shall be available to the industrial fire brigade for all areas in which a fire could jeopardize the ability to meet the performance criteria described in Section 1.5.Subsection TitlePre-Fire PlansNFPA 805 Section # 3.4.2EEEE DescriptionSummaryPage A-75PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Procedure F5 Appendix A, "Fire Strategies," details each area©s layout, hazards, fire protection features, communications capability, and equipment control in its pre-fire plan.Plant DocumentationProcedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe plans shall detail the fire area configuration and fire hazards to be encountered in the fire area, along with any nuclear safety components and fire protection systems and features that are present.Subsection TitlePre-Fire PlansNFPA 805 Section # 3.4.2.1EEEE DescriptionSummaryPage A-76PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 1.0 of Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," states, "This Instruction establishes the process for reviewing modifications (engineering changes, equivalency changes, design changes, temporary modifications, etc.) at PINGP. The review ensures that the fire protection requirements are included. It also ensures adequate evaluation and documentation of the type and quantity of combustible loading in each fire area."Section 1.1 of Fleet Procedure FP-G-DOC-04, "Procedure Processing," states "The purpose of this procedure is to establish a common process for initiation, revision, review, and approval of the 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.Plant DocumentationFleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 9, dated 10/8/09.Procedure 5AWI 3.13.1, "Fire Protection Review of Modifications," Rev. 10, dated 11/24/05Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePre-fire plans shall be reviewed and updated as necessary.Subsection TitlePre-Fire PlansNFPA 805 Section # 3.4.2.2EEEE DescriptionSummaryPage A-77PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 5.20 of Fleet Procedure FP-G-CD-01, "Controlled Documents," distribution of controlled documents is performed using the PASSPORT computer module. Procedure F5 Appendix A, "Fire Strategies," is distributed to the Control Room through this computer module.Plant DocumentationProcedure FP-G-CD-01, "Controlled Documents," Rev. 4, dated 2/27/09Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePre-fire plans shall be available in the control room and made available to the plant industrial fire brigade.Subsection TitlePre-Fire PlansNFPA 805 Section # 3.4.2.3EEEE DescriptionSummaryPage A-78PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Fire brigade coordination with other plant groups during fire emergencies is not addressed in individual pre-fire plans. However, Procedure F5, "Fire Fighting," the parent document to Procedure F5 Appendix A, "Fire Strategies," addresses coordination with non-fire brigade groups (e.g., security, operations) during fire events. Per Section 1.0, "The purpose of this section is to provide specific instructions on the organization of fire brigades, individual responsibilities in regard to fires, and procedures for extinguishing fires."Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePre-fire plans shall address coordination with other plant groups during fire emergencies.Subsection TitlePre-Fire PlansNFPA 805 Section # 3.4.2.4EEEE DescriptionSummaryPage A-79PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis The fire brigade has been reviewed against the requirements of NFPA 600, as detailed in Fire Protection Engineering Evaluation (FPEE) 11-031.(NFPA 1500 does not apply as the plant operates a fire brigade, not a fire department.)Plant DocumentationFleet Procedure FP-G-DOC-04, "Procedure Processing," Rev. 9, dated 10/8/09.Fleet Procedure FP-G-RM-01, "Records Management," Rev. 10, dated 2/12/10Fleet Procedure QF-1720, "Fitness for Duty Handbook," Rev. 9, dated 2/12/10Procedure 5AWI 3.11.0, "Site Training and Staff Selection," Rev. 29, dated 5/20/11Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure 5AWI 10.2.0, "Emergency Preparedness," Rev. 18, dated 2/22/10Procedure 5AWI 10.2.1, "Emergency Response Organization," Rev. 1, dated 8/16/07Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix A, "Fire Strategies," Rev. 27, dated 11/17/11Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Technical Training R7600W-0501, "Nuclear Fire Brigade Practical," Rev. 0, dated 12/19/07Requirement/GuidanceIndustrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the 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.Subsection TitleTraining and DrillsSubsection 3.4.3(a), "Plant Industrial Fire Brigade Training," Section (1)NFPA 805 Section #3.4.3Page A-80PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1FPEE-11-031, Revision 1Industry-Related ReferencesFAQ 06-0007, "NFPA 805 Section 3.4.1, Specific Clarification," Rev. 2, dated 5/21/07NFPA 600, "Standard on Industrial Fire Brigades," 2000 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-81PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.8.3 of Procedure F5, "Fire Fighting," the fire brigade training program includes instruction on general plant access, fire fighting tactics and hazards, use of fire fighting equipment, and radiation and contamination considerations.Per Section 1.2.1 of Procedure F5 Appendix J, "Fire Drills," "Fire drills shall be scheduled so that each Fire Brigade participates in at least four (4) fire drills per year. Drills should be performed at regular intervals with one (1) drill per calendar quarter for each Fire Brigade."Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.(a) Plant Industrial Fire Brigade Training. All of the following requirements shall apply.(2) Industrial fire brigade members shall be given quarterly training and practice in fire fighting, including radioactivity and health physics considerations, to ensure that each member is thoroughly familiar with the steps to be taken in the event of a fire.Subsection TitleTraining and DrillsSubsection 3.4.3(a), "Plant Industrial Fire Brigade Training," Section (2)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-82PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-83PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Section 4.8.3 of Procedure F5, "Fire Fighting," details the industrial fire brigade training program.Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the 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.Subsection TitleTraining and DrillsSubsection 3.4.3(a), "Plant Industrial Fire Brigade Training," Section (3)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-84PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.8 of Procedure 5AWI 3.13.0, "Fire Protection Program," "Classroom training sessions, practice sessions, and drills for the brigade shall be documented-"Per Section 17.5, individual fire brigade training records, drills, practices, and critiques are maintained in accordance with Fleet Procedure FP-G-RM-01, Records Management.Plant DocumentationFleet Procedure FP-G-RM-01, "Records Management," Rev. 9, dated 2/12/10Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency 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.Subsection TitleTraining and DrillsSubsection 3.4.3(a), "Plant Industrial Fire Brigade Training," Section (4)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-85PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-86PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.11 of Procedure 5AWI 3.13.0, "Fire Protection Program," "Level I (A) fire protection training shall be general training given to operations and mechanical maintenance personnel. The training shall include:...Basic principles of fire chemistry and physics...Fire hazards...Fire detection systems...Types of extinguishing systems...Special fire hazards associated with nuclear power-[and] Emergency planning with emphasis on fire emergency"Section 2.7 of Procedure F5, "Fire Fighting," provides a description of the responsibilities of non-operations personnel, such as radiation protection, security, and nuclear plant service personnel, when responding to fires with the fire brigade.Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 1/5/12Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who would respond to a fire in conjunction with the brigade shall be provided with training commensurate with their emergency responsibilities.(b) Training for Non-Industrial Fire Brigade Personnel. Plant personnel who respond with the industrial fire brigade shall be trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.Subsection TitleTraining and DrillsSubsection 3.4.3(b), "Training for Non-Industrial Fire Brigade Personnel"NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-87PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-88PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 1.2.1 of Procedure F5 Appendix J, "Fire Drills," "Fire drills shall be scheduled so that each Fire Brigade participates in at least four (4) fire drills per year...Drills should be performed at regular intervals with one (1) drill per calendar quarter for each Fire Brigade."Plant DocumentationProcedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who 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.(1) Drills shall be conducted quarterly for each shift to test the response capability of the industrial fire brigade.Subsection TitleTraining and DrillsSubsection 3.4.3(c), "Drills," Section (1)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-89PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.8 of Procedure 5AWI 3.13.0, "Fire Protection Program," fire drills are used to determine the fire brigade©s ability to "operate as a team."Per Section 1.2.3 of Procedure F5 Appendix J, "Fire Drills," "To the extent practical, Fire Brigade members shall use protective equipment, suppression systems, and other equipment used to fight an actual fire during the drills."Per Section 4.2.1, "The drill should be conducted with as much realism as possible. Fire Brigade members should respond as expeditiously as they would in the event of an actual fire."Per Section 4.2.2, "The scenario used for the drill shall be included in the fire drill report."Per Section 4.2.3, "PINGP 1676 shall be used as the drill objectives and as an objective evaluation checklist for all fire drills that are conducted."Per Section 4.2.5, "A critique shall be conducted as soon as possible after the fire drill is terminated. All items discussed during the critique shall be included in the fire drill report."PINGP 1676, "Fire Drill Critique Report" specifically includes an evaluation/critique of brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups.Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10PING 1676, "Fire Drill Critique Report"Requirement/GuidanceIndustrial fire brigade members and other plant personnel who 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.(2) Industrial fire brigade drills shall be developed to test and challenge industrial fire brigade response, including brigade performance as a team, proper use of equipment, effective use of pre-fire plans, and coordination with other groups. These drills shall evaluate the industrial fire brigade's abilities to react, respond, and demonstrate proper fire-fighting techniques to control and extinguish the fire and smoke conditions being simulated by the drill scenario.Subsection TitleTraining and DrillsSubsection 3.4.3(c), "Drills," Section (2)NFPA 805 Section #3.4.3Page A-90PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-91PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisProcedure F5 Appendix J, "Fire Drills" does not specifically require that fire drills be conducted in various plant areas, although drills have historically been conducted in a variety of plant areas.Plant DocumentationProcedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationProcedure F5 Appendix J, "Fire Drills," will be revised to require that fire brigade drills be conducted in various plant areas.Identifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who 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.Subsection TitleTraining and DrillsSubsection 3.4.3(c), "Drills," Section (3)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-92PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Details of the drill are recorded per PINGP 1676, "Fire Drill Critique Report".Per Section 5.1 of Procedure F5 Appendix J, "Fire Drills," "Documentation of drills and practices shall be maintained in accordance with FP-G-RM-01, Records Management, for two (2) years."Plant DocumentationProcedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10PINGP 1676, "Fire Drill Critique Report"Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who 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.(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.Subsection TitleTraining and DrillsSubsection 3.4.3(c), "Drills," Section (4)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-93PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.2.5 of Procedure F5 Appendix J, "Fire Drills," "A critique shall be conducted as soon as possible after the fire drill is terminated. All items discussed during the critique shall be included in the fire drill report."PINGP 1676, "Fire Drill Critique Report", includes the fire drill scenario and fire drill critique.Plant DocumentationPINGP 1676, "Fire Drill Critique Report"Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIndustrial fire brigade members and other plant personnel who 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.(5) A critique shall be held and documented after each drill.Subsection TitleTraining and DrillsSubsection 3.4.3(c), "Drills," Section (5)NFPA 805 Section #3.4.3EEEE DescriptionSummaryPage A-94PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Table 1 of Procedure F5, "Fire Fighting," establishes a list of personal protective clothing and equipment which are available for the fire brigade at several locations throughout the plant. The equipment includes SCBA, turnout gear, fire hose and nozzles, smoke ejectors, emergency lighting, communications equipment, spanner wrenches, and other such tools.Per Section 7.2.2, in the event of a radioactive fire incident, fire brigade members are required to "Obtain a dosimeter."Per Section 6.1 of Procedure RPIP 1101, "TLD Issue," a TLD is issued "to any worker entering the Radiologically Controlled Area (RCA)-"Per Section 7.5.9 of Procedure 5AWI 3.13.0, "Fire Protection Program," the fire protection coordinator is responsible for "procuring, inspecting, and maintaining fire brigade equipment in accordance with applicable NFPA requirements."FP-RP-DP-01, "Dosimetry Program", Section 3.5. lists the responsibilities of personnel issued a TLD. PINGP General Employee Training instructs employees to wear their TLDs at all times when on site.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.Plant DocumentationProcedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure RPIP 1101, "TLD Issue," Rev. 20, dated 2/6/09FP-RP-DP-0, Rev. 4, "Dosimetry Program"Industry-Related ReferencesNFPA 600, "Standard on Industrial Fire Brigades," 2000 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProtective clothing, respiratory protective equipment, radiation monitoring equipment, personal dosimeters, and fire suppression equipment such as hoses, nozzles, fire extinguishers, and other needed equipment shall be provided for the industrial fire brigade. This equipment shall conform with the applicable NFPA standards.Subsection TitleFire-Fighting EquipmentNFPA 805 Section #3.4.4EEEE DescriptionSummaryPage A-95PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceOff-Site Fire Department Interface.Subsection TitleOff-Site Fire Department InterfaceNFPA 805 Section #3.4.5EEEE DescriptionSummaryPage A-96PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 6.1 of Procedure F5, "Fire Fighting," "The primary off site fire department (Red Wing Fire Department) shall provide emergency assistance and shall be called immediately on report of fire."Per Section 6.2, "Upon arrival, the RWFD shall have primary responsibility for extinguishing the fire...The RWFD may call other mutual aid Departments in the local area for assistance, if necessary."Per Section 5.6.4.A of Procedure E-PLAN, "Emergency Plan," "The Red Wing Fire Department will provide assistance in the event of a fire occurring at the plant."Plant DocumentationProcedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceOff-site fire authorities shall be offered a plan for their interface during fires and related emergencies on site.Subsection TitleOff-Site Fire Department InterfaceMutual Aid AgreementNFPA 805 Section #3.4.5.1EEEE DescriptionSummaryPage A-97PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 6.4.1 of Procedure 5AWI 3.11.0, "Site Training and Staff Selection," "The Emergency Preparedness (EP) Manager maintains and implements an emergency preparedness training plan for...local fire departments...that provide primary support services to the site and its personnel."Per Section 1.2.1.C of Procedure F5 Appendix J, "Fire Drills," "A drill involving the local on-duty fire department shall be done at least once per year. Credit may be taken for the annual drill if the local fire department responds to a site fire emergency or participates in training at PINGP or with the fire brigade."Per Section 7.5.6 of Procedure 5AWI 3.13.0, "Fire Protection Program," The site Fire Protection Coordinator establishes "coordination with the local fire department, including joint drill and training sessions to familiarize fire department personnel with plant access routes, layout, equipment and special hazards.Plant DocumentationProcedure 5AWI 3.11.0, "Site Training and Staff Selection," Rev. 29, dated 5/20/11Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceFire fighters from the off-site fire authorities who are expected to respond to a fire at the plant shall be offered site-specific training and shall be invited to participate in a drill at least annually.Subsection TitleOff-Site Fire Department InterfaceSite-Specific TrainingNFPA 805 Section #3.4.5.2EEEE DescriptionSummaryPage A-98PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 2.7 of Procedure F5, "Fire Fighting," "Security is responsible to escort the off-site Fire Department personnel and vehicle on to plant property, through the security gate to the building door selected by brigade chief for entry."Per Section 6.2, "Upon arrival, the RWFD Shall have primary responsibility for extinguishing the fire...Anti-C clothing should be provided by radiation protection personnel, if required.Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePlant security and radiation protection plans shall address off-site fire authority response.Subsection TitleOff-Site Fire Department InterfaceSecurity and Radiation ProtectionNFPA 805 Section #3.4.5.3EEEE DescriptionSummaryPage A-99PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 10.3.8 of the USAR, "A fixed public address system interfaced with a UPS powered Private Branch Exchange (PBX) telephone system provide normal and emergency communications. In the event of a PBX failure, power fail telephone stations from the local telephone office and extensions operating on the Xcel Energy Sherco Plant Telephone Switch could be utilized to conduct emergency communications. In addition, a sound powered communications system is installed with communications jacks located throughout the plant. The sound powered system requires no external power, and headsets for use with the system are readily available....The site radio system utilizes hand-held portable radios, mobile radios, and stationary radio consoles to facilitate two way communications 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 site's emergency Plant DocumentationProcedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010Updated Safety Analysis Report (USAR) Section 10, Rev. 32PIndustry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceAn effective emergency communications capability shall be provided for the industrial fire brigade.Subsection TitleCommunicationsNFPA 805 Section # 3.4.6EEEE DescriptionSummaryPage A-100PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1organization carry personal pagers which can be activated from the Technical Support Center. A special emergency code is displayed on the pager."Page A-101PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceWater Supply.Subsection Title Water SupplyNFPA 805 Section # 3.5EEEE DescriptionSummaryPage A-102PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisPer Section 4.3.1.1 of NRC SER dated 9/6/79, "Water for fire protection is from the Mississippi River through the intake canal. The water is drawn by fire pumps located in the screen house. A secondary water supply is available through the cooling water system emergency intake pipe via crossovers to the fire mains."We find the water supply meets the objectives identified in Section 2.2 of this report and is, therefore, acceptable."Per Section 4.1 of Plant Procedure F5 Appendix F, "Fire Hazard Analysis," "Water for fire protection system is from the Mississippi River through the intake canal. The water is drawn by two horizontal shaft centrifugal fire pumps each with a design capacity of 2,000 gpm at a pressure 125 psi."Per Section 7.3 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The fire protection water system is supplied from the Mississippi River by two horizontal centrifugal fire pumps rated at 2,000 gpm at 125 psig."As stated in Section 3.5.3, of this attachment, the largest design demand of any sprinkler or fixed water spray system determined in accordance with NFPA 13 and NFPA 15 is a transformer system with a demand of 1534 gpm (including a hose allowance of 500 gpm). Therefore, water quantity required for 2 hour supply is 184,080 gallons. The Mississippi River is capable of supplying this water quantity.Plant DocumentationNRC SER dated 9/6/79Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix K, "Fire Protection Systems Funtional Requirements," Rev. 15, dated 4/11/2012Requirement/GuidanceA fire protection water supply of adequate reliability, quantity, and duration shall be provided by one of the two following methods.(a) Provide a fire protection water supply of not less than two separate 300,000-gal (1,135,500-L) supplies.(b) Calculate the fire flow rate for 2 hours. This fire flow rate shall be based on 500 gpm (1892.5 L/min) for manual hose streams plus the largest design demand of any sprinkler or fixed water spray system(s) in the power block as determined in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems, or NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection. The fire water supply shall be capable of delivering this design demand with the hydraulically least demanding portion of fire main loop out of service.Subsection TitleWater SupplyNFPA 805 Section # 3.5.1Page A-103PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationComplete 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.Identifier:EEEE DescriptionSummaryPage A-104PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Complies with Exception No. 1.Per Section 4.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Water for fire protection system is from the Mississippi River through the intake canal. -"The electric motor-driven fire pump and the diesel engine-driven fire pump are located at the east side of the screenhouse separated by a distance of approximately 20 feet. A three-hour rated fire barrier is provided around the electric motor-driven fire pump."Therefore, PINGP is in compliance with Exception No. 1 to this requirement.Per Section 7.3 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The fire protection water system is supplied from the Mississippi River-"Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Industry-Related ReferencesNoneRequirement/GuidanceThe tanks shall be interconnected such that fire pumps can take suction from either or both. A failure in one tank or its piping shall not allow both tanks to drain. The tanks shall be designed in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.Exception No. 1: Water storage tanks shall not be required when fire pumps are able to take suction from a large body of water (such as a 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.Subsection TitleWater SupplyNFPA 805 Section # 3.5.2Page A-105PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-106PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisPer Section 4.1.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Water for fire protection system is from the Mississippi River through the intake canal. The water is drawn by two horizontal shaft centrifugal fire pumps each with a design capacity of 2,000 gpm at a pressure 125 psi. 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. On loss of offsite AC power, the diesel driven pump will be available to supply water to the fire protection system."Per Section 7.3 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," The fire protection water system is supplied from the Mississippi River by two horizontal centrifugal fire pumps rated at 2,000 gpm at 125 psig. One pump is motor driven and the other pump is diesel driven. The 10" fire header is maintained between 110 and 113 psig by a jockey pump. The jockey pump does not supply water to the header. If the water demand is such that the jockey pump cannot maintain the header pressure, the screen wash pump will start (if not running). The screen wash pump, which is rated at 2000 gpm at 125 psig, provides water to the fire header when the bypass valve opens at 106 psig. However the screenwash pump has a bypass line which is orificed to restrict flow to 450 gpm to the fire header. The screen wash pump may be directly aligned to the fire header by a manual action from the Control Room in order to provide the rated 2,000 gpm at 125 psig. Due to the required manual action, this pump can not be credited as a primary fire pump. The motor driven fire pump will automatically start at 98 psig. If the header pressure to drops to 93 psig, the diesel-driven fire pump will start. The motor and diesel-driven fire pumps are designed to pump 2,000 gpm and Plant DocumentationCode Compliance Review NFPA 20-1969, "NFPA 20, Standard for the Installation of Centrifugal Fire Pumps, 1969, Code Compliance Review," Rev. 1 dated 6/1/2010Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11 Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70Industry-Related ReferencesNFPA 20, "Standard for the Installation of Centrifugal Fire Pumps," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)AR 1189183 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.Identifier:Requirement/GuidanceFire pumps, designed and installed in accordance with NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.Subsection TitleWater SupplyNFPA 805 Section # 3.5.3EEEE DescriptionFire pumps are tested every 18 months, while NFPA 20 requires that they be tested annually. Based on the design of the fire pumps and the firewater system, the 18 month test frequency currently used by PINGP is deemed adequate. Code Compliance ReviewSummary1. System Design: The redundancy provided by the three pumps will more than compensate for the potential failure of one pump to perform as intended. If debris caused one pump to be disabled, two other pumps are available. Since any single pump can satisfy the largest demand, sufficient firewater is expected Page A-107PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1maintain a minimum of 65 psig in the fire header, measured at the highest point in the system. The motor driven fire pump, diesel-driven fire pump, and the manually-aligned screenwash pump can be used to supply all fire fighting water requirements."In the event that the motor driven pump is impared, the control room may manually align the screen wash pump directly to the FP header via CV-31055 with unrestricted flow (2,000 GPM).If all three fire pumps are impaired, or if the fire suppression water system is incapable of supplying water to a safety related area, a backup fire suppression water system must be established within 24 hours."Per Section 3.7 of Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," "Both fire pumps are of bronze-fitted cast iron construction-and conform to NFPA Standard 20."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.to be available at all times.2. Additional Tests: In addition to the 18 month performance tests, the fire pumps are also tested weekly and/or monthly. Performance of these tests would provide indication of potential obstructions or degradations in the fire water supply.3. Pump Design: Experience has shown that fire pumps are durable,and are capable of passing various debris with minimal impact on performance. The design capacity of each pump is 2000 gpm at 125 psi, which is well in excess of the largest hydraulic system demand: the deluge system for Transformer #2 requires 1534 gpm @ 89.4 psi, including hose stream allowance. The diesel driven fire pump can supply approximately 3300 gpm at 89.4 psi; the electric motor driven fire pump can supply approximately 3600 gpm at 89.4 psi. Given that the fire water supply is screened, it is unlikely that any debris would completely disable a pump. While the extent of the reduced flow cannot be predicted, sufficient fire water flow required for any single system can be expected. In the unlikely event a pump is completely disabled, the redundant pumps are available.Page A-108PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNone4. The 18 months test interval reflects the testing frequency previously accepted by the NRC. This test frequency was established under NSP©s original Technical Specifications. Thus, at the time PINGP©s Fire Protection Program was established and approved, the NRC considered the current 18 month test interval acceptable. Eight deviations were dispositioned as acceptable.Page A-109PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "The water is drawn by two horizontal shaft centrifugal fire pumps each with a design capacity of 2,000 gpm at a pressure 125 psi. 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. On loss of offsite AC power, the diesel driven pump will be available to supply water to the fire protection system."Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceAt least one diesel engine-driven fire pump or two more seismic Category I Class IE electric motor-driven fire pumps connected to redundant Class IE emergency power buses capable of providing 100 percent of the required flow rate and pressure shall be provided.Subsection TitleWater SupplyNFPA 805 Section # 3.5.4EEEE DescriptionSummaryPage A-110PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "The electric motor-driven fire pump and the diesel engine-driven fire pump are located at the east side of the screenhouse separated by a distance of approximately 20 feet. A three-hour rated fire barrier is provided around the electric motor-driven fire pump. Electric cables for the electric motor-driven fire pump were re-routed to assure that a diesel fuel fire will not damage the controls or power source for the electric motor-driven fire pump. The screen wash pump, used as a backup fire pump, is located at the west side of the screenhouse, well separated from the regular fire pumps."Per Section 3.2.6 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, "We concur with the licensee©s conclusion that the control cable for the 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."Plant DocumentationLetter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceEach pump and its driver and controls shall be separated from the remaining fire pumps and from the rest of the plant by rated fire barriers.Subsection TitleWater SupplyNFPA 805 Section # 3.5.5EEEE DescriptionSummaryPage A-111PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.3.1.2 of NRC SER dated 9/6/79, "The fire pumps can be started manually at the control room or at the pumps. The fire pumps are also arranged to start automatically upon drop in system pressure by means of Underwriters Laboratory listed fire pump controllers."Per Section 7.3 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The motor driven fire pump will automatically start at 98 psig. If the header pressure to drops to 93 psig, the diesel-driven fire pump will start."Per Sections 5.2 and 5.4 of Procedure C31, "Fire Protection & Detection Systems," both the motor and diesel fire pumps are shut off manually at local pump panels.Fire Protection Engineering Evaluation, NFPA 20 - 1969, Standard for Centrifugal Fire Pumps, Code Compliance Deviations, Rev. 1Plant DocumentationNRC SER dated 9/6/79Procedure C31, "Fire Protection & Detection Systems," Rev. 38, dated 5/11/07Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Fire Protection Engineering Evaluation, NFPA 20 - 1969, Standard for Centrifugal Fire Pumps, Code Compliance Deviations, Rev. 1Industry-Related ReferencesNFPA 20 - 1969, Standard for Centrifugal Fire Pumps,Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceFire pumps shall be provided with automatic start and manual stop only.Subsection TitleWater SupplyNFPA 805 Section # 3.5.6EEEE DescriptionSummaryPage A-112PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Drawing NF-39228-1, fire pump connections to the yard main fire loop are provided with sectionalizing valves between connections. Valves FP-30-1 and FP-30-2 are provided for the motor driven fire pump; valves FP-30-4 and FP-30-5 are provided for the diesel driven fire pump; and valve FP-21-1 is provided for the jockey pump.Plant DocumentationDrawing NF-39228-1, "Flow Diagram Fire Protection and Screen Wash System - Unit 1 and 2, Rev. 77, dated 8-09Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIndividual fire pump connections to the yard fire main loop shall be provided and separated with sectionalizing valves between connections.Subsection TitleWater SupplyNFPA 805 Section # 3.5.7EEEE DescriptionSummaryPage A-113PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Pressurization of the fire water system is maintained by an electric motor-driven jockey pump.Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceA method of automatic pressure maintenance of the fire protection water system shall be provided independent of the fire pumps.Subsection TitleWater SupplyNFPA 805 Section # 3.5.8EEEE DescriptionSummaryPage A-114PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.1.3 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Water flows from the automatic wet pipe and preaction deluge suppression systems are annunciated on the fire panel in the Control Room. Flows from manual hose stations are not annunciated, but they will cause the fire pump to start, thereby transmitting a "fire pump running" signal to the Control Room."Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceMeans shall be provided to immediately notify the control room, or other suitable constantly attended location, of operation of fire pumps.Subsection TitleWater SupplyNFPA 805 Section # 3.5.9EEEE DescriptionSummaryPage A-115PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisPer Section 4.3.1.3 of NRC SER dated 9/6/79, "Separate 10-inch supply lines to the 10-inch underground yard main encircling the plant are provided from the fire pump header in the screen house. Valving is provided so a single break in the discharge piping will not remove both fire pumps from service. A backup supply of water to the yard fire main loop is provided by eight crossovers between the cooling water system and the fire water system."Per Drawing NF-39256-1, "Yard Fire Protection Piping," the plant is surrounded by a 10-inch underground fire main loop.Plant DocumentationNRC SER dated 9/6/79Code Compliance Review - NFPA 24, Standard for Outside Protection, 1969 ed., Rev 1, 12/2010Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)Items for ImplementationNoneIdentifier:Requirement/GuidanceAn underground yard fire main loop, designed and installed in accordance with NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be installed to furnish anticipated water requirements.Subsection TitleWater SupplyNFPA 805 Section # 3.5.10EEEE DescriptionCode Compliance Review - NFPA 24, Standard for Outside Protection, 1969 ed., Rev 1, 12/2010SummaryAll code deviations have been justified as acceptable. Reference individual reports for basis descriptions.Page A-116PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.3.1.3 of NRC SER dated 9/6/79, "Separate 10-inch supply lines to the 10-inch underground yard main encircling the plant are provided from the fire pump header in the screen house. Valving is provided so a single break in the discharge piping will not remove both fire pumps from service-Sectionalizing valves with post indicators subdivide the loop into a number of sections enabling a single section to be isolated without impairing the entire loop...The isolation valves in the interior fire header in the turbine building and auxiliary building are of the butterfly valve type with chain operators. Because of this arrangement, the necessity of isolating a portion of the underground yard loop to repair a hydrant or leaking main will not result in shutting off the supply of water to systems protecting safety-related equipment or areas...We find that...fire water piping systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable."Plant DocumentationNRC SER dated 9/6/79Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceMeans shall be provided to isolate portions of the yard fire main loop for maintenance or repair without simultaneously shutting off the supply to both fixed fire suppression systems and fire hose stations provided for manual backup. Sprinkler systems and manual hose station standpipes shall be connected to the plant fire protection water main so that a single active failure or a crack to the water supply piping to these systems can be isolated so as not to impair both the primary and backup fire suppression systems.Subsection TitleWater SupplyNFPA 805 Section # 3.5.11EEEE DescriptionSummaryPage A-117PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-118PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.3.1.3 of NRC SER dated 9/6/79, "Threads on hydrant outlets and hose couplings are compatible with those of fire departments which serve the plant."Per Section 1.2.1.C of Procedure F5 Appendix J, "Fire Drills," "A drill involving the local on-duty fire department shall be done at least once per year."The NFPA 14 code compliance reviews (Section 444 of NFPA 14-1969; Section 4-1.3 of NFPA 14-1986) confirmed that the threads are compatible by those by the Red Wing Fire Department. Per General Note 5 on NF-39300-1 and NF-39301-1, all hose threads to be National Standard hose threads at both ends.Plant DocumentationNRC SER dated 9/6/79Procedure F5 Appendix J, "Fire Drills," Rev. 14, dated 9/13/10NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1969 Code Compliance Review, Revision 1FPEE-11-050, Code Compliance Review, NFPA 14-1986, Standard for the Installation of Standpipe and Hose Systems, D5/D6 Building, Revision 1Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThreads compatible with those used by local fire departments shall be provided on all hydrants, hose couplings, and standpipe risers.Subsection TitleWater SupplyNFPA 805 Section # 3.5.12EEEE DescriptionSummaryPage A-119PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis The hose standpipe system is not seismically designed, but the system meets the requirements of NFPA 805. See Section 3.6.4 below. As a result, the requirements of ANSI B31.1 are not applicable.The hose stations and standpipes provided for PINGP are in accordance with the requirements of BTP 9.5-1, Appendix A for plants which received a construction permit before July 1, 1976 which do not require a seismic category I water system.Provisions to supply water to standpipes and hose stations for manual fire suppression in the event of a safe shutdown earthquake are outlined in EDMG-2, Guideline for Damage Mitigation Strategies (Attachment B - Fire System Management and Attachment L - Establishing Emergency Water Supply).Per Section 4.3.4 of Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," "The sprinkler system shut-off valves are 150 lb. position indicating, outside screw and yoke gate valves, flanged ends."Plant DocumentationLetter from Mayer (NSP) to Stello (NRC) dated 12/8/76NRC SER dated 9/6/79Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70PINGP Unit 1 & 2 Project Design Manual, dated 4/1967EDMG-2, Guideline for Damage Mitigation Strategies (Attachment B - Fire System Management and Attachment L - Establishing Emergency Water Supply).Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionRequirement/GuidanceHeaders fed from each end shall be permitted inside buildings to supply both sprinkler and standpipe systems, provided steel piping and fittings meeting the requirements of ANSI B31.1, Code for Power Piping, are used for the headers (up to and including the first valve) supplying the sprinkler systems where such headers are part of the seismically analyzed hose standpipe system. Where provided, such headers shall be considered an extension of the yard main system. Each sprinkler and standpipe system shall be equipped with an outside screw and yoke (OS&Y) gate valve or other approved shutoff valve.Subsection TitleWater SupplyNFPA 805 Section # 3.5.13Page A-120PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-121PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.5.11 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "Each valve (manual, power operated or automatic) in the flow path for safety-related areas and areas posing a fire hazard to safety-related areas shall be verified to be in the correct position and secured to prevent inadvertent misalignment every month."Per Section 1.1 of Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," "The purpose of this surveillance is to verify that fire protection valves supplying safety related areas, and areas posing a fire hazard to safety related areas, are in the correct position and secured."Per Section 1.5.1, the acceptance criteria for all water supply and fire suppression system control valves is "Valve verified open per 5AWI 3.10.1 Appendix E" and "Block Wire in place."Per Section 5.1, "Block Wire is required to prevent inadvertent mispositioning of valves."Appendix E of Procedure 5AWI 3.10.1, "Methods of Performing Verifications," provides instructions for inspecting valves to ensure they are adequately locked.Plant DocumentationProcedure 5AWI 3.10.1, "Methods of Performing Verifications," Rev. 16, dated 6/30/10Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," Rev. 32, dated 11/20/08Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionRequirement/GuidanceAll fire protection water supply and fire suppression system control valves shall be under a periodic inspection program and shall be supervised by one of the following methods.(a) Electrical supervision with audible and visual signals in the main control room or other suitable constantly attended location.(b) Locking valves in their normal position. Keys shall be made available only to authorized personnel.(c) Sealing valves in their normal positions. This option shall be utilized only where valves are located within fenced areas or under the direct control of the owner/operator.Subsection TitleWater SupplyNFPA 805 Section # 3.5.14Page A-122PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-123PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.3.1.3 of NRC SER dated 9/6/79, "Eight hydrants are provided in the yard spaced from 180 to 300 feet apart. The hydrants are supplied from the underground fire loop although the laterals feeding the hydrant are not provided with isolation valves-Each of the hydrants is provided with a well maintained corrugated metal hose house containing: 100 feet of 1 1/2-inch and 200 feet of 2 1/2-inch single jacket lined hose, one 2 1/2-inch and one 1 1/2-inch fog nozzle and various other items of fire fighting equipment. The inventory of equipment in the hose houses requires upgrading to include additional 1 1/2-inch hose, hose gaskets and a gated wye to allow connecting two 1 1/2-inch hose lines to a 2 1/2-inch hose line.""We find that, subject to implementation of the above listed modifications, fire water piping systems satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable."Per Section 7.14 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "Thirty two (32) hydrant units are located around the plant, warehouses, cooling towers, and in the switch yard. Each house contains 200 feet of 2 1/2" fire hose with a nozzle, 200 feet of 1 1/2" fire hose with a nozzle, adaptors for various size hose, spanner wrenches, a 2 1/2" hose control unit, gated wye, hydrant wrench, and hose gaskets."Per Drawing NF-39256-1, "Yard Fire Protection Piping," the fire hydrants are located along the 10 inch fire main and are approximately 180 feet to 300 feet apart.Drawing NF-38201, "Outdoor Hose House Fire Protection," details the materials required to furnish the hose houses, which include spanner Plant DocumentationNRC SER dated 9/6/79Code Compliance Review NFPA 24-1969, "Code Compliance Review - NFPA 24-1969, Standard for Outside Protection," dated 12/2010Drawing NF-38201, "Outdoor Hose House Fire Protection," Rev. E, dated 3/1/73Drawing NF-39256-1, "Yard Fire Protection Piping," Rev. AG, dated 2/7/92Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Requirement/GuidanceHydrants shall be installed approximately every 250 ft (76 m) apart on the yard main system. A hose house equipped with hose and combination nozzle and other auxiliary equipment specified in NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, shall be provided at intervals of not more than 1000 ft (305 m) along the yard main system.Exception: Mobile means of providing hose and associated equipment, such as hose carts or trucks, shall be permitted in lieu of hose houses. Where provided, such mobile equipment shall be equivalent to the equipment supplied by three hose houses.Subsection TitleWater SupplyNFPA 805 Section # 3.5.15Page A-124PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1wrenches, hoses, hose couplings, fog nozzles, etc.Hose house equipment has been reviewed against the requirements of NFPA 24, as detailed in the Code Compliance Review Code Compliance Review - NFPA 24-1969, Standard for Outside Protection," dated 12/2001.Industry-Related ReferencesNFPA 24, "Standard for Outside Protection," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-125PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementSubmit for NRC ApprovalCompliance BasisPer Section 1.2 of System Description B31A, "Fire Protection System," "The motor-driven fire pump can be aligned to provide a backup water supply to the Screenhouse screenwash system in the event of a screenwash pump failure."Per Section 3.1.C, "If the fire pump is required to supplement the screenwash header flow, the pump must be started manually either locally or remotely. Once the pump is operating and no auto start signal exists, the discharge to the screenwash header valve opens automatically and maintains the screenwash header pressure at approximately 90 psig."Per Drawing NF-39228-1, "Fire Protection and Screen Wash System - Unit 1 and 2," valve FP-30-10 ties the fire protection water system to the screenwash header.Since the fire water system can be aligned for screenwash system use and such use does not meet the requirement or allowed exceptions to the requirement, this configuration is included in Attachment L and NRC approval is being requested.Plant DocumentationDrawing NF-39228-1, "Fire Protection and Screen Wash System - Unit 1 and 2," Rev. 77, dated 8/09System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Code Compliance Review, NFPA 24-1969, Standard for Outside Protection Revision 1, December 2010Requirement/GuidanceThe fire protection water supply system shall be dedicated for fire protection use only.Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis.Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section.Subsection TitleWater SupplyNFPA 805 Section # 3.5.16Page A-126PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:EEEE DescriptionSummaryPage A-127PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceStandpipe and Hose Stations.Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6EEEE DescriptionSummaryPage A-128PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies by Previous NRC Approval; Complies with Use of Existing Engineering Equivalency EvaluationsCompliance BasisPer Item 125 of the table attached to 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," "The classification of the fire system is QA Type III. Design of hose stations to QA Type I in safeguards areas is not required in operating plants in accordance with Appendix A to APCSB 9.5-1. The system is built to power piping ANSI B31.1 code. Crossover lines from the Cooling Water system and valves are QA Type I to the check valves."Per Section 4.3.1.4 of NRC SER dated 9/6/79, "Interior hose stations are provided throughout most areas of the plant connected to the fire water header. Most hose stations consist of a pin lug type hose rack, 300 psi hose valve with drip vent and 50 to 100 feet of 1 1/2-inch unlined linen hose coupled to an all fog type nozzle with a ball shut off feature. The provision of unlined linen hose is considered unsatisfactory in an industrial application since it cannot be practically tested, deteriorates readily when subjected to moisture, and is more subject to failure from abrasion and cuts than hose with synthetic lining and jacketing.-"All interior unlined linen fire hose will be replaced with 100% synthetic material fire hose (300 psi test pressure) FM or UL labelled, that is suitable for pin rack storage. -"We find that, subject to implementation of the above described modifications, interior fire hose stations satisfy the objectives identified in Section 2.2 of this report and are, therefore, acceptable."Per Section 3.8.A of System Description B31A, "Fire Protection System," "Each hose station is equipped with 50; 75© or 100© of 1-1/2" E-Z off, lightweight, synthetic jacket lined fire hose with an adjustable spray nozzle."Per Page 5 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, "By letter dated Plant DocumentationLetter from Mayer (NSP) to Stello (NRC) dated 12/8/76Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80NRC SER dated 9/6/79Code Compliance Review NFPA 14-1969, "Code Compliance Review - NFPA 14-1969, Standard for the Installation of Standpipe and Hose Systems," dated 2/15/2011Code Compliance Review NFPA 14-1986, FPEE-11-050, "Code Compliance Review - NFPA 14-1986, Standard for the Installation of Standpipe and Hose Systems," dated 3/9/2011 Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesFAQ 06-0019, "Definition of ©Power Block© and ©Plant©," Rev. 4, dated 9/28/07NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 EditionsExisting Engineering Equivalency Evaluations (EEEEs)Code Compliance Review NFPA 14-1986, FPEE-11-050, "Code Compliance Review - NFPA 14-1986, Standard for the Installation of Standpipe and Hose Systems," dated 3/9/2011Identifier:Requirement/GuidanceFor all power block buildings, Class III standpipe and hose systems shall be installed in accordance with NFPA 14, Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems.Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6.1EEEE DescriptionDocument the review of the standpipe and hose station systems for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 14 -1986SummaryFour deviations have been found acceptable based on the justification provided. One deviation has been found to be unacceptable and will require the performance of hydraulic calculations to verify the design bases of the standpipe and hose station system. GAR 01183456-01, Perform Hydraulic Calculations for FP Page A-129PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1December 26, 1979, the licensee provided design details regarding a more timely method of providing fire suppression water for the containment standpipes. Originally, fire suppression water would not be available for a period of 6 to 8 hours following the detection of a fire in containment. The licensee has proposed a design modification in which the existing containment fire line will be supplied by a four-inch cross-connect from the four-inch supply to the CRDM Shroud Cooling Coils. The cross-connect 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."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."NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 1969 Code Compliance Review, Revision 1Items for ImplementationNoneDocument the review of the stand pipe and hose systems for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 14-1969, Standard for the Installation of Stand Pipe and Hose SystemsSystems, is tracking resolution of this issue.Eleven deviations to the code requirements have been identified, nine of which are identified as acceptable and two with action requests (ARs) to address resolutions to the identified issues.Page A-130PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Standpipes, 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 for the Installation of Standpipe and Hose Systems," dated 3/9/2011.Page A-131PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per the NFPA 14-1969 Code Compliance Review, Rev 1 table dated 2/15/2011, "The Mississippi River and the fire pumps can provide adequate water volume and pressure for the most remote hose stations."Per the NFPA 14-1986 Code Compliance Review, Rev. 1 table dated 3/9/2011, "The two fire pumps can provide adequate pressure for the most remote hose stations."Pressure reducers are not required on standpipe outlets for 2-1/2 inch hose because it is assumed 2-1/2 inch hose will be attached only when the persons likely to use it are trained in handling large streams. Since the brigade is qualified to use large hose streams, they are also qualified to use 1-1/2 inch hose at higher pressures. Training on the use of large hose is conducted annually at the live fire training session.City of Red Wing Job Description, Firefighter/Paramedic: Minimum Qualifications:The job requires two years of formal training beyond high school diploma, 1 year of related experience, and Firefighter II certification. National Registry EMT-Paramedic Certification required.City of Red Wing Job Description, Paid On Call Firefighter, The job requires a high school diploma 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.Plant DocumentationNFPA 14-1969 Code Compliance Review Rev. 1, dated 2/15/2011NFPA 14-1986 Code Compliance Review Rev. 1, FPEE-11-019, dated 3/9/2011City of Red Wing Job Description, Firefighter/Paramedic:City of Red Wing Job Description, Paid On Call Firefighter, F5, Firefighting, Rev 33.F5 Appendix J, Fire Drills, Rev 14Industry-Related ReferencesNFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 EditionsMinnesota Fire Service Certification, Fire Fighter II Skills Testing NFPA 1001 Fire Fighter II, 2008 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceA capability shall be provided to ensure an adequate water flow rate and nozzle pressure for all hose stations. This capability includes the provision of hose station pressure reducers where necessary for the safety of plant industrial fire brigade members and off-site fire department personnel.Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6.2EEEE DescriptionSummaryPage A-132PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 3.8 of System Description B31A, "Fire Protection System," "Six low gallonage hose stations are located in the plant. Each of the hose stations is equipped with a continuous flow reel, 100© of 1" solid rubber hose, and a 1" low gallonage fog nozzle. The hose stations are located along the ©G© wall on the 715© and 735© levels of the Turbine Building for use in the Relay and Cable Spreading Room, the Unit 1 & Unit 2 480V & 4.16KV Safeguards Switchgear Rooms, and the Control Room. The low gallonage hose stations are designed to prevent the extensive damage which could occur in the rooms from the use of the existing 1-1/2" hose stations."Per Section 7.10 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "All fire hose stations are equipped with adjustable fog nozzles (95 gpm) and 75 or 100 feet of 1 1/2" fire hose. They can be used on all types of fires."Per Section 3.4 of Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," "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."Per Section 4.3.1.4 of NRC SER dated 9/6/79, "Interior hose stations are provided throughout most areas of the plant connected to the fire water header. Most hose stations consist of a pin lug type hose rack, 300 psi hose valve with drip vent and 50 to 100 feet of 1 1/2-inch unlined linen hose coupled to an all fog type nozzle with a ball shut off feature- The licensee has agreed to improve the interior fire hose stations by providing the following modifications:- (3) A one-inch booster hose with variable gallonage nozzle with shut off will be provided adjacent to the existing hose Plant DocumentationNRC SER dated 9/6/79Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesFAQ 06-0019, "Definition of ©Power Block© and ©Plant©," Rev. 4, dated 9/28/07NFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 EditionsExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceThe proper type of hose nozzle to be supplied to each power block area shall be based on the area fire hazards. The usual combination spray/straight stream nozzle shall not be used in areas where the straight stream can cause unacceptable damage or present an electrical hazard to fire-fighting personnel. Listed electrically safe fixed fog nozzles shall be provided at locations where high-voltage shock hazards exist. All hose nozzles shall have shutoff capability and be able to control water flow from full open to full closed.Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6.3EEEE DescriptionSummaryPage A-133PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1stations 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.Items for ImplementationNonePage A-134PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Item No. 9 of Letter from Mayer (NSP) to Stello (NRC) dated 12/8/76, "As permitted in Appendix A to APCSB 9.5-1, the system has not been analyzed to withstand the SSE. The system can function under all expected natural phenomena characteristic of the region. The system is not subject to man-created site related event damage."Per Section 4.3.1.4 of NRC SER dated 9/6/79, "interior fire hose stations satisfy the objectives identified in-this report and are, therefore, acceptable."The hose stations and standpipes provided for PINGP are in accordance with the requirements of BTP 9.5-1, Appendix A for plants which received a construction permit before July 1, 1976 which do not require a seismic category I water system.Provisions to supply water to standpipes and hose stations for manual fire suppression in the event of a safe shutdown earthquake are outlined in EDMG-2, Guideline for Damage Mitigation Strategies (Attachment B - Fire System Management and Attachment L - Establishing Emergency Water Supply).Plant DocumentationLetter from Mayer (NSP) to Stello (NRC) dated 12/8/76NRC SER dated 9/6/79EDMG-2, Guideline for Damage Mitigation Strategies, Rev. 8Industry-Related ReferencesNFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 EditionsExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProvisions shall be made to supply water at least to standpipes and hose stations for manual fire suppression in all areas containing systems and components needed to perform the nuclear safety functions in the event of a safe shutdown earthquake (SSE).Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6.4EEEE DescriptionSummaryPage A-135PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 10.3.1.2.1 of the Updated Safety Analysis Report (USAR), "In addition to the two dedicated fire pumps, a third pump, electric motor-driven and 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 cooling water system provides a backup source of water for the fire protection headers. Via normally closed valves, the cooling water system can provide a backup water supply for the following safeguards equipment fire protection spray and sprinkler systems: auxiliary feedwater pumps, diesel generators, containment cable penetrations, and safeguards cooling water pumps."Per Section 10.4.1.2.2, "Upon occurrence of the design basis seismic event, the cooling water system flow demand is approximately 36,691 gpm- This is with the two diesel driven safeguards cooling water pumps operating, since this creates the highest demand on the suction supply. There is an additional 2000 gpm demand from the diesel fire pump. Initially, the supply to the safeguards cooling water pumps is from both 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-Plant DocumentationCalculation ENG-ME-160, "Aux Bldg Fire Protection to Cooling Water Header Cross Tie Hydraulic Calc," Rev. 2Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Updated Safety Analysis Report (USAR) Section 10, Rev. 32PIndustry-Related ReferencesNFPA 14, "Standard for the Installation of Standpipe and Hose Systems," 1969 and 1986 EditionsExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceWhere the seismic required hose stations are cross-connected to essential seismic non-fire protection water supply systems, the fire flow shall not degrade the essential water system requirement.Subsection TitleStandpipe and Hose StationsNFPA 805 Section #3.6.5EEEE DescriptionSummaryPage A-136PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1operated crossovers between the Cooling Water System and the main loop and sprinklers within the Fire Protection System. The Cooling Water System and Fire Protection System normally are isolated from each other. At the crossovers, isolation is provided by a normally closed stop valve and a check valve."Per Section 2 of System Description B31A, "Fire Protection System," "The Cooling Water 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 Water 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.Page A-137PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.2 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Portable and wheeled fire extinguishers are provided throughout the plant. Most of the extinguishers are of the CO2 to dry chemical type." Table 6-1 of Procedure F5 Appendix F establishes the location and type of each fire extinguisher in the plant.Fire extinguishers have been reviewed against the requirements of NFPA 10, as detailed in the Code Compliance Review "Code Compliance Review - NFPA 10-1969, Standard for Portable Fire Extinguishers, Code Compliance Deviations" Rev 1, dated 3/26/2010 and "Code Compliance Review - NFPA 10-1986, Standard for Portable Fire Extinguishers," dated 8/16/07.Plant DocumentationCode Compliance Review NFPA 10-1969, "Code Compliance Review - NFPA 10-1969, Standard for Portable Fire Extinguishers, Code Compliance Deviations" Rev 1, dated 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 8/8/11Industry-Related ReferencesNFPA 10, "Standard for the Installation of Portable Fire Extinguishers," 1969 EditionNFPA 10, "Standard for Portable Fire Extinguishers," 1986 EditionExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceWhere provided, fire extinguishers of the appropriate number, size, and type shall be provided in accordance with NFPA 10, Standard for Portable Fire Extinguishers. Extinguishers shall be permitted to be positioned outside of fire areas due to radiological conditions.Subsection TitleFire ExtinguishersNFPA 805 Section # 3.7EEEE DescriptionSummaryPage A-138PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceFire Alarm and Detection Systems.Subsection TitleFire Alarm and Detection SystemsNFPA 805 Section #3.8EEEE DescriptionSummaryPage A-139PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationsCompliance BasisPer Section 3.0 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Fire Detection Systems (FDS) are provided throughout the plant. The fire detectors are connected to an alarm which annunciates either in the Control Room or at local panels, which in turn alarms in the Control Room, thus providing the Control Room operator with an indication of system operation, tampering or malfunction. In addition to handling fire detector signals, the system transmits indication of water flow from the sprinkler and deluge extinguishing systems. In all cases, the zone from which the alarm or signal is initiated is indicated. Indication of operation of the CO2 extinguishing system is indicated on a separate panel. The fire detection system is powered from an emergency source of power and all circuits from local control panel to Control Room are electrically supervised."Per Section 3.0, "The Fire Detection System meets the requirements established by Underwriter's Laboratories and Factory Mutual. These requirements comply with National Fire Protection Association (NFPA) recommendations in effect when the plant was constructed (1969)."Per Technical Specification 3.14.A, identified in letter from Davis (NRC) to Mayer (NSP) dated 2/14/78, "The minimum number of fire detection instruments for each fire zone specified in Table TS.3.14-1 shall be operable."Fire alarm systems have been reviewed against the requirements of NFPA 72D, as detailed in the NFPA 72D-1967 and NFPA 72D-1986 code review checklists.Plant DocumentationLetter from Mayer (NSP) to Director (NRC) dated 11/30/79Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80Letter from NSP to Director of Nuclear Reactor Regulation (NRC) dated 10/24/80Requirement/GuidanceAlarm initiating devices shall be installed in accordance with NFPA 72, National Fire Alarm Code. Alarm annunciation shall allow the proprietary alarm system to transmit fire-related alarms, supervisory signals, and trouble signals to the control room or other constantly attended location from which required notifications and response can be initiated. Personnel assigned to the proprietary alarm station shall be permitted to have other duties. The following fire-related signals shall be transmitted:(1) Actuation of any fire detection device(2) Actuation of any fixed fire suppression system(3) Actuation of any manual fire alarm station(4) Starting of any fire pump(5) Actuation of any fire protection supervisory device(6) Indication of alarm system trouble conditionSubsection TitleFire AlarmNFPA 805 Section # 3.8.1Page A-140PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Letter from Schwencer (NRC) to Mayer (NSP), dated 4/21/80Letter from Long (NRC) to Parker (NSP) dated 4/28/92NRC SER dated 9/6/79NFPA 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.Design Basis Document DBD-TOP-06, "Fire Protection/Appendix R Design Basis Document," Rev. 5, dated 10/8/09Drawing NE-40007-127.1, "0.480Kv Bus 160 Motor Control Center IE Bus 1," Rev. DB, dated 5/5/79Drawing NE-40009 Sheet 63, "208/120AC VAC Panel 116," Rev. BF, dated 10/7/99Drawing NE-40011 Sheet 36, "BOP Annunciator Point Schematic Diagram Field TB 131-140, SER Points 131-140," Rev. PS, dated 5/5/00Drawing NE-40011 Sheet 37, Rev. AV, dated 8/1/05Drawing NE-40011 Sheet 40, "BOP Annunciator Point Schematic Diagram Field TB 171-180, SER Points 171-180," Rev. TU, dated 7/27/94Drawing 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 3/23/94Drawing NE-40014 Sheet 7, "Fire Detection Control Panel," Rev. R, dated 6/29/84Drawing NE-40014 Sheet 8, "Fire Detection Control Panel," Rev. T, dated 10/13/95Drawing NE-40014 Sheet 9, "Fire Detection Control Panel," Rev. R, dated 11/13/87Drawing NE-40014 Sheet 10, "Fire Detection Control Panel," Rev. P, dated 9/14/88Drawing NE-40014 Sheet 11, "Fire Detection Control Panel," Rev. Q, dated 9/8/05Drawing NE-40014 Sheet 12, "Fire Detection Control Panel," Rev. 76, dated 5/6/06Drawing NE-40014 Sheet 13, "Fire Detection Control Panel," Rev. 76, dated 5/09Drawing NE-40014 Sheet 14, "Fire Detection Control Panel," Rev. W, dated 4/17/03Drawing NE-40014 Sheet 15, "Fire Detection Control Panel," Rev. W, dated 4/22/03Drawing NE-40014 Sheet 16, "Zones 5 & 7," Rev. M, dated 11/1/74Drawing 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 9/25/95Drawing NE-40014 Sheet 19, "Zones 38, 41, & 45," Rev. D, dated 12/13/72Drawing NE-40014 Sheet 20, "Zones 48, 58, 59, & 49," Rev. G, dated 5/9/96Drawing NE-40014 Sheet 21, "Zones 60, 61, 62, & 63," Rev. F, dated 8/16/23Drawing NE-40014 Sheet 22, "Zones 76, 77, 78, 79, 80, 95, & 96," Rev. G, dated 11/29/92Drawing NE-40014 Sheet 23, "Local Red Warning Lights-Low Air Pressure in H.A.D.," Rev. GDrawing 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 8/3/88Drawing 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 8/14/73Page A-141PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Drawing NE-40014 Sheet 28, "II Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -8 Unit-1," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 29, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit-2," Rev. H, dated 12/20/73Drawing NE-40014 Sheet 30, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -5 Unit-2," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 31, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -8 Unit-2," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 32, "Relay & Computer Room Fire Protection System," Rev. 76, dated 12/08Drawing NE-40014 Sheet 33, "Relay & Computer Room Fire Protection System," Rev. 76, dated 12/08Drawing NE-40014 Sheet 36, "Fire Detection Control Panel 70466," Rev. B, dated 5/5/00Drawing NE-40014 Sheet 37, "Zone 1," Rev. C, dated 5/5/00Drawing NE-40014 Sheet 38, "Zone 1," Rev. C, dated 5/8/00Drawing NE-40014 Sheet 39, "Zone 2," Rev. C, dated 5/8/00Drawing NE-40014 Sheet 40, "Zone 2," Rev. C, dated 5/8/00Drawing NE-40014 Sheet 41, "Zone 4 & 22," Rev. B, dated 5/8/00 Drawing NE-40014 Sheet 42, "Zone 3 & 21," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 43, "Zone 5," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 44, "Zone 6," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 45, "Zones 8, 10, 14 & 19 Flow Switch 2FS-6057," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 46, "Zones 7, 9, & 13 & Flow Switch 2FS-5057," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 47, "Zones 11, 15, & 17," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 48, "Zones 12, 16 & 18," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 49, "Pre-Action & Sprinkler System," Rev. D, dated 5/8/00Drawing NE-40014 Sheet 50, "Zone 20," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 51, "D5/D6 Pre-Action Valves," Rev. B, dated 5/9/00Drawing NE-40014 Sheet 52, "Fire Detection Control Panel," Rev. B, dated 5/9/00Drawing NF-40250-1, "Wiring Diagram - Fire Detection Protection Panels 121 & 122," Rev. N, dated 10/26/00Drawing 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, "Wiring Diagram -11 Turbine Bearing Fire Protection Panel - Unit 1" Rev. C, dated 10/12/95Drawings NF-40889-14, "Wiring Diagram -21 Turbine Bearing Fire Protection Panel - Unit 2," Rev. A, dated 7/23/96Drawings NF-40889-15, "Transformer Fire Detection System Layout and Details Unit 1 & 2," Rev. 76, dated 12/13/05Page A-142PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Drawing NF-74564-4, "120/208V AC Distribution Panels 3135, 3145, 4135, and 4145 One Line Diagrams," Rev. 78, dated 11/16/09Drawing NF-85593-1, "Wiring Diagram - Fire Detection," Rev. E, dated 1/12/93Drawing NF-85599, "Wiring 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 2/1/10Drawing NF-93025-2, "Wiring Diagram - Service Building Control Panel 70456," Rev. B, dated 8/11/87Drawings NF-116700, "Fire Detection Plan - D5/D6 Bldg. Ground Floor Plan," Rev. B, dated 5/9/00Drawing NF-111629, "Schedules," Rev. 76, dated 5/5/06Drawing NF-116701, "Fire Detection Plan - D5/D6 Bldg. Grd. Fl. & Upper Deck," Rev. B, dated 10/2/92Drawing NF-116702, "Fire Detection Plan - D5/D6 Bldg Mezzanine Floor," Rev. B, dated 10/2/92Drawing NF-116703, "Fire Detection Plan - D5/D6 Bldg. Operating Floor," Rev. C, dated 5/8/00Drawing NF-116709, "Fire Detection Plan - D5/D6 Basement Floor," Rev. B, dated 10/2/92Drawing NF-172049, "FACP 70466 Control Room Wiring diagram," Rev. 76, dated 1/26/05 Drawing NF-172049-1, "Wiring 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 10/1/91Drawing NX-48389-1, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-2, "Fire Alarm System,' Rev. 76, dated 9/8/05Drawing NX-48389-3, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-4, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-5, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-6, "Fire Alarm System," Rev. 76, dated 3/21/05Drawing NX-48389-7, "Fire Alarm System," Rev. 76, dated 3/21/06Drawing NX-48389-8, "Building Monitor Annunciator," Rev. A, dated 10/30/90Drawing 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 12/19/90Fleet Procedure FP-G-RM-01, "Records Management," Rev. 10, dated 2/12/10Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 19, dated 3/16/09Procedure 5AWI 3.15.0, "Plant Operation," Rev. 30, dated 10/9/09 Procedure C31, "Fire Protection & Detection Systems," Rev. 43, dated 4/17/09Procedure C47022, "Alarm Response Procedure," Rev. 47, dated 2/19/10Procedure F5, "Fire Fighting," Rev. 32, dated 9/9/09Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 20, dated 5/3/05Procedure 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 1/17/06Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," Page A-143PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Rev. 32, dated 11/20/08Procedure SP 1524, "122 Diesel Fire Pump Weekly Test," Rev. 37, dated 9/2/09Procedure 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 2/18/01Industry-Related ReferencesNFPA 72D, "Proprietary Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service," 1967 EditionNFPA 72D, "Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems," 1986 EditionExisting Engineering Equivalency Evaluations (EEEEs)FPEE-11-034FPEE-11-036Items for ImplementationNoneIdentifier:EEEE DescriptionNFPA 72D, 1967 Code Compliance Deviations.NFPA 72D, 1986 Code Compliance DeviationsSummaryEach deviation has a separate justification, see evaluation for detailed bases.Each deviation has a separate justification, see evaluation for detailed bases.Page A-144PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 2.1 of Procedure F5, "Fire Fighting," the "Individual discovering a fire shall immediately report it to the Control Room (CR) using the emergency numbers listed on the telephone, (4911) giving location, type and intensity."Per Section 10.3.8 of the Updated Safety Analysis Report (USAR), "A fixed public address system interfaced with UPS powered Private Branch Exchange (PBX) telephone system provide normal and emergency communications. In the event of a PBX failure, power fail telephone stations from the local telephone office and extensions operating on the Xcel Energy Sherco Plant Telephone Switch could be utilized to conduct emergency communications. In addition, a sound powered communications system is installed with communications jacks located throughout the plant. The sound powered system requires no external power, and headsets for use with the system are readily available."Plant DocumentationProcedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Updated Safety Analysis Report (USAR) Section 10, Rev. 32PIndustry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceMeans shall be provided to allow a person observing a fire at any location in the plant to quickly and reliably communicate to the control room or other suitable constantly attended location.Subsection TitleFire AlarmNFPA 805 Section # 3.8.1.1EEEE DescriptionSummaryPage A-145PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis (1) Per Sections 2.1 and 2.2 of Procedure F5, "Fire Fighting," the individual discovering the fire is required to notify the Control Room via an emergency telephone. "The Control Room Operator shall respond as directed in the Annunciator Response Procedure for a fire detection panel alarm."Per Section 4.6, a "Fire Alarm page" is sent by the Control Room Operator to notify plant occupants of a fire alarm condition.Per Section 7.2.1 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 areaThe plant evacuation alarm consists of a 125 VDC operated siren, manually started from the Control Room. This tone consists of a signal starting at approximately 600 cycles per second rising to a peak of approximately 1450 cycles per second, then returning slowly to the low value of 600 cycles per second and repeating. The Control Room operator can remove the siren tone for emergency voice communication over the loudspeaker PA system.(2) Per Section 4.6 of Procedure F5, "Fire Fighting," the fire brigade members are notified of a fire incident via a "Fire Alarm page" which is sent by the Control Room Operator. Per Section 1.2.6, fire brigade members are equipped with a Plant DocumentationProcedure E-PLAN, "Emergency Plan," Rev. 41, dated 3/29/2010Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceMeans shall be provided to promptly notify the following of any fire emergency in such a way as to allow them to determine an appropriate course of action:(1) General site population in all occupied areas(2) Members of the industrial fire brigade and other groups supporting fire emergency response(3) Off-site fire emergency response agencies. Two independent means shall be available (e.g., telephone and radio) for notification of off-site emergency services.Subsection TitleFire AlarmNFPA 805 Section # 3.8.1.2EEEE DescriptionSummaryPage A-146PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1pager 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 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 Warning 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 site's 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 EOC's, and Treasure Island Casino (Prairie Island Indian Tribe)."Items for ImplementationNonePage A-147PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisPer Section 3.0 of Procedure F5 Appendix F, "Fire Hazard Analysis," "The Fire Detection System meets the requirements established by Underwriter's Laboratories and Factory Mutual. These requirements comply with National Fire Protection Association (NFPA) recommendations in effect when the plant was constructed (1969)."Per Section 4.2 of NRC SER dated 9/6/79, "Some detectors are located in areas that are blocked from view by equipment or other obstructions. The licensee will provide detector locations markings on the floor or install remote wall mounted indicator lights to show the approximate location of hidden detectors. The licensee will also provide verification that the existing installed detectors will respond promptly to the various types of materials found in the plant, including cabling, when these materials are involved in the incipient stages of a fire. Manufacturer©s test reports describing the detector response from burning of specific type materials will be considered acceptable."Section 3.2.8 of Letter from Mayer (NSP) to Director (NRC) dated 11/30/79, details the "response testing reports" of the fire detectors, as required per Section 4.2 of NRC SER dated 9/6/79. However, "Response testing data for specific cable types not included in the attached reports has been requested and will be submitted at a later date."Per Section 3.2.8 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, "We have reviewed the data regarding the fire detector response capability submitted by the licensee. Based on our review, we have concluded that this information verifies that existing installed detectors will respond to the various types of materials found in the plant when these materials are involved in the incipient stages of fire. Therefore, we find that the fire detectors the licensee has selected acceptable."Plant DocumentationLetter from Mayer (NSP) to Director (NRC) dated 11/30/79Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80Letter from NSP to Director of Nuclear Reactor Regulation (NRC) dated 10/24/80Letter from Schwencer (NRC) to Mayer (NSP), dated 4/21/80Letter from Long (NRC) to Parker (NSP) dated 4/28/92NRC SER dated 9/6/79 Code Compliance Review FPP-5 R2, NFPA 72E Code Compliance Evaluation (NFPA 72E-1974, -85, and -87, "Prairie Island Nuclear Generating Plant Appendix 7 - NFPA 72E Code Compliance Review," performed by Areva), dated 4/21/04, Design Basis Document DBD-TOP-06, "Fire Protection/Appendix R Design Basis Document," Rev. 5, dated 10/8/09Drawing NE-40007-127.1, "0.480Kv Bus 160 Motor Control Center IE Bus 1," Rev. DB, dated 5/5/79Drawing NE-40009 Sheet 63, "208/120AC VAC Panel 116," Rev. BF, dated 10/7/99Drawing NE-40011 Sheet 36, "BOP Annunciator Point Schematic Diagram Field TB 131-140, SER Points 131-140," Rev. PS, dated 5/5/00Drawing 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 7/27/94Drawing NE-40011 Sheet 105, "BOP Annunciator Point Schematic Diagram Field TB 821-830, SER Points 821-839," Rev. G, dated 5/4/00Drawing NE-40014 Sheet 6, "Fire Detection Control Panel Power Supply," Rev. R, dated 3/23/94Drawing NE-40014 Sheet 7, "Fire Detection Control Panel," Rev. 76, dated 5/09Drawing NE-40014 Sheet 8, "Fire Detection Control Panel," Rev. 76, dated 5/09Drawing NE-40014 Sheet 9, "Fire Detection Control Panel," Rev. R, dated 11/13/87Drawing NE-40014 Sheet 10, "Fire Detection Control Panel," Rev. P, dated 9/14/88Drawing 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 5/6/06Drawing NE-40014 Sheet 13, "Fire Detection Control Panel," Rev. 76, dated 5/09Requirement/GuidanceIf automatic fire detection is required to meet the performance or deterministic requirements of Chapter 4, then these devices shall be installed in accordance with NFPA 72, National Fire Alarm Code, and its applicable appendixes.Subsection TitleDetectionNFPA 805 Section # 3.8.2Page A-148PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Item 3.2.8 of Letter from NSP to Director of Nuclear Reactor Regulation (NRC) dated 10/24/80, details the testing data for several other cable types that were previously unavailable.Per Section 3.2.8 of Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80, the NRC determined "that the fire detectors installed will respond to the various types of materials found in the plant and, therefore, are acceptable."Automatic fire detection systems have been reviewed against the requirements of NFPA 72E, as detailed in "FPP-5 R2, NFPA 72E Code Compliance Evaluation", dated 4/21/04. Subsequent analysis of identified code deviations was completed and required modifications have been captured in EC 19648.Drawing NE-40014 Sheet 14, "Fire Detection Control Panel," Rev. W, dated 4/17/03Drawing NE-40014 Sheet 15, "Fire Detection Control Panel," Rev. W, dated 4/22/03Drawing NE-40014 Sheet 16, "Zones 5 & 7," Rev. M, dated 11/1/74Drawing NE-40014 Sheet 17, "Zones 9, 13, & 16," Rev. C, dated 7/2/84Drawing NE-40014 Sheet 18, "Zones 18 & 22," Rev. G, dated 9/25/95Drawing NE-40014 Sheet 19, "Zones 38, 41, & 45," Rev. D, dated 12/13/72Drawing 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 8/16/23Drawing NE-40014 Sheet 22, "Zones 76, 77, 78, 79, 80, 95, & 96," Rev. G, dated 11/29/92Drawing NE-40014 Sheet 23, "Local Red Warning Lights-Low Air Pressure in H.A.D.," Rev. GDrawing 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 8/3/88Drawing NE-40014 Sheet 26, "II Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit I," Rev. H, dated 12/20/73Drawing NE-40014 Sheet 27, "II Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -5 Unit-1," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 28, "II Turbine Bearing Fire Protection Panel Turbine Bearing-7 and - 8 Unit-1," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 29, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-I Unit-2," Rev. H, dated 12/20/73Drawing NE-40014 Sheet 30, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-2 and -5 Unit-2," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 31, "21 Turbine Bearing Fire Protection Panel Turbine Bearing-7 and -8 Unit-2," Rev. F, dated 8/14/73Drawing NE-40014 Sheet 32, "Relay & Computer Room Fire Protection System," Rev. 76, dated 12/08/8/00Drawing NE-40014 Sheet 42, "Zone 3 & 21," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 43, "Zone 5," Rev. B, dated 5/8/00Drawing 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 5/8/00Drawing NE-40014 Sheet 46, "Zones 7, 9, & 13 & Flow Switch 2FS-5057," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 47, "Zones 11, 15, & 17," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 48, "Zones 12, 16 & 18," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 49, "Pre-Action & Sprinkler System," Rev. D, dated 5/8/00Drawing NE-40014 Sheet 50, "Zone 20," Rev. B, dated 5/8/00Drawing NE-40014 Sheet 51, "D5/D6 Pre-Action Valves," Rev. B, dated 5/9/00Drawing NE-40014 Sheet 52, "Fire Detection Control Panel," Rev. B, dated 5/9/00Drawing 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 5/5/06Page A-149PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Drawing NF-40250-3, "Wiring Diagram Fire Detection Protection Panels 125 and 126," Rev. T, dated 4/24/03Drawing 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, "Wiring Diagram -11 Turbine Bearing Fire Protection Panel - Unit 1" Rev. C, dated 10/12/95Drawings NF-40889-14, "Wiring Diagram -21 Turbine Bearing Fire Protection Panel - Unit 2," Rev. A, dated 7/23/96Drawings NF-40889-15, "Transformer Fire Detection System Layout and Details Unit 1 & 2," Rev. 76, dated 12/13/05Drawing NF-74564-4, "120/208V AC Distribution Panels 3135, 3145, 4135, and 4145 One Line Diagrams," Rev. 78, dated 11/16/09Drawing NF-85593-1, "Wiring Diagram - Fire Detection," Rev. E, dated 1/12/93Drawing NF-85599, "Wiring 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 2/1/10Drawing NF-93025-2, "Wiring Diagram - Service Building Control Panel 70456," Rev. B, dated 8/11/87Drawings NF-116700, "Fire Detection Plan - D5/D6 Bldg. Ground Floor Plan," Rev. B, dated 5/9/00Drawing NF-111629, "Schedules," Rev. 76, dated 5/5/06Drawing NF-116701, "Fire Detection Plan - D5/D6 Bldg. Grd. Fl. & Upper Deck," Rev. B, dated 10/2/92Drawing NF-116702, "Fire Detection Plan - D5/D6 Bldg Mezzanine Floor," Rev. B, dated 10/2/92Drawing NF-116703, "Fire Detection Plan - D5/D6 Bldg. Operating Floor," Rev. C, dated 5/8/00Drawing NF-116709, "Fire Detection Plan - D5/D6 Basement Floor," Rev. B, dated 10/2/92Drawing NF-172049, "FACP 70466 Control Room Wiring diagram," Rev. 76, dated 1/26/05Drawing NF-172049-1, "Wiring diagram FAIP 70467 & Assoc. Term. Boxes Unit 1 &2," Rev. 76, dated 1/26/05Drawing NH-50383, "NPD-SBO Fire Alarm System," Rev. B, dated 10/1/91 Drawing NX-48389-1, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-2, "Fire Alarm System,' Rev. 76, dated 9/8/05Drawing NX-48389-3, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-4, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-5, "Fire Alarm System," Rev. 76, dated 9/8/05Drawing NX-48389-6, "Fire Alarm System," Rev. 76, dated 3/21/05Drawing NX-48389-7, "Fire Alarm System," Rev. 76, dated 3/21/06Drawing NX-48389-8, "Building Monitor Annunciator," Rev. A, dated 10/30/90Drawing NX-48389-9, "NSP Administration Bldg Fire Protection System," Rev. A, dated 12/19/90Drawing NX-48389-10, "NSP Administration Bldg Fire Protection System," Rev. A, dated 12/19/90Fleet Procedure FP-G-RM-01, "Records Management," Rev. 10, dated 2/12/10Page A-150PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Procedure 5AWI 3.13.0, "Fire Protection Program," Rev. 21, dated 01/05/12Procedure 5AWI 3.15.0, "Plant Operation," Rev. 32, dated 9/23/11Procedure C31, "Fire Protection & Detection Systems," Rev. 43, 4/17/09Procedure C47022, "Alarm Response Procedure," Rev. 47, dated 2/19/10Procedure F5, "Fire Fighting," Rev. 33, dated 4/12/11Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Procedure ICPM 0-046, "Fire Protection Sprinkler Flow Switch Test", Rev. 0, dated 1/17/06Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," Rev. 32, dated 11/20/08Procedure SP 1524, "122 Diesel Fire Pump Weekly Test," Rev. 37, dated 9/2/09Procedure 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 2/18/01Industry-Related ReferencesNFPA 72E, "Standard on Automatic Fire Detectors"Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationRequired modifications have been captured in EC 19648 (NFPA 805 LAR ATTACHMENT S - PLANT MODIFICATIONS AND CONFIRMATORY ITEMS) and will be completed in accordance with the schedule associated with completion of these items. This EC addresses all fire detection system modifications determined to be required.Identifier:EEEE DescriptionSummaryPage A-151PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceAutomatic and Manual Water-Based Fire Suppression Systems.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9EEEE DescriptionSummaryPage A-152PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisPer Section 4.0 of Procedure F5 Appendix F, "Fire Hazard Analysis," "The Fire Protection System was designed for continuous standby service. The system was designed in accordance with some sections of the standards to the National Fire Protection Association (NFPA) which were applicable in 1969 (1989 for D5/D6), except as identified and justified in the NFPA code compliance review. The system was also based on general recommendations of the Nuclear Energy Property Insurance Association (NEPIA) - now Nuclear Electric Insrance Limited (NEIL)."Water mist and foam-water systems are not installed at PINGP.Water-based fire suppression systems have been reviewed against the requirements of NFPA 13, as detailed in the system specific Code Compliance Review.Plant DocumentationNRC SER dated 9/6/79Code Compliance Review NFPA 13-1969, "Code Compliance Review - NFPA 13, Standard for the Installation of Sprinkler Systems, 1969," dated 6/13/07Code Compliance Review NFPA 13-1987, "Code Compliance Review - NFPA 13, Standard for the Installation of Sprinkler Systems, 1987," dated 6/13/07Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Requirement/GuidanceIf an automatic or manual water-based fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:(1) NFPA 13, Standard for the Installation of Sprinkler Systems(2) NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection(3) NFPA 750, Standard on Water Mist Fire Protection Systems(4) NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray SystemsSubsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.1Page A-153PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Industry-Related ReferencesNFPA 13, "Standard for the Installation of Sprinkler Systems," 1969 and 1987 EditionsNFPA 15, "Standard for Water Spray Fixed Systems for Fire Protection," 1969 EditionExisting Engineering Equivalency Evaluations (EEEEs)FPEE-11-058FPEE-11-042Pre-action Sprinkler System PA-9 Engineering Evaluation, March 2011Identifier:EEEE DescriptionNFPA 13 Code Compliance Review, WPS-25, Wet Pipe Sprinkler System, Working Materials & Lunch RoomNFPA 13 Code Compliance Review, WPS-10, Wet Pipe Sprinkler Systems Auxiliary Feedwater Pump RoomsNFPA 13 Code Compliance Review, PA-9, Pre-Action Sprinkler System, ScreenhouseSummaryThe evaluation documents the review of the WPS-25 wet pipe sprinkler system protecting the Working Materials & Lunch Room, Fire Area 14, for compliance with the requirements of National Fire Protection Association (NFPA) 13. Identified deviations require a modification to resolve noncompliances associated with partial system installation and obstructions due to ducts. This modification is identified in Attachment S, Table S-2.The evaluation documents the review of the WPS-10 wet pipe sprinkler system protecting the Auxiliary Feedwater Pump Rooms, Fire Areas 31 and 32, for compliance with the requirements of National Fire Protection Association (NFPA) 13.A modification is required to resolve a noncompliance in both AFW Pump Rooms associated with pendent heads without return bends. This modification is identified in Attachment S, Table S-2.The evaluation documents the review of the PA-9 pre-action Page A-154PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonesprinkler system protecting the Screenhouse, Fire Area 41, for compliance with the requirements of National Fire Protection Association (NFPA) 13.A modification is required to add a sprinkler head under a large obstruction over the Diesel Driven Fire Pump and to add a sprinkler which was found to be missing. This modification is identified in Attachment S, Table S-2Page A-155PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.2 of NRC SER dated September 6, 1979, "a fire detection and signaling system is provided throughout many areas of the plant which transmits alarm and supervisory signals to the control room where they are annunciated at the fire panel. In addition to handling fire detector signals, the system transmits indications of water flow from the sprinkler and deluge extinguishing systems."Per Section 2 of System Description B31A, "Fire Protection System," "Each sprinkler system is equipped with a readily visible, manually operated, shutoff valve to isolate the system and a flow switch or alarm check valve which activates an alarm upon initiation of water flow."Plant DocumentationNRC SER dated 9/6/79System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceEach system shall be equipped with a water flow alarm.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.2EEEE DescriptionSummaryPage A-156PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 4.2 of NRC SER dated 9/6/79, "A fire detection and signaling system is provided throughout many areas of the plant which transmits alarm and supervisory signals to the control room where they are annunciated at the fire panel. In addition to handling fire detector signals, the system transmits indications of water flow from the sprinkler and deluge extinguishing systems. The system also indicates the operation of the carbon dioxide (CO2) extinguishing systems. In all cases, the zone from which the alarm or supervisory signal is initiated is indicated."Per Section 4.1.3 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Water flows from the automatic wet pipe and preaction deluge suppression systems are annunciated on the fire panel in the Control Room. Flows from manual hose stations are not annunciated, but they will 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.Plant DocumentationNRC SER dated 9/6/79Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Pioneer Service & Engineering Co. System Description 323.6720, "Prairie Island Fire Protection System," dated 9/15/70Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceAll alarms from fire suppression systems shall annunciate in the control room or other suitable constantly attended location.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.3EEEE DescriptionSummaryPage A-157PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 5.19.4 of NRC SER dated 9/6/79, the electric motor-driven and the diesel engine-driven fire pumps are located in the lower level of the screenhouse. The entire screenhouse is protected by a preaction type automatic sprinkler system.Per Table 6-1 of Procedure F5 Appendix F, "Fire Hazard Analysis," the diesel-driven fire pump is located in Fire Area 41B, and is protected by a full-coverage, pre-action sprinkler system.Plant DocumentationNRC SER dated 9/6/79Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceDiesel-driven fire pumps shall be protected by automatic sprinklers.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.4EEEE DescriptionSummaryPage A-158PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.4.1 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The system shall be functional at all times with a functional flow path capable of taking suction from the river and transferring water through distribution piping with functional sectional control or isolation valves to the yard hydrant valves and the first isolation valve for each deluge system, hose station, or sprinkler system."Per Section 3.9 of System Description B31A, "Fire Protection System," the wet pipe sprinkler "systems are monitored by alarm valves and flow switches. A readily visible, manually operated shutoff valve is located upstream of each alarm valve.Per Section 3.11, the deluge systems are 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.Plant DocumentationProcedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceEach system shall be equipped with an OS&Y gate valve or other approved shutoff valve.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.5EEEE DescriptionSummaryPage A-159PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 8.5.11 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "Each valve (manual, power operated or automatic) in the flow path for safety-related areas and areas posing a fire hazard to safety-related areas shall be verified to be in the correct position and secured to prevent inadvertent misalignment every month."Per Section 1.1 of Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," "The purpose of this surveillance is to verify that fire protection valves supplying safety related areas, and areas posing a fire hazard to safety related areas, are in the correct position and secured."Per Section 1.5.1, the acceptance criteria for all water supply and fire suppression system control valves is "Valve verified open per 5AWI 3.10.1 Appendix E" and "Block Wire in place."Per Section 5.1, "Block Wire is required to prevent inadvertent mispositioning of valves."Appendix E of Procedure 5AWI 3.10.1, "Methods of Performing Verifications," provides instructions for inspecting valves to ensure they are adequately locked.Plant DocumentationProcedure 5AWI 3.10.1, "Methods of Performing Verifications," Rev. 16, dated 6/30/10Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Procedure SP 1200, "Fire Protection System Supply to Safety Related Areas Valve Check," Rev. 32, dated 11/20/08Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceAll valves controlling water-based fire suppression systems required to meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.Subsection TitleAutomatic and Manual Water-Based Fire Suppression SystemsNFPA 805 Section #3.9.6EEEE DescriptionSummaryPage A-160PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)N/AItems for ImplementationN/AIdentifier:Requirement/GuidanceGaseous Fire Suppression Systems.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10EEEE DescriptionSummaryPage A-161PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisPer Section 4.0 of Procedure F5 Appendix F, "Fire Hazard Analysis," The Fire Protection System was designed for continuous standby service. The system was designed in accordance with some section of the standards to the National Fire Protection Association (NFPA) which were applicable in 1969 (1989 for D5/D6), except as identified and justified in the NFPA code compliance review. The system was also based on general recommendations of the Nuclear Energy Property Insurance Association (NEPIA) - now Nuclear Electric Insrance Limited (NEIL)."Per Section 4.2.7, "The relay and cable spreading room is protected by an automatic 6 ton carbon dioxide (CO2) suppression system with alarm sirens and a sixty-second delay. A detection system and a thermal actuation system is provided. Products of combustion detectors provide an early warning alarm to the Control Room. The auto action mode is normally bypassed when the room is occupied; however, the carbon dioxide system may be manually actuated at any time. The carbon dioxide system is backed up by manual hose stations and extinguishers. The system is designed for total flooding application with a 50 percent concentration for 15 minutes. Storage tank capacity is adequate for two shots. The system is actuated by thermal detectors with provisions for manual actuation. The area is also provided with fire detectors which alarm on the control Room fire panel."Per Section 4.2.18, the "Records storage vault is protected by a Halon system. In addition, hose stations and extinguishers are located outside the record storage vault entrance door."Per Table 6-1, a Halon suppression system is installed in the Old Administration Building (Fire Plant DocumentationNRC SER dated 9/6/79Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11FPEE-11-038 Code Compliance Review, NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 1972, Relay and Computer Room, Fire Area 18, 10/4/2011.Industry-Related ReferencesNFPA 12, "Standard on Carbon Dioxide Extinguishing Systems"NFPA 12A, "Standard of Halon 1301 Fire Extinguishing Systems"Existing Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceIf an automatic total flooding and local application gaseous fire suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:(1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems(2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems(3) NFPA 2001, Standard on Clean Agent Fire Extinguishing SystemsSubsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.1EEEE DescriptionSummaryPage A-162PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Area 5), the Guardhouse (Fire Area 89), and the Service Building/Computer Room (Fire Area 94).Per Section 4.3.2 of NRC SER dated 9/6/79, "A carbon dioxide (CO2) type gas fire suppression system is provided in the cable spreading and relay room. The computer room is located within this room and is also protected by the CO2 system. The system is designed for total flooding application with a 50 percent concentration for 15 minutes. Storage tank capacity is adequate for two shots. The system is actuated by thermal detectors with provisions for manual actuation. The area is also provided with early warning detectors which indicate an alarm but does not actuate the CO2 suppression system. We find that the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable." NFPA 2001 does not apply, as there are no clean agent extinguishing systems at PINGP.Items for ImplementationResolution of AR01305680 - Cardox Fire Suppression System Calculation. This action will verify/validate the results of calculation ENG-ME-420 through the performance of a door fan test to determine room leakage rate.Resolution of AR01306187 - NFPA Code issue: Thermal detection for actuation of FP System. Identified deviations require a modification to resolve noncompliances associated with unprotected beam pockets and system supervision. This modification is identified in Attachment S, Table S-2.Page A-163PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 3.0 of Procedure F5 Appendix F, " Fire Hazard Analysis," "Fire Detection Systems (FDS) are provided throughout the plant. The fire detectors are connected to an alarm which annunciates either in the Control Room or at local panels, which in turn alarms in the Control Room, thus providing the Control Room operator with an indication of system operation, tampering or malfunction. In addition to handling fire detector signals, the system transmits indication of water flow from the sprinkler and deluge extinguishing systems. In all cases, the zone from which the alarm or signal is initiated is indicated. Indication of operation of the CO2 extinguishing system is indicated on a separate panel." Per Table 6-2, the Relay and Cable Spreading Room (Fire Area 18) and the Service Building/Computer Room (Fire Area 94) are monitored in the Detection Zone Control Room Circuit.Per Section 3.21B of System Description B31A, "Fire Protection System", "An audible alarm- is generated in the Computer Room," upon initiation of the Halon suppression system.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..."Plant DocumentationProcedure F5 Appendix F, " Fire Hazard Analysis," Rev. 25A, dated 8/8/11System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceOperation of gaseous fire suppression systems shall annunciate and alarm in the control room or other constantly attended location identified.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.2EEEE DescriptionSummaryPage A-164PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 3.18.A of System Description B31A, "Fire Protection System," "The Cardox system provides a total flood capability for the Relay/Computer Room in the event of a fire-The Relay Room penetration seals are protected from over-pressurization on a Cardox actuation by allowing the room doors to open to relieve excess pressure. The Unit 1 Relay Room door latch deenergizes after 43 to 58 second time delay, allowing excess pressure to force the door open. The Unit 2 Relay Room door latch deenergizes if the room pressure exceeds 14 ounces, allowing the door to open when pressure becomes excessive."Confinement of radioactive contaminants is not required as there are no gaseous fire suppression systems within the radiologically controlled area.Plant DocumentationProcedure PM 3122-10, "Cardox Preventative Maintenance Procedure," Rev. 8, dated 5/19/09System Description B31A "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceVentilation system design shall take into account prevention from over-pressurization during agent injection, adequate sealing to prevent loss of agent, and confinement of radioactive contaminants.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.3EEEE DescriptionSummaryPage A-165PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementN/ACompliance Basis Not Applicable. PINGP does not have areas protected by both primary and backup gaseous suppression.Plant DocumentationNoneIndustry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceIn any area required to be protected by both primary and backup 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.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.4EEEE DescriptionSummaryPage A-166PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis The CO2 suppression system is not provided with provisions for local disarming. The system is disarmed in the Control Room.Per Section 3.5 from Attachment 7 of Procedure FP-OP-COO-01, "Conduct of Operations," "Equipment configuration shall be controlled such that status of plant equipment is known at all times."Per Section 3.10, "Repositioning of equipment during the conduct of maintenance and/or testing that is not covered by written instruction may be performed by qualified individuals provided these manipulations are authorized by shift supervision. Such manipulations must be formally tracked to ensure proper repositioning."Plant DocumentationProcedure FP-OP-COO-01, "Conduct of Operations," Rev. 6, dated 07/08/2009Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceProvisions for locally disarming automatic gaseous suppression systems shall be secured and under strict administrative control.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.5EEEE DescriptionSummaryPage A-167PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 4.3.2 of NRC SER dated 9/6/79, "A carbon dioxide (CO2) type gas fire suppression system is provided in the cable spreading and relay room. The computer room is located within this room and is also protected by the CO2 system. The system is designed for total flooding application with a 50 percent concentration for 15 minutes- The area is provided with early warning detectors which indicate an alarm but does not actuate the CO2 suppression system. We find that the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."Per Section 3.18 of System Description B31A, "Fire Protection System," "The Cardox System provides a total flood capability for the 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.Plant DocumentationNRC SER dated 9/6/79Procedure C31, "Fire Protection & Detection Systems," Rev. 40, dated 6/3/09System Description B31A, "Fire Protection System," Rev. 12, dated 9/16/11Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceTotal flooding carbon dioxide systems shall not be used in normally occupied areas.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.6EEEE DescriptionSummaryPage A-168PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with Item for ImplementationCompliance BasisPer Section 7.8 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The relay and cable spreading room is protected by an automatic 6 ton carbon dioxide (CO2) suppression system with alarm sirens and a sixty-second delay. A detection system and a thermal actuation system are provided. Smoke detectors provide an early warning alarm to the Control Room."Per Section 3.18.B of System Description B31A, "Fire Protection System," "Upon receipt of either an automatic or 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."The requirement for an odorizer is not in the 1972 version of NFPA 12, Standard on Carbon Dioxide Extinguishing Systems which is the system design code of record. However, an odorizer will be added to the system as a modification as outlined in Attachment S.Plant DocumentationProcedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012System Description B31A, "Fire Protection System." Rev. 12, dated 9/16/11FPEE-11-038 Code Compliance Review, NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 1972, Relay and Computer Room, Fire Area 18Industry-Related ReferencesNational Fire Protection Association (NFPA) 12 -1972, Standard on Carbon Dioxide Extinguishing Systems.Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationAn odorizer will be added to the carbon dioxide system protecting the relay and cable spreading room.Identifier:Requirement/GuidanceAutomatic total flooding carbon dioxide systems shall be equipped with an audible pre-discharge alarm and discharge delay sufficient to permit egress of personnel. The carbon dioxide system shall be provided with an odorizer.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.7EEEE DescriptionSummaryPage A-169PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Section 7.9.1 of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "During those periods when the relay and cable spreading room area is occupied, automatic initiation of the CO2 system may be bypassed. During those periods when the area is normally unoccupied, the CO2 system shall be capable of automatic initiation."The mechanical bypass switch (CS-5843001) located in the Control Room disables the automatic function of the CO2 system, thereby preventing actuation of the system while work is on-going in the area protected by the CO2 system.Plant DocumentationProcedure F5 Appendix K "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Procedure C31, "Fire Protection & Detection Systems", Rev 52, dated 1/7/2012Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidancePositive mechanical means shall be provided to lock out total flooding carbon dioxide systems during work in the protected space.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.8EEEE DescriptionSummaryPage A-170PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis Per Item 131 of 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," "CO2 outlet nozzles are positioned to direct stream away from concentrations of cables or cabinets."Per NRC SER dated 9/6/79, "We find that the gas fire suppression system satisfies the objectives identified in Section 2.2 of this report and is, therefore, acceptable."Halon 1301 does not present a risk of secondary thermal shock due to the discharge nozzle configuration and the relatively low quantity of Halon to be discharged upon system actuation. Halon 1301 is installed in the Security Building, Records Storage Vault, and Service Building Addition Computer Room. None of these areas contain equipment required for NFPA 805 compliance.Plant DocumentationNRC SER dated 9/6/79Letter 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,"Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThe possibility of secondary thermal shock (cooling) damage shall be considered during the design of any gaseous fire suppression system, but particularly with carbon dioxide.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.9EEEE DescriptionSummaryPage A-171PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2008, Annex G, General Information on Carbon DioxideG.1. For fire-extinguishing applications, carbon dioxide has a number of desirable properties. It is noncorrosive, non-damaging, and leaves no residue to clean up after the fire.Plant DocumentationNoneIndustry-Related ReferencesNFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2008Existing Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceParticular attention shall be given to corrosive characteristics of agent decomposition products on safety systems.Subsection TitleGaseous Fire Suppression SystemsNFPA 805 Section #3.10.10EEEE DescriptionSummaryPage A-172PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCovered in the sub-sections belowCompliance BasisCovered in the sub-sections belowPlant Documentation N/AIndustry-Related ReferencesN/AExisting Engineering Equivalency Evaluations (EEEEs)NoneItems for ImplementationNoneIdentifier:Requirement/GuidanceThis section shall be used to determine the 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.Subsection TitlePassive Fire Protection FeaturesNFPA 805 Section #3.11EEEE DescriptionSummaryPage A-173PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementCompliesCompliance Basis The power block is defined in Attachment I to this Transition Report.Per Section 2.2 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Reinforced concrete (Grade B is used in the construction of structural components) requires the following minimum thicknesses to provide a fire resistance of three hours, per UBC: Walls - 6 1/2 inches; Floors - 4 1/2 inches; For all floors, the minimum required concrete (Grade B) cover thickness of the reinforcing bars is 1 inch; for beams and columns the minimum required concrete cover thickness is 1 1/2 inches. All PINGP reinforced concrete walls supporting fire areas in safety-related structures are at least 12 inches in thickness. All floor slabs between floors are at least 5 1/2 inches in thickness with a concrete covering reinforcing steel of at least 1 inch. Two exceptions are the 8 inch concrete floors over the OSC room and the Operator's Lounge, which have a concrete cover of 3/4 inch. These two floors, although acting as fire barriers, act only as an enclosing ceiling and support no equipment. The D5/D6 Building three hour barriers adequately separate redundant trains, fuel oil/lube oil storage, and the stairwell. Concrete beam and column reinforcing steel has at least a cover of 1 1/2 inches. In some cases, concrete masonry units (calcareous or siliceous gravel) are used in the construction of fire barrier walls with a minimum thickness of 6 inches. The minimum thickness of these walls required for a fire resistance of three hours is 5.3 inches."Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Industry-Related ReferencesFAQ 06-0019, "Definition of ©Power Block© and ©Plant©," Rev. 4, dated 9/28/07NFPA 80A, "Recommended Practice for Protection of Buildings from Exterior Fire Exposure," 1967 and 1987 EditionsExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Requirement/GuidanceEach major building within the power block shall be separated from the others by barriers having a designated fire resistance rating of 3 hours or by open space of at least 50 ft (15.2 m) or space that meets the requirements of NFPA 80A, Recommended Practice for Protection of Buildings from Exterior Fire Exposures.Exception: Where a performance-based analysis determines the adequacy of building separation, the requirements of 3.11.1 shall not apply.Subsection TitleBuilding SeparationNFPA 805 Section # 3.11.1EEEE DescriptionSummaryPage A-174PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Items for ImplementationNonePage A-175PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisPer Section 2.1 of Procedure F5 Appendix F, "Fire Hazard Analysis," "Walls that do not protect safe shutdown equipment are maintained as unrated barriers. In all cases, good fire prevention practices are followed."Per Section 2.2, "Fire Hazard Analysis," "Barriers that must be maintained as three hour rated barriers per BTP 9.5-1 or Appendix R are those that:A. Separate safety-related systems from any potential fires in non-safety related areas that could affect their ability to perform their safety function;B. Separate redundant divisions or trains of safety-related systems from each other so that both are not subject to damage from a single fire; orC. Separate individual units. "All safeguard equipment is located within structures or compartments designed to seismic Category 1 requirements which require the use of building materials inherently resistive to structural damage due to fire. Safety-related systems are also separated from high concentrations of combustible material by reinforced concrete or concrete masonry walls. Reinforced concrete (Grade B is used in the construction of structural components) requires the following minimum thicknesses to provide a fire resistance of three hours, per UBC: Walls - 6 1/2 inches; Floors - 4 1/2 inches;"For all floors, the minimum required concrete (Grade B) cover thickness of the reinforcing bars is 1 inch; for beams and columns the minimum required concrete cover thickness is 1 1/2 inches.""All PINGP reinforced concrete walls supporting fire areas in safety-related structures are at least Plant DocumentationProcedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Industry-Related ReferencesNFPA 251, "Standard Methods of Tests of Fire Endurance of Building Construction and Materials," 1999 EditionExisting Engineering Equivalency Evaluations (EEEEs)FPEE-12-006Identifier:Requirement/GuidanceFire barriers required by Chapter 4 shall include a specific fire-resistance rating. Fire barriers shall be designed and installed to meet the specific fire resistance rating using assemblies qualified by fire tests. The qualification fire tests shall be in accordance with NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials.Subsection TitleFire BarriersNFPA 805 Section # 3.11.2EEEE DescriptionFA 85 Boundaries and F5 Appendix K BarriersSummaryThe evaluation assesses the impact of postulated fires on either side of the Fire Area 85 boundaries that communicate with Fire Areas 60 and 75 on the 715ft elevation and Fire Areas 59 and 74 on the 715ft elevation for impact on fire Page A-176PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-112 inches in thickness. All floor slabs between floors are at least 5 1/2 inches in thickness with a concrete covering reinforcing steel of at least 1 inch. Two exceptions are the 8 inch concrete floors over the OSC room and the Operator's Lounge, which have a concrete cover of 3/4 inch. These two floors, although acting as fire barriers, act only as an enclosing ceiling and support no equipment."Concrete beam and column reinforcing steel has at least a cover of 1 1/2 inches. In some cases, concrete masonry units (calcareous or siliceous gravel) are used in the construction of fire barrier walls with a minimum thickness of 6 inches. The minimum thickness of these walls required for a fire resistance of three hours is 5.3 inches."Per Section 7.16.A of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "The PINGP has been designed generally with physical separation to prevent the spread of a postulated fire in safe shutdown equipment areas to prevent the loss of both Appendix R trains. This separation is maintained in part by fire resistive compartment isolation of plant safety systems. The walls and ceilings of such compartments are rated fire barriers. These walls and ceilings contain penetrations for the passage of pipes and electrical cables from one fire area to another. Therefore, these penetrations are a breach of the fire barriers and must be sealed so as to maintain the integrity of the fire barriers. PINGP is divided into fire areas based on general plant layout and fire protection equipment. Existing barriers, including the containment vessels, were used whenever possible for the fire area boundaries. All safeguards equipment is located within structures or compartments designed to seismic Category I requirements which require the use of building materials inherently resistive to structural damage due to fire. Safety-related systems are also separated from high concentrations of combustible material FPEE-11-020Items for ImplementationNoneNFPA Codes Referenced in NFPA 805 not addressed by separate code reviewssafe shutdown capability. The evaluation also assesses the location of the F5 Appendix K barrier separating Fire Area 85 and Fire Areas 59 and 74 on the 715ft elevation.Based on the evaluation, 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 evaluation documents the review of the NFPA codes referenced in NFPA 805 that are not addressed in individual NFPA code compliance reviews.A deviation was identified regarding the use of a radiant energy shield in Unit 1 Containment that has not been demonstrated to have a 1/2-hour fire rating when subject to testing following ASTM E-119. AR 01317872 is tracking resolution of this issue.Page A-177PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1by reinforced concrete or concrete masonry walls."Page A-178PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisPer Section 7.16.1.B of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," "Fire doors and frames in Appendix R-required fire barriers are rated to the equivalent fire resistance duration of three hours, in accordance with the criteria established in NFPA 252, Standard Methods of Fire Tests of Door Assemblies, 1968, ed."Fire doors have been reviewed against the requirements of NFPA 80, as detailed in the Code Compliance Review - NFPA 80, Standard for Fire Doors and Windows, 1968 ed.," Rev 1, dated 11/7/11 and "Code Compliance Review - NFPA 80, Standard for Fire Doors and Windows, 1986 ed.," dated 11/7/12) Per Section 3.2.5 of Letter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80, "the licensee proposed to install fire dampers in all ventilation ducts which are unprotected and could endanger areas containing safe shutdown equipment in the event of a fire. Further, the licensee committed to provide three hour fire dampers in those ducts communicating with the Turbine Building. The licensee has shown to our satisfaction that all ventilation ducts which could endanger areas containing safe shutdown equipment will be protected with fire dampers. Based on our review, we find the licensee©s commitment to provide fire dampers in ventilation ducts in all fire zones containing equipment necessary for safe shutdown."Fire dampers have been reviewed against the requirements of NFPA 90A, as detailed in the Code Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, 1969 ed., dated 9/12/07 and "Code Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, 1978 ed.," dated 9/12/07.3) Fire rated door assembly requirements are addressed in Section 8.2.3.2.1 of NFPA 101 which refers to NFPA 80, and is Requirement/GuidancePenetrations in fire barriers shall be provided with listed fire-rated door assemblies or listed rated fire dampers having a fire resistance rating consistent with the designated fire resistance rating of the barrier as determined by the performance requirements established by Chapter 4. (See 3.11.3.4 for penetration seals for through penetration fire stops.) Passive fire protection devices such as doors and dampers shall conform with the following NFPA standards, as applicable:(1) NFPA 80, Standard for Fire Doors and Fire Windows(2) NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems (3) NFPA 101, Life Safety CodeException: Where fire area boundaries are not wall-to-wall, floor-to-ceiling boundaries with all penetrations sealed to the fire rating required of the boundaries, a performance-based analysis shall be required to assess the Subsection TitleFire Barrier PenetrationsNFPA 805 Section #3.11.3Page A-179PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1evaluated in the Code Compliance Review - NFPA 80, Standard for Fire Doors and Windows, 1968 ed., Rev 1, dated 11/7/11 and "Code Compliance Review - NFPA 80, Standard for Fire Doors and Windows, 1986 ed.," dated 11/7/11. Rated fire dampers requirements are addressed in Section 9.2.1 of NFPA 101 which refers to NFPA 90A, and is evaluated in theCode Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, 1969 ed., dated 9/12/07 and "Code Compliance Review - NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, 1978 ed.," dated 9/12/07Plant DocumentationLetter from Schwencer (NRC) to Mayer (NSP) dated 4/21/80; Fire Protection Engineering Evaluation FPEE-12-003, CA-01311055-01, Fire Door Frames, Revision 0, 4/5/2012; Fire Protection Engineering Evaluation, FPEE-CA124448-02, Revision 0, 1/20/2012; Code Compliance Review NFPA 80-1968, FPEE-11-049, "Code Compliance Review - NFPA 80, 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 Windows, 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 4/11/2012Industry-Related ReferencesNFPA 80, "Standard for Fire Doors and Fire Windows," 1968 and 1986 EditionsNFPA 90A, "Installation of Air Conditioning and Ventilating Systems," 1969 and 1978 EditionsNFPA 101, "Life Safety Code," 2000 EditionExisting Engineering Equivalency Evaluations (EEEEs)CE0112159401FPEE 0113625201CA 0124445802CA 0131104601CA 0131105701FPEE 0124191701FPEE 10-006AR 117907003Identifier:adequacy of fire barrier forming the fire boundary to determine if the barrier will withstand the fire effects of the hazards in the area. Openings in fire barriers shall be permitted to be protected by other means as acceptable to the AHJ.EEEE DescriptionEngineering evaluations can be found in the SharePoint Portal.SummarySee individual evaluationPage A-180PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1FPEE 11001FPEE 11019FPEE 11021FPEE 11022FPEE 11049FPEE 12002 CA 013274301 FPEE 12003CA 0131105501FPEE 12004CA 0131380801Items for ImplementationNonePage A-181PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies via Previous ApprovalCompliance BasisPer Section 2.4 of Procedure F5 Appendix F, "Fire Hazard Analysis," "All (cable) penetration seals passed the criteria of no flame passage, temperature, and hose stream test of IEEE 634. Fire stops are not provided at intermediate points in vertical or horizontal cable spans. Penetrations are sealed with packed thermal fiber or foam and covered with thermal board and approximately 1/8 in. coat of thermal mastic. Where the penetration is through a structure forming the boundary between ventilation zones, fire dampers have been installed except where determined unnecessary by evaluation. Conduit penetrations through walls, floors, and ceilings of the relay/cable spreading rooms are provided with fire stops."Per Section 2.5, "Most piping penetrations in walls and floors, in safety-related areas of the plant, are sealed. In those instances where seals are not provided, evaluations exist to justify conditions. The small area surrounding pipe is sealed with a qualified penetration seal, designed for the maximum fire severity on either side of the barrier, and to allow for thermal movement. In all cases, when new penetrations are sealed, the sealing material is noncombustible, or, as in the case of silicone foam, has been reviewed and found acceptable by the NRC."Per Enclosure 1 to Letter from Clark (NRC) to Mayer (NSP) dated 12/29/80, "The test slab containing the penetrations was placed on a horizontal furnace and exposed to the ASTM E119 time/temperature curve for 3-hours. The ASTM E119 time/temperature curve is the standard time/temperature curve used for fire endurance tests. After three hours the test slab was lifted in a horizontal position and subjected to a hose stream test. The hose stream test was performed in accordance with the recommendations of IEEE 634-1978, "Standard Cable Fire Stop Qualification Test," which is an acceptable method. The Requirement/GuidanceThrough penetration fire stops for penetrations such as pipes, conduits, bus ducts, cables, wires, pneumatic tubes and ducts, and similar building service equipment that pass through fire barriers shall be protected as follows.(a) The annular space between the penetrating item and the through opening in the fire barrier shall be filled with a qualified fire-resistive penetration seal assembly capable of maintaining the fire resistance of the fire barrier. The assembly shall be qualified by tests in accordance with a fire test protocol acceptable to the AHJ or be protected by a listed fire-rated device for the specified fire-resistive period.(b) Conduits shall be provided with an internal fire seal that has an equivalent fire-resistive rating to that of the fire barrier through opening fire stop and shall be permitted to be installed on either side of the barrier in a location that is as close to the barrier as possible.Subsection TitleThrough Penetration Fire StopsNFPA 805 Section #3.11.4Page A-182PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1acceptance criteria for the fire stops was based on the acceptance criteria in IEEE 634-1978. We find the acceptance criteria for the test provide reasonable assurance that the penetration seals will be capable of preventing a fire from spreading from one fire area to another. All of the tested penetration seals qualified as three-hour seals. "Based on our review and the test data, we find that the penetration seals are qualified as 3-hour fire rated seals. Therefore, we conclude that the licensee©s proposed modification regarding upgraded penetration firestops is acceptable."Procedure D52, "Installation Guidelines for the Permanent & Temporary Sealing of Electrical/Mechanical Openings between Established Fire Areas," provides guidelines and procedures for the installation of penetration seals, including material requirements. Section 1.0 states, "The purpose of this installation guideline is to establish the controls & instructions necessary for new, existing and/or temporary electrical/mechanical openings that will be constructed or have been breached during construction/maintenance work. These guidelines are designed to meet the conditions set forth by Operations Manual F5 Appendix K (fire penetrations), T.S.3.7.12 for Aux Building Special Vent Zone and H27 for Steam Exclusion."Per Section 7.16.C of Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Piping and electrical penetrations are provided with qualified seals where they penetrate boundaries between fire areas. Seals are qualified for the maximum fire severity present on either side of the barrier. Seals are installed in the annulus with a qualified penetration seal designed to allow for thermal movement.Operations Manual Section D52, "Installation Guidelines for the Permanent and Temporary Sealing of Electrical/Mechanical Openings Between Established Fire Areas", provides the Plant DocumentationLetter from Clark (NRC) to Mayer (NSP) dated 12/29/80Engineering Manual 2.1.14, "Engineering Design, Fabrication, and Installation Summary for Fire Barriers and Penetration Seals," Rev. 1, dated 1/26/00Procedure D52, "Installation Guidelines for the Permanent & Temporary Sealing of Electrical/Mechanical Openings between Established Fire Areas," Rev. 13, dated 1/27/09 Procedure F5 Appendix F, "Fire Hazard Analysis," Rev. 25A, dated 8/8/11Procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Rev. 15, dated 4/11/2012Industry-Related ReferencesNoneExisting Engineering Equivalency Evaluations (EEEEs)NoneIdentifier:Exception: Openings inside conduit 4 in. (10.2 cm) or less in diameter shall be sealed at the fire barrier with a fire-rated internal seal unless the conduit extends greater than 5 ft (1.5 m) on each side of the fire barrier. In this case the conduit opening shall be provided with noncombustible material to prevent the passage of smoke and hot gases. The fill depth of the material packed to a depth of 2 in. (5.1 cm) shall constitute an acceptable smoke and hot gas seal in this application.EEEE DescriptionSummaryPage A-183PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1overall 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 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."Items for ImplementationNonePage A-184PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Compliance StatementComplies with use of Existing Engineering Equivalency EvaluationCompliance BasisElectrical raceway fire barrier systems are installed at PINGP. Per Section 2.1 of Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," "Except as provided for in paragraph G.3 of this section, where cables or equipment, 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 and maintain Hot Shutdown conditions are located within the same fire area outside of primary containment, one (1) of the following means of ensuring that one (1) of the redundant trains is free of fire damage shall be provided: A. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier; B. 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 combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or C. Enclosure of cable and equipment and associated non-safety circuits of one (1) redundant train in a fire barrier having a one (1) hour rating. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area;"Per Section 2.6, "the SBO/ESU Project established and enhanced basic routing paths for trained cables. Certain fire areas were designated as basic Train A (or B) routes or areas, meaning that normally Train A (or B) cables would be routed through the area. Thus, in a Train A area, it is expected that Train A systems and components would be affected by a fire and that Train B would Requirement/GuidanceERFBS required by Chapter 4 shall be capable of resisting the fire effects of the hazards in the area. ERFBS shall be tested in accordance with and shall meet the acceptance criteria of NRC Generic Letter 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria for Fire Barrier Systems Used to Separate Safe Shutdown Trains Within the Same Fire Area." The ERFBS needs to adequately address the design requirements and limitations of supports and intervening items and their impact on the fire barrier system rating. The fire barrier system's ability to maintain the required nuclear safety circuits free of fire damage for a specific thermal exposure, barrier design, raceway size and type, cable size, fill, and type shall be demonstrated.Exception No. 1: When the temperatures inside the fire barrier system exceed the maximum temperature allowed by the acceptance criteria of Generic Letter 86-10, "Fire Endurance Subsection TitleElectrical Raceway Fire Barrier System (ERFBS)NFPA 805 Section #3.11.5Page A-185PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1be relied on for safe shutdown. This methodology allows protecting (wrapping) the least affected train in each area. (The previous analyses essentially provided for Train A operation in the event of a control room fire and ensuring that Train B would be available for other fires.) For the most part, Train B would be protected and credited in Train A areas and Train A would be protected and credited in Train B areas."Per Section 2.7.2, "All cables and components, identified in the circuit analyses as being required for operation, are included in the Safe Shutdown data base along with the cable route and component location. Once all cables and components were entered, reports were generated that summarize required information needed for the overall analysis. A compliance assessment summary, and a compliance assessment report is included for every fire area that contains required safe shutdown cables."Engineering Manual 4.3.1-E, "Engineering Design, Fabrication and Installation Summary for Fire Barriers," provides detailed specifications and installation instructions for electrical raceway fire barrier systems in accordance with NRC GL 86-10 Supplement 1.FPEE-2005-001 Qualification of PCI PROMATEC INTERAM" Flexible Fire Protective System, evaluation performed a detailed comparison and analysis of the fire wrap design configurations to fire-tested configurations and concluded that the system applied to 1CB-31 is considered qualified for a fire endurance rating of 1-hour in accordance with USNRC GL 86-10 Supplement 1.Acceptance Test Criteria for Fire Barrier Systems Used to Separate Redundant Safe Shutdown Training Within the Same Fire Area," Supplement 1, functionality of the cable at these elevated temperatures shall be demonstrated. Qualification demonstration of these cables shall be performed in accordance with the electrical testing requirements of Generic Letter 86-10, Supplement 1, Attachment 1, "Attachment Methods for Demonstrating Functionality of Cables Protected by Raceway Fire Barrier Systems During and After Fire Endurance Test Exposure."Exception No. 2: ERFBS systems employed prior to the issuance of Generic Letter 86-10, Supplement 1, are acceptable providing that the system successfully met the limiting end point temperature requirements as specified by the AHJ at the time of acceptance.Page A-186PINGP Northern States Power - MinnesotaAttachment A - NEI 04-02 Table B-1Plant DocumentationEngineering Manual EM 4.3.1-E, "Engineering Design, Fabrication and Installation Summary for Fire Barriers," Rev. 2, dated 4/19/01Procedure F5 Appendix E, "Fire Protection Safe Shutdown Analysis Summary," Rev. 14, dated 4/29/10FPEE-2005-001 Qualification of PCI PROMATEC INTERAM" Flexible Fire Protective SystemIndustry-Related ReferencesUSNRC IN-95-52, Supplement Fire Endurance Test Results for Electrical Raceway Fire Barrier Systems Constructed from 3M Company Interam Fire Barrier Materials.Existing Engineering Equivalency Evaluations (EEEEs)FPEE-2005-001 Qualification of PCI PROMATEC INTERAM" Flexible Fire Protective SystemItems for ImplementationNoneIdentifier:EEEE DescriptionThis Fire Protection Engineering Evaluation (FPEE) is written to demonstrate the acceptability of the fire protected conduit 1CB-31. This protection has been achieved with the 3M Interam Flexible Fire Wrap System as necessary to achieve the required fire rating of one-hour.SummaryThe evaluation performed a detailed comparison and analysis of the fire wrap design configurations to fire-tested configurations and concluded that the system applied to 1CB-31 is considered qualified for a fire endurance rating of 1-hour in accordance with USNRC GL 86-10 Supplement 1.Page A-187PINGP Northern States Power - Minnesota Attachment B - NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review PINGP Page B-1 B. NEI 04-02 Table B Nuclear Safety Capability Assessment Methodology Review 97 Pages Attached

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".

Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDeterministic MethodologyNEI 00-01 Section 3.0 GuidanceThis 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 plant's 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP utilized a deterministic methodology to assess conformance of the PINGP SSA with the Nuclear Safety Capability Assessment (NSCA), as described in NFPA 805, Section 1.5.1. This assessment evaluated the current program for readiness to transition, identified gaps and gap closure actions, and culminated in the PINGP's safe and stable position with respect to the deterministic guidance given in Chapter 3 of NEI 00-01, Revision 1, "Deterministic Methodology".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".The comparison concluded that the PINGP NSCA falls within the following two categories when compared with NEI 00-01 Revision 1:1. Aligns or Aligns with Intenta. May include open items that are not required to be closed to ensure Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology. Additional references are identified within each subsection of this document. NFPA 805 Section 2.4.2 and NEI 00-01, Revision 1, Chapter 3 are the general references for all sections.Alignment Basis3.0A 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 mal-operation of those components needed to meet the nuclear safety criteria shall be included. Availability and reliability of equipment selected shall be evaluated.2.4.2.1 Nuclear Safety Capability Systems and Equipment Selection (Taken From NFPA 805, 2001 Edition)Page B-2PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 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 plant configurations.Page B-3PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefSafe Shutdown Systems and Path DevelopmentNEI 00-01 Section 3.0 GuidanceThis section discusses the identification of systems available and necessary to perform the required safe shutdown 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 addressed3.1Page B-4PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 ApplicabilityApplicableCommentsAlignment StatementAligns with IntentSystems, functions, equipment, cables and logics required to maintain fuel in a safe and stable condition have been identified and are included in the PINGP model, Genesis and PRISM databases.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 Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology FPRA-PI-PRM, "Fire Induced Risk Model" PRISM Database Safe Genesis DatabaseEC 19988NEI 00-01, Revision 1 NFPA 805 Section 1.3.1, Section 1.5.1, and Section 1.6.56 Appendix C of NEI 00-01, Revision 1 NEI 00-01 Revision 1 NEI 00-01 Revision 2 (Loss of DC control power consideration only) FAQ 06-0006P2117-2400-01-00P2117-2400-03-00 Generic Letter 86-10 Attachment S Table S-2 Attachment S Table S-3 Technical SpecificationsAlignment BasisPage B-5PINGP Northern States Power - MinnesotaAttachment 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) have an on-site fuel oil supply that will last for 14 days, assuming one EDG on each unit, or 7 days if both EDGs are operating for each unit. The diesel driven cooling water pumps (DDCLPs) have a separate fuel oil supply that will last for 14 days for one operating pump, or 7 days if two pumps are operating. Offsite sources of fuel oil are available to replenish fuel oil levels if needed via established contracts. 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) PRISM 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 Genesis and PRISM databases are 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).High/low pressure interfaces have been considered and precluded from spurious operation of the pathway viaplant 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 Page B-6PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 valves in each path.NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.1Page B-7PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 Guidance[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.ApplicabilityNot ApplicableCommentsAlignment StatementNot ApplicableNot Applicable to PINGP - BWR Specific.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.1.1Page B-8PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 Guidance[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.ApplicabilityNot ApplicableCommentsAlignment StatementNot RequiredNot Applicable to PINGP - BWR Specific.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.1.2Page B-9PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 Guidance[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.ApplicabilityApplicableCommentsAlignment StatementAlignsSafe and stable is defined as Mode 3 Hot Standby for PINGP.Pressurizer heaters are not credited for increasing RCS pressure, but can be utilized if the circuits are not affected in a particular fire area. Pressurizer heaters are primarily evaluated for spurious operation concerns. If a pressurizer heater is not available, RCS pressure can be increased by utilizing a water solid pressurizer and controlling RCS makeup and letdown flow." This section of GEN-PI-052 has been revised by revision 3D to state that Pressurizer heaters are credited in areas where SI is credited for RCS inventory control.Spurious operation of the pressurizer heaters is addressed in calculation P2117-2400-02-00 which states: "[D]e-energizing the heaters will be necessary in order to achieve a safe and stable condition in the RCS-[T]he timing of de-energizing the heaters is not critical."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 Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database NFPA 805 Section 1.5.1 NEI 00-01 Revision 1 P2117-2400-02-00 P2117-2400-06-00FPRA-PI-ES, "Equipment Selection Handbook"Alignment Basis3.1.1.3Page B-10PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 required when SI is credited for RCS makeup has not been completed. P2117-2400-06-00 provides the necessary thermal-hydraulic analysis supporting the conclusion that pressurizer heaters are not required when safety injection (SI) is the credited makeup source for the RCS.Page B-11PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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.ApplicabilityApplicableCommentsAlignment StatementNot in Alignment [but Prior NRC Approval]NFPA-805 does not have an analogous definition or methodology for the 10 CFR 50 Appendix R term: "alternative / dedicated shutdown".Fire areas 13 and 18 (Control Room and Relay Room) were defined as "Alternative / Dedicated Shutdown" areas under 10CFR50 Appendix R. In these areas, for safe and stable, PINGP credits the use of a hot shutdown (HSD) panel as the primary control station for fires that require control room abandonment. The following applies:* The hot shutdown panel provides a minimum subset of required equipment and assured isolation from the effects of the fire. Hot shutdown panel credited is PNL-51000.* Actions taken to enable the HSD panel are detailed in Attachment G. Modifications to the HSD panels are defined in Attachment S.* Upon abandoning the control room, the action to close the PORV block valves and subsequently open disconnect switches to de-energize the PORV control valves, is being credited as a previously approved action and is detailed in Attachment K and T to the LAR.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.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database Attachment K Attachment T Attachment SFPRA-PI-FASD, "Fire Alternative Shutdown Analysis Notebook"Alignment Basis3.1.1.4Page B-12PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAt the onset of the postulated fire, all safe shutdown systems (including applicable redundant trains) are assumed 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.ApplicabilityApplicableCommentsAlignment StatementAlignsThe PINGP NFPA-805 safe and stable analysis assumes the availability / operability of credited systems at the onset of the fire. This assurance is provided by including appropriate systems / components in the PINGP monitoring program as defined in LAR Section 4.6.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyLAR Section 4.6 NFPA 805 Section 2.6Alignment Basis3.1.1.5Page B-13PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceNo 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.ApplicabilityApplicableCommentsAlignment StatementAlignsNo accidents or other design basis events, including single failures and non-fire induced transients, are considered in conjunction with the fire.Reference Table B-1 Section 3.6.4 for how PINGP aligns with the earthquake provisions of NFPA 805.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Table B-1 Section 3.6.4Alignment Basis3.1.1.6Page B-14PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceFor 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.ApplicabilityApplicableCommentsAlignment StatementAlignsCredit will not be taken for off-site power in a specific fire area unless an analysis is performed to demonstrate the availability of off-site power following the worst-case postulated fire in the area in which all unprotected cables in the area are assumed damaged. The loss of off-site power may not be credited such that the affected component can be assumed to fail to its desired SSD position.Distribution components and cables of the credited plant AC and DC systems are modeled in the Genesis and PRISM databases in a cascading fashion. Within PRISM and Genesis, the distribution equipment, source cables and credited load equipment are combined to form a complete cascading success path from all potential sources to load. All sources are analyzed for availability within Genesis, and PRISM 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, are analyzed.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database NFPA 805 Appendix B, Section B.2.2 NEI 04-02, Section 2.2.3 FPRA-PI-ES, "Equipment Selection Handbook"Alignment Basis3.1.1.7Page B-15PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidancePost-fire safe shutdown systems and components are not required to be safety-related.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP credits both safety-related and non-safety related equipment to achieve safe and stable conditions.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.1.8Page B-16PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentNFPA 805 Nuclear Safety Performance Criteria (NSPC) requires the licensee to demonstrate that the plant can achieve and maintain a "safe and stable" condition, but it has no explicit requirement to demonstrate that cold shutdown can be achieved within 72 hours.Achieving cold shutdown in 72 hours is a requirement of 10CFR50 Appendix R which has been proven to be achievable by PINGP under that licensing basis. The actions required to accomplish this under 10CFR50 Appendix R were proven to be feasible and reliable by calculation GEN-PI-055, "10CFR50 Appendix R Manual Action Feasibility Study ". Because these actions are not required to maintain safe and stable conditions under NFPA 805, they are not included in the Variances from Deterministic Requirements (VFDR).Reference Section 3.1 above for PINGP's definition of Safe and Stable.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologySection 3.1 of this document. PRISM Database Genesis Database NFPA 805 Section 1.3.1, Section 1.5.1, and Section 1.6.56Alignment Basis3.1.1.9Page B-17PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceManual 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentAutomatic functions (e.g., load sequencer), when credited, have been analyzed within the Genesis and PRISM databases for availability. EC 19988 analyzed applicable plant automatic functions for the adverse effects of spurious operation (e.g., spurious safety injection, spurious containment spray, etc.).Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyEC 19988, "NFPA 805 LAR Attachment B - RIS 04-003 (Updated) Analysis" PRISM Database Genesis Database FPRA-PI-ES, "Equipment Selection Notebook"Alignment Basis3.1.1.10Page B-18PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceWhere 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentThe PINGP PRISM and Genesis models evaluate the effects on both PINGP units, of a single fire occurring in a single fire area, for all analyzed areas in the plant. This methodology assures that fuel in both units is maintained in a safe and stable condition.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM DatabaseNFPA 805 Appendix D, D.3.4Alignment Basis3.1.1.11Page B-19PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefShutdown FunctionsNEI 00-01 Section 3.0 GuidanceThe 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-T43-00002-00-01-R01 entitled "Original Safe Shutdown Paths for the BWR."ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.2Page B-20PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefReactivity ControlNEI 00-01 Section 3.0 Guidance[BWR] Control Rod Drive SystemThe 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/ChargingThere must be a method for ensuring that adequate shutdown margin is maintained by ensuring borated water is utilized for RCS makeup/charging.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentLong-term reactivity control is accomplished by adding borated water from the refueling Water Storage Tank (RWST) to ensure reactivity margin throughout safe and stable.RWST is supplied to the RCS through either the Chemical and Volume Control System (CVCS) or the Safety Injection System (SI).Calculation P2117-2400-01-00 provides the required justification for long-term reactivity control under safe and stable conditions. This calculation also identifies that operator action is required to terminate a boron dilution MSO within 24 minutes should it occur (reference section 3.1 above for additional details regarding RWST supply for safe and stable). PINGP analysis 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.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM DatabaseGenesis DatabaseP2117-2400-01-00 Section 3.1 of this documentAlignment Basis3.1.2.1Page B-21PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefPressure Control SystemsNEI 00-01 Section 3.0 Guidance[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/ChargingRCS 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.ApplicabilityApplicableCommentsAlignment StatementAlignsRCS Pressure Control is necessary to prevent exceeding RCS design pressure-temperature limits and to minimize void formation in the reactor. RCS pressure control is also necessary to control high/low pressure interfaces and to prevent rupture of any primary coolant boundary. Some key goals of pressure control are:

• 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 operatingOver-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 Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology P2117-2400-02-00 Section 3.1.1.3 of this document.

PRISM Database Genesis DatabaseAlignment Basis3.1.2.2Page B-22PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 depressurize the RCS; however, these flow paths are not credited for safe 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 PRISM and Genesis databases and in thermal hydraulic calculation P2117-2400-02-00. Reference Section 3.1.1.3 above, for additional details regarding pressurizer heaters and the use of safety injection as the makeup source.Page B-23PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefInventory ControlNEI 00-01 Section 3.0 Guidance[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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentTo ensure fuel is maintained in a safe and stable condition, RCS makeup is required for maintenance of RCS integrity (isolating flow diversion paths and maintaining the pressurizer level within the indicating range), and to compensate for RCS inventory losses due to seal leakoff and shrinkage during cooldown. RCS makeup is provided by the Chemical and Volume Control System (CVCS) or the Safety Injection System (SI). Typically, the 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 PRISM and Genesis databases include 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 Table S-2 for seal modification).
• Operation of the charging system or SI system.* Maintenance of 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.Inventory control to maintain safe and stable conditions is demonstrated by P2117-2400-02-00, "Inventory and Pressure Control Calculations for NFPA 805 Safe Shutdown Analysis"Reference DocumentsEC-19775, NFPA 805 LAR Attachment B -

Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database P2117-2400-02-00 Attachment S Table S-2Section 3.1 of this documentAlignment Basis3.1.2.3Page B-24PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDecay Heat RemovalNEI 00-01 Section 3.0 Guidance[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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentFollowing a reactor trip, decay heat is removed via the steam generators by natural or forced circulation within the reactor coolant loops. Feedwater is supplied to the steam generators by the Auxiliary Feedwater (AFW) System. At a minimum, one AFW pump and one steam generator is required for removal of decay heat from the RCS.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).Adequacy of decay heat removal for safe and stable conditions is Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database NFPA 805 Section 1.3.1, Section 1.5.1, and Section 1.6.56 P2117-2400-03-00 Section 3.1 of this documentAlignment Basis3.1.2.4Page B-25PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 demonstrated by P2117-2400-03-00, "Prairie Island Nuclear Generating Plant - Decay Heat Removal Calculations for NFPA 805 Safe Shutdown Analysis"Page B-26PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefProcess MonitoringNEI 00-01 Section 3.0 GuidanceThe 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 systemsThe 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP has modeled the required process monitoring functions in the Genesis and PRISM databases.The performance of the primary system (RCS) is monitored by RCS pressure, pressurizer level, and RCS Hot Leg and Cold Leg Temperatures. The secondary system (AFW) is monitored by the SG level indicators. 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).Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database FPRA-PI-ESAlignment Basis3.1.2.5Page B-27PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 Additional tank level monitoring is provided by local mechanical level 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 TankDiagnostic 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.Page B-28PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefElectrical SystemsNEI 00-01 Section 3.0 GuidanceAC Distribution SystemPower for the Appendix R safe shutdown equipment is typically provided by a medium voltage system such as 4.16 KV Class 1E busses either directly from the busses 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).ApplicabilityApplicableCommentsAlignment StatementAlignsDistribution components of the credited plant AC and DC systems are modeled in the Genesis and PRISM Databases in a cascading fashion. Within PRISM and Genesis, individual source cables and equipment are combined to form a complete cascading success path from source to load. Additionally, PRISM provides the means to analyze a loss of DC control power to the credited AC buses.Upon loss of AC power to the battery chargers, the batteries are credited Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis DatabasePRISM Database Battery Calculations: ENG-EE-001 ENG-EE-002Alignment Basis3.1.2.6.1Page B-29PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 to supply power to interim loads, including diesel generator startup loads, until an AC source is re-established to the credited chargers.ENG-EE-003 ENG-EE-004 FPRA-PI-ESNEI 00-01 RefCooling SystemsNEI 00-01 Section 3.0 GuidanceVarious 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 manufacturer's 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 roomsPlant-specific evaluations are necessary to determine which HVAC systems are essential to safe shutdown equipment operation.ApplicabilityApplicableCommentsAlignment StatementAlignsNecessary room cooling and HVAC systems for PINGP have been identified and are included in the model. Component Cooling, seal injection, seal barrier cooling, cooling to heat exchangers as well as HVAC cooling of components have been considered for safe and stable.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database PRA-PI-SY-SVCS-0.1, "PRA Safeguards Ventilation and Control System Notebook"Alignment Basis3.1.2.6.2Page B-30PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefMethodology for Shutdown System SelectionNEI 00-01 Section 3.0 GuidanceRefer to NEI-00-01 Rev 1 Figure 3-2 for a flowchart illustrating the various steps involved in selecting safe shutdown 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:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.1.3Page B-31PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Safe Shutdown FunctionsNEI 00-01 Section 3.0 GuidanceReview 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"ApplicabilityApplicableCommentsAlignment StatementAlignsConsistent with the guidance of this section of NEI 00-01, Revision 1, the following input documents were utilized in the development of the PINGP safe and stable model:* Updated Safety Analysis Report* Fire Hazards Analysis

• 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 Database
• PRISM DatabaseReference DocumentsEC-19775, NFPA 805 LAR Attachment B -

Table B-2, Nuclear Safety Capability Methodology FPRA-PI-ESAlignment Basis3.1.3.1Page B-32PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Combinations of Systems That Satisfy Each Safe Shutdown FunctionNEI 00-01 Section 3.0 GuidanceGiven the criteria/assumptions defined in Section 3.1.1, identify the available combinations of systems capable of achieving the safe shutdown functions of reactivity control, pressure control, inventory control, decay heat removal, 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP utilized the methodology of NEI 00-01 Revision 1, Section 3.1.1 and Section 3.1.2, coupled with procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" to establish the systems, components, cables and functions to satisfy the Nuclear Safety Performance Criteria NSPC as defined in NFPA 805 Section 1.5.1.The PRISM and Genesis databases are used to analyze the post-fire impact of spurious operations and power supply issues that can affect the safe and stable conditions of the plant. Additionally, the PRISM database presents the combination of systems and paths in a logic diagram fashion.EPM-DP-EP-004 has been added to Attachment S Table S-3 to update the procedure and enter it into the NSPM document control system.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" PRISM Database Genesis Database NFPA 805 Section 1.5.1 Attachment S Table S-3FPRA-PI-ESSection 3.1 of this documentAlignment Basis3.1.3.2Page B-33PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDefine Combination of Systems for Each Safe Shutdown PathNEI 00-01 Section 3.0 GuidanceSelect combinations of systems with the capability of performing all of the required safe shutdown functions and designate 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP utilizes both the Genesis and PRISM databases to maintain the logical relationships between the components and paths that make up the required NSPC function. Additionally, supporting systems were identified and included in the logical relationship when required. Power supplies are modeled in a cascading fashion such that a loss of an upstream supply will affect all downstream supplies and credited equipment serviced by those supplies.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis Database PRISM Database FPRA-PI-ESAlignment Basis3.1.3.3Page B-34PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefAssign Shutdown Paths to Each Combination of SystemsNEI 00-01 Section 3.0 GuidanceAssign a path designation to each combination of systems. The path will serve to document the 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentThe Genesis database assigns numbers to the various paths of system combinations. Although the PRISM database does not utilize path numbers, the logic diagrams that are displayed in PRISM meet the intent of a safe and stable path for each combination.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyPRISM DatabaseGenesis DatabaseAlignment Basis3.1.3.4Page B-35PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefSafe Shutdown Equipment SelectionNEI 00-01 Section 3.0 GuidanceThe previous section described the methodology for selecting the systems and paths necessary to achieve and maintain 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.2Page B-36PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceConsider the following criteria and assumptions when identifying equipment necessary to perform the required safe shutdown functions:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.2.1Page B-37PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceSafe 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP did not differentiate between primary and secondary components within the Genesis and PRISM models but nevertheless, all analysis performed in support of added equipment for NFPA 805 included the secondary components, or at a minimum, the function of the secondary components within the model. 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.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database FPRA-PI-ES Circuit Analysis for SV-33193 and SV-33194Alignment Basis3.2.1.1Page B-38PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP assumes no fire-induced damage to manual valves or piping. NSPM discovered that two rising stem valves: VC 1 and 2VC 1 are required to be manually operated (recovery action) after the valves have potentially been exposed to the fire. The post-fire operation of these valves will be evaluated for feasibility as described in Attachment S Table S-3.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyNEI 00-01, Revision 2 - As referenced by LAR Template 1L Attachment S Table S-3 FPRA-PI-ESAlignment Basis3.2.1.2Page B-39PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume that manual valves are in their normal position as shown on P&IDs or in the plant operating procedures.ApplicabilityApplicableCommentsAlignment StatementAlignsFor safe and stable, manual valves are assumed to be in their normal operating positions per their respective plant documentation.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM DatabasePlant P&IDs and other plant supporting documents FPRA-PI-ES FPRA-PI-CSAlignment Basis3.2.1.3Page B-40PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP assumes check valves are installed properly in that they will prevent reversal of flow. PINGP also assumes that the check valve's integrity is such that they will not produce a leak rate that is other than inconsequential.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis Database PRISM Database FPRA-PI-ESAlignment Basis3.2.1.4Page B-41PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceInstruments (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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP assumes that instrumentation circuits fail in their worst-case positions when damaged by the fire. Circuit analysis of instrumentation circuits is performed per the guidance of PINGP procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" Genesis Database PRISM Database FPRA-PI-ESAlignment Basis3.2.1.5Page B-42PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceIdentify 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.ApplicabilityApplicableCommentsAlignment StatementAlignsSpurious operation was considered in the selection of components as well as cable selection via procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis DatabaseEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" EC 19988 PRISM Database FPRA-PI-ESAlignment Basis3.2.1.6Page B-43PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceIdentify 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.ApplicabilityApplicableCommentsAlignment StatementAlignsAn instrument tubing analysis has been performed under AR 01121820. The analysis identified the subset of required process monitoring instrumentation that utilizes sensor tubing, and compared the routing of the tubing to the fire areas where the instrument was credited. The analysis did not identify any impacts to the credited process instrumentation.An update to AR 01121820 is required to address the possible effects of fire-exposed tubing in secondary circuits affecting primary circuit operation. This has been added to Attachment S Table S-3 to ensure alignment with this section of NEI 00-01, Revision 1 for safe and stable.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAR 01121820Attachment S Table S-3Alignment Basis3.2.1.7Page B-44PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefMethodology for Equipment SelectionNEI 00-01 Section 3.0 GuidanceRefer to NEI-00-01 Rev 1 Figure 3-3 for a flowchart illustrating the various steps involved in selecting safe shutdown equipment.Use the following methodology to select the safe shutdown equipment for a post-fire safe shutdown analysis:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.2.2Page B-45PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify the System Flow Path for Each Shutdown PathNEI 00-01 Section 3.0 GuidanceMark up and annotate a P&ID to highlight the specific flow paths for each system in support of each shutdown path. Refer to Attachment 2 for an example of an annotated P&ID illustrating this concept.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP utilized marked-up P&IDs identify both required flow paths as well as diversion flow paths. This information was used as a basis for the safe and stable logic diagrams and equipment listings that are contained in the PRISM and Genesis databases. The marked up P&IDs are not required to be retained as the logic diagrams within the PRISM database are sufficient to show flowpaths with credited components.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM Database2117-3104-001 "Multiple Spurious Operations Review" FPRA-PI-ESAlignment Basis3.2.2.1Page B-46PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify the Equipment in Each Safe Shutdown System Flow Path Including Equipment That May Spuriously Operate and Affect System OperationNEI 00-01 Section 3.0 GuidanceReview the applicable documentation (e.g. P&IDs, electrical drawings, instrument loop diagrams) to assure that all equipment in each system's flow path has been identified. Assure that any equipment that could spuriously operate and adversely affect the desired system function(s) is also identified. If additional systems are identified which are necessary for the operation of the safe shutdown system under review, include these as systems required for safe shutdown. Designate these new systems with the same safe shutdown path as the primary safe shutdown system under review (Refer to Figure 3-1).ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP utilized P&IDs, single line diagrams, loop diagrams, connection diagrams and procedures to identify equipment required to meet NSPC. Spurious operation of equipment that could affect the NSPC was considered in the selection process.A modification (as described in Attachment S Table S-2), is required to preclude spurious operation of the containment spray signal in Fire Area 59 that could cause a drain down of the RWST.The safe and stable equipment listing and resulting logic diagrams are contained within the Genesis and PRISM databases.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database EC 19988 Attachment S Table S-2 FPRA-PI-ESAlignment Basis3.2.2.2Page B-47PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDevelop a List of Safe Shutdown Equipment and Assign the corresponding System and Safe Shutdown Path(s) Designation to EachNEI 00-01 Section 3.0 GuidancePrepare a table listing the equipment identified for each system and the shutdown path that it supports. Identify any valves or other equipment that could spuriously operate and impact the operation of that safe shutdown system.Assign the safe shutdown path for the affected system to this equipment. During the cable selection phase, identify 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.ApplicabilityApplicableCommentsAlignment StatementAlignsThe Genesis and PRISM databases contain the listing of the components that were identified as being required to meet the NSPC. In addition to the equipment listing, shutdown paths are displayed logically within the databases. Electrical distribution equipment is logically arranged in a cascading manner such that a failure of an upstream component will cascade down to show a loss of the downstream components. Other supporting equipment is logically tied to the component(s) which it supports.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database FPRA-PI-ESAlignment Basis3.2.2.3Page B-48PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Equipment Information Required for the Safe Shutdown AnalysisNEI 00-01 Section 3.0 GuidanceCollect additional equipment-related information necessary for performing the post-fire safe shutdown analysis for the equipment. In order to facilitate the analysis, tabulate this data for each piece of equipment on the SSEL. Refer to 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP has identified and recorded similar data to that given in this guidance. PINGP maintains the NSCA equipment listing and analysis data within the Genesis and PRISM databases.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database FPRA-PI-ESAlignment Basis3.2.2.4Page B-49PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Dependencies Between Equipment, Supporting Equipment, Safe Shutdown Systems and Safe Shutdown PathsNEI 00-01 Section 3.0 GuidanceIn the process of defining equipment and cables for safe shutdown, identify additional supporting equipment such as electrical power and interlocked equipment. As an aid in assessing identified impacts to safe shutdown, consider modeling the dependency between equipment within each safe shutdown path either in a relational database or in the form of a Safe Shutdown Logic Diagram (SSLD). Attachment 4 provides an example of a SSLD that may be developed to document these relationships.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP utilizes both the Genesis and PRISM relational databases to provide logical relationships between equipment, cables, power supplies and supporting equipment, to the fire areas in which they are located. Both databases provide the necessary logical relationships to allow analysis of fire-induced failures on a fire-area-by-fire-area basis. The logical relationships provide for proper cascading of equipment losses from an upstream component to the downstream components.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database FPRA-PI-ESAlignment Basis3.2.2.5Page B-50PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefSafe Shutdown Cable Selection and LocationNEI 00-01 Section 3.0 GuidanceThis section provides industry guidance on the recommended methodology and criteria for selecting safe shutdown cables 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.32.4.2.2.1 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 mal-operation 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.2.4.2.2 Nuclear Safety Capability Circuit Analysis(Taken From NFPA 805, 2001 Edition)Page B-51PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceTo identify an impact to safe shutdown equipment based on cable routing, the equipment must have cables that affect it 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:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.3.1Page B-52PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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 postfire 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP utilized schematic and connection diagrams to identify all cables associated with the component being analyzed. The analysis included cables from both on-scheme and off-scheme categories when adequate circuit isolation could not be shown to exist.EC 19988 identified inadequately isolated cables whose fire-induced failures could cause a loss of DC control power to non-safeguards buses as well as damage that could cause adverse spurious operation of credited components. Modifications to correct these deficiencies were added to Attachment S Table S-2.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"FPRA-PI-CS EC 19988 Attachment S Table S-2Alignment Basis3.3.1.1Page B-53PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceIn 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.ApplicabilityApplicableCommentsAlignment StatementAlignsThe Genesis and PRISM databases maintain cable to equipment relationships with the ability to have a one-to-many relationship. Cables appearing in more than one component's schematic are captured by the circuit analysis methods as described in EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification".Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM DatabaseEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-ESAlignment Basis3.3.1.2Page B-54PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceElectrical 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentThe PINGP circuit analysis procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" clearly defines what isolation devices are acceptable to credit for the NFPA-805 safe and stable analysis.EC 19990, was performed to investigate the instrumentation isolation devices credited for the legacy circuit analysis (carried directly over to NFPA 805). EC 19990 determined that the isolation devices credited in the legacy circuit analysis were adequate to assure operation under fire conditions for safe and stable.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" Genesis Database PRISM Database EC 19990Alignment Basis3.3.1.3Page B-55PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceScreen 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 component's control scheme in such a way that a cable fault would not impact the performance of the circuit.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPer PINGP Post Fire Safe Shutdown Cable Identification Procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification", reason codes are used to identify cables that have no impact on the safe and stable function. Cables were only excluded when proper isolation existed.EC 19988 identified inadequately isolated cables whose fire-induced failures could cause a loss of DC control power to non-safeguards buses as well as damage that could cause adverse spurious operation of credited components. Modifications to correct these deficiencies were added to Attachment S Table S-2.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis Database PRISM Database EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" EC 19988 Attachment S Table S-2Alignment Basis3.3.1.4Page B-56PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceFor 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPower supply logics have been created within Genesis and PRISM to identify the cascading affects of a loss of upstream power supplies. Power supplies are cascaded from the offsite power sources and / or the emergency diesel generator. The effects of loss of DC control power (common power supply, common enclosure) have also been incorporated into the analysis for safeguards buses. For non-credited buses, modifications to correct discrepancies have been added to Attachment S Table S-2.FPRA-PI-CS states that required cables that were identified include circuits directly involved with power, control and operation of the component, including interlocks, permissives, and other associated circuits.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database EC 19988 Attachment S Table S-2FPRA-PI-CSAlignment Basis3.3.1.5Page B-57PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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.ApplicabilityApplicableCommentsAlignment StatementAlignsFor safe and stable, PINGP does not credit automatic functions unless circuit analysis supports the availability of the function, along with the required supporting equipment and power.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. Modifications (Attachment S) were identified for the deterministic areas to eliminate the VFDR.The findings of EC 19988 (with respect to spurious operation of automatic functions in legacy circuit analysis) were dispositioned via one VFDR and one modification (as defined in Attachment S Table S-2) for Fire Area 59. All other areas of concern for spurious operation of automatic functions were rectified via strategy changes (actions taken from the control room) for the deterministic analysis. Spurious operations of automatic functions within RI / PB areas are being addressed via those processes.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology LAR Attachment G Genesis Database PRISM Database EC 19988 FPRA-PI-ES FPAR-PI-CSAlignment Basis3.3.1.6Page B-58PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceCabling 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.ApplicabilityApplicableCommentsAlignment StatementAlignsLoss of DC control power to NFPA 805 credited plant busses is incorporated in the NFPA-805 model and the impact of secondary fires and loss of power supply have been considered (common power supply, common enclosure). Logics contained in both Genesis and PRISM databases detail the cascading effects of power supply losses when they occur as a result of fire-induced damage.The findings of EC 19988 (with respect to the loss of DC control power) resulted in the addition of modifications to Attachment S Table S-2 to prevent common enclosure (secondary fires) from occurring as a result of faults on the buses that are not credited power supplies for NFPA 805. EC 19989 identified that the PINGP coordination program has the proper controls in place to include the NFPA 805 engineer when electrical coordination changes are made that can affect the NFPA 805 analysis. However, EC 19989 also identified several NFPA 805 credited power supplies that did not have coordination studies on record. This finding was evaluated under V.SPA.12.018 and additional modifications were identified in Attachment S Table S-2.Finally, 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.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM DatabaseEC 19988EC 19989 ENG-EE-177 Attachment S Table S-3 V.SPA.12.018 FPRA-PI-ES AR 01342798Alignment Basis3.3.1.7Page B-59PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefAssociated Circuit CablesNEI 00-01 Section 3.0 GuidanceAssociated Circuit Cables Appendix R, Section III.G.2, requires that separation features be provided for equipment and cables, including associated nonsafety 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 enclosureCables Whose Failure May Cause Spurious ActuationsSafe shutdown system spurious actuation concerns can result from fire damage to a cable whose failure could cause the spurious actuation/mal-operation 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 CablesThe 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 CablesThe 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.ApplicabilityApplicableComments3.3.2Page B-60PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 Alignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment BasisNEI 00-01 RefMethodology for Cable Selection and LocationNEI 00-01 Section 3.0 GuidanceRefer to Figure 3-4 for a flowchart illustrating the various steps involved in selecting the cables necessary for performing a 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:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric Guidance OnlyReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.3.3Page B-61PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Circuits Required for the Operation of the Safe Shutdown EquipmentNEI 00-01 Section 3.0 GuidanceFor each piece of safe shutdown equipment defined in section 3.2, review the appropriate electrical diagrams including the following documentation to identify the circuits (power, control, instrumentation) required for operation or whose failure 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP safe and stable circuits were identified using schematics, connection diagrams, single lines and loop diagrams. Logic diagrams detailing the cascade power sources to equipment are included in both Genesis and PRISM databases. Loss of DC control power to power operated circuit breakers is being addressed via the OCT analysis in Genesis and PRISM and via modifications resulting from additional analysis as discussed in Sections 3.3.1.7 of this document.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Section 3.3.1.7 of this document. Genesis Database PRISM DatabaseAlignment Basis3.3.3.1Page B-62PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Interlocked Circuits and Cables Whose Spurious Operation or Mal-operation Could Affect ShutdownNEI 00-01 Section 3.0 GuidanceIn reviewing each control circuit, investigate interlocks that may lead to additional circuit schemes, cables and equipment. Assign to the equipment any cables for interlocked circuits that can affect the equipment.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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP circuit analysis considered interlocked and required supporting equipment. This methodology is addressed by the PINGP NPFA 805 transition circuit analysis procedure EPM-DP-EP-004 Revision 2, Post Fire Safe Shutdown Cable Identification FPRA-PI-ES, "Equipment Selection Notebook", FPRA-PI-CS, "Cable Selection and Circuit Analysis Notebook", and under the pre-transition program by GEN-PI-026, GEN-PI-052, GEN-PI-059 and EM 3.4.3.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology EPM-DP-EP-004 Revision 2, Post Fire Safe Shutdown Cable Identification EM 3.4.3, "Safe Shutdown Circuit Analysis" GEN-PI-026 GEN-PI-052GEN-PI-059FPRA-PI-ES FPRA-PI-CSAlignment Basis3.3.3.2Page B-63PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefAssign Cables to the Safe Shutdown EquipmentNEI 00-01 Section 3.0 GuidanceGiven the criteria/assumptions defined in Section 3.3.1, identify the cables required to operate or that may result in 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.ApplicabilityApplicableCommentsAlignment StatementAlignsA listing of required cables from the existing Appendix R model was obtained from the ARC database and combined with circuit analysis that was created in support of NFPA-805. This information was entered into the Genesis and PRISM databases for safe and stable under NFPA-805. At a minimum, Genesis relates cable to equipment, cable to raceway, and raceway to location for the analysis. The information in Genesis is supplied to the PRISM database to provide logics displaying the potential success paths for each fire area.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology ARC DatabaseGenesis DatabasePRISM DatabaseAlignment Basis3.3.3.3Page B-64PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Routing of CablesNEI 00-01 Section 3.0 GuidanceIdentify 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.ApplicabilityApplicableCommentsAlignment StatementAlignsCable routing information was obtained from the plant Passport system. This information was entered into the Genesis and PRISM databases for safe and stable under NFPA-805.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM DatabasePassport DatabaseEC 20498 - Cable to Fire Zone LocationAlignment Basis3.3.3.4Physical location of equipment and cables shall be identified.2.4.2.3 Nuclear Safety Equipment and Cable Location(Taken From NFPA 805, 2001 Edition)Page B-65PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify Location of Raceway and Cables by Fire AreaNEI 00-01 Section 3.0 GuidanceIdentify the fire area location of each raceway and cable endpoint identified in the previous step and join this information 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP utilizes the Genesis database to track cable to equipment, cable to raceway, and raceway to location information. As stated above, the routing information was obtained from the Passport system. When routing was determined to be missing or inadequate, raceway drawings and walkdowns were utilized to generate the correct information.The information tracked by Genesis is consistent with the guidance of NEI 00-01, Revision 1 for safe and stable and is utilized by the PRISM database to provide logic diagrams demonstrating success paths for each fire area.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis DatabasePassport Database PRISM DatabaseAlignment Basis3.3.3.5Page B-66PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefFire Area Assessment and Compliance StrategiesNEI 00-01 Section 3.0 GuidanceBy determining the location of each component and cable by fire area and using the cable to equipment relationships 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.4Fire 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)].2.4.2.4 Fire Area Assessment(Taken From NFPA 805, 2001 Edition)Page B-67PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.4.1Page B-68PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume only one fire in any single fire area at a time.ApplicabilityApplicableCommentsAlignment StatementAlignsThe PINGP safe and stable analysis under NFPA-805 considers only one fire occurring in one area at a time.Common enclosure concerns, common enclosure caused by loss of DC control power have been considered in the model and by other analysis (Reference Section 3.3.1.7 above).Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM DatabaseSection 3.3.1.7 of this documentAlignment Basis3.4.1.1Page B-69PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP assumed that a fire could affect all unprotected equipment and cables in the fire area. PINGP did not credit fire dynamics (intensity or size) when analyzing the deterministic areas for fire-induced damage. For areas utilizing RI / PB methodology, fire modeling was often employed to demonstrate that success paths would remain available.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis DatabasePRISM DatabaseAlignment Basis3.4.1.2Page B-70PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAddress 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.ApplicabilityApplicableCommentsAlignment StatementAlignsThe PINGP analysis considered all cable and equipment impacts as a result of the fire and addressed the impacts to achieve success paths for each NSPC.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database FPRA-PI-ESAlignment Basis3.4.1.3Page B-71PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceUse manual actions where appropriate to achieve and maintain postfire safe shutdown conditions in accordance with NRC requirements.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentTo achieve and maintain safe and stable conditions, and to minimize the use of recovery actions, the least fire-impacted success path was credited for each fire area.All recovery actions that varied from the deterministic requirements were addressed via the VFDR process. Areas with VFDRs that were not solved by a modification utilized the RI / PB methodology.Feasibility and / or Reliability of the recovery actions are being addressed as part of the NFPA 805 process as identified in Attachment S Table S-3.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology LAR Attachment GVFDR and FRE ProcessNFPA 805 Appendix B Attachment S Table S-3 Section 3.1 of this documentAlignment Basis3.4.1.4Page B-72PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceWhere appropriate to achieve and maintain cold shutdown within 72 hours, use repairs to equipment required in support of post-fire shutdown.ApplicabilityApplicableCommentsAlignment StatementAlignsThe 10CFR50 Appendix R requirement to achieve and maintain cold shutdown within 72 hours is not a requirement of NFPA 805; NFPA 805 requires maintaining fuel in a safe and stable condition. PINGP achieves safe and stable conditions at Mode 3. Reference Section 3.1 (above) for additional information regarding PINGP's safe and stable conditions.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Section 3.1 of this document.Alignment Basis3.4.1.5Page B-73PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAppendix 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 nonsafetycircuits of redundant trains within the same fire area by a firebarrier having a 3-hour rating (III.G.2.a)- Separation of cables and equipment and associated nonsafety 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 noninerted containments, the following additional options are also available: - Separation of cables and equipment and associated nonsafety 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.ApplicabilityApplicableComments3.4.1.6Page B-74PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 Alignment StatementNot in Alignment [but Prior NRC Approval]Areas crediting methods or mitigating strategies that varied from the deterministic requirements were addressed through the VFDR process. In each case, a success path was assured for each performance goal within each fire area. 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.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology LAR Attachment G LAR Attachment K LAR Attachment T Genesis DatabasePRISM DatabaseVFDR and FRE ProcessesAlignment BasisPage B-75PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceConsider 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 NPP's current licensing basis.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP considered multiple success paths and alternative equipment when deciding on how to best meet the NSPC. In each case, a success path was assured for each performance goal within each fire area by choosing the path least impacted by the fire, so as to minimize the reliance upon recovery actions. Spurious operations were addressed as detailed in the applicable sections of this document.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyLAR Attachment GGenesis Database PRISM Database FPRA-PI-ESAlignment Basis3.4.1.7Page B-76PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceConsider 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 postfire safe shutdown capability. This can be done systematically or via procedures such as Emergency Operating Procedures.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentAnalysis performed under AR 01121820 found that fire induced faults on credited process instrumentation tubing has no impact to safe and stable analysis under NFPA-805.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAR 01121820Section 3.2.1.7 of this document Attachment S Table S-3Alignment Basis3.4.1.8Page B-77PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefMethodology for Fire Area AssessmentNEI 00-01 Section 3.0 GuidanceRefer to Figure 3-5 for a flowchart illustrating the various steps involved in performing a fire area assessment.Use the following methodology to assess the impact to safe shutdown and demonstrate Appendix R compliance:ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.4.2Page B-78PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefIdentify the Affected Equipment by Fire AreaNEI 00-01 Section 3.0 GuidanceIdentify the safe shutdown cables, equipment and systems located in each fire area that may be potentially damaged by 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).ApplicabilityApplicableCommentsAlignment StatementAlignsThe Genesis and PRISM databases provide a listing of equipment and associated cables, as well as a logical relationship for meeting NSPC requirements used to identify success paths for each fire area under the safe and stable analysis for NFPA-805. Support systems and interfaces were also identified on the logics in the PRISM database.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis Database PRISM DatabaseAlignment Basis3.4.2.1Page B-79PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDetermine the Shutdown Paths Least Impacted By a Fire in Each Fire AreaNEI 00-01 Section 3.0 GuidanceBased on a review of the systems, equipment and cables within each fire area, determine which shutdown paths are either unaffected or least impacted by a postulated fire within the fire area. Typically, the safe shutdown path with the least 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 mal-operation 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 equipment's 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.ApplicabilityApplicableCommentsAlignment StatementAlignsThe Genesis and PRISM databases were utilized to identify the NSPC paths least affected by the fire occurring in each fire area. Both Genesis and PRISM identify and logically relate the NSPC components to their support equipment such that a fire-induced failure of the support equipment will cascade as a loss of the NSPC component and its path when applicable.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis DatabaseAlignment Basis3.4.2.2Page B-80PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDetermine Safe Shutdown Equipment ImpactsNEI 00-01 Section 3.0 GuidanceUsing the circuit analysis and evaluation criteria contained in Section 3.5 of this document, determine the equipment that can impact safe shutdown and that can potentially be impacted by a fire in the fire area, and what those possible impacts are.ApplicabilityApplicableCommentsAlignment StatementAlignsThe Genesis and PRISM databases generate reports of all affected equipment and cables within the fire area of concern. These reports include a listing of cascaded losses of support equipment. The circuit analysis tied to the cables within the databases describes the potential impacts due to the fireReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis DatabasePRISM Database EPM-DP-EP-004 Revision 2, Post Fire Safe Shutdown Cable IdentificationAlignment Basis3.4.2.3Page B-81PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDevelop a Compliance Strategy or Disposition to Mitigate the Effects Due to Fire Damage to Each Required Component or CableNEI 00-01 Section 3.0 GuidanceThe available deterministic methods for mitigating the effects of circuit failures are summarized as follows (see Figure 1-2):- Provide a qualified 3-fire rated barrier.- 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP fire areas that are remaining deterministic, utilize one of the options listed in NFPA 805 Section 4.2.3 to assure success paths. For those areas differing from the deterministic requirements, VFDRs were created and resolved via the non-deterministic (RI / PB) methodology or though the modification process for areas remaining deterministic.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology NFPA 805 Section 4.2.3 Genesis Database PRISM Database VFDR and FRE ProcessesAlignment Basis3.4.2.4Page B-82PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefDocument the Compliance Strategy or Disposition Determined to Mitigate the Effects Due to Fire Damage to Each Required Component or CableNEI 00-01 Section 3.0 GuidanceAssign compliance strategy statements or codes to components or cables to identify the justification or mitigating actions proposed for achieving safe shutdown. The justification should address the cumulative effect of the actions relied upon by the licensee to mitigate a fire in the area. Provide each piece of safe shutdown equipment, equipment not in the path whose spurious operation or mal-operation could affect safe shutdown, and/or cable for the required safe shutdown path with a specific compliance strategy or disposition. Refer to Attachment 6 for an example of a Fire Area Assessment Report documenting each cable disposition.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGPs safe and stable model incorporates the resolution (compliance strategy) for components and cables affected by the fire (reference LAR Attachment C). The overall effect of recovery actions (mitigation activities), has been considered via the VFDR and FRE processes for RI / PB areas. For deterministic areas, VFDRs were resolved via the modification process. The Genesis and PRISM databases) were utilized to facilitate this analysis and develop the strategies / FREs.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology PRISM Database Genesis Database VFDR and FRE Processes LAR Attachment CAlignment Basis3.4.2.5Page B-83PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Analysis and EvaluationNEI 00-01 Section 3.0 GuidanceThis 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.5Page B-84PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceApply the following criteria/assumptions when performing fire-induced circuit failure evaluations.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.5.1Page B-85PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceConsider 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.ApplicabilityApplicableCommentsAlignment StatementAlignsFor safe and stable, PINGP considers hot shorts, open circuits and shorts to ground in alignment with NEI 00-01 Revision 1 as detailed in the following sections of this document. Refer to Section 3.5.2.1 for discussion of open circuits. 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.For those circuits carried over from the original Appendix R analysis, consideration of RIS 2004-03 was documented in EC 19988.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyReference Sections 3.5.2.1, 3.5.2.2 and 3.5.2.3 EC 19988 EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-CSAlignment Basis3.5.1.1Page B-86PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP circuit analysis assumes that the initial contact and operational positions are per normal lineup as described in plant documentation. Cable selection included components that require repositioning to achieve and maintain safe and stable conditions.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyF5 Appendix E EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" GEN-PI-026 GEN-PI-052 EC 19991 FPRA-PI-CSAlignment Basis3.5.1.2Page B-87PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceAssume 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP does not credit self-mitigation of hot shorts in its safe and stable analysis.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis Database PRISM Database RIS 2004-03 EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"Alignment Basis3.5.1.3Page B-88PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceWhen 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentAll unprotected cables, and equipment within the analysis area, that did not meet the separation requirements of NFPA 805 Section 4.2.3 were identified and the appropriate failure modes were considered and addressed through either deterministic or RI / PB methods.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"Genesis Database PRISM Database NFPA 805 Section 4.2.3Alignment Basis3.5.1.4Page B-89PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCriteria/AssumptionsNEI 00-01 Section 3.0 GuidanceThe 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 thantwo 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 3.5.1.5Page B-90PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 permissive signal) or cause maloperation (e.g., unwanted start/stop/reposition signal) of systems necessary to achieve and maintain hot shutdown, then the instrument circuit may be considered an associated circuit and handled accordingly.Likelihood of Undesired ConsequencesDetermination 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 NPP's 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentPINGP procedure EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" is consistent with the guidance given in this section as it pertains to maintaining the fuel in a safe and stable condition. For cable selection and circuit analysis purposes, PINGP did not differentiate or pre-screen cables based upon cable type / insulation material (e.g., thermoset and thermoplastic cables).EC 19988 analyzed the legacy circuit analysis (for components that were directly carried over from Appendix R to the NFPA 805 transition database) against the guidance of RIS 2004-03. The results of EC 19988 were addressed to ensure alignment with this section.The circuit analysis for instrumentation circuits (shielded twisted pair), was "redone" per the findings detailed in FPRA-PI-ES, to address the proper fire-induced failure modes.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology EC 19988 EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-ESAlignment BasisPage B-91PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefTypes of Circuit FailuresNEI 00-01 Section 3.0 GuidanceAppendix 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/mal-operation 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.ApplicabilityApplicableCommentsAlignment StatementNot RequiredGeneric GuidanceReference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyAlignment Basis3.5.2Page B-92PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Failures Due to an Open CircuitNEI 00-01 Section 3.0 GuidanceThis section provides guidance for addressing the effects of an open circuit for safe shutdown equipment. An open 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 deenergizing 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.ApplicabilityApplicableCommentsAlignment StatementAligns with IntentOpen circuits were considered for all unprotected cables within the fire area of concern, in keeping with the guidance of this section.Report R2013-2700-001 was performed to identify the population of PINGP current transformer circuits (CTs) that are susceptible to secondary fires using the industry standard screening criteria. Disposition of these identified current transformers has been included as a modification in Attachment S Table S-2.Reference DocumentsPINGP Current Transformer Analysis Report R2013-2700-001 NEI 00-01, Revision 2 as clarified by LAR Template 1L Attachment S Table S-2EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-CSAlignment Basis3.5.2.1Page B-93PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Failures Due to a Short-to-GroundNEI 00-01 Section 3.0 GuidanceThis section provides guidance for addressing the effects of a short-to-ground on circuits for safe shutdown equipment. A 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.ApplicabilityApplicableCommentsAlignment StatementAlignsPINGP has considered the effects of shorts to ground in alignment with the guidance given in this section to maintain safe and stable conditions.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-CSAlignment Basis3.5.2.2Page B-94PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Failures Due to a Hot ShortNEI 00-01 Section 3.0 GuidanceThis 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.ApplicabilityApplicableCommentsAlignment StatementAlignsFor safe and stable, PINGP utilizes the "hot probe" method to determine the effects of hot shorts on the circuits during the initial circuit analysis activity. The hot probe method is not dependent upon the source (inter, intra or power supply).Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Genesis Database PRISM Database EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification"EC 19988 FPRA-PI-CSAlignment Basis3.5.2.3Page B-95PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Failures Due to Inadequate Circuit CoordinationNEI 00-01 Section 3.0 GuidanceThe evaluation of associated circuits of a common power source consists of verifying proper coordination between the 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 usingacceptable 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.ApplicabilityApplicableComments3.5.2.4Page B-96PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 Alignment StatementAlignsOriginal installation and subsequent PINGP processes have followed proper design standards for circuit protection. Engineering manuals, short circuit evaluations and loading evaluations pertaining to proper circuit protection and coordination are in place to maintain circuit protection and coordination where required. EC 19989 identified that the PINGP coordination program was being maintained and has the proper controls in place to include the NFPA 805 engineer when electrical coordination changes that affect the NFPA 805 analysis are made.Loss of DC control power has been analyzed in the PINGP model and through additional evaluations, including common power supply and common enclosure considerations resulting from this fire-induced phenomenon.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability MethodologyGenesis DatabasePRISM Database EC 19988 EC 19989 Section 3.3.1.7 of this document EPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-CSAlignment BasisPage B-97PINGP Northern States Power - MinnesotaAttachment B - NEI 04-02 Table B-2 NEI 00-01 RefCircuit Failures Due to Common Enclosure ConcernsNEI 00-01 Section 3.0 GuidanceThe common enclosure associated circuit concern deals with the possibility of causing secondary failures due to fire 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.ApplicabilityApplicableCommentsAlignment StatementAlignsOriginal installation and subsequent PINGP processes have followed proper design standards for circuit protection. An analysis of the latest coordination studies was performed in support of section 3.5.2.4 of the B-2 Table, and can be found in section 3.5.2.4. Plant physical barriers pertaining to the defined NFPA-805 fire areas were verified as part of the compartment analysis review and can be found in document FPRA-PI-PP.Reference DocumentsEC-19775, NFPA 805 LAR Attachment B - Table B-2, Nuclear Safety Capability Methodology Section 3.5.2.4 of this document.FPRA-PI-PPEPM-DP-EP-004 Revision 2, "Post Fire Safe Shutdown Cable Identification" FPRA-PI-CSAlignment Basis3.5.2.5Page B-98PINGP Northern States Power - Minnesota Attachment C - NEI 04-02 Table B-3 Fire Area Transition PINGP Page C-1 C. NEI 04-02 Table B Fire Area Transition 353 Pages Attached Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 2 Unit Fire Area Description 1 1 Containment Unit 1 Fire Area 1 includes Fire Area(s): 68 Containment Annulus Unit 1 Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 3 Process Monitoring If Unit 1 Process Monitoring Train A is not available, use Train B 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) Unit 2 - Charging System (Train A) or Safety Injection System (Train B) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 4 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 - 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. 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 EC20706, Fire Risk Evaluation, Fire Area 01, Unit 1 Containment, Rev. 0, September 2012 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 5 EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests in the Corrective Action Program are tracking resolution of the identified issues. Variances from Deterministic Requirements (VFDR) VFDR-001 01 A fire in FA 01 could damage the cable for LOOP 1L-433 (Pressurizer Level Cold Calibration Instrument) and cable for LOOP 1L-426-RP (Pressurizer Level Red Channel). Cable 1CF-31 is routed in a raceway with a radiant energy shield installed on the top and bottom of the tray, but it cannot be verified that it has a 1/2 hour rating. Components and Cables: Pressurizer Level Cold Calibration Instrument, LOOP 1L-433 (1CF-31) Pressurizer Level Red Channel, LOOP 1L-426-RP (1CR-36) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3.4.b, due to lack of separation between redundant trains of Pressurizer Level Indication. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring. Compliant Case: Pressurizer Level Instrumentation would remain free of fire damage. Disposition Recovery Action(s): No recovery action 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 fire modeling required. VFDR-001 02 A fire in FA 01 could damage cables for CV-31245 (11 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX) CC). A fire in FA 01 could also damage cables for CV-31335 (11 RCP seal water outlet isolation CV). This could result in increased leakage through the RCP seals. Components and Cables: 11 RCP TBHX CC, CV-31245 (1C-2163, 1C-2178, 1C-2179, 1C-2180, 1C-4641, 1C-4643) 11 RCP seal injection outlet valve, CV-31335 (1C-1075, 1C-1076, 1C-1080) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 6 This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3.4.b, due to lack of separation between redundant trains of RCP seal cooling. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: Reactor Coolant Pump Seal cooling should remain available from this area. Disposition Recovery Action(s): No recovery action credited. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification credited. VFDR-001 03 A fire in FA 01 could damage cables for CV-31246 (12 RCP TBHX CC). A fire in FA 01 could also damage cables for CV-31336 (12 RCP seal water outlet isolation CV). This could result in increased leakage through the RCP seals. Components and Cables: 12 RCP TBHX CC, CV-31246 (1C-2162, 1C-2174, 1C-2175, 1C-2176, 1C-4640, 1C-4642) 12 RCP seal injection outlet valve, CV-31336 (1C-1081, 1C-1082, 1C-1086)

This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3.4.b, due to lack of separation between redundant trains of RCP seal cooling. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: Reactor Coolant Pump Seal cooling should remain available from this area. Disposition Recovery Action: No recovery action credited. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 7 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 10, 20, 29, 32 Ionization N N N Y Y Suppression - - - - - - - 1 Feature 1CV-T42I RES N N N Y Y Raceway 1CV-T42I is wrapped with a radiant energy shield Detection 21 Ionization N N N Y Y 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. 68 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 8 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 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 9 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 10 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 Compressed Air System Train A or B Temporary Control Room and Relay Room HVAC See VFDR-002 01 Reference Documents Safe/Genesis V 4.0.2 EC 20707, Fire Risk Evaluation, Fire Area 02, Ventilation Fan Room, Unit 1, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-053, NFPA 13, 1969 Code Compliance Deviations, Vent Filters (FA-2, 76) Summary The purpose of this analysis is to document the review of the FA2 and FA76 Vent Filter deluge sprinkler systems protecting the Auxiliary Building Special Vents (121 and 122 ABSV) and Shield Building Exhaust Filters (11, 12, 21, and 22 SBEF) on the 755ft elevation of the Auxiliary Building, Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 11 for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Seven deviations have been justified as "acceptable"; therefore, no further action is necessary. Three deviations require additional actions to resolve noncompliance's associated with (a) testing of vent filter deluge system drains and flow switches, (b), lack of pressure gages on the systems, and (c) the configuration of drains for the vent filter deluge systems and which drains are used for flushing the system in SP 1197. An Action Request has been initiated to track resolution of the identified issues. 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-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance's associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 12 configuration (without damper) provides adequate protection from a fire in Fire Area 76 propagating into Fire Area 92. EEEE Title AR 1352782, 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-002 01 This variance is due to fire-induced loss of function for 121 and 122 safeguard chillers due to fire damage to cables for MTR-112G-11, MTR-112G-12, MTR-112G-5, MTR-122G-11, MTR-122G-12, and MTR-122G-5. This could fail both trains of chillers and result in control room and relay room temperature above limits. Components and Cables: 121 Control Room Chiller, MTR-112G-11 (1CA-546, 1CA-547) 121 Control Room Chilled Water Pump, MTR-112G-12 (1CA-54, 1CA-546, 1CA-547) 121 Control Room Air Handler, MTR-112G-5 (1CA-484, 1CA-485) 122 Control Room Chiller, MTR-122G-11 (1CB-412, 1CB-413) 122 Control Room Chilled Water Pump, MTR-122G-12 (1CB-397, 1CB-412, 1CB-413) 122 Control Room Air Handler, MTR-122G-5 (1CB-340, 1CB-341)

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 chilled water. This is a separation issue for Vital Auxiliaries. Compliant Case: The ability to maintain Control Room temperature within limits should be available, to keep temperatures below the point at which significant instrument drift is assumed to occur, and subsequent loss of control of plant equipment could result. Disposition Recovery Action(s): The recovery action for this variance is to put a fan in the records room door to provide control room cooling per procedure C37.9 AOP1. This action takes place between the control room, FA13 (FDZ 57), and the records room, FA 12 (FDZ 25). This will ensure that Control Room temperature stays in the required range to prevent loss of control of plant equipment. The recovery action for this variance is to open the door to the relay room to provide relay room cooling per procedure C37.9 AOP2. This action takes place in the Relay and Cable Spreading Room, FA 18 (FDZ 12). This will ensure that Relay Room temperature stays in the required range to prevent loss of control of plant equipment. 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 credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 13 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 30, 108 Ionization N N N N Y Suppression - Wet Pipe N N N N N Filter system 2 Feature - - - - - - - Detection 53 Ionization N N N N N Suppression - Wet Pipe N N N N N Filter system 76 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 14 Unit Fire Area Description 1 3 Water Chiller Room Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 15 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 16 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 Compressed Air System Train A or B Control Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. EEEE Title AR 1352782, 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 maximium 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 hours rating Variances from Deterministic Requirements (VFDR) None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 17 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 31 Ionization N N N N N Suppression - - - - - - - 3 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 18 Unit Fire Area Description 1, 2 4 Fuel Handling Area Fire Area 4 includes Fire Area(s): 39 Radwaste Building 40 Maintenance Storage Shed/CAF 61A Aux Building Hatch Area 62 Spent Fuel Pool Area 67 Resin Disposal Building 93 Drum Storage/Low Level Rad Waste Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 19 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 20 Vital Auxiliaries Unit 1 - Offsite Power (1R) supplying Electrical Distribution Trains A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 21 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 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 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. EEEE Title FPEE-11-008, NFPA 13, 1980 Code Compliance Deviations, DM-7, Resin - Rad Waste Storage Summary The purpose of this analysis is to document the review of the DM-7 manually-actuated sprinkler system protecting the Low Level Radwaste Enclosure in Fire Area 93 and the Truck Loading Enclosure in Fire Area 67 for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1980, Standard for the Installation of Sprinkler Systems (Code of Record). Two deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with the lack of isolation valve position verification and flow testing through the system drain, the use of sprinklers with different temperature ratings, the distance of sprinklers below the pitched roof and the position of deflectors in the Truck Loading Enclosure, and the manual mode of the closed head sprinkler system operation that could challenge the capability of the system to control a large fire, along with the misidentification of the system operating characteristics in program documents. An Action Request has been initiated to track resolution of the four identified issues. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. 6.4 Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 22 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-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-12-005, CA-01311402-03, Fire Doors 136 & 139 Summary The purpose of this evaluation is to assess Doors 136 and 139, both of which have 12in by 12in access openings near the bottom of the door to pass temporary materials such as hoses. The openings are protected by 14in by 14in access opening metal cover plates that are secured closed when not in use. The doors are in series on opposite ends of the airlock in the boundaries between Fire Area 4 (Fuel Handling Area) and Fire Area 64 (Auxiliary Building Low Level Decay Area Unit 1) on the 695ft elevation of the Fuel Handling Building. Fire Doors 136 and 139, inclusive of the 1/16in access opening metal cover plate assemblies that cover both sides of the access openings in each door, provide adequate protection to prevent fire spread between Fire Area 4 and Fire Area 64. In the unlikely event that fire does spread between the two areas, there will be no adverse impact on safe shutdown capability. The 1R and 2RY transformers remain available from the Control Room to provide offsite power to Bus 15 and Bus 16, and to Bus 25 and Bus 26, respectively, given a fire in either or both of these areas, and Bus 16 will be isolated from a postulated fault on its normal offsite power feed by implementation of existing local manual actions. Variances from Deterministic Requirements (VFDR) None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 23 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 8, 30, 33 Ionization N N N N N Suppression SWP-1 Wet Pipe N N N N N Stairwell 4 Feature - - - - - - - Detection 34, 81 Ionization, Thermal, Smoke N N N N N Suppression SWP-1 Wet Pipe N N N N N Stairwell System 39 Feature - - - - - - - Detection - - - - - - - Suppression - - - - - - - 40 Feature - - - - - - - Detection 30 Ionization N N N N N Detection 53 Ionization N N N N N 61A Suppression - - - - - - - Feature - - - - - - - Detection 30 Ionization N N N N N Suppression - - - - - - - 62 Feature - - - - - - - Detection 34 Ionization, Smoke N N N N N Detection 81 Ionization N N N N N 67 Suppression SWP-1 Wet Pipe N N N N N Stairwell System Feature - - - - - - - Detection 104 Thermal, Flame N N N N N Suppression DM-7 Deluge N N N N N 93 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 24 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 25 Unit Fire Area Description 1, 2 8 Turbine Building Fire Area 8 includes Fire Area(s): 9 Maintenance Shops 21 Unit 1 4.16 KV Normal Switchgear, (Bus 13, 14) 23 Unit 2 4.16 KV Normal Switchgear (Bus 23, 24) 69 Turbine Building Ground Floor & Mezzanine Floors Unit 1 70 Turbine Building Ground Floor & Mezzanine Floors Unit 2 Regulatory Basis 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 - 21 MDAFW Pump to 21 SG

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 26 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-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 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 - D1 supplying Electrical Distribution Trains A Unit 2 - D5 supplying Electrical Distribution Trains A Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Compressed Air System Train A Control Room and Relay Room HVAC Train A Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 27 Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-009, NFPA 13, 1992 Code Compliance Deviations, PA-14 & 15, TB 735© U1& 2 Turbine Bearings. Summary The purpose of this analysis is to document the review of the PA-14 and PA-15 automatic deluge suppression system protecting the Turbine Generator and Exciter bearings against the requirements of National Fire Protection Association 13, (NFPA) - 1991, Standard for the Installation of Sprinkler Systems. Four deviations from the criteria of the code have been identified. Three have been determined to be acceptable as is based on meeting the intent of the criteria. An action request in the Corrective Action Program is tracking resolution of one item. 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-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 28 EEEE Title FPEE-11-035, NFPA 72, 1990 Code Compliance Deviations Summary 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, Maintenance, and Use of Protective Signaling Systems (Code of Record). Four deviations have been justified as acceptable as is. 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 deviation is being tracked in the corrective action system. 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-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests in the Corrective Action Program are tracking resolution of the identified issues. 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 29 EEEE Title FPEE-11-003, NFPA 15 1969 Code Compliance Deviations, DA-1, DA-5, 11 H2 Seal Oil U1 and 21 H2 Seal Oil U2 Summary The purpose of this analysis is to document the review of the DA-1 & DA-5 hydrogen seal oil units' automatic deluge system for compliance with the applicable requirements cited in National Fire Protection Association 15, (NFPA) -1969, Standard for Water Spray Fixed Systems for Fire Protection (Code of Record). Two deviations have been justified as "acceptable"; requiring no further Action. Ten deviations have been identified as "not acceptable". EEEE Title FPEE-11-005, NFPA 15 1969 Code Compliance Deviations, 11 & 21 Turbine Oil Reservoir, DA-3, DA-4 Summary The purpose of this analysis is to document the review of the DA-3 & DA-4 Turbine Oil Reservoir Water Spray automatic deluge systems for compliance with the applicable requirements cited in National Fire Protection Association 15, (NFPA) -1969, Standard for Water Spray Fixed Systems for Fire Protection (Code of Record). Two deviations have been justified as "acceptable"; requiring no further Action. Ten deviations have been identified as "not acceptable". Action requests in the Corrective Action Program are tracking resolution of these issues. EEEE Title FPEE-11-010, NFPA 13, 1969 Code Compliance Deviations, WPS-7, 8, and 9 Summary The purpose of this analysis is to document the review of the WPS-7, WPS-8, and WPS 9 wet pipe sprinkler systems protecting the Unit 1 Turbine Building, elevation 695ft, Fire Area 69, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Eleven deviations have been justified as "acceptable"; therefore, no further action is necessary. One deviation requires additional actions to resolve the noncompliance associated with pendent heads without return bends in areas protected by WPS-7 and WPS-8. An action request in the Corrective Action Program is tracking resolution of this issue. EEEE Title FPEE-11-011, NFPA 13, 1969 Code Compliance Deviations, WPS-15, 16, and 17 Summary The purpose of this analysis is to document the review of the WPS-15, WPS-16, and WPS 17 wet pipe sprinkler systems protecting the Unit 2 Turbine Building, elevation 695ft, Fire Area 70, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record).. Twelve deviations have been justified as "acceptable"; therefore, no further action is necessary. Two deviations require additional actions to resolve the noncompliance associated with pendent heads without return bends in areas protected by WPS-15 and WPS-17 and the use of sidewall sprinklers in WPS-15. Action requests in the Corrective Action Program are tracking resolution of the identified issues. EEEE Title FPEE-11-012, NFPA 13, 1991 Code Compliance Deviations, WPS-18, 21 Summary The purpose of this analysis is to document the review of the WPS-18 and WPS-21 automatic wet pipe sprinkler systems protecting the 715ft elevations of the U1 and U2 Turbine Buildings where oil lines from the turbine generators above are run against the requirements of National Fire Protection Association 13, (NFPA) - 1991, Standard for the Installation of Sprinkler Systems (Code of Record). Six deviations from the criteria of the code have been identified. Five have been determined to be acceptable as is based on meeting the intent of the criteria. An action request in the Corrective Action Program is tracking resolution of the remaining issue. EEEE Title FPEE-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 30 Variances from Deterministic Requirements (VFDR) VFDR-069 01 This Variance From Deterministic Requirements is due to a fire in FA 069 that could damage cables 1CA-1109, 1CA-1111, and 1CA-1248. Damage to cable 1CA-1109 could cause CV-31998 to spuriously close. Damage to cables 1CA-1111 or 1CA-1248 could cause CV-31153, 11 TDAFW Pump recirculation lube oil cooler line to close and also damage the 11 TDAFW Pump. 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. Components and Cables: CV-31998 1CA-1109 CV-31153 1CA-1111 1CA-1248 Compliant Case: One train of Decay Heat Removal should remain available. Disposition Recovery Action(s): No recovery action. Modification to eliminate the possibility that a fire could cause CV-31998 to spuriously close (Table S-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 a plant modification credited.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 31 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 24, 49 Heat N N N N N Detection 107 Heat, Smoke N N N N N Smoke detector in Elevator Machine room Detection 27 Ionization, Thermal. Heat N N N N N Detection 107 Smoke N N N N N Smoke detector in Elevator Machine room Suppression PA-14 Pre-Action N N N N Y Unit 1 Generator and Exciter Suppression PA-15 Pre-Action N N N N Y Unit 2 Generator and Exciter Suppression WPS-9 Wet Pipe N N N N N Protects Elevator Machine room and pit Suppression SWP-6 Wet Pipe N N N N N Stairway System 8 Feature - - - - - - - Detection 27 Ionization, Thermal, Heat N N N N N 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 9 Feature - - - - - - - Detection 84 Ionization N N N N N Suppression - - - - - - - 21 Feature - - - - - - - Detection 86 Ionization N N N N N Suppression - - - - - - - 23 Feature - - - - - - - Detection 3 Ionization N N N N N Detection 4 Ionization, Heat, Smoke N N N N N Detection 15 Ionization, Flame N N N N N Detection 107 Heat, Smoke N N N N N Suppression WPS-7 Wet Pipe N N N N N Suppression WPS-8 Wet Pipe N N N N N Suppression WPS-9 Wet Pipe N N N N N 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 N N Suppression PA-14 Pre-Action N N N N N Suppression SWP-3 Wet Pipe N N N N N Stairwell system Suppression SWP-5 Wet Pipe N N N N N Stairwell system 69 Feature

- - - - - - -

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 32 Detection 36 Ionization N N N N N Detection 37 Ionization, Heat, Smoke N N N N N Detection 44 Ionization, Thermal N N N N N Suppression WPS-15 Wet Pipe N N N N N Suppression WPS-16 Wet Pipe N N N N 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 N 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 70 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 33 Unit Fire Area Description 1 10 Train A Event Monitoring Equipment Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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-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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 34 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 Compressed Air System Train A or B Temporary Relay Room HVAC and Control Room HVAC Train A See VFDR-10 01 Reference Documents Safe/Genesis V 4.0.2 EC 20708, Fire Risk Evaluation, Fire Area 10, Train A Event Monitoring Equipment Room, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 35 Variances from Deterministic Requirements (VFDR) VFDR-10 01 This variance is caused by loss of Relay/Cable Spreading Room cooling due to fire damage to cables for MTR 112G-15, MTR 112G-17, MTR 122G-11, and MTR 122G-12. Fire damage to cables associated with MTR 112G-15 and MTR 112G-17 results in the loss of the Train A Relay/Cable Spreading room unit coolers. Fire damage to the cables associated with MTR 122G-11 and MTR 122G-12 result in the loss of the B Train of the Chilled Water System. Both of these failures together result in the loss of all Relay/Cable Spreading Room cooling. 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 safeguards chilled water. This is a separation issue for Vital Auxiliaries. Components and Cables: 121N Relay Room Unit Cooler, MTR-112G-15 (1HVA-92) 121S Relay Room Unit Cooler, MTR-112G-17 (1HVA-88) 122 Cont Room Chiller, MTR-122G-11 (1CB-412, 1CB-413) 122 Cont Room Chilled Water Pump, MTR-122G-12 (1CB-397, 1CB-412, 1CB-413) PNL-119 (1T1-36, 1T1-37) Compliant Case: One train of Relay/Cable Spreading Room cooling should remain unaffected by a fire, to maintain temperatures below the point at which significant instrument drift is assumed to occur, and subsequent loss of control of plant equipment could result. Disposition Recovery Action: Open the door to the relay room to provide cooling per procedure C37.9 AOP2. This action takes place in the Relay and Cable Spreading Room, FA 18 (FDZ 12). This will ensure that relay/cable spreading room temperature stays in the required range to prevent loss of control of plant equipment.

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 credited.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 36 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 26 Ionization N N N Y Y Suppression - - - - - - - 10 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 37 Unit Fire Area Description 1 11 Unit 1 Normal Switchgear & Control Rod Drive Room Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 38 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 (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 or use Alternate Rod Insertion. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 39 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 Train B Compressed Air System Train A or B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 40 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 87 Ionization N N N N N Suppression - - - - - - - 11 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 41 Unit Fire Area Description 1 12 OSC Room Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 42 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title AR 1352782, 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-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 43 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-057, NFPA 13, 1989 Code Compliance Deviations, WPS-23, 24 Summary The purpose of this analysis is to document the review of the WPS-23 and WPS-24 wet pipe sprinkler systems protecting the Records Room and Hot Instrument Lab in the Unit 1 Auxiliary Building, elevation 735ft, Fire Area 12, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems. Six deviations have been justified as "acceptable"; therefore, no further action is necessary. Five deviations require additional actions to resolve noncompliances associated with (a) lack of drawings depicting the systems, (b) use of upright sprinklers in the Hot Instrument Lab with sidewall deflectors (that are neither standard pendent nor standard sidewall sprinklers), (c) clear space between the Records Room sprinklers and the open grid ceiling, and (d) obstructions to water distribution in both rooms. Action Requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 25 Ionization N N N N N Suppression WPS-23, 24 Wet Pipe N N N N N 12 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 in a Change Evaluation or Fire Risk Evaluation 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 44 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 45 Unit Fire Area Description 1, 2 13 Control Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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: 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 redundant train remains available. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 46 (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 (Train B) Train A or B RCS Head Vents or Pressurizer Vents Unit 2 - Charging System (Train A) or Safety Injection (Train B) 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 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, or D1 Emergency Diesel Generator supplying Electrical Distribution Train A Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B, or D5 Emergency Diesel Generators supplying Electrical Distribution Train A Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 20728, Fire Risk Evaluation, Fire Area 13, Control Room, Rev. 0, September 2012 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 47 Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) VFDR-013 01 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control. Components and Cables: Many 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31200 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe and stable. Manually trip Unit 1 Main Turbine at the front standard in Fire Area 008. 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 credited. VFDR-013 02 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 48 Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control at the Primary Control Station. Disposition Recovery Action(s): Manually close VC 8 after opening VC 1 in Fire Area 058 for VCT isolation. Prior to starting MTR 111J-1, manually close VC-14-1 (11 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals.

Prior to starting MTR 111J-1, manually close VC-14-2 (12 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals. Verify open or manually trip BKR 112C at BUS 112 in Fire Area 079 to de-energize MCC 1S1 and mitigate spurious operation of PZR Heater Group A. Verify open or manually trip BKR 122C at BUS 122 in Fire Area 082 to de-energize MCC 1R1 and mitigate spurious operation of PZR Heater Group B.

At BUS 16 in Fire Area 020, open DC Knife switches (located inside breaker cubicles) for BKR 16-1 (12 CS PMP) and verify breaker open. Verify open or manually trip BKR 180-183 at BUS 180 in Fire Area 011 to de-energize MCC 1P1 and mitigate spurious operation of PZR Heater Group C. Verify open or manually trip BKR 180-184 at BUS 180 in Fire Area 011 to de-energize MCC 1P2 and mitigate spurious operation of PZR Heater Group D. Verify open or manually trip BKR 180-182 at BUS 180 in Fire Area 011 to de-energize MCC 1R2 and mitigate spurious operation of PZR Heater Group E.

Prior to starting MTR 111J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31198 in the required open position. De-energize MV-32077 at MCC 1A1, BKR 111E-9, located in Fire Area 032. De-energize MV-32078 at MCC 1A2, BKR 121E-9, located in Fire Area 032. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 49 De-energize MV-32075 at MCC 1K1, BKR 111J-8, located in Fire Area 058. Manually trip MTR 121J-1 (11 CHG PMP) at MCC 1K2, BKR 121J-1, in Fire Area 058. De-energize MV-32076 at MCC 1KA2, BKR 121B-28, located in Fire Area 058. De-energize MV-32166 at MCC 1L1, BKR 112E-6, located in Fire Area 059. Take local control of MTR 111J-1, 12 charging pump at panel 70810 by placing CS-7081001 in "LOCAL" and pressing CS-7081002 once to energize the VFD and a second time to start the 12 charging pump at the local panel in 12 charging pump room in Fire Area 058 Manually operate MTR 111J-1 (12 CHARGING PUMP) at the VFD panel by MCC 1K1 in Fire Area 058 by placing the LOC/REM SEL SW in the "LOCAL" position.

Prior to starting MTR 111J-1, manually close MV-32166 in Fire Area 085. De-energize PNL 171 at PNL 11, breaker 11-8, located in Fire Area 033 in order to fail CV-31232 closed. This action will fail all components powered from PNL 171 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 181 at PNL 12, breaker 12-8, located in Fire Area 034 in order to fail CV-31231 closed. This action will fail all components powered from PNL 181 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail CV-31226 closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31330 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe and stable.

Manually open VC 1 in Fire Area 058 to align RWST supply to charging pump suction. Time constraint to open VC 1 before starting charging pump. Seal Modification will resolve this issue of losing all water to RCP seals (Table S-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 and a plant modification credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 50 VFDR-013 03 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe and stable. FI-18032 (11 TD AFW PMP DISCH FI) remains available in Fire Area 032 to provide local AFW flow indication.

Manually start 11 TDAFWP by verifying that the lube oil pump is running and placing AF-292-1, 11 TD AFW PMP MN STM SPLY CV-31998 ROOT ISOL, in the "OPEN" position. At BUS 11 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 11-3 (MTR 11-3, 11 FW PMP) and verify breaker open. At BUS 12 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 12-3 (MTR 12-3, 12 FW PMP) and verify breaker open.

At BUS 16 in Fire Area 020, open DC knife switches (located inside breaker cubicles) for BKR 16-3 (MTR 16-3, 12 MD AFW PMP) and verify breaker open. De-energize MV-32238 at MCC 1A1, BKR 111-17, located in Fire Area 032. When the AFW pump suction pressure reaches 4" Hg (PI-11054), de-energize MV-32025 at MCC 1A1, BKR 111E-1 (11 TD AFW PMP SUCT CLG WTR SPLY MV-32025), located in Fire Area 032.

De-energize MV-32333 at MCC 1A1, 111E-4, located in Fire Area 032. De-energize MV-32006 at MCC 1B1 (BKR 151-5) located in Fire Area 069.

Manually close MV-32006 in Fire Area 069 to isolate Main Steam flow. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 51 De-energize MV-32010 at MCC 1B1 (BKR 151-6) located in Fire Area 069. Manually close MV-32010 in Fire Area 069 to isolate Main Steam flow. De-energize MV-32016 at BKR 1K1-H2 at MCC 1K1, located in Fire Area 058. Verify open MV-32016 in Fire Area 060.

De-energize MV-32017 at BKR 1K2-D4 at MCC 1K2, located in Fire Area 058. Manually close MV-32017 in Fire Area 060 to isolate the non-credited steam generator.

Manually open MV-32025, 11 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. Manually throttle MV-32238 (11 AFW TO 11 SG MV) in Fire Area 032 as necessary to control AFW flow.

Manually close MV-32243 in Fire Area 060 to support isolation of the non-credited steam generator (12 SG). Verify open MV-32238 in Fire Area 032.

Verify open MV-32333 in Fire Area 032. 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 04 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems at the Primary Control Station. Disposition Recovery Action(s): Modify D1 to ensure cooling water is available to D1 (Table S-2).

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 52 Put local control for the DDCLPs near the HSD Panel (Table S-2). Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. 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 05 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation. 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 Instrumentation. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation at the Primary Control Station. Disposition Recovery Action LOOP 1L-433 (local indicator 1LI-433C) remains available in Fire Area 058 to provide pressurizer level indication for local control of charging pump flow.

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-013 06 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power at the Primary Control Station. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 53 Disposition Recovery Action(s): Stop D1 DSL GEN if running with inadequate cooling water pressure. Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-3 is open. Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-7 is open. Verify D1 Diesel running and ensure all loads are stripped from BUS 15. Manually close BKR 15-2 (BUS 15 SOURCE FROM D1 DSL GEN) at BUS 15 in Fire Area 081 by pulling the manual CLOSURE lever with the hot stick.

On the front panel of BKR 15-11, BUS 15 FEED TO 111M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position. Verify D1 Diesel running and manually close BKR 15-11 at BUS 15 in Fire Area 081.

On the front panel of BKR 15-6, BUS 15 FEED TO 112M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position. Verify D1 Diesel running and manually close BKR 15-6 at BUS 15 in Fire Area 081.

Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 by opening Metering CT Switches (six knife switches) for remote metering. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the DIESEL GENERATOR GAUGE PANEL.

PI-55001 (D1 DSL GEN RAW WATER PI) remains available in Fire Area 025 to provide local indication of CL header pressure. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 DIESEL GENERATOR PANEL.

Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 REMOTE CONTROL ISOLATION PANEL. De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033. De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033 and verify breaker 15-6 is closed. Obtain switching protective equipment and the 4 ft. hot stick from the Bus 13/14 Room Appendix R cabinet. Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear.

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 01 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 54 Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31213 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable. Manually trip Unit 2 Main Turbine at the front standard in Fire Area 008.

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 credited. VFDR-013 02 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control at the Primary Control Station. Disposition Recovery Action(s): Manually open 2VC 1 in Fire Area 073 to establish RWST supply to charging suction. Time constraint to open 2VC 1 before starting charging pump. Manually close 2VC 8 after opening 2VC 1 in Fire Area 073 to establish VCT isolation from charging suction.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 55 Prior to starting MTR 211J-1, manually close 2VC-14-1 (21 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals.

Prior to starting MTR 211J-1, manually close 2VC-14-2 (22 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals. Verify open or manually trip BKR 212C at BUS 212 in Fire Area 127 to de-energize MCC 2S1 and mitigate spurious operation of PZR Heater Group A. Verify open or manually trip BKR 222C at BUS 222 in Fire Area 122 to de-energize MCC 2R1 and mitigate spurious operation of PZR Heater Group B. At BUS 26 in Fire Area 118, open DC Knife switches (located inside breaker cubicles) for BKR 26-9 (22 CS PMP) and verify breaker open.

Verify open or manually trip BKR 270-273 at BUS 270 in Fire Area 017 to de-energize MCC 2P1 and mitigate spurious operation of PZR Heater Group C. Verify open or manually trip BKR 270-274 at BUS 270 in Fire Area 017 to de-energize MCC 2P2 and mitigate spurious operation of PZR Heater Group D. Verify open or manually trip BKR 270-272 at BUS 270 in Fire Area 017 to de-energize MCC 2R2 and mitigate spurious operation of PZR Heater Group E.

Prior to starting MTR 211J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31211 in the required open position. De-energize MV-32180 at MCC 2A1, BKR 211E-9, located in Fire Area 031. De-energize MV-32181 at MCC 2A2, BKR 221E-9, located in Fire Area 031. De-energize MV-32178 at MCC 2K1, BKR 211J-8, located in Fire Area 073. Manually trip MTR 221J-1 (21 CHG PMP) at MCC 2K2, BKR 221J-1, in Fire Area 073. De-energize MV-32179 at MCC 2KA2, BKR 221B-28, located in Fire Area 073. De-energize MV-32194 at MCC 2L1, BKR 212E-6, located in Fire Area 074. Manually operate MTR 211J-1 (22 CHARGING PUMP) at the local panel in Fire Area 073 by placing the LOC/REM SEL switch, CS-7082001 in the "LOCAL" position. Then ENERGIZE the VFD by momentarily depressing the START pushbutton, CS-7082002. Then START the 22 CHARGING PUMP by momentarily depressing CS-7082002. Switch 22 charging pump local/remote switch to the "LOCAL" position at 22 Charging pump VFD cabinet next to MCC 2K1 in Fire Area 073. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 56 Prior to starting MTR 211J-1, manually close MV-32194 in Fire Area 085. De-energize PNL 271 at PNL 21, breaker 21-10, located in Fire Area 035 in order to fail CV-31234 closed. This action will fail all components powered from PNL 271 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 281 at PNL 22, breaker 22-10, located in Fire Area 036 in order to fail CV-31233 closed. This action will fail all components powered from PNL 281 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31230 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31422 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect safe and stable. Modification for Charging Pump Suction Trip will resolve MSO issue (Table S-2).

Seal Modification will resolve the issue of losing all RCP seal cooling (Table S-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 and plant modifications credited. VFDR-013 03 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal. Components and Cables: Many

This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal at the Primary Control Station.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 57 Disposition Recovery Action(s): De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect safe and stable. FI-18035 (22 TD AFW PMP DISCH FI) remains available in Fire Area 031 to provide local AFW flow indication. Manually start 22 TDAFWP by verifying that the lube oil pump is running and placing 2AF-292-1, 22 TD AFW PMP MN STM SPLY CV-31999 ROOT ISOL, in the "OPEN" position.

At BUS 21 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 21-3 (MTR 21-3, 21 FW PMP) and verify breaker open. At BUS 22 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 22-3 (MTR 22-3, 22 FW PMP) and verify breaker open. At BUS 25 in Fire Area 117, verify BKR 25-10 (MTR 25-10, 21 MD AFW PMP) is open.

De-energize MV-32246 at MCC 2A2, BKR 221E-11, located in Fire Area 031. When the AFW pump suction pressure reaches 4" Hg (PI-11081), de-energize MV-32030 at MCC 2A2, BKR 221E-6 (CLG WTR TO 22 TD AFW PMP SUCT), located in Fire Area 031.

De-energize MV-32345 at MCC 2A2, BKR 221E-5, located in Fire Area 031. De-energize MV-32022 at MCC 2B1 (BKR 251-6) located in Fire Area 070.

Manually close MV-32022 in Fire Area 070 to isolate Main Steam flow. De-energize MV-32021 at MCC 2B1 (BKR 251-5) located in Fire Area 070. Manually close MV-32021 in Fire Area 070 to isolate Main Steam flow. De-energize MV-32019 at MCC 2K1, BKR 211J-13, located in Fire Area 073. Verify open MV-32019 in Fire Area 075. De-energize MV-32020 at BKR 221J-13 at MCC 2K2, located in Fire Area 073. Manually close MV-32020 in Fire Area 075 to isolate the non-credited steam generator. Manually open MV-32030, 22 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. Manually throttle MV-32246 (22 AFW TO 21 SG MV) in Fire Area 031 as necessary to control AFW flow. Manually close MV-32249 in Fire Area 075 to support isolation of the non-credited steam generator (22 SG). Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 58 Verify open MV-32246 in Fire Area 031.

Verify open MV-32345 in Fire Area 031. When the AFW pump suction pressure reaches 4" Hg (PI-11081), verify MV-32030 (22 TD AFW PMP SUCT CL SPLY MV) open; then manually close MV-32345 in Fire Area 031 to isolate the CST supply to 245-201 (22 TD AFW PMP) suction. 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 04 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems. Components and Cables: Many

This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems at the Primary Control Station. Disposition Recovery Action(s): Place CV-31654 in emergency at local panel 70383 in Fire Area 041A to provide strainer backwash for 21 CLG WTR STRNR.

Put local control for the DDCLPs near the HSD Panel (Table S-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 action and plant modifications credited. VFDR-013 05 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation. 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 Instrumentation.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 59 Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation at the Primary Control Station. Disposition Recovery Action: LOOP 2L-433 (local indicator 2LI-433C) remains available in Fire Area 073 to provide pressurizer level indication for local control of charging pump flow. 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-013 06 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power at the Primary Control Station. Disposition Recovery Action(s): Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-13 is open. Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-16 is open. Verify D5 Diesel running and ensure all loads are stripped from BUS 25. Manually close BKR 25-2 (BUS 25 SOURCE FROM D5 DSL GEN) at BUS 25 in Fire Area 117 by pulling the manual CLOSURE lever with the hot stick. Verify D5 Diesel running and manually close BKR 25-6 at BUS 25 in Fire Area 117. Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-5 is open. Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Diesel Gen Benchboard. Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Vertical Panel. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 60 At D5 Diesel Gen Benchboard, place BUS 25 BKR SEL Switch in "LOCAL."

De-energize DC control power to BUS 25 at PNL 27, breaker 27-1, located in Fire Area 107. Obtain switching protective equipment and the 4 ft. hot stick from the Appendix R Switching Equipment cabinet (in hallway outside 25 Bus Room). Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. 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 S L E R D Notes Detection 57 Ionization N N N Y Y Area wide and under raised floor Suppression - - - - - - - 13 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 61 Unit Fire Area Description 1 14 Working Material, Lunch Room Regulatory Basis 4.2.3.2 - Deterministic Approach Note: 20 foot separation with no intervening combustibles between fire areas 8 and 14 with suppression and detection (Table S-2). 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 62 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 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-058, NFPA 13, 1989 Code Compliance Deviations, WPS-25 Summary The purpose of this analysis is to document the review of the WPS-25 wet pipe sprinkler system protecting the Working Materials, Lunch Room, Fire Area 14, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Eight deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with valve position verification, securing valves in the open position, partial installations, and obstructions due to ducts. An Action Request has been initiated to track resolutions of the identified issues. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 63 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 15 Ionization Y N N N N Suppression WPS-25 Wet Pipe Y N N N N 14 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 in a Change Evaluation 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 s 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 64 Unit Fire Area Description 1 15 Access Control Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 65 Unit 1 - CC Train A or B Unit 2 - CC Train A or B CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-055, NFPA 13, 1989 Code Compliance Deviations, WPS-20 Summary The purpose of this analysis is to document the review of the WPS-20 wet pipe sprinkler systems protecting Access Control in the Unit 1 Auxiliary Building, elevation 715ft, Fire Area 15, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems. Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Three Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 66 deviations require additional actions to resolve the noncompliance associated with incomplete drawings for the system, the inadequate size of the supply line servicing more sprinklers than allowed for a pipe schedule system, and pendent heads without return bends in Fire Area 15, Access Control, that is protected by WPS-20. An Action Request has been initiated to track resolution of the three identified issues. EEEE Title AR 1352782, 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 S L E R D Notes Detection 17 Ionization N N N N N Suppression WPS-20 Wet Pipe N N N N N 15 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 67 Unit Fire Area Description 2 16 Train B Event Monitoring Equipment Room Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 68 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 50 Ionization N N N N N Suppression - - - - - - - 16 Feature - - - - - - - Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 69 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 70 Unit Fire Area Description 2 17 Unit 2 Normal Switchgear Room & Control Rod Drive Room Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 71 (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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 72 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 88 Ionization N N N N N Suppression - - - - - - - 17 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 73 Unit Fire Area Description 1, 2 18 Relay and Cable Spreading Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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: 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 redundant train remains available. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 74 (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 (Train B) Train A or B RCS Head Vents or Pressurizer Vents. Unit 2 - Charging System (Train A) or Safety Injection (Train B) Train A or B RCS Head Vents or Pressurizer Vents. Reactivity Control 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 Emergency Diesel Generator supplying Electrical Distribution Train A Unit 2 - Offsite Power or supplying Electrical Distribution Trains A or B, or D5 Emergency Diesel Generators supplying Electrical Distribution Train A Unit 1 CC Train A or B Unit 2 CC Train A or B CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 20729, Fire Risk Evaluation, Fire Area 18, Relay & Cable Spreading Room, Unit 1 & 2, Rev 0, September, 2012. Licensing Actions None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 75 Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-038, NFPA 12 - 1972, Standard on Carbon Dioxide Extinguishing Systems Summary The purpose of this analysis is to document the review of the Carbon Dioxide (C02) system for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 12 1972, Standard on Carbon Dioxide Extinguishing Systems (Code of Record). One deviation was identified to the code requirements. The existing deviation is acceptable as-is. Two deviations require additional actions to resolve the noncompliance associated with the quantities of CO2 required to achieve and maintain a 50% concentration for 15 minutes with sufficient gas for a second shot, taking into account the level indicator calibration tolerance. Action requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. 6.4 Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 76 Variances from Deterministic Requirements (VFDR) VFDR-018 01 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant equipment to perform the Nuclear Safety Performance Criteria for Reactivity Control. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31200 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe and stable. Manually trip Unit 1 Main Turbine at the front standard in Fire Area 008.

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 credited. VFDR-018 02 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control at the Primary Control Station. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 77 Disposition Recovery Action(s): Manually close VC 8 after opening VC 1 in Fire Area 058 for VCT isolation. Prior to starting MTR 111J-1, manually close VC-14-1 (11 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals.

Prior to starting MTR 111J-1, manually close VC-14-2 (12 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals. Verify open or manually trip BKR 112C at BUS 112 in Fire Area 079 to de-energize MCC 1S1 and mitigate spurious operation of PZR Heater Group A. Verify open or manually trip BKR 122C at BUS 122 in Fire Area 082 to de-energize MCC 1R1 and mitigate spurious operation of PZR Heater Group B. At BUS 16 in Fire Area 020, open DC Knife switches (located inside breaker cubicles) for BKR 16-1 (12 CS PMP) and verify breaker open.

Verify open or manually trip BKR 180-183 at BUS 180 in Fire Area 011 to de-energize MCC 1P1 and mitigate spurious operation of PZR Heater Group C. Verify open or manually trip BKR 180-184 at BUS 180 in Fire Area 011 to de-energize MCC 1P2 and mitigate spurious operation of PZR Heater Group D. Verify open or manually trip BKR 180-182 at BUS 180 in Fire Area 011 to de-energize MCC 1R2 and mitigate spurious operation of PZR Heater Group E.

Prior to starting MTR 111J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31198 in the required open position. De-energize MV-32077 at MCC 1A1, BKR 111E-9, located in Fire Area 032. De-energize MV-32078 at MCC 1A2, BKR 121E-9, located in Fire Area 032. De-energize MV-32075 at MCC 1K1, BKR 111J-8, located in Fire Area 058. Manually trip MTR 121J-1 (11 CHG PMP) at MCC 1K2, BKR 121J-1, in Fire Area 058. De-energize MV-32076 at MCC 1KA2, BKR 121B-28, located in Fire Area 058. De-energize MV-32166 at MCC 1L1, BKR 112E-6, located in Fire Area 059. Take local control of MTR 111J-1, 12 charging pump at panel 70810 by placing CS-7081001 in "LOCAL" and pressing CS-7081002 once to energize the VFD and a second time to start the 12 charging pump at the local panel in 12 charging pump room in Fire Area 058 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 78 Manually operate MTR 111J-1 (12 CHARGING PUMP) at the VFD panel by MCC 1K1 in Fire Area 058 by placing the LOC/REM SEL SW in the "LOCAL" position. Prior to starting MTR 111J-1, manually close MV-32166 in Fire Area 085. De-energize PNL 171 at PNL 11, breaker 11-8, located in Fire Area 033 in order to fail CV-31232 closed. This action will fail all components powered from PNL 171 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 181 at PNL 12, breaker 12-8, located in Fire Area 034 in order to fail CV-31231 closed. This action will fail all components powered from PNL 181 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail CV-31226 closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31330 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe and stable. Manually open VC 1 in Fire Area 058 to align RWST supply to charging pump suction. Time constraint to open VC 1 before starting charging pump. Seal Modification will resolve this issue of losing all water to RCP seals (Table S-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 and a plant modification credited. VFDR-018 03 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 79 Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe and stable. FI-18032 (11 TD AFW PMP DISCH FI) remains available in Fire Area 032 to provide local AFW flow indication. Manually start 11 TDAFWP by verifying that the lube oil pump is running and placing AF-292-1, 11 TD AFW PMP MN STM SPLY CV-31998 ROOT ISOL, in the "OPEN" position. At BUS 11 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 11-3 (MTR 11-3, 11 FW PMP) and verify breaker open. At BUS 12 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 12-3 (MTR 12-3, 12 FW PMP) and verify breaker open.

At BUS 16 in Fire Area 020, open DC knife switches (located inside breaker cubicles) for BKR 16-3 (MTR 16-3, 12 MD AFW PMP) and verify breaker open. De-energize MV-32238 at MCC 1A1, BKR 111-17, located in Fire Area 032.

When the AFW pump suction pressure reaches 4" Hg (PI-11054), de-energize MV-32025 at MCC 1A1, BKR 111E-1 (11 TD AFW PMP SUCT CLG WTR SPLY MV-32025), located in Fire Area 032. De-energize MV-32333 at MCC 1A1, 111E-4, located in Fire Area 032. De-energize MV-32006 at MCC 1B1 (BKR 151-5) located in Fire Area 069. Manually close MV-32006 in Fire Area 069 to isolate Main Steam flow. De-energize MV-32010 at MCC 1B1 (BKR 151-6) located in Fire Area 069. Manually close MV-32010 in Fire Area 069 to isolate Main Steam flow. De-energize MV-32016 at BKR 1K1-H2 at MCC 1K1, located in Fire Area 058. Verify open MV-32016 in Fire Area 060. De-energize MV-32017 at BKR 1K2-D4 at MCC 1K2, located in Fire Area 058. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 80 Manually close MV-32017 in Fire Area 060 to isolate the non-credited steam generator.

Manually open MV-32025, 11 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. Manually throttle MV-32238 (11 AFW TO 11 SG MV) in Fire Area 032 as necessary to control AFW flow.

Manually close MV-32243 in Fire Area 060 to support isolation of the non-credited steam generator (12 SG). Verify open MV-32238 in Fire Area 032.

Verify open MV-32333 in Fire Area 032. 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 04 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems Components and Cables: Many

This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems at the Primary Control Station. Disposition Recovery Action(s): Modify D1 to ensure cooling water is available to D1 (Table S-2).

Put local control for the DDCLPs near the HSD Panel (Table S-2). Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 81 VFDR-018 05 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation.

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 Instrumentation. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation at the Primary Control Station. Disposition Recovery Action: LOOP 1L-433 (local indicator 1LI-433C) remains available in Fire Area 058 to provide pressurizer level indication for local control of charging pump flow. 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-018 06 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power at the Primary Control Station. Disposition Recovery Action(s): Stop D1 DSL GEN if running with inadequate cooling water pressure. Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-3 is open.

Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-7 is open. Verify D1 Diesel running and ensure all loads are stripped from BUS 15. Manually close BKR 15-2 (BUS 15 SOURCE FROM D1 DSL GEN) at BUS 15 in Fire Area 081 by pulling the manual CLOSURE lever with the hot stick. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 82 On the front panel of BKR 15-11, BUS 15 FEED TO 111M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position.

Verify D1 Diesel running and manually close BKR 15-11 at BUS 15 in Fire Area 081. On the front panel of BKR 15-6, BUS 15 FEED TO 112M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position.

Verify D1 Diesel running and manually close BKR 15-6 at BUS 15 in Fire Area 081. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 by opening Metering CT Switches (six knife switches) for remote metering. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the DIESEL GENERATOR GAUGE PANEL. PI-55001 (D1 DSL GEN RAW WATER PI) remains available in Fire Area 025 to provide local indication of CL header pressure. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 DIESEL GENERATOR PANEL. Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 REMOTE CONTROL ISOLATION PANEL. De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033. De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033 and verify breaker 15-6 is closed.

Obtain switching protective equipment and the 4 ft. hot stick from the Bus 13/14 Room Appendix R cabinet. Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. 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 01 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant equipment to perform the Nuclear Safety Performance Criteria for Reactivity Control. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Reactivity Control at the Primary Control Station.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 83 Disposition Recovery Action(s): De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31213 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable. Manually trip Unit 2 Main Turbine at the front standard in Fire Area 008.

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 credited. VFDR-018 02 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Inventory Control at the Primary Control Station. Disposition Recovery Action(s): Manually open 2VC 1 in Fire Area 073 to establish RWST supply to charging suction. Time constraint to open 2VC 1 before starting charging pump.

Manually close 2VC 8 after opening 2VC 1 in Fire Area 073 to establish VCT isolation from charging suction. Prior to starting MTR 211J-1, manually close 2VC-14-1 (21 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals.

Prior to starting MTR 211J-1, manually close 2VC-14-2 (22 RC PMP SEAL INJECTION THROTTLE VLV) in Fire Area 085 to prevent thermal shock to the RCP seals. Verify open or manually trip BKR 212C at BUS 212 in Fire Area 127 to de-energize MCC 2S1 and mitigate spurious operation of PZR Heater Group A. Verify open or manually trip BKR 222C at BUS 222 in Fire Area 122 to de-energize MCC 2R1 and mitigate spurious operation of PZR Heater Group B. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 84 At BUS 26 in Fire Area 118, open DC Knife switches (located inside breaker cubicles) for BKR 26-9 (22 CS PMP) and verify breaker open. Verify open or manually trip BKR 270-273 at BUS 270 in Fire Area 017 to de-energize MCC 2P1 and mitigate spurious operation of PZR Heater Group C.

Verify open or manually trip BKR 270-274 at BUS 270 in Fire Area 017 to de-energize MCC 2P2 and mitigate spurious operation of PZR Heater Group D. Verify open or manually trip BKR 270-272 at BUS 270 in Fire Area 017 to de-energize MCC 2R2 and mitigate spurious operation of PZR Heater Group E. Prior to starting MTR 211J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31211 in the required open position. De-energize MV-32180 at MCC 2A1, BKR 211E-9, located in Fire Area 031. De-energize MV-32181 at MCC 2A2, BKR 221E-9, located in Fire Area 031. De-energize MV-32178 at MCC 2K1, BKR 211J-8, located in Fire Area 073. Manually trip MTR 221J-1 (21 CHG PMP) at MCC 2K2, BKR 221J-1, in Fire Area 073.

De-energize MV-32179 at MCC 2KA2, BKR 221B-28, located in Fire Area 073. De-energize MV-32194 at MCC 2L1, BKR 212E-6, located in Fire Area 074.

Manually operate MTR 211J-1 (22 CHARGING PUMP) at the local panel in Fire Area 073 by placing the LOC/REM SEL switch, CS-7082001 in the "LOCAL" position. Then ENERGIZE the VFD by momentarily depressing the START pushbutton, CS-7082002. Then START the 22 CHARGING PUMP by momentarily depressing CS-7082002.

Switch 22 charging pump local/remote switch to the "LOCAL" position at 22 Charging pump VFD cabinet next to MCC 2K1 in Fire Area 073. Prior to starting MTR 211J-1, manually close MV-32194 in Fire Area 085. De-energize PNL 271 at PNL 21, breaker 21-10, located in Fire Area 035 in order to fail CV-31234 closed. This action will fail all components powered from PNL 271 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 281 at PNL 22, breaker 22-10, located in Fire Area 036 in order to fail CV-31233 closed. This action will fail all components powered from PNL 281 to their loss of power position, which will not adversely affect safe and stable. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 85 De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31230 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable. De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31422 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe and stable.

De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect safe and stable.

Modification for Charging Pump Suction Trip will resolve MSO issue (Table S-2). Seal Modification will resolve the issue of losing all RCP seal cooling (Table S-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 and plant modifications credited. VFDR-018 03 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Decay Heat Removal at the Primary Control Station. Disposition Recovery Action(s): De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect safe and stable. FI-18035 (22 TD AFW PMP DISCH FI) remains available in Fire Area 031 to provide local AFW flow indication. Manually start 22 TDAFWP by verifying that the lube oil pump is running and placing 2AF-292-1, 22 TD AFW PMP MN STM SPLY CV-31999 ROOT ISOL, in the "OPEN" position.

At BUS 21 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 21-3 (MTR 21-3, 21 FW PMP) and verify breaker open. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 86 At BUS 22 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 22-3 (MTR 22-3, 22 FW PMP) and verify breaker open. At BUS 25 in Fire Area 117, verify BKR 25-10 (MTR 25-10, 21 MD AFW PMP) is open. De-energize MV-32246 at MCC 2A2, BKR 221E-11, located in Fire Area 031. When the AFW pump suction pressure reaches 4" Hg (PI-11081), de-energize MV-32030 at MCC 2A2, BKR 221E-6 (CLG WTR TO 22 TD AFW PMP SUCT), located in Fire Area 031.

De-energize MV-32345 at MCC 2A2, BKR 221E-5, located in Fire Area 031. De-energize MV-32022 at MCC 2B1 (BKR 251-6) located in Fire Area 070.

Manually close MV-32022 in Fire Area 070 to isolate Main Steam flow. De-energize MV-32021 at MCC 2B1 (BKR 251-5) located in Fire Area 070.

Manually close MV-32021 in Fire Area 070 to isolate Main Steam flow. De-energize MV-32019 at MCC 2K1, BKR 211J-13, located in Fire Area 073.

Verify open MV-32019 in Fire Area 075. De-energize MV-32020 at BKR 221J-13 at MCC 2K2, located in Fire Area 073. Manually close MV-32020 in Fire Area 075 to isolate the non-credited steam generator. Manually open MV-32030, 22 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. Manually throttle MV-32246 (22 AFW TO 21 SG MV) in Fire Area 031 as necessary to control AFW flow. Manually close MV-32249 in Fire Area 075 to support isolation of the non-credited steam generator (22 SG). Verify open MV-32246 in Fire Area 031. Verify open MV-32345 in Fire Area 031. When the AFW pump suction pressure reaches 4" Hg (PI-11081), verify MV-32030 (22 TD AFW PMP SUCT CL SPLY MV) open; then manually close MV-32345 in Fire Area 031 to isolate the CST supply to 245-201 (22 TD AFW PMP) suction. 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 87 VFDR-018 04 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems. Components and Cables: Many

This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital Auxiliary Systems at the Primary Control Station. Disposition Recovery Action(s): Place CV-31654 in emergency at local panel 70383 in Fire Area 041A to provide strainer backwash for 21 CLG WTR STRNR.

Put local control for the DDCLPs near the HSD Panel (Table S-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 action and plant modifications credited. VFDR-018 05 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation. 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 Instrumentation. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Instrumentation at the Primary Control Station. Disposition Recovery Action: LOOP 2L-433 (local indicator 2LI-433C) remains available in Fire Area 073 to provide pressurizer level indication for local control of charging pump flow. 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 88 VFDR-018 06 This variance from the deterministic requirements results from fire induced damage that affects both divisions of equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power. Components and Cables: Many This represents a variation from the deterministic requirements (VFDR) 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. Compliant Case: Ability to operate equipment required to perform the Nuclear Safety Performance Criteria for Vital AC Power at the Primary Control Station. Disposition Recovery Action(s): Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-13 is open. Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-16 is open. Verify D5 Diesel running and ensure all loads are stripped from BUS 25. Manually close BKR 25-2 (BUS 25 SOURCE FROM D5 DSL GEN) at BUS 25 in Fire Area 117 by pulling the manual CLOSURE lever with the hot stick. Verify D5 Diesel running and manually close BKR 25-6 at BUS 25 in Fire Area 117.

Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-5 is open. Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Diesel Gen Benchboard.

Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Vertical Panel. At D5 Diesel Gen Benchboard, place BUS 25 BKR SEL Switch in "LOCAL."

De-energize DC control power to BUS 25 at PNL 27, breaker 27-1, located in Fire Area 107. Obtain switching protective equipment and the 4 ft. hot stick from the Appendix R Switching Equipment cabinet (in hallway outside 25 Bus Room). Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear.

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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 89 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 12, 14 Ionization, Thermal N N N Y Y Suppression CO2 N N N Y Y Total Flooding 18 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 in a Change Evaluation 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. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 90 Unit Fire Area Description 1 20 Unit 1, 4.16 kV Safeguards Switchgear (Bus 16) Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments Decay Heat Removal (HSB) Hot: Unit 1 - 11 TDAFW to 11 SG Unit 2 - 22 TDAFW or 21 MDAFW Pump to 21 SG or 22 SG See VFDR020 06 See VFDR020 07 See VFDR020 08 See VFDR020 09 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-427) 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 See VFDR020 03 See VFDR020 04 See VFDR020 05 Inventory and Pressure Control Unit 1 - Charging System (Train A) Unit 2 - Charging System (Train A) or Safety Injection System (Train B) See VFDR020 02 Reactivity Control Unit 1 - Trip reactor from the Control Room. Use Charging Pump to inject borated Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 91 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 - D1 supplying Electrical Distribution Train A Unit 2 - Offsite Power (2RY) supplying Electrical Distribution Train A or B Unit 1 - CC Train A Unit 2 - CC Train A or B CL Train A or B Compressed Air System Train A Control Room and Relay Room HVAC Train A See VFDR020 01 Reference Documents Safe/Genesis V 4.0.2 EC 20720, Fire Risk Evaluation, Fire Area 20, Unit 1, 4.16kV Safeguards Switchgear (Bus 16), Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 92 penetrations above two rated doors, doors that would not close under airflow, and two sets of door combinations without positive latching. Each deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-020 01 This Variance From Deterministic Requirements is caused by fire damage to Bus 16 and cables that could affect operation of Bus 15. Fire could damage the 1RY bus duct that supplies offsite power to Bus 15 and Bus 16. Fire could also damage a cable affecting the CT 11 offsite power supply to Bus 15 and Bus 16. Fire damage could cause loss of remote control and spurious operation of BKR 15-3 (1RY Offsite Source to 4.16KV Bus 15) that prevents D1 from powering Bus 15. Local manual action is required in order to open BKR 15-3 so that Bus 15 can be repowered from the D1 Emergency Diesel Generator. Fire damage could prevent the Load Sequencer from automatically re-powering Bus 15. If RCP seal cooling is not restored within 15 minutes, seal leakage could increase. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3 lack of separation between redundant trains of safeguards AC power. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries AC power. Components and Cables: 1RY Bus Duct to BUS 15/16 16408 CT11 source to BUS 15/16

BKR 15-3 (1C-419) BUS 15 Load Sequencer (1C-6354) The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries AC power. Compliant Case: Train "A" safeguards power should remain unaffected by fire. Disposition Recovery Action(s): No recovery actions. Modification to move subject conductors of cable 1C-419 to cable 15403-B (which is not routed in FA 20) to eliminate the concern (Table S-2).

Modification to provide separate potential transformers for indication to the Load Sequencer so the Load Sequencer will function properly to automatically re-power Bus 15 (Table S-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 plant modifications. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 93 VFDR-020 02 This Variance From Deterministic Requirements is caused by fire damage which causes loss of the normal power feed from 13 Inverter to 120VAC Panel 113. Loss of Panel 113 causes CV-31198 (Charging Line to 11 Regenerative Heat Exchanger CV) to fail open causing diversion of flow from RCP seal injection to charging. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 13 Inverter to 120 VAC Panel 113 (1CX-99) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of RCP seal cooling. Compliant Case: Control of CV-31198 should remain available from the Control Room. Recovery Action(s): No recovery actions.

Modification to protect load sequencer so CC to the RCP THBX remains available by restoring power to Bus 15 (Table S-2). VFDR-020 03 This Variance From Deterministic Requirements is caused by fire damage which causes loss of the normal power feed from 13 Inverter to Panel 113. Loss of Panel 113 causes loss of Control Room indication for instrument Loops 1N51 (Unit 1 Excore Detection Train A), 1T-450A (Unit 1 RCS Loop A Hot Leg Temperature) and 1T-450B (Unit 1 RCS Loop A Cold Leg Temperature). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring. Components and Cables: 13 Inverter to 120 VAC Panel 113 (1CX-99)

This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 94 Compliant Case: One train of Process monitoring instrumentation should remain functional in the Control Room. Disposition Recovery Action(s): No recovery actions. Modification to protect 1CX-99 from a fire in this area, so one train of process monitoring will remain available (Table S-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 plant modifications. VFDR-020 05 This Variance From Deterministic Requirements is caused by fire damage to cable 1CW-99, which causes loss of the normal power feed from 11 Inverter to Panel 111. Loss of Panel 111 results in the loss of Control Room indication for instrument Loop 1L-487 (11 SG Wide Range Level) displayed on Level Recorder 1LR-470. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring. Components and Cables: Panel 111, Instrument Bus II, (1CW-99) 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring. Compliant Case: One train of Process monitoring instrumentation should remain functional in the Control Room. Disposition Recovery Action(s): No recovery actions. Modification to protect 1CW-99 from a fire in this area. One train of process monitoring will remain available (Table S-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 plant modifications. VFDR-020 06 This Variance From Deterministic Requirements is caused by fire damage to cables for Bus 11 and Bus 12 that prevent tripping the 11 and 12 Main Feedwater Pumps which could cause an over-fill of the steam generators. Damage to cables 1DCA-4 and Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 95 1DCB-18 would prevent crediting the Main Feedwater Regulating Valves. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. The NFPA Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Components and Cables: 12 FW Pump, MTR 12-3 (12403-B, 12403-U) BUS 11 (11402-B) BUS 12 (12402-B, 12403-B, 12403-D, 12403-U) CV-31127 (1DCA-4, 1DCB-18) CV-31128 (1DCA-4, 1DCB-18) CV-31369 (1DCA-4, 1DCB-18) CV-31370 (1DCA-4, 1DCB-18) 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring. Compliant Case: Control for 12 Main Feedwater Pump (MTR 12-3) should remain available from the Control Room. Control of 11 Main Feedwater Pump (MTR 11-3) should remain available from the Control Room. Disposition Recovery Action(s): No recovery actions. Modification to re-route cable 1DCA-4 out of FA 20 (similar to cable 1CX-99, and, 1CW-99) to ensure automatic main feedwater isolation can be credited (Table S-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 a plant modification. VFDR-020 07 This Variance From Deterministic Requirements is caused by fire damage to cables 16403-A, 16403-C, 16403-D, 16403-E and 1CB-16 causing a spurious start of 12 AFW Pump (MTR 16-3). This can result in SG overfill and failure of the credited 11 Turbine-driven AFW Pump. Components and Cables: MTR 16-3 (16403-A, 16403-C, 16403-D, 16403-E and 1CB-16). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3, due to lack of separation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 96 between redundant trains of decay heat removal due to over-fill of steam generator. The NFPA Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Compliant Case: Control of 12 AFW Pump (MTR 16-3) should be available from the Control Room. Disposition Recovery Action(s): Throttle MV-32238 and MV-32239 from the control room to prevent SG over-fill if 12 MDAFW Pump is spuriously running. De-energize MV-32381 (12 MD AFW Pump Discharge to 11 SG MV) at MCC 1A2, BKR 121E-17 in FA-32. De-energize MV-32382 (12 MD AFW Pump Discharge to 12 SG MV) at MCC 1A2, BKR 121E-18 in FA-32. Locally close MV-32381 and MV-32382 in FA-32 to isolate the uncontrolled feed to 11 and 12 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. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 11 Ionization N N N N Y Suppression - - - - - - - 20 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 97 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 98 Unit Fire Area Description 1 21 Unit 1, 4.16 kV Normal Switchgear (Bus 13, 14) See Fire Area 8 None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 99 Unit Fire Area Description 1 22 480 V Safeguards Switchgear (Bus 121) Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 VFDR-22 01 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 Unit 2 - Offsite Power supplying Electrical Distribution Train A VFDR-22 01 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 100 Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Compressed Air System Train A Control Room and Relay Room HVAC (Train A) Reference Documents Safe/Genesis V 4.0.2 EC 20721, Fire Risk Evaluation, Fire Area 22, 480V Safeguards Switchgear (Bus 121), Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 101 Variances from Deterministic Requirements (VFDR) VFDR-022 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers, due to fire damage to cable 1CB-374. This could fail the function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage to control cable 1CB-374 affects components CV-31652, CV-31653, CV-31654, CV-31655, MTR-111C-21, MTR-111C-22, MTR-121C-21 and MTR-121C-22. Damage to cable 1CB-374 causes a loss of automatic backwash capability for all CL Strainers when the strainers are in the Normal Control Mode. Loss of automatic backwash capability for cooling water strainers MTR-111C-21 and 111C-22 can result in the loss of cooling water to the credited A Loop header. One strainer with automatic backwash capability is required per cooling water loop header. The A Loop header is credited to supply cooling water to the necessary Unit 1 and Unit 2 systems since the credited 12 CL pump supplies this header. The 12 Diesel Driven Cooling Water Pump (DDCLP) is isolated from the non-credited B Loop header from the Control Room. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. 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) 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. Compliant Case: The ability to automatically backwash the cooling water strainers should remain unaffected by a fire. Disposition Recovery Action(s): An operator action is required to switch the 11 strainer from Normal Control mode to the Emergency Control mode (F5 App D). This action must be performed locally in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainer, and avoid loss of the CL system.

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 actions credited. VFDR-022 01 This Variance From Deterministic Requirements is caused by fire damage to cable 1CB-16 causing a spurious start of 12 AFW Pump (MTR 16-3). This can result in SG overfill and failure of the credited 11 Turbine-driven AFW Pump. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 102 This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal. Components and Cables: 1CB-16 This condition would challenge the Nuclear Safety Performance Criteria for Decay Heat Removal. 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 decay heat removal due to over-fill of steam generator. Compliant Case: Control of 12 MDAFW Pump (MTR 16-3) should be available from the Control Room. Disposition Recovery Action(s): Locally close MV-32381 and MV-32382 in FA-32 to isolate the uncontrolled feed to 11 and 12 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 a recovery action credited.

Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 43 Ionization N N N N Y Suppression - - - - - - - 22 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 103 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 104 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 105 Unit Fire Area Description 1, 2 24 Oil Storage Area Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 106 (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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-004, NFPA 13, 1969 Code Compliance Deviations, DA-2 Summary The purpose of this analysis is to document the review of the DA-2 automatic deluge suppression system protecting the Turbine Oil Storage Room against the requirements of National Fire Protection Association 13, (NFPA) - 1969, Standard for the Installation of Sprinkler Systems. Three deviations from the criteria of the code have been identified. All three have been determined to be acceptable as is based on meeting the intent of the criteria. No further actions are required. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 107 during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 4 Ionization, Flame, Heat N N N N Y Oil Storage Room, High Combustible Loading Suppression DA-2 Deluge N N N N Y Oil Storage Room, High Combustible Loading 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 108 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 109 Unit Fire Area Description 1 25 Diesel Generator 1 Room Regulatory Basis 4.2.3.3 - 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 110 (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) 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 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B VFDR-025 01 Reference Documents EC 20709, Fire Risk Evaluation, Fire Area 25, Diesel Generator 1 Room, Rev. 0, September 2012 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 111 EEEE Title FPEE-11-039, NFPA 13, 1969 Code Compliance Deviations, PA-1 DG- 1 & 2 Summary The purpose of this analysis is to document the review of the D1 & D2 rooms' Pre-Action system for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Fourteen deviations have been justified as "acceptable"; therefore, no further action is necessary. EEEE Title AR 1352782, 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-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-025 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21, and 22 Cooling Water (CL) Strainers, due to fire damage to cables. Fire damage could potentially cause spurious closure of BKR 15-2 which would close the faulted D1 Emergency Diesel Generator onto 4.16KV Bus 15 resulting in a Bus 15 lockout, or an out of phase parallel of the D1 DSL GEN, 034-011, and Bus 15. Bus 15 is the ultimate power source for 230V Panel 136 which provides the control power to the backwash control panel for all four of the CL Strainers when they are in the Normal Control Mode of backwash operation. Loss of Panel 136 results in the loss of automatic backwash control for all four CL Strainers. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: BKR 15-2, (15402-G, 15402-1, 15402-K, 1CA-1140, 1CA-1141, 1CA-1142) D1 DSL GEN, 034-011 (1CA-1312) (Reference Safe/Genesis V 4.0.2 for additional affected cables). Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 112 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. Compliant Case: The ability to automatically backwash the CL Strainers should be available, to ensure strainer plugging is alleviated so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): No recovery action credited. Modification to protect BUS-15 (Table S-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 a plant modification credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 82 Ionization, Heat, Flame N N N N Y Diesel Fuel Day Tank, High Combustible Loading Suppression PA-1 Pre-Action N N N N Y Diesel Fuel Day Tank, High Combustible Loading 25 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 in a Change Evaluation 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 113 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 114 Unit Fire Area Description 1 26 Diesel Generator 2 Room Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 115 (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 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-039, NFPA 13, 1969 Code Compliance Deviations, PA-1 DG- 1 & 2 Summary The purpose of this analysis is to document the review of the D1 & D2 rooms' Pre-Action system for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Fourteen deviations have been justified as "acceptable"; therefore, no further action is necessary. EEEE Title AR 1352782, 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 116 EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 6 Ionization, Heat, Flame N N N N Y Diesel Fuel Day Tank, High Combustible Loading Suppression PA-1 Pre-Action N N N N Y Diesel Fuel Day Tank, High Combustible Loading 26 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 117 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 118 Unit Fire Area Description 1 27 Water Conditioning Equipment Area Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 119 (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 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 120 EEEE Title FPEE-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair. Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 4 Ionization N N N N N Suppression WPS-9 Wet Pipe N N N N N Suppression SWP-6 Wet Pipe N N N N N Stairwell System 27 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 121 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 122 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 123 (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) 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 124 Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-059, NFPA 15, 1969 Code Compliance Deviations, DM-1, Transformer 1GT Deluge, DM- 2, Transformer 1M Deluge, DM- 3, Transformer 1R Deluge, DM-4, Transformer 2M Deluge, DM-5, Transformer 2GT Deluge Summary The purpose of this analysis is to document the review of the DM-1, DM-2, DM-3, DM-4 and DM-5 manual deluge systems protecting yard transformers 1GT, 1M, 1R, 2M and 2GT against the requirements of National Fire Protection Association 15, (NFPA) -1969, Standard for Water Spray Fixed Systems for Fire Protection. Seven deviations from the criteria of the code have been identified. All seven have been determined to be acceptable as is based on meeting the intent of the criteria. No further actions are required. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-007, NFPA 15, 1969 Code Compliance Deviations, DM-6, Transformer 2RX, 2RY Deluge Summary The purpose of this analysis is to document the review of the DM-6 manual deluge system protecting yard transformers 2RX and 2RY against the requirements of National Fire Protection Association 15, (NFPA) -1977, Standard for Water Spray Fixed Systems for Fire Protection Four deviations from the criteria of the code have been identified. Two have been determined to be acceptable as is based on meeting the intent of the criteria. One requires the performance of hydraulic calculations for FP systems. Variances from Deterministic Requirements (VFDR) None

Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 58 HAD N N N N N Suppression DM-1 Deluge N N N N N Manual Actuation 28a Feature - - - - - - - Detection 60 HAD N N N N N Suppression DM-5 Deluge N N N N N Manual actuation 28b Feature - - - - - - - Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 125 Detection 62 HAD N N N N N Suppression DM-3 Deluge N N N N N Manual activation 28c Feature - - - - - - - Detection 59 HAD N N N N N Suppression DM-2 Deluge N N N N N Manual activation 28d Feature - - - - - - - Detection 61 HAD N N N N N Suppression DM-4 Deluge N N N N N Manual activation 28e Feature - - - - - - - Detection 96 HAD N N N N N 28f 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 in a Change Evaluation 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. Fire Area Comments Note: Fire Area 28 a - f is now combined into Fire Area 28. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 126 Unit Fire Area Description 1 29 Administration Building Elect & Piping Room #1 Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 127 (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 supplying Electrical Distribution Trains A and B Unit 2 - Offsite Power supplying Electrical Distribution Trains A and B Unit 1 - CC Train B Unit 2 - CC Train B CL Train B Compressed Air System Train B Control Room and Relay Room HVAC Train B VFDR-029 01 Reference Documents Safe/Genesis V 4.0.2 EC 20710, Fire Risk Evaluation, Fire Area 29, Administration Building Elect & Piping Room # 1, Rev. 0, September 2012 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 128 EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-029 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers, due to fire damage to cables. This could fail the function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage to control cable 1CA-529 affects components CV-31654, CV-31655, MTR-111C-22, MTR-121C-22. Loss of the cooling water strainers MTR-121C-22 and MTR-111C-22 results in the loss of cooling water to the B Loop header. One strainer is required per cooling water loop header. The B loop header is credited to supply cooling water to the necessary systems since the ability to isolate the loop is available. 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 condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. 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)

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 129 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 condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Compliant Case: The ability to automatically backwash the cooling water strainers should be available to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): A recovery action is required to switch the 22 CL Strainer from Normal Control mode to the Emergency Control mode in order to restore automatic backwash capability. This action must be performed locally in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited. A modification to install a fire door between Fire Area 29 and Fire Area 69 will ensure Cooling Water availability to support operation of D1 for a fire in FA 69. This will ensure compliance with deterministic requirements for D1 Diesel Generator in Fire Area 69 (See Attachment S, Table S-2). Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 4 Ionization N N N N Y Suppression - - - - - - - 29 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 130 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 131 Unit Fire Area Description 2 30 Administration Building Elect & Piping Room #2 Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 132 (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) 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 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Trains A and B 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 Compressed Air System Train A Control Room and Relay Room HVAC (Train A) VFDR-030 01 Reference Documents Safe/Genesis V 4.0.2 EC 20711, Fire Risk Evaluation, Fire Area 30, Administration Building Elect & Piping Room # 2, Rev. 0, September 2012 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 133 EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-030 01 This Variance From Deterministic Requirements (VFDR) results from fire-induced damage to cable 1CB-370 which affects the Cooling Water Strainer control panel, which could fail the automatic function of the cooling water strainers to backwash on a high differential pressure (dp). Damage to control cable affects components CV-31652, CV-31653, MTR-111C-21, MTR-121C-21, CV-31654, CV-31655, MTR-111C-22, and MTR-121C-22. Loss of the automatic backwash function of the cooling water strainers will result in a reduction of flow to the cooling water header Loop A. One strainer is required per cooling water loop header. The A loop header is credited to supply cooling water to the necessary systems since the ability to isolate the loop is available.

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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 134 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. Compliant Case: The automatic backwash function for the cooling water strainers should be available, so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): A recovery action is required to switch the 11 CL Strainer from Normal Control Mode to Emergency Control Mode. These actions are located in the plant screenhouse, FA41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 40 Ionization N N N N Y Suppression - - - - - - - 30 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 in a Change Evaluation 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 135 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 136 Unit Fire Area Description 1, 2 31 "A" Train Hot Shutdown Panel & Air Compressor/Aux. Feedwater Pump Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 VFDR-031 01 VFDR-031 01 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-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 VFDR-031 02 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 of Train B Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A and portions See VFDR-031 01 See VFDR-031 02 for HVAC

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 137 of Train B Unit 1 - CC Train A Unit 2 - CC Train A CL Train A Compressed Air System Not Available Temporary Control Room and Relay Room HVAC Reference Documents Safe/Genesis V 4.0.2 EC 20722, Fire Risk Evaluation, Fire Area 31, A Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-042, NFPA 13, 1969 Code Compliance Deviations, WPS-10, AFW Pump Rooms Summary The purpose of this analysis is to document the review of the WPS-10 wet pipe sprinkler system protecting the Auxiliary Feedwater Pump Rooms, Fire Areas 31 and 32, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record).. Thirteen deviations have been justified as "acceptable"; therefore, no further action is necessary. Three deviations require additional actions to resolve the noncompliances in both AFW Pump Rooms associated with pendent heads without return bends, temperature ratings of installed sprinklers, and partial installation where coverage is not provided in the area over the battery rooms. Action Requests have been initiated to track resolutions of the identified issues. 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 deviation is being tracked in the corrective action system. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 138 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 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 01 This Variance From Deterministic Requirements results from fire-induced damage to cable 1CB-370 which affects the Cooling Water Strainer control panel, or fire damage to cable 1CB-374, either of which results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers. This could fail the automatic function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage to these cables affects components CV-31652, MTR 111C-21, CV-31653, MTR 121C-22, CV-31654, MTR 111C-22, CV-31655, and MTR 121C-22. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 139 21 Cooling Water Strainer Motor, MTR-111C-22 (1CB-370, 1CB-374) 22 Cooling Water Strainer Motor, MTR-121C-22 (1CB-370, 1CB-374)

This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to the lack of separation between redundant trains of cooling water strainers. Compliant Case: The ability to automatically backwash the cooling water strainers should remain unaffected by a fire in this area. Disposition Recovery Action(s): A recovery action is required to switch the 11 CL strainer from Normal Control Mode to the Emergency Control Mode in order to restore automatic backwash capability (F5 App D). These actions are located in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited. VFDR-031 02 This Variance From Deterministic Requirements is caused by fire damage to 123 Instrument Air Compressor (which is located in FA 031) fire damage to PNL 132 which powers the Unit Cooler for 121 Air Compressor, and fire damage to the power cable to MCC 1A2 which powers PNL 133 which powers the Unit Cooler for the 122 Instrument Air Compressor. Loss of all Instrument Air would eventually fail the Safeguards Chillers which cool the Control Room and Relay Room. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. Components and Cables: 121 Air Compressor failed by loss of PNL 132 (1A1-14, 1A1-15, 1CA-671) 122 Air Compressor failed by loss of cable 121E-1 which powers MCC 1A2 which powers 122 Air Compressor 123 Air Compressor fails because it is located within FA 031 123 Air Compressor, MTR 211E-5 (2A1-1, 2A1-1A, 2C-176, 2C-177, 2C-179, 2CA-770) 123 Air Compressor Unit Cooler, MTR 111E-43 (1HVA-33, 1HVA-34, 1HVA-35, 1HVA-36, 1HVA-41, 1HVA-42, 1HVA-43, 1HVA-44) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 140 121 Air Compressor Unit Cooler, MTR 111E-44 (1HVA-29) Compliant Case: The 122 Instrument Air Compressor and associated unit cooler should remain free of fire damage to provide compressed air for safeguards chillers to cool the Control Room and Relay Room. Disposition Recovery Action(s): Replace compressed air cylinders for safeguards chilled water system when air pressure drops below the minimum value (C37). 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 credited. VFDR-031 01 The Variance From Deterministic Requirements is due to a fire that could damage the 12 Motor Driven Auxiliary Feedwater Pump (MDAFW Pump) (Train B) and the control switches for the 11 Turbine Driven Auxiliary Feedwater Pump (TDAFW Pump) discharge valves. Fire damage to control switch CS-51003 could cause spurious closure of MV-32238 which would isolate the 11 TDAFW Pump flow to the credited 11 Steam Generator. Fire damage to control switch CS-51005 could prevent closing MV-32239 which could divert the 11 TDAFW Pump flow to the non-credited 12 Steam Generator. The NFPA 805 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 Aux Feedwater. The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal. Components and Cables: 11 AFW to 11 SG MV, MV-32238 (cable 1CA-115 and CS-51003) 11 TDAFW Pump to 12 SG MV, MV-32239 (cable 1CA-116, CS-51005) Compliant Case: Auxiliary Feedwater addition using the 11 TDAFW Pump should be available from the Control Room. Disposition Recovery Action(s): No recovery actions. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 141 Modification to relocate control switches CS-51003 and CS-51005 so that 11 TDAFW Pump is not affected by a fire in FA 31 (Table S-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 a plant modification credited. VFDR-031 02 This Variance From Deterministic Requirements is due to a fire that could damage MTR 16-3 (12 MDAFW Pump) and power to MCC 1A2 which may be required to close the 12 MDAFW Pump discharge valves. If 12 MDAFW Pump were spuriously running and power was lost to MCC 1A2, the discharge valves would not be able to be closed from the control room. The steam generators could eventually be over-filled which could fail the 11 Turbine Driven AFW Pump. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Components and Cables: 12 MDAFW Pump, MTR 16-3 (16403-C, 1CB-16, 1CB-31, 1CB-920) Motor Control Center 1A Bus 2, MCC 1A2 (121E-1)

This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of Aux Feedwater. Compliant Case: One Auxiliary Feedwater Pump should remain available from the control room. Disposition Recovery Action(s): Locally trip the 12 MDAFW Pump at Bus 16 (F5 App D). 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 credited. VFDR-031 01 This Variance From Deterministic Requirements is due to a fire in FA 31 that could damage the 22 TDAFW Pump (Train B) and damage the circuits for the 21 MDAFW Pump (Train A). Fire damage at the Train A Hot Shutdown Panel or MCC 2A1 could affect MV-32383 (21 MDAFW Pump to 21 SG) or MV-32384 (21 MDAFW Pump to 22 SG). A fire at MCC 2A1 could affect MV-32026 (21 MDAFW Pump suction from Cooling Water) or MV-32336 (21 MDAFW Pump suction from CST) or MV-32383 (21 MDAFW Pump to 21 SG) or MV-32384 (21 MDAFW Pump to 22 SG). The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 142 Components and Cables: 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 (2A1-4, 2A1-4A, 2CA-30) Compliant Case: Auxiliary Feedwater addition using the 21 MDAFW Pump should be available from the Control Room. Disposition Recovery Action(s): A modification to protect one train of AFW from damage due to a fire in FA 31 will resolve this issue (Table S-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 a plant modification. VFDR-031 02 This Variance From Deterministic Requirements is due to a fire in FA 031 that could damage cables for MCC 2AC2 which powers the 22 Battery Charger which powers the 22 Inverter which powers PNL 212 which powers LOOP 2L-426RP (Pressurizer Level Indication). A fire in FA 031 could also damage cables for LOOP 2L-433, (Pressurizer Level Indication) and damage cables for PNL 211 which powers 2LR-470 (SG level recorder). A fire in FA 031 could also damage cables for the PNL 217 feed to PNL 211. Loss of both pressurizer level instrumentation and SG level recorder will prevent control of SG level and could lead to SG overfill. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring, pressurizer level indication. Components and Cables: MCC 2AC2 (221F-1) PNL 212 (2CR-1) LOOP 2L-433 (1C-5118, 1CA-1106, 2CF-207, 2CF-214) PNL 211 (2CW-1) 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 143 Compliant Case: Pressurizer Level Instrumentation should remain free of fire damage. Disposition Recovery Action Re-power PNL 211 from PNL 217 to restore pressurizer level indication. PNL 217 is available because cable 2AC1-5 is wrapped with a one hour fire barrier with fire detection and an automatic fire suppression system. 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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 2 Ionization N N N N Y Suppression WPS-10 Wet Pipe Y N N Y Y 31 Feature See Note ERFBS Y N N Y Y Cables 2AC1-5, 1CA-115, 2A1-4A, 2A1-5A, 2CA-30, 2CA-115, 2CA-116, 2CA-117, TB-2390 and 2SG-TA11 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 144 Unit Fire Area Description 1, 2 32 "B" Train Hot Shutdown Panel & Air Compressor/Aux. Feedwater Pump Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 22 SG VFDR-032 01 VFDR-032 01 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 145 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train B Unit 2 - Offsite Power supplying Electrical Distribution Trains A or B Unit 1 - CC Train B Unit 2 - CC Train B CL Train B Compressed Air System Not Available Temporary Control Room and Relay Room HVAC VFDR-032 01 VFDR-032 02 VFDR-032 02 Reference Documents Safe/Genesis V 4.0.2 EC 20730, Fire Risk Evaluation, Fire Area 32, B Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-042, NFPA 13, 1969 Code Compliance Deviations, WPS-10, AFW Pump Rooms Summary The purpose of this analysis is to document the review of the WPS-10 wet pipe sprinkler system protecting the Auxiliary Feedwater Pump Rooms, Fire Areas 31 and 32, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Thirteen deviations have been justified as "acceptable"; therefore, no further action is necessary. Three deviations require additional actions to resolve the noncompliances in both AFW Pump Rooms associated with pendent heads without return bends, temperature ratings of installed sprinklers, and partial installation where coverage is not provided in the area over the battery rooms. Action Requests have been initiated to track resolutions of the identified issues. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 146 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 deviation is being tracked in the corrective action system. 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 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 01 This Variance From Deterministic Requirements results from fire damage to cables which result in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers. This could fail the automatic function of the cooling water strainers to automatically backwash on a high differential pressure (dp). In addition, a fire could damage the CL Strainers or support equipment for the CL Strainers and affect both trains of CL to support Vital Auxiliaries. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 147 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) BKR 15-2, (15402-G, 15402-1, 15402-K, 1CA-1141) D1 DSL GEN, 034-011 (1CA-1312) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. Compliant Case: The ability to automatically backwash the cooling water strainers should remain unaffected by a fire. Disposition Recovery Action(s): A recovery action is required to switch the 22 CL strainer from Normal Control Mode to the Emergency Control Mode, in order to restore automatic backwash capability (F5 App D). These actions are located in the plant screenhouse, FA 41A. This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 148 VFDR-032 02 This Variance From Deterministic Requirements is caused by fire damage to 121 and 122 Instrument Air Compressors which are located in FA 032, and fire damage to MCC 1A1 which powers the Unit Cooler (MTR 111E-43) for the 123 Instrument Air Compressor. Loss of all Instrument Air would eventually fail the Safeguards Chillers which cool the Control Room and Relay Room. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. Components and Cables: 121 and 122 Air Compressors fails because they are located within 032. 123 Air Compressor fails due to loss of MCC 1A1 (located in FA 32) due to fire damage to cable 111E-1 causing a loss of PNL132. PNL 132 provides power to the 123 Air Compressor Unit Cooler (MTR 111E-43). This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of Instrument Air Compressors to support operation of Safeguards Chilled Water System. Compliant Case: The 123 Air Compressor Unit Cooler should remain unaffected by a fire in FA 032. Disposition Recovery Action(s): Replace compressed air cylinders for safeguards chilled water system when air pressure drops below the minimum value (C37).

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 credited. VFDR-032 01 This Variance From Deterministic Requirements is due to a fire in FA 032 that could damage the 11 TDAFW Pump (Train A) and damage the circuits for the 12 MDAFW Pump (Train B). Fire damage at the Train B Hot Shutdown Panel or MCC 1A2 could cause spurious operation of MV-32381 or MV-32382. A fire at MCC 1A2 could cause spurious operation of MV-32027 or MV-32335. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Components and Cables: 12 MDAFW Pump to 11 SG, MV-32381 (1A2-7A, 1CB-52, 1CB-53, 1CB-54) 12 MDAFW Pump to 12 SG, MV-32382 (1A2-8A, 1CB-52, 1CB-55, 1CB-56) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 149 12 MDAFW Pump suction from Cooling Water, MV-32027 (1A2-3, 1A2-3A, 1A2-6A) 12 MDAFW Pump suction from CST, MV-32335 (1A2-6, 1A2-6A) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of AFW. The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal. Compliant Case: The 12 MDAFW Pump should remain free of fire damage. Disposition Recovery Action(s): No recovery action. A modification to protect one train of AFW from damage due to a fire in FA 32 will resolve this issue (Table S-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 a plant modification credited. VFDR-032 02 This Variance From Deterministic Requirements is due to fire damage that affects Bus 15 (Train A) and Bus 16 (Train B), 4kV Safeguards Power. A fire in FA 032 could damage cables 15407-1, 15407-2, or 16408-1 for the CT11 source to Bus 15 and Bus 16. A fire in FA 032 could damage cable 1C-333 for the 1RY source to Bus 15 or Bus 16. A fire in FA 032 could damage cables for the D1 Diesel Generator source to Bus 15. A fire in FA 032 could damage DC control power and AC power cables for MTR 15-1, MTR 15-4, MTR 15-5, or MTR 15-9 which could fail Bus 15. A fire in FA 032 could damage cables 1DCB-2 and 1DCB-95 for the D2 source to Bus 16. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries AC Power. Components and Cables: BUS 15 (15406-B, 1DCA-1) BKR 15-2 (1CA-27) BKR 15-3 (1C-333, 15403-B, 15404-A, 1CA-27) BKR 15-7 (15407-A, 15407-1, 15407-2, 15407-A, 16408-1, 1CA-27) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 150 11 SI Pump, MTR 15-1 (15401-1, 15401-B, 15401-C) 11 RHR Pump, MTR 15-4 (15404-1, 15404-C, 15404-E, 1CA-753, 1CA-98) 11 CC Pump, MTR 15-5 (15405-1, 15401-B, 15401-C) 11 CS Pump, MTR 15-9 (15409-1, 15409-B, 1CA-97) BUS 16 (1DCB-1) BKR 16-2 (15403-B, 1C-333) BKR 16-8 (15407-1, 15407-2, 16408-1) BKR 16-9 (1DCB-2, 1DCB-95) This represents a VFDR of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of safeguard power. The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Vital Auxiliaries AC Power. Compliant Case: BUS 16 should remain unaffected by a fire in this area. Disposition Recovery Action(s): No recovery action. A modification will be performed to protect one of the power supplies to Bus 16 to support safe and stable (Table S-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 a plant modification credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 151 VFDR-032 03 This Variance From Deterministic Requirements is due to a fire in FA 032 that could damage cables for DC control power to Bus 15 tripping circuits and subsequent damage to AC power cables resulting in a loss of overcurrent protection for of Bus 15. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries AC Power. Components and Cables: BUS 15 (1DCA-1) 11 SI Pump, MTR 15-1 (15401-1, 15401-B, 15401-C) 11 RHR Pump, MTR 15-4 (15404-1, 15404-C, 15404-E, 1CA-753, 1CA-98) 11 CC Pump, MTR 15-5 (15405-1, 15401-B, 15401-C) 11 CS Pump, MTR 15-9 (15409-1, 15409-B, 1CA-97)

This represents a VFDR of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of safeguard power. Compliant Case: A fire in FA 32 should not cause secondary fires in FA 81. Disposition Recovery Action(s): No recovery action. Modification to eliminate the possibility that a fire could cause 4kV power cables to start on fire in other fire areas (Table S-2). VFDR-032 01 The Variance From Deterministic Requirements is due to a fire that could damage the 21 MDAFW Pump (Train A) and the control switches for the 22 TDAFW Pump discharge valves. Fire damage to control switch CS-51605 could cause spurious closure of MV-32247 which would isolate the 22 TDAFW Pump flow to the credited 22 Steam Generator. Fire damage to control switch CS-51603 could prevent closing MV-32246 which could divert the 22 TDAFW Pump flow to the non-credited 21 Steam Generator. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Components and Cables: 22 AFW to 21 SG MV, MV-32246 (cable 2CB-164 has a one hour fire barrier) 22 AFW to 22 SG MV, MV-32247 (cable 2CB-163 has a one hour fire barrier) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 152 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of AFW. Compliant Case: The 22 TDAFW Pump should remain free of fire damage. Disposition Recovery Action: No recovery action. A modification to protect one train of AFW from damage due to a fire in FA 32 will resolve this issue (Table S-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 a plant modification. VFDR-032 02 This Variance From Deterministic Requirements is caused by fire damage to cables 25410-D, 25410-E, 2CA-505, 2CA-506, 2CA-525, and 2CA-778 causing a spurious start of 21 AFW Pump (MTR 25-10). This can result in SG overfill of the credited SG. The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal. Components and Cables: MTR-25-10 (25410-D, 25410-E, 2CA-505, 2CA-506, 2CA-525, 2CA-778) 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. Compliant Case: Control of 21 MDAFW Pump (MTR 25-10) should be available from the Control Room. Disposition Recovery Action(s): An operator will locally trip the 21 MDAFW Pump at BKR 25-10 in FA 117 (4kV Bus 25 Room). 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 credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 153 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 2 Ionization N N N N Y Suppression WPS-10 Wet Pipe N N N Y Y Feature ERFBS Y N N Y Y 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, 2CB-164, TB-1263 and 1SG-TA11 have supplemental barriers (ERFBS) 32 Feature RES Y N N Y Y Cable 1SG-LB22 has a radiant energy shield (RES), Marinite board 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 154 Unit Fire Area Description 1 33 Battery Room 11 Regulatory Basis 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 155 Safety Injection Pump (Train B) to inject borated water from the RWST Vital Auxiliaries Unit 1 - Offsite Power Unit 2 - Offsite Power Unit 1 CC Train B Unit 2 CC Train B CL Train B Compressed Air System Train B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 156 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 1 Ionization N N N N N Suppression - - - - - - - 33 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 in a Change Evaluation 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 33. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 157 Unit Fire Area Description 1 34 Battery Room 12 Regulatory Basis 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 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) or Safety Injection (Train B) 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) 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 158 Unit 1 CC Train A Unit 2 CC Train A or B CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 159 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 1 Ionization N N N N N Suppression - - - - - - - 34 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 160 Unit Fire Area Description 2 35 Battery Room 21 Regulatory Basis 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-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-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 - 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 161 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 - CC Train A or B Unit 2 - CC Train B CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 162 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 35 Ionization N N N N N Suppression - - - - - - - 35 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 in a Change Evaluation 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 31 extends above Fire Area 35. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 163 Unit Fire Area Description 2 36 Battery Room 22 Regulatory Basis 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 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 or B Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 164 Unit 1 CC Train A or B Unit 2 CC Train A CL Train A or B Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents SAFE/GENESIS V 4.0.2 Rev 5 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 165 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 35 Ionization N N N N N Suppression - - - - - - - 36 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 in a Change Evaluation 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 31 extends above Fire Area 36. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 166 Unit Fire Area Description 1 37 Unit 1, 480 V Normal Switchgear Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 167 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 168 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 B Unit 2 CC Train B CL Train B Compressed Air System Train B Control Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 EC 20712, Fire Risk Evaluation, Fire Area 37, Unit 1 480V Normal Switchgear Room, Rev. 0, September, 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 169 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 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers, due to fire damage to cables. This could fail the function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage to control cable 1CA-529 affects components CV-31652, CV-31653, MTR-111C-21, MTR-121C-21, CV-31654, CV-31655, MTR-111C-22, and MTR-121C-22. Loss of the cooling water strainers MTR-121C-22 and MTR-111C-22 results in the loss of cooling water to the B Loop header. One strainer is required per cooling water loop header. The B loop header is credited to supply cooling water to the necessary systems since the ability to isolate the loop is available. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 170 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. Compliant Case: The automatic backwash function for the cooling water strainers should be available. Disposition Recovery Action(s): A recovery action is required to switch the 22 CL Strainer from Normal Control mode to the Emergency Control mode in order to restore automatic backwash capability (F5 App D). These actions are located in the plant screenhouse, FA41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system.

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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 83 Ionization N N N N Y Suppression - - - - - - - 37 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 in a Change Evaluation 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 171 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 172 Unit Fire Area Description 2 38 Unit 2, 480 V Normal Switchgear Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 173 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 174 Vital Auxiliaries Unit 1 - Offsite Power 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 Unit 2 CC Train A CL Train A Compressed Air System Train A Control Room HVAC Train A Reference Documents Safe/Genesis V 4.0.2 EC 20713, Fire Risk Evaluation, Fire Area 38, Unit 2 480V Normal Switchgear Room, Rev. 0, September, 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 175 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 01 This Variance From Deterministic Requirements results from fire damage to cable 1CB-370 which results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers. This could fail the automatic function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage to this cable affects components CV-31652, CV-31653, MTR-111C-21, MTR-121C-21, CV-31654, CV-31655, MTR-111C-22 and MTR-121C-22.

Loss of the cooling water strainers MTR-111C-21 and MTR-121C-21 results in the loss of cooling water to the A Loop header. One strainer is required per cooling water loop header. The A loop header is credited to supply cooling water to the necessary systems since the ability to isolate the loop is available. 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) 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. Compliant Case: The automatic backwash function for the cooling water strainers should be available. Disposition Recovery Action(s): A recovery action is required to switch the 11 CL Strainer from Normal Control mode to the Emergency Control mode in order to restore automatic backwash capability (F5 App D). These actions are located in the plant screenhouse, FA41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 176 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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 85 Ionization N N N N Y Suppression - - - - - - - 38 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 177 Unit Fire Area Description 1, 2 39 Radwaste Building Note: Fire Area 39 is now combined into Fire Area 4. This fire area is being included due to the potential for radioactive release. No damage to equipment relied on for achieving safe and stable will occur due to a fire in this area.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 178 Unit Fire Area Description 1, 2 40 Maintenance Storage Shed (CAF) Note: Fire Area 40 is now combined into Fire Area 4. This fire area is being included due to the potential for radioactive release. No damage to equipment relied on for achieving safe and stable will occur due to a fire in this area.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 179 Unit Fire Area Description 1, 2 41 Screenhouse (General Area) Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 180 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 181 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 182 EEEE Title FPEE-11-041, NFPA 13, 1969 Code Compliance Deviations, PA-9 Screenhouse Summary The purpose of this analysis is to document the review of the Pre-Action Sprinkler System in the Plant Screenhouse (referred to in this document as the Screenhouse) for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Eight deviations have been justified as "acceptable". An improvement has been recommended for one of these deviations. Two deviations will require modifications to the system. A CAP been written to add a sprinkler head under the large junction box over the Diesel Driven Fire Pump and to add sprinkler #229 which is shown on drawing XH-106-376 but was found to be missing during walkdowns. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 75 Ionization Y N N N Y Suppression PA-9 Pre-Action Y N N N Y 41 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 in a Change Evaluation or Fire Risk Evaluation

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 183 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 184 Unit Fire Area Description 1, 2 41A Screenhouse (DDCLP Rooms) Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 185 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 186 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B VFDR-041A 01 Reference Documents Safe/Genesis V 4.0.2 EC 20714, Fire Risk Evaluation, Fire Area 41A, Screenhouse (DDCLP Rooms), Rev. 0, September, 2012 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, Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 187 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. EEEE Title FPEE-11-041, NFPA 13, 1969 Code Compliance Deviations, PA-9 Screenhouse Summary The purpose of this analysis is to document the review of the Pre-Action Sprinkler System in the Plant Screenhouse (referred to in this document as the Screenhouse) for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Eight deviations have been justified as "acceptable". An improvement has been recommended for one of these deviations. Two deviations will require modifications to the system. CAP # 1273295 has been written to add a sprinkler head under the large junction box over the Diesel Driven Fire Pump and to add sprinkler #229 which is shown on drawing XH-106-376 but was found to be missing during walkdowns. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-041A 01 The variance is a fire which could damage all the cooling water strainers in FA 41A (11, 12, 21 and 22 cooling strainers). Table 6.1 shows the cables unique to each cooling water strainer motor and the cables that affect all the motors. 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. This is a separation issue for Vital Auxiliaries. Components and Cables: 1CA-678 MTR-111C-22 1AB1-8 1AB1-9 1CA-403 1CA-408 1CA-529 1CA-677 1CA-678 MTR-121C-21 1AB2-6 1AB2-9 1CA-529 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 188 1CB-247 1CB-528 1CB-529 MTR-121C-22 1AB2-7 1CA-529 1CB-247 1CB-528 1CB-529 MTR-111C-21, MTR-111C-22, MTR-121C-21 and MTR-121C-22 1AB1-7A 1AB1-8A 1AB2-6A 1AB2-7A 1C-1496 1C-1497 1C-2862 1CA-399 1CA-400 1CA-401 1CA-402 1CA-404 1CA-405 1CA-406 1CA-407 1CB-238 1CB-239 1CB-240 1CB-241 1CB-243 1CB-244 1CB-245 1CB-246 1CB-370 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. Compliant Case: The ability to automatically backwash the CL strainers should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 189 Disposition Recovery Action(s): A recovery action is required to manually operate one CL Strainer of each Train in order to restore backwash capability. This action must be performed locally in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 75 Ionization, Heat N N N N Y Suppression PA-9 Wet Pipe N N N N Y 41A 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 190 Unit Fire Area Description 1, 2 41B Screenhouse Basement Below Grade Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 191 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 192 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A or B Unit 1 - If CC Train A is not available use CC Train B Unit 2 - If CC Train A is not available use CC Train B If CL Train A is not available use CL Train B If Compressed Air System Train A is not available use Train B If Control Room and Relay Room HVAC Train A is not available use Train B VFDR FA41B-02 VFDR-FA41B-03 Reference Documents Safe/Genesis V 4.0.2 EC 20723, Fire Risk Evaluation, Fire Area 41B, Screenhouse Basement Below Grade, Rev. 0, September, 2012 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 FPEE-11-041, NFPA 13, 1969 Code Compliance Deviations, PA-9 Screenhouse Summary The purpose of this analysis is to document the review of the Pre-Action Sprinkler System in the Plant Screenhouse (referred to in this document as the Screenhouse) for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Eight deviations have been justified as "acceptable". An improvement has been recommended for one of these deviations. Two deviations will require modifications to the system. An action request has been written to add a sprinkler head under the large junction box over the Diesel Driven Fire Pump and to add sprinkler #229 which is shown on drawing XH-106-376 but was found to be missing during walkdowns. Variances from Deterministic Requirements (VFDR) VFDR-FA41B 02 This variance results from fire-induced damage could fail the function of the cooling water strainers to automatically backwash on a high differential pressure (dp). Damage affects components CV-31652 (11 Cooling Water Strainer Backwash CV), CV-31655 (22 Cooling Water Strainer Backwash CV), MTR-111C-21 (11 Cooling Water Strainer), and MTR-121C-22 (22 Cooling Water Strainer). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 193 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) 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) 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. Compliant Case: The ability to automatically backwash the CL strainers from the Control Room should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. Disposition Recovery Action(s): A recovery action is required to switch the 11 or 22 CL Strainer from Normal Control Mode to Emergency Control Mode for MTR-111C-21 and MTR-121C-22. These actions are located in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system. 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 credited. VFDR-41B 03 This Variance From Deterministic Requirements is due to a fire in FA 041B that could damage DC control power to Bus 23 tripping circuits and subsequent damage to AC power cables resulting in a failure of Bus 23. Components and Cables: 121 Screenwash Pump MTR 23-1 (23401-2, 1C-1550, 1C-1552, 1C-2280, 1C-2285, 1C-4661, 2C-1359) This represents a variation from the deterministic requirements (VFDR) 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 pumps. Compliant Case: Circuits for the Screenwash pump should be protected against common enclosure fires, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 194 Disposition Recovery Action(s): No recovery action. VFDR-41B 03 will be resolved by implementation of a modification to protect DC cubicle control power (Table S-2). Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 74 Ionization, Heat N N N N Y Suppression PA-9 Pre-Action N N N Y Y 41B Feature ERFBS N N N Y Y Cable 221C-4 has a Darmatt 1-hour cable wrap 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 195 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 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 196 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 197 Vital Auxiliaries Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A and B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 S L E R D Notes Detection 71 Ionization N N N N N Suppression - - - - - - - 46 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 198 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 199 Unit Fire Area Description 1, 2 46A Cooling Tower Transformers Note: Fire Area 46A is now combined into Fire Area 46.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 200 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 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 22 SG VFDR-058 07 VFDR-058 09 VFDR-058 07 VFDR-058 09 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 201 Inventory and Pressure Control Unit 1 - If Charging System (Train A) is not available use Safety Injection (Train B) Unit 2 - If Charging System (Train A) is not available use Safety Injection (Train B) VFDR-058 02 VFDR-058 05 VFDR-058 06 VFDR-058 08 VFDR-058 02 VFDR-058 05 VFDR-058 06 VFDR-058 08 Reactivity Control Unit 1 - Trip reactor from the Control Room. If Charging Pump is not available use Safety Injection Pump (Train B) to inject borated water from the RWST Unit 2 - Trip reactor from the Control Room. If Charging Pump is not available use Safety Injection Pump (Train B) to inject borated water from the RWST VFDR-058 02 VFDR-058 02 Vital Auxiliaries Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A or B. Use train A if B is not available Unit 2 - D5 Emergency Diesel Generator supplying Electrical Distribution Train A or D6 Emergency Diesel Generator supplying Electrical Distribution Train B Use train A if B is not available Unit 1 - If CC Train B is not available use CC Train A Unit 2 - If CC Train B is not available use CC Train A CL Train A or B Compressed Air System Train B Control Room and Relay Room HVAC (Train B) VFDR-058 01 VFDR-058 02 VFDR-058 01 VFDR-058 03 VFDR-058 04 VFDR-058 01 VFDR-058 03 VFDR-058 04 VFDR-058 010 Reference Documents Safe/Genesis V 4.0.2 EC 20724, Fire Risk Evaluation, Fire Area 58, Auxiliary Building Ground Floor Unit 1, Rev. 0, September, 2012 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 202 EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 203 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 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. Variances from Deterministic Requirements (VFDR) VFDR-058 01 This Variance From Deterministic Requirements (VFDR) results in loss of automatic backwash to 11, 12, 21 and 22 Cooling Water (CL) Strainers, due to fire damage to cable 1CA-538. This could fail the function of the cooling water strainers to automatically backwash on a high differential pressure (dp).

Loss of automatic backwash capability for cooling water strainers MTR-121C-21 and MTR-121C-22 can result in the loss of cooling water to the credited B Loop header. One strainer with automatic backwash capability is required per cooling water loop header. The B Loop header is credited to supply cooling water to the necessary Unit 1 and Unit 2 systems since the credited 22 CL pump supplies this header. The 12 CL pump is isolated from the non-credited B Loop header from the Control Room. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. 1CA-538 is wrapped by a one hour barrier with detection but without suppression.

Vital AC power from BUS-15 is required see VFDR-058 11 for affected cables. Components and Cables: 11 CL Strainer Backwash CV, CV-31652, 11 CL Strainer Motor, MTR 111C-21 (1CA-538) 12 CL Strainer Backwash CV, CV-31653, 12 CL Strainer Motor, MTR 121C-21 (1CA-538) 21 CL Strainer Backwash CV, CV-31654, 21 CL Strainer Motor, MTR 111C-22 (1CA-538) 22 CL Strainer Backwash CV, CV-31655, 22 CL Strainer Motor, MTR 121C-22 (1CA-538) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 204 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of cooling water strainers. Compliant Case: The ability to backwash the CL strainers should be available to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads Disposition Recovery Action(s): A recovery action is required to switch the 12 and 22 CL strainers from Normal Control Mode to the Emergency Control Mode. This action must be performed locally in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system.

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 credited. VFDR-058 02 This VFDR involves a fire that could damage cable 1C-781 for the 122 Instrument Air Compressor. The 121 and 123 Instrument Air Compressors are also fire affected for this Fire Area. Components and Cables 122 IAC (1C-781) 121 IAC (1C-765) 123 IAC (2CA-770)

This represents a VFDR of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of Instrument Air Compressors to support operation of Safeguards Chilled Water System. This will ensure that adequate cooling is provided to the Control and Relay Rooms. Compliant Case: 122 Instrument Air Compressor should be free of fire damage for this Fire Area and capable of supporting Control and Relay Room cooling. Disposition Recovery Action(s): Locally operate 122 Instrument Air Compressor in FA 32 to provide compressed air to the safeguards chillers per F5 Appendix D. This will ensure that adequate cooling is provided to the Control and Relay Rooms. 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 credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 205 VFDR-058 01 This variance from deterministic requirements involves systems that are protected by a one hour barrier and detection but with a lack of suppression in FA 58: between 11 Component Cooling (CC) and 12 Component Cooling (CC) and support systems. The cables 1CA-693 and 1CA-695 for 12 DDCLP and cables for 12 CC and 22 CC are protected with a one hour fire barrier with no suppression. However, cables 16405-A, 16405-1 and 1CB-71 are not wrapped at their termination point, which is located in FA 58, so cable protection cannot be credited for these cables. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries because CC supports cooling to the SI and RCP Seals. Components and Cables: 12 DDCLP, 145-392 (1CA-693 and 1CA-695) 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) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the area. Compliant Case: The 12 CC and its support systems should be available to supply Component Cooling water for the plant. Disposition Recovery Action(s): No recovery action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR-15-5 (11 CC Pump) and MTR-16-5 (12 CC Pump), so at least one CC pump will remain available to supply Component Cooling water to the SI pumps and the RCP seals. 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 modeling credited. VFDR-058 02 This Variance From Deterministic Requirements (VFDR) involves systems that are protected by a one hour barrier or 20 feet and detection but with a lack of suppression and a fire could cause damage at the 12 SI pump and 12 Charging Pump.

The 12 charging pump (Train A) and the 12 SI pump (Train B) are both located in fire area 58. A fire could damage the pumps or support equipment for the pumps and affect both trains of pumps to provide inventory and reactivity control. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control and Reactivity Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 206 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, and 1K1-3B), 12 SI Pump, MTR 16-7 (16407-1, 16407-B) BKR 15-2, (15402-G, 15402-K, 15402-1, 1CA-1140, 1CA-1141) D1 DSL GEN, 034-011 (1CA-1312) This represents a VFDR of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of Inventory Control. Compliant Case: The 12 SI Pump should be free of fire damage and available for this FA for Inventory and Reactivity Control. Disposition Recovery Action(s): No recovery action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both MTR 111J-1 (12 Charging Pump) and MTR 16-7 (12 SI Pump). This means that at least one of these pumps will remain available for RCS inventory control. 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 modeling or a plant modification credited. VFDR-058 03 This Variance From Deterministic Requirements involves systems that are protected by a one hour barrier and detection but with a lack of suppression. A fire could damage cables to the 11 CC pump and cause spurious opening of MV-32093 and MV-32094. In this area the 12 CC pump is credited, and with both divisions of RHR Heat Exchanger Valves (MV-32093 and MV-32094) open, a runout condition could occur on the 12 CC pump. If only one (11 or 12) Component Cooling Water pump is available and both of the RHR Heat Exchanger Valves (MV-32093 and MV-32094) spuriously open, flow through the single component cooling water pump could exceed recommended flow, resulting in a runout condition on the one component cooling water pump. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries because CC cannot support cooling to both RHR Heat Exchangers without creating a runout condition on the pump. Components and Cables: 11 CC Pump, MTR 15-5 (15405-1, 15405-A, 15405-B, 15405-G, 1CA-184) 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 207 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of Component Cooling Pumps. Compliant Case: One train of component cooling water should remain unaffected by a fire. Disposition Recovery Action(s): No recovery action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables associated with MTR-15-5 (11 CC Pump), MTR-16-5 (12 CC Pump), MV-32093, MV-32094, MV-32120 and MV-32121. This ensures the Unit 1 CC pumps will not be placed in any runout conditions as a result of credible fire scenarios in FA-58. 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 modeling or a plant modification credited. VFDR-058 04 This Variance From Deterministic Requirements is due to a fire in FA 058 that could damage cables for DC control power to Bus 15 and Bus 16 tripping circuits, and subsequent damage to AC power cables. These cable failures could fail Bus 15 and Bus 16.

The NFPA 805 Nuclear Safety Performance Criteria is not met is for Vital Auxiliaries AC Power due to a loss of vital power. Components and Cables: 11 SI Pump, MTR 15-1 (15401-1, 15401-B, 15401-C) 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-B, 15405-G, 1CA-184) 11 CS Pump, MTR 15-9 (15409-B, 15409-D, 15409-E 1CA-97) 12 RHR Pump, MTR 16-6 (16406-1, 1CB-36, 1CB-564) 12 CS Pump, MTR 16-1 (16401-B, 1CB-29) 12 SI, MTR 16-7 (16407-1, 16407-B) BKR 15-8 (2CA-749, 25417-1, 25417-2) 12 CC Pump, MTR 16-5 (16405-1, 16405-A, 1CB-181, 1CB-71) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of vital buses. Compliant Case: One train of safeguards power should remain unaffected by a fire.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 208 Disposition Recovery Action(s): No recovery action. Modification to eliminate the possibility that a fire could cause 4kV power cables to start a fire in other fire areas (Table S-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 plant modification credited. VFDR-058 05 This Variance From Deterministic Requirements involves a fire in FA 58 that could damage cables 15409-B, 15409-D, 15409-E, or 1CA-97 and cause a spurious start of MTR 15-9 and damage cable 1K1-10A, which could spuriously open MV-32103, causing a flow diversion from the Refueling Water Storage Tank (RWST). Cable 1K1-10A is routed in cable trays wrapped with a one hour fire barrier with detection and without suppression. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control due to a flow diversion from the RWST. 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) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3. due to lack of suppression with a one hour barrier and detection in the area 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 action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR-15-9 (11 CS Pump) and MV-32103. This ensures that flow diversion from the RWST through the Unit 1 Train A CS system will not occur for credible fire scenarios in FA-58.

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 modeling. VFDR-058 06 This Variance From Deterministic Requirements involves a fire in FA 58 that could damage cables 16401-B or 1CB-29 and cause a spurious start of MTR 16-1 and cable 1KA2-3A, which could spuriously open MV-32105. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control due to a flow diversion from the RWST.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 209 Components and Cables: 12 CS Pump, MTR 16-1 (16401-B, or 1CB-29), 12 CS discharge valve, MV-32105 (1KA2-3A) 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. 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 action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR-16-1 (11 CS Pump) and MV-32105. This ensures that flow diversion from the RWST through the Unit 1 Train B CS system will not occur for credible fire scenarios in FA-58. 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 modeling. VFDR-058 07 This Variance From Deterministic Requirements involves a fire causing damage to cables for MV-32382 and MV-32381. MV-32382 could spuriously close, causing loss of Auxiliary Feed to the credited 12 Steam Generator. MV-32381 is normally open and it is desired to close MV-32381 to prevent flow diversion to the non-credited 11 Steam Generator. 1CB-52 is wrapped with one hour fire barrier and FA 58 has an automatic fire detection system, but an automatic fire suppression system is not installed in FA 58. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. 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) 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. Compliant Case: The 12 MDAFW Pump is fully able to inject to the 12 SG, to ensure adequate Auxiliary Feedwater is provided to the Steam Generator for decay heat removal. Disposition Recovery Action(s): No recovery action. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 210 Fire modeling for FA 58 indicates that there are no fire scenarios that will result in damage to cables affecting MV-32381 and MV-32382. Because of this, remote control of MV-32381 and MV-32382 remains available from the control room to direct flow to the credited 12 steam generator and isolate flow to the 11 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 credited fire modeling. VFDR-058 08 This Variance From Deterministic Requirements involves a fire causing MV-32202 or MV-32203 to spuriously close, which would isolate the minimum flow recirculation line from the SI pumps back to the RWST. If the RCS is at normal pressure, the SI pumps would be dead headed and the SI pumps could be damaged. If the Fire also damaged MV-32060, such that MV-32060 could not be opened, it could cause a loss of credited makeup to the Charging Pump. A modification will be implemented to install suction pressure trips on the Unit 1 charging pumps to prevent damage to the charging pumps. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. 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 wrapped) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation with one hour barrier and detection in the area. Compliant Case: The 12 SI Pump should be free of fire damage and available for this FA, in order to provide adequate makeup for Inventory Control. Disposition Recovery Action(s): Recovery action to manually open VC 1 and restart a charging pump. Modification to install suction pressure trips on the Unit 1 charging pumps (Table S-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 a plant modification and recovery action. VFDR-058 11 This Variance From Deterministic Requirements is caused by fire damage to cables for BKR-15-2, BKR-15-3, and BKR-15-7 which could cause a loss of power to BUS-15. BUS-16 could be lost due to cable damage to BKR-16-2, BKR-16-8, and BKR-16-9. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, lack of suppression with a one hour barrier and detection in the area. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 211 Components and Cables: BKR-15-2 (15402-1, 15402-G, 15402-K, 1CA-1140, 1CA-27) BKR-15-3 (15403-B, 15404-A, 1CA-27, 1C-333) BKR-15-7 (15404-A, 15407-3, 15407-A, 16408-1, 1CA-27) BKR-16-2 (1C-333) BKR-16-8 (15407-3, 16408-1) BKR-16-9 (16409-1, 1CB-135) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of suppression with a one hour barrier and detection in the area. Compliant Case: One train of safeguards power should remain available. Disposition Recovery Action(s): No recovery action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables, affecting BKR-15-2, BKR-15-3 and BKR 15-7 together with BKR-16-2, BKR 16-8 and BKR 16-9 together. Because of this, one train of safeguards power will remain available. The modification to protect cable 1C-333 will allow Bus 16 to remain available from the 1RY Source. (Table S-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 fire modeling credited. VFDR-058 01 This variance from deterministic requirements involves systems that are protected by a one hour barrier and detection but with a lack of suppression for FA 58 between 21 CC (Train A) and 22 CC (Train B) and support systems. Cables 1CA-693 and 1CA-695 for 12 DDCLP and cables for 12 CC and 22 CC are protected with a one hour fire barrier with no suppression. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries because CC supports cooling to the SI and RCP Seals. Components and Cables: 12 DDCLP (1CA-693 and 1CA-695) 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 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 212 Compliant Case: The 22 CC and its support systems should be fully available for this area, to ensure adequate Component Cooling is provided to the SI and RCP seals. One train of component cooling water should remain unaffected by a fire. Disposition Recovery Action(s): No recovery action. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR-25-13 (21 CC Pump) and MTR-26-5 (22 CC Pump) so at least one CC pump will remain available to supply Component Cooling water to the SI pumps and the RCP. 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 modeling. VFDR-058 02 This Variance From Deterministic Requirements involves systems that are protected by a one hour barrier or 20 feet and detection but with a lack of suppression, and a fire could cause damage to cables for the 22 SI Pump (Train B) and 22 Charging Pump (Train A). The 22 Charging Pump (Train A) and the 22 SI Pump (Train B) are both located in fire area 58 but separated by a one hour barrier or more than 20 feet with detection, but no suppression. A fire could damage the pumps or support equipment for the pumps and affect both trains of pumps to provide inventory and reactivity control. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control and Reactivity Control. Components and Cables: 22 Charging Pump, MTR 211J-1 (cables 2CA-148, 2CA-162, 2CA-199, 2CA-45, 2CA-624, 2CA-626, 2K1-41, 2K1-42, 2K1-5, 2K1-5A, and 2K1-7B) MCC 2K1(211J-1) 22 SI Pump, MTR 26-10 (26410-1, 26410-C) This represents a VFDR of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of Inventory Control. Compliant Case: The 22 Safety Injection and 22 Charging Pumps should remain free of fire damage, to provide adequate Inventory Control and Reactivity Control. Disposition Recovery Action(s): No recovery action.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 213 Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both MTR-211J-1 (22 Charging Pump) and MTR-26-10 (22 SI Pump). This means that at least one of these pumps will remain available for RCS inventory control. 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 modeling. VFDR-058 03 This Variance From Deterministic Requirements involves systems that are protected by a one hour barrier and detection, but with a lack of suppression, and a fire could cause damage to cables for the 22 CC pump and a spurious opening of the 21 RHR Heat Exchanger Valve MV-32128. In this area the 22 CC pump is credited and with both divisions of RHR Heat Exchanger Valves (MV-32128 and MV-32129) open, a runout condition could occur on the 22 CC pump. If only one (21 or 22) Component Cooling Water pump is available and both of the RHR Heat Exchanger Valves (MV-32128 and MV-32129) spuriously open, flow through the single Component Cooling water pump could exceed recommended flow, resulting in a runout condition on the one component cooling water pump. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. 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) 22 RHR HX CC Inlet Valve, MV-32129 (26411-D, 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) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of Component Cooling Pumps. Compliant Case: One train of component cooling should remain unaffected by a fire. Disposition Recovery Action(s): No recovery action.

Fire modeling for FA 58 indicates that one fire scenario (FDS-58GRP-004) will result in simultaneous damage to cables associated with MTR-25-13 (21 CC Pump), MTR-26-5 (22 CC Pump), MV-32128, MV-32129, MV-32122 and MV-32123. This will cause a runout condition and the loss of both trains of CC. 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 modeling. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 214 VFDR-058 04 This Variance From Deterministic Requirements is due to a fire in FA 058 that could damage cables for DC control power to Bus 25 and BUS 26 tripping circuits, and subsequent damage to AC power cables resulting and could fail Bus 25 and BUS 26. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries AC Power due to a loss of vital power. Components and Cables: 21 SI Pump, MTR 25-8 (25408-1, 25408-B, 25408-C), 21 RHR Pump, MTR 25-7, (25407-C, 2CA-8) 21 CC Pump, MTR 25-13 (25413-1, 25413-D, 25413-E, 2CA-4) 21 CS Pump, MTR 25-9 (25409-1, 25409-C/D/E, 2CA-7), 21 AFW Pump, MTR 25-10 (25410-1, 25410-C/D/E, 2CA-778), 22 RHR Pump, MTR 26-11 (26411-1, 2CB-9) 22 CS, MTR 26-9 (26409-C, 26409-E, 26409-F, 2CB-315) 22 SI Pump, MTR 26-10 (26410-1, 26410-C) BKR 25-17 (2CA-749, 25417-1, 25417-2) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains for vital buses. Compliant Case: One train of safeguards power should remain unaffected by a fire. Disposition Recovery Action(s): No recovery actions. Modification to eliminate the possibility that a fire could cause 4kV power cables to start a fire in other fire areas (Table S-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 a plant modification. VFDR-058 05 This Variance From Deterministic Requirements involves a fire in FA 58 that could cause spurious start of the 21 CS pump and spurious opening of the 21 CS Pump Discharge Valve MV-32105, causing a flow diversion from the RWST. Cable 1KA2-3A is routed in cable trays wrapped with a one hour fire barrier with detection and without suppression. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 21 CS Pump, MTR 25-9 (25409-1, 25409-C/D/E, 2CA-7) 21 CS Pump Discharge Valve, MV-32114 (2K1-13B) 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 215 Compliant Case: No flow diversion caused by spurious operation of the Containment Spray System, so adequate Inventory Control is maintained. Disposition Recovery Action(s): No recovery actions. Fire modeling for FA 58 indicates that there are two fire scenarios (FDS-58GRP-002 and FDS-58GRP-008) that will result in simultaneous damage to cables affecting MTR 25-9 (21 CS Pump) and MV-32114 . This could cause a flow diversion from the RWST through the Unit 2 Train A CS system to Unit 2 containment. 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 modeling. VFDR-058 06 This Variance From Deterministic Requirements involves a fire in FA 58 that could cause spurious start of the 22 CS Pump (MTR 26-9) and spurious opening of the 22 CS Pump discharge valve (MV-32116), causing a flow diversion from the RWST. Cable 2KA2-8C is routed in cable trays wrapped with a one hour fire barrier with detection and without suppression. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 22 CS Pump, MTR 26-9 (26409-C/E/F, 2CB-315) 22 CS Pump Discharge Valve, MV-32116 (2KA2-8C)

This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of suppression with a one hour barrier and detection in the area. Compliant Case: No flow diversion is caused by spurious operation of the Containment Spray System, so adequate Inventory Control is maintained. Disposition Recovery Action(s): No recovery actions.

Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR 26-9 (22 CS Pump) and MV-32116. This ensures that flow diversion from the RWST through the Unit 2 Train B CS system will not occur for credible fire scenarios in FA-58.

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 modeling. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 216 VFDR-058 07 This Variance From Deterministic Requirements involves a fire in FA 58 that could cause spurious closure of MV-32019 and MV-32020, and failure of 21 MDAFW Pump (MTR 25-10) to run. The NFPA 805 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 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) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to the lack of separation between redundant trains of decay heat removal. Compliant Case: The 22 TDAFW Pump to the 22 Steam Generator should be free from fire damage, to ensure adequate Decay Heat Removal is provided. Disposition Recovery Action(s): No recovery actions. Fire modeling for FA 58 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting MTR 25-10 (21 MDAFW Pump), MV-32019 and MV-32020. This ensures that at least one train of AFW remains available for credible fire scenarios in FA-58. 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 modeling. VFDR-058 08 This Variance From Deterministic Requirements involves a fire causing MV-32204 or MV-32205 to spuriously close, which could isolate the minimum flow recirculation line to the RWST from the SI pumps. If the RCS is at normal pressure, and the SI pumps spuriously started, they could be dead headed and damaged if there is no flow. If the fire also prevented MV-32062 from opening, then the RWST supply to the charging pumps could be affected. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 21 RWST to Charging Pump Suction Valve, MV-32062 (2K1-6A, 2K1-6B) SI Recirculation Valve SI test to 21 RWST isolation MV Train A, MV-32204 (2K1-16B wrapped) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 217 SI Recirculation Valve SI test to 21 RWST isolation MV Train B, MV-32205 (2KA2-20B) Compliant Case: 22 SI Pump should be free of fire damage and available for this FA. Disposition Recovery Action(s): Recovery action to manually open 2VC 1. Modification to install suction pressure trips on the Unit 2 charging pumps (Table S-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 a recovery action and a plant modification. VFDR-058 10 This Variance From Deterministic Requirements involves a fire in FA 058 that could damage cables for remote control of the D5 Emergency Diesel Generator, and damage cables for BKR 25-16 (2RY source to Bus 25) and cables for BKR 25-5 (CT12 source to Bus 25). Components and Cables: D5 Diesel Generator (2CA-755, 2CA-757, 2CA-775) BKR 25-2 (25402-E, 2CA-751, 2CA-757) BKR 25-16 (25416-1, 25416-2, 25415-C, 2CA-730) BKR 25-5 (25405-C, 2CA-751) BKR CT12-6 (1CT-1) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of safeguards power. Compliant Case: Train B SI and CC pumps should remain free of fire damage so one train of safeguards power is available. Manually operate D5 in FA 101 at the D5 Benchboard per F5 Appendix D. Disposition Recovery Action(s): Manually operate D5 in FA 101 at the D5 Benchboard per F5 Appendix D. 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 credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 218 VFDR-058 11 This Variance From Deterministic Requirements is caused by fire damage to cables 25410-C, 25410-D, 25410-E, and 2CA-778 which causes a spurious start of the 21 MDAFW Pump (MTR 25-10). This can result in SG overfill of the credited SG. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal. Components and Cables: MTR-25-10 (25410-C, 25410-D, 25410-E, 2CA-778) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of decay heat removal due to over-fill of steam generator. Compliant Case: One train of AFW should remain unaffected by a fire. Disposition Recovery Action(s): Locally open BKR-25-10 at Bus 25 in FA 117 (FDZ 97) to trip the 21 MDAFW 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 recovery actions credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 8 Ionization, Heat N N N N Y Detection 40 Ionization N N N N Y Detection 108 Ionization, Heat N N N N Y Suppression SWP-2 Wet Pipe N N N N Y Stairwell System Suppression SWP-4 Wet Pipe N N N N Y Stairwell System Suppression WPS-11 Wet Pipe N N N N Y Elevator Machine Room 58 Feature See Note ERFBS Y N N Y Y 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 219 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 in a Change Evaluation 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 Fire Area 58 now includes the Unit 2 portion of the elevation, which was Fire Area 73 prior to the transition to NFPA 805. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 220 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 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments Decay Heat Removal (HSB) Hot: Unit 1 - 12 MDAFW Pump to 12 SG Unit 2 - 21 MDAFW Pump to 21 or 22 SG

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 221 Process Monitoring If Train B Process Monitoring is not available, use Train A 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) Unit 2 - Charging System (Train A) VFDR-059 01 VFDR-059 02 VFDR-059 03 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 222 Reactivity Control Unit 1 - Trip reactor from the Control Room. Use Charging Pump (Train A) (Train 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 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A and B Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train A Unit 1 - CC Train A or B Unit 2 - CC Train A CL Train A and B Compressed Air System Train A or B Temporary Control Room and Relay Room HVAC VFDR-059 01 VFDR-059 02 Reference Documents Safe/Genesis V 4.0.2 EC 20725, Fire Risk Evaluation, Fire Area 59, Auxiliary Building Mezzanine Level, Rev. 0, September, 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE 010123, App R Compliance in the Unit 1 & 2, 715© Aux. Bldg, Fire Areas 59 and 74 Summary The purpose of this evaluation is to address the adequacy of the fire area boundary between Aux Bldg Fire Areas 59 (U1) and 74 (U2), and Annulus Fire Areas 68 (U1) and 72 (U2), specifically the adequacy of the separation provided at penetration cabinets 1134 and 1136 in Fire Area 59 and penetration cabinets 2134 and 2136 in Fire Area 74. Power and control cables associated with RCS Vent System valves (credited for RCS pressure reduction during the transition from hot standby to cold shutdown), as well as those for the PZR PORVs and their block valves (a third letdown path and a high-low pressure interface) are routed in the general Aux Building area, and inside the penetration cabinets. Although the cabinet design is not a tested configuration, the cabinet suppression system, fire detection system, negligible in-situ combustibles in the area and spatial separation provides adequate protection to withstand the hazards associated with these fire areas. The combination of all these measures provides adequate assurance that unwrapped penetration cabinets, although not a rated fire design, will provide adequate protection and the ability to achieve safe shutdown will not be adversely affected. The existing fire area boundary penetration cabinet design provides adequate fire protection from a fire outside the cabinets, and would prevent a fire inside the cabinet becoming an exposure fire. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 223 during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-040, NFPA 13, 1969 Code Compliance Deviations, PA-3, 4, 6, 7 Penetration Areas Summary The purpose of this analysis is to document the review of the PA-3, PA-4, PA-6, and PA 7 pre-action sprinkler systems in the Auxiliary Building and in the Containment Annulus of each unit for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record).. Eight deviations have been justified as "acceptable"; therefore, no further action is necessary. Two deviations require additional actions to resolve the noncompliances associated with temperature ratings of installed sprinklers and the location of sprinkler heads relative to the "ceiling" in the Containment Annulus. Action Requests have been initiated to track resolutions of the identified issues. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. 6.4 Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. EEEE Title AR 1352782, 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 224 Variances from Deterministic Requirements (VFDR) VFDR-059 01 This Variance From Deterministic Requirements involves a fire in FA 059 that could damage Train A safeguards chillers (MCC 1T1, MTR 112G-11, MTR 112G-12, MTR 112G-15, MTR 11G-17) and Train B safeguards chillers (MTR 122G-11, MTR 122G-12, MTR 122G-5) which causes loss of cooling to the Control Room (FA 13) and Relay Room (FA 18). The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. Components and Cables: Train A Safeguards Chillers MCC 1T1 (212G-1, 212G-2) 121 Control Room Air Handler and Fan, MTR 112G-5 (1CA-484, 1CA-485) 121 Control Room Chiller, MTR 112G-11 (1CA-546, 1CA-547) 121 Control Room Chilled Water Pump, MTR 112G-12 (112G-1B, 1CA-54, 1CA-546, 1CA-547) 121N Relay Room Unit Cooler, MTR 112G-15 (1HVA-92) (Relay Room Only) 121S Relay Room Unit Cooler, MTR 112G-17 (1HVA-88) (Relay Room Only)

Train B Safeguards Chillers 122 Control Room Air Handler and Fan, MTR 122G-5 (1CB-340, 1CB-341 122 Control Room Chiller, MTR 122G-11 (1CB-412, 1CB-413) 122 Control Room Chilled Water Pump, MTR 122G-12 (1CB-397, 1CB-412, 1CB-413 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of safeguards chilled water. There is a lack of separation between redundant trains of safeguards chilled water. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries. Compliant Case: One Train of Safeguards chillers should remain free of fire damage. Disposition Recovery Action(s): Open door to control room and install fan to provide supplemental cooling to the control room per procedure C37.9 AOP1. Open door to relay room to provide supplemental cooling to the control room per procedure C37.9 AOP2. 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 credited. VFDR-059 01 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which spuriously closes CV-31245 (11 Reactor Coolant Pump (RCP) Thermal Barrier Heat Exchanger (TBHX)) and CV-31335 (11 RCP Seal Injection), which could cause a loss of all seal cooling to the Reactor Coolant Pump. This could result in increased leakage through the RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 225 Components and Cables: 11 RCP TBHX, CV-31245 (1C-2221) 11 RCP Seal Injection CV-31335 (1C-1169) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of cooling to RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31245 or CV-31335 should remain free of fire damage to provide cooling to the RCP seals. Disposition Recovery Action(s): No recovery actions. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification. VFDR-059 02 This Variance From Deterministic Requirements involves a fire in FA 059, which damages CV-31246, 12 RCP TBHX and CV-31336 (12 RCP Seal Injection), which could cause a loss of all seal cooling to the Reactor Coolant Pump. This could result is increased leakage through the RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 12 RCP TBHX, CV-31246 (1C-4638) 12 RCP Seal Injection, CV-31336 (1C-1171) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of cooling to RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31246 or CV-31336 should remain free of fire damage to provide cooling to the RCP seals. Disposition Recovery Action(s): No recovery actions. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 226 control room to provide makeup for RCS leakage (Table S-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 a plant modification. VFDR-059 03 This Variance From Deterministic Requirements (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 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 1 PRZR PORV B Control Valve, CV-31231 (1CB-928, 1CR-34, 1CY-109) 1 PRZR PORV A Isolation Valve, MV-32195 (1LA1-11, 1LA1-11A, 1LA1-11B) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of PORV isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31231 or MV-32195 should remain free of fire damage to isolate the PORV letdown path to maintain Inventory Control. Disposition Recovery Action(s): No recovery actions. Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31231 and MV-32195. Because of this, there will always be a means from the control room to isolate RCS leakage through the pressurizer PORV either with the PORV itself (CV-31231) or its associated block valve (MV-32195). In this manner, RCS inventory control is maintained. 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 modeling. VFDR-059 04 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which spuriously opens CV-31232 (1 PRZR PORV A CV) and MV-32196 (1 PRZR PORV B Isolation MV). If the PORV spuriously opens and the block valve cannot close, a loss of RCS Inventory could occur. CV-31232 is separated from MV-32196 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 227 Components and Cables: 1 PRZR PORV A Control Valve, CV-31232 (1CA-1133, 1CR-34, 1CY-109) 1 PRZR PORV B Isolation Valve, MV-32196 (1LA2-12, 1LA2-12A, 1LA2-12B) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of PORV isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31232 or MV-32196 should remain free of fire damage to isolate the PORV letdown path to maintain Inventory Control. Disposition Recovery Action(s): No recovery actions. Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31232 and MV-32196. Because of this, there will always be a means from the control room to isolate RCS leakage through the pressurizer PORV either with the PORV itself (CV-31232) or its associated block valve (MV-32196). In this manner, RCS inventory control is maintained. 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 modeling. VFDR-059 05 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which fails the ability to close CV-31226 (U1 Letdown Isolation Train A) and CV-31255 (U1 Letdown Isolation Train B). If both letdown valves fail to isolate, a loss of RCS Inventory could occur. CV-31226 is separated from CV-31255 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: Letdown Isolation Train A, CV-31226 (1CA-291) Letdown Isolation Train B, CV-31255 (1CB-283) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of letdown isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31226 or CV-31255 should remain free of fire damage to isolate the normal letdown path. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 228 Disposition Recovery Action(s): No recovery actions. Fire modeling for FA-59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31226 and CV-31255. Because of this, there will always be a means from the control room to isolate RCS letdown flow to maintain RCS inventory control. 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 modeling. VFDR-059 06 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which spuriously opens CV-31330 (U1 Excess Letdown HX Inlet Isolation) and CV-31210 (U1 Excess Letdown HX Outlet Flow Control Valve). If both excess letdown valves spuriously open, a loss of RCS Inventory could occur. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: Excess Letdown HX Inlet Isolation Valve, CV-31330 (1C-1128) Excess Letdown HX Outlet Flow Control Valve, CV-31210 (1CF-144) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of letdown isolation. Compliant Case: CV-31210 or CV-31330 should remain free of fire damage to isolate the excess letdown path. Disposition Recovery Action(s): No recovery actions. Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31330 and CV-31210. Because of this, there will always be a means from the control room to isolate RCS excess letdown flow to maintain RCS inventory control. 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 modeling. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 229 VFDR-059 08 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which spuriously opens 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. NFPA 805, Section 2.4.2.2.1 Circuits Required for Nuclear Safety Functions, references Appendix B for considerations in analyzing circuits. NFPA 805, Appendix B.3.3 Specific Circuit Failure Scenarios states "It should be noted that for high-low pressure interface valves, removing power at the motor control center (MCC) during normal power operations does not eliminate the potential three-phase proper phase ac hot shorts." If both valves spuriously open, a loss of RCS Inventory could occur. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 1RCS Loop A Hot Leg RHR Supply (Inside), MV-32164 (1LA1-2, 1LA1-2A, 1LA1-2B) 1RCS Loop A Hot Leg RHR Supply (Outside), MV-32165 (1LA1-3, 1LA-3A, 1LA1-3B) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant RHR suction valves. Compliance Case: MV-32164 should remain free of fire damage to isolate the RHR letdown path. Disposition Recovery Action(s): MV-32164 is de-energized and will remain closed to provide isolation of the high/low pressure interface. MV-32165 will remain closed to provide isolation of the high/low pressure interface per configuration change (Table S-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 configuration change credited. VFDR-059 09 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which spuriously opens 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. NFPA 805, Section 2.4.2.2.1 Circuits Required for Nuclear Safety Functions, references Appendix B for considerations in analyzing circuits. NFPA 805, Appendix B.3.3 Specific Circuit Failure Scenarios states "It should be noted that for high-low pressure interface valves, removing power at the motor control center (MCC) during normal power operations does not eliminate the potential three-phase proper phase ac hot shorts." If both valves spuriously open, a loss of RCS Inventory could occur. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. This represents a variation from the deterministic requirements (VFDR) 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, 1LA2-4A, 1LA2-4B) 1RCS Loop B Hot Leg RHR Supply (Outside), MV-32231 (1LA2-11, 1LA2-11A, 1LA2-11B) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 230 Compliance Case MV-32230 should remain free of fire damage to isolate the RHR letdown path. Disposition Recovery Action(s): MV-32230 is de-energized and will remain closed to provide isolation of the high/low pressure interface. MV-32231 will remain closed to provide isolation of the high/low pressure interface per configuration change. (Table S-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 configuration change credited. VFDR-059 10 This Variance From Deterministic Requirements involves a fire in FA 059 which damages Train A and Train B Process Monitoring Indication. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring, Pressurizer Level, Steam Generator Level, Source Range, RCS Pressure, and RCS Temperature Indication. Components and Cables: PNL 1EMA (1CA-1228) LOOP 1L-433 (1CA-1106, 1CF-236) LOOP 1L-487 (1CX-125) LOOP 1N51 (1CNX-3, 1CNX-4) LOOP 1P-709 (1CX-119) LOOP 1T-450A (1CX-131) LOOP 1T-450B (1CX-133)

PNL 1EMB (1CB-981, 2CV-38) LOOP 1L-426RP (1CR-34) LOOP 1L-488 (1CR-128) LOOP 1N52 (1CNY-3) LOOP 1P-710 (1CR-122) LOOP 1T-451A (1CR-132) LOOP 1T-451B (1CR-134)

This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of process monitoring. The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring, Pressurizer Level, Steam Generator Level, Source Range, RCS Pressure, and RCS Temperature Indication. Compliant Case: One Train of Process Monitoring should remain free of fire damage. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 231 Disposition Recovery Action(s): No recovery action. Fire modeling for FA 59 indicates that there are no fire scenarios that will result in loss of both trains of instrumentation required for process monitoring. This ensures that adequate process monitoring instrumentation remains available to monitor required parameters. 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 modeling. VFDR-059 11 This Variance From Deterministic Requirements involves a fire in FA 59 which damages 4 kV power cables and DC control power to trip BKR 16-10, Bus 16/26 cross-tie. Bus 16 is credited to power 12 MDAFW Pump. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries to provide vital AC power. Components and Cables: BKR 16-10 (26401-1, 26401-2, 2CB-679)

This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between 4KV safeguards power. The NFPA 805 Nuclear Safety Performance Criteria is not met for Vital Auxiliaries to provide vital AC power. Compliant Case: 12 MDAFW Pump fully able to inject to the 12 SG Disposition Recovery Action(s): No recovery action.

Modification to eliminate the possibility that a fire could cause a loss of DC cubicle control power to BKR-16-10. Modification will allow BUS-16 to remain available in FA 59 (Table S-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 a plant modification. VFDR-059 01 The Variance From Deterministic Requirements involves a fire in FA 59, which damages CV-31248 (22 RCP TBHX) and CV-31427 (22 RCP Seal Injection) which could cause a loss of all seal cooling to the Reactor Coolant Pump. This could result is increased leakage through the RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 232 Components and Cables: 22 RCP TBHX, CV-31248 (2C-2556) 22 RCP Seal Injection, CV-31427 (2C-1455) This represents a VFDR of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of RCP seal cooling. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. 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 action. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification. VFDR-059 02 This Variance From Deterministic Requirements (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 NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 2 PRZR PORV B, CV-31233 (2CB-472, 2CR-9, 2CX-9, 2CY-9) 2 PRZR PORV ISOLATION A, MV-32197 (2LA1-23, 2LA1-23A, 2LA1-23B) This represents a VFDR of NFPA 805, Section 4.2.3.4 due to lack of separation between redundant trains of PORV isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31233 or MV-321971 should remain free of fire damage to isolate the PORV letdown path to maintain Inventory Control. Disposition Recovery Action(s): No recovery action Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 233 Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31233 and MV-32197. Because of this, there will always be a means from the control room to isolate RCS leakage through the pressurizer PORV either with the PORV itself (CV-31233) or its associated block valve (MV-32197). In this manner, RCS inventory control is maintained. 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 modeling. VFDR-059 03 This Variance From Deterministic Requirements involves a fire in FA 59 which damages 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. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 2 PRZR PORV A, CV-31234 (2CA-522, 2CR-9, 2CW-9, 2CY-9) 2 PRZR PORV ISOLATION B, MV-32198 (2LA2-20, 2LA2-20A, 2LA-20B)

This represents a VFDR of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of PORV isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31234 or MV-32198 should remain free of fire damage to isolate the PORV letdown path to maintain Inventory Control. Disposition Recovery Action(s): No recovery action Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31234 and MV-32198. Because of this, there will always be a means from the control room to isolate RCS leakage through the pressurizer PORV either with the PORV itself (CV-31234) or its associated block valve (MV-32198). In this manner, RCS inventory control is maintained.

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 modeling. VFDR-059 04 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59, which spuriously opens 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 with negligible intervening combustibles with automatic fire detection, but an automatic fire suppression system is not installed in the area. Failure to isolate letdown could result in a loss of RCS Inventory. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 234 Components and Cables: Letdown Isolation Train A, CV-31230 (2CA-359) Letdown Isolation Train B, CV-31279 (2CB-350) This represents a VFDR of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of letdown isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Compliant Case: CV-31230 or CV-31279 should remain free of fire damage to isolate the normal letdown path. Disposition Recovery Action(s): No recovery action Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables affecting both CV-31230 and CV-31279. Because of this, there will always be a means from the control room to isolate RCS letdown flow to maintain RCS inventory control. 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 modeling. VFDR-059 05 This Variance From Deterministic Requirements involves a fire in FA 59 which damages CV-31422 (U2 Excess Letdown HX Inlet Isolation) and CV-31222 (U2 Excess Letdown HX Outlet Flow Control Valve). The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: Excess Letdown HX Inlet Isolation Valve, CV-31422 (2C-1455) Excess Letdown HX Outlet Flow Control Valve, CV-31222 (2CF-96) This represents a VFDR of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of excess letdown isolation. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control

Compliant Case: CV-31222 should remain free of fire damage to isolate the excess letdown path. Disposition Recovery Action(s): No recovery action Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 235 Fire modeling for FA 59 indicates that three fire scenarios (FDS-59GRP-013, -022, -041) will result in simultaneous damage to cables for both CV-31422 and CV-31222, resulting in loss of both trains of excess letdown isolation and loss of RCS inventory control. 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 modeling. VFDR-059 06 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 059 which damages 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. NFPA 805, Section 2.4.2.2.1 Circuits Required for Nuclear Safety Functions, references Appendix B for considerations in analyzing circuits. NFPA 805, Appendix B.3.3 Specific Circuit Failure Scenarios states "It should be noted that for high-low pressure interface valves, removing power at the motor control center (MCC) during normal power operations does not eliminate the potential three-phase proper phase ac hot shorts." If both valves spuriously open, a loss of RCS Inventory could occur. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 2RCS Loop A Hot Leg RHR Supply (Inside), MV-32192 (2LA1-10, 2LA1-10A, 2LA1-10B) 2RCS Loop A Hot Leg RHR Supply (Outside), MV-32193 (2LA1-14, 2LA1-14A, 2LA1-14B) This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 2.4.2.2 due to a lack of separation between redundant RHR suction valves. Compliant Case: MV-32192 should remain free of fire damage to isolate the RHR letdown path. Disposition Recovery Action(s): MV-32192 is de-energized and will remain closed to provide isolation of the high/low pressure interface. MV-32193 is de-energized and will remain closed to provide isolation of the high/low pressure interface per configuration change (Table S-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 configuration change credited. VFDR-059 07 This Variance From Deterministic Requirements involves a fire in FA 059 which damages MV-32232, 2RCS Loop B Hot Leg RHR Supply (Inside) and MV-32233, 2RCS Loop B Hot Leg RHR Supply (Outside). MV-32233 has its breaker de-energized to preclude spurious opening. NFPA 805, Section 2.4.2.2.1 Circuits Required for Nuclear Safety Functions, references Appendix B for considerations in analyzing circuits. NFPA 805, Appendix B.3.3 Specific Circuit Failure Scenarios states "It should be noted that for high-low pressure interface valves, removing power at the motor control center (MCC) during normal power operations does not eliminate the potential three-phase proper phase ac hot shorts." The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 236 Components and Cables: 2RCS Loop B Hot Leg RHR Supply (Inside), MV-32232 (2LA2-10, 2LA2-10A, 2LA2-10B) 2RCS Loop B Hot Leg RHR Supply (Outside), MV-32233 (2LA2-8, 2LA2-8A, 2LA2-8B) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant RHR suction valves Compliant Case: MV-32232 should remain free of fire damage to isolate the RHR letdown path. Disposition Recovery Action(s): MV-32232 is de-energized and will remain closed to provide isolation of the high/low pressure interface. MV-32233 is de-energized and will remain closed to provide isolation of the high/low pressure interface per configuration change (Table S-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 configuration change credited. VFDR-059 08 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which damages cables for Train A Process Monitoring Indication for LOOP 2L-433 (21 Pressurizer Level Indication), LOOP 2L-487 (21 Steam Generator Level Indication), LOOP 2N51 (U2 Excore Detection), LOOP 2P-709 (U2 Loop A RCS Wide Range Pressure), LOOP 2T-450A (U2 RCS Loop A Hot Leg Temperature) and LOOP 2T-450B (U2 RCS Loop A Cold Leg Temperature). A fire in FA 74 could also damage cable 221F-1 for MCC 2AC2 which powers 22 Battery Charger, which powers Inverter 28, which powers PNL 2EMB, which powers Train B Process Monitoring Indication LOOP 2L-488 (Pressurizer Level Red Channel), LOOP 2N52 (U2 Excore Detection), LOOP 2P-710 (U2 Loop B RCS Wide Range Pressure), LOOP 2T-451A (U2 RCS Loop B Hot Leg Temperature), and LOOP 2T-451B (U2 RCS Loop B Cold Leg Temperature). Damage to cable 221F-1 also affects power to 22 Inverter which powers PNL 212 for 2L-426 (Pressurizer Level Indication). The NFPA 805 Nuclear Safety Performance Criteria is not met for Process Monitoring for Steam Generator Level, Source Range Flux, RCS Temperature, and RCS Pressure. Components and Cables: Train A LOOP 2L-433 (1CA-1106, 2CF-207) LOOP 2L-487 (2CX-70) LOOP 2N51 (2CNX-3, 2CNX-4) LOOP 2P-709 (2CX-64) LOOP 2T-450A (2CX-76) LOOP 2T-450B (2CX-78) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 237 Train B LOOP 2L-426RP (221F-1) Pressurizer Level Indication, 2LR-460 (221F-1) LOOP 2L-488 (221F-1, 2CR-74) LOOP 2N52 (221F-1, 2CNY-3) LOOP 2P-710 (221F-1, 2CR-68) LOOP 2T-451A (221F-1, 2CR-78) LOOP 2T-451B (221F-1, 2CR-80) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of process monitoring. Compliant Case: At least one train of Process Monitoring instrumentation should remain free of fire damage. Disposition Recovery Action(s): No recovery action Fire modeling for FA 59 indicates that there are no fire scenarios that will result in simultaneous damage to cables to cause loss of both Unit 2 A and B Trains of Process Monitoring instrumentation. This means that at least one train of process monitoring will remain free of fire damage such that critical parameters can be monitored from the Control Room. 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 modeling. VFDR-059 10 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which damages the ability to trip MTR 21-3 (21 Main Feedwater Pump), and close MV-32028 (21 Main Feedwater Isolation Valve), close CV-31135 (21 Main Feedwater Regulating Valve) and close CV-31371 (21 Main Feedwater Bypass Control Valve). Failure to isolate main feedwater to the 21 Steam Generator could over-fill the Steam Generator. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. 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, 2CB-322) 21 Main Feedwater Bypass Control Valve, CV-31371 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-363, 2CB-323)

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 238 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of process monitoring. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Compliant Case: Main Feedwater should automatically isolate to 21 Steam Generator from the Control Room. Disposition Recovery Action(s): No recovery action Fire modeling for FA 59 indicates that there are no fire scenarios that will result in damage to cable 21403-G, so operators retain the ability to trip 21 Main Feedwater pump from the control room to prevent steam generator overfill.

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 modeling. VFDR-059 11 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 which damages the ability to trip MTR 22-3 (22 Main Feedwater Pump), close MV-32029 (22 Main Feedwater Isolation Valve), close CV-31136 (22 Main Feedwater Regulating Valve), and close CV-31372 (22 Main Feedwater Bypass Control Valve). Failure to isolate main feedwater to the 22 Steam Generator could over-fill the Steam Generator. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Components and Cables: 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, 2CB-321) 22 Main Feedwater Bypass Control Valve, CV-31372 (2CX-13, 2CR-12, 2CY-11, 2CW-13, 2CA-417, 2CB-115, 2CA-362, 2CB-320) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of process monitoring. The NFPA 805 Nuclear Safety Performance Criteria is not met for Decay Heat Removal. Compliant Case: Main Feedwater should automatically isolate to 22 Steam Generator from the Control Room. Disposition Recovery Action(s): No recovery action Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 239 Fire modeling for FA 59 indicates that there are no fire scenarios that will result in damage to cable 21403-K, so operators retain the ability to trip 22 Main Feedwater pump from the control room to prevent steam generator overfill.

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 modeling. VFDR-059 12 This Variance From Deterministic Requirements is due to a fire in FA 059 that could damage DC control power to Bus 26 tripping circuits and subsequent damage to AC power cables resulting in a loss of Bus 26. 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) BKR 26-1 (26401-1, 26401-2, 2CB-679) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between 4KV Breakers Compliant Case: 4KV Breaker would be free of fire damage. Disposition Recovery Action(s): No recovery action VFDR-059 12 will be resolved by a modification that will protect the over-current trip capability on Bus 26 (Table S-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 a plant modification. VFDR-059 13 The Variance From Deterministic Requirements involves a fire in FA 059 which damages 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 result in increased leakage through the RCP seals. The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 21 RCP TBHX, CV-31247 (2C-2553) 21 RCP Seal Injection, CV-31426 (2C-1455)

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 240 This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of RCP seal cooling. Compliant Case: CV-31247 or CV-31426 should remain free of fire damage to provide cooling to the RCP seals. Disposition Recovery Action(s): No recovery action. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification. VFDR-059 16 This Variance From Deterministic Requirements (VFDR) involves a fire in FA 59 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, results in a spurious "P" signal. The spurious "P" signal will open MV-32116, 22 CS PMP DISCH MV, and close BKR 26-9, 22 CONTAINMENT SPRAY PUMP BREAKER, resulting in a RWST drain down. Damage to cables for BKR 26-9 results in a loss of DC control power for BKR 26-9 trip coil and the inability to trip the breaker.

The NFPA 805 Nuclear Safety Performance Criteria is not met for Inventory Control and Reactivity Control. 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-E)

This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3, due to lack of separation between redundant trains of containment pressure transmitters. Compliant Case: No flow diversion should be caused by spurious operation of the Containment Spray System, so that RWST inventory is maintained. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 241 Disposition Recovery Action(s): Modification to protect cable 2CW-19 (2PT-946) from fire damage in FA 58 (Table S-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 a plant modification. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 19 Ionization N N N N Y Detection 46 Ionization N N N N Y Detection 108 Ionization N N N N Y Suppression PA-3 Pre-Action N N N N Y Suppression PA-4 Pre-Action N N N N Y Suppression PA-6 Pre-Action N N N N Y Suppression PA-7 Pre-Action N N N N Y Suppression WPS-12 Wet Pipe N N N N Y Suppression WPS-19 Wet Pipe N N N N Y 59 Feature See Note ERFBS N N N Y N 1AM-TA12, 1AM-TA13, 1AM-TA16, 1AM-TB26I, 1AM TR1, 1CA-1133, 1CB-928, 1CNY-3, 1LA1-1A, 1LA1-3B, 2CF-74 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 242 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 243 Unit Fire Area Description 1 60 Auxiliary Building Operating Level Unit 1 Regulatory Basis 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 (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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 244 Reactivity Control Unit 1 - 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 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 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC (Train B) Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. 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-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 245 Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues EEEE Title FPEE-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. 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 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 246 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 S L E R D Notes Detection 28 Ionization, Heat N N N N N Detection 108 Ionization, Heat N N N N N Suppression SWP-4 Wet Pipe N N N N N Stairwell System 60 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 in a Change Evaluation 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 247 Unit Fire Area Description 1, 2 61 Auxiliary Building Anti "C" Clothing Area Regulatory Basis 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-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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 248 Reactivity Control Unit 1 - 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 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 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-015, NFPA 13, 1969 Code Compliance Deviations, WPS-27, 28 Summary The purpose of this analysis is to document the review of the WPS-27 and WPS-28 wet pipe sprinkler systems protecting the Demin. Removal and Anti-C Clothing Area in the Auxiliary Building, elevation 735ft, Fire Area 61, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems (Code of Record). Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Seven deviations require additional actions to resolve noncompliances associated with (a) lack of testing of system drain valves and flow switches, (b) lack of drawings depicting the systems, (c) use of pendent sprinklers without return bends in the part-height office enclosure, (d) use of a sidewall sprinklers by the removable cover in WPS-28, (e) use of intermediate temperature rated heads in the part-height office enclosure, (f) beam obstructions to water distribution in WPS-28, and (g) a sprinkler head located under a 30in deep beam, too far from the ceiling, in WPS-27. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 249 during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes 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 61 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 in a Change Evaluation or Fire Risk Evaluation

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 250 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 251 Unit Fire Area Description 1, 2 61A Auxiliary Building Hatch Area Note: Fire Area 61A is now combined into Fire Area 4. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 252 Unit Fire Area Description 1, 2 62 Spent Fuel Pool Area Note: Fire Area 62 is now combined into Fire Area 4. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 253 Unit Fire Area Description 1, 2 63 Filter Room Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 254 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 (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) (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) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 255 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 S L E R D Notes Detection - - - - - - - Suppression - - - - - - - 63 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 256 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 257 Unit Fire Area Description 1 64 Auxiliary Building Low Level Decay Area Unit 1 Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 258 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 (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) (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) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 259 Vital Auxiliaries Unit 1 - Offsite Power (1R) supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-12-005, CA-01311402-03, Fire Doors 136 & 139 Summary The purpose of this evaluation is to assess Doors 136 and 139, both of which have 12in by 12in access openings near the bottom of the door to pass temporary materials such as hoses. The openings are protected by 14in by 14in access opening metal cover plates that are secured closed when not in use. The doors are in series on opposite ends of the airlock in the boundaries between Fire Area 4 (Fuel Handling Area) and Fire Area 64 (Auxiliary Building Low Level Decay Area Unit 1) on the 695ft elevation of the Fuel Handling Building. Fire Doors 136 and 139, inclusive of the 1/16in access opening metal cover plate assemblies that cover both sides of the access openings in each door, provide adequate protection to prevent fire spread between Fire Area 4 and Fire Area 64. In the unlikely event that fire does spread between the two areas, there will be no adverse impact on safe shutdown capability. The 1R and 2RY transformers remain available from the Control Room to provide offsite power to Bus 15 and Bus 16, and to Bus 25 and Bus 26, respectively, given a fire in either or both of these areas, and Bus 16 will be isolated from a postulated fault on its normal offsite power feed by implementation of existing local manual actions.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 260 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 8 Ionization N N N N N Suppression - - - - - - - 64 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 261 Unit Fire Area Description 1 65 Spent Fuel Pool Heat Exchanger & Pumps Regulatory Basis 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 21 SG or 22 SG

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 262 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 (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) (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) (Train A) or Safety Injection Pump (Train B) to inject borated water from the RWST Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 263 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 264 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection - - - - - - - Suppression - - - - - - - 65 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 265 Unit Fire Area Description 2 66 D3 Lunch Room Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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-426-RP) Pressurizer Level Red Channel (LOOP 1L-433) 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 266 Inventory and Pressure Control Unit 1 - Charging System (Train A) or Safety Injection (Train B) Unit 2 -Safety Injection (Train B) Reactivity Control Unit 1 - 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 2 - Trip reactor from the Control Room. Use 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 (CT 12) supplying Electrical Distribution Train B Unit 1 - CC Train A or B Unit 2 - CC Train B CL Train A or B Compressed Air System Train B Control Room and Relay Room HVAC (Train B) Reference Documents Safe/Genesis V 4.0.2 EC 20726, Fire Risk Evaluation, Fire Area 66, D3 Lunch Room, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. EEEE Title FPEE-11-056, NFPA 13, 1989 Code Compliance Deviations, WPS-22 Summary The purpose of this analysis is to document the review of the WPS-22 wet pipe sprinkler system protecting Fire Area 66, Storage Room, against the requirements of National Fire Protection Association 13, (NFPA) -1969, Standard for the Installation of Sprinkler Systems. Attachment 1 identifies ten deviations to the code requirements of NFPA 13-1969. Several of the identified deviations are associated with multiple code sections, for a total of thirteen code sections as identified in this report. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 267 Variances from Deterministic Requirements (VFDR) VFDR-066 01 This variance from the deterministic requirements results in loss of automatic backwash to 11, 12, 21, and 22 Cooling Water (CL) Strainers, due to fire damage to cables. Fire damage could potentially cause a spurious closure of BKR 15-8 (Bus 15 crosstie to Bus 25). Additional cable failures could cause a loss of Overcurrent Trip capability on BKR 15-8. Additional cable failures could then fault Bus 15. Bus 15 is the ultimate power source for 230V Panel 136 which provides the control power to the backwash control panel for all four of the CL Strainers when they are in the Normal Control Mode of backwash operation. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: BKR-15-8 (25417-1, 25417-2 and 2CA-749) 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. Compliant Case: The ability to automatically backwash the CL Strainers should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. This would impact Unit 1 and Unit 2. Disposition Recovery Action(s): No recovery action. Modification to correct breaker coordination such that a fault on BKR 15-8 will not result in the loss of Bus 15 (Table S-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 a plant modification credited. VFDR-066 02 This Variance From Deterministic Requirements is due to a fire in FA 066 that could damage cables for DC control power to Bus 25 tripping circuits, and subsequent fire damage to AC power cables. These cable failures could fail Bus 25. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: BKR 25-8 (25410-E), BKR 25-7, (25410-E) BKR 25-13 (25413-1, 25413-D, 25413-E) BKR 25-9 (25410-E) BKR 25-10 (25410-1, 25410-C, 25410-D, 25410-E, 2CA-778) BKR 25-17 (2CA-749, 25417-1, 25417-2) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 268 BKR 25-15 (112A-1, 112A-2, 112A-3, 25410-E, 25415-1, 2CA-750) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains vital buses. Compliant Case: Breaker coordination should exist such that associated loads do not result in the loss of the 4kV bus. Disposition Recovery Action(s): No recovery action. Modification to eliminate the possibility that a fire could cause 4kV power cables to start a fire in other fire areas (Table S-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 a plant modification credited. VFDR-066 03 This Variance From Deterministic Requirements is caused by fire damage to cables 25410-C, 25410-D, and 25410-E causing a spurious start or the inability to stop 21 AFW Pump (MTR 25-10). This can result in SG overfill of the credited SG. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal. Components and Cables: MTR-25-10 25410-C, 25410-D, 25410-E This represents a variance from the deterministic requirements (VFDR) 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. Compliant Case: One train of Decay Heat Removal should remain available. Disposition Recovery Action(s): Locally close MV-32383 and MV-32384 in FA 031 to isolate the uncontrolled feed to 21 and 22 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 a recovery action credited. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 269 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 39 Ionization N N N N Y Suppression WPS-22 Wet Pipe N N N N Y 66 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 in a Change Evaluation 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 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 270 Unit Fire Area Description 1, 2 67 Resin Disposal Building Note: Fire Area 67 is now combined into Fire Area 4. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 271 Unit Fire Area Description 1, 2 68 Containment Annulus Unit 1 Note: Fire Area 68 is now combined into Fire Area 1 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 272 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 273 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 274 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 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 Note: Unit 2, one SG could be affected but the redundant SG remains available. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 275 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 (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. 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 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 276 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 EC 20715, Fire Risk Evaluation, Fire Area 71, Unit 2 Containment, Rev. 0, September 2012 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 010123, App R Compliance in the Unit 1 & 2, 715© Aux. Bldg, Fire Areas 59 and 74 Summary The purpose of this evaluation is to address the adequacy of the fire area boundary between Aux Bldg Fire Areas 59 (U1) and 74 (U2), and Annulus Fire Areas 68 (U1) and 72 (U2), specifically the adequacy of the separation provided at penetration cabinets 1134 and 1136 in Fire Area 59 and penetration cabinets 2134 and 2136 in Fire Area 74. Power and control cables associated with RCS Vent System valves (credited for RCS pressure reduction during the transition from hot standby to cold shutdown), as well as those for the PZR PORVs and their block valves (a third letdown path and a high-low pressure interface) are routed in the general Aux Building area, and inside the penetration cabinets. Although the cabinet design is not a tested configuration, the cabinet suppression system, fire detection system, negligible in-situ combustibles in the area and spatial separation provides adequate protection to withstand the hazards associated with these fire areas. The combination of all these measures provides adequate assurance that unwrapped penetration cabinets, although not a rated fire design, will provide adequate protection and the ability to achieve safe shutdown will not be adversely affected. The existing fire area boundary penetration cabinet design provides adequate fire protection from a fire outside the cabinets, and would prevent a fire inside the cabinet becoming an exposure fire. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 277 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 FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) VFDR-071 01 This Variance From Deterministic Requirements occurs from a fire in FA 071 that could damage cables for CV-31247 and CV-31426. Fire induced cable damage and spurious closure of this component will interrupt RCP seal leakoff flow, which is credited for RCP seal injection. The Nuclear Safety Performance Criteria is not met for Inventory Control. 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)

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. Compliant Case: CV-31247 or CV-31426 should remain free of fire damage to provide thermal barrier cooling to the RCP seals. Disposition Recovery Action(s): No recovery action. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 278 VFDR-071 02 This Variance From Deterministic Requirements occurs from a fire in FA 071 that could damage cables for CV-31248 and CV-31427. Fire induced cable damage and spurious closure of this component will interrupt RCP seal leakoff flow, which is credited for RCP seal injection. The Nuclear Safety Performance Criteria is not met for Inventory Control. Components and Cables: 22 RCP TBHX CC, CV-31248 (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) 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. Compliant Case: CV-31248 or CV-31427 should remain free of fire damage to provide thermal barrier cooling to the RCP seals. Disposition Recovery Action(s): No recovery actions. Modification to install shutdown RCP seals will alleviate the need for a recovery action given RCS injection is restored from the control room to provide makeup for RCS leakage (Table S-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 a plant modification. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 42 Ionization N N N N Y Detection 47 Ionization, Flame N N N N Y Detection 52 Ionization N N N N Y Detection 54 Ionization N N N N Y Detection 56 Ionization N N N N Y 71 Feature See Note ERFBS N N N N Y Cable 2CF-74 has 3M Interam wrap Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 279 Detection 42 Ionization N N N N Y Detection 47 Ionization, Flame N N N N Y Detection 52 Ionization N N N N Y Detection 54 Ionization N N N N Y Detection 56 Ionization N N N N Y Suppression PA-5 Pre-Action N N N N N Suppression PA-6 Pre-Action N N N N N 72 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 in a Change Evaluation 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 Fire Area 71 now includes the Unit 2 Annulus, which was Fire Area 72 prior to the transition to NFPA 805. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 280 Unit Fire Area Description 2 72 Containment Annulus Unit 2 Note: Fire Area 72 is now combined into Fire Area 71. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 281 Unit Fire Area Description 2 73 Auxiliary Building Ground Floor Unit 2 Note: Fire Area 73 is now combined into Fire Area 58. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 282 Unit Fire Area Description 2 74 Auxiliary Building Mezzanine Floor Unit 2 Note: Fire Area 74 is now combined into Fire Area 59. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 283 Unit Fire Area Description 2 75 Auxiliary Building Operating Level Unit 2 Regulatory Basis 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 -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-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 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 284 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 Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 285 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. 6.4 Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. 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 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 286 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 51 Ionization N N N N N Suppression - - - - - - - 75 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 287 Unit Fire Area Description 2 76 Vent & Fan Room Unit 2 Note: Fire Area 76 is now combined into Fire Area 2. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 288 Unit Fire Area Description 2 77 Auxiliary Building Low Level Decay Area Unit 2 Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 289 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 290 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 S L E R D Notes Detection - - - - - - - Suppression - - - - - - - 77 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 291 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 F5 Appendix A. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 292 Unit Fire Area Description 2 78 Waste Gas Compressor Area Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 293 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 (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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 294 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 Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 S L E R D Notes Detection 33 Ionization N N N N N Suppression - - - - - - - 78 Feature - - - - - - - Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 295 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 296 Unit Fire Area Description 1 79 480 V Safeguard Switchgear Room (Bus 112) Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 297 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 298 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution portions of Train A or all of Train B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 299 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 26 Ionization N N N N N Suppression - - - - - - - 79 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 300 Unit Fire Area Description 1 80 480 V Safeguard Switchgear Room (Bus 111) Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 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 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 301 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 Train A or B Unit 2 - Offsite Power supplying Electrical Distribution Train A or B Unit 1 CC Train B Unit 2 CC Train B CL Train B Compressed Air System Train B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 EC 20731, Fire Risk Evaluation, Fire Area 80, 480V Safeguards Switchgear Room (Bus 111), Rev. 0, September 2012 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. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 302 necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) VFDR-080 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21, and 22 Cooling Water (CL) Strainers, due to fire damage to cables. Fire damage could potentially cause loss of Bus 111. Power is provided from Panel MCC-1AB1 to Panel 136 via Bus 111. Bus 111 is the power source for 230V Panel 136 which provides the control power to the backwash control panel for all four of the CL Strainers when they are in the Normal Control Mode of backwash operation. Loss of Panel 136 results in the loss of automatic backwash control for all four CL Strainers. Bus 111 is located in FA 080. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: MCC-1AB1, motor control center 1AB Bus 1 (111C-1, 111C-2, 111C-3, 111C-4, 211C-1 and 211C-2) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers. Compliance Case: The ability to backwash the CL strainers should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): A recovery action is required to switch the 22 CL Strainer from Normal Control mode to Emergency Control mode (F5 App D). This action is located in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainer, and avoid loss of the CL system. 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.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 303 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 43 Ionization N N N N Y Suppression - - - - - - - 80 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 in a Change Evaluation 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 Mezzanine of FA 80 extends over hallway; is adjacent to FA 23. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 304 Unit Fire Area Description 1 81 4.16 kV Safeguard Switchgear Room (Bus 15) Regulatory Basis 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 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 -Safety Injection (Train B) Unit 2 -Safety Injection (Train B) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 305 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 (D2) supplying Electrical Distribution Train B Unit 2 - Offsite Power (CT 12) supplying Electrical Distribution Train B Unit 1 CC Train B Unit 2 CC Train B CL Train B Compressed Air System Train B Control Room and Relay Room HVAC Train B Reference Documents Safe/Genesis V 4.0.2 EC 20732, Fire Risk Evaluation, Fire Area 81, 4.16KV Safeguards Switchgear Room (Bus 15), Rev. 0, September, 2012 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 306 EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) VFDR-081 01 This Variance From Deterministic Requirements results in loss of automatic backwash to 11, 12, 21, and 22 Cooling Water (CL) Strainers, due to fire damage to cables. Fire damage could potentially cause loss of Bus 111. Power is provided from Panel MCC-1AB1 to Panel 136 via Bus 111. Bus 111 is the power source for 230V Panel 136 which provides the control power to the backwash control panel for all four of the CL Strainers when they are in the Normal Control Mode of backwash operation. Loss of Panel 136 results in the loss of automatic backwash control for all four CL Strainers. Bus 111 is located in FA 080. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: BKR 15-1 (15404-1, 15404-B, 15404-C, 15404-E) BKR 15-4 (15404-1, 15404-C, 15404-E, 15404-F, 15406-B, 1DCA-1, 1DCA-103) BKR 15-5 (15405-1, 15405-A, 15405-C, 15405-G, 15406-B, 1DCA-1, 1DCA-103) BKR 15-6 (15406-1, 15406-A, 15406-B, 15406-C, 1DCA-1, 1DCA-103) BKR 15-8 (15406-B, 15408-A, 15408-C, 1DCA-1, 1DCA-103, 25417-1, 25417-2, 2CA-749) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 307 BKR 15-9 (15406-B, 15409-1, 15409-B, 15409-C, 1DCA-1, 1DCA-103) BKR 15-11 (15406-B, 15411-1, 15411-A, 15411-C, 1DCA-1, 1DCA-103) BKR 15-12 (15406-B, 15412-1, 15412-A, 15412-B, 1DCA-1, 1DCA-103, 2CA-749) BUS 15 (15406-B, 1DCA-1) This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. This represents a variance from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to lack of separation between redundant trains of cooling water strainers. Compliant Case: The ability to automatically backwash the CL Strainers should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): A recovery action is required to switch the 22 CL Strainers from Normal Control mode to the Emergency Control mode (F5 App D). This action must be performed locally in the plant screenhouse, FA 41A (FDZ 75). This recovery action will prevent plugging of the strainers, and avoid loss of the CL system.

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 credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 11 Ionization N N N N Y Suppression - - - - - - - 81 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 308 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 309 Unit Fire Area Description 1 82 480 V Safeguard Switchgear Room (Bus 122) Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 310 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 311 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room HVAC Train A Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 50 Ionization N N N N N Suppression - - - - - - - 82 Feature - - - - - - - Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 312 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 313 Unit Fire Area Description 2 83 Operator©s Lounge Regulatory Basis 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 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 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 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) Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 314 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 Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 315 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 64 Ionization N N N N N Suppression - - - - - - - 83 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 in a Change Evaluation 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 83 is split into two parts (Secondary Alarm Station and Operator's Lounge). Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 316 Unit Fire Area Description 1, 2 84 Counting Room and Labs Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 317 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 318 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 319 EEEE Title FPEE-11-054, NFPA 13, 1989 Code Compliance Deviations, WPS-19 Summary The purpose of this analysis is to document the review of the WPS-19 wet pipe sprinkler systems protecting the Hot Chem Lab, Sample and Count Rooms in the Unit 1 Auxiliary Building, elevation 715ft, Fire Area 84, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1969, Standard for the Installation of Sprinkler Systems. Eight deviations have been justified as "acceptable"; therefore, no further action is necessary. Two deviations require additional actions to resolve noncompliances associated with (a) pendent heads without return bends and (b) for use of a pendent sprinkler with a sidewall deflector (that is neither a standard pendent nor standard sidewall sprinkler) in Fire Area 84, Hot Chem Lab, Sample and Count Rooms, that is protected by WPS-29. Action Requests have been initiated to track resolution of the identified issues. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection - - - - - - - Suppression WPS-19 Wet Pipe N N N N N 84 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 320 Unit Fire Area Description 1, 2 85 Hold-up Tank Area/Demineralizer Area Regulatory Basis 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 21 SG or 22 SG

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 321 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 322 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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-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 deviation is being tracked in the corrective action system. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 323 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 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 8 Ionization, Thermal N N N N N Suppression - - - - - - - 85 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 324 Fire Area Comments None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 325 Unit Fire Area Description 1, 2 86 Intake Screenhouse Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 326 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 327 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC 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 S L E R D Notes Detection - - - - - - - Suppression - - - - - - - 86 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 in a Change Evaluation or Fire Risk Evaluation Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 328 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 329 Unit Fire Area Description 2 92 Water Chiller Room Unit 2 Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 330 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 331 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room HVAC Train A Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title AR 1352782, 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. EEEE Title FPEE-11-022, NFPA 90A, 1969, 1978 Code Compliance Deviations Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1969 and NFPA 90A - 1978, Standard for Installation of Air Conditioning and Ventilating Systems (Codes of Record.) Two separate code editions are evaluated in this review based on the time period of initial ductwork and damper installations and subsequent modifications to include additional fire dampers as a result of the 1979 NRC Fire Protection Safety Evaluation Report, along with Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 332 changes to incorporate additional criteria such as steam exclusion. One deviation has been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliances associated with the criteria to shut down HVAC systems during the performance of hot work, the lack of fire dampers in specified horizontal and vertical fire barriers, and the location of two sets of fire dampers outside of the plane of the barrier. Action Requests have been initiated to track resolution of the identified issues. 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 deviation is being tracked in the corrective action system. Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 31 Ionization N N N N N Suppression - - - - - - - 92 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 333 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 334 Unit Fire Area Description 1, 2 93 Drum Storage/Low Level Rad Waste Note: Fire Area 93 is now combined into Fire Area 4. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 335 Unit Fire Area Description 1, 2 94 Service Building/Computer Room Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 336 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 337 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-014, NFPA 13, 1980 Code Compliance Deviations, DPS-25 Summary The purpose of this analysis is to document the review of the DPS-25 (DPS-2) dry pipe sprinkler system protecting the Truck Aisle in the Unit 1 Service Building, elevation 695ft, Fire Area 94, for compliance with the requirements of National Fire Protection Association (NFPA) 13 -1980, Standard for the Installation of Sprinkler Systems (Code of Record). Attachment 1 identifies eleven deviations to the code requirements of fourteen code sections. Ten deviations have been justified as "acceptable"; therefore, no further action is necessary. One deviation requires additional actions to resolve the noncompliance associated with inconsistent temperature ratings of sprinklers in the Truck Aisle Dry Pipe System. An Action Request is tracking resolution of the identified issue. Variances from Deterministic Requirements (VFDR) None

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 338 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes 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 94 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 339 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 4.2.4 - Performance Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions 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 22 SG Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 340 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 -Safety Injection (Train B) Train B RCS Head Vents or Pressurizer Vents. Unit 2 -Safety Injection (Train B) Train B RCS Head Vents or Pressurizer Vents. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 341 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train B Unit 2 - D6 supplying Electrical Distribution Train B Unit 1 - CC Train B Unit 2 - CC Train B CL Train B Compressed Air System Train B Control Room and Relay Room HVAC (Train B) Reference Documents Safe/Genesis V 4.0.2 EC 20727, Fire Risk Evaluation, Fire Area 97, D5 Building, Rev. 0, September 2012 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-045, NFPA 13, 1989 Code Compliance Deviations, WPS- 32, 33, D5/D6 FOLO Summary The purpose of this analysis is to document the review of the D5/D6 Fuel Oil/Lube Oil Storage Areas (WPS 32/33) system for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1989, Standard for the Installation of Sprinkler Systems (Code of Record). The deviations have been justified as acceptable to the requirements of NFPA 13; therefore this evaluation is not being carried forward into the LAR since the basis for acceptance is a compliant feature. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-050, NFPA 14, 1986 Standpipes and Hose Stations Code Compliance Deviations Summary The purpose of this analysis is to document the review of the standpipe and hose station systems for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 14 -1986, Standard for the Installation of Standpipe and Hose Systems. Four deviations have been found acceptable based on the justification provided. One deviation has been found to be unacceptable and will require the performance of hydraulic calculations to verify the design bases of the standpipe and hose station system. Perform hydraulic calculations for FP systems will resolve this issue. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 342 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. EEEE Title FPEE-11-052, NFPA 13, 1969, 1980, 1989 Code Compliance Deviations, SWP-1, 12, 2, 4, 3, 13, 14, 5, 6, 31, D5/D6 stairwells Summary The purpose of this analysis is to document the review of the wet pipe sprinkler systems protecting stairways. The stairway suppression systems addressed in this analysis are SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14, SWP-31, and the D5/D6 Building Stair (identified as 2FP-92-2, the system isolation valve, in F5 Appendix F, Fire Hazards Analysis.) The stairway suppression systems are located in the Turbine, Auxiliary, Radwaste, Service, and D5/D6 Buildings. The systems have been reviewed for compliance with the requirements of National Fire Protection Association (NFPA) 13, Standard for the Installation of Sprinkler Systems. The codes of record for these systems are: NFPA 13-1969: SWP-1, SWP-2, SWP-3, SWP-4, SWP-5, SWP-6, SWP-12, SWP-13, SWP-14 NFPA 13-1980: SWP-31 NFPA 13-1989: D5/D6 Building Stair Five deviations have been justified as "acceptable"; therefore, no further action is necessary. Four deviations require additional actions to resolve the noncompliance associated with flushing of the D5/D6 Stair, pressure gauges that read higher than maximum system pressure, pendent heads without return bends all stairway systems except SWP-31 and the D5/D6 Stair, and a missing protective canopy over a sprinkler in SWP-14. Action Requests have been initiated to track resolution of the identified issues. EEEE Title FPEE-11-021, NFPA 90A, 1985 Code Compliance Deviations, D5/D6 Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers in the D5/D6 Building for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1985, Installation of Air Conditioning and Ventilating Systems (Code of Record). There are a total of 16 fire dampers in HVAC duct penetrations of fire barriers in the D5/D6 Building at PINGP. Two deviations have been justified as "acceptable"; therefore, no further action is necessary. There are no deviations that require additional actions. 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. EEEE Title FPEE-11-019, NFPA 80, 1986 Code Compliance Deviations D5/D6 Building 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 -1986, Standard for Fire Doors and Windows (Code of Record). Three deviations have been justified as "acceptable"; therefore, no further action is necessary. Two deviations require additional actions to resolve the noncompliances associated with the qualification of frames in fire door assemblies and the failure of doors to self-close and latch due to changes in ambient airflow conditions in the D5/D6 Building. Action Requests have been initiated to track resolution of the identified issues.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 343 Variances from Deterministic Requirements (VFDR) VFDR-97 01 This Variance From Deterministic Requirements results in loss of automatic backwash to the 11, 12, 21 and 22 Cooling Water (CL) strainers, due to fire damage to cables. Fire damage could cause a loss of overcurrent trip protection of breakers BKR 15-8 and/or BKR 15-12. The loss of overcurrent trip protection of the breaker can result in a lockout for 4.16KV Bus 15. Bus 15 is the ultimate power source for MCC 1AB1 which powers 230V Panel 136, which provides the control power to the backwash control panel for all four of the CL Strainers when they are in the Normal Control Mode of backwash operation. Loss of Panel 136 results in the loss of automatic backwash control for all four CL Strainers. CL Strainers 11 and 21 are powered from MCC 1AB1 and lose power, so that backwash capability cannot be restored to these strainers. This condition would challenge the Nuclear Safety Performance Criteria for Vital Auxiliaries. Components and Cables: BKR 15-8 (25417-1, 25417-2, 25417-D, 2CA-749) BKR 15-12 (15412-1, 2CA-749, 211A-1, 211A-2, 211A-3, 212A-2) This represents a variation from the deterministic requirements (VFDR) of NFPA 805, Section 4.2.3 due to a lack of separation between redundant trains of cooling water strainers. Compliant Case: The ability to automatically backwash the CL Strainers should be available, to ensure strainer plugging is alleviated, so adequate cooling is provided for plant equipment heat loads. This would impact both Unit 1 and Unit 2. Disposition Recovery Action(s): A modification to ensure that over current trip protection remains available for Bus 15 (Table S-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 a plant modification credited. VFDR-97 01 This Variance From Deterministic Requirements is caused by fire damage to cables 25410-A and 25410-B causing a spurious start of 21 AFW Pump (MTR 25-10). This can result in SG overfill of the credited SG. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. The NFPA 805 Nuclear Safety Performance Goal is not met for Decay Heat Removal. Components and Cables: MTR-25-10 25410-A, 25410-B This represents a variation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 344 Compliant Case: One train of Decay Heat Removal should remain available. Disposition Recovery Action(s): Locally close MV-32383 and MV-32384 in FA 031 to isolate the uncontrolled feed to 21 and 22 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 a recovery action credited. Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 97 Ionization, Flame, Thermal N N N N Y Ionization at elevation 718' and at elevation 735' Suppression PA-12 Pre-Action N N N N Y Diesel fuel, large combustible loading. Suppression D5 Stairwell Wet Pipe N N N N N Stairwell system Suppression WPS-32 Wet Pipe N N N N Y Fuel Oil/Lube Oil storage room 97 Feature Area 113/115 Barriers - - - - Y Lube Oil/Fuel Oil Day Tank rooms. Large combustible loading 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 in a Change Evaluation 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. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 345 Fire Area Comments None Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 346 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 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 - 21 MDAFW Pump to 21 SG Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 347 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 Pressurizer Level (LOOP 1L-433) Pressurizer Level (LOOP 1L-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 1N52) U1 Excore Detection Train B 1N52 (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 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

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 Inventory and Pressure Control Unit 1 - Charging System (Train A) Train A RCS Head Vents or Pressurizer Vents. Unit 2 - Charging System (Train A) Train A RCS Head Vents or Pressurizer Vents. 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 348 Vital Auxiliaries Unit 1 - Offsite Power (1RY) supplying Electrical Distribution Train A Unit 2 - D5 supplying Electrical Distribution Train A Unit 1 CC Train A Unit 2 CC Train A CL Train A Compressed Air System Train A Control Room and Relay Room HVAC Train A Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-044, NFPA 13, 1989 Code Compliance Deviations, D6 PA-13 Summary The purpose of this analysis is to document the review of the D6 (PA 13) system for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1989, Standard for the Installation of Sprinkler Systems (Code of Record). The deviations have been justified as acceptable to the requirements of NFPA 13. EEEE Title FPEE-11-045, NFPA 13, 1989 Code Compliance Deviations, WPS- 32, 33, D5/D6 FOLO Summary The purpose of this analysis is to document the review of the D5/D6 Fuel Oil/Lube Oil Storage Areas (WPS 32/33) system for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1989, Standard for the Installation of Sprinkler Systems (Code of Record). The deviations have been justified as acceptable to the requirements of NFPA 13; therefore this evaluation is not being carried forward into the LAR since the basis for acceptance is a compliant feature. EEEE Title FPEE-11-048, NFPA 72E, 1974, 1982, 1987 Plant Areas / Systems Not Addressed in FPP-5 R2 Summary 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. One issue has been justified as "acceptable"; therefore, no further action is necessary. Two recommendations are provided to consider augmenting detection actuation device coverage in Fire Area 25 (Diesel Generator 1) and in Fire Area 18 (Relay and Computer Room) pending the results of the Fire PRA. If the Fire PRA relies on the capabilities of the detection actuation devices for suppression system actuation, then additional actions will be required. An action request is tracking resolution of both issues. Additional actions are required in the Screenhouse (electric fire pump enclosure) to resolve the lack of a heat actuating device in the electric fire pump enclosure, and in the Annulus of each unit to address the Appendix A commitment to a preaction sprinkler system that is actuated by HADs in the Annulus of each unit. Action requests have been initiated to track resolution of the identified issues. Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 349 EEEE Title FPEE-11-019, NFPA 80, 1986 Code Compliance Deviations D5/D6 Building 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 -1986, Standard for Fire Doors and Windows (Code of Record). Three deviations have been justified as "acceptable"; therefore, no further action is necessary. Two deviations require additional actions to resolve the noncompliances associated with the qualification of frames in fire door assemblies and the failure of doors to self-close and latch due to changes in ambient airflow conditions in the D5/D6 Building. Action Requests have been initiated to track resolution of the identified issues. 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. 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. EEEE Title FPEE-11-050, NFPA 14, 1986 Standpipes and Hose Stations Code Compliance Deviations Summary The purpose of this analysis is to document the review of the standpipe and hose station systems for compliance with the applicable requirements cited in National Fire Protection Association (NFPA) 14 -1986, Standard for the Installation of Standpipe and Hose Systems. Four deviations have been found acceptable based on the justification provided. One deviation has been found to be unacceptable and will require the performance of hydraulic calculations to verify the design bases of the standpipe and hose station system. This will be resolved by performing hydraulic calculations for FP systems. EEEE Title FPEE-11-021, NFPA 90A, 1985 Code Compliance Deviations, D5/D6 Summary The purpose of this analysis is to document the review of HVAC systems and fire dampers in the D5/D6 Building for compliance with the requirements of National Fire Protection Association (NFPA) 90A - 1985, Installation of Air Conditioning and Ventilating Systems (Code of Record). There are a total of 16 fire dampers in HVAC duct penetrations of fire barriers in the D5/D6 Building at PINGP. Two deviations have been justified as "acceptable"; therefore, no further action is necessary. There are no deviations that require additional actions.

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 350 Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes Detection 97 Ionization, Flame. Thermal N N N N Y Diesel fuel, large combustible loading Suppression PA-13 Pre-Action N N N N Y Diesel fuel. Large combustible loading Suppression WPS-33 Wet Pipe N N N N Y Fuel Oil/Lube Oil Storage Room 98 Feature Area 114/116 Barriers - - - - Y Lube Oil/Fuel Oil Day Tank rooms. Large combustible loading 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 in a Change Evaluation 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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 351 Unit Fire Area Description 2 100 #21 D5/D6 Fuel Oil Unit: 2 Fire Area: 100 Receiving Tank (South of D6 Room) Regulatory Basis 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

Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 352 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 (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 Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 353 Vital Auxiliaries Unit 1 - Offsite Power supplying Electrical Distribution Train A or B 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 Compressed Air System Train A or B Control Room and Relay Room HVAC Train A or B Reference Documents Safe/Genesis V 4.0.2 Licensing Actions None Existing Engineering Equivalency Evaluations (EEEE) EEEE Title FPEE-11-006, NFPA 13, 1989 Code Compliance Deviations, DA-6, 21 D5/D6 Fuel Oil Receiving Tank Summary The purpose of this analysis is to document the review of DA-6, the Deluge Sprinkler System protecting the D5/D6 Fuel Oil Receiving Tank, for compliance with the applicable requirements cited in National Fire Protection Association 13, (NFPA) -1989, Standard for the Installation of Sprinkler Systems (Code of Record). Six deviations from the criteria of NFPA 13-1989 have been identified. Four have been justified as "acceptable". Variances from Deterministic Requirements (VFDR) None Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required? Fire Area Category ID Type S L E R D Notes 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. 100 Feature - - - - - - - Northern States Power - Minnesota Attachment C - Table B-3 Fire Area Transition PINGP Page C- 354 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 in a Change Evaluation 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 Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-1 D. NEI 04-02 Non-Power Operational Modes Transition 11 Pages Attached Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-2 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 Operation Modes Review," 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.

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-3 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 Operation Modes Review." 5AWI 15.6.0, "Outage Scheduling and Outage Management," (Revision 12). 5AWI 15.6.1, "Shutdown Safety Assessment," (Revision 26).

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-4 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 Operation Modes Review." 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 Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-5 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, Instrument Air, 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. Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-6 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 Operation Modes Review." 5AWI 15.6.1, "Shutdown Safety Assessment," (Revision 26).

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-7 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 Operation Modes Review," 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 sixty (60) fire areas at the PINGP.

• Twenty-eight (28) 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 Operation Modes Review."

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-8 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 Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-9 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: The use of recovery actions to mitigate potential losses of key safety functions is not credited in the NPO analysis contained within PINGP Engineering Evaluation EC-20612, "Non-Power Operation Modes Review," contemporaneous with this LAR submittal.

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-10 The NPO analysis is contained within PINGP Engineering Evaluation EC-20612, "Non-Power Operation Modes Review," which includes the NPO equipment and cable selection process and results, the NPO cable failure analysis, the NPO KSF pinch point analysis process and results by fire area, the NPO risk reduction actions to be completed, and the evaluation and definition of PINGP POS's that are considered HREs.

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 Operation Modes Review," and a road map to identify the site specific implementing procedures used to implement the NPO requirements. Fire protection procedures that implement NPO requirements include the following (See Attachment S):

• 5AWI 3.13.2, "Fire Prevention" defines control of combustible materials, and contains controls to establish the outage roving fire watches that includes the required scope for the NPO risk reduction actions.
• 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. In these cases continuous fire watches will be implemented in the affected systems areas.
• 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 risk due to fire, 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 implement NPO guidance include the following (see Attachment S):
• D2-1, "Draining the Reactor Coolant System - Unit 1," contains a check list of the HRE risk reduction actions and requirements to implement the HRE risk reduction actions as a pre-requisite to conduct of the procedure which results in RCS reduced inventory states.
• D2-2, "Draining the Reactor Coolant System - Unit 2," contains a check list of the HRE risk reduction actions and requirements to implement the HRE risk reduction actions as a pre-requisite to conduct of the procedure which results in RCS reduced inventory states.

Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-11

• 1D8, "Filling and Venting the Reactor Coolant System," contains a decision point to check RCS level and T-Boil to determine if the HRE has been exited, then an HRE Risk Reduction Actions exit check list is provided.
• 2D8, "Filling and Venting the Reactor Coolant System," contains a decision point to check RCS level and T-Boil to determine if the HRE has been exited, then an HRE Risk Reduction Actions exit check list is provided.
• 1C1.6, "Shutdown Operations - Unit 1," contains 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," contains 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," contains 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," contains 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" contains 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.
• 2C4.2, "RCS Inventory Control - Post Refueling" contains 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 3.13.2, "Fire Prevention" (Revision 21).

5AWI 3.13.3, "Hot Work," (Revision 3). F5 Appendix K, "Fire Protection Systems Functional Requirements" (Revision 15). Northern States Power Company Attachment D - Non-Power Operational Modes Transition PINGP Page D-12 EM 3.4.1, "Review of Proposed Changes to the Fire Protection Program" (Revision 2). 5AWI 15.6.1, "Shutdown Safety Assessment," (Revision 26). D2-1, "Draining the Reactor Coolant System - Unit 1," (Revision 25). D2-9, "Draining the Reactor Coolant System - Unit 2," (Revision 12). 1D8, "Filling and Venting the Reactor Coolant System," (Revision 35). 2D8, "Filling and Venting the Reactor Coolant System," (Revision 31). 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 Operation Modes Review." Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-1 E. NEI 04-02 Radioactive Release Transition 34 Pages Attached Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-2 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.
• A new fire fighting strategy will be prepared to provide instructions for fighting fires in the Maintenance Storage Shed / Containment Access Facility, which is a newly-designated fire area with contaminated material stored in sea-land containers. Refer to Section 4.4, Radiological Release Performance Criteria, and Attachment S for details.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-3 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 1 Containment Unit 1

Containment Annulus Unit 1 (Previously identified as Fire Area 68) Det. Zone 10

• U1 Rx Bldg 697' Det. Zone 20
• U1 Rx Bldg 711' Det. Zone 29
• U1 Rx Bldg 733' Det. Zone 32
• U1 Rx Bldg 755'

Det. Zone 21 U1 Cntmt Annulus Yes Floor drains to Containment Sump, then pumped to Aux Bldg Aerated Drains System. Liquid is treated, filtered, processed and sampled before release.

Liquids drain to sumps in floor and transferred to Aux Bldg Aerated Drain System. Liquid is treated, filtered, processed and sampled before release. Under accident conditions, liquids transferred to Containment Sump. Containment Internal Cleanup Subsystem recirculates and filters air for Modes 1, 2, 3, 4. Containment Purge and In-Service Purge Systems filters air prior to exhaust through U1 Shield Bldg Stack for Modes 5 and 6.

Shield Building Ventilation System recirculates air in annulus and maintains negative pressure. In exhaust mode, Shield Building Ventilation System filters air before exhausting through Shield Building vent stack. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-4 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 2 Ventilation Fan Room Det. Zone 30

• Unit 1 Aux Bldg 755' SFP & Fuel Receipt Area Det. Zone 108
• Aux Bldg Elevator Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 3 Water Chiller Room, Unit 1 Det. Zone 31

• 121 & 122 Cont Rm Chiller Aux Bldg 755 Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Chiller rooms are part of the Control Room Habitability Envelope and have internal air handling unit during operations and a closed loop cleanup system during an accident. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-5 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 4 Fuel Handling Area Det. Zone 8

• U1 695 Aux Bldg Det. Zone 33
• Fuel Loading & Spent Fuel Area Det. Zone 30
• Unit 1 Aux Bldg 755 SFP & Fuel Receipt Area Waterflow: 9
• Unit 1 695' Aux Bldg Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. No ventilation. Potential transfer of contaminated smoke to adjacent areas and to exterior. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria Revised fire strategies (to be completed as 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-6 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 5 Old Admin Building Det. Zone 13

• Turb Floor Storage & Chem Storage Room, Halon Records Vault Det. Zone 90
• 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 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. 6 Old Admin Bldg HVAC Equip Area Det. Zone 55
• OAB HVAC Equipment 750' Det. Zone 66
• OAB 735' & 750' 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-7 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 7 Old Admin Bldg Office Area Det. Zone 23

• OAB I&C, Tech Support, 735' & 750' Det. Zone 66 OAB 735' & HVAC Penthouse 750'

Det. Zone 91

• OAB West Elevator, Stairwell Det. Zone 105
• OAB East Elevator Det. Zone 106 OAB West Elevator 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-8 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 8 Turbine Deck and Maintenance Shops Det. Zone 24

• U1 Turb Gen Brg Prot Pnl Det. Zone 49
• Turbine Bearing Protection Unit 2 El. 735 Det. Zone 107
• Turb/Service Building Elevator Det. Zone 27
• Machine Shops, 735' Yes Floor drains to Turbine Building Sump, part of Waste Liquid Treatment System. Liquid sampled prior to release. Turbine Building Ventilation System, which is not filtered. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria The only contaminated area within Fire Area 8 is the location of the spare RCP motor on the 735ft elevation of the Unit 2 Turbine Deck. An area of approximately 10ft by 10ft around the spare RCP is marked and barricaded as a contaminated area.

The potential for contaminated smoke or contaminated water due to fire fighting activities in this location is considered negligible. However, revised fire strategies will incorporate mitigative 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-9 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 10 'A' Train Event Monitoring Room Det. Zone 26

• 480V Swgr 112 Bus Rm & Trn A Em Room 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. 11 Unit 1 Normal SWGR & Control Rod Drive Room Det. Zone 87
• U1 Rod Drive Room 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. 12 OSC Room Det. Zone 25
• Records Room & Hot Instr Shop Waterflow: 18
• Lndry, Chem & Inst Labs or Records Room 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. 13 Control Room Det. Zone 57
• Control Room U1 & U2 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. 14 Working Material & Lunch Room Det. Zone 15
• U1 Turb Bldg 715, Locker Room, Lunch Room, Serv Bldg Stairway, Fan Rm, &

Work Area 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-10 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 15 Access Control Det. Zone 17

• Access Control Waterflow: 18
• Lndry, Chem & Inst Labs or Records Room Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. However, there are no barriers to water spread between the potentially contaminated and clean portions of Access Control. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria Revised fire strategies will incorporate mitigative actions to utilize booms to prevent flow of potentially contaminated water between the potentially contaminated and clean portions of Access Control.

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. 16 Train B Event Monitoring Equipment Room Det. Zone 50

• 480V Swgr 122 Bus Rm & Trn A Em Room 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. 17 Unit 2 Normal SWGR & Control Rod Drive Room Det. Zone 88
• Rod Control Room Unit 2 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-11 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 18 Relay & Cable Spreading Room Units 1 & 2 Det. Zone 12

• Relay & Cable Spreading Rm Units 1 & 2 Det. Zone 14
• Old Computer Room 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. 20 Unit 1 4.16 kV Safeguards SWGR (Bus 16) Det. Zone 11
• Bus Rms 15 & 16 Unit 1 715 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. 21 Unit 1 4.16 kV Normal SWGR (Bus 13, 14) Det. Zone 84
• Bus Rms 13 & 14 Unit 1 715 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. 22 480 V Safeguards SWGR (Bus 121) Det. Zone 43
• 480V Bus 111 and 121 715' 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. 23 Unit 2 4.16 kV Normal SWGR (Bus 23, 24) Det. Zone 86
• Normal Switchgear Bus 23 & 24 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-12 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 24 Oil Storage Area Det. Zone 4

• U1 695 Turb Bldg Waterflow: 5
• U1 695 Turb Bldg 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. 25 Diesel Generator Room 1 Det. Zone 82
• D1 Diesel Gen Rm Waterflow: 7
• D1 & D2 Rooms 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. 26 Diesel Generator Room 2 Det. Zone 6
• D2 Diesel Gen Rm Waterflow: 7
• D1 & D2 Rooms 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. 27 Water Conditioning Equipment Area Det. Zone 4
• U1 695 Turb Bldg 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. 28a 1GT Transformer Det. Zone 58
• 1GT Waterflow: 76
• 1GT 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-13 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 28b 2GT Transformer Det. Zone 60

• 2GT Waterflow: 78
• 2GT 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. 28c 1R Transformer Det. Zone 62
• 1R Waterflow: 80
• 1R 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. 28d 1M Transformer Det. Zone 59
• 1M Waterflow: 77
• 1M 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. 28e 2M Transformer Det. Zone 61
• 2M Waterflow: 79
• 2M 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. 28f 2RX/Y Transformer Det. Zone 96
• 2RX/Y Waterflow: 95
• 2RX/Y 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-14 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 29 Admin Bldg Elec. & Piping Room 1 Det. Zone 4

• U1 695 Turb Bldg 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. 30 Admin Bldg Elec. & Piping Room 2 Det. Zone 4
• U1 695 Turb Bldg 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. 31 "A" Train Hot Shutdown Panel & Air Compressor / Auxiliary Feedwater Pump Room Det. Zone 2
• Air Cmprsr & Aux Feed Pmp Room 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. 32 "B" Train Hot Shutdown Panel & Air Compressor / Auxiliary Feedwater Pump Room Det. Zone 2
• Air Cmprsr & Aux Feed Pmp Room 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. 33 Battery Room 11 Det. Zone 1
• 11 & 12 Batt Rms Turb Bldg 695 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-15 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 34 Battery Room 12 Det. Zone 1

• 11 & 12 Batt Rms Turb Bldg 695 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. 35 Battery Room 21 Det. Zone 35
• 21 & 22 Battery Rooms 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. 36 Battery Room 22 Det. Zone 35
• 21 & 22 Battery Rooms 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. 37 480V Normal SWGR Room Unit 1 Det. Zone 83
• Bus Rms 150 & 160 Unit 1 695 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. 38 480V Normal SWGR Room Unit 2 Det. Zone 85
• Normal Switchgear Bus 250 & 260 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-16 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 39 Rad Waste Building Det. Zone 34

• Rad Waste & Resin Disposal El. 695 Det. Zone 81
• Rad Waste & Resin Disposal El. 695 & El. 715 Yes Floor drains to Radwaste Building Sumps, collected in tanks, filtered, processed and sampled prior to release. Radwaste Building Ventilation filters air prior to release. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 40 Maintenance Storage Shed / CAF (Containment Access Facility) Det. Zone - None
• CAF Yes No drains. Potential transfer of contaminated liquids to exterior. No ventilation. Potential transfer of contaminated smoke to exterior. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria A combination of containerization and administrative controls will limit the amount of exposed contaminated combustible materials.

Revised fire strategies will incorporate mitigative actions to utilize booms to prevent flow of potentially contaminated water to the exterior, 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-17 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 41 Screenhouse (General Area) 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. 41A Screenhouse (DDCWP Rooms) Det. Zone 74

• Plant Screen House El. 670 Det. Zone 75
• Plant Screen House El. 695 Waterflow: 63
• Screen House 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. 41B Screenhouse (Basement) Det. Zone 75
• Plant Screen House El. 695 Waterflow: 63
• Screen House 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. -- Cooling Tower Pump House (CTPH) Det. Zone 71
• CTPH, CTEH, Warehouse 1, Construction / Fab Shop 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. -- Fuel Oil and Transfer House Det. Zone 72
• Fuel Oil & Transfer House 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-18 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 46 Cooling Tower Equipment House (CTEH) Det. Zone 71

• CTPH, CTEH, Warehouse 1, Construction / Fab Shop 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. 46A Cooling Tower Transformers 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. -- 121/122 CLG Tower Control House Det. Zone 68
• Cooling Tower Control House 121/122 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. -- Waste Neutralizing Tank Pump House /

Warehouse 2 Det. Zone 92

• Neut Tk House & Whse #2 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. -- 123/124 CLG Tower Control House Det. Zone 69
• Cooling Tower Control House 123/124 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-19 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions -- Main Warehouse 1 and Fab Shop Det. Zone 71

• CTPH, CTEH, Warehouse 1, Construction / Fab Shop 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. 57 Hydrogen House Det. Zone 4
• U1 695 Turb Bldg 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. 58 Aux Building Ground Floor Unit 1 & Unit 2 (Unit 2 was previously identified as Fire Area

73) Det. Zone 8

• U1 695 Aux Bldg Waterflow: 9
• U1 695' Aux Bldg Det. Zone 40
• U2 695' Aux Bldg Det. Zone 108
• Aux Bldg Elevator Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-20 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 59 Aux Building Mezzanine Floor Unit 1 & Unit 2 (Unit 2 was previously identified as Fire Area

74) Det. Zone 19

• U1 715 Aux Bldg Waterflow: 22
• U1 715' Aux Bldg Penetrations Waterflow: 41
• Auxiliary Building Unit 2 & D-3 Storage Room Det. Zone 46
• Auxiliary Building Unit 2 El. 715 Waterflow: 48 Annulus Penetration Unit 2 Det. Zone 108
• Aux Bldg Elevator Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-21 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 60 Aux Building Operating Level Unit 1 Det. Zone 28

• Unit 1 Aux Bldg 735 Det. Zone 108
• Aux Bldg Elevator Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 61 Aux Bldg Unit "C" Clothing Area Det. Zone 28

• Unit 1 Aux Bldg 735 Waterflow: 103
• E/W Demin Removal Area Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. No ventilation.

Potential transfer of contaminated smoke to adjacent areas and to exterior. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria Revised fire strategies (to be completed as 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-22 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 61A Aux. Bldg Hatch Area Det. Zone 30

• Unit 1 Aux Bldg 755 SFP & Fuel Receipt Area Det. Zone 53
• Auxiliary Building Unit 2 & West Side Fuel Handling Area El. 755 Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. No ventilation. Potential transfer of contaminated smoke to adjacent areas and to exterior. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria Revised fire strategies (to be completed as 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. 62 Spent Fuel Pool Area Det. Zone 30

• Unit 1 Aux Bldg 755 SFP & Fuel Receipt Area Yes No drains. Floor drains in adjacent areas route to Aerated Drains System.

Liquid is treated, filtered, processed and sampled before release. Spent Fuel Pool Normal Ventilation System filters air prior to release.

Spent Fuel Pool Special Ventilation System filters air before exhausting through Shield Building vent stack. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-23 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 63 Filter Room Det. Zone - None

• Filter Room (Refer to FA 60 and FA 75) Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 64 Aux Bldg Low Level Decay Area Unit 1 Det. Zone 8

• U1 695 Aux Bldg Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-24 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 65 Spent Fuel Pool Heat Exchangers & Pumps Det. Zone - None

• SFP Hx Room (Refer to U1 715' Aux Bldg, Det. Zone 19 ) Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 66 D3 Lunch Room Det. Zone 39

• D-3 Storage/Diesel Room Detection Waterflow: 41
• Auxiliary Building Unit 2 & D-3 Storage Room 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. 67 Resin Disposal Area Det. Zone 34
• Rad Waste & Resin Disposal El. 695 Det. Zone 81
• Rad Waste & Resin Disposal El. 695 & El. 715 Yes Floor drains to Radwaste Building Sumps, collected in tanks, filtered, processed and sampled prior to release. Radwaste Building Ventilation System filters air prior to release. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-25 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 69 Turbine Bldg Ground & Mezzanine Floors Unit 1 Det. Zone 3

• FW Pmp Turb Bldg 695 Det. Zone 4
• U1 695 Turb Bldg 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 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-26 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 70 Turbine Bldg Ground & Mezzanine Floors Unit 2 Det. Zone 36

• Feed Water Pump Area Unit 2 Det. Zone 37
• Turbine Building Unit 2 El. 695 Det. Zone 44
• Turbine Building Unit 2 El. 715 Waterflow: 38
• Turbine Building Unit 2. 695 Waterflow: 45
• Turbine Building Unit 2, 715'

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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-27 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 71 Containment Unit 2

Containment Annulus Unit 2 (Previously identified as Fire Area 72) Det. Zone 42

• U2 Rx Bldg 697' Det. Zone 52
• U2 Rx Bldg 733' Det. Zone 54
• U2 Rx Bldg 755' Det. Zone 56 U2 Rx Bldg 711' Det. Zone 47 U2 Cntmt Annulus Yes Floor drains to Containment Sump, then pumped to Aux Bldg Aerated Drains System.

Liquid is treated, filtered, processed and sampled before release. Liquids drain to sumps in floor and transferred to Aux Bldg Aerated Drain System. Liquid is treated, filtered, processed and sampled before release. Under accident conditions, liquids transferred to Containment Sump. Shield Building Ventilation System recirculates air in annulus and maintains negative pressure.

Shield Building Ventilation System recirculates air in annulus and maintains negative pressure. In exhaust mode, Shield Building Ventilation System filters air before exhausting through Shield Building vent stack. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-28 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 75 Aux Bldg Operating Level Unit 2 Det. Zone 51

• Auxiliary Building Unit 2 El. 735 Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 76 Vent and Fan Room Unit 2 Det. Zone 30

• Unit 1 Aux Bldg 755 SFP & Fuel Receipt Area Det. Zone 53 Auxiliary Building Unit 2 & West Side Fuel
• Handling Area El. 755 Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-29 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 77 Aux Bldg Low Level Decay Unit 2 None Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 78 Waste Gas Compressor Area Det. Zone 33

• Fuel Loading & Spent Fuel Area Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-30 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 79 480 V SFGD SWGR Room (Bus 112) Det. Zone 26

• 480V Swgr 112 Bus Rm & Trn A Em Room 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. 80 480 V SWGR Room (Bus 111) Det. Zone 43
• 480V Switch Gear 111 and 121 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. 81 4.16kV Safeguard SWGR Room (Bus

15) Det. Zone 11

• Bus Rms 15 & 16 Unit 1 715 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. 82 480 V Safeguard SWGR Room (Bus 122) Det. Zone 50
• 480V Switch Gear 122 Bus Room & Train B EM Room 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. 83 Operators Lounge Det. Zone 64
• Operators Study Area / Security Office 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-31 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 84 Counting Room & Labs None (FA 59, Zone 19) Waterflow: 18

• Lndry, Chem & Inst Labs or Records Room Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Area is positively pressurized with respect to rest of Auxiliary Building. Additional filters and exhaust fans are installed, and air is filtered prior to discharge.

Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-32 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 85 Hold-up Tank Area / Demineralizer Area Det. Zone 8

• U1 695 Aux Bldg Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. North side 695ft and entire 715ft elevation portions: Auxiliary Building Ventilation System maintains negative pressure. Air is monitored prior to release. The control room can turn off the Auxiliary Building 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. South side 695ft portions: No ventilation. Potential transfer of contaminated smoke to adjacent CAAB areas. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria Revised fire strategies will incorporate mitigative actions to utilize Spent Fuel Pool Normal Ventilation to filter potentially contaminated smoke occurring from fires on south side of 695ft elevation 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. 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-33 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions -- Radiation Monitor Station Det. Zone 70

• Radiation Monitoring Station / De-icing Pump House / Envir.

Lab / Intake Screen House 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. -- Deep Well Pump House 1 & 2 Det. Zone 73

• Deep Well Pump House 1 & 2 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. -- Deep Well Pump House 1 & 2 Det. Zone 73
• Deep Well Pump House 1 & 2 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. 89 Guard House Det. Zone 89
• Guard House & Emerg Gen Bldg 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. 90 Emergency Generator Bldg Det. Zone 89
• Guard House & Emerg Gen Bldg 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.

Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-34 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 92 Water Chiller Room Unit 2 Det. Zone 31

• 121 & 122 Cont Rm Chiller Aux Bldg 755 Yes Floor drains route to Aerated Drains System. Liquid is treated, filtered, processed and sampled before release. Chiller rooms are part of the Control Room Habitability Envelope and have internal air handling unit during operations and a closed loop cleanup system during an accident. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria 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. 93 Low Level Rad Waste Area Det. Zone 104
• Low Level Rad Waste - Building Waterflow: 101
• Low Level Rad Waste Storage Bldg & Warehouse Yes Floor drains route to Aerated Drains System.

Liquid is treated, filtered, processed and sampled before release. No ventilation. Potential transfer of contaminated smoke to exterior. Upon completion of implementation items identified in Attachment S, fire brigade training materials will meet NFPA radioactive release performance criteria A combination of containerization and administrative controls will limit the amount of exposed contaminated combustible materials. Revised fire strategies (to be completed as 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. Northern States Power - Minnesota Attachment E - Radioactive Release Transition PINGP Page E-35 Engineering Controls Fire Area Description Fire Strategies Detection Zones Screened In? Liquid Airborne Training Review Results Conclusions 94 Service Building/Computer Room Det. Zone 94

• Service Bldg 695 - 715 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. 97 D5 Diesel Generator Building (Previously identified as Fire Areas 97, 99, 101, 103, 105, 107, 109, 111, 113, 115, 117, 119, 123, 125, & 127) Det. Zone 97
• D5/D6 Diesel Building 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. 98 D6 Diesel Generator Building (Previously identified as Fire Areas 98, 102, 104, 106, 108, 110, 112, 114, 116, 118, 120, 122, 124, 126 &

128) Det. Zone 97

• D5/D6 Diesel Building 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. 100 D5/D6Fuel Oil Receiving Tank 21 Det. Zone 97
• D5/D6 Diesel Building 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. 131 New Admin Bldg Det. Zone 99
• New Admin Building 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.

Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-1 F. Fire-Induced Multiple Spurious Operations Resolution 6 Pages Attached Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-2 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 could 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).

Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-3 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 Owner's 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 EPM Report 2117-3104-001, "Multiple Spurious Operations Review." 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 are potentially harmful to the mitigation of fire events. 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 Group's 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 the function of mitigating systems.
• A listing of the resulting SSO and MSO combinations identified. EPM Report 2117-3104-001 documents the methodology used for this systematic review and the resulting SSO and MSO combinations. 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).

Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-4

• 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. 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. 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. Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-5 Additional Fire PRA model refinements are also documented in Technical Evaluation Reports. The additional Technical Evaluation Reports relevant to spurious operations include:

• P2117-3700-01-00, PINGP Fire Compartment 18 Refinements.
• P2117-3700-02-00, PINGP Fire Area 69 Refinements.
• P2117-4102-01-00, PINGP Fire Modeling Reviews - Fire Area 1.
• P2117-4102-02-00, PINGP Fire Modeling Reviews - Fire Area 71.
• P2117-4102-03-00, PINGP Fire Modeling Reviews - Fire Compartment 58GRP.
• P2117-4102-04-00, PINGP Fire Modeling Reviews - Fire Compartment 59GRP.
• P2117-4103-01-00, PINGP Fire PRA Notebook Open Item Review.
• P2117-4104-01-00, PINGP Fire PRA Quantification (FQ) Technical Evaluation Update. 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 20758, "PINGP NSPC Strategy Reviews." 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.

Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-6 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:

• Report 2117-3104-001, Multiple Spurious Operations Review.
• 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. Additional Fire PRA model refinements are also documented in Technical Evaluation Reports. The additional Technical Evaluation Reports relevant to spurious operations include:
• P2117-3700-01-00, PINGP Fire Compartment 18 Refinements.
• P2117-3700-02-00, PINGP Fire Area 69 Refinements.
• P2117-4102-01-00, PINGP Fire Modeling Reviews - Fire Area 1.
• P2117-4102-02-00, PINGP Fire Modeling Reviews - Fire Area 71.
• P2117-4102-03-00, PINGP Fire Modeling Reviews - Fire Compartment 58GRP.
• P2117-4102-04-00, PINGP Fire Modeling Reviews - Fire Compartment 59GRP.
• P2117-4103-01-00, PINGP Fire PRA Notebook Open Item Review.
• P2117-4104-01-00, PINGP Fire PRA Quantification (FQ) Technical Evaluation Update. 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).

Northern States Power - Minnesota Attachment F - Fire-Induced MSOs Resolution PINGP Page F-7 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. Spurious operations, both single and multiple, have an impact on the overall fire risk and are included in the fire PRA model. Fire-induced spurious operations generating a control signal can lead to initiating events (e.g., Pressurizer PORV(s) transferring open) and can also affect mitigation of initiators such as AFW supplying the steam generators or Steam Generator PORV operation used for relieving pressure. Given the potential significance of fire-induced MSOs, an Expert Panel and systematic reviews were held to search for and identify MSO failures not already captured by the Internal Events PRA model. Logic modifications were made when building the Fire PRA to incorporate several fire-induced MSO-related failures not already captured by the Internal Events 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 evaluation of each VFDR. The VFDRs are identified in Attachment C and a summary of the Fire PRA results is provided in Attachment W.

Northern States Power Company Attachment G - Recovery Action Transition PINGP Page G-1 G. Recovery Actions Transition 40 Pages Attached Northern States Power Company Attachment G - Recovery Action Transition PINGP Page G-2 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: Based on the definition provided in RG 1.205, and the additional guidance provided in FAQ 07-0030, the following location is considered the primary control station, with associated enabling, control, and indication functions as identified:

• Hot Shutdown Panel A, PNL-51000 Actions to enable use of Hot Shutdown Panel A include the following:
• Place the following Local/Remote Control Switches on "A" Train HSDP to "Local" to transfer control from the Control Room to Hot Shutdown Panel A. o CS-51001, UNIT 1 PZR HEATERS GROUP A o CS-51003, 11 TD AFWP TO 11 STM GEN MV-32238 o CS-51005, 11 TD AFWP TO 12 STM GEN MV-32239 o CS-51009, LTDN ORIFICE ISOL 40 GPM CV-31325 o CS-51011, LTDN ORIFICE ISOL 40 GPM CV-31326 o CS-51013, LTDN ORIFICE ISOL 80 GPM CV-31327 o CS-51007, 11 BORIC ACID TRANSFER PUMP o CS-51101, UNIT 2 PZR HEATERS GROUP A o CS-51103, 21 MD AFWP TO 21 STM GEN MV-32383 Northern States Power Company Attachment G - Recovery Action Transition PINGP Page G-3 o CS-51105, 21 MD AFWP TO 22 STM GEN MV-32384 o CS-51109, LTDN ORIFICE ISOL 40 GPM CV-31347 o CS-51111, LTDN ORIFICE ISOL 40 GPM CV-31348 o CS-51113, LTDN ORIFICE ISOL 80 GPM CV-31349 o CS-51107, 21 BORIC ACID TRANSFER PUMP o HC-28400, 1A ATM STM RELIEF (POWER OP) CV-31084 o HC-28408, 2A ATM STM RELIEF (POWER OP) CV-31102 o CS-51517, 12 MD AFWP o CS-51617, 22 TD AFWP o CS-19640, CLG WTR TO 12 MD AFWP SUCT o CS-19642, COND TO 12 MD AFWP SUCT o CS-19650, COND TO 22 MD AFWP SUCT o CS-19648, COND TO 22 MD AFWP SUCT Hot Shutdown Panel A is the Primary Control Station for implementation of the Alternate Shutdown Strategy in the event of a fire that requires evacuation of the Main Control Room. Modifications to Hot Shutdown Panel A to reduce risk for fire Areas 31 and 32 may result in additional actions taken at the panel. (See Attachment S). Table G Recovery Actions and Activities Occurring at the Primary Control Station(s) identifies the activities that occur at the primary control station(s). Activities necessary to enable the primary control station(s) are also identified in Table G-1 as primary control station(s) activities. These activities do not require the treatment of additional risk. 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 and Activities Occurring at the Primary Control Station. Modifications to Hot Shutdown Panel A to reduce risk for fire Areas 31 and 32 may result in additional actions taken at the panel. (See Attachment S) 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, Northern States Power Company Attachment G - Recovery Action Transition PINGP Page G-4 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. Note that since actions taken at the primary control station are not recovery actions their feasibility is evaluated in accordance with procedures for validation of off normal procedures. Results of Step 4: Each of the feasibility criteria in FAQ 07-0030 were assessed for the recovery actions listed in Table G-1. 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. Implementation items resulting from the feasibility evaluation include: Development/revision of procedures. Revisions to the Training Program to reflect procedure changes. Revision to the drill development procedure. These items are included in Table S-3. Step 5: Evaluate the Reliability of Recovery Actions The evaluation of the reliability of recovery actions depends upon its characterization. The reliability of recovery actions that were modeled specifically in the Fire PRA were addressed using Fire PRA methods (i.e., HRA). The reliability of recovery actions not modeled specifically in the Fire PRA is bounded by the treatment of additional risk associated with the applicable VFDR. In calculating the additional risk of the VFDR, the compliant case recovers the fire-induced failure(s) as if the variant condition no longer exists. The resulting delta risk between the variant and compliant condition bounds any additional risk for the recovery action even if that recovery action were modeled. Results of Step 5: The reliability of recovery actions that are being modeled specifically in the Fire PRA has been addressed using Fire PRA methods as documented in PINGP Calculation Northern States Power Company Attachment G - Recovery Action Transition PINGP Page G-5 FPRA-PI-FHRA, "Fire Human Reliability Analysis." Bounding reliability results are documented in Attachment W. PINGP procedures F5 Appendix B, "Control Room Evacuation," and F5 Appendix D, "Impact of Fire Outside Control/Relay Room" will be updated to incorporate credited Recovery Actions. These implementation actions are included in Table S-3. Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-6 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 002 WR-10/DISC SW Welding Receptacle 10 Disconnect Switch Manually operate the Appendix R fan at WR-10/DISC SW in Fire Area 008. VFDR-002 01 RA 002 Records Room doors Records Room doors To establish temporary Control Room Cooling, open the Records Room doors and install the Appendix R fan in Fire Area 012. VFDR-002 01 RA 002 Relay Room doors Relay Room doors To establish temporary Relay Room Cooling, open one of the Relay Room doors in Fire Area 018. VFDR-002 01 RA 010 Relay Room doors Relay Room doors To establish temporary Relay Room Cooling, open one of the Relay Room doors in Fire Area 018. VFDR-10 01 RA 013, 018 PNL 11 DC Distribution Panel 11 De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31200 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 01 VFDR-018 01 RA 013, 018 U1 Turbine Front Standard Turbine Overspeed Trip Mechanism Manually trip Unit 1 Main Turbine at the front standard in Fire Area 008. VFDR-013 01 VFDR-018 01 RA 013, 018 VC 8 11 Volume Control Tank Outlet Manual Valve Isolation Manually close VC 8 after opening VC 1 in Fire Area 058 for VCT isolation. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-7 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 VC-14-1 11 Reactor Coolant Pump Seal Injection Throttle Valve Prior to starting MTR 111J-1, manually close VC-14-1 (11 RC PMP SEAL INJECTION THROTTLE VALVE) in Fire Area 085 to prevent thermal shock to the RCP seals. VFDR-013 02 VFDR-018 02 RA 013, 018 VC-14-2 12 Reactor Coolant Pump Seal Injection Throttle Valve Prior to starting MTR 111J-1, manually close VC-14-2 (12 RC PMP SEAL INJECTION THROTTLE VALVE) in Fire Area 085 to prevent thermal shock to the RCP seals. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 112 BUS 112 480V Switchgear Verify open or manually trip BKR 112C at BUS 112 in Fire Area 079 to de-energize MCC 1S1 and mitigate spurious operation of PZR Heater Group A. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 122 BUS 122 480V Switchgear Verify open or manually trip BKR 122C at BUS 122 in Fire Area 082 to de-energize MCC 1R1 and mitigate spurious operation of PZR Heater Group B. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 16 BUS 16 4.16KV Switchgear At BUS 16 in Fire Area 020, open DC Knife switches (located inside breaker cubicles) for BKR 16-1 (12 CS PMP) and verify breaker open. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-8 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 BUS 180 BUS 180 480V Switchgear Verify open or manually trip BKR 180-183 at BUS 180 in Fire Area 011 to de-energize MCC 1P1 and mitigate spurious operation of PZR Heater Group C. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 180 BUS 180 480V Switchgear Verify open or manually trip BKR 180-184 at BUS 180 in Fire Area 011 to de-energize MCC 1P2 and mitigate spurious operation of PZR Heater Group D. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 180 BUS 180 480V Switchgear Verify open or manually trip BKR 180-182 at BUS 180 in Fire Area 011 to de-energize MCC 1R2 and mitigate spurious operation of PZR Heater Group E. VFDR-013 02 VFDR-018 02 RA 013, 018 CV-31198 Charging Line To 11 Regenerative Heat Exchanger Control Valve Prior to starting MTR 111J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31198 in the required open position. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 1A1 Motor Control Center 1A BUS 1 De-energize MV-32077 at MCC 1A1, BKR 111E-9, located in Fire Area 032. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 1A2 Motor Control Center 1A BUS 2 De-energize MV-32078 at MCC 1A2, BKR 121E-9, located in Fire Area 032. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 1K1 Motor Control Center 1K BUS 1 De-energize MV-32075 at MCC 1K1, BKR 111J-8, located in Fire Area 058. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-9 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MCC 1K2 Motor Control Center 1K BUS 2 Manually trip MTR 121J-1 (11 CHG PMP) at MCC 1K2, BKR 121J-1, in Fire Area 058. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 1KA2 Motor Control Center 1KA BUS 2 De-energize MV-32076 at MCC 1KA2, BKR 121B-28, located in Fire Area 058. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 1L1 Motor Control Center 1L BUS 1 De-energize MV-32166 at MCC 1L1, BKR 112E-6, located in Fire Area 059. VFDR-013 02 VFDR-018 02 RA 013, 018 MTR 111J-1 Local Panel 12 Charging Pump Local Panel Take local control of MTR 111J-1, 12 charging pump at panel 70810 by placing CS-7081001 in "LOCAL" and pressing CS-7081002 once to energize the VFD and a second time to start the 12 charging pump at the local panel in 12 charging pump room in Fire Area 058 VFDR-013 02 VFDR-018 02 RA 013, 018 MTR 111J-1 VFD 12 Charging Pump Variable Frequency Drive Cabinet Manually operate MTR 111J-1 (12 CHARGING PUMP) at the VFD panel by MCC 1K1 in Fire Area 058 by placing the LOC/REM SEL SW in the "LOCAL" position. VFDR-013 02 VFDR-018 02 RA 013, 018 MV-32166 1 Reactor Excess Letdown Line Isolation Motor Valve A Prior to starting MTR 111J-1, manually close MV-32166 in Fire Area 085. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-10 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 PNL 11 DC Distribution Panel 11 De-energize PNL 171 at PNL 11, breaker 11-8, located in Fire Area 033 in order to fail CV-31232 closed. This action will fail all components powered from PNL 171 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 11 DC Distribution Panel 11 De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 12 DC Distribution Panel 12 De-energize PNL 181 at PNL 12, breaker 12-8, located in Fire Area 034 in order to fail CV-31231 closed. This action will fail all components powered from PNL 181 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 11 DC Distribution Panel 11 De-energize PNL 191 at PNL 11, breaker 11-18, located in Fire Area 033 in order to fail CV-31226 closed. This action will fail all components powered from PNL 191 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-11 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 PNL 11 DC Distribution Panel 11 De-energize PNL 15 at PNL 11, breaker 11-16, located in Fire Area 033 in order to fail CV-31330 closed. This action will fail all components powered from PNL 15 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 12 DC Distribution Panel 12 De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 VC 1 MV-32060 Bypass Charging Pump Suction Manually open VC 1 in Fire Area 058 to align RWST supply to charging pump suction. Time constraint to open VC 1 before starting charging pump. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 12 DC Distribution Panel 12 De-energize PNL 16 at PNL 12, breaker 12-18, located in Fire Area 034 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 16 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-12 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 18032 11 Turbine Driven Auxiliary Feedwater Pump Discharge Flow Indicator FI-18032 (11 TD AFW PMP DISCH FI) remains available in Fire Area 032 to provide local AFW flow indication. VFDR-013 03 VFDR-018 03 RA 013, 018 AF-292-1 11 Turbine Driven Auxiliary Feedwater Pump Main Steam Supply CV-31998 Air Accumulator Vent Manually start 11 TDAFWP by verifying that the lube oil pump is running and placing AF-292-1, 11 TD AFW PMP MN STM SPLY CV-31998 ROOT ISOL, in the "OPEN" position. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 11 BUS 11 4.16KV Switchgear At BUS 11 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 11-3 (MTR 11-3, 11 FW PMP) and verify breaker open. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 12 BUS 12 4.16KV Switchgear At BUS 12 in Fire Area 069, open DC knife switches (located inside breaker cubicles) for BKR 12-3 (MTR 12-3, 12 FW PMP) and verify breaker open. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 16 BUS 16 4.16KV Switchgear At BUS 16 in Fire Area 020, open DC knife switches (located inside breaker cubicles) for BKR 16-3 (MTR 16-3, 12 MD AFW PMP) and verify breaker open. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 1A1 Motor Control Center 1A BUS 1 De-energize MV-32238 at MCC 1A1, BKR 111-17, located in Fire Area 032. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-13 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MCC 1A1 Motor Control Center 1A BUS 1 When the AFW pump suction pressure reaches 4" Hg (PI-11054), de-energize MV-32025 at MCC 1A1, BKR 111E-1 (11 TD AFW PMP SUCT CLG WTR SPLY MV-32025), located in Fire Area 032. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 1A1 Motor Control Center 1A BUS 1 De-energize MV-32333 at MCC 1A1, 111E-4, located in Fire Area 032. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 1B1 Motor Control Center 1B BUS 1 De-energize MV-32006 at MCC 1B1 (BKR 151-5) located in Fire Area 069. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32006 1 Turbine Gland Steam Seal Supply Upstream Shut Off Motor Valve Manually close MV-32006 in Fire Area 069 to isolate Main Steam flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 1B1 Motor Control Center 1B BUS 1 De-energize MV-32010 at MCC 1B1 (BKR 151-6) located in Fire Area 069. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32010 1 Turbine Gland Steam Seal Supply Bypass Motor Valve Manually close MV-32010 in Fire Area 069 to isolate Main Steam flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 1K1 Motor Control Center 1K BUS 1 De-energize MV-32016 at BKR 1K1-H2 at MCC 1K1, located in Fire Area 058. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32016 11 Steam Generator Main Steam Supply To 11 Turbine Driven Auxiliary Feedwater Pump Motor Valve Verify open MV-32016 in Fire Area 060. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-14 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MCC 1K2 Motor Control Center 1K BUS 2 De-energize MV-32017 at BKR 1K2-D4 at MCC 1K2, located in Fire Area 058. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32017 12 Steam Generator Main Steam Supply To 11 Turbine Driven Auxiliary Feedwater Pump Motor Valve Manually close MV-32017 in Fire Area 060 to isolate the non-credited steam generator. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32025 11 Turbine Driven Auxiliary Feedwater Pump Suction Cooling Supply Motor Valve Manually open MV-32025, 11 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32238 11 Auxiliary Feedwater To 11 Steam Generator Motor Valve Manually throttle MV-32238 (11 AFW TO 11 SG MV) in Fire Area 032 as necessary to control AFW flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32243 11/12 Auxiliary Feedwater To 12 Steam Generator Isolation Motor Valve Manually close MV-32243 in Fire Area 060 to support isolation of the non-credited steam generator (12 SG). VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32238 11 Auxiliary Feedwater To 11 Steam Generator Motor Valve Verify open MV-32238 in Fire Area 032. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32333 11 Turbine Driven Auxiliary Feedwater Pump Suction From Condensate Storage Tank Motor Valve Verify open MV-32333 in Fire Area 032. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-15 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MV-32333 11 Turbine Driven Auxiliary Feedwater Pump Suction From Condensate Storage Tank Motor Valve When the AFW pump suction pressure reaches 4" Hg (PI-11054), verify MV-32025 (11 TD AFW PMP SUCT CL SPLY MV) open; then manually close MV-32333 in Fire Area 032 to isolate the CST supply to 145-201 (11 TD AFW PMP) suction. VFDR-013 03 VFDR-018 03 RA 013, 018 PNL 70381 11 Cooling Water Strainer Local Panel Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. VFDR-013 04 VFDR-018 04 RA 013, 018 1LI-433C Pressurizer Level Cold Calibration Local Indicator LOOP 1L-433 (local indicator 1LI-433C) remains available in Fire Area 058 to provide pressurizer level indication for local control of charging pump flow. VFDR-013 05 VFDR-018 05 RA 013, 018 034-011 D1 Diesel Generator Stop D1 DSL GEN if running with inadequate cooling water pressure. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-3 is open. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear Prior to starting the D1 Diesel, at BUS 15 in Fire Area 081, verify BKR 15-7 is open. VFDR-013 06 VFDR-018 06 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-16 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 BUS 15 BUS 15 4.16KV Switchgear Verify D1 Diesel running and ensure all loads are stripped from BUS 15. Manually close BKR 15-2 (BUS 15 SOURCE FROM D1 DSL GEN) at BUS 15 in Fire Area 081 by pulling the manual CLOSURE lever with the hot stick. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear On the front panel of BKR 15-11, BUS 15 FEED TO 111M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear Verify D1 Diesel running and manually close BKR 15-11 at BUS 15 in Fire Area 081. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear On the front panel of BKR 15-6, BUS 15 FEED TO 112M XFMR, place the LOCAL/REMOTE switch in the "LOCAL" position. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 15 BUS 15 4.16KV Switchgear Verify D1 Diesel running and manually close BKR 15-6 at BUS 15 in Fire Area 081. VFDR-013 06 VFDR-018 06 RA 013, 018 Metering CT Switches (six knifeswitches) D1 remote metering knifeswitches Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 by opening Metering CT Switches (six knifeswitches) for remote metering. VFDR-013 06 VFDR-018 06 RA 013, 018 Panel 55000 D1 Diesel Generator Gauge Panel Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the DIESEL GENERATOR GAUGE PANEL. VFDR-013 06 VFDR-018 06 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-17 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 Panel 55000 D1 Diesel Generator Gauge Panel PI-55001 (D1 DSL GEN RAW WATER PI) remains available in Fire Area 025 to provide local indication of CL header pressure. VFDR-013 06 VFDR-018 06 RA 013, 018 Panel 55000 D1 Diesel Generator Gauge Panel Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 DIESEL GENERATOR PANEL. VFDR-013 06 VFDR-018 06 RA 013, 018 Panel 55410 D1 Remote Control Isolation Panel Manually operate 034-011 (D1 DSL GEN) in Fire Area 025 at the D1 REMOTE CONTROL ISOLATION PANEL. VFDR-013 06 VFDR-018 06 RA 013, 018 PNL 11 DC Distribution Panel 11 De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033. VFDR-013 06 VFDR-018 06 RA 013, 018 PNL 11 DC Distribution Panel 11 De-energize DC control power to BUS 15 at PNL 11, breaker 11-5, located in Fire Area 033 and verify breaker 15-6 is closed. VFDR-013 06 VFDR-018 06 RA 013, 018 U1 Appendix R Switching Equipment cabinet Storage for Electrical Safety Personal Protective Equipment (PPE) and Equipment Obtain switching protective equipment and the 4 ft. hot stick from the Bus 13/14 Room Appendix R cabinet. Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. VFDR-013 06 VFDR-018 06 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-18 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 PNL 21 DC Distribution Panel 21 De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31213 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 01 VFDR-018 01 RA 013, 018 U2 Turbine Front Standard Turbine Overspeed Trip Mechanism Manually trip Unit 2 Main Turbine at the front standard in Fire Area 008. VFDR-013 01 VFDR-018 01 RA 013, 018 2VC 1 MV-32062 Bypass Manually open 2VC 1 in Fire Area 073 to establish RWST supply to charging suction. Time constraint to open 2VC 1 before starting charging pump. VFDR-013 02 VFDR-018 02 RA 013, 018 2VC 8 21 Volume Control Tank Outlet Manual Valve Isolation Manually close 2VC 8 after opening 2VC 1 in Fire Area 073 to establish VCT isolation from charging suction. VFDR-013 02 VFDR-018 02 RA 013, 018 2VC-14-1 21 Reactor Coolant Pump Seal Injection Throttle Valve Prior to starting MTR 211J-1, manually close 2VC-14-1 (21 RC PMP SEAL INJECTION THROTTLE VALVE) in Fire Area 085 to prevent thermal shock to the RCP seals. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-19 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 2VC-14-2 22 Reactor Coolant Pump Seal Injection Throttle Valve Prior to starting MTR 211J-1, manually close 2VC-14-2 (22 RC PMP SEAL INJECTION THROTTLE VALVE) in Fire Area 085 to prevent thermal shock to the RCP seals. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 212 BUS 212 480V Switchgear Verify open or manually trip BKR 212C at BUS 212 in Fire Area 127 to de-energize MCC 2S1 and mitigate spurious operation of PZR Heater Group A. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 222 BUS 222 480V Switchgear Verify open or manually trip BKR 222C at BUS 222 in Fire Area 122 to de-energize MCC 2R1 and mitigate spurious operation of PZR Heater Group B. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 26 BUS 26 4.16KV Switchgear At BUS 26 in Fire Area 118, open DC Knife switches (located inside breaker cubicles) for BKR 26-9 (22 CS PMP) and verify breaker open. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 270 BUS 270 480V Switchgear Verify open or manually trip BKR 270-273 at BUS 270 in Fire Area 017 to de-energize MCC 2P1 and mitigate spurious operation of PZR Heater Group C. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-20 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 BUS 270 BUS 270 480V Switchgear Verify open or manually trip BKR 270-274 at BUS 270 in Fire Area 017 to de-energize MCC 2P2 and mitigate spurious operation of PZR Heater Group D. VFDR-013 02 VFDR-018 02 RA 013, 018 BUS 270 BUS 270 480V Switchgear Verify open or manually trip BKR 270-272 at BUS 270 in Fire Area 017 to de-energize MCC 2R2 and mitigate spurious operation of PZR Heater Group E. VFDR-013 02 VFDR-018 02 RA 013, 018 CV-31211 Charging Line To 21 Regenerative Heat Exchanger Control Valve Prior to starting MTR 211J-1, operate valves in Fire Area 085 to isolate and vent the air supply to fail CV-31211 in the required open position. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 2A1 Motor Control Center 2A BUS 1 De-energize MV-32180 at MCC 2A1, BKR 211E-9, located in Fire Area 031. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 2A2 Motor Control Center 2A BUS 2 De-energize MV-32181 at MCC 2A2, BKR 221E-9, located in Fire Area 031. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 2K1 Motor Control Center 2K BUS 1 De-energize MV-32178 at MCC 2K1, BKR 211J-8, located in Fire Area 073. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 2K2 Motor Control Center 2K BUS 2 Manually trip MTR 221J-1 (21 CHG PMP) at MCC 2K2, BKR 221J-1, in Fire Area 073. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-21 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MCC 2KA2 Motor Control Center 2KA BUS 2 De-energize MV-32179 at MCC 2KA2, BKR 221B-28, located in Fire Area 073. VFDR-013 02 VFDR-018 02 RA 013, 018 MCC 2L1 Motor Control Center 2L BUS 1 De-energize MV-32194 at MCC 2L1, BKR 212E-6, located in Fire Area 074. VFDR-013 02 VFDR-018 02 RA 013, 018 MTR 211J-1 Local Panel 22 Charging Pump Local Panel Manually operate MTR 211J-1 (22 CHARGING PUMP) at the local panel in Fire Area 073 by placing the LOC/REM SEL switch, CS-7082001 in the "LOCAL" position. Then ENERGIZE the VFD by momentarily depressing the START pushbutton, CS-7082002. Then START the 22 CHARGING PUMP by momentarily depressing CS-7082002. VFDR-013 02 VFDR-018 02 RA 013, 018 MTR 211J-1 VFD 22 Charging Pump Variable Frequency Drive Cabinet Switch 22 charging pump local/remote switch to the "LOCAL" position at 22 Charging pump VFD cabinet next to MCC 2K1 in Fire Area 073. VFDR-013 02 VFDR-018 02 RA 013, 018 MV-32194 2 Reactor Excess Letdown Line Isolation Motor Valve A Prior to starting MTR 211J-1, manually close MV-32194 in Fire Area 085. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-22 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 PNL 21 DC Distribution Panel 21 De-energize PNL 271 at PNL 21, breaker 21-10, located in Fire Area 035 in order to fail CV-31234 closed. This action will fail all components powered from PNL 271 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 21 DC Distribution Panel 21 De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail "A" Train RCS Vent System valves closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 22 DC Distribution Panel 22 De-energize PNL 281 at PNL 22, breaker 22-10, located in Fire Area 036 in order to fail CV-31233 closed. This action will fail all components powered from PNL 281 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 21 DC Distribution Panel 21 De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31230 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-23 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 PNL 21 DC Distribution Panel 21 De-energize PNL 25 at PNL 21, breaker 21-16, located in Fire Area 035 in order to fail CV-31422 closed. This action will fail all components powered from PNL 25 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 22 DC Distribution Panel 22 De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train RCS Vent System valves closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect safe shutdown. VFDR-013 02 VFDR-018 02 RA 013, 018 PNL 22 DC Distribution Panel 22 De-energize PNL 26 at PNL 22, breaker 22-18, located in Fire Area 036 in order to fail "B" Train valves downstream of MSIVs closed. This action will fail all components powered from PNL 26 to their loss of power position, which will not adversely affect VFDR-013 03 VFDR-018 03 RA 013, 018 18035 22 Turbine Driven Auxiliary Feedwater Pump Discharge Flow Indicator FI-18035 (22 TD AFW PMP DISCH FI) remains available in Fire Area 031 to provide local AFW flow indication. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-24 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 2AF-292-1 22 Turbine Driven Auxiliary Feedwater Pump Mainstream Steam Supply Control Valve-31999 Root Isolation Manually start 22 TDAFWP by verifying that the lube oil pump is running and placing 2AF-292-1, 22 TD AFW PMP MN STM SPLY CV-31999 ROOT ISOL, in the "OPEN" position. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 21 BUS 21 4.16KV Switchgear At BUS 21 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 21-3 (MTR 21-3, 21 FW PMP) and verify breaker open. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 22 BUS 22 4.16KV Switchgear At BUS 22 in Fire Area 070, open DC knife switches (located inside breaker cubicles) for BKR 22-3 (MTR 22-3, 22 FW PMP) and verify breaker open. VFDR-013 03 VFDR-018 03 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear At BUS 25 in Fire Area 117, verify BKR 25-10 (MTR 25-10, 21 MD AFW PMP) is open. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2A2 Motor Control Center 2A BUS 2 De-energize MV-32246 at MCC 2A2, BKR 221E-11, located in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2A2 Motor Control Center 2A BUS 2 When the AFW pump suction pressure reaches 4" Hg (PI-11081), de-energize MV-32030 at MCC 2A2, BKR 221E-6 (CLG WTR TO 22 TD AFW PMP SUCT), located in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2A2 Motor Control Center 2A BUS 2 De-energize MV-32345 at MCC 2A2, BKR 221E-5, located in Fire Area 031. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-25 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MCC 2B1 Motor Control Center 2B BUS 1 De-energize MV-32022 at MCC 2B1 (BKR 251-6) located in Fire Area 070. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32022 2 Turbine Gland Steam Seal Supply Bypass Motor Valve Manually close MV-32022 in Fire Area 070 to isolate Main Steam flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2B1 Motor Control Center 2B BUS 1 De-energize MV-32021 at MCC 2B1 (BKR 251-5) located in Fire Area 070. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32021 2 Turbine Gland Steam Seal Supply Upstream Shut Off Motor Valve Manually close MV-32021 in Fire Area 070 to isolate Main Steam flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2K1 Motor Control Center 2K BUS 1 De-energize MV-32019 at MCC 2K1, BKR 211J-13, located in Fire Area 073. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32019 21 Steam Generator Main Steam Supply To 22 Turbine Driven Auxiliary Feedwater Pump Motor Valve Verify open MV-32019 in Fire Area 075. VFDR-013 03 VFDR-018 03 RA 013, 018 MCC 2K2 Motor Control Center 2K BUS 2 De-energize MV-32020 at BKR 221J-13 at MCC 2K2, located in Fire Area 073. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32020 22 Steam Generator Main Steam Supply To 22 Turbine Driven Auxiliary Feedwater Pump Motor Valve Manually close MV-32020 in Fire Area 075 to isolate the non-credited steam generator. VFDR-013 03 VFDR-018 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-26 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 MV-32030 22 Turbine Driven Auxiliary Feedwater Pump Suction Cooling Supply Motor Valve Manually open MV-32030, 22 TD AFW PMP SUCT CL SPLY MV, in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32246 22 Auxiliary Feedwater To 21 Steam Generator Motor Valve Manually throttle MV-32246 (22 AFW TO 21 SG MV) in Fire Area 031 as necessary to control AFW flow. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32249 21/22 Auxiliary Feedwater To 22 Steam Generator Isolation Motor Valve Manually close MV-32249 in Fire Area 075 to support isolation of the non-credited steam generator (22 SG). VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32246 22 Auxiliary Feedwater To 21 Steam Generator Motor Valve Verify open MV-32246 in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32345 22 Turbine Driven Auxiliary Feedwater Pump Suction From Condensate Storage Tank Motor Valve Verify open MV-32345 in Fire Area 031. VFDR-013 03 VFDR-018 03 RA 013, 018 MV-32345 22 Turbine Driven Auxiliary Feedwater Pump Suction From Condensate Storage Tank Motor Valve When the AFW pump suction pressure reaches 4" Hg (PI-11081), verify MV-32030 (22 TD AFW PMP SUCT CL SPLY MV) open; then manually close MV-32345 in Fire Area 031 to isolate the CST supply to 245-201 (22 TD AFW PMP) suction. VFDR-013 03 VFDR-018 03 RA 013, 018 PNL 70383 21 Cooling Water Strainer Local Panel Place CV-31654 in emergency at local panel 70383 in Fire AREA 041a to provide strainer backwash for 21 CLG WTR STRNR. VFDR-013 04 VFDR-018 04 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-27 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 2LI-433C Pressurizer Level Cold Calibration Local Indicator LOOP 2L-433 (local indicator 2LI-433C) remains available in Fire Area 073 to provide pressurizer level indication for local control of charging pump flow. VFDR-013 05 VFDR-018 05 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-13 is open. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-16 is open. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear Verify D5 Diesel running and ensure all loads are stripped from BUS 25. Manually close BKR 25-2 (BUS 25 SOURCE FROM D5 DSL GEN) at BUS 25 in Fire Area 117 by pulling the manual CLOSURE lever with the hot stick. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear Verify D5 Diesel running and manually close BKR 25-6 at BUS 25 in Fire Area 117. VFDR-013 06 VFDR-018 06 RA 013, 018 BUS 25 BUS 25 4.16KV Switchgear Prior to starting the D5 Diesel, at BUS 25 in Fire Area 117, verify BKR 25-5 is open. VFDR-013 06 VFDR-018 06 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-28 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 013, 018 D5 Diesel Gen Benchboard D5 Diesel Generator Benchboard Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Diesel Gen Benchboard. VFDR-013 06 VFDR-018 06 RA 013, 018 D5 Vertical Panel D5 Vertical Panel Manually operate 234-031 (D5 DSL GEN) in Fire Area 103 at the D5 Vertical Panel. VFDR-013 06 VFDR-018 06 RA 013, 018 D5 Diesel Gen Benchboard D5 Diesel Generator Benchboard At D5 Diesel Gen Benchboard, place BUS 25 BKR SEL Switch in "LOCAL." VFDR-013 06 VFDR-018 06 RA 013, 018 PNL 27 DC Distribution Panel 27 De-energize DC control power to BUS 25 at PNL 27, breaker 27-1, located in Fire Area 107. VFDR-013 06 VFDR-018 06 RA 013, 018 U2 Appendix R Switching Equipment cabinet Storage for Electrical Safety PPE and Equipment Obtain switching protective equipment and the 4 ft. hot stick from the Appendix R Switching Equipment cabinet (in hallway outside 25 Bus Room). Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. VFDR-013 06 VFDR-018 06 RA 020 MCC 1A2 Motor Control Center 1A BUS 2 De-energize MV-32381 at MCC 1A2, BKR 121E-17, located in Fire Area 032. VFDR-020 07 RA 020 MCC 1A2 Motor Control Center 1A BUS 2 De-energize MV-32382 at MCC 1A2, BKR 121E-18, located in Fire Area 032. VFDR-020 07 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-29 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 020 MV-32381 12 Motor Driven Auxiliary Feedwater Pump Discharge TO 11 Steam Generator Motor Valve Manually close MV-32381 in Fire Area 032 to prevent/terminate uncontrolled feed of 11 Steam Generator. VFDR-020 07 RA 020 MV-32238 11 Auxiliary Feedwater To 11 Steam Generator Motor Valve Throttle MV-32238 from the control room to prevent SG over-fill if 12 MDAFW Pump is spuriously running. VFDR-020 07 RA 020 MV-32239 11 Auxiliary Feedwater To 12 Steam Generator Motor Valve Throttle MV-32239 from the control room to prevent SG over-fill if 12 MDAFW Pump is spuriously running. VFDR-020 07 RA 020 MV-32382 12 Motor Driven Auxiliary Feedwater Pump Discharge To 12 Steam Generator Motor Valve Manually close MV-32382 in Fire Area 032 to isolate the non-credited steam generator and prevent/terminate uncontrolled feed of 12 Steam Generator. VFDR-020 07 RA 022 PNL 70381 11 Cooling Water Strainer Local Panel Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. VFDR-022 01 RA 022 MV-32381 12 Motor Driven Auxiliary Feedwater Pump Discharge To 11 Steam Generator Motor Valve Manually close MV-32381 in Fire Area 032 to prevent/terminate uncontrolled feed of 11 Steam Generator. VFDR-022 01 RA 022 MV-32382 12 Motor Driven Auxiliary Feedwater Pump Discharge To 12 Steam Generator Motor Valve Manually close MV-32382 in Fire Area 032 to isolate the non-credited steam generator and prevent/terminate uncontrolled feed of 12 Steam Generator. VFDR-022 01 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-30 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 029 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-029 01 RA 030 PNL 70381 11 Cooling Water Strainer Local Panel Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. VFDR-030 01 RA 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51001, UNIT 1 PZR HEATERS GROUP A, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51003, 11 TD AFWP TO 11 STM GEN MV-32238, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51005, MV-32239, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51009, LTDN ORIFICE ISOL 40 GPM CV-31325, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51011, LTDN ORIFICE ISOL 40 GPM CV-31326, on "A" Train HSDP to "Local". NA PCS Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-31 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51013, LTDN ORIFICE ISOL 80 GPM CV-31327, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51007, 11 BORIC ACID TRANSFER PUMP, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51101, UNIT 2 PZR HEATERS GROUP A, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51103, 21 MD AFWP TO 21 STM GEN MV-32383, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51109, LTDN ORIFICE ISOL 40 GPM CV-31347, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51111, LTDN ORIFICE ISOL 40 GPM CV-31348, on "A" Train HSDP to "Local". NA PCS Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-32 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51113, LTDN ORIFICE ISOL 80 GPM CV-31349, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51107, 21 BORIC ACID TRANSFER PUMP, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch HC-28400, 1A ATM STM RELIEF (POWER OP) CV-31084, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch HC-28408, 2A ATM STM RELIEF (POWER OP) CV-31102, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51517, 12 MD AFWP, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-51617, 22 TD AFWP, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-19640, CLG WTR TO 12 MD AFWP SUCT, on "A" Train HSDP to "Local". NA PCS Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-33 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-19642, COND TO 12 MD AFWP SUCT, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-19650, COND TO 22 TD AFWP SUCT, on "A" Train HSDP to "Local". NA PCS 031 PNL-51000 Hot Shutdown Panel A Place Local/Remote Control Switch CS-19648, CLG WTR TO 22 TD AFWP SUCT, on "A" Train HSDP to "Local". NA PCS 031 COMP AIR CYL A Compressed air cylinder for safeguards chillers Replace the compressed air cylinders for the safeguards chilled water system when air pressure drops below acceptable value. VFDR-031 02 RA 031 BUS 16 BUS 16 4.16KV Switchgear Open DC Knife switches (located inside breaker cubicles) for BKR 16-3 (12 MDAFW Pump breaker) and verify breaker open at BUS 16 in Fire Area 020 to mitigate spurious actuation. VFDR-031 02 RA 031 U1 Appendix R Switching Equipment cabinet Storage for Electrical Safety PPE and Equipment Obtain switching protective equipment and the 4 ft. hot stick from the Bus 13/14 Room Appendix R cabinet. Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. VFDR-031 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-34 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 031 PNL 211 Instrument Bus II (White) Panel 211 Transfer the source breaker for PNL 211 to the "INTERRUPTIBLE PANEL 217" position at PNL 211 in Fire Area 018 to restore power for credited "A" Train instruments in the Control Room. VFDR-031 02 RA 031 PNL 70381 11 Cooling Water Strainer Local Panel Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. VFDR-031 01 RA 032 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-032 01 RA 032 COMP AIR CYL B Compressed air cylinder for safeguards chillers Replace the compressed air cylinders for the safeguards chilled water system when air pressure drops below acceptable value. VFDR-032 02 RA 032 U2 Appendix R Switching Equipment cabinet Storage for Electrical Safety PPE and Equipment Obtain switching protective equipment and the 4 ft. hot stick from the Appendix R Switching Equipment cabinet (in hallway outside 25 Bus Room). Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. VFDR-032 02 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-35 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 032 BUS 25 BUS 25 4.16KV Switchgear Open DC Knife switches (located inside breaker cubicles) for BKR 25-10 (21 MDAFW Pump breaker) and verify breaker open at BUS 25 in Fire Area 117 to mitigate spurious actuation. VFDR-032 02 RA 037 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-037 01 RA 038 PNL 70381 11 Cooling Water Strainer Local Panel Place CV-31652 in emergency at local panel 70381 in Fire AREA 041a to provide strainer backwash for 11 CLG WTR STRNR. VFDR-038 01 RA 041A CV-31652 11 Cooling Water Strainer Backwash Control Valve When access to Fire Area 041A has been restored, manually operate valves in Fire Area 041A to isolate and vent the air supply to fail open CV-31652 for backwash of 11 CLG WTR STRNR. VFDR-041A 01 RA 041A CV-31653 12 Cooling Water Strainer Backwash Control Valve When access to Fire Area 041A has been restored, manually operate valves in Fire Area 041A to isolate and vent the air supply to fail open CV-31653 for backwash of 12 CLG WTR STRNR. VFDR-041A 01 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-36 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 041A CV-31654 21 Cooling Water Strainer Backwash Control Valve When access to Fire Area 041A has been restored, manually operate valves in Fire Area 041A to isolate and vent the air supply to fail open CV-31654 for backwash of 21 CLG WTR STRNR. VFDR-041A 01 RA 041A CV-31655 22 Cooling Water Strainer Backwash Control Valve When access to Fire Area 041A has been restored, manually operate valves in Fire Area 041A to isolate and vent the air supply to fail open CV-31655 for backwash of 22 CLG WTR STRNR. VFDR-041A 01 RA 041A MTR 111C-21 11 Cooling Water Strainer When access to Fire Area 041A has been restored, manually rotate the backwash arm to flush 11 CLG WTR STRNR as necessary in Fire Area 041A. VFDR-041A 01 RA 041A MTR 111C-22 21 Cooling Water Strainer When access to Fire Area 041A has been restored, manually rotate the backwash arm to flush 21 CLG WTR STRNR as necessary in Fire Area 041A. VFDR-041A 01 RA 041A MTR 121C-21 12 Cooling Water Strainer When access to Fire Area 041A has been restored, manually rotate the backwash arm to flush 12 CLG WTR STRNR as necessary in Fire Area 041A. VFDR-041A 01 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-37 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 041A MTR 121C-22 22 Cooling Water Strainer When access to Fire Area 041A has been restored, manually rotate the backwash arm to flush 22 CLG WTR STRNR as necessary in Fire Area 041A. VFDR-041A 01 RA 041B PNL 70382 12 Cooling Water Strainer Local Panel Place CV-31653 in emergency at local panel 70382 in Fire AREA 041a to provide strainer backwash for 12 CLG WTR STRNR. VFDR-41B 02 RA 041B PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-41B 02 RA 058 D5 Diesel Gen Benchboard D5 Diesel Generator Benchboard In the event of a fire that precludes use of "B" Train RCS makeup to achieve safe shutdown, manually operate 234-031 (D5 DSL GEN) in Fire Area 101 at the D5 Diesel Gen Benchboard and the D5 Vertical Panel. VFDR-058 10 RA 058 PNL 70382 12 Cooling Water Strainer Local Panel Place CV-31653 in emergency at local panel 70382 in Fire AREA 041a to provide strainer backwash for 12 CLG WTR STRNR. VFDR-058 01 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-38 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 058 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-058 01 RA 058 Panel 70556 122 Air Compressor Local Panel In the event of a fire that precludes use of "B" Train RCS makeup to achieve safe shutdown, manually operate MTR 121E-6 (122 AIR COMPRESSOR) at local panel 70556 in Fire Area 032 to provide instrument air for safe shutdown support. VFDR-058 02 RA 058 U2 Appendix R Switching Equipment cabinet Storage for Electrical Safety PPE and Equipment Obtain switching protective equipment and the 4 ft. hot stick from the Appendix R Switching Equipment cabinet (in hallway outside 25 Bus Room). Don the switching protective equipment prior to locally operating circuit breakers at 4kV switchgear. VFDR-058 11 RA 058 BUS 25 BUS 25 4.16KV Switchgear Open DC Knife switches (located inside breaker cubicles) for BKR 25-10 (21 MDAFW Pump breaker) and verify breaker open at BUS 25 in Fire Area 117 to mitigate spurious actuation. VFDR-058 11 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-39 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 058 VC 1 MV-32060 Bypass Charging Pump Suction Manually open VC 1, RWST to charging pump suction MV-32060 bypass valve, in 12 Charging Pump room in Fire Area 058. VFDR-058 08 RA 058 2VC 1 MV-32062 Bypass Charging Pump Suction Manually open 2VC 1, RWST to charging pump suction MV-32062 bypass valve, in 22 Charging Pump room in Fire Area 058. VFDR-058 08 RA 059 WR-10/DISC SW Weld Receptacle 10 Disconnect Switch Manually operate the Appendix R fan at WR-10/DISC SW in Fire Area 008. VFDR-059 01 RA 059 Records Room doors Records Room doors To establish temporary Control Room Cooling, open the Records Room doors and install the Appendix R fan in Fire Area 012. VFDR-059 01 RA 066 MCC 2A1 Motor Control Center 2A BUS 1 De-energize MV-32383 at MCC 2A1, BKR 211E-2, located in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs. VFDR-066 03 RA 066 MCC 2A1 Motor Control Center 2A BUS 1 De-energize MV-32384 at MCC 2A1, BKR 211E-4, located in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs. VFDR-066 03 RA 066 MV-32383 21 Motor Driven Auxiliary Feedwater Pump Discharge To 21 Steam Generator Motor Valve Manually close MV-32383 in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs VFDR-066 03 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-40 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 066 MV-32384 21 Motor Driven Auxiliary Feedwater Pump Discharge To 22 Steam Generator Motor Valve Manually close MV-32384 in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs VFDR-066 03 RA 080 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-080 01 RA 081 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-081 01 RA 097 MCC 2A1 Motor Control Center 2A BUS 1 De-energize MV-32383 at MCC 2A1, BKR 211E-2, located in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs. VFDR-097 01 RA 097 MCC 2A1 Motor Control Center 2A BUS 1 De-energize MV-32384 at MCC 2A1, BKR 211E-4, located in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs. VFDR-097 01 RA 097 MV-32383 21 Motor Driven Auxiliary Feedwater Pump Discharge To 21 Steam Generator Motor Valve Manually close MV-32383 in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs VFDR-097 01 RA 097 MV-32384 21 Motor Driven Auxiliary Feedwater Pump Discharge To 22 Steam Generator Motor Valve Manually close MV-32384 in Fire Area 031 to prevent/terminate uncontrolled feed of Unit 2 SGs VFDR-097 01 RA Northern States Power Company Attachment G - Recovery Actions Transition PINGP Page G-41 Table G-1 Recovery Actions (RA) and Activities Occurring at the Primary Control Station (PCS) Fire Area Operated Component Component Description Actions VFDR RA/PCS 097 PNL 70384 22 Cooling Water Strainer Local Panel Place CV-31655 in emergency at local panel 70384 in Fire AREA 041a to provide strainer backwash for 22 CLG WTR STRNR. VFDR-097 01 RA Northern States Power - Minnesota Attachment H - NEI 04-02 FAQs Summary Table PINGP Page H-1 H. NFPA 805 Frequently Asked Question Summary Table 2 Pages Attached Note: The NFPA 805 FAQ process will continue through the transition of non-pilot NFPA 805 transition plants. Final closure of the FAQs will occur when RG 1.205, which endorses the new revision of NEI 04-02, is approved by the NRC. Northern States Power - Minnesota Attachment H - NEI 04-02 FAQs Summary Table PINGP Page H-2 This table includes the approved FAQs that have not been incorporated into the current endorsed revision of NEI 04-02 and were utilized in this submittal: Table H NEI 04-02 FAQs Utilized in LAR Submittal No. Rev. Title FAQ Ref. Closure Memo 06-0008 9 NFPA 805 Fire Protection Engineering Analyses ML090560170 ML073380976 06-0022 3 Electrical Cable Flame Propagation Tests ML090830220 ML091240278 07-0030 5 Establishing Recovery Actions ML103090602 ML110070485 07-0032 2 Clarification of 10 CFR 50.48(c), 10 CFR 50.48(a) and GDC 3 clarification ML081300697 ML081400292 07-0035 2 Bus Duct Counting Guidance for High Energy Arcing Faults ML091610189 ML091620572 07-0038 3 Lessons Learned on Multiple Spurious Operations ML103090608 ML110140242 07-0039 2 Incorporation of Pilot Plant Lessons Learned - Table B-2 ML091420138 ML091320068 07-0040 4 Non-Power Operations Clarifications ML082070249 ML082200528 08-0042 0 Fire Propagation from Electrical Cabinets ML080230438 ML091460350 ML092110537 08-0043 1 Electrical Cabinet Fire Location ML083540152 ML091470266 ML092120448 08-0044 0 Main Feedwater Pump Oil Spill Fires ML081200099 ML091540179 ML092110516 08-0046 0 Incipient Fire Detection Systems ML081200120 ML093220197 ML093220426 08-0047 1 Spurious Operation Probability Clarifications ML082770662 ML082950750 08-0048 0 Revised Fire Ignition Frequencies ML081200291 ML092180383 ML092190457 08-0049 0 Cable Tray Fire Propagation ML081200309 ML091470242 ML092100274 08-0050 0 Manual Non-Suppression Probability ML081200318 ML092510044 ML092190555 08-0051 0 Hot Short Duration ML083400188 ML100820346 ML100900052 Northern States Power - Minnesota Attachment H - NEI 04-02 FAQs Summary Table PINGP Page H-3 Table H NEI 04-02 FAQs Utilized in LAR Submittal No. Rev. Title FAQ Ref. Closure Memo 08-0052 0 Transient Fires - Growth Rates and Control Room Non-Suppression ML081500500 ML091590505 ML092120501 08-0053 0 Kerite-FR Cable Failure Thresholds ML082660021 ML120060267 07-0054* 1 Demonstrating Compliance with Chapter 4 of NFPA 805 ML103510379 ML110140183 09-0056 2 Radioactive Release Transition ML102810600 ML102920405 09-0057 3 Safe Shutdown Strategy Change ML100330863 ML100960568 10-0059 5 NFPA 805 Monitoring ML111180481 ML120410589 ML120750108 12-0062 0 USAR Content ML120790015 ML121980557

• Note: The FAQ submittal number was 08-0054 but the NRC closure memo for the FAQ was listed as 07-0054. 07-0054 was used to be consistent with the Closure Memo.

Northern States Power - Minnesota Attachment I - Definition of Power Block PINGP Page I-1 I. Definition of Power Block 1 Page Attached Northern States Power - Minnesota Attachment I - Definition of Power Block PINGP Page I-2 The structures in the owner controlled area were evaluated in Prairie Island Nuclear Generating Plant (PINGP) Engineering Evaluation EC 19646, "NFPA 805 LAR Attachment I - Power Block Definition," to determine those that are required to meet the nuclear safety performance criteria and/or the radioactive release performance criteria as described in Section 1.5 of NFPA 805. For the purposes of establishing the structures included in the Fire Protection program in accordance with 10 CFR 50.48(c) and NFPA 805, plant structures listed in the following table are considered to be part of the power block. Table I Power Block Definition Power Block Structures Fire Area(s) Reactor Containment Vessels & Shield Buildings 1, 68, 71, 72 Auxiliary Building 2, 3, 4, 58, 59, 60, 61, 61A, 62, 63, 64, 65, 73, 74, 75, 76, 77, 78, 84, 85, 92 Turbine Building 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 20, 21, 22, 23, 24, 25, 26, 27, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 66, 69, 70, 79, 80, 81, 82, 83 Screenhouse 41, 41A, 41B Intake Screenhouse 86* D5/D6 Diesel Generator Building 97, 98, 99, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, 116, 117, 118, 119, 120, 122, 123, 124, 125, 126, 127, 128 Cooling Tower Equipment House and Transformers 46, 46A* Radwaste, Resin Disposal, Low Level Radwaste Storage Building, Maintenance Storage Shed (Containment Access Facility - CAF), & Truck Loading Enclosure 39, 40, 67, 93 New Service Building 9, 94 Transformers 28a, 28b, 28c, 28d, 28e, 28f Fuel Oil Receiving Tank 100 Fuel Oil Transfer House YARD Underground Fuel Oil Storage Vault YARD

• Fire Area designations for Intake Screenhouse (Fire Area 86) and Cooling Tower Transformers (Fire Area 46A) to be added in FHA revision - See Attachment S, Table S-3 Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-1 J. Fire Modeling V&V 9 Pages Attached Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-2 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Flame Height (Method of Heskestad) Calculates the vertical extension of the flame region of a fire.
• NUREG-1805, Chapter 3, 2004
• NUREG-1824, Volume 3, 2007
• Society of Fire Protection Engineers (SFPE) Handbook, 4th Edition, Chapter 2-1, Heskestad, 2008
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability. Plume Centerline Temperature (Method of Heskestad) Calculates the vertical separation distance, based on temperature, to a target in order to determine the vertical extent of the Zone of Influence (ZOI) or severity factor Heat Release Rate (HRR).
• NUREG-1805, Chapter 9, 2004
• NUREG-1824, Volume 3, 2007
• SFPE Handbook, 4th Edition, Chapter 2-1, Heskestad, 2008
• NUREG/CR-6850, Appendix H - Damage Criteria, 2005
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.
• NUREG/CR-6850 generic screening damage criteria is used, which is considered conservative.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-3 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Radiant Heat Flux (Point Source Method) Calculates the horizontal separation distance, based on heat flux, to a target in order to determine the horizontal extent of the ZOI or severity factor HRR.

• NUREG-1805, Chapter 5. 2004
• NUREG-1824, Volume 4, 2007
• SFPE Handbook, 4th edition, Chapter 3-10, Beyler, C., 2008
• NUREG/CR-6850, Appendix H - Damage Criteria, 2005
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.
• NUREG/CR-6850 generic screening damage criteria is used, which is considered conservative. Hot Gas Layer (Method of MQH) Calculates the hot gas layer temperature for a room with natural ventilation.
• NUREG-1805, Chapter 2, 2004
• NUREG-1824, Volume 3, 2007
• SFPE Handbook, 4th Edition, Chapter 3-6, Walton W. and Thomas, P., 2008
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-4 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Hot Gas Layer (Method of Beyler) Calculates the hot gas layer temperature for a closed compartment with no ventilation.

• NUREG-1805, Chapter 2, 2004
• NUREG-1824, Volume 3, 2007
• SFPE Handbook, 4th Edition, Chapter 3-6, Walton W. and Thomas, P., 2008
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability. Hot Gas Layer (Method of Foote, Pagni, and Alvares [FPA]) Calculates the hot gas layer temperature for a room with forced ventilation.
• NUREG-1805, Chapter 2, 2004
• NUREG-1824, Volume 3, 2007
• SFPE Handbook, 4th Edition, Chapter 3-6, Walton W. and Thomas, P., 2008
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability. Hot Gas Layer (Method of Deal and Beyler) Calculates the hot gas layer temperature for a room with forced ventilation.
• NUREG-1805, Chapter 2, 2004
• NUREG-1824, Volume 3, 2007
• SFPE Handbook, 4th Edition, Chapter 3-6, Walton W. and Thomas, P., 2008
• The correlation is used in the NUREG-1805 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-5 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Ceiling Jet Temperature (Method of Alpert) Calculates the horizontal separation distance, based on temperature at the ceiling of a room, to a target in order to determine the horizontal extent of the ZOI.

• FIVE-Rev1, Referenced by EPRI Report 1002981, 2002
• NUREG-1824, Volume 4, 2007
• SFPE Handbook, 4th Edition, Chapter 2-2, Alpert, R., 2008
• NUREG/CR-6850, Appendix H - Damage Criteria, 2005
• The correlation is used in the FIVE-Rev1 fire model, for which V&V was documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.
• NUREG/CR-6850 generic screening damage criteria is used, which is considered conservative. Hot Gas Layer Calculations using Fire Dynamics Simulator (Version 5) Used to calculate the hot gas layer temperatures for various compartments, and the layer height.
• FDS Version 5
• NIST Special Publication 1018-5, Volume 2: Verification
• NIST Special Publication 1018-5, Volume 3: Validation
• NUREG-1824, Volume 7, 2007
• V&V of the FDS is documented in NIST Special Publication 1018-5.
• The V&V of FDS specifically for Nuclear Power Plant applications has also been documented in NUREG-1824.
• It was concluded that FDS models the hot gas layer height, temperature and smoke concentration in an appropriate manner. Furthermore, the predictions of HGL height and temperature are deemed to be within the bounds of experimental uncertainty.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-6 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Hot Gas Layer Calculations using CFAST (Version 6) Calculates the upper and lower layer temperatures for various compartments, the layer height, and smoke obscuration.

• NIST Special Publication 1086, 2008
• CFAST Version 6
• NUREG-1824, Volume 5, 2007
• V&V of the CFAST code is documented in the NIST Special Publication 1086.
• The V&V of CFAST specifically for Nuclear Power Plant applications has also been documented in NUREG-1824.
• It was concluded that CFAST models the hot gas layer height, temperature and smoke concentration in an appropriate manner. Furthermore, the predictions of HGL height and temperature are deemed to be within the bounds of experimental uncertainty. Smoke Detection Actuation Correlation (Method of Heskestad and Delichatsios) Alpert Ceiling Jet used to determine temperature and Heskestad and Delichatsios temperature to smoke density for smoke detection timing estimates.
• NUREG-1805, Chapter 11, 2004
• NUREG-1824, Volume 4, 2007
• SFPE Handbook, 4th Edition, Chapter 4-1, Custer R., Meacham B., and Schifiliti, R., 2008
• SFPE Handbook, 4th Edition, Chapter 2-2, Alpert, R., 2008
• The smoke detection correlation is used in the NUREG-1805 fire model.
• Alpert's ceiling jet correlation V&V is documented in NUREG-1824.
• The temperature to smoke density correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-7 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Heat Detection Actuation Correlation Alpert Ceiling Jet used to determine temperature for heat detection timing estimates.

• NUREG-1805, Chapter 11, 2004
• NUREG-1824, Volume 4, 2007
• NFPA Handbook, 20th Edition, Chapter 2-4, Custer, R., 2008
• The heat detection correlation is used in the NUREG-1805 fire model.
• Alpert's ceiling jet correlation V&V is documented in NUREG-1824.
• The correlation is documented in an authoritative publication of the NFPA Fire Protection Handbook.
• The correlation is used within the limits of its range of applicability. Sprinkler Activation Correlation Used to estimate sprinkler actuation timing based on ceiling jet temperature, velocity, and thermal response of sprinkler.
• NUREG-1805, Chapter 10, 2004
• NFPA Handbook, 20th Edition, Chapter 2-4, Custer, R., 2008
• The sprinkler actuation correlation is used in the NUREG-1805 fire model.
• The correlation is documented in an authoritative publication of the NFPA Fire Protection Handbook.
• The correlation is used within the limits of its range of applicability.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-8 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Control Room Abandonment Calculation using FDS Evaluates the time at which control room abandonment is necessary based on smoke obscuration and average HGL temperature.

• FDS Version 5
• NIST Special Publication 1018-5, Volume 2: Verification
• NIST Special Publication 1018-5, Volume 3: Validation
• NUREG-1824, Volume 7, 2007
• NUREG/CR-6850, Appendix H - Damage Criteria, 2005
• V&V of the FDS is documented in the NIST Special Publication 1018-5.
• The V&V of FDS specifically for Nuclear Power Plant applications has also been documented in NUREG-1824.
• It was concluded that FDS models the radiant heat and gas temperature in an appropriate manner. Furthermore, the predictions of radiant heat and temperature are deemed to be within the bounds of experimental uncertainty.
• NUREG/CR-6850 generic screening damage criteria is used, which is considered conservative. Corner and Wall HRR Determines a heat release rate adjustment factor for fires that are proximate to a wall or corner.
• IMC 0609, Appendix F, 2005
• SFPE Handbook, 4th Edition, Chapter 2-14, Lattimer, 2008
• The correlation is recommended by IMC 0609 for fires near walls and corners.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-9 Table J-1 - V & V Basis for Fire Models / Model Correlations Used Calculation Application V & V Basis Discussion Correlation for Heat Release Rates of Cables (Method of Lee) Used to correlate bench-scale data to heat release rates from cable tray fires.

• NUREG/CR-6850, Appendix R, 2005
• SFPE Handbook, 4th Edition, Chapter 3-1, Babrauskas, 2008
• The correlation is recommended by NUREG/CR-6850.
• The correlation is documented in an authoritative publication of the SFPE Handbook of Fire Protection Engineering.
• The correlation is used within the limits of its range of applicability. Fire Door Closure Calculation using FDS (Version 5) Evaluates that the door thermal link will activate prior to cable damage.
• FDS Version 5
• NIST Special Publication 1018-5, Volume 2:

Verification

• NIST Special Publication 1018-5, Volume 3: Validation
• NUREG-1824, Volume 7, 2007
• NUREG/CR-6850, Appendix H - Damage Criteria, 2005
• V&V of the FDS is documented in NIST Special Publication 1018-5.
• The V&V of FDS specifically for Nuclear Power Plant applications has also been documented in NUREG-1824.
• It was concluded that FDS models the hot gas layer height, temperature and smoke concentration in an appropriate manner. Furthermore, the predictions of HGL height and temperature are deemed to be within the bounds of experimental uncertainty.
• NUREG/CR-6850 generic screening damage criteria is used, which is considered conservative.

Northern States Power - Minnesota Attachment J - Fire Modeling V&V PINGP Page J-10 Table J-1

References:

1. NUREG-1805, "Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods for the U. S. Nuclear Regulatory Commission Fire Protection Inspection Program," U.S. Nuclear Regulatory Commission, Washington, DC, December 2004. 2. NUREG-1824, "Verification & Validation of Selected Fire Models for Nuclear Power Plant Applications," U.S. Nuclear Regulatory Commission, Washington, DC, May 2007. 3. NUREG/CR-6850, "EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities," U.S. Nuclear Regulatory Commission, Washington, DC, September 2005.

4. The SFPE Handbook of Fire Protection Engineering, 4th Edition, P. J. DiNenno, Editor-in-Chief, National Fire Protection Association, Quincy, MA, 2008.

5. The NFPA Fire Protection Handbook, 20th Edition, A. E. Cote, Editor-in-Chief, National Fire Protection Association, Quincy, MA, 2008. 6. NIST Special Publication 1018-5, "Fire Dynamics Simulator (Version 5) Technical Reference Guide, Volume 2: Verification", National Institute of Standards and Technology, October 29, 2010. 7. NIST Special Publication 1018-5, "Fire Dynamics Simulator (Version 5) Technical Reference Guide, Volume 3: Validation", National Institute of Standards and Technology, October 29, 2010. 8. "Fire Modeling Guide for Nuclear Power Plant Applications", EPRI 1002981, FINAL REPORT, August 2002.

9. IMC 0609, Appendix F, "Fire Protection Significance Determination Process," Issue Date February 28, 2005.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-1 K. Existing Licensing Action Transition 24 Pages Attached Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-2 Attachment K Existing Licensing Action Transition Licensing Action: Appendix R Exemption, Control Room, Lack of automatic fixed suppression system (III.G.3 criteria), Units 1 and 2, Fire Area 13 Basis Date: February 2, 1983 Transitioned? No Licensing Basis: This exemption was requested in a December 6, 1982 NSP submittal to the NRC for the lack of a fixed fire suppression system in the control room as required by Section III.G.3 of Appendix R.

This exemption was approved by the NRC in a letter dated February 2, 1983, which provided the following justification: 1. Ionization smoke detectors are located throughout the control room. 2. Manual suppression is available within and just outside the control room, with good access for manual suppression. 3. The room is continuously manned and access is controlled. 4. The hot shutdown panels provide an alternate shutdown capability outside of the Control Room. 5. Ventilation system can remove smoke and byproducts.

6. Fire loading is light. This exemption is no longer required for the Prairie Island Nuclear Generating Plant (PINGP) NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy is in accordance with Section 4.2.4, and uses a performance based approach that does not credit a fixed suppression system in the control room. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 13, Control Room Initial Exemption Request: December 6, 1982 Information Related to Compliance with Safe Shutdown Requirements of 10 CFR Part 50 Appendix R and Request for Exemption from Requirements of 10CFR Part 50, Appendix R, Section III.G.3 Exemption Correspondence: None Exemption SER: NRC Exemption, February 2, 1983 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-3 Licensing Action: 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 Area 31 Basis Date: May 4, 1983 Transitioned? No Licensing Basis: This exemption was requested in a June 30, 1982 NSP submittal to the NRC for the lack of 20 feet of horizontal separation free of intervening combustibles or lack of a 1-hour fire barrier as required by Section III.G.2 of Appendix R. Additional information was provided in an NSP letter dated October 22, 1982. This exemption was approved by the NRC in a letter dated May 4, 1983, which provided the following justification: 1. The area is equipped with an automatic sprinkler system. 2. Ionization smoke detectors are provided.

3. Portable fire extinguishers are provided. 4. A standpipe hose station and fire extinguishers are located immediately outside the area and can provide service to the area. 5. Thermal barriers will be installed on the top and bottom of Division B cable trays and Division B conduits will be wrapped in one-hour fire rated barriers. 6. The existing sprinkler system will be modified to provide coverage below the cable trays and piping in the areas. 7. The area has low in-situ combustible fuel loads with a fire severity of 8 minutes. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. Although the number and configuration of combustibles has changed since the approval of this exemption, the NFPA 805 transition compliance strategy uses a performance based approach in accordance with Section 4.2.4. The NFPA 805 evaluation does not credit 20 feet of horizontal separation with no intervening combustibles. This exemption will not be transitioned into the NFPA 805 licensing basis.

Applicable Fire Area: 31, "A" Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room Initial Exemption Request: June 30, 1982 Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982 Clarification of Information provided in Support of Request for Exemption Exemption SER: NRC SER, May 4, 1983 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned. Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-4 Licensing Action: 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-hour fire barrier (III.G.2 criteria), Units 1 and 2, Fire Area 32 Basis Date: May 4, 1983 Transitioned? No Licensing Basis: This exemption was requested in a June 30, 1982 NSP submittal to the NRC for the lack of 20 feet of horizontal separation free of intervening combustibles or lack of a 1-hr fire barrier as required by Section III.G.2 of Appendix R. Additional information was provided in a letter dated October 22, 1982. This exemption was approved by the NRC in a letter dated May 4, 1983, which provided the following justification: 1. The area is equipped with an automatic sprinkler system. 2. Ionization smoke detectors are provided. 3. Portable fire extinguishers are provided. 4. A standpipe hose station and fire extinguishers are located immediately outside the area and can provide service to the area. 5. Thermal barriers will be installed on the top and bottom of Division B cable trays and Division B conduits will be wrapped in one-hour fire rated barriers. 6. The existing sprinkler system will be modified to provide coverage below the cable trays and piping in the areas. 7. The area has low in-situ combustible fuel loads with a fire severity of 12 minutes. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. Although the number and configuration of combustibles has changed since the approval of this exemption, the NFPA 805 transition compliance strategy uses a performance based approach in accordance with Section 4.2.4. The NFPA 805 evaluation does not credit 20 feet of horizontal separation with no intervening combustibles. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 32, "B" Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room Initial Exemption Request: June 30, 1982, Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982 Clarification of Information provided in Support of Request for Exemption Exemption SER: NRC SER, May 4, 1983 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned. Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-5 Licensing Action: Appendix R Exemption, Auxiliary Building, Operating Level, Lack of automatic fixed suppression system (III.G.2 criteria), Unit 1, Fire Area 60 Basis Date: May 4, 1983 Transitioned? No Licensing Basis: This exemption was requested in a June 30, 1982, NSP submittal to NRC for the lack of automatic fixed fire suppression as required by Section III.G.2 of Appendix R. Additional information was provided in an NSP letter dated October 22, 1982. This exemption was approved by the NRC in a letter dated May 4, 1983, which provided the following justification: 1. The area is equipped with ionization smoke detectors. 2. Portable fire extinguishers are provided. 3. Standpipe hose stations are provided. 4. Motor control centers and associated cabling entering and leaving the motor control centers are horizontally separated by 22 feet. 5. All cables are qualified to IEEE-383.

6. In-situ combustible loadings in the area are light. 7. Hazardous quantities of transient combustibles are not expected. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. Plant modifications changed the power supplies for steam supply valves and there is no redundant equipment required for safe shutdown located in this fire area. The NFPA 805 transition compliance strategy uses a deterministic approach in accordance with Section 4.2.3 and this exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 60, Auxiliary Building, Operating Level, Unit 1 Initial Exemption Request: June 30, 1982 Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982 Clarification of Information provided in Support of Request for Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G Exemption SER: NRC SER, May 4, 1983 Associated EEEEs: None Evaluation: Based on plant modifications, there is no redundant equipment required for safe shutdown located in this fire area and this exemption is no longer required. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-6 Licensing Action: Appendix R Exemption, Auxiliary Building, Operating Level, Lack of automatic fixed suppression system (III.G.2 criteria), Unit 2, Fire Area 75 Basis Date: May 4, 1983 Transitioned? No Licensing Basis: This exemption was requested in a June 30, 1982 NSP submittal to NRC for the lack of automatic fixed fire suppression as required by Section III.G.2 of Appendix R. Additional information was provided in an NSP letter dated October 22, 1982. This exemption was approved by the NRC in a letter dated May 4, 1983, which provided the following justification: 1. The area is equipped with ionization smoke detectors. 2. Portable fire extinguishers are provided. 3. Standpipe hose stations are provided. 4. Motor control centers and associated cabling entering and leaving the motor control centers are horizontally separated by 22 feet. 5. All cables are qualified to IEEE-383.

6. In-situ combustible loadings in the area are light. 7. Hazardous quantities of transient combustibles are not expected. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. Plant modifications changed the power supplies for steam supply valves and there is no redundant equipment required for safe shutdown located in this fire area. This exemption will not be transitioned into the NFPA 805 licensing basis.

Applicable Fire Area: 75, Auxiliary Building, Operating Level, Unit 2 Initial Exemption Request: June 30, 1982 Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982 Clarification of Information provided in Support of Request for Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G Exemption SER: NRC SER, May 4, 1983 Associated EEEEs: None Evaluation: Based on plant modifications, there is no redundant equipment required for safe shutdown located in this fire area and this exemption is no longer required. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-7 Licensing Action: Appendix R Exemption, Normal Switchgear Room, Lack of automatic fixed suppression system (III.G.2 criteria), Unit 1, Fire Area 37 Basis Date: May 4, 1983 Transitioned? No Licensing Basis: This exemption was requested in a June 30, 1982 NSP submittal to the NRC for the lack of an automatic fixed suppression system as required by Section III.G.2 of Appendix R. Additional information was provided in an NSP letter dated October 22, 1982. This exemption was approved by the NRC in a letter dated May 4, 1983, which provided the following justification: 1. The area is equipped with ionization smoke detectors. 2. Portable fire extinguishers are provided. 3. Standpipe hose stations and fire extinguishers are located outside the access door and are available for servicing this fire area. 4. This fire area was described in the SER as containing emergency diesel generator power cables of redundant divisions from which one train is necessary for safe shutdown. Both division cables are routed in conduit through the area. Horizontal separation between redundant emergency diesel generator power supplies is greater than 20 feet. NOTE: Upon further review NSPM has determined that this cable description is incorrect and should have stated the following: Diesel driven cooling water pump control cables in both divisions are routed in conduit through the area. Existing horizontal separation between redundant diesel driven cooling water pump cables is greater than 20 feet. 5. All cables are qualified to IEEE-383. 6. In-situ combustible loadings in the area are light, consisting of cable insulation that corresponds to a fire severity of approximately 9 minutes. 7. Hazardous quantities of transient combustibles are not expected. Subsequent to approval of this exemption, the safe shutdown components in Fire Area 37 that did not have 20 feet of separation were relocated. This exemption was withdrawn in a letter from NSP to the NRC dated June 9, 1986, and is no longer applicable to PINGP. It will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 37, Unit 1 480V Normal Switchgear Room Initial Exemption Request: June 30, 1982 Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982 Clarification of Information provided in Support of Request for Exemption from the Requirements of 10 CFR Part 50, Appendix R, Section III.G June 9, 1986 Fire Protection Safe Shutdown Analysis and Compliance with Section III.G and III.O of 10 CFR 50, Appendix R

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-8 Exemption SER: NRC SER, May 4, 1983 Associated EEEEs: None Evaluation: This exemption was withdrawn and is no longer applicable to PINGP. It will not be transitioned to the new licensing basis.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-9 Licensing Action: Appendix R Exemption, Auxiliary Building, Ground Level, Lack of automatic fixed suppression system (III.G.2 criteria), Unit 1, Fire Area 58 Basis Date: January 9, 1984 Transitioned? No Licensing Basis: This exemption was initially requested in a June 30, 1982 NSP submittal to the NRC for the lack of separation between redundant equipment and the lack of automatic fixed suppression as required by Section III.G.2 of Appendix R. In a letter dated May 4, 1983, the NRC determined that the level of fire protection as described was not adequate and the initial request was denied.

NSP re-submitted a request for this exemption in a letter dated March 11, 1983, in which NSP explained the separation provisions for redundant equipment and requested exemption from the Section III.G.2 requirement to install an automatic fire suppression system in this area. This exemption was approved by the NRC in a letter dated January 9, 1984; the SER provided the following justification: 1. The area is equipped with a smoke detection system. 2. Adequate manual fire fighting equipment is available. 3. Division B cables and certain Division A safe shutdown cable trays will be enclosed with one-hour fire barriers. 4. Spatial separation is provided between safe shutdown equipment. 5. Fuel loading is low, consisting of cable insulation which if consumed would correspond to a fire severity of approximately 8 minutes. 6. Hazardous quantities of transient combustibles are not expected. Modifications: The SER also described the installation of a one-hour fire rated barrier around all Division B safe shutdown cables and Division A safe shutdown cable trays in the vicinity of MCC 1K2 (Division B). This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy is in accordance with Section 4.2.4, and uses a performance based approach that does not credit a fixed fire suppression system. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 58, Auxiliary Building, Ground Level, Unit 1 Initial Exemption Request: June 30, 1982, Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982, NSP Clarifying Information in Support of Requests for Exemption from 10 CFR Part 50, Appendix R, Section III.G January 12, 1983, NRC Draft SER on Appendix R Exemption Request; this letter was referenced in NSP letter dated March 11, 1983 as the basis for NSP's re-submittal of the exemption request for Fire Areas No. 58, 59, 73, and 74 Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-10 March 11, 1983, NSP Request for Relief from the Requirements of 10 CFR Part 50, Section 50.48(b) for Fire Areas No. 58, 59, 73 and 74 May 4, 1983, NRC letter; this letter denied the exemption for FA 58 as originally requested in the June 30, 1982 NSP letter

May 16, 1983, NSP letter Clarifying Information in Support of Exemption Requests for Fire Areas 58, 59, 73, and 74 Exemption SER: NRC SER, Enclosure 2 to the approval letter dated January 9, 1984 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-11 Licensing Action: Appendix R Exemption, Auxiliary Building, Ground Level, Unit 2, Lack of automatic fixed fire suppression system (III.G.2 criteria), Fire Area 73 Basis Date: January 9, 1984 Transitioned? No Licensing Basis: This exemption was initially requested in a June 30, 1982 NSP submittal to the NRC for the lack of separation between redundant equipment and the lack of automatic fixed suppression as required by Section III.G.2 of Appendix R. In a letter dated May 4, 1983, the NRC determined that the level of fire protection as described was not adequate and the initial request was denied.

NSP re-submitted a request for this exemption in a letter dated March 11, 1983, in which NSP explained the separation provisions for redundant equipment and requested exemption from the Section III.G.2 requirement to install an automatic fire suppression system in this area. This exemption was approved by the NRC in a letter dated January 9, 1984; the SER provided the following justification: 1. The area is equipped with a smoke detection system. 2. Adequate manual fire fighting equipment is available. 3. Division B cables and certain Division A safe shutdown cable trays will be enclosed with one-hour fire barriers. 4. Spatial separation is provided between safe shutdown equipment. 5. Fuel loading is low, consisting of cable insulation which if consumed would correspond to a fire severity of approximately 6 minutes. 6. Hazardous quantities of transient combustibles are not expected. Modifications: The SER also described installation of a one-hour fire rated barrier around all Division B safe shutdown cables and Division A safe shutdown cable trays in the vicinity of Division B MCC 2K2. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy is in accordance with Section 4.2.4, and uses a performance based approach that does not credit a fixed fire suppression system. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 73, Auxiliary Building, Ground Level, Unit 2 Initial Exemption Request: June 30, 1982, Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982, NSP Clarifying Information in Support of Requests for Exemption from 10 CFR Part 50, Appendix R, Section III.G January 12, 1983, NRC Draft SER on Appendix R Exemption Request; this letter was referenced in NSP letter dated March 11, 1983 as the basis for NSP's re-submittal of the exemption request for Fire Areas No. 58, 59, 73, Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-12 and 74 March 11, 1983, NSP Request for Relief from the Requirements of 10 CFR Part 50, Section 50.48(b) for Fire Areas No. 58, 59, 73 and 74

May 4, 1983, NRC letter; this letter denied the exemption for FA 73 as originally requested in the June 30, 1982 NSP letter

May 16, 1983, NSP letter Clarifying Information in Support of Exemption Requests for Fire Areas 58, 59, 73, and 74 Exemption SER: NRC SER, Enclosure 2 to the approval letter dated January 9, 1984 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-13 Licensing Action: Appendix R Exemption, Auxiliary Building, Mezzanine Level, Unit 1, Lack of automatic fixed suppression (III.G.2 criteria), Fire Area 59 Basis Date: January 9, 1984 Transitioned? No Licensing Basis: This exemption was initially requested in a June 30, 1982 NSP submittal to the NRC for the lack of separation between redundant equipment and the lack of automatic fixed suppression as required by Section III.G.2 of Appendix R. In a letter dated May 4, 1983, the NRC determined that the level of fire protection as described was not adequate and the initial request was denied. NSP re-submitted a request for this exemption in a letter dated March 11, 1983, in which NSP explained the separation provisions for redundant equipment and requested exemption from the Section III.G.2 requirement to install an automatic fire suppression system in this area. This exemption was approved by the NRC in a letter dated January 9, 1984; the SER provided the following justification: 1. The area is equipped with a smoke detection system. 2. Adequate manual fire fighting equipment is available. 3. Safe shutdown cable trays will be enclosed with one-hour fire barriers. 4. Redundant MCCs are separated by 28 feet and spatial separation is provided between redundant cables for safe shutdown equipment. 5. Fuel loading is low, consisting of cable insulation which if consumed would correspond to a fire severity of approximately 15 minutes. 6. Hazardous quantities of transient combustibles are not expected. Modifications: The SER also described installation of a one-hour fire rated barrier around all Division B safe shutdown cables. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy is in accordance with Section 4.2.4, and uses a performance based approach that does not credit a fixed fire suppression system. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 59, Auxiliary Building, Mezzanine Level, Unit 1 Initial Exemption Request: June 30, 1982, Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982, NSP Clarifying Information in Support of Requests for Exemption from 10 CFR Part 50, Appendix R, Section III.G January 12, 1983, NRC Draft SER on Appendix R Exemption Request; this letter was referenced in NSP letter dated March 11, 1983 as the basis for NSP's re-submittal of the exemption request for Fire Areas No. 58, 59, 73, and 74 Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-14 March 11, 1983, NSP Request for Relief from the Requirements of 10 CFR Part 50, Section 50.48(b) for Fire Areas No. 58, 59, 73 and 74 May 4, 1983, NRC letter; this letter denied the exemption for FA 59 as originally requested in the June 30, 1982 NSP letter

May 16, 1983, NSP letter Clarifying Information in Support of Exemption Requests for Fire Areas 58, 59, 73, and 74 Exemption SER: NRC SER, Enclosure 2 to the approval letter dated January 9, 1984 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-15 Licensing Action: Appendix R Exemption, Auxiliary Building, Mezzanine Level, Unit 2, Lack of automatic fixed suppression (III.G.2 criteria), Fire Area 74 Basis Date: January 9, 1984 Transitioned? No Licensing Basis: This exemption was initially requested in a June 30, 1982 NSP submittal to the NRC for the lack of separation between redundant equipment and the lack of automatic fixed suppression as required by Section III.G.2 of Appendix R. In a letter dated May 4, 1983, the NRC determined that the level of fire protection as described was not adequate and the initial request was denied. NSP re-submitted a request for this exemption in a letter dated March 11, 1983, in which NSP explained the separation provisions for redundant equipment and requested exemption from the Section III.G.2 requirement to install an automatic fire suppression system in this area. This exemption was approved by the NRC in a letter dated January 9, 1984; the SER provided the following justification: 1. The area is equipped with a smoke detection system. 2. Adequate manual fire fighting equipment is available. 3. Safe shutdown cable trays will be enclosed with one-hour fire barriers. 4. Redundant MCCs are separated by 28 feet and spatial separation is provided between redundant cables for safe shutdown equipment. 5. Fuel loading is low, consisting of cable insulation which if consumed would correspond to a fire severity of approximately 14 minutes. 6. Hazardous quantities of transient combustibles are not expected. Modifications: The SER also described installation of a one-hour fire rated barrier around all Division B safe shutdown cables. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy is in accordance with Section 4.2.4, and uses a performance based approach that does not credit a fixed fire suppression system. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 74, Auxiliary Building, Mezzanine Level, Unit 2 Initial Exemption Request: June 30, 1982, Fire Protection Safe Shutdown Analysis and Compliance with Section III.G of 10 CFR Part 50, Appendix R, Including Requests for Relief Exemption Correspondence: October 22, 1982, NSP Clarifying Information in Support of Requests for Exemption from 10 CFR Part 50, Appendix R, Section III.G January 12, 1983, NRC Draft SER on Appendix R Exemption Request; this letter was referenced in NSP letter dated March 11, 1983 as the basis for NSP's re-submittal of the exemption request for Fire Areas No. 58, 59, 73, and 74 Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-16 March 11, 1983, NSP Request for Relief from the Requirements of 10 CFR Part 50, Section 50.48(b) for Fire Areas No. 58, 59, 73 and 74 May 4, 1983, NRC letter; this letter denied the exemption for FA 74 as originally requested in the June 30, 1982 NSP letter

May 16, 1983, NSP letter Clarifying Information in Support of Exemption Requests for Fire Areas 58, 59, 73, and 74 Exemption SER: NRC SER, January 9, 1984 Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. This exemption will not be transitioned.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-17 Licensing Action: Appendix R Exemption, Unit 1 and Unit 2 Containments, Intervening combustibles between redundant shutdown divisions, Fire Areas 1 and 71 Basis Date: July 31, 1984 Transitioned? No Licensing Basis: This exemption was requested in a January 23, 1984 NSP submittal to the NRC based on the lack of 20 feet horizontal separation between cables and equipment of redundant trains with no intervening combustibles, as required by Section III.G.2(d) of Appendix R. With one exception as described in the submittal, these areas have the required spatial separation between redundant components needed for safe shutdown, but there are intervening combustibles.

This exemption was approved by NRC in a letter dated July 31, 1984 with the following justification: 1. All redundant components are separated by 20 feet or more, except for the pressurizer level transmitters for Unit 2. As will be discussed later, this exception actually applies to both Units 1 and 2. 2. Redundant cabling associated with the pressurizer level transmitters is separated by 10 feet and one division will be protected with a one-hour fire barrier. As will be discussed later, the protection of this cabling is different for Units 1 and 2. 3. Combustibles in these fire areas are RCP lubricating oil and cable insulation. The amount of cable insulation, if consumed, would correspond to a fire severity of 7.5 minutes in Unit 1 and 7.7 minutes in Unit 2. 4. Ionization smoke detectors are located on each level with alarms in the Control Room. 5. Standpipe hose stations are located on each level. 6. Access is restricted during power operation due to high radiation fields. 7. RCP lubricating oil would drain to the sump (approved exemption from Section III.O). 8. The cable is IEEE-383 qualified.

9. Hazardous quantities of transient combustible materials are not expected due to access restrictions in containment during power operation. 10. Administrative controls during use of transient combustibles require a dedicated fire watch armed with a fire extinguisher.

During the review of this exemption, it was discovered that the protection of cabling for the pressurizer level transmitters is different for Units 1 and 2, as follows:

• NSP letter dated April 5, 1984 identified the lack of 20' separation for this cabling and stated that cables of one division would be wrapped in an approved one hour barrier for both Units 1 and 2.
• The NRC SER dated July 31, 1984 approved the exemption request and cited NSP actions to protect cabling of one division in a one-hour barrier, but this SER only identified this action for Unit 2.
• NSP installed a one-hour barrier in Unit 2 in accordance with the SER.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-18

• During a subsequent review in 1997 NSP recognized that protection of the pressurizer level transmitter cabling was required in Unit 1 and installed a noncombustible radiant energy shield. The previously unprotected condition of this cabling and the installation of a noncombustible radiant energy shield was described in LER 1-97-017, "Separation of Pressurizer level Indication Channels Not in Compliance with 10 CFR 50 Appendix R Section III.G.2," submitted to the NRC on January 2, 1998.
• PINGP LER 1-97-017 was reviewed by the NRC in Inspection Report 50-28250-306-97023 dated January 30, 1998, and was closed in NRC Inspection Report 50-282/50-306-98016 dated October 9, 1998.
• The existing radiant energy shield in Unit 1 has been determined to be acceptable in accordance with the NFPA 805 performance based approach. This exemption is no longer required for the PINGP NFPA 805 Fire Protection Program. The NFPA 805 transition compliance strategy for these Fire Areas uses a performance based approach in accordance with Section 4.2.4. Although the installation of fire barriers differs from that described in NSP's exemption request, the pressurizer level transmitter cable protection features for both Unit 1 and Unit 2 were determined to be acceptable in accordance with the NFPA 805 performance based approach and this exemption is no longer required. This exemption will not be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 1, 71, Containment, Units 1 and 2 Initial Exemption Request: January 23, 1984, NSP letter, Exemption Requests to the Requirements of Appendix R to 10 CFR 50 Exemption Correspondence: April 5, 1984, Information in Support of Exemption Requests Submitted January 23, 1984 and Request for Exemption from the Requirements of Section III.O of Appendix R to 10 CFR Part 50 January 2, 1988, NSP letter, LER 1-97-17, Separation of Pressurizer Level Indication Channels Not in Compliance with 10 CFR 50 Appendix R Section III.G.2

January 30, 1998, NRC letter, Notice of Violation and NRC Inspection Report No. 50-282/97023(DRP), 50-306/97023(DRP) for PINGP October 9, 1998, NRC letter, NRC Fire Protection Functional Inspection (FPFI) Reports 50-282/98016(DRS); 50-306/98016(DRS) Exemption SER: July 31, 1984, NRC Exemption In the Exemption attached to the approval letter the NRC states in part the following:

"The licensee requested an exemption from Subsection III.G.2 to the extent that these areas have intervening combustibles between components of redundant trains needed for safe shutdown. In addition, except for the redundant cabling associated with the pressurizer level transmitters for unit 2 (Fire Area 71), all other redundant components are separated by twenty feet or more. The redundant cabling associated with the pressurizer level transmitters is separated by ten feet. For this cabling the licensee has Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition  PINGP Page K-19  committed to protecting one division with a one-hour fire barrier."    [Note: as discussed in the Licensing Basis discussion above, the SER only identifies pressurizer level transmitters in Unit 2, although the NSP submittal identified that this exemption applies to both Units 1 and 2]   Associated EEEEs: None Evaluation: The NFPA 805 transition compliance strategy for this Fire Area uses a performance based approach and this exemption is no longer required under the new licensing basis. Also, the installation of fire barriers to protect cables for one of the redundant divisions of the pressurizer level transmitters has been evaluated using the performance based approach and, while the installations are different for Unit 1 and Unit 2, both installations have been determined to be acceptable. This exemption will not be transitioned.    

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-20 Licensing Action: Appendix R Exemption, RCP Oil Collection, RCP oil collection system is not in strict compliance (III.O criteria), Fire Areas 1, 71 Basis Date: July 31, 1984 Transitioned? Yes Licensing Basis: This exemption was requested in an April 5, 1984 NSP submittal to the NRC for the lack of a closed vented container inside containment capable of holding the entire inventory of the Reactor Coolant Pump (RCP) lube oil collection system, as required by Section III.O of Appendix R. This exemption was approved by NRC in a letter dated July 31, 1984, with the following justification: 1. The sump is a concrete pit in the basement of containment with a capacity of 990 gallons, which is more than the capacity needed to contain the total inventory of lube oil for the two RCPs for each unit. 2. There is no safe shutdown equipment in the area surrounding the RCPs or Sump A. 3. The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the control room if this level is exceeded. 4. The sump can also manually be pumped down at any time.

5. The sump is normally drained to vented containers in the auxiliary building which have a total capacity of 2600 gallons. This system is designed to collect contaminated water from pump seal leakage as well as oil leakage. 6. The pipe from the sump to the vented container in the auxiliary building has been designed to seismic category III which meets the requirement of Regulatory Guide 1.29, paragraph C-2.

The bases for this exemption, as approved by the NRC, reflect the current plant configuration and remain valid. This exemption will be transitioned into the NFPA 805 licensing basis. Applicable Fire Area: 1, 71, Containment, Units 1 and 2 Initial Exemption Request: April 5, 1984, Information in Support of Exemption Requests Submitted January 23, 1984 and Request for Exemption from the Requirements of Section III.O of Appendix R to 10 CFR Part 50 NSP described the RCP lube oil collection system and requested exemption from the specific requirement of Section III.O to have a closed vented container inside containment. NSP stated its belief that the existing collection system meets the intent of Appendix R, as previously described in a letter dated January 23, 1984, in that all lube oil is collected to a common point which will prevent its contact with hot piping in the area and is isolated from electrical power cable which might cause ignition. NSP provided the following justification for this exemption: 1. The lube oil collection system is seismically designed.

2. High flash point Mobile Synthetic lube oil is being utilized.

3. There is no safety related equipment in the vicinity of the RCP or Sump A inside containment. 4. Safe shutdown equipment and cabling is separated from the RCPs and Sump A by the shield wall and 18" thick concrete floors.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-21 5. During design and installation (1978) of the collection system a decision was made to not install a vented closed collection tank inside containment because the collection system also collects RCP water seal leakage, and it was determined that it would be better to deliver all leakage from both sources directly to the sump, where it would then be pumped to a vented closed tank. This letter also provided the following description of the collection system: PINGP Units 1 and, 2 have two Reactor Coolant Pumps each. For purposes of this description the units are identical. Each Reactor Coolant Pump contains 265 gallons of lube oil for a total of 530 gallons per unit. The lube oil is Mobile Synthetic lube oil which has a flash point of 480°F and an ignition point of 520°F. A series of drip pans and deflectors are located around the pump such that leakage from all potential pressurized and unpressurized leakage sites in the Reactor Coolant Pump lube oil systems are collected and piped to the adjacent floor drain which empties into Sump A in the basement of the containment. Sump A is a concrete open pit, covered with grating, built into the floor which has a capacity of 990 gallons. There is no Safe Shutdown Equipment in the area surrounding the Reactor Coolant Pumps or Sump A. Sump A is designed to automatically pump down when the level of the tank reaches the 695©-9" elevation. (The bottom of" the sump is at 693© -6".) This is at approximately the 555 gallon point. If level continued to rise due to failure of the automatic pump function, an alarm would sound in the Control room at the 696©-9" level of the sump, approximately 800 gallons. An operator can then initiate manual control of the sump pump for pumping down. The top of the sump pit is at floor level, the 697 ©-6" elevation which represents the 990 gallon maximum capacity point of the sump. In addition to the automatic function, operators may at any level manually control the pump to pump down the sump. The sump is normally lined up to pump to the aerated sump tank in the Auxiliary Building which has a capacity of 600 gallons.

The aerated sump tank is a vented closed tank. The aerated sump tank then pumps to the aerated drain tanks in the Auxiliary Building. Each aerated drain tank has a capacity of 1000 gallons for a total capacity of 2000 gallons. The aerated sump tank and drain tanks serve both units. The aerated drain tanks are vented closed tanks. The capability also exists to pump from the aerated sump tank to the 25,000 gallon waste hold-up tank which is also a vented closed tank. Exemption Correspondence: January 23, 1984, NSP letter, Exemption Requests to the Requirements of Appendix R to 10 CFR 50. This letter described the RCP lube oil collection and stated its understanding that the collection system meets the intent and is in compliance with Section III.O of Appendix R to 10 CFR 50. May 22, 1984 NSP letter, Information in Support of the Request for Exemption from the Requirement of Section III.O of Appendix R to 10 CFR 50 dated April 5, 1984 This letter described that piping from the sump to the vented container in the auxiliary building is designed to either Seismic Category III or Category I.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-22 Exemption SER: NRC Exemption, July 31, 1984 In the exemption attachment to the approval letter the NRC states: "The licensee requested an exemption from Subsection III.O to the extent that the reactor coolant pump lube oil collection system is piped to the sump inside containment. The contents of the sump can be pumped to a closed vented container located in the auxiliary building. The licensee states that the sump in the basement of the containment is a concrete pit having a capacity of 990 gallons, which is more than the capacity needed to contain the total inventory of lube oil for the two reactor coolant pumps for each unit. There is no safe shutdown equipment in the area. The sump is designed to automatically pump down at a prescribed sump level and an alarm will sound in the control room if this level is exceeded. The operator can initiate manual control of the sump pump at any time, overriding the automatic control of sump level. The sump is normally drained to vented containers in the auxiliary building having a total capacity of 2600 gallons. The basis for the design of this collection system is to collect any contaminated water from the pump seal leakage as well as any oil leakage.

In addition, 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. This is based on a review conducted by the licensee and confirmed by letter dated May 22, 1984.

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 existing 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.O of Appendix R. Therefore, the exemption from the requirements specified in Subsection III.O for the lube oil collection system is granted." Associated EEEEs: None Evaluation: The bases for this exemption remain valid. This exemption will be transitioned and will be included in the new licensing basis.

Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-23 Licensing Action: Appendix R Exemption, Control Room, Use of repair to remove fuses (III.G.1 criteria), Fire Area 13 Basis Date: February 21, 1995 Transitioned? Yes Licensing Basis: This exemption was requested in a May 2, 1994 NSP submittal to the NRC to allow manual removal of fuses from the power-operated relief valve (PORV) control circuit in the event of a fire (considered a repair action outside the bounds of Section III.G.1), in lieu of modifying plant hardware which would otherwise be required to achieve compliance with Section III.G.1 of Appendix R. The NRC approved this exemption in a letter dated February 21, 1995 and provided the following justification: 1. Closing the block valves and pulling the PORV control circuit fuses is an effective means of preventing potential loss of RCS inventory in the event of a control room fire that could result in a hot short or short to ground that may cause the PORV to open or be maintained open. 2. The requirement to remove/pull the PORV fuses is included in plant procedures as an immediate action in response to a control room evacuation. 3. The fuse panels are readily accessible and the fuses are clearly identified in the panels. 4. Sufficient space is available to permit access for pulling fuses and emergency lights and fuse pullers are provided in the vicinity of each panel. 5. The operators are trained for a control room evacuation and to remove these fuses. Action to isolate power to the PORV control circuits in the event of a fire is still a required action and this exemption will be transitioned into the NFPA 805 licensing basis. Subsequent to the approval of this exemption, a modification was installed to allow power to be isolated from the PORV control circuits by opening disconnect switches in lieu of pulling fuses. The basis for the continued applicability of this exemption is clarified in Attachment T. Applicable Fire Area: 13, Control Room Initial Exemption Request: May 2, 1994 NSP letter, Exemption Request, Use of Hot Shutdown Repair to Meet the Requirements of Appendix R NSP requested an exemption from the specific criteria in Section III.G.1 of Appendix R to allow removal of the fuses in the PORV control circuit as a means of ensuring that proper RCS inventory is maintained in the event of a fire that causes an open PORV resulting in the loss of RCS inventory. The following justification is provided: 1. Three separate failures are required to cause this event: - The operator fails to shut the PORV Block valve and/or a material failure occurs (i.e., a short prevents the valve from closing or causes the valve to open). - A "hot short" in the control circuitry causes the PORV to open. Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-24 - The PORV circuit failure is sustained long enough for "the open PORV to jeopardize plant safety. 2. A Probabilistic Risk Assessment demonstrated that the event of a PORV hot short due to a control room fire represents a small contribution to overall risk of core damage. 3. Operator actions required to manually remove the fuses in the PORV control circuit are straightforward and are included in plant procedures and training. Exemption Correspondence: None Exemption SER: February 21, 1995, NRC Exemption In the exemption attached to the approval letter the NRC states: "By letter dated May 2, 1994, the licensee requested an exemption to permit it to manually remove fuses from the power-operated relief valve control circuit in the event of a fire, in lieu of modifying plant hardware which would otherwise be required to achieve compliance with Section III.G.1 of Appendix R. The licensee©s submittal initially referenced Section III.G.2 of Appendix R as providing the requirements from which the licensee was seeking an exemption, but in a follow-up telephone conversation with the staff the licensee concurred that Section III.G.1 is the appropriate reference.

This exemption was requested by the licensee in response to inspection findings identified in inspection reports 50-282/87-004, 50-282/88-013, 50-282/92-011 and 50-282/94-004. These findings addressed a concern with circuit failure modes that could adversely affect the ability to maintain hot shutdown in the event of a control room fire. This condition could occur if the power operated relief valves (PORV) block valves were not shut and a hot short damaged the PORV control circuit causing the PORV to open and remain open. Specifically, this involves the high/low pressure interface spurious signal concerns associated with Unit 1 PORVs CV-31231 and CV-31232 and their associated block valves MOV-32195 and MOV-32196 and with Unit 2 PORVs CV-31233 and CV-31234 and their associated block valves, MOV-32197 and MOV-32198. As a precaution to prevent the potential loss of reactor coolant system (RCS) inventory during a control room fire, the licensee has proposed to close the PORV block valves prior to control room evacuation. The licensee also proposed to remove the PORV control circuit fuses to prevent a hot short or short to ground which may cause the PORV to open or be maintained open. As stated above, removal of fuses for isolation in such circumstances is considered a repair and, therefore, does not meet Appendix R, Section III.G.1, as interpreted by the staff. The licensee©s proposed actions of closing the PORV block valves and removing the control circuit fuses was reviewed by the staff and was found to be an effective means of assuring that a control room fire will not result in a sustained loss of RCS inventory. The substance of the licensee©s submittal was reviewed by Region III inspectors during the inspection conducted from July 18-22, 1988. The inspection findings were documented in NRC Inspection Report No. 50-282/88-013 and 50-306/88-013. The inspectors walked down the control room evacuation shutdown procedures. Step 3.3.1 of Procedure F5, Northern States Power - Minnesota Attachment K - Existing Licensing Action Transition PINGP Page K-25 Appendix B, "Control Room Evacuation (Fire)," directs the operators to remove/pull the fuses for the PORVs as an immediate action in response to a control room evacuation. The inspectors found that the fuse panels were readily accessible and the fuses were clearly identified in the panels. The inspectors also found that sufficient space is available to permit access for pulling fuses and that emergency lights and the fuse pullers had been provided in the vicinity of each panel. A training program has been established for all plant operators to enhance the familiarity with and proper response to the control room evacuation. Additionally, as a part of Emergency Operating Procedures (EOP) training, all the operators are trained on the above-mentioned procedures to ensure their familiarity with respect to the removal of fuses during hot shutdown. Therefore, operators are trained and experienced in removing the fuses.

On the basis of this evaluation, the Commission concludes that the proposed action to close the PORV block valves prior to control room evacuation and to remove fuses from the PORV control circuit provides reasonable assurance that safe shutdown can be achieved in the event of a control room fire and is acceptable." Associated EEEEs: None Evaluation: The bases for this exemption remain valid. This exemption will be transitioned and will be included in the new licensing basis, subject to clarification in Attachment T. Northern States Power - Minnesota Attachment L NFPA 805 Chapter 3 Requirements for Approval PINGP Page L-1 L. NFPA 805 Chapter 3 Requirements for Approval (10 CFR 50.48(c)(2)(vii)) 3 Pages Attached Northern States Power - Minnesota Attachment L NFPA 805 Chapter 3 Requirements for Approval PINGP Page L-2 Approval Request 1 NFPA 805 Section 3.5.16 NFPA 805 Section 3.5.16 states: "The fire protection water supply system shall be dedicated for fire protection use only. Exception No. 1: Fire protection water supply systems shall be permitted to be used to provide backup to nuclear safety systems, provided the fire protection water supply systems are designed and maintained to deliver the combined fire and nuclear safety flow demands for the duration specified by the applicable analysis. Exception No. 2: Fire protection water storage can be provided by plant systems serving other functions, provided the storage has a dedicated capacity capable of providing the maximum fire protection demand for the specified duration as determined in this section." Basis for Request: NRC approval is being requested since the fire water system can be aligned for screenwash system use and emergency uses, and as such it does not meet the requirement or allowed exceptions. Acceptance Criteria Evaluation: The Mississippi river provides fire protection water. The system consists of two horizontal centrifugal fire pumps each rated at 2,000 gpm at 125 psig. One pump is motor driven (MDFP) and the other pump is diesel driven (DDFP). The 10" fire header is maintained between 108 and 113 psig by a jockey pump. The motor driven fire pump will automatically start at 95 psig. If the header pressure drops to 90 psig, the diesel-driven fire pump will start. The motor and diesel-driven fire pumps are designed to pump 2,000 gpm at a discharge pressure of 125 psi. Contrary to the requirements of NFPA 805 Section 3.5.16, the fire protection water supply system at PINGP may periodically be utilized to supply water for non-fire protection purposes (screenwash). The motor-driven fire pump can be aligned to provide a backup water supply to the Screenhouse screenwash system in the event of a screenwash pump failure. If the fire pump is required to supplement the screenwash header flow, the pump must be started manually either locally or remotely. Control valve FP-30-10 ties the fire protection water system to the screenwash header. FP-30-10 is normally closed and requires a manual action to open it. Once the pump is operating and no auto start signal exists from the fire protection header, the discharge to the screenwash header valve (CV 31131) opens automatically via Solenoid Valve SV 33049 and maintains the screenwash header pressure at approximately 90 psig. The non-fire protection use of the PINGP fire protection water system requires prior notification of the Control Room. This process ensures that the fire water system will be restored to full capacity during a fire scenario. Personnel utilizing fire protection water Northern States Power - Minnesota Attachment L NFPA 805 Chapter 3 Requirements for Approval PINGP Page L-3 for non-fire protection purposes are in contact with the Control Room, therefore ensuring the ability to secure the full fire water system capacity should a fire occur. There are two potential impacts to the use of the fire protection water system for screenwash purposes - one is a fire within the Screenhouse Fire Area 41, and one for all other fire areas, as delineated below: For a fire in any fire area except Fire Area 41 The plant P&ID drawing indicates that SV 33049 will only open Control Valve 31131 if the 121 MDFP is not running and the pressure demand on the fire header is not below 90 psi. If there is not a demand on the fire header and the pump is manually started, the control valve will open and allow fire protection water into the Screenwash system to clean the screens. If a demand is placed on the fire header from a suppression system actuation, the pressure drop will cause SV 33049 to close CV 31131 thereby realigning the water flow to the fire protection header. The control cables for SV 33049/CV 31131 run from the MDFP room FA 41B (elev. 670' screenhouse) to FA 41, (elev. 695' screenhouse). A fire event in any fire area other than FA 41 will cause a pressure drop on the fire header thereby closing CV 31131 via SV 33049 and re-aligning the MDFP water supply from the traveling screens to the fire header. For a fire in Fire Area 41 The control cables for SV 33049/CV 31131 run from the MDFP room FA 41B (elev. 670' screenhouse) to FA 41, (elev. 695' screenhouse). A postulated fire in FA 41 may cause cable damage, thereby creating the potential for a hot short of the circuit resulting in CV 31131 failing in the open position. This would divert some fire protection water from the MDFP from entering the fire header. If this scenario occurs, the DDFP will start, providing the fire header with 2,000 gpm at 125 psi. FA 41 suppression system, PA-9, has a demand of 1,094.1 gpm at 89.1 psi. This demand is within the design capacity of the DDFP. Check valve FP-28-2 will prevent water in the fire protection header from entering the Screenwash diversion piping network. The use of the MDFP for Screenwash cleaning will not impact the ability of the fire protection header to deliver the system demand for fire suppression activities in any plant fire area. Nuclear Safety and Radiological Release Performance Criteria: The ability to use the 121 MDFP for the Screenwash function has no impact on the radiological release performance criteria. The radiological release review was performed based on the release of firefighting water potentially containing radioactive materials and is not dependent on the MDFP alignment to supplement the Screenwash function. The ability to use the 121 MDFP for the screenwash function does not change the radiological release evaluation and does not add additional radiological materials to the area or challenge system boundaries. Northern States Power - Minnesota Attachment L NFPA 805 Chapter 3 Requirements for Approval PINGP Page L-4 Safety Margin and Defense-in-Depth: The ability to use the 121 MDFP for the Screenwash function does not change the safety margin since it has no impact on the ability of the MDFP to supply water to the fire header unless there is a fire in FA 41. If a fire occurs in FA 41, the DDFP will supply the fire header with adequate flow and pressure. The use of the MDFP for Screenwash cleaning will not impact the ability of the fire protection header to deliver the system demand for fire suppression requirements. The three echelons of defense-in-depth are to: 1) prevent fires from starting (combustible/hot work controls), 2) rapidly detect, control and extinguish fires that do occur thereby limiting damage (fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans), and 3) provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (fire barriers, fire rated cable, success path remains free of fire damage, recovery actions). The use of the MDFP for Screenwash cleaning does not affect echelons 1, 2 and 3. The ability to use the 121 motor driven fire pump for the Screenwash function does not directly result in compromising automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability since water will automatically be re-directed to the fire protection header upon actuation of a fire suppression system or supplied from the DDFP in the event the MDFP is unavailable. Conclusion: Aligning the 121 MDFP to perform the screenwash function and emergency uses does not meet the requirement or allowed exceptions of NFPA 805 Section 3.5.16. The evaluation determined that the performance-based approach utilized to evaluate a variance from the requirements of NFPA 805 Chapter 3: 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). Therefore, NRC approval is being requested to permit the fire water system to be aligned for the screenwash function and other emergency uses, only when the screenwash pump is out of service. Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-1 M. License Condition Changes 9 Pages Attached Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-2 NSPM proposes to replace the current PINGP fire protection license conditions 2.C.(4) for Units 1 and 2 with the standard license condition in Regulatory Position 3.1 of Regulatory Guide 1.205. The License Condition markups follow. ______________________________________________________________________ NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated ___________ (and supplements dated____________ ) and as approved in the Safety Evaluation Report dated ____________ (and supplements dated _____________). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied. Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact. (a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. (b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval is not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-3 element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the NSPM PINGP NFPA 805 Transition Report - Attachment M, Revision 0, Page M-3 component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows: * "Fire Alarm and Detection Systems" (Section 3.8); * "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9); * "Gaseous Fire Suppression Systems" (Section 3.10); and, * "Passive Fire Protection Features" (Section 3.11). (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval is not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation Report dated ________ to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program. Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above. (2) The licensee shall implement the modifications described in Attachment S, Table S-2, of the September 2012 PINGP NFPA 805 LAR and as supplemented by letters dated [date] to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the second full operating cycle for each unit after approval of the LAR. (3) The licensee shall maintain appropriate compensatory measures in place until completion of the modifications delineated above. Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-4 It is NSPM's understanding that implicit in the replacement of the current license condition, all prior fire protection program SERs and commitments will be superseded in their entirety by the revised license condition.

No other license conditions need to be replaced or revised.

NSPM implemented the following process for determining that these are the only license conditions required to be either revised or superseded to implement the new fire protection program which meets the requirements in 10 CFR 50.48(a) and 50.48(c):

• A review was conducted of the PINGP Unit 1 Renewed License Number DPR-42, through Amendment No. 205 and Unit 2 Renewed License Number DPR-60, through Amendment No. 192. The review was performed by reading the Operating License and performing electronic searches. Outstanding LARs that have been submitted to the NRC were also reviewed for potential impact on the license conditions.

Marked-up License Condition pages follow.

Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-5 License Condition Markups 5 Pages Follow Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-6 Unit 1 License Condition 2.C(4): Safeguards Information protected under 10 CFR 73.21, is entitled: "Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program," submitted by letters dated October 18, 2006, and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011. NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company -Minnesota (NSPM) Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 202. 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. (5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 188, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions. (6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas: (a) Fire fighting response strategy with the following elements: 1. Pre-defined coordinated fire response strategy and guidance 2. Assessment of mutual aid fire fighting assets 3. Designated staging areas for equipment and materials 4. Command and control 5. Training of response personnel Renewed Operating License No. DPR-42 Amendment Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-7 Unit 2 License Condition 2.C(4): (4 Safeguards Information protected under 10 CFR 73.21, is entitled: "Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program," submitted by letters dated October 18, 2006 and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011. NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company -Minnesota (NSPM) Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 189. 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, April21, 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. The Additional Conditions contained in Appendix B, as revised through Amendment No. 177, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions. (6) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas: (a) Fire fighting response strategy with the following elements: 1. Pre-defined coordinated fire response strategy and guidance 2. Assessment of mutual aid fire fighting assets 3. Designated staging areas for equipment and materials 4. Command and control 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following: 1. Protection and use of personnel assets 2. Communications 3. Minimizing fire spread 4. Procedures for implementing integrated fire response strategy 5. Identification of readily-available pre-staged equipment 6. Training on integrated fire response strategy 7. Spent fuel pool mitigation measures Renewed Operating License No. DPR-60 Amendment No. 4.QO Cerresteel ey letter elateel 4.1:1!ji:ISt ;!;j, ::;1011 Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-8 Insert A for License Condition 2.C.(4) for both Units 1 and 2: NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated ___________ (and supplements dated____________ ) and as approved in the Safety Evaluation Report dated ____________ (and supplements dated _____________). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied. Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact. (a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. (b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval is not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-9 corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the NSPM PINGP NFPA 805 Transition Report - Attachment M, Revision 0, Page M-3 component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows: * "Fire Alarm and Detection Systems" (Section 3.8); * "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9); * "Gaseous Fire Suppression Systems" (Section 3.10); and, * "Passive Fire Protection Features" (Section 3.11). (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval is not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation Report dated ________ to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program. Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above. (2) The licensee shall implement the modifications described in Attachment S, Table S-2, of the September 2012 PINGP NFPA 805 LAR and as supplemented by letters dated [date] to complete the transition to full compliance with 10 CFR 50.48(c) before the end of the second full operating cycle for each unit after approval of the LAR. Northern States Power - Minnesota Attachment M - License Condition Changes PINGP Page M-10 (3) The licensee shall maintain appropriate compensatory measures in place until completion of the modifications delineated above. Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-1 N. Technical Specification Changes 5 Pages Attached Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-2 The following PINGP Technical Specifications (TS) will be revised as indicated: TS 5.0, Administrative Controls, Section 5.4, Procedures, specification 5.4.1 currently states, in part that written procedures shall be established, implemented, and maintained covering the following activities: 5.4.1.d. Fire Protection Program implementation; and This LAR proposes to delete the words: "Fire Protection Program implementation" and replace this wording with the words: "Not used." This change is proposed because after completion of the transition to NFPA 805, the requirement for fire protection program implementation procedures will be contained in 10 CFR 50.48(a) and 10 CFR 50.48(c), as specifically outlined in Section 3.2.3, "Procedures," of NFPA 805. The requirement to maintain a fire protection program in accordance with 10 CFR 50.48(a) and 10 CFR 50.48(c) is included in the new License Condition described in Attachment M. No changes to the TS Bases are required to support the transition to the new NFPA 805 FPP. Changes to the PINGP Renewed Operating License include a revision to License Condition 2.C.(4), Fire Protection, as described in Attachment M. NSPM implemented the following process for determining which TS or TS Bases sections were required to be revised or deleted to implement the new FPP which meets the requirements in 10 CFR 50.48(a) and 50.48(c).

• A review was conducted of the PINGP TS by NSPM Regulatory Affairs personnel assigned to the NFPA 805 transition team. The review was performed by reviewing the TS and performing electronic searches. Outstanding TS changes that have been submitted to the NRC were also included. The TS Markups and retyped "clean" pages follow.

Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-3 Technical Specification Markup 1 Page Follows Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-4 Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities: Prairie Island Units 1 and 2 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; b. The emergency operating procedures required to implement the requirements ofNUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33; e. All programs specified in Specification 5.5. 5.0-6 Unit 1 -Amendment Unit 2 -Amendment No. -l49 Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-5 Technical Specification Retype 1 Page Follows

Northern States Power - Minnesota Attachment N - Technical Specification Changes PINGP Page N-6 Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained covering the following activities: Prairie Island Units 1 and 2 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; b. The emergency operating procedures required to implement the requirements ofNUREG-0737 and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33; c. Quality control for effluent and environmental monitoring; d. Not used; and e. All programs specified in Specification 5.5. 5.0-6 Unit 1-AmendmentNo. Unit2 -Amendment No. +49 Northern States Power - Minnesota Attachment O - Orders and Exemptions PINGP Page O-1 O. Orders and Exemptions 2 Pages Attached Northern States Power - Minnesota Attachment O - Orders and Exemptions PINGP Page O-2 Exemptions As described in Section 4.2.3, previously approved exemptions from the requirements of 10 CFR 50, Appendix R have been determined to be either compliant with 10 CFR 50.48(c) or are no longer needed. Therefore, NSPM requests that the following exemptions granted against 10 CFR 50, Appendix R, pursuant to 10 CFR 50.12 in NRC letters dated February 2, 1983, May 4, 1983, January 9, 1984, July 31, 1984, and February 21, 1995 be rescinded:

• An exemption from Section III.G.3 for lack of a fixed fire suppression system in the Control Room, Units 1 and 2, Fire Area 13, (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 (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 (May 4, 1983).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Operating Level, Unit 1, Fire Area 60 (May 4, 1983).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Operating Level, Unit 2, Fire Area 75 (May 4, 1983).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Normal Switchgear Room, Unit 1, Fire Area 37 (May 4, 1983).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Ground Floor Level, Unit 1, Fire Area 58 (January 9, 1984).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Ground Floor Level, Unit 2, Fire Area 73 (January 9, 1984).
• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Mezzanine Level, Unit 1, Fire Area 59 (January 9, 1984).

Northern States Power - Minnesota Attachment O - Orders and Exemptions PINGP Page O-3

• An exemption from Section III.G.2 for lack of an automatic fixed fire suppression system in the Auxiliary Building Mezzanine Level, Unit 2, Fire Area 74 (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 (July 31, 1984).
• 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 (July 31, 1984).
• An exemption from Section III.G.1 to allow operators to remove fuses from 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, Units 1 and 2, Control Room Fire Area 13 (February 21, 1995). Specific details regarding these exemptions are contained in Attachment K. Orders No Orders need to be superseded or revised. NSPM implemented the following process for making this determination:
• A review was conducted of the PINGP docketed correspondence by NSPM licensing staff. The review was performed by reviewing the correspondence files and performing electronic searches of internal PINGP records and the NRC's ADAMS document system.
• A specific review was performed of the license amendment that incorporated the mitigation strategies required by Section B.5.b of Commission Order EA-02-026 (TAC Nos. MD4612 and MD4613) to ensure that any changes being made to ensure compliance with 10 CFR 50.48(c) do not invalidate existing commitments applicable to the plant. The review of this order demonstrated that changes to the fire protection program will not affect measures required by B.5.b.
• The Fukushima Orders are being independently evaluated. Any plant changes will continue to be evaluated for impact on the fire protection program in accordance with the PINGP design change process.

Northern States Power - Minnesota Attachment P - RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) PINGP Page P-1 P. RI-PB Alternatives to NFPA 805 10 CFR 50.48(c)(4) No risk-informed or performance-based alternatives to compliance with NFPA 805 (per 10 CFR 50.48(c)(4)) were utilized by Northern States Power - Minnesota. Northern States Power - Minnesota Attachment Q - No Significant Hazards Evaluation PINGP Page Q-1 Q. No Significant Hazards Evaluations 4 Pages Attached Northern States Power - Minnesota Attachment Q - No Significant Hazards Evaluation PINGP Page Q-2 A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92, "Issuance of amendment." As described in 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: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. Northern States Power - Minnesota (NSPM) has evaluated the proposed amendment and determined that it involves no significant hazards consideration, using the three standards set forth in 10 CFR 50.92, as discussed below: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Operation of the Prairie Island Nuclear Generating Plant (PINGP) in accordance with the proposed amendment does not increase the probability or consequences of accidents previously evaluated. Engineering analyses, which may include engineering evaluations, probabilistic safety assessments, and fire modeling evaluations, have been performed to demonstrate that the performance-based requirements of National Fire Protection Association Standard 805 (NFPA 805) have been satisfied. The PINGP Updated Safety Analysis Report (USAR) documents the analyses of design basis accidents (DBAs) at PINGP. The proposed amendment does not adversely affect accident initiators nor alter design assumptions, conditions, or configurations of the facility that would increase the probability or consequences of accidents previously evaluated. Further, the changes to be made for fire hazard protection and mitigation do not adversely affect the ability of structures, systems, and components (SSCs) to perform their design functions, nor do they affect the postulated initiators or assumed failure modes for accidents described and evaluated in the USAR. SSCs required to safely shut down the reactor and to maintain it in a safe shutdown condition will remain capable of performing their design functions.

The purpose of this proposed amendment is to permit PINGP to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of Regulatory Guide (RG) 1.205. The NRC considers that NFPA 805 provides an acceptable methodology and performance criteria for licensees to identify fire protection systems and features that are an acceptable alternative to the 10 CFR 50, Appendix R fire protection features (69 FR 33536, June 16, 2004). Engineering analyses, in accordance Northern States Power - Minnesota Attachment Q - No Significant Hazards Evaluation PINGP Page Q-3 with NFPA 805, have been performed to demonstrate that the risk-informed, performance-based (RI-PB) requirements per NFPA 805 have been met. NFPA 805, taken as a whole, provides an acceptable alternative to 10 CFR 50.48(b), satisfies 10 CFR 50.48(a) and General Design Criterion (GDC) 3 of Appendix A to 10 CFR 50, and meets the underlying intent of the NRC©s existing fire protection regulations and guidance, and provides for defense-in-depth. The goals, performance objectives, and performance criteria specified in Chapter 1 of NFPA 805 ensure that if there are any increases in the net core damage frequency (CDF) or risk associated with this license amendment request (LAR) submittal, the increase will be small and consistent with the Commission©s Safety Goal Policy.

Based on this, the implementation of this amendment does not significantly increase the probability of any accident previously evaluated. Equipment required to mitigate an accident remains capable of performing the assumed function(s). The proposed amendment will not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of any accident previously evaluated. Therefore, the consequences of any accident previously evaluated are not significantly increased with the implementation of the proposed amendment. 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated? Response: No.

Operation of PINGP in accordance with the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. Any scenario or previously analyzed accident with offsite dose was included in the evaluation of DBAs documented in the USAR. The proposed change does not alter the requirements or function for systems required during accident conditions. Implementation of the new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of RG 1.205 will not result in new or different accidents.

The proposed amendment does not introduce new or different accident initiators nor alter design assumptions or conditions of the facility. The proposed amendment does not adversely affect the ability of SSCs to perform their design function. SSCs required to safely shut down the reactor and maintain it in a safe shutdown condition remain capable of performing their design functions.

The purpose of this amendment is to permit PINGP to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of RG 1.205. The NRC considers that NFPA 805 Northern States Power - Minnesota Attachment Q - No Significant Hazards Evaluation PINGP Page Q-4 provides an acceptable methodology and performance criteria for licensees to identify fire protection systems and features that are an acceptable alternative to the 10 CFR 50, Appendix R fire protection features (69 FR 33536, June 16, 2004). The requirements in NFPA 805 address only fire protection and the impacts of fire on the plant that have already been evaluated. Based on this, the implementation of this amendment does not create the possibility of a new or different kind of accident from any kind of accident previously evaluated. The proposed amendment does not introduce any new accident scenarios, transient precursors, failure mechanisms, malfunctions, or limiting single failures that could initiate a new accident. There will be no adverse effect or challenges imposed on a safety related system as a result of this proposed amendment.

Therefore, the possibility of a new or different kind of accident from any kind of accident previously evaluated is not created with the implementation of this amendment. 3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Operation of PINGP in accordance with the proposed amendment does not involve a significant reduction in a margin of safety. The proposed amendment does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by this change. The proposed amendment does not adversely affect existing plant safety margins or the reliability of equipment assumed to mitigate accidents in the USAR. The proposed amendment does not adversely affect the ability of SSCs to perform their design function. SSCs required to safely shut down the reactor and to maintain it in a safe shutdown condition remain capable of performing their design function.

The purpose of this amendment is to permit PINGP to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of RG 1.205. The NRC considers that NFPA 805 provides an acceptable methodology and performance criteria for licensees to identify fire protection systems and features that are an acceptable alternative to the 10 CFR 50, Appendix R fire protection features (69 FR 33536, June 16, 2004). Engineering analyses, which may include engineering evaluations, probabilistic safety assessments, and fire modeling evaluations, have been performed to demonstrate that the performance-based methods do not result in a significant reduction in a margin of safety.

Northern States Power - Minnesota Attachment Q - No Significant Hazards Evaluation PINGP Page Q-5 Based on this, the implementation of this amendment does not significantly reduce a margin of safety. The proposed changes are evaluated to ensure that the risk and safety margins are kept within acceptable limits. Therefore, the transition to NFPA 805 does not involve a significant reduction in a margin of safety. The proposed amendment to transition to NFPA 805 continues to protect public health and safety and the common defense and security because the overall approach of NFPA 805 is consistent with the key principles for evaluating license basis changes, as described in RG 1.174, is consistent with the defense-in-depth philosophy, and maintains sufficient safety margins. Based on the responses to questions 1, 2, and 3 above, NSPM has concluded that the proposed amendment presents no significant hazards consideration in accordance with the requirements in 10 CFR 50.92(c). Northern States Power - Minnesota Attachment R -Environmental Considerations PINGP Page R-1 R. Environmental Considerations Evaluation 2 Pages Attached Northern States Power - Minnesota Attachment R -Environmental Considerations PINGP Page R-2 NSPM has evaluated this LAR against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. NSPM has determined that this LAR meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50.

The purpose of this amendment is to permit the Prairie Island Nuclear Generating Plant (PINGP) to adopt a new fire protection licensing basis which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 of RG 1.205. The NRC considers that NFPA 805 provides an acceptable methodology and performance criteria for licensees to identify fire protection systems and features that are an acceptable alternative to the 10 CFR 50, Appendix R fire protection features (69 FR 33536, June 16, 2004).

The requirements in NFPA 805 address only fire protection and the impacts of fire on the plant have already been evaluated, as part of compliance to 10 CFR 50.48(a) and (b).

This proposed amendment to transition the PINGP Fire Protection Program to NFPA 805 would change requirements with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment meets the following specific criteria: i. The amendment involves no significant hazards consideration. As stated in Section 5.3.1 and Attachment Q, this proposed amendment does not involve a significant hazards consideration. ii. There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite. Compliance with NFPA 805 explicitly requires the attainment of performance criteria, objectives, and goals for radioactive releases to the environment. The radioactive release goal is to provide reasonable assurance that a fire will not result in a radiological release that affects the public, plant personnel, or the environment. Transition to the NFPA 805 requirements does not impact effluents. Therefore, there will be no significant change in the types or significant increase in the amounts of any effluents released offsite. iii. There is no significant increase in individual or cumulative occupational radiation exposure. Compliance with NFPA 805 explicitly requires the attainment of performance criteria, objectives, and goals for occupational exposure. There will be no Northern States Power - Minnesota Attachment R -Environmental Considerations PINGP Page R-3 significant increase in individual or cumulative occupational radiation exposure resulting from this change. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in conjunction with the proposed amendment.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-1 S. Plant Modifications and Items to be Completed During Implementation 28 Pages Attached

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-2 Tables S-1, Plant Modifications Completed, and S-2, Plant Modifications Committed, provided below, include a description of the modifications along with the following information:

• A problem statement,
• Risk ranking of the modification,
• An indication if the modification is currently included in the FPRA,
• Compensatory Measure in place, and
• A risk-informed characterization of the modification and compensatory measure.
• The following legend should be used when reviewing the Risk Rank in Tables S-1 and S-2: o High = Modification would have an appreciable impact on reducing overall fire CDF. o Medium = Modification would have a measurable impact on reducing overall fire CDF. o Low = Modification would have either an insignificant or no impact on reducing overall fire CDF. o N/A = Not modeled in the FPRA, therefore a risk ranking is not provided NSPM is requesting two full operating cycles beyond SE issuance to fully implement modifications. This is, in part, due to the outage strategies implemented at PINGP where only one train is removed from service per outage, per unit. Due to the significant modifications required to transition PINGP to NFPA 805, additional time is necessary to fully implement modifications described in Table S-2. As discussed during the April 2012 pre-submittal meeting, NSPM will implement Code Conformance modifications before the end of the first full operating cycle per unit after SE issuance. Therefore:

NSPM will complete implementation of the modifications described in Table S-2 as follows:

• Before the end of the first full operating cycle per unit after issuance of the NFPA 805 license amendment: Items 8, 9, and 16
• Before the end of the second full operating cycle per unit after issuance of the NFPA 805 license amendment: all remaining items Table S-1 Plant Modifications Completed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization None Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-3 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 1 High 1 A fire could damage Train B 12 Motor Driven Auxiliary Feedwater Pump (MDAFWP) and the control switches for the 11 Turbine Driven Auxiliary Feedwater Pump (TDAFWP) discharge valves (MV-32242 & MV-32243). Fire damage to CS-51003 could cause spurious closure of MV-32238 which would isolate the 11 TDAFWP flow to the credited 11 Steam Generator. Fire damage to control switch CS-51005 could prevent closing MV-32239 which could divert the 11 TDAFWP flow to the non-credited 12 Steam Generator. The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal.

Cables of Concern: 11 AFW to 11 SG MV, MV-32238 (cable 1CA-115) 11 AFW to 12 SG MV, MV-32239 (cable 1CA-116) Modify equipment in FA 31 ensure that Train "A" equipment is available for fire safe shutdown. Yes Yes The modifications proposed by Items 1-4 will reduce risk by modifying FAs 31 and 32 to ensure that each FA has either A-train or B-train related equipment. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory Measures: Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-4 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 2 High 2 A fire in FA 31 could damage the 22 TDAFWP (Train B) and damage the circuits for the Train A 21 MDAFWP (MV-32383 & MV-32384). Fire damage at the Train A Hot Shutdown Panel or MCC 2A1 could affect MV-32383 (21 MDAFWP to 21 SG) or MV-32384 (21 MDAFWP to 22 SG). A fire at MCC 2A1 could affect MV-32026 (21 MDAFWP suction from Cooling Water), MV-32336 (21 MDAFWP suction from CST), MV-32383 (21 MDAFWP to 21 SG) and MV-32384 (21 MDAFWP to 22 SG). The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal. Cables of Concern: 21 MDAFWP to 21 SG, MV-32383 (2A1-5, 2A1-5A, 2CA-115, 2CA-116, 2CA-

65) 21 MDAFWP to 22 SG, MV-32384 (2A1-5A, 2A1-6, 2CA-116, 2CA-117, 2CA-

66)

MDAFWP suction from CST, MV-32026 (2A1-2, 2A1-2A, 2A1-4A, 2CA-30) 21 MDAFWP suction from CST, MV-32336 (2A1-4, 2A1-4A, 2CA-30) Modify equipment in FA 31 ensure that Train "A" equipment is available for fire safe shutdown. Yes Yes The modifications proposed by Items 1-4 will reduce risk by modifying FAs 31 and 32 to ensure that each FA has either A-train or B-train related equipment. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-5 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 3 High 1 A fire could damage the 11 TDAFWP (Train A) and the control switches for the 12 MDAFWP discharge valves (MV-32381 & MV-32382). Fire damage at the Train B Hot Shutdown Panel or MCC 1A2 could affect MV-32381 (12 MDAFWP to 11 SG) or MV-32382 (12 MDAFWP to12 SG). A fire at MCC 1A2 could affect MV-32027 (12 MDAFWP suction from Cooling Water), MV-32335 (12 MDAFWP suction from CST), MV-32381 (12 MDAFWP to 11 SG) and MV-32382 (12 MDAFWP to 12 SG). The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal. Cables of Concern: 12 MDAFWP to 11 SG, MV-32381 (1A2-7A, 1CB-52, 1CB-53, 1CB-54) 12 MDAFWP to 12 SG, MV-32382 (1A2-8A, 1CB-52, 1CB-55, 1CB-56) 12 MDAFWP suction from Cooling Water, MV-32027 (1A2-3, 1A2-3A, 1A2-6A) 12 MDAFWP suction from CST, MV-32335 (1A2-6, 1A2-6A) Modify equipment in FA 32 ensure that Train "B" equipment is available for fire safe shutdown. Yes Yes The modifications proposed by Items 1-4 will reduce risk by modifying FAs 31 and 32 to ensure that each FA has either A-train or B-train related equipment. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-6 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 4 High 2 A fire could damage the 21 MDAFWP (Train A) and the control switches for the 22 TDAFWP discharge valves. Fire damage to CS-51605 could cause spurious closure of MV-32247 which would isolate the 22 TDAFWP flow to the credited 22 Steam Generator. Fire damage to control switch CS-51603 could prevent closing MV-32246 which could divert the 22 TDAFWP flow to the non-credited 21 Steam Generator. The NFPA 805 Nuclear Safety Performance Goal Criteria is not met for Decay Heat Removal.

Cables of Concern: 22 AFW to 21 SG MV, MV-32246 (cable 2CB-164) 22 AFW to 22 SG MV, MV-32247 (cable 2CB-163) Modify equipment in FA 32 ensure that Train "B" equipment is available for fire safe shutdown. Yes Yes The modifications proposed by Items 1-4 will reduce risk by modifying FAs 31 and 32 to ensure that each FA has either A-train or B-train related equipment. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-7 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 5 High 1,2 A fire in FA 18, Relay Room could damage both trains of safe shutdown. Since the risk of Recovery Actions taken in procedure F5 App B, Control Room Evacuation (Fire) are still high, installing incipient detection is needed to reduce risk in the relay room. Install Incipient Detection System in the Relay Room that will continuously sample the Relay Room air near or inside the most likely sources of fires (i.e., cabinets) to identify fires based on the detection of the presence of small amounts of products of combustion and, if detected, will sound an alarm in the MCR.Yes Yes The proposed modification will reduce risk by installing an incipient detection system that will notify operators of fires in their incipent state. This reduces the significance of the fire scenarios that could lead to control room abandonment. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-8 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 6 Medium 1, 2 Fire damage to cable 1CX-99 in FA 20 could cause a loss of the normal power feed from 13 Inverter to 120VAC Panel 113. Loss of Panel 113 causes CV-31198 (Charging Line to 11 Regenerative Heat Exchanger CV) to fail open causing diversion of flow from RCP seal injection to charging. Loss of Panel 113 causes loss of Control Room indication for instrument Loops 1N51 (Unit 1 Excore Detection Train A), 1T-450A (Unit 1 RCS Loop A Hot Leg Temperature) and 1T-450B (Unit 1 RCS Loop A Cold Leg Temperature).

Modification is needed to protect 1CX-99 from fire damage in Fire Area 20 to maintain Process Monitoring indication in the control room.

Modification (described in Item #7) to allow Bus 15 load sequencer to automatically re-power Bus 15 from D1 will allow 11 CC pump to provide component cooling to the RCP Thermal Barrier Heat Exchanger. Reroute the following cables through FA 58 along the "G" line between 8 and 9 and out of FA 20: - 1CX-99 (Instrument Bus III (Blue) Panel 113 Normal Power Feed) - 1CW-99 (Instrument Bus II (White) Panel 111 Normal Power Feed) - 1DCA-4 (DC Power supply to PNL 15) Re-route conductors from 1C-419 (Breaker 15-3, Bus 15 Offsite Source from 1R Transformer) to cable 15403-B. Re-route affected conductors of cable 1C-333 out of FA 32 and FA 58 so the 1RY offsite power supply will be available in FA 32 and FA 58. Install New Cable (or protect with tray cover above initiator) - 2DCA-105 (DC Power Cable from 21 Battery 125V DC Panel 27 Train A) Yes Yes The proposed modification will reduce risk because it will reroute cables associated with the opposite train of equipment to another FA. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-9 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 6 Cont Fire damage to cable 1CW-99 in FA 20 could cause a loss of the normal power feed from 11 Inverter to Panel 111. Loss of Panel 111 results in the loss of Control Room indication for instrument Loop 1L-487 (11 SG Wide Range Level) displayed on Level Recorder 1LR-470. Modification is needed to protect 1CW-99 (Instrument Bus II (White) Panel 111 Normal Power Feed).

Fire damage to cable 1CF-35 in FA 20 could cause a loss of Control Room indication for Loop 1L-433 (Unit 1 Pressurizer Level). Modification to protect cable 1CW-99 from fire damage in FA 20 will ensure Pressurizer Level Indication LOOP 1L-427 remains available in the control room.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-10 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 6 Cont A fire in FA 20 could damage cable 1DCA-4 which is required for automatic feedwater isolation, and could also damage cables which could cause a loss of DC control power to 4.16KV Bus 11 and Bus 12. Loss of control power to Bus 11 and 12 results in the inability to remotely trip 11 Main Feedwater Pump (MTR 11-3) and 12 Main Feedwater Pump (MTR 12-3) from the Control Room. This can result in SG overfill and failure of the credited 11 Turbine-driven AFW Pump. Modification is needed to re-route cable 1DCA-4 to ensure automatic main feedwater isolation can be credited. A fire in FA 20 could damage cable 1C-419 which couuld affect the ability of BKR 15-3, 1RY source to Bus 15, to clear from the potentially faulted 1RY source to Bus 15. Local manual action is required to open BKR 15-3 so that Bus 15 can be repowered from the D1 Emergency Diesel Generator. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-11 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 6 Cont A fire in FA 32 could damage cable 1C-333 affecting the 1RY source to Bus 16, and could damage cable 16408-1, CT11 source to Bus 16, and cables 1DCB-2 and 1DCB-95 which support the D2 source to Bus 16. A modification to route affect conductors of cable 1C-333 out of fire area 32 is needed to protect the 1RY source to Bus 16 in fire area 32. A fire in FA 058/073, 695' elevation of the Aux Building could damage cable 2DCA-105 which provides DC control power to PNL 27 which provides DC control power to Bus 25 to trip 4 KV breakers. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-12 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 7 Medium 1 A fire in FA 20 could damage cables which could prevent the Load Sequencer from automatically re-powering Bus 15. Bus 15 needs to automatically be re-powered from D1 by the Load Sequencer to provide vital AC power.

A fire in FA 81 could damage cables which could prevent the Bus 16 Load Sequencer from automatically re-powering Bus 16 from D2. Bus 16 needs to be automatically re-powered to provide vital AC power Install additional potential transformers, one on the 1RY source to Bus 16 for the Bus 16 Load Sequencer. Install one potential transformer on the CT11 source to Bus 15 for the Bus 15 Load Sequencer. The following cables will be modified so they will not fail the Load Sequencer in FA 20 or FA 69: 11401-D, 12401-A, 13401-J, 14404-E, 15403-B, 15403-C, 16408-D, 1C-1456, 1C-3105, 1C-419, 1C-421, 1C-5611, 1C-6354, 1C-6356, BUS 15 Load Sequencer (1C-6354) Yes Yes The proposed modification will reduce risk by ensuring the Unit 1 Load Sequencers will not be affected by certain fires in FA 20 and

69. Also, the modification will ensure the Load Sequencers will be able to auto-load the Diesel Generators for fires in FA 20 and 69.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-13 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 8 High 1,2 Fire Detection required for the Fire PRA is not code compliant, as required by NFPA 805, for the following Fire Areas: FA-18, 41, 58/73, 59/74 Install New Fire Detectors per NFPA 72 (Detection) to resolve NFPA 72 code deviations in the following areas:

FA 18: Install missing Ionizing detectors in several beam pockets. FA 41B: Relocate detector from the exhaust stream of a ventilation duct. FA58/73: Resolve various detector code issues based on S&L Fire Detector Study, Rev 0, PINGP, Project No: 111973-055, 12/20/2008. FA59/74: Resolve various detector code issues based on S&L Fire Detector Study., Rev 0, PINGP, Project No: 111973-055, 12/20/2008. Yes Yes The proposed modification will reduce risk by allowing the Fire PRA to credit fire detection systems in the listed Fire Areas. Per the 2009 ASME PRA Standard, fire detection systems must be code compliant if they are credited in the Fire PRA. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-14 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 9 High 1,2 Fire Suppression required for the Fire PRA is not code compliant, as required by NFPA 805, for the following Fire Areas: FA 18, 41A, 41B, 31, & 32. Fire Suppression in Fire Area 14 required for the deterministic compliance to NFPA 805 is not code compliant. Install additional suppression and detection in various rooms to resolve NFPA Suppression code deviations as follows:

FA 18: Install heat detectors to actuate CO2 fire suppression system in beam pockets in the ceiling of the Relay Room. Provide electrical supervision. Install odorizer for the Cardox System. FA31: Install return bends on the Suppression System. FA32: Install return bends on the Suppression System. FA41A: Install missing Sprinkler #229. The sprinkler is shown on the drawings but is missing in the field. FA41B: Move Heat Activated Detector (HAD) under enclosure of Electric Fire Pump. Move or install a head above the Diesel Driven Fire Pump because of a large obstruction. FA14: Install sprinklers below suspended ceiling in Break Area and as needed to resolve obstructions caused by ductwork. Yes Yes The proposed modification will reduce risk by allowing the Fire PRA to credit fire suppression systems in the listed Fire Areas. Per the 2009 ASME PRA Standard, fire suppression systems must be code compliant if they are credited in the Fire PRA. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-15 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 10 N/A 1,2 A fire could damage DC control cables for 4 KV breakers which could blow the tripping control power fuses which would prevent the breaker from tripping on over-current. The fire could then damage the 4 KV power cable, but since the breaker can't trip, the cable would be subjected to an over-current condition up to the full fault current available to the bus. If the cable is not sized large enough to carry this amount of current, the cable could be damaged and start a fire in other fire areas where it is routed. Affected Breakers: BKR 15-1, BKR 15-4, BKR 15-5, BKR 15-8, BKR 15-9, BKR 16-1, BKR 16-3, BKR 16-5, BKR 16-6, BKR 16-7, BKR 16-10, BKR 25-7, BKR 25-8, BKR 25-9, BKR 25-10 BKR 25-13, BKR 25-1, BKR 25-17, BKR 26-1, BKR 26-5, BKR 26-9, BKR 26-10, BKR 26-11, BKR 26-17, BKR 13-4, BKR 13-5, BKR 14-3, BKR 23-1, BKR 23-6, BKR 23-7, BKR 24-5 Install an additional relay and separate fuses on the control cables from the over-current relays so that faults on the control cables will not prevent the over-current trip relay from protecting the cable. The modifications to BKR 25-1 and BKR 26-17, tracked by EC 19324, calls for fuses but does not involve installing additional relays. No Yes Not modeled in the FPRA, therefore a risk ranking is not provided.

This modification ensures there are no secondary fires. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches and operator recovery actions. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-16 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 11 Medium 1 A fire at CV-31998 could damage cables 1CA-1109, 1CA-1111 and 1CA-1248. This could cause spurious energizing of SV-33299 and maintain CV-31998, 11 TDAFWP steam supply valve closed. Damage to cable 1CA-1111 or 1CA-1248 could cause CV-31153, 11 TDAFWP recirculation lube oil cooler line to close and also damage the 11 TDAFWP. Route 1CA-1109 in dedicated conduit so that hot shorts from 1CA-1111 to 1CA-1109 cannot occur which will allow CV-31998 to open to supply steam to 11 TDAFWP. Re-wire CV-31153 to spare relay contacts in FA 32 instead of the limit switches on CV-31998 in FA 69 so it is not affected by a fire in FA 69. Yes Yes The modification will reduce risk by ensuring the 11 TDAFW Pump is protected from fires in FA 69.

Compensatory measures for the Current Fire Protection Licensing Basis are operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-17 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 12 High 1 Fire Area 29 and 69 were defined as separate fire areas in the 1977 Fire Hazards Analysis which the NRC accepted so these areas have always been treated separately. The Fire PRA Plant Boundary and Partitioning grouped FA 8, 14, 27, 29, 69, and 70 together as one Fire Compartment, 8GRP. Offsite power (1RY and CT11 source) can be affected by a fire in FA 69. The D1 Emergency Diesel Generator ventilation can be affected by a fire in FA 14. Cooling Water to D1 could be affected by a fire in FA

29. Based on grouping all of these fire areas together under one fire compartment the Fire PRA produced very conservative results for the Turbine Building because the Fire PRA fails all equipment in the compartment.

Install a rated fire barrier between FA 69 and FA 29 to ensure the following cables are not affected by a fire in FA 69:

1CA-527, 1CA-528, 1CA-529, 1CA-530, 111C-4, 111C-5, 1DCA-60 Yes No This modification will reduce risk by increasing the availability of the 12 DDCLP by physically separating Fire Areas 29 and 69. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-18 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 13 High 1 A fire in the control room or relay room could cause hot shorts on cables that could spuriously start D1 and close the cooling water supply valve. This condition results in unrecoverable damage to the credited Emergency Diesel Generator during a fire induced control room evacuation. Wire additional relay contacts off the low speed relay in series with indicating light in the control room so that once D1 > 250 RPM, the potential hot short on the indicating light in the control room is cleared. This work is being performed by plant Electrical Design Engineering under EC 18746. Yes Yes This modification will reduce risk by increasing the availability of the D1 diesel generator for fires that are postulated in the control room and relay room. Compensatory measures for the Current Fire Protection Licensing Basis are operator recovery actions.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-19 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 14 N/A 1,2 A fire in FA 13/18 could damage cables causing multiple spurious operations that could damage D1 Emergency Diesel Generator. If fire induced cable damage caused multiple spurious operations that caused D1 (034-011) to spuriously start with no cooling water (CV-31055, 11 MDCLP MTR 13-8, 12 DDCLP 145-392, 21 MDCLP MTR 23-4, 22 DDCLP 245-392) then the EDG could be damaged.

A fire that results in evacuation of the control room requires one operator (STA) to go to D1 to verify it is not running without cooling water. Another operator (U1 RO) goes to the screenhouse to locally start the 12 and 22 Diesel Driven Cooling Water Pumps (DDCLP). Both actions are considered Recovery Actions because they are not performed at the emergency control station so the risk of these actions has to be evaluated based on the guidance in NFPA 805 Frequently Asked Questions (FAQ-07-0030). Install a local/remote switch in the AFWP room at the emergency control station to eliminate the current required manual action of sending an operator to the D1 Room and Screenhouse. These actions will then become compliant (because DDCLP will be controlled at the Emergency Control Station) and will take significantly less time and would allow the operators to focus on locally restoring the TDAFWP in less time which would also significantly reduce risk.

Install new cable between TB 1750 and Emergency Control Station for 12 DDCLP.

Install new cable between TB 1751 and Emergency Control Station for 22 DDCLP. No Yes Not modeled in the FPRA, therefore a risk ranking is not provided.

This modification was not included in the Fire PRA because it was not going to provide a significant risk benefit.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-20 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 15 Medium 1,2 Fire-induced damage that could damage cables causing multiple spurious operations resulting in damage to the charging pumps. If fire induced cable damage caused spurious isolation of letdown to the VCT (CV-31226 and CV-31255) and failure to open the RWST supply (MV-32060) and failure to trip the charging pumps, the positive displacement charging pumps (MTR 111J-1) and MTR 211J-1 could be damaged due to lack of Net Positive Suction Head (NPSH). Need to prevent unrecoverable damage to credited charging pump due to fire in FA 13/18 to resolve MSO issue. Install suction pressure protection for the charging pumps if inadequate Net Positive Suction Head (NPSH) exists to prevent damage to the charging pumps. Yes Yes The proposed modification will reduce risk by installing suction pressure protection that will protect the charging pumps against fires that involve spurious valve closure and other failures that impact NPSH for the charging pumps.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-21 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 16 N/A 1 The ventilation duct between Fire Areas 32 and 37 is missing a fire damper and is not code compliant for the Fire PRA, as required by NFPA 805. There is a ventilation duct between Fire Areas 32 and 37 that is missing a fire damper. This missing fire damper is located on the supply duct and was not justifiable through a Fire Protection Engineering Evaluation. Install a fire damper in the ventilation duct between FA 32 and 37. No Yes Not modeled in the FPRA, therefore a risk ranking is not provided.

Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete. 17 High 1,2 The fire risk in FA 18 is a driving factor for the plant's overall CDF. In order to reduce the risk of a fire in FA 18, detailed fire modeling was performed to determine the time it would take for a transient or fixed ignition source fire to damage both divisions of safety related trays due to direct plume impingement or the formation of a hot gas layer. This analysis yielded trays where covering the top and bottom of the tray would support significantly reducing the risk of having to go to alternate shutdown. Provide protection for risk significant cable trays directly over the initiators of critical concern. Yes Yes The proposed modification will reduce risk by enclosing specified cable trays in FA 18. Enclosing the cable trays will allow additional time to suppress a postulated fire. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches.

Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-22 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 18 High 1,2 A fire in the FA 13/18 could fail all cooling (RCP seal injection from charging and CCW to TBHX). If all seal cooling is lost for very long, the seals could be damaged and leak excessively. Install new RCP seals that would not be subject to excessive leakage if all seal cooling is lost. Yes Yes The proposed modification will reduce risk by installing a Shutdown RCP Seal package. The Shutdown seal will have the ability to preclude larger seal leakage rates during accident scenarios. Compensatory measures for the Current Fire Protection Licensing Basis are hourly fire watches. Compensatory measures will continue to remain in effect after the NFPA 805 fire protection program becomes effective until this modification is complete. 19 N/A 1, 2 A fire could damage DC control cables for 4 KV breakers which could trip the control power fuses which would prevent the breaker from tripping on over-current on Bus 11/12/13/14/21/22/23/24. Install cables that are of sufficient size to preclude secondary fires. e.g. OCT issues were identified in FA 69, 70, 21, and 23. No No Not modeled in the FPRA, therefore a risk ranking is not provided. This modification ensures there are no secondary fires. NUREG/CR- 6850 methodology does not address secondary fires, but the issue of secondary fires was raised during the pilot plant RAI process. Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-23 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization 20 N/A 1,2 The current Fire PRA Model assumes proper coordination exists for all credited power supplies. Per Fire PRA credited power supplies lack selective coordination. Install the appropriate fuses and/or breakers to establish proper selective coordination per analysis. No No Not modeled in the FPRA, therefore a risk ranking is not provided. 21 N/A 2 A fire in the Southwest corner of FA 59 could damage Unit 2 containment pressure instrumentation cables and the control cables for 22 containment spray (CS) pump. The fire-induced damage could cause a spurious containment spray signal (1 out of two taken three times), while preventing the 22 CS Pump from being tripped, and in addition, precluding the use of the pull to lock function for the pump. This condition presents a potential to drain-down the RWST. Modification to protect cable 2CW-19 (2PT-946) from fire damage in FA 58. No No Not modeled in the FPRA, therefore a risk ranking is not provided. 22 N/A 1, 2 A fire could damage cables associated with secondary side of applicable current transformers causing a concern of secondary fires. Modification to protect secondary side of applicable current transformers. No No Not modeled in the FPRA, therefore a risk ranking is not provided.

Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-24 Table S-3, Implementation Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program. This will occur within the later of six (6) months after NRC approval, or six months after a refueling outage if one is in progress at the time of approval. Table S-3 Implementation Items Item Unit Description LAR Section / Source 1 1, 2 Implement monitoring program required by NFPA 805 Section 2.6 in accordance with NFPA 805 FAQ 10-0059, including a process that reviews the FPP performance and trends in performance. 4.6.2, Attachment A Section 3.2.3(3) 2 1, 2 Revise plant procedure 5AWI 3.13.3, "Hot Work," to address the following:

- Address the requirements for hot tapping. (NFPA 51B-1999, Section 3-5) - 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) Attachment A Section 3.3.1.3.1 3 1, 2 Revise procedure F5 Appendix J, "Fire Drills," to require that fire brigade drills be conducted in various plant areas. Attachment A, Section 3.4.3 (C)(3) 4 1,2 Perform 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 in accordance with NFPA 805 requirements. Attachment A Section 3.5.1 5 1, 2 Initiate a procedure for surveillance, testing, and maintenance. The installation of the system will disposition the existing code compliance deviation for a lack of compliant detector location. Attachment A Section 3.10.1 6 1, 2 Revise procedure F5, Firefighting, Section 7, to include a Section 7.5, Control of Spread of Contamination, to address ventilation, floor drains, opening walkways or stairs between areas, and salvage/overhaul activities. Attachment E 7 1, 2 Revise Fire Brigade Training Lesson Plan R7637L-010, Section VI, Fire Attack, to address the spread of contamination during firefighting activities. Attachment E 8 1, 2 Revise Fire Brigade Training Lesson Plan R7637L-011, Section III, Brigade Member Responsibilities, to identify the responsibilities of each brigade member relative to limiting the spread of cross contamination when fighting fires in radiologically controlled areas. Attachment E Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-25 Table S-3 Implementation Items Item Unit Description LAR Section / Source 9 1, 2 Revise Fire Brigade Training Lesson Plan R7637-035, Section IV.F, Size Up Possibilities, to provide sufficient details on the impact of fire fighting activities on the potential spread of contamination, and the methods available for mitigating such cross contamination via ventilation and drainage control. Attachment E 10 1, 2 Revise procedure F5 Appendix A, Fire Strategies, to include information on cross-contamination identified for each fire area. Attachment E 11 1, 2 Revise procedure F5, Firefighting, Section 2.7 to address potential access requirements for the Duty RP Tech or Chemist. Attachment E 12 1, 2 Revise Radiation Protection Continuing Training to address control of contamination during firefighting activities. Attachment E 13 1, 2 Revise procedure F5, Appendix A, Fire Strategies to address operations of the Auxiliary Building Ventilation or Special Ventilation systems. Attachment E 14 1, 2 Prepare new Fire Strategy or revise existing Fire Strategy for Fire Area 40, Maintenance Storage Shed / CAF - 695' elevation. Attachment E 15 1, 2 Provide a container with booms and other appropriate equipment for the containment of water in the Low Level Rad Waste Enclosure and Containment Access Facility (CAF). Attachment E 16 1, 2 Provide procedures to utilize a combination of containerization and administrative controls to ensure that exposed contaminated waste in the Low Level Rad Waste Enclosure and CAF are kept as low as reasonably achievable. Attachment E 17 1, 2 Revise Fire Hazards Analysis to align with the fire area descriptions listed in Attachment I. Attachment I 18 1, 2 Revise Operator Action for CL Strainer Backwash. Attachment B 19 1, 2 Revise procedures and checklists 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. Attachment B 20 1, 2 Update the Fire PRA Model, as necessary, after all modifications are complete and as-built. 4.8.2 Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-26 Table S-3 Implementation Items Item Unit Description LAR Section / Source 21 1, 2 Revise post-fire shutdown procedures and training as necessary to incorporate updated NSCA strategies. 4.2.1.3 and Attachment G 22 1, 2 Create new Fire Protection Design Basis Document to reflect content requirements of NFPA 805. 4.7.1 23 1, 2 Revise operating procedures, training plans, and drill procedures based on feasibility study conclusions for recovery actions. Attachment B and G 24 1, 2 Revise F5 Appendix B, Control Room Evacuation F5 Appendix B. Attachment B and G 25 1, 2 Provide a Change Evaluation Process procedure in accordance with the requirements of NFPA 805. 4.7.2 26 1, 2 Develop qualification requirements and position-specific training for personnel involved with the Fire PRA. 4.7.3 27 1, 2 Revise procedure 5AWI 3.13.0, "Fire Protection Program," to add NPO overview, definitions; road map; and risk reduction requirements for all NPO, then HRE. 4.3.2 and Attachment D 28 1, 2 Revise configuration control procedures which govern the various PINGP documents and databases that currently exist (or develop new procedures/processes) to reflect the new NFPA 805 licensing bases requirements. 4.7.2 29 1, 2 Revise system level design basis documents to reflect NFPA 805 requirements. 4.7.2 30 1,2 Revise/initiate procedures and/or procure additional compressed air bottles to support this operator action to achieve 30 hours to ensure we are "safe and stable" at 24 hours. 4.5 31 1,2 Revise Control Room abandonment procedure F5 Appendix B to identify Operator actions for hot shutddown panel switch operation/power isolation. Attachment B and G 32 1,2 Revise H24, Maintenance Rule Program, to add High Safety Significant SSCs that require monitoring based on the Fire PRA. 4.6.2 33 1, 2 Additional implementation items based on on-going reviews, e.g., H24, Maintenance Rule Program, revision per Section 4.6. 4.6 Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-27 Table S-3 Implementation Items Item Unit Description LAR Section / Source 34 1, 2 Revise Design Calculations ENG-EE-177, 194401-2.3-008, 12911.6214-E-01 and ENG-EE-013. Revision to these calculations is to support the Fire PRA credited power supply breaker fuse coordination. 4.5 35 1, 2 Revise 5AWI 15.6.0, Outage Scheduling and Outage Management procedure for inclusion of NPO requirements. 4.3.2 and Attachment D 36 1,2 Revise 5AWI 3.13.2, Fire Prevention to establish the outage roving fire watches required for NPO risk reduction. 4.3.2 and Attachment D 37 1,2 Revise 5AWI 3.13.3, Hot Work to contain controls to establish fire watches for hot work activities including all plant operating states within the NPO scope. 4.3.2 and Attachment D 38 1,2 Revise F5 Appendix K, Fire Protection Systems Functional Requirements to contain the compensatory actions to be implemented should a fire protection system required to be operable during HRE periods be found to be impaired. 4.3.2 and Attachment D 39 1,2 Revise EM 3.4.1, Review of Proposed Changes to the Fire Protection Program to contain guidance to ensure that changes to the fire protection program are reviewed for impact to the NPO requirements and risk reduction actions. 4.3.2 and Attachment D 40 1,2 Revise 5AWI 15.6.1, Shutdown Safety Assessment to contains discussion on risk due to fire, NFPA 805 and the NPO requirements as part of risk management. 4.3.2 and Attachment D 41 1 Revise D2-1, Draining the Reactor Coolant System - Unit 1, to contain a check list of the HRE risk reduction actions and requirements to implement the HRE risk reduction actions as a pre-requisite to conduct of the procedure which results in RCS reduced inventory states. 4.3.2 and Attachment D 42 2 Revise D2-2, Draining the Reactor Coolant System - Unit 2, to contain a check list of the HRE risk reduction actions and requirements to implement the HRE risk reduction actions as a pre-requisite to conduct of the procedure which results in RCS reduced inventory states. 4.3.2 and Attachment D Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-28 Table S-3 Implementation Items Item Unit Description LAR Section / Source 43 1 Revise 1D8, Filling and Venting the Reactor Coolant System to contain a decision point to check RCS level and T-Boil to determine if the HRE has been exited, then an HRE Risk Reduction Actions exit check list is provided. 4.3.2 and Attachment D 44 2 Revise 2D8, Filling and Venting the Reactor Coolant System to contain a decision point to check RCS level and T-Boil to determine if the HRE has been exited, then an HRE Risk Reduction Actions exit check list is provided. 4.3.2 and Attachment D 45 1 Revise 1C1.6, Shutdown Operations - Unit 1 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. 4.3.2 and Attachment D 46 2 Revise 2C1.6, Shutdown Operations - Unit 1 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. 4.3.2 and Attachment D 47 1 Revise 1C4.1, RCS Inventory Control Pre-refueling 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. 4.3.2 and Attachment D 48 2 Revise 2C4.1, RCS Inventory Control Pre-refueling 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. 4.3.2 and Attachment D 49 1 Revise 1C4.2 RCS Inventory Control - Post Refueling to contain contains 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. 4.3.2 and Attachment D 50 2 Revise 2C4.2 RCS Inventory Control - Post Refueling to contain contains 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. 4.3.2 and Attachment D Northern States Power - Minnesota Attachment S - Plant Modifications and Items to be Completed PINGP Page S-29 Table S-3 Implementation Items Item Unit Description LAR Section / Source 51 1, 2 Update EPM-DP-EP-004, "Post Fire Safe Shutdown Cable Identification" procedure to reflect PINGP specific (not vendor general) information and enter this procedure into the PINGP document control system. 4.3.2 and Attachment B 52 1, 2 Update to GEN-PI-052 is required to support Attachment B and transition to NFPA 805. Attachment B 53 1, 2 Update GEN-PI-055 to reflect transition to NFPA 805, including incorporation of feasibility of operating rising stem valves VC 1 and 2VC 1 in fire area 73. Attachment B and G 54 1, 2 Update the analysis in AR 01121820 to address the effects of fire on tubing for secondary circuits that could affect primary circuits. Attachment B 55 1, 2 Update CT analysis R2013-2700-01 to incorporate recent findings and close open items with respect to current transformers. Additionally, incorporate this report in the PINGP document control system. Attachment B 56 1, 2 Develop a process and create a procedure to depressurize the Reactor Coolant System and use alternate makeup sources to address long-term (>24 hours) needs to provide makeup. This capability will be independent of the system failures that result in the initial failure of RCP seal cooling. This capability may be manually and locally aligned. Attachment W 57 1, 2 Revise procedure F5, Appendix B "Control Room Abandonment" to direct the isolation of containment prior to leaving the control room. EPM Technical Report P2117-4104-01-01, Section 3.1.3 58 1, 2 Revise F 5 Appendix D as required to include fire response HFEs in the Fire PRA Model. EPM Technical Report P2117-4103-01-00, Attachment 1 59 1, 2 Revise drill procedures for operator actions. Attachment G Northern States Power - Minnesota Attachment T - Clarification of Prior NRC Approvals PINGP Page T-1 T. Clarification of Prior NRC Approvals 2 Pages Attached Northern States Power - Minnesota Attachment T - Clarification of Prior NRC Approvals PINGP Page T-2 Introduction The elements of the pre-transition fire protection program licensing basis for which specific NRC previous approval is uncertain are included in this attachment. Also included is sufficient detail to demonstrate how those elements of the pre-transition fire protection program licensing basis meet the requirements in 10 CFR 50.48(c) (RG 1.205, Revision 1, Regulatory Position 2.2.1). Prior Approval Clarification Request 1 of 1: Operator Action to Isolate Power to PORV Control Circuits Pre-transition Fire Protection Program Licensing Basis: The Prairie Island Nuclear Generating Plant (PINGP) pre-transition licensing basis relative to the preclusion of spurious operation of pressurizer power operated relief valve (PORV) flow paths, for fires involving control room evacuation, included a previously approved exemption from the requirements of Section III.G.1 of Appendix R to 10 CFR 50. Specifically, the exemption allowed operators to close the Unit 1 and 2 PORV block valves prior to evacuating the control room, and then taking the follow-on action to remove control power fuses from the PORV control circuits for both units at their respective branch circuit panels. The exemption was required because the removal of fuses involved the use of a fuse-pulling tool, which was considered to be a "repair action." This repair action was interpreted as a non-compliance to Section III.G.1 of Appendix R to 10 CFR 50 which requires, in part, that fire protection features shall be provided for structures, systems, and components important to safe shutdown so that one train of systems necessary to achieve and maintain hot shutdown conditions be free of fire damage. This exemption was approved in a letter dated February 21, 1995. In 1999, PINGP performed a plant modification (99DC03), which included modification of the PORV control power supplies such that disconnect switches could be used in lieu of pulling control power fuses. The feasibility of utilizing the disconnect switches (no tool required) has been validated and has proven to be a beneficial change with respect to this activity. Background/Basis: NSP Exemption Request Letter, dated May 2, 1994 NSP requested an exemption from the requirements of Section III.G.2 of Appendix R to 10 CFR 50, to allow the manual removal of fuses from the PORV control circuits in the event of a fire, in lieu of modifying plant hardware. The reference to III.G.2 was later revised to III.G.1 during a follow-up phone call between NSP and NRR. Issuance of Exemption Letter, dated February 21, 1995 The NRC issued an exemption from certain requirements of Appendix R to 10 CFR Part 50 to allow NSP to remove fuses from the PORV control circuits as a means of ensuring the reactor coolant system inventory in the event of a control room fire. Northern States Power - Minnesota Attachment T - Clarification of Prior NRC Approvals PINGP Page T-3 PINGP Plant Modification (99DC03) Summary: This modification relocated EQ circuit power supplies from harsh environments to mild environments. This modification repowered the Unit 1 and 2 PORV control circuits, from new distribution panels PNL 171, PNL 181, PNL 271, and PNL 281 respectively, which were, in turn, powered by upstream feeder distribution panels PNL 11, PNL 12, PNL 21, and PNL 22 respectively. An added benefit of this modification is that it allowed the PORV control circuits to be de-energized via disconnect switches in the feeder distribution panels, thus eliminating the need to pull control power fuses for fire events requiring control room evacuation. Request As part of this LAR submittal and transition to NFPA 805, it is requested that the NRC accept the following clarification of a prior NRC approval, with respect to the exemption granted to NSP on February 21, 1995: This operator action (recovery action) to preclude PORV opening remains a required action for PINGP under NFPA 805. The use of recovery actions is not allowed under the deterministic requirements of NFPA 805 Section 4.2.3.1. Clarification is requested to allow the previous exemption for operator actions to be extended to the NFPA 805 program. In addition, clarification is requested to extend the previous allowance to pull fuses to also allow the operation of disconnect switches. Although fuse removal remains an option, the manual operation to open disconnect switches, demonstrated by PINGP to be feasible and reliable, is simpler than pulling fuses and therefore, for the purposes of this request, is requested to be deemed equivalent in intent and function. Clarification is also requested that the term "control room fire", as referred to in the exemption letter, applies to fires occurring in Fire Area 013 (Control Room) and Fire Area 018 (Relay Room). Under the pre-transition (Appendix R) program, both Fire Area 013 and Fire Area 018 were analyzed as one analysis area. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-1 U. Internal Events PRA Quality 17 Pages Attached Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-2 U.1 Internal Events PRA Model The Prairie Island Nuclear Generating Plant (PINGP) base internal events PRA, Revision 3.1, was the starting point for the Fire PRA. With the exception of Internal Flooding Events, the PINGP Rev 3.1 Level 1 analysis evaluates core damage frequency (CDF) from all internal initiating events consistent with the most current combined PRA Standard, ASME/ANS RA-Sa-2009, and RG 1.200, Revision 2. The PINGP Rev 3.1 PRA evaluates large early release frequency (LERF) utilizing the Westinghouse Owner's Group Simplified Level 2 Analysis Approach, WCAP-16341.

A self-assessment of the PINGP PRA was conducted by NSPM personnel, and an independent peer review was performed of the PRA model, data, and documentation in accordance with the 2009 ASME PRA Standard Capability Category (CC) II requirements. Two Peer Reviews were performed against the internal events PRA model, data, and documentation. The first peer review includes the PINGP at-power/internal events PRA and specifically addressed eight of the nine technical elements plus the configuration control element. The first peer review did not include applicable SRs for the internal flooding hazard. A follow-on peer review was performed to specifically review the internal flooding PRA. For both peer reviews, the peer team met the independence requirement of the 2009 ASME PRA Standard.

U.2 Internal Events PRA Peer Review Results An independent peer review team evaluated the PINGP Rev 3.0 PRA, which did not include the Internal Flooding analysis. The peer team concluded that 256 (>96%) of the total 264 numbered supporting requirements (SRs) outlined within the 2009 ASME PRA Standard fully met the Capability Category II or greater, not including the Internal Flooding SRs. Two of the internal events SRs (AS-B4 and QU-B10) were determined to not be applicable to the PINGP PRA and are not discussed any further. Six of the applicable SRs were rated as CC I, or as "Not Met." LE-C3 and HR-D2 met CC I falling below the CC II threshold while LE-G5, IE-C10, IE-C14, and QU-C2 did not meet the Capability Category requirement criteria. NSPM resolved the 6 SRs that were rated as CC I or as "Not Met," to meet a CC II per the independent peer review team suggestions. Table U-1 contains the 6 SRs that were rated as CC I or as "Not Met," the peer review assessment description, and means by which NSPM resolved these findings.

The independent peer review team identified 65 Facts and Observations which comprised of 22 findings, 41 suggestions, and 2 best practices. Table U-1 describes the 22 findings including the peer review team's assessment comments and the PINGP resolutions. The Findings/Observations in Table U-1 are provided from the final PRA peer review report with minor editorial corrections. The internal events peer review report is documented in LTR-RAM-II-11-005, RG 1.200 PRA Peer Review Against the ASME PRA Standard Requirements for the Prairie Island Nuclear Generating Plant Units 1 and 2 Probabilistic Risk Assessment, Final Deliverable, March 2, 2011, and is available upon request.

Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-3 U.3 Internal Flooding Peer Review Results An independent peer reviewer evaluated the PINGP Rev 3.1 PRA model that was updated in a sensitivity analysis to include the results of the Internal Flooding analysis. The peer review was performed in September 2012 and concluded that 61 (98%) of the total 62 numbered supporting requirements (SRs) outlined within the 2009 ASME PRA Standard for At-Power Internal Flooding met Capability Category II or greater. All SRs were rated as CC II or above with the exception of IFQU-A6, which did not meet the Capability Category required criteria.

The independent peer review identified 8 Facts and Observations which are comprised of 5 findings, 2 suggestions, and 1 best practice. Table U-2 lists the 5 findings, including the peer review assessment comments. Due to the timing of this peer review, the Facts and Observations in Table U-2 are still considered Draft and NSPM has not yet provided a disposition. NSPM will provide a supplement to this LAR to identify final information from this Internal Flooding PRA peer review and to provide a disposition for these Facts and Observations. The Flooding Analysis peer review report is available upon request. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-4 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition AS-B3 Accident Sequence - Containment Sump Blockage Closed Sections 5.x-6 discuss the adverse environmental condition in terms of increasing containment temperature and pressure. However, there is no discussion of potential plugging of the sump screen by the debris generated in a LOCA (e.g., a large LOCA).

Basis for Significance: No discussion of potential plugging of the sump screen by the debris generated in a LOCA (e.g., a large LOCA). Reviewed WCAP-16882-NP, Rev. 1. This document provides a methodology and example application for determining representative screen plugging frequencies based on the initiating event (Non-LOCAs, LOCAs, and Steam line breaks inside and outside containment) that lead to the need for sump recirculation. Incorporated this into the PRA model. The Residual Heat Removal System Notebook was updated to document the re-modeling of the sump strainer plugging logic by initiating event. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. DA-C9 Data Analysis - Run-time Estimation Closed PRA-PI-DA, Sections 4.5.5. PINGP used estimates for test run time for some data taken from Operator logs or other plant data as ©-25% of the full test duration©. Discussed with PINGP and this is related to lack of good data from around pre-2003 records when improved data recording was done. This should be discussed in the notebook.

Basis for Significance: Some run time data is estimated but no clear explanation of why this was necessary or the basis for using 25% was in the notebook. The Data Analysis notebook was updated to clarify how component run-time was estimated using Operator Logs. The documentation update did not result in a change to the assumption or any Data that was collected. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-5 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition DA-D2 Data Analysis - Expert Judgment Closed PRA-PI-DA, Sections 3.5 (Data based on Expert Judgment) states ©There were no instances in which expert judgment was used to estimate a failure mode because either plant specific or generic failure data were available. A basis for all probabilities that did not have generic data is documented in Table 7.1 and through its associated references.© Table 7.1 (Special Event Probabilities) contains some instances of use of expert judgment where the basis is not clear. For example 1VVAxxx and 2VVAxxx values in Table 7.1 are identified as "Based on conversation with system engineering this value is conservative, however, updated basis is needed."

Also, the basis for Data Analysis Notebook (PRA-PI-DA) Section 1.6, Assumption 1, ©conservatively assumed that a component would not be run for more than 25% of the full test duration if the exact time were not listed© is not clear. Basis for Significance: Table 7.1 (Special Event Probabilities) contains instances of use of expert judgment where basis is not clear. Need to at least document the rationale behind the choice of parameter values in these cases. Also, basis for DA Notebook, Section 1.6, Assumption 1 is not clear. The Peer Review Finding was issued because the data notebook was unclear how Expert Judgment was utilized in the Data Analysis. There were two specific issues that were identified: The first issue deals with Special Events in the Data Analysis notebook (Table 7.1) because two events were identified as using expert judgment, but sufficient basis for the use of expert judgment was not provided and it contradicted with a statement in another section of the Data Analysis notebook.

The second issue that was identified by the Peer Review team was an inadequate basis for assumption 1.6(1). Since this issue was documented as a separate Peer Review Finding (SR DA-C9), it will be discussed further below.

The Data Analysis was reviewed for instances where expert judgment was used. Additional justification was provided for the two events identified by the Peer Review Team as well as another event that were identified as not having sufficient supporting information. In the cases where the value changed as a result of providing updated justification, the PRA model was also updated. The updated values had no significant affect on the final result. Also, the Data Analysis Notebook was updated to more clearly discuss the use of expert judgment. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-6 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition starting point for the Fire PRA. DA-D3 Data Analysis - Error Factors Closed PRA-PI-DA. All basic events for failure modes, CCF and unavailability have mean, distribution and uncertainty values assigned. The significant basic events had Bayes updated uncertainty values. Section 6.1.2 has CCF uncertainty. Unavailability assumes an Error Factor (EF) of 3 but no basis is provided. Basis for Significance: Unavailability assumes EF of 3 but no basis is provided. The Data Analysis notebook was updated to provide justification for using an EF of 3 using maintenance data provided in NUREG/CR-6928. The model was also reviewed and updated to ensure all maintenance events were using the correct EF.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. DA-D4 Data Analysis - Reasonableness Check Closed PRA-PI-DA, Sections 4.7 documents the reasonableness check. Did not find documentation of the identified inconsistencies and their disposition. Basis for Significance: Identification and disposition of inconsistencies were not documented. The Data Notebook provides a narrative that describes the methodology and the results of the consistency check. To clarify the Data Analysis notebook, the ASME Standard Roadmap was updated to point the reader to the appropriate sections of the notebook that discuss the methodology and results of the reasonableness checks. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-7 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition DA-D8 Data Analysis - Modifications Closed Section 4.5.3 (Identify Equipment Failures) contains the statement ©For instances were a modification or change to an operation practice made past data no longer representative of current performance, the use of such data was evaluated to determine if it was appropriate to use in the data analysis. If the data was not consistent with current plant design and operating practices, the use of the data was limited or not used.© The replacement of steam generators for Unit 1 is an example where PRA model data was updated. Sump screen replacements are also reflected in revised model data. The SR roadmap for this SR needs work. Basis for Significance: The SR roadmap points to Section 5.1 of the notebook (Maintenance Data), which is not relevant to this subject. The SR roadmap comment for this SR was "There were no modifications identified that would have affected the data analysis during the specified time interval for Risk Significant components or maintenance unavailability." Were there no plant modifications for the data analysis time period 1/1/2002 to 12/31/2007 such as sump screens? Were there no significant procedure changes, such as "water management" for the sump screen issue? The Data Analysis notebook accounts for the modifications that occurred within the analysis timeframe. For the data collection period that was used in the current notebook, there were no additional modifications identified that affected the data analysis, with the exception of the sump strainer modification, which was accounted for in the PRA.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA.

Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-8 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition DA-E3 Data Analysis - References Closed No section related to this point. Must be added to only reference Uncert notebook. Basis for Significance: The sources of model uncertainty and related assumptions are not documented in this notebook. Updated the Data Notebook to reference the Uncertainty Analysis notebook.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. HR-D2 Human Reliability Analysis - Pre-Initiator Human Error Probabilities Closed Detailed assessments were used to quantify most of the pre-initiator HEPs. However, a screening value (that is relatively small) was used for risk significant HFEs - for example, 1EOPMDAFWRZ in Table 4-1 of PRA-PI-HR.

Does not meet CC II because detailed assessments were used to quantify many but not all of the risk significant pre-initiator HEPs. For example a screening value (that is relatively small) was used for risk significant HFEs - 1EOPMDAFWRZ in Table 4-1 of PRA-PI-HR. Basis for Significance: Screening values (although relatively small) were used for risk significant HFEs - for example, 1EOPMDAFWRZ in Table 4-1 of PRA-PI-HR.

All risk-significant pre-initiator operator actions were updated with detailed Human Error Probabilities (HEPs) assessments. HRA Notebook and Database were updated accordingly.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-9 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition HR-G1 Human Reliability Analysis - References Closed The Human Reliability Analysis Notebook Table 5-3 lists the RAW and FV values for all the post-initiator HFE basic events. Basic Events (BEs) with RAW > 2 or FV > 0.005 are listed as risk significant. Table 5-1 lists the method used to analyze the HFEs. The only risk significant HFEs that use screening values use a value of 1.0. All other risk significant HFEs use a detailed method. Basis for Significance: No reference to which model was used to calculate the importance measures for the post-initiator HFEs. Provided reference for the current PRA Model revision used to calculate the importance measures for post-initiator Human Failure Events (HFEs) in the Human Reliability Analysis (HRA) Notebook. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. IE-C10

Initiating Events - Mission Time Closed SR Not Met. PRA-PI-IE-INITS Initiating Events Notebook, Section 4.4.8. Some events in I-LOCL tree have 32 hour mission time (see event 0SPCHZXSCCR). Also 0SE121RFESR events used 32 hours. Why not use 24 hours? Need to confirm fault trees. Basis for Significance: Initiator should use MTTR for standby failures and other system initiator fault trees used 24 hours. The Support System Initiating Event fault trees were reviewed and the mean time to repair mission time for the standby failures was updated to 24 hours. The Data Analysis Notebook was updated to reflect a mission time of 24 hours for standby components. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA.

Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-10 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition IE-C14 Initiating Events - Interfacing System Loss of Coolant Accident Mission Time Closed SR Not Met. RA-PI-IE-INITS Model Initiating Events Notebook, Section 4.3.7, Appendix 5. ISLOCA fault trees are quantified in the single top model CDF and LERF. Section A5.3, 2. Mission time for MOVs and check valves states, ©both valves are assumed to have a mission time for valve rupture of 8760 hours©. This results in cutsets for ISLOCA that have more than one event with a mission time of 8760 hours which is not correct. Only one event should have the 8760 mission time.

Basis for Significance: The ISLOCA cutsets have multiple events with longer than the annual frequency. The Initiating Events notebook was updated to document the justification for using 8760 hours for in-series valve failures for the ISLOCA modeling. Since there is a potential for the valve nearest the Reactor Coolant System (RCS) to leak prior to rupture, thereby exposing the inner valve to the RCS pressure for much of the operating cycle, an 8760 hour mission time was conservatively applied to each valve in-series. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. LE-C3 Large Early Release Frequency - Significant Accident Sequence Progressions Closed Did not observe a review of significant accident progressions documented in the LERF Notebook (PRAPI- LE, Rev. 0) to determine if repair can be credited. The LERF Notebook Section 4.9.2 (SBO Sequences) includes a statement that "Because there are no PI procedures for recovering power after the batteries are depleted, the assumption is made that power cannot be recovered and that all sequences will progress to vessel breach." This SR is assessed as met at CC I. Basis for Significance: Did not observe a review of significant accident progressions documented in the LERF Notebook (PRA-PI-LE, Rev. 0) to determine if repair can be credited. A section was added to the LERF Notebook to document the review of significant accident progressions that lead to a Large Early Release to determine if repair of equipment could be credited. The review looked at accident progressions such as Interfacing Systems Loss of Coolant Accidnet (ISLOCA), Medium LOCA, Station Blackout (SBO), and Steam Generator Tube Rupture (SGTR). Discussion of the recovery potential of each scenario, and the basis for not considering in the LERF, was added to the LERF notebook. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-11 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition LE-F1 Large Early Release Frequency - Dominant Contributors Closed Relative contribution to LERF from plant damage states and initiating events were provided. LERF contributor listing from Table 2-2.8-9 is not complete. Basis for Significance: LERF contributor listing from Table 2-2.8-9 is not complete. The LERF notebook analyzed the list of LERF Contributors from WCAP-16341 because it provided a broader band of evaluated LERF Contributors than the ASME Standard. Per the review of the list provided in the WCAP, all of the LERF contributors listed in the ASME Standard are accounted for and the intent of the ASME Standard is met.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. LE-G5 Large Early Release Frequency - Limitations Closed SR Not Met. No description and discussion of LERF model limitations. Basis for Significance: No description of limitations of the model and their implications for Risk-Informed applications. The LERF Notebook was modified to include a technical discussion on the limitations of only considering the large early containment release scenarios needed for LERF quantification. Also included is a discussion of the fact that, since longer term containment releases are not modeled in the PINGP PRA, systems that play a role in controlling and mitigating long-term containment releases (Containment Spray (CS) and Containment Fan Coil Units (CFCUs)) are not modeled. An Appendix was added to the LERF Notebook to document sensitivity studies performed to demonstrate that modeling successful operation or failure of CFCUs and CS will not result in reducing the release magnitude below LERF categorization or cause non-LERF sequences to become LERF due to increased pressure from hydrogen burns from CS or CFCUs de-inerting the post accident containment steam environment. The specific issue identified in the Peer Review Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-12 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. MU-F1 Maintenance and Update - Procedure Implementation Closed It appears that some of the FP-PE-PRA procedures that are in "Draft" form are already being implemented. Basis for Significance: Some of the FP-PE-PRA procedures are in "Draft" form. This Peer Review Finding was written since some of the Peer Reviewed procedures were not officially approved at the time of the Peer Review. All the PRA procedures have been approved and are being used by the PRA Program staff. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA.

QU-A3 Quantification - Interfacing System Loss of Coolant Accident Closed PRA-PI-QU, Sections 4.1 and 4.2.6. The UNCERT code was used to determine the distribution of the CDF and LERF. The PRA-PI-INITS notebook, section A5.3 discusses how the state of knowledge correlation was evaluated and adjustments made for some ISLOCA events for valves. However, PINGP self identified that these corrected values are not included in the overall CDF/LERF frequency and should have been. However, there should be a reference in QU to the INITS section. Error identified in section 4.2.6 for Unit 1 CDF of 1.46E-5 vs. Figure 4.2-9 value needs to be corrected.

Basis for Significance: There is no reference to the INITS notebook and PINGP identified that the Revised ISLOCA correlated valve failure probability calculation in the Initiating Event Notebook to recognize the updated check valve and motor operated valve catastrophic rupture (large internal leakage) failure probabilities in the Data Notebook. The quantification results were updated to reflect the incorporation of this model change. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-13 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition ISLOCA basic events did not use the adjusted values in the final model. The value of the unit 1 CDF from UNCERT does not agree with that shown in the figure. QU-C2 Quantification - Human Failure Event Dependency Analysis Closed SR Not Met. PRA-PI-QU, Section 4.3.4 discusses the process used to adjust multiple HFEs using HRA calculator, EXCEL spreadsheets and utility programs. PRA-PI-HRA, section 3.4.2 and Attachment E address the dependent HFE analysis and resultant values which were used in the final quantification. This should be referenced in the QU notebook. These are included in Appendix F in the HEPCombos.txt file. There is no listing provided of the [item] and no discussion of the details of the adjustments made to the dependent HFEs to justify that the combination HFEs in any cases have extremely low values well below 1E-05. These low values and their impact on CDF/LERF should be justified and evaluated.

Basis for Significance: The combination HFEs in many cases have extremely low values well below 1E-05. These low values should be justified and their impact on CDF/LERF evaluated. This issue was resolved by specifying a minimum value for individual HEPs and to joint dependent HEPs in the dependency analysis. The details of how these adjustments were made were documented in the Quantification Notebook. The information was also included in the HRA Notebook.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-14 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition QU-D4 Quantification - Plant Comparison Open Section 4.3.6 gives comparison of PINGP PRA results to Point Beach, Ginna, and Kewaunee plants. The causes for significant differences are only assumed but no evidences are given. Causes for differences are not identified.

Basis for Significance: The causes for significant differences are only assumed but no evidences are given. Causes for differences are not identified. The Quantification notebook discusses the differences between Prairie Island Nuclear Generating Plant (PINGP) and other similar 2-LOOP Westinghouse designs. The Initiating Event contributions for each plant were compared and the differences are discussed by postulating how the PINGP design differs. As noted in the Peer Review finding, it is suggested that a detailed review of sister plants design features and/or modeling techniques be performed. This level of a detailed comparison has not been completed. This F&O has not been closed out.

It is not expected that updating the documentation associated with the comparison of similar plants will result in any changes to the PRA model or its supporting analyses. This Finding will not have an effect on the Fire PRA or its supporting analysis. SY-A4 Systems Analysis - Walkdowns and Interviews Closed Plant walkdowns and interviews have been done (see System Walkdowns and Interviews notebook). Some issues seem not to have been addressed.

Basis for Significance: Some issues were found during the plant walkdowns and interviews but were not addressed in this revision. So the PRA model could be considered as non coherent with the as-build as-operated plant. However these issues are managed and become parts of the PRA maintenance and update process. Each comment from the system engineering interviews and plant walkdowns was reviewed to determine whether or not the issue had been resolved. Every item that was identified as not being completed was entered into the PRA Change Database (PCD) to determine its impact on the PRA. Depending on the issue's significance, it was either completed immediately or was deferred to a future PRA model update. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-15 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition SY-A8 Systems Analysis - Component Boundaries Open The pressure switch failure for the Component Cooling pump noted in Component Cooling notebook assumption 28 for miscalibration of pressure sensors should not be included in the boundary of the Component Cooling pump.

Basis for Significance: The pressure switch failure is separately modeled in CC and miscalibration is not. The specific model changes have been incorporated into the PRA, but the Finding has not been closed out due to an extent of condition evaluation that was performed to review modeled Instrument and Control (I&C) component failure events relative to the component boundaries of the modeled equipment that they support. Similar to the Component Cooling pressure switch, other inconsistencies related to I&C components were identified. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Although the extent of condition reviewed similar inconsistencies, the current model is considered conservative and adequate for the risk-informed NFPA-805 application. SY-A17 Systems Analysis - References Closed PRA-PI-SY-CL Section 4.0 which discusses specific operator actions and applicable plant procedures. Cannot find reference to PRA-PI-HR notebook in Section 4.0 of the CL notebook. Do not find a reference in Section 4.0 of the CT notebook either.

Basis for Significance: The system model should include HFEs that are expected during the operation of the system. No reference to PRA-PI-HR notebook in CL and CT notebooks. The Cooling Water (CL) and External Circulating Water (CT) System Notebooks have been updated to include a reference to HRA Notebook. The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-16 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition SY-B14 Systems Analysis - Containment Cooling Closed Section 6.13 of the Success Criteria Notebook (CONTAINMENT) states: "Containment cooling is not required for any of the Level 1 accident sequences. In addition, for LERF modeling no containment cooling is required (see the LE notebook, Reference 21). Therefore, the PINGP Level 1 and LERF models do not include containment spray (CS) or [containment] fan cooler units (CFCUs)." Observed one MAAP LLOCA scenario (LLOCA-CONT) that did not credit CS or CFCUs (SC Notebook Table 6.4) but did not find documentation of the results for this case in Appendix B of the SC Notebook or elsewhere. Need documented basis for not crediting containment spray and CFCUs in the PINGP PRA model to ensure no impact on CDF and LERF results. Basis for Significance: Not crediting CS and CFCUs in the PRA may ignore their impact for some scenarios (e.g., NPSH for large LOCA recirculation mode RHR). The following was completed to address this Peer review Finding from both a Level 1 Plus LERF perspective.

(1) A sensitivity calculation was developed to evaluate the affects of Containment Fan Coil Units and Containment spray. This Thermal Hydraulic calculation confirmed that for LLOCA and MSLB scenarios the operation of the Containment Fan Cooler Units (CFCUs) or Containment Sprays (CS) will result in lower peak pressures. This calculation also confirmed that for the LLOCA and MSLB scenarios with failure of CFCUs and CS, the calculated peak containment pressures will remain below the best estimated containment failure pressure. Therefore, it was concluded that there is no need to model CFCUs or CS operation or failure in the Level 1 PRA accident sequences.   

(2) The Success Criteria Notebook was amended to describe the results of the sensitivity studies performed in the calculation described above.

(3) An additional sensitivity calculation was performed to evaluate the effects of the Containment Fan Coil Units and Containment Spray on LERF analysis. This calculation confirmed that for all plant damage states previously evaluated operation/failure of the Containment Fan Cooler Units (CFCUs) or Containment Sprays (CS) would not alter the classification of LERF vs. non-LERF sequences. Therefore, it was concluded that there is no need to model CFCUs or CS operation or failure in the Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-17 Table U-1 Internal Events PRA Peer Review - Facts and Observations SR Topic Status Finding/Observation Disposition Level 1 Plus LERF PRA accident sequences. (4) The LERF Notebook was amended to describe the results of the sensitivity studies performed in additional sensitivity study described above.

The specific issue identified in the Peer Review Finding was corrected when finalizing the Revision 3.1 PRA Model, which was used as a starting point for the Fire PRA. Northern States Power - Minnesota Attachment U - Internal Events PRA Quality PINGP Page U-18 Table U-2 Internal Events PRA Peer Review - DRAFT Facts and Observations SR Topic Status Finding/Observation Disposition IFPP- B3-01 Identification of assumptions Open A parametric uncertainty analysis was performed on the final results. An evaluation of generic sources of model uncertainty from NUREG-1855 was documented. Although some of the plant specific sources of modeling uncertainty are documented in Table 18, not all key assumptions contained in the analysis documents are listed and evaluated for their potential effect on applications. To be provided in a supplement to the LAR. IFPP-A2-01 Credit for sealed penetrations Open In defining the flood areas, assumption 6 of the accident sequence notebook states: "Sealed penetrations are assumed to be effective at preventing propagation between areas such that the propagation would result in equipment failure in the adjoining area." On page 169, the table states that for zone 419 the sealed penetration fails. This is in conflict with assumption 6. To be provided in a supplement to the LAR. IFSN-A10-01 Credit for floor drains Open The assumption states that no credit was taken for drains. However, the accident analyses and initiating event definitions discriminate based on flooding flow rates and area drain flows. As a result, there is a conflict between the documented analyses and Assumption 2 of the flood area definition notebook and the accident sequence analysis. To be provided in a supplement to the LAR. IFSO A1-01 Explanation of potential flooding source Open The heating steam pipe is not considered a flooding source but there is no explanation for this. To be provided in a supplement to the LAR. IFQU-A6-01 Application of internal events HFE's Open There is no evidence that all the applicable HFE©s from the internal events model were reviewed to see how they were affected by flood scenarios. To be provided in a supplement to the LAR. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-1 V. Fire PRA Quality 52 Pages Attached Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-2 Northern State Power-Minnesota (NSPM) has determined that the Prairie Island Nuclear Generating Plant (PINGP) Fire PRA is adequate to support the NFPA 805 Licensing Basis. A Peer Review of the PINGP Fire PRA against the requirements of Section 4 of ASME/ANS Standard RA-Sa-2009 was conducted the week of May 7 through May 11, 2012. Based on this peer review, the PINGP Fire PRA was found to be essentially consistent with the ASME/ANS PRA Standard.

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). The remaining SRs were evaluated against the ASME/ANS PRA Standard and were assessed as meeting Capability Category (CC) I, II, III, or "Not Met." Meeting the ASME/ANS-RA-Sa-2009 standard at Capability Category II represents a degree of accuracy such that the PRA may be used for most regulatory submittals. Capability Category III represents a high degree of accuracy that is also acceptable for regulatory submittals. Meeting a requirement of the standard at Capability Category I represents a lower degree of accuracy. 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." 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. The Best Practice F&O was issued for the Seismic Fire Interaction Technical Element. 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 Status column in Table V-1 indicates whether Findings are open or closed. Findings are considered Open until associated documentation updates have been completed and accepted into the NSPM process. The Findings that remain open have been determined to be acceptable for this LAR. In all cases, an explanation is provided in the "Disposition" column. The "Issues" in Table V-1 are presented directly from the Peer Review report, with minor editorial corrections.

The PINGP Fire PRA was determined by the Peer Review Team to meet Capability Category II in most but not all cases. A limited number of ASME/ANS Standard areas were identified as either not meeting a Supporting Requirement or only meeting Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-3 Capability Category I requirements. These are listed in Table V-2 with the planned disposition. The impact of those areas where a requirement was judged to be "Not Met" or where only the Capability Category I requirement was met is evaluated in Table V-2.

The full PINGP Fire PRA Peer Review Report will be made available to the NRC staff upon request.

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-4 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition PP-C3-01 Other Affected SR PP-C1 Agreement between the Plant Walkdown Notes and the Plant Partitioning Notebook Appendix Open DOCUMENT the general nature and key or unique features of the partitioning elements that define each physical analysis unit defined in plant partitioning in a manner that facilitates Fire PRA applications, upgrades, and peer review. The information in the Appendix A, PINGP Compartment Table, Basis for fire area separation, does not always agree with the information contained in the walkdown sheets. An example is on walkdown sheet 4GRP which states "unsealed cable tray penetration between FC39 and 4GRP. Likely to spread fire due to continuity of combustibles". The PINGP Compartment table states, "Unsealed cable tray penetration FC 39. Unsealed piping penetration to FC 39 and 85. These penetrations aside, the barriers are still sufficient to contain a fire." These two descriptions need to agree and provide reasons for the plant partitioning. Appendix A and the walkdown sheets need to be reviewed. These two documents need to be revised so they agree. The term "active fire door" needs to be revised to a door activated by a fusible link. A fusible link is considered to be a passive device and not an active device. It is acceptable to use the active definition for these fire barriers, but if that does occur, then PP-B5 changes from "N/A" to "CC-I". To go from "CC-I" to "CC-II" PINGP needed to "define and justify" the criteria applied for crediting the active fire barriers in the partitioning report. This finding discusses a discrepancy between the original walkdown notes and the final fire area separation table that are documented in the Plant Boundary and Partitioning notebook. The peer finding identifies that the separation between two of the identified Fire Compartments (FC) was not consistent. Per the review of the Plant Boundary and Partitioning notebook, it was identified that the justification for separating the compartments is valid for the purposes of the Single Compartment analysis. It should be noted that the multi-compartment analysis evaluated the risk associated with the interaction between FC 4GRP and FC 39 and 4GRP and FC 85. As such, this finding requires that the documentation associated with the Plant Boundary Partitioning notebook to be updated to ensure there is a clear link as to why the original plant walkdown notes do not match the credited separation criteria. This documentation upgrade will not affect the results of the Fire PRA. With regards to the "active fire door", Fire doors held open with a fusible link are defined as "active" barriers in the CCII requirement for PP-B5 in the Standard. Additional justification for crediting these active partitioning elements will need to be added to the PP notebook where necessary. This documentation upgrade will not affect the results of the Fire PRA. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-5 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition This finding is considered open until the Fire PRA notebooks are updated to completely address this issue. ES-C1-01 Other Affected SR CS-A1 Add instruments required for new HFEs to the ES Notebook Open HFEs created specifically for Fire Scenarios (identified in FPRA-PI-FHRA) and their credited instrumentation have not been included in the Equipment Selection documentation. Related to this, not all instrumentation for those HFEs are cable selected. Standard requires that all HFEs and associated instrumentation required for FPRA are identified in the Equipment Selection task (and it is noted that Equipment Selection is an iterative process). Also, associated instrumentation requires cable selection if cable routing is not available. Include all HFEs in the Equipment Selection documentation. Cable selection will be required on instrumentation if not already available. It has been noted that there is a revision plan in place to address instrumentation currently not cable selected in the HRA. This Finding deals with Human Failure Events (HFEs) that are credited in the Fire PRA. Additional cable selection and routing was performed, but not all the information was incorporated into the Fire PRA. The HFEs that did not have credited instrumentation failures accounted for in the final Fire PRA were reviewed for their potential impact on the Fire Risk Evaluations (FREs). The review showed the results of the FREs would remain unaffected such that the acceptance criteria remained valid. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. CS-A10-01 Cable routing through compartments Open Open item No. 1 on Page 17 of 17 of FPRA-PI-CS, Revision C, states that "in order to fully comply with Capability Category II, cables that are routed through fire compartments 2A, 41B-1, 46A, 58A, 58B, 58C, 58D, 76A, 78E, 86, 94A, 94B, 94C, 94D, 94E, and 94F need to be identified. This will be accomplished by identifying This issue involves the lack of specific routing information for cables through fire compartments (physical analysis units or PAUs) versus Fire Areas. As a result, damage to cables for additional equipment is assumed to occur beyond what is actually located in the compartment, making the risk results for these compartments conservative. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-6 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition routing on electrical drawings, and with walkdowns performed as needed." Since this has not yet been completed, and the methodology not specified, this SR is provisionally met. Completeness of Fire PRA. Route cables through the listed fire compartments, and perform walkdowns to confirm accuracy of the routing. Utilize EPM Division Procedure EPM-DP-EP-005, Revision 1-Post-Fire Safe Shutdown Cable Routing and Component Location, and EPM Division Procedure EPM-DP-EP-004, Revision 2-Post Fire Safe Shutdown Cable Identification-February 2011. Although this is a conservative approach, the results of the Fire PRA have shown to be acceptable. For example, Fire Risk Evaluations for Fire Areas 2, 41B and 58 show delta risk results that are also conservatively higher, but meet established acceptance criteria. Since the results for these FREs meet the criteria established this level of conservatism is acceptable. This finding is considered open until the Fire PRA notebooks are updated to completely address this issue. CS-B1-01 Other Affected SR CS-C4 Breaker coordination study Open As identified in FPRA-PI-CS, Appendix R overcurrent coordination and protection analysis has been reviewed but the analysis of additional circuits identified during the Fire PRA is currently in progress and is therefore not complete. Appendix R Breaker Coordination study has been reviewed. Additional breaker coordination is still being performed. Finish breaker coordination study. This issue involves completing the coordination studies that were on-going at the time of the peer review. A final coordination study has not been completed for the power supplies credited within the Fire PRA Model. Subsequent modifications will be performed to resolve outstanding coordination issues that are relevant to the Fire PRA. The Fire PRA assumes that there are not any coordination issues with the power supplies that are credited in the Fire PRA model. Resolution of coordination issues is captured in Attachment S of the LAR. This finding is considered open until the Fire PRA notebooks and analysis are updated to Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-7 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition completely address this issue. PRM-A1-01 Screening of ignition sources Open This SR states "CONSTRUCT the Fire PRA plant response model so that it is capable of determining fire-initiated conditional core damage probabilities (CCDPs) and conditional large early release probabilities (CLERPs) for various fire scenarios." The Fire PRA model is developed so that it is capable of determining fire-initiated CCDPs and LERPs for most ignition sources/scenarios. However, a large number of ignition sources have been "screened" in the Fire Compartment Analysis based on the fact that a fire associated with them only has the potential to impact the equipment that is the ignition source. A basic event showing the ignition source was screened as "ANDed" with the ignition source in the Fire PRA model. This does not appear to be correct modeling for ALL components that were screened since it does not include consideration of whether or not the equipment failure will result in a reactor trip. Verify, and where applicable state, that the "screened" ignition sources do not result in a reactor trip, and that it is accurate to eliminate them as initiators. For those "screened" sources that can result in a reactor trip, they need to be retained as initiators with their target sets including the equipment itself only. This finding involves fire scenarios that damage only the component from which the fire originates and does not consider if the screened component will result in a reactor trip. In these cases, loss of the component and any resulting plant transient (including a reactor trip) is encompassed by the internal events PRA. Screening these fire scenarios from the Fire PRA is appropriate. This documentation upgrade will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address this issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-8 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition PRM-A1-02 Loss of instrument air piping integrity Open This SR states "CONSTRUCT the Fire PRA plant response model so that it is capable of determining fire-initiated conditional core damage probabilities (CCDPs) and conditional large early release probabilities (CLERPs) for various fire scenarios." PINGP uses soldered connections in their instrument air system. They acknowledge that fires can result in failure of the soldered connections. However, PINGP contends that failure of a soldered connection will not lead to failure of the instrument air system because they assume that the second air compressor would make up for the lost air. However, this assumption appears to overlook the condition where the failed solder joint will lead to separation of the line. Any or all equipment downstream of the failed solder joint will lose air and go to their loss-of-air position. Furthermore, with an open line, the air flow would be preferentially directed to the line break. Depending on the break size, this bypass flow may be sufficient to lead to a significant drop in system pressure. This could lead to all air-operated components working off the system going to their loss-of-air position. PINGP needs to re-evaluate the impact of a fire-induced loss of instrument air considering the two scenarios above. For the second scenario, a calculation demonstrating that the two compressors are capable of maintaining adequate system air pressure even given severing of the largest A PRA calculation was completed to evaluate the impact of fires on the Instrument Air (IA) header. Plant walkdowns were performed to review components with an IA dependency in the Fire PRA and if either a fixed or transient initiator could affect soldered joints. Per the results of the calculation, only transient initiators were found to affect soldered joints on the IA header. Of the three (3) identified areas where fire could affect the IA header, the most limiting case was evaluated to determine the air flow from the IA system. The resultant system air flow was found to be within the capacity of the IA system (i.e. standby air compressor). Per the review of the fire PRA, additional analysis is needed to ensure the model accounts for the failure of components downstream of the soldered joints that could be affected by a fire. Because of the limited number of points where the IA could be affected by a transient fire, the resultant changes to the Fire PRA are expected to be minimal. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-9 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition line with soldered connections. PRM-A1-03 Other Affected SRs FQ-D1, FQ-E1 Containment bypass due to multiple spurious operation of isolation valves in small lines Open This SR states "CONSTRUCT the Fire PRA plant response model so that it is capable of determining fire-initiated conditional core damage probabilities (CCDPs) and conditional large early release probabilities (CLERPs) for various fire scenarios." When the Containment bypass lines were evaluated for potential inclusion of additional MSOs due to fires, one of the criteria that appears to have been used to screen lines was the size of the line. If the line was not >1 inch (water) or >2 inch (steam), it appears to have been screened out. Although this may be appropriate for internal events, it is not appropriate for fire events since a fire can cause multiple failures that result in multiple smaller lines being impacted simultaneously such that the LERF criteria is met. Re-evaluate the potential Containment Bypass lines and ensure that no lines are screened using the size criteria, or provide a justification for why the 1 inch (water) and 2 inch (steam) screening criteria is appropriate for fire-analyses. This finding suggests that multiple small flow diversions through lines that would otherwise have been screened out should be considered as a potential path for containment bypass. The probability of multiple small flow diversions being created simultaneously by spurious operations is very small. SR ES-A6 states for Capability Category II: "CONSIDER up to three spurious actuations of equipment alone or in combination with other fire-induced loss of function failures for the special case where fire-induced failures could contribute to an initiating event that in turn leads to core damage and a large early release." Note 8 for this SR states: "Fire-induced failures leading to interfacing system loss-of-coolant accident (ISLOCA) or containment bypass are examples of cases where fire-induced failures could contribute to an initiating event that in turn leads to core damage and large early release." To ensure this criterion was met, a search was performed for cases where up to three spurious operations within small lines that have been screened could lead to containment bypass events. No such spurious operation combinations were identified. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-10 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address the issue. PRM-A2-01 Other Affected SRs PRM-A3, FQ-A4 Fire scenario analysis inputs Open This SR states: CONSTRUCT the Fire PRA plant response model so that it is capable of determining fire-initiated core damage frequencies (CDFs) and fire-initiated large early release frequencies (LERFs) once the fire frequencies (see Section 4.2.7) are also applied to the quantification. Although the scenario specific ignition sources, non-suppression probabilities, and severity factors are included directly in the Fire PRA model on a scenario specific basis, the basic events and probabilities included in the model do not appear to match what is stated in the notebooks.

• For example, looking at FC 32, the notebook states that the Non-Suppression Probability is based on a wet pipe system, and basic events 0SUPR-----M and 0SWET-----F. These basic events are modeled correctly under gate SUP-WET-G, but the probabilities used are incorrect. The fault tree has probabilities of 1E-2 and 3E-2 respectively, and the document shows probabilities of 2.2E-3 and 1E-2 respectively. These two need to be consistent The finding deals with consistent treatment of basic events 0SUPR-----M and 0SWET----F. The Fire PRA logic model was updated to ensure values associated BEs 0SUPR-----M and 0SWET-----F were consistently treated in the top logic model. With regards to clarifying how plant damage states translate into the Plant Response Model fault trees, updates to the documentation are needed to address this issue. The suggested documentation enhancements are not expected to affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue.

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-11 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition

• Additionally, compartment documentation describes how the various damage states are determined. However, the documentation does not clearly state how these damage states are translated into the Plant Response Model fault trees. This is leading to confusion when attempting to validate that the PRM logic is correct. Create a table of the inputs for each scenario to ensure that the inputs into the PRM are complete and correct. It is recommended that this table include the scenario, ignition frequency, NSP [Non-Suppression Probability] (including BE names), and Severity Factor (including BE names)) so that it is easy to ensure the logic reflects the notebook. PRM-B2-01 Plant Response Model - Internal Events Peer Review Findings Open VERIFY the peer review exceptions and deficiencies for the Internal Events PRA are dispositioned, and the disposition does not adversely affect the development of the Fire PRA plant response model. Not all the F&O's were addressed in Appendix F of PINGP-FPRA-PI-PRM notebook. It is not clear that all the suggestions have also been addressed. In its current form, what is in the Appendix F does [not] appear to be complete, but once all F&Os have been added, the table appears sufficient. Completion of the Appendix F and addressing the suggestion F&O for the A review of internal events peer review Findings and Suggestions was performed to determine if there were any effects on the Fire PRA. The results of the review showed that none of the Findings or Suggestions remaining open impacted the Fire PRA. Attachment U of the LAR provides detailed information regarding the peer review Findings that affect the internal events PRA. Note that a peer review was performed in September 2012 to evaluate the PINGP Internal Flooding analysis against the 2009 ASME standard. Due to the timing of this review, peer review finding have not yet Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-12 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition internal events peer review will met this SR. been addressed by NSPM. This information will be provided in a supplement to this LAR. A draft version of the peer review findings is included in Attachment U to illustrate the technical adequacy of the Internal Flooding PRA, and NSPM will provide final findings and resolution in a supplement to this LAR. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. PRM-B13-02 Other Affected SR PRM-B12 Naming convention for fire scenario analysis parameters Open There is a requirement to develop and use a system model nomenclature to allow model manipulation in the Internal Events PRA (SY-A23), and PRM-B9 states "ALL the SRs under HLR-SY-A and HLR-SY-B in Part 2 are to be addressed in the context of fire scenarios" - therefore the naming scheme established under SY-A23 of Part 2 is also applicable to the Fire PRA. Spurious transfers of valves were added into the model, but did not use the naming scheme established in the Internal Events PRA model. This implies that these events were meant to be used solely as Flag events. If this is true, then the naming scheme for Flag events needs to be used. If the addition of these events was done to include them as spurious failures as well, then data needs to be established for them in accordance with the Data SRs. If these events are to be used as Flag The spurious valve transfer events were not intended to be used as flag events. The fact that they do not follow the naming convention for basic events does not affect the results of the PRA because when these events are used, their probabilities are set by flag files for quantification of the model. The Fire PRA results and the change in risk calculated for the Fire Risk Evaluations are therefore performed correctly. This finding does not have an affect on the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue.

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-13 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition events, change their names to use the established Flag naming scheme. If they are to be used as random failure events, either use the already established "transfers open/closed" type code and data, or develop appropriate Type Codes and supporting data for them. PRM-C1-01 Fire compartment analysis documentation Open This SR is associated with documenting the Fire PRA plant response model in a manner consistent with the document requirements of the Internal Events PRA SRs for IE, AS, SC, SY, and DA. The documentation requirements are developed to ensure that the development of the Fire PRA model is easily understood and reproducible, and that they facilitate PRA applications, upgrades, and peer reviews. Although most of the information appears to be available throughout the various notebooks, it is difficult to find, and verify. Therefore, it is difficult to ensure that the Fire PRA model accurately reflects the information currently contained in the compartment specific notebooks, and in many instances it was determined that the two were inconsistent. A summary section that contains a table of the scenarios, and their applicable ignition frequencies, NSPs, and severity factors would be very useful, and would help ensure that the PRM accurately reflects the latest compartment information. However, this is not the only option. Any documentation restructuring or enhancement that would Appendix C of the Compartment Analysis Notebook shows the event trees for all ignition sources. The event trees include top event headings that consider the fire ignition frequency, all severity factors, and non-suppression probabilities applied and the resulting Plant Damage State. The event trees also consider frequency modifiers and the impact of spurious equipment operations that would change the Plant Damage State from a general transient to a LOCA event. Each Plant Damage State is linked directly into the Fire PRA logic model and then quantified independently. Since the scenario event trees and top logic fault trees have been prepared and reviewed, adding a second check by means of the table of inputs will not affect the Fire PRA results. This finding provides suggested documentation enhancements that will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-14 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition make it easier to follow the process employed for identifying the required PRM changes, and to find the required changes with their bases would be acceptable. FSS-A5-01 Other Affected SRs FSS-A1, FSS-A2, FSS-D10 Fire scenario development and fire modeling Open Section 6.1.1 (Unit 1, Fire Compartment 1-Containment) of FPRA-PI-SCA, Detailed Compartment Analysis Notebook, indicates that "the contribution to the plant Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) from initiators in this compartment is sufficiently low to preclude fire modeling to screen initiators." The report FPRA-PI-FQ, Rev. B, Fire PRA Quantification, indicates that the CDF contribution from fire compartment 1 is 6% and is not sufficiently low. Therefore, additional evaluation is necessary beyond assuming full room burnout. A number of other fire compartments have the same issue. An F&O is being issued to recognize the fact that this SR must be met for the further analysis that will need to be used to ensure that the scenarios are evaluated and/or quantified at a level of detail commensurate with the risk significance of the scenarios. Additionally, IF new analysis methods (methods that are different from the ones currently being used by PINGP and that were reviewed as part of this Peer Review) are required to ensure the risk is adequately characterized, the new analysis methods may require a focused Peer Review to ensure they are applied appropriately. Additional detailed fire modeling has been performed for many fire compartments within the Fire PRA. In addition, planned modifications to address Variances from Deterministic Requirements (VFDRs) and recommended procedure changes described in Attachment S have also been incorporated. The results of this modeling were incorporated into the compartment analysis and overall Fire PRA quantification results (CDF/LERF) for the LAR. No new methodologies requiring focused Peer Review were necessary to address this Finding. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-15 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition Perform additional ignition source and target set refinement and fire modeling to better characterize the fire risk contribution to CDF/LERF. FSS-B2-01 Other Affected SR FSS-A6 Main Control Room (MCR) analysis Open Per Procedure EPM-DP-RSD-005, the MCR abandonment scenarios were developed to bound the risk in the main control room. This meets the standard at the CC-I level. Additionally, Section 9.2.1 of FPRA-PI-MCR, Main Control Room Analysis, Revision B (page 33 of 79) uses a bounding assumption associated with how the probability of a fire starting near a target is determined, which is acceptable for a bounding analysis, but will need to be revisited in order to ensure the MCR risk is realistically characterized. This F&O is a finding to go from CC-I to CC-II, which requires the FPRA to realistically characterize main control room abandonment fire scenarios instead of using a bounding analysis. The Standard requires an evaluation of two types of Main Control Room scenarios - those that require Full Abandonment, and those that do not lead to MCR Abandonment but do rely on ex-control room actions [i.e., external to the MCR] to safely shutdown the reactor. The scenarios evaluated do not appear to adequately consider or address Main Control Board (MCB) fires that do NOT require full abandonment, but DO require ex-control room operator actions including remote The current PINGP main control board fire scenarios are developed by determining where fire impact to redundant Fire PRA credited systems which are physically located in close proximity on the main control board is possible. The calculation of fire scenario frequency for MCB scenarios is performed consistent with guidance given in Section L.3 of NUREG/CR-6850. Section L.3 directs the use of Figure L-1 for determination of fire scenario frequency. The scenarios defined in the MCR notebook were quantified and incorporated in the results of the Fire PRA. The MCR analysis quantifies fire scenarios that lead to control room abandonment and non-abandonment. The current MCR technical analysis and documentation that supports the Fire PRA was found to be consistent with NUREG/CR-6850 methods. There were no changes to the conclusions of the MCR analysis as a result of this Finding. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-16 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition and/or alternate shutdown actions. Note - it is expected that some MCB fires will only impact a single Unit - and the need for ex-control room actions to assist that Unit - so the assumption that every fire results in a Dual Unit trip needs may need to be re-evaluated for some MCB fires. Since there is no single correct way to perform a realistic MCR analysis, it is recommended that PINGP contact other utilities to see the methods they used, and then select the methodology that best fits for PINGP. FSS-C1-01 Conduits located between ignition source and nearest cable tray Open The screening portion of fires included all fire sizes up to the nearest cable tray, but did not consider conduits between the ignition source and the cable tray that could potentially be a PRA target. This is non-conservative as it could result in screening risk contribution from PRA targets not in cable trays. Not considering conduits between the ignition source and the nearest cable tray is non-conservative as the conduit may be a PRA target. Recommend reducing the fraction of fires screened from an ignition source to those that cannot affect the nearest conduit to an ignition source, which may be a PRA target. It would be acceptable to ignore conduits that are known not to be PRA targets. Walkdowns were conducted to identify risk important redundant cables, routed in conduit, that are located in previously screened regions of the initiator zone-of-influence (ZOI). These walkdowns involved a review of fire areas that required the performance of FREs; fire areas that did not require performance of an FRE are deterministically compliant with NFPA 805 and therefore the loss of risk important circuits is unlikely. The walkdowns were used to identify the presence of redundant, risk important, cables routed in conduit which may have been screened from previously identified target sets. This review was performed using PRISM to identify the cable failures that resulted in the loss of credited Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-17 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition For the fires beyond the screened portion, a full-room burnup would still need to be considered in the scoping fire modeling in order to capture all PRA targets, even though the conduit / raceway itself is less likely to cause an HGL than if the equipment or an associated cable tray combusted. redundant equipment/systems. In cases where risk important, conduit targets were identified, the physical location of the potential target conduits was determined with respect to screened initiators. Location of the potential target conduits was performed via drawing review or in-plant walkdowns. New severity factors were developed for the identified target conduits where they were found to be inside of previously screened regions of the initiator ZOIs. The application of this process provides a graded approach to assessing the potential risk impact from these intervening conduits for all fire areas that have FREs. The remaining fire areas are deterministically compliant and therefore would have a much lesser risk significance resulting from any intervening conduit since these compartments have been demonstrated to have at least one train free of fire damage. This process, therefore, provides a method of addressing the finding as it applies to the NFPA 805 LAR submittal. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-18 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition FSS-C5-01 Assumption for cable damage temperature Open Based on the wording in the reports, and a spot check of analyses, cables are assumed to be thermoset for self ignited cable purposes, and are assumed to be thermoplastic for the purposes of being a target. The cable database has information about which type of cable each individual cable really is, however the cable database does not appear to be used when determining what properties to use in the analysis for individual cables. The cable properties impact the CDF/LERF calculated for scenarios. Utilize the cable database to determine the target cable failure situation. If assumptions are used for screening/full compartment analyses, but actual cable types are used in detailed analyses - this needs to be clearly stated in the report. This finding involves clarifying the wording related to the application of thermoset and thermoplastic cable properties in the detailed fire analysis. The Fire PRA does not consider self-ignited cable fires because a review of the PINGP cable database has shown that PINGP has predominantly thermoset cable. In addition, the properties used in the PINGP Fire PRA for cable fire spread and cable damage are in accordance with those specified for Kerite cable in FAQ 08-053, Kerite-FR Cable Failure Thresholds. A significant quantity of the cable at PINGP is Kerite, but there also exists a limited amount of cable that is either thermoset or thermoplastic. Because a mix of these cable types could exist in any cable tray, the use of the properties for Kerite cable provides a realistic result. The current methodology is therefore reasonable. Since no change to the model is required, the results of the fire PRA are not affected. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-C8-01 Integrity of credited fire wraps Open If raceway fire wraps are credited: a) ESTABLISH a technical basis for their fire-resistance rating, and CONFIRM that the fire wrap will not be subject to either mechanical This issue deals with the documentation related to how fire wraps were credited in the Fire PRA. Raceway fire wraps that are credited in the Fire PRA are fully qualified via Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-19 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition damage or direct flame impingement from a high-hazard ignition source unless the wrap has been subject to qualification or other proof of performance testing under these conditions. There is no discussion of mechanical damage or direct flame impingement. There is also no discussion in the notebooks of the wrap being qualified. The justification found in the self assessment should be included in one of the fire notebooks. Also a confirmatory walkdown to ensure fire wrap is not damaged and associated documentation is needed. fire testing. The wraps credited were installed and are currently inspected and maintained in accordance with the plant fire protection program. Accordingly, the fire resistance rating and application of these wraps is considered acceptable for the Fire PRA. Fire wraps are not credited in the Fire PRA for high hazard sources (i.e. high energy arcing fault (HEAF)). This is a documentation related finding and does not affect the results of the fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-D7-01 Other Affected SR PRM-A2 Unreliability of detection in deluge system Open The Non-Suppression probability for the deluge system appears to be calculated incorrectly in several places in the FPRA-PI-SS report. In particular, in Table 20 on page 25 of 34 in report FPRA-PI-SS, Revision A, the unreliability of the detection system required to activate the deluge valve is not factored into the calculation. Additionally, it appears that the event tree in section P.1.3 and Figure P-1of NUREG/CR-6850 has been solved incorrectly. It also appears that the bullet titled "Pr(failure auto det):" and the bullet titled "Pr(failure auto supp):" on page P-6 of NUREG/CR-6850v2 is being interpreted incorrectly. This impacts the accuracy of the FPRA. Revise the calculation method on pages 25-This issue deals with the fact that the unreliability of the detection system was not initially considered for the deluge system. This factor was added to correctly modify the event tree to match that of Figure P-1 in NUREG 6850. With regards to the failure of auto detection and suppression, the analysis was reviewed and was found to be consistent with NUREG/CR-6850 methods. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-20 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition 26 of 34 in report FPRA-PI-SS, Revision A and document its accuracy. FSS-D7-02 Other Affected SR PRM-A2 Suppression system unavailability Open PRM model for fire compartment 18 does not reflect the basic events and failure rates identified in FPRA-PI-SCA, Rev. B. In particular, Section 6.19.2 of FPRA-PI-SCA states that the 0SPUR-----M is used in this room, but the PRM model does not include this basic event, but does include a different basic event that is not discussed for this compartment." A similar issue was also noted for fire compartment 48GRP - Section 6.35 of FPRA-PI-SCA states that the 0SPUR-----M is also used in this room, but again, the PRM does not include this basic event, but does model a different basic event for this fire compartment. It is believed that the PRM is correct, and that the documentation is incorrect in these cases, but a complete review of all fire compartments has not been done to verify that these are isolated instances. This will result in an error in final CDF values. A complete review of the Single Compartment Analysis write-up needs to be performed to verify that the "Modeling Factors" that are documented for each compartment are correct, and reflect the ones actually used in the PRM. Any discrepancies need to be corrected. The basic event 0SPUR-----M represents the unavailability of a suppression system due to maintenance. The value associated with this basic event is a bounding value of 0.01. The suppression system unavailability analysis section of Compartment Analysis notebook was completed to show that the value 0.01 will bound the actual Automatic Suppression System unavailability due to maintenance as determined by a review of past maintenance history. In scenarios where 0.01 will not bound the unavailability due to maintenance, the calculated value is used and documented. A review of the FPRA-PI-SCA was performed. No additional issues with non-suppression modeling factors were identified. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-21 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition FSS-D8-01 Evaluation of detection and suppression system effectiveness Open The SR states to document the assessment of fire detection and suppression system effectiveness in the context of each fire scenario analyzed. Did not find any evidence that this requirement was documented. Provide copies of the assessment for each fire scenario analyzed. Document that all systems are installed in accordance with NFPA and industry standards. Fire detection and suppression systems response was generically evaluated and applied to bounding fire modeling that employs conservative fire modeling treatments using Fire Dynamics Tools (FDTs). For more detailed treatments, analysis of system response was determined using Fire Dynamics Simulator (FDS) models. Fire detection and suppression system effectiveness is assessed to be high based on installation and maintenance in accordance with applicable standards. Where credited, system effectiveness is quantified in the event trees documented in the Compartment Analysis Notebook. In addition, fire suppression and detection systems that were credited in the Fire PRA were reviewed to ensure that they meet applicable codes and standards. Modifications were initiated for systems that were credited in the Fire PRA, but were found not to be code compliant. These modifications are listed in Attachment S of the LAR. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-D9-01 Component sensitivity due to smoke Open The self-assessment states that no equipment was felt to be sensitive to smoke damage, therefore no evaluation for smoke damage effects was performed. If electronic In addition to damage due to direct flame impingement, high temperature, or radiative heat flux, electrical components also have the potential to be damaged by smoke. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-22 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition equipment is being used, smoke damage is likely. Many electrical parts have data on the effects of smoke, which can be consulted if needed to make a decision. The assumption that no smoke damage will occur needs to be justified. Provide justification and documentation for smoke damage applicability to support Category II and future use of the fire PRA. Appendix T of NUREG/CR-6850 details the potential methods of damage by smoke during a fire event. Section T.3.1 of NUREG/CR-6850 indicates that, even for potentially vulnerable components, a general compartment fire will not lead to short-term smoke damage. A general compartment fire is taken to mean any fire that is reasonably expected to be possible within the compartment based on initiators present (98th percentile: electrical cabinet fire, transient fire, cable fire, etc). Section T.3.1 also indicates that for components located within the same electrical cabinet as the fire, or for components located in the immediately adjacent cabinets if the fire is in an interconnected bank of cabinets, smoke damage should be assumed. The methodology of the fire modeling used to support the PINGP Fire PRA analysis was to assume all components within the initiator will be damaged by smoke or thermal effects. A fire in any interconnected bank of electrical cabinets was assumed to spread to the immediately adjacent cabinets, as these were considered radiative damage targets. Through the completion of fire modeling and fire scenario development, no smoke-induced damage to Fire PRA equipment was identified that was not bounded by the analysis completed in the Compartment Analysis Notebook. Therefore, potential Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-23 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition smoke-induced equipment damage is bounded by thermally-induced target damage assumptions, and was not explicitly incorporated into the target sets for fire scenarios. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-D10-01 Other Affected SRs FSS-D11, FSS-H10 Walkdowns needed for added fire scenarios Open Since it is recognized that additional detailed fire scenarios need to be developed in order to accurately reflect the fire risk, this finding is being written to document that as more detailed scenarios are evaluated, confirmatory walkdowns of the newly defined scenarios to confirm the combinations of fire sources and target sets will also be required. These walkdowns need to be conducted in accordance with current EPM procedures. Such fire scenario revisions and associated walkdowns will be required to demonstrate an acceptable CDF/LERF value. Conduct and document confirmatory walkdowns of the newly defined scenarios to validate the fire sources and target sets Additional fire modeling and other analysis refinements were performed to address model conservatisms, as described in the resolution to F&O FSS-A5-01. Some of these activities resulted in the addition of new scenarios. Confirmatory walkdowns of the new scenarios were performed as appropriate to validate the fire sources and target sets. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-24 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition FSS-F1-01 Hydrogen piping and storage tanks Open During walkdowns it was determined that hydrogen lines in the turbine building have the capability of initiating a fire that would directly impinge on the building structural steel. In many plants, the use of fork trucks is not allowed in the area of exposed hydrogen pipelines. However, based on the walkdown performed, fork truck use is allowed in the area of exposed hydrogen pipelines at PINGP. The potential for a fork lift inadvertently impacting an exposed hydrogen line resulting in a direct hydrogen flame on exposed structural steel in the Turbine Building needs to be addressed. Additionally, the Hydrogen Storage Tanks outside the Turbine Building are stored in a physical configuration such that a fire in the storage tank area that impacts the valves and ends of the tanks could result in the tanks becoming missiles and punching through the concrete wall separating them from the Turbine Building. The potential for and impact of this scenario needs to be addressed. Evaluate and document the missing hydrogen scenarios. The events described in the finding are low likelihood and are not normally addressed in fire PRA (i.e. fracture of hydrogen piping due to a fork lift and hydrogen tanks becoming missiles). Hydrogen fires were evaluated based upon likely break points, such as flanged joints or valves. Welded sections of hydrogen piping are robust (Schedule 80) and would not normally be considered as a flame impingement source for the structural steel analysis. The resolution of this finding is documentation related and will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-F3-01 Structural steel analysis quantification Open If, per SR FSS-F1, one or more scenarios are selected, Complete a quantitative assessment of the risk of the selected fire scenarios consistent with the FQ requirements, including collapse of the exposed structural steel. At present, Table 22 on page 31 of 34 in report FPRA-PI-SS, The fire scenarios developed in the Structural Steel notebook were examined, and it was determined all fire scenarios contained initiators that were previously evaluated during compartment analysis. Their anticipated damage targets were then compared with the Plant Damage States Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-25 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition Revision A, has not been completed and a quantitative assessment has not been done. The quantitative assessment table exists in the report but needs the values for CDF and LERF entered into it. Complete the table with the quantitative values. If the table is completed, this F&O will be satisfied. (PDS) already assigned to the initiators. The plant damage states were found to be equal to or bounding for all target sets determined in the Structural Steel notebook. Therefore, no new scenarios need to be added into the quantification task, as existing scenarios already evaluate all initiators and damage states found during the structural steel-fire interaction analysis. The resolution of this finding is documentation related and will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-G2-01 Outside area fires Open It was noted during the walkdown that there are large transformers located outside of the turbine building which are close to the turbine building. There appear to be cables /ductwork between the transformers and the turbine building, and these cables/ductwork do not currently appear to be included in any fire compartment. Because there are no physical barriers between the transformers and the outside ductwork/cables, and because the walkdown team determined that an explosion and/or fire in one of the transformers could physically impact the outside of the turbine building, the ductwork/cables need to be considered as part of the transformer fire compartment. Industry events have occurred where large transformers have failed and the resulting The Yard Fire Area scenario is calculated as a full "room" burnout, so all components in this fire area are affected by every initiator. Also, cables and ducts in vicinity of transformers are for components that support the transformers themselves (oil pumps, fans and instrumentation), so their failure in addition to that of the transformers adds no risk. This information is contained in the Compartment Analysis notebook. Qualification of the barriers separating this area from the Turbine Building is part of the fire protection program and is therefore credited in the Fire PRA. Since no change to the model is required, the results of the Fire PRA will not be affected. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-26 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition fire or debris has impacted adjacent structures. Since the ductwork/cables are on the outside of the Turbine Building, they can be impacted by the Transformer fire, and need to be included in the evaluation. Fire scenarios involving the outside transformers and cables/ductwork external to the Turbine Building need to be evaluated as part of the single compartment analysis. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-G6-01 Multi-compartment analysis quantification Open Requirement is to quantify the risk contribution of any selected multi-compartment fire scenarios consistent with the FQ [Fire Quantification] requirements. Quantification approach should be consistent with FQ supporting requirements. CCDP's are assumed to be 1 for combined areas. Multi-compartment fire CCDP's currently add up to mid-E-4 range, which is conservative. No LERF information is provided, need to provide LERF. Suggest providing more realistic evaluations and including LERF information for unscreened scenarios. Realistic estimates of multi-compartment CCDPs and CLERPs were developed following the peer review. These new results have been incorporated into the Fire PRA and are reflected in the final quantification results. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-H5-01 Other Affected SR PRM-C1 Fire compartment analysis documentation difficult to follow Open Section 6 of FPRA-PI-SCA, Detailed Compartment Analysis Notebook, is very cumbersome to use and understand. In addition, many sections have nothing substantive except for a reference to another section - which takes up a lot of pages and makes it difficult to correlate the information that is in fact relevant to the subject. Also, many references are merely to event or Resolution of this finding involves suggested improvements to documentation for the Fire PRA. Since no change to the model is required, Fire PRA results will not be affected. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-27 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition computer ID's and codes that have no corresponding name or description. To facilitate use of the FSS notebook in the future, a substantial rewrite is needed that better organizes and condenses common information and references applicable to each compartment, and provides missing information. Improved documentation will be very valuable for future use, upgrade and peer review of the Fire PRA. Provide additional tables and descriptions of computer ID's rather than continual reference to another location that is not specifically identified (ie. A specific part or page in an appendix, rather than just reference to an appendix). Reduce duplicate statements of general information that increases the number of pages and complexity of the report. FSS-H5-02 Scenario specific parameter uncertainty Open Section 6 of FPRA-PI-SCA, Detailed Compartment Analysis Notebook, does not include any kind of detailed documentation related to scenario specific parameter uncertainty evaluations such that it can be referenced and utilized in Section 4.1.11 and Table 2 of Appendix A of the Uncertainty and Sensitivity Notebook (FPRA-PI-UNC, Revision B). This missing information is needed for long term use, upgrade and peer review of the Fire PRA. Provide documentation of scenario specific parameter uncertainty evaluations in report Scenario specific parameter uncertainty evaluations were not performed for the fire modeling inputs to the Fire PRA. The standard requires parameter uncertainty evaluations to meet Capability Category II or III. The finding suggests including the parametric uncertainty evaluations to satisfy the requirements for Capability Category II. However, the results of the Fire PRA are not affected if the uncertainty evaluations have not been performed. Since no change to the model is required, the Fire PRA results are not affected. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-28 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition FPRA-PI-SCA, Detailed Compartment Analysis Notebook. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-H9-01 Fire modeling parameter uncertainty Open The uncertainty discussions in FPRA-PI-UNC, Revision B, Uncertainty and Sensitivity Notebook, are very general in nature and not specific to the analyses in the fire scenario selection tasks of the Fire PRA. Therefore, this SR is judged to be met, although the need for more specific information and evaluation has been identified. Lack of specific detail which would allow long term use of the Fire PRA. Provide expanded, upgraded, and enhanced qualitative discussions, and possibly quantitative results related to uncertainty in the FSS portions of the fire PRA. This Finding is related to the level of detail that is provided in the Uncertainty and Sensitivity notebook. As stated in the Finding, the documentation meets the intent of the ASME standard, but could be enhanced to provide additional details. The resolution of this finding of this finding involves suggested improvements to documentation for the Fire PRA. Since no change to the model is required, Fire PRA results will not be affected. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FSS-H10-01 Other Affected SR FSS-D10 Documentation of walkdown information Open The electronic copies of walkdown data located at the following path: O:\Xcel Energy - PINGP Fire PRA\Task 1006-FIF\! Old Files from P2007\PINGP Initiator Photos and Data Sheets" needs to be incorporated into the Fire PRA documentation. This is needed in order to use, maintain, and update the Fire PRA in the future and provide completeness of the FPRA Documentation. It is recommended that the walkdown data in O:\Xcel Energy - PINGP Fire PRA\Task 1006-FIF\! Old Files from P2007\PINGP be This Finding is related to incorporating the output of plant walkdowns into the Fire PRA documentation so that conclusions from the walkdowns are retrievable and able to be verified. As noted by the Finding, it is recognized that some walkdown information should be included directly into the Fire PRA documentation. The resolution of this finding involves suggested improvements to documentation for the Fire PRA. Since no change to the model is required, Fire PRA results will not be affected. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-29 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition directly referenced in FPRA-PI-SCA, Detailed Compartment Analysis Notebook or this information should be incorporated into an appendix to report FPRA-PI-SCA, Detailed Compartment Analysis Notebook. The walkdowns performed need to be easily retrievable, and to be able to be verified to be complete (i.e. none are inadvertently missing). This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. IGN-A1-01 Other Affected SRs UNC-A1, UNC-A2 Sensitivity study needed for updated ignition frequencies Open PI used the ignition frequencies provided in NUREG/CR-6850 Supplement 1 (FAQ-0048). When using the Supplement 1 frequencies a sensitivity analysis must be performed against the ignition frequencies in NUREG/CR-6850. When using the Supplement 1 frequencies, a sensitivity analysis needs to be performed against using the NUREG/CR-6850 fire ignition frequencies. Perform sensitivity analysis between the NUREG/CR-6850 fire ignition frequencies and the frequencies provided in NUREG/CR-6850 Supplement 1. The sensitivity analysis only needs to be performed for those bins characterized by an alpha less than or equal to 1. A sensitivity study has been created to use the generic ignition frequencies provided in NUREG/CR-6850 for those bins with an alpha value of less than or equal to one as given in EPRI 1016735. The exception to this is Bin 9 where NUREG/CR-6850 Supplement 1 states that EPRI 1016735 is incorrect in that Bin 9 should have an alpha value greater than one, hence a sensitivity analysis does not need to be performed for this bin. The initiator frequencies from the sensitivity study were used to re-quantify the Fire PRA for the sensitivity case. The CDF and LERF results from the sensitivity case were compared to the baseline model case results in order to determine the effects on due to using the NUREG/CR-6850 Supplement 1 generic frequencies in place of the NUREG/CR-6850 generic frequencies. The results of the sensitivity showed that CDF increased approximately 46% and 43% for Unit 1 and 2 respectively. Also, LERF increased approximately 36% and 41% for Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-30 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition Unit 1 and 2 respectively. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. IGN-A7-01 Other Affected SR IGN-B3 Ignition source binning Open Bin 29, Yard Transformers (Others) is not filled. Additionally, Bin 15.1 Electrical Cabinets Non-HEAF may not be filled correctly. Fire Compartment 20 (Switchgear Room) has more HEAF electrical cabinet counts (13) than non-HEAF counts (7). This suggests that electrical cabinets with the potential to have a HEAF event are not assigned a non-HEAF fire event. Thus the failure mode of electrical cabinet fire may not be counted and underestimate risk in compartments with the potential for HEAF. This may inadvertently skew risk away from important areas such as transformer yard and switchgear rooms. Fill Bin 29 similar to how bins 27 and 28 are filled. If Electrical Cabinet can have a HEAF failure mode, ensure that both Bins 15.1 and 15.2 are filled. Also, for Bin 21 (Pumps), believe that the split fractions in 6850 electrical/oil are still valid. NUREG/CR-6850, Task 6, states that Bin 29 is reserved for items associated with the yard transformers, such as oil-filled power output cables, but not the transformers themselves. After additional review with plant personnel, and review of photographs showing the transformer areas, Bin 29 remains not applicable to PINGP. There are no initiators near the transformers that are not a part of the transformers themselves nor that are not already counted in a different bin. For example, the frequency for the segmented bus ducts in the transformer areas is counted in Bin 16.1. It should be noted that PINGP does not have any oil-filled power cables near the transformers. Electrical Cabinets - HEAF, Bin 15.2, were removed from the Bin 15.1, Electrical Cabinets Non-HEAF, count because of the guidance provided in EPRI 1016735. This guidance states that regarding the updated EPRI generic ignition frequency values, "the high energy fire ignition events associated with electrical cabinets have been removed from bin 15, now designated bin 15.1, to a new bin, designated 15.2, electrical cabinets-HEAF" (2-6). Electrical cabinets that are a Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-31 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition HEAF concern should be counted in both Bin 15.1 and Bin 15.2 as both types of fires could occur in these electrical cabinets. Initiators counted in Bin 15.2 have been added to Bin 15.1 and documented in the Fire PRA documentation. EPRI 1016735 does not provide guidance regarding the fire type split fractions; therefore, the split fractions provided in Table 6-1 of NUREG/CR-6850 are still applicable. This includes Bin 21 (Pumps) along with several other bins. The fire type split fraction values are used in the CAFTA top logic model. The Compartment Analysis states that such frequency modifiers are used when applicable. The compartment analysis documentation was updated to clarify NUREG/CR-6850 as the source for the split fraction information. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. IGN-A7-02 Ignition frequency summation Open The summation of the fire ignition frequency bins does not equal the summation of all ignition sources. The ignition frequency is not distributed correctly (with respect to transient ignition source bins). As discussed with FPRA personnel, ensure that the generic plant locations (battery rooms, diesel rooms) are lumped into the After review of the fire compartment generic locations it was determined that based on plant configuration and the guidance available in Table 6-2 of NUREG/CR-6850, the generic plant locations should be corrected as suggested. The PINGP fire ignition frequencies have been updated to properly assign generic Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-32 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition correct transient bin (control/aux reactor, or plant wide transient bins). Document the sum of the ignition frequencies in the calculation and verify ignition frequencies are conserved for each revision. locations to fire compartments. The ignition frequencies were verified to ensure that fire ignition frequency was conserved. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. IGN-A9-01 Assignment of maintenance weighting factors Open No maintenance factors of 50 have been assigned in the ignition frequency task. A fire compartment, like the maintenance shop, which has contestant [sic] maintenance activities should have this number assigned. No fire compartments have been assigned a maintenance factor of 50. By not assigning a maintenance factor of 50 to high maintenance compartments, this can divert risk to these compartments. Review plant information (review work orders/interview operators) to identify fire compartments which may have higher than normal maintenance activities. If, because of the large size of the PAUs, no single PAU is determined to warrant a maintenance factor of 50, even if rooms within the PAU would typically have a maintenance factor of 50 applied to them, the basis and methodology employed for determining the appropriate maintenance factor for the whole PAU should be documented. Per the review of Supporting Requirement IGN-A9, the standard requires to "POSTULATE the possibility of transient combustible fires for all physical analysis units regardless of the administrative restrictions."

• Specific to the intent of the SR, PINGP has postulated a transient fire in every Fire Compartment per the Fire Ignition Frequency Notebook.
• The Finding was assessed against IGN-A9 for not assigning a maintenance factor of 50. In addition, the Finding stipulates that a review of plant information (review work orders/interview operator) should be completed to identify fire compartments with higher than normal maintenance activities. Per the review of NUREG/CR-6850, Section 6.5.7.2, there is general guidance provided to assign maintenance weighting factors, stating that the application of the factors is a subjective process and must consider plant-Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-33 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition specific layout and practices. Per section 5.2.7-2 of the Fire Ignition Frequency notebook, "influencing factors were assigned based on a review of the fire compartments with personnel familiar with PINGP." As such, the Fire Ignition Frequency notebook applied the appropriate weighting factors to the identified Fire Compartments. In addition, the compartment of interest for this Finding was the 8GRP. Fire Compartment 8GRP includes nearly the whole turbine building and was assigned a maintenance weighting factor of 10. The Maintenance Shop is part of the 8GRP and it would normally be assigned a maintenance weighting factor of 50. But 8GRP is a very large fire compartment, and the maintenance shop is only a small portion of the compartment, so assigning a Maintenance Weighting Factor of 50 to the 8GRP would disproportionally weight maintenance for the Fire Compartment. As such, the methodology described in NUREG/CR-6850 as implemented in the Fire Ignition Frequency analysis was followed correctly. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. IGN-B5-01 Other Affected Identification assumptions and sources of uncertainty Open Although there is a section in the Ignition Frequency notebook entitled Assumptions, it does not appear to be complete. This is This Finding is related to the Assumption section of the Fire Ignition Frequency notebook. As stated in the Finding, Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-34 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition SRs IGN-A10, CF-A1, UNC-A2 evidenced by the following examples:
• In section 5.2.7-2, the notebook states: "To estimate the ignition frequency for transient sources or activities, the concept of "influencing factors" is used to assess the likelihood of fire ignition. These factors represent a subjective judgment of the relative weighting of transient sources of ignition." A subjective judgment is an assumption by definition and should be identified as such.
• In Section 5.2.6, the notebook states: "Equipment screened during the walk down process is not included in the total plant count for its bin, and does not contribute to the ignition frequency of the compartment where it is located; however, later reviews during the Detailed Compartment Analysis task may result in screened targets being added back as ignition sources." Since the detailed reviews do not appear to be complete, this is a potential source of uncertainty. Additionally, Section 6.0 on Uncertainties and Sensitivities refers to the Uncertainty and Sensitivity Task report, which also does not appear to be complete. This is evidenced by the following examples:
• Section 9.0 of the Ignition Frequency notebook contains Open Items associated with the Ignition Source Frequency assumptions were identified that should also be identified in either the Assumption section of the notebook or included Uncertainty and Sensitivity notebook. Consolidating the assumptions within the Fire Ignition Frequency notebook or the Uncertainty Analysis notebook represent suggested improvements to documentation. Performing this documentation upgrade will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue.

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-35 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition calculation. o The first one states that several fire compartments do not currently contain cable loading estimates, and that these will need to be estimated. Estimations, by definition, contain uncertainty and should be identified as such. o The second one states: "The fire ignition sources for Unit 2 Containment were based off the Unit 1 walk down. " This is equivalent to assuming that Unit 1 and Unit 2 Containments are identical with respect to ignition sources, and should be identified as such.

• Section 4.1.6 of the Uncertainty and Sensitivity notebook states "Point values for the associated severity factors and floor area ratios (where applicable) were calculated, because these do not have uncertainty associated with them; the point values were entered into the fire PRA with no variability." Although the floor area ratios may be calculated, it is not evident where these calculations are performed, so their accuracy could not be confirmed. Additionally, there are no severity factors associated with ignition frequencies, so this statement makes no sense.
• Section 4.1.6 of the Uncertainty and Sensitivity notebook also states "With respect to accuracy, issues arising from mapping of plant specific locations to Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-36 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition generic locations, equipment counting, determination of location-weighting and ignition source weighting factors, and plant specific fire experience were properly identified, categorized and analyzed." Although the majority of ignition sources are easily partitioned, it is very difficult to ensure that ALL ignition sources have been identified and appropriately partitioned in the plant since NOT ALL locations have had detailed walk downs associated with them to confirm the presence or absence of ignition sources. Additionally, the use of weighting factors introduces uncertainties into the evaluation, and should be identified as such. Ensure all assumptions, and implied assumptions, are contained in the assumptions section. Additionally, ensure that sources of uncertainty associated with the ignition source frequency development are appropriately identified and included, either in this notebook, or in the Uncertainty and Sensitivity notebook. It is recommended that a Table be added in PRA-PI-IGN with the mean frequencies, 5% bound and 95% bound. FQ-A2-01 Dual unit trip assumption Open This SR states: For each fire scenario selected per the FSS requirements that will be quantified as a contributor to fire-induced plant CDF and/or LERF, IDENTIFY the This finding involves the assumption that a dual unit trip is considered for each fire initiator. Since comprehensive cable tracing for all systems that could result in a plant trip Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-37 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition specific initiating event or events (e.g., general transient, LOOP) that will be used to quantify CDF and LERF. The quantification process currently assumes BOTH units experience a Reactor Trip with loss of PCS [Power Conversion System] for EVERY scenario. Although it is reasonable to assume a Single Unit reactor trip with loss of PCS is initiated by each fire initiator, assuming a dual unit trip is overly restrictive, and is masking real risk insights. Although it is not possible to determine the potential impacts of a fire in all PAUs because not all cables were traced, there are a number of obvious PAUs that can be more realistically evaluated. These include PAUs like Containment and ECCS pump rooms, where opposite Unit cables would not realistically expected to be present. For these types of PAUs, at a minimum, the assumption of a dual unit trip needs to be re-evaluated. has not been done, it cannot be assured that a fire in a compartment on one unit will not also affect the other unit. The prudent approach is to make a moderately conservative assumption to bound the range of possibilities. One enhancement that has been made was to eliminate an opposite unit trip for a containment fire. This correction had only a very minimal impact on overall risk results and did not have any impact on FRE results since the opposite unit from a containment fire does not credit recovery actions. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FQ-B1-02 Other Affected SRs FQ-A1, FQ-A3, FQ-A4, FSS-D2 Computer code verification and validation Open This SR has look backs to the Internal Events QU [Quantification] SRs. QU-B1 provides requirements for ensuring that computer codes used in the analysis have demonstrated to generate appropriate results when compared to those from accepted algorithms and with ensuring that method-specific limitations and features of software used in the quantification process that could impact the results are identified. This Finding is related to understanding the capabilities of software products that are used to support the Fire PRA. Various software products were used to support the Fire PRA analysis, including the Plant Risk-Informed Systems Model (PRISM) and the NUREG 1805 spreadsheets. As stated in the Finding, PRISM is an EPM developed software used for associating Fire PRA model basic events to fire areas based Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-38 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition This F&O does not address standard quantifying software (CAFTA, FTREX, etc.), but rather it focuses on non-standard software which is used in the quantification process. Per discussions with EPM and Xcel Energy personnel the following non-standard software is used in the quantification process: PRISM - This EPM developed software is used for associating basic events to fire areas based on the fire location, equipment location, cable routing, etc. This software is also used to create the flag files used in the quantification process for "failing" specific target sets based upon the associations performed by the software. EPM has also developed a spreadsheet based on NUREG-1805 for performing FDT evaluations, but no validation of this software could be located. This software is subject to the requirements of QU-B1. Since this software directly impacts the development of the fire impacts, they directly impact the results and insights of the Fire PRA. As such, any errors in the software can have a significant impact on results, and the software needs to be V&Ved. Any limitations of the software also need to be identified and discussed. Ensure the software is V&Ved in accordance with standard site Software Quality on the fire location, equipment location, cable routing, etc. The outputs of PRISM (i.e. Flag files that support the quantification of each fire scenario) have been reviewed for acceptability as they are incorporated in the Fire PRA quantification. As stated in the Finding, NUREG-1805 spreadsheets were used to support the PINGP Fire PRA. The plume hot gas layer spreadsheets that were used to support the PINPG Fire PRA account for increased plume temperatures caused by entrainment of hot gas into the plume in a compartmentalized fire. In a compartmentalized fire, where a hot gas layer begins to form, the ambient temperature used in the plume temperature calculation may be higher than the original room temperature, particularly in the upper portion of the plume. To account for this phenomenon, EPM developed two spreadsheets that conservatively use the upper layer temperature of the evaluated scenario as the ambient temperature for the centerline plume temperature calculation. This was accomplished by combining the NUREG 1805 Chapter 9 - Estimating Centerline Temperature of a Buoyant Fire Plume spreadsheet with the hot gas layer calculation that is appropriate for the room being evaluated, (i.e., Chapter 2.1 - Predicting Hot Gas Layer Temperature and Smoke Layer Height in a Room Fire with Natural Ventilation for compartments with Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-39 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition Assurance Procedures, and identify any software limitations. openings, or Chapter 2.3 - Predicting Hot Gas Layer Temperature in a Room with Door Closed (Revision 1805.1, Issued August 2005) for closed compartments. The spreadsheets developed by EPM employ the same closed form correlations and variable input values contained in the above referenced spreadsheets. No new methods were created by use of the NUREG-1805 spreadsheets. Resolution of this finding involves the inclusion of software (i.e. PRISM and the combined NUREG-1805 spreadsheets) into the NSPM Software Quality Assurance (SQA) program. The current Fire PRA analysis used to support the LAR has been delivered to NSPM by EPM under the vendor's quality process. NSPM will incorporate applicable software products into their SQA program as the Fire PRA is accepted into the NSPM process. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FQ-E1-01 Completion of additional detailed scenarios for high risk compartments Open IDENTIFY significant contributors in accordance with HLR-QU-D and HLR-LE-F and their SRs in Section 2 with the following clarifications: a) SR QU-D5a and QU-D5b of Section 2 are to be met including identification of which fire scenarios and which physical analysis units (consistent with All fire scenarios and especially the most risk significant ones have been revised to add further detail and credit fire modeling and mitigation. All scenarios have now been included in the Fire PRA and are reflected in the results.

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-40 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition the level of resolution of the Fire PRA such as fire area or fire compartment) are significant contributors; b) SR QU-D5b of Section 2 is to be met recognizing that "component" in Pa Section 2 is generally equivalent to "equipment" in this standard; c) SR QU-D3 for comparison to similar plants is not applicable; d) SR LE-F3 including the "Note" for that SR of Section 2 is to be met; (1) following HLR-QU-D of Section 2 with clarifications above concerning SRs QU-D5a and (2) but the uncertainty requirement and reference to Table 2.2.7.6(e) in Section 2 does not apply here. See 4-2.13 and DEVELOP a defined basis to support the claim of non applicability of any of the requirements under the sections in Part 2. There are several identified fire scenarios that have been removed from the quantification results. These scenarios were removed to prevent the skewing of the importance calculations. This removal was noted in the notebook so that when detailed analysis of the removed scenarios was performed the removed scenarios would be included in the total CDF and LERF. Perform the detailed analysis for the scenarios that were removed and include the new results in the CDF and LERF. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. FQ-F1-01 Completion of revised quantification analyses Open DOCUMENT the CDF and LERF analyses in accordance with the HLR-QU-F and HLR-LE-G and their SRs in Section 2 with the This Finding discusses documentation discrepancies related to the Fire Quantification notebook. Specific to the Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-41 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition following clarifications: a) SRs QU-F2 and QU-F3 of Section 2 are to be met including identification of which fire scenarios and which physical analysis units (consistent with the level of resolution of the Fire PRA such as fire area or fire compartment) are significant contributors; b) SR QU-F4 of Section 2 is to be met consistent with Section 4.2.13; c) SRs LE-G2 (uncertainty discussion) and LE-G4 of Section 2 are to be met consistent with Section 4.2.13, and DEVELOP a defined basis to support the claim of non-applicability of any of the requirements under these sections in Section 2. There are several tables and sections in the notebook which are incomplete. There are discussions about uncertainty and truncation, but they are based on the incomplete tables and sections in the notebook. Ensure that all tables and section of the notebook are complete. Update the uncertainty discussion and truncation study in the notebook to reflect the final information [sic]. issues discussed in the peer review Finding, the parametric uncertainty analysis is covered in Section 5.10 of the Fire Quantification notebook, while the truncation analysis is discussed in Section 5.9 of the Fire Quantification notebook. Also, the qualitative uncertainties are discussed in the Uncertainty Analysis notebook. The Fire Quantification notebook that was completed to support the peer review contained the necessary sections to address what was captured in the peer review Finding. Relevant sections from the peer reviewed Fire Quantification notebook have been updated via an amended PRA Calculation to be consistent with the Fire PRA analysis that was used to support the NFPA 805 LAR. Documentation updates are needed to consolidate the peer reviewed quantification notebook and the amended Fire Quantification PRA Calculation. This documentation upgrade will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. UNC-A1-01 Discussion of uncertainty introduced by assumptions Open This SR requires in part: "PERFORM the uncertainty analysis in accordance with HLR-QU-E and its SRs" which include QU-E1, QU-E2, QU-E3, and QU-E4. This element With regards to the specific issues that were identified within the Finding, the following information is provided: Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-42 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition has not been satisfied. There are a number of assumptions and sources of uncertainty which were not identified or which were identified but whose impact was not provided. Examples of areas of uncertainty which should be addressed further include: HRR values used, non-suppression probabilities used, choices of target sets, location of instrument air headers relative to fire scenarios and fire impacts due to soldered joint failures. Other examples include the issue discussed in F&O IGN-A1-01, regarding a comparison of new vs. old ignition frequencies; the issue discussed in F&O FSS-A5-02, regarding parameter uncertainty evaluations required for category two for SR FSS-H5. It was assumed that containment heat removal is not required for success in any scenario; this assumption was not explored. Additionally Table 2 in the uncertainty notebook is confusing. The information associated with how kerite was treated, and the basis for the treatment is unclear, and the potential impacts of the assumptions which were made about kerite on the model were not identified. Some aspects of required search for, and characterization of, sources of uncertainty / assumptions have not been performed completely. Non-Suppression Probabilities: The non-suppression probabilities are taken directly from NUREG-6850 Supplement 1 without modification. Target Sets: Target sets were chosen using accurate drawings and item locations verified by visual inspection, so this was not included in model uncertainty. Instrument Air: See resolution to Finding PRM-A1-02 above. Ignition Frequencies: See resolution to Finding IGN-A1-01 above. Containment Heat Removal: Credit containment heat removal was dispostioned within the internal events PRA analysis. The thermal hydraulic analysis is also valid for the fire PRA and determined that Containment heat removal is not required. Kerite Cable: The assumption that fire damage of Kerite cable would occur at 400F (thermoplastic damage temperature) was conservative. Per the closure memo for FAQ 08-0053, Kerite-FR Cable Failure Thresholds, Kerite FR is a thermoset material and the lower damage threshold should be 477F. Thus uncertainty was introduced by this assumption and introduced conservatism into the model results. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-43 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition Address the specifically cited examples, and search all main Fire PRA reports for assumptions. If additional items are found then list them and address them. The resolution of this finding involves reviewing the Fire PRA documentation and including all assumptions in the Uncertainty and Sensitivity notebook. Completing this analysis is not expected to have an affect on the Fire PRA results, but a better understanding of the sources of uncertainty. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. UNC-A2-01 Quantitative uncertainty analysis incorporating all input parameters Open This SR says: INCLUDE the treatment of uncertainties, including their documentation, as called out in SRs PRM-A4, FQ-F1, IGN-A10, IGN-B5, FSS-E3, FSS-E4, FSS-H5, FSS-H9, and CF-A2 and that required by performing Part 2 referenced requirements throughout this Standard. Some of these back-referenced SR's appear not to be met: FSS-E3 requires "Provide a mean value of, and a statistical representation of, the uncertainty intervals for the parameters used for modeling the significant fire scenarios." Statistical representations of the uncertainty intervals for the parameters used for modeling significant fire scenarios were identified for HRA, data, and ignition frequencies. However uncertainty information was not provided for other parameters. The resolution of this finding involves reviewing the Fire PRA documentation to identify each source of uncertainty and characterize how it could impact the Fire PRA in the Uncertainty and Sensitivity notebook. Completing this analysis is not expected to have an affect on the Fire PRA results, but a better understanding of the sources of uncertainty. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-44 Table V-1 Fire PRA Peer Review - Facts and Observations Finding F&O Topic Status Issue Disposition FSS-E4 requires "PROVIDE a characterization of the uncertainties associated with cases where cable routing has [Note (1)] been assumed based on SRs CS-A10 and/or CS-A11. NOTE: (1) Uncertainties associated with cases where cable routing was assumed may be associated with the exact location of the cables with respect to the ignition sources, and fire-resistance characteristics and fire protection (e.g., fire-resistant covers) of the cables." However; No characterization of uncertainties associated with cable routing was identified. (assumptions re. conduit for example). FSS-H5 requires "Document fire modeling output results for each analyzed fire scenario, including the results of parameter uncertainty evaluations (as Performed) in a manner that facilitates Fire PRA applications, upgrades, and peer review." However, no parameter uncertainty evaluations were identified. Uncertainty information has not been developed for a number of important parameters. This makes it impossible to provide a complete understanding of the uncertainty of the results. Provide more detailed characterizations of uncertainty for the identified elements. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-45 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status CS-A10 CC I As identified in Finding CS-A10-01, a limited number of Fire Areas did not have specific cable routing information available. Open item No. 1 on Page 17 of 17 of FPRA-PI-CS, Revision C, states that "in order to fully comply with Capability Category II, cables that are routed through fire compartments 2A, 41B-1, 46A, 58A, 58B, 58C, 58D, 76A, 78E, 86, 94A, 94B, 94C, 94D, 94E, and 94F need to be identified. This will be accomplished by identifying routing on electrical drawings, and with walkdowns performed as needed." Since this has not yet been completed, and the methodology not specified, this SR is provisionally met.

Route cables through the listed fire compartments, and perform walkdowns to confirm accuracy of the routing. Utilize EPM Division Procedure EPM-DP-EP-005, Revision 1-Post-Fire Safe Shutdown Cable Routing and Component Location, and EPM Division Procedure EPM-DP-EP-004, Revision 2-Post Fire Safe Shutdown Cable Identification-February 2011. Current CC: Met CC I

This issue involves the lack of specific routing information for cables through fire compartments (physical analysis units or PAUs) versus Fire Areas. As a result, damage to cables for additional equipment is assumed to occur beyond what is actually located in the compartment, making the risk results for these compartments conservative.

Although this is a conservative approach, the results of the Fire PRA have shown to be acceptable. For example, Fire Risk Evaluations for Fire Areas 2, 41B and 58 show delta risk results that are also conservatively higher, but meet established acceptance criteria. Since the results for these FREs meet the criteria established this level of conservatism is acceptable.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. CS-B1 CC I As identified in FPRA-PI-CS, Appendix R overcurrent coordination and protection analysis has been reviewed but the analysis of additional circuits identified during the Fire PRA is currently in progress and is therefore not complete. Appendix R Breaker Coordination study has been reviewed. Additional breaker coordination is still being performed. Current CC: Met CC I This issue involves completing the coordination studies that were on-going at the time of the peer review. A final coordination study has not been Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-46 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status completed for the power supplies credited within the Fire PRA Model. Subsequent modifications will be performed to resolve outstanding coordination issues that are relevant to the Fire PRA.

The Fire PRA assumes that there are not any coordination issues with the power supplies that are credited in the Fire PRA model. Resolution of coordination issues is captured in Attachment S of the LAR.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. CS-C4 Not Met As identified in FPRA-PI-CS, Appendix R overcurrent coordination and protection analysis has been reviewed but the analysis of additional circuits identified during the Fire PRA is currently in progress and is therefore not complete. Appendix R Breaker Coordination study has been reviewed. Additional breaker coordination is still being performed. Current CC: Not Met This issue involves completing the coordination studies that were on-going at the time of the peer review. A final coordination study has not been completed for the power supplies credited within the Fire PRA Model. Subsequent modifications will be performed to resolve outstanding coordination issues that are relevant to the Fire PRA. The Fire PRA assumes that there are not any coordination issues with the power supplies that are credited in the Fire PRA model. Resolution of coordination issues is captured in Attachment S of the LAR. This finding is considered open until the Fire Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-47 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status PRA notebooks and analysis are updated to completely address this issue. FSS-B2 CC I Per Procedure EPM-DP-RSD-005, the MCR abandonment scenarios were developed to bound the risk in the main control room. This meets the standard at the CC-I level. Additionally, Section 9.2.1 of FPRA-PI-MCR, Main Control Room Analysis, Revision B (page 33 of 79) uses a bounding assumption associated with how the probability of a fire starting near a target is determined, which is acceptable for a bounding analysis, but will need to be revisited in order to ensure the MCR risk is realistically characterized. Current CC: Met CC II The current MCR technical analysis and documentation that supports the Fire PRA was found to be consistent with NUREG/CR-6850 methods. There were no changes to the conclusions of the MCR analysis as a result of this Finding. The MCR analysis quantifies fire scenarios that lead to control room abandonment and non-abandonment.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FSS-C8 Not Met There is no discussion of mechanical damage or direct flame impingement. There is also no discussion in the notebooks of the wrap being qualified but there is justification in the self assessment. The justification from the self assessment should be included in one of the fire notebooks. Also, a confirmatory walkdown to ensure fire wrap is not damaged, and supporting documentation would be needed. Current CC: Met CC I/II/III

This issue deals with the documentation related to how fire wraps were credited in the Fire PRA. Raceway fire wraps that are credited in the Fire PRA are fully qualified via fire testing. The wraps credited were installed and are currently inspected and maintained in accordance with the plant fire protection program. Accordingly, the fire resistance rating and application of these wraps is considered acceptable for the Fire PRA. Fire wraps are not credited in the Fire PRA for high hazard sources (i.e. high energy arcing fault (HEAF)).

Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-48 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status Updates to applicable documentation are still needed to ensure it is clear how the affects of mechanical damage or direct flame impingement are handled in the Fire PRA. This documentation update will not affect the results of the Fire PRA. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FSS-D9 CC I The self-assessment states that no equipment was felt to be sensitive to smoke damage therefore no evaluation for smoke damage effects was performed. An assumption that no smoke damage occurs needs to be justified. Current CC: Met CC II/III

As discussed in the disposition of Finding FSS-D9-01 in Table V-1, the current analysis accounts for the affects of smoke damage. Updates to applicable documentation are still needed to ensure it is clear how the affects of smoke damage were accounted for. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FSS-F3 CC I At the time of the review, Table 22 on page 31 of 34 in report FPRA-PI-SS, Revision A, has not been completed and a quantitative assessment has not been done. The quantitative assessment table exists in the report but needs the values for CDF and LERF entered into it. This SR is considered met at a CC I level because Table 19 in notebook PINGP-FPRA-PI-SS provides fire scenario frequencies that will be used in the quantification task. Current CC: Met II/III

The fire scenarios developed in the Structural Steel notebook were examined, and it was determined all fire scenarios contained initiators that were previously evaluated during compartment analysis. Their anticipated damage targets were then compared with the Plant Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-49 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status Damage States (PDS) already assigned to the initiators. The plant damage states were found to be equal to or bounding for all target sets determined in the Structural Steel notebook. Therefore, no new scenarios need to be added into the quantification task, as existing scenarios already evaluate all initiators and damage states found during the structural steel-fire interaction analysis. The resolution of this finding is documentation related and will not affect the results of the Fire PRA.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FSS-G6 Not Met Requirement is to quantify the risk contribution of any selected multi-compartment fire scenarios consistent with the FQ requirements. Quantification seems generally similar to FQ. It is noted that CCDPs are assumed to be 1 for combined areas. Multi-compartment fire CCDPs currently add up to mid-E-4 range, this is conservative. Need realistic evaluations for unscreened scenarios. No LERF information is provided, need to provide LERF. Current CC: Met II/III Realistic estimates of multi-compartment CCDPs and CLERPs were developed following the peer review. These new results have been incorporated into the Fire PRA and are reflected in the final quantification results.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FSS-H5 CC I There were two (2) Findings that were issued against Supporting Requirement FSS-H2. Finding FSS-H5-01 identified that the Detailed Compartment Analysis notebook was cumbersome and difficult to interpret. Finding FSS-H5-02 identified that the Detailed Compartment Analysis notebook did not include detailed documentation related to scenario specific parameter uncertainty evaluations. Current CC: Met I Resolution of this finding involves suggested improvements to documentation for the Fire PRA. Since no change to the model is required, Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-50 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status Fire PRA results are not affected. Further enhancements to the Detail Compartment Analysis notebook are needed to show compliance with Capability Category II.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. IGN-B5 Not Met Although there is a section in the Ignition Frequency notebook entitled Assumptions, it does not appear to be complete. Current CC: Not Met Resolution of this finding involves suggested improvements to documentation that would consolidate all the assumptions that could affect the Fire Ignition Frequency notebook. Since no change to the model is required, Fire PRA results are not affected. This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FQ-A2 Not Met The quantification process currently assumes BOTH units experience a Reactor Trip with loss of PCS for EVERY scenario. Although it is reasonable to assume a reactor trip with PCS is initiated by each fire initiator, assuming a dual unit trip is overly restrictive, and is masking real risk insights. A review of "opposite unit" equipment failures needs to be performed to determine if a dual unit trip is realistic, and if it is not - then do not assume one. Current CC: Met I/II/III Since comprehensive cable tracing for all systems that could result in a plant trip has not been done, it cannot be assured that a fire in a compartment on one unit will not also affect the other unit. The prudent approach is to make a moderately conservative assumption to bound the range of possibilities. An opposite unit trip for a containment fire was eliminated from the model. Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-51 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status This correction had only a very minimal impact on overall risk results and did not have any impact on FRE results since the opposite unit from a containment fire does not credit recovery actions.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FQ-E1 Not Met There are several identified fire scenarios that have been removed from the quantification results. These scenarios were removed to prevent the skewing of the importance calculations. This removal was noted in the notebook so that when detailed analysis of the removed scenarios was performed the removed scenarios would be included in the total CDF and LERF. Current CC: Met I/II/III All scenarios, and especially the most risk significant ones have been revised to add further detail and credit fire modeling and mitigation. All scenarios are now included in the final results.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. FQ-F1 Not Met This SR is not met due to the fact that the Quantification notebook contains many areas that are not complete (Tables 5-9, 5-10, 5-11, etc.). There is a good discussion of the top cutsets. Current CC: Not Met

The Fire Quantification notebook that was completed to support the peer review contained the necessary sections to address what was captured in the peer review Finding. Relevant sections from the peer reviewed Fire Quantification notebook have been updated via an amended PRA Calculation to be consistent with the Fire PRA analysis that was used to Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-52 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status support the NFPA 805 LAR. Documentation updates are needed to consolidate the peer reviewed quantification notebook and the amended Fire Quantification PRA Calculation. This documentation upgrade will not affect the results of the Fire PRA.

This finding is considered open until the Fire PRA notebooks and analysis are updated to completely address this issue. UNC-A1 Not Met Task discussions and Table 2 in UNC notebook provide identification of some sources of model uncertainty. However the team identified additional sources which should be explored. Task discussions and Table 2 in the UNC notebook provide identification of some assumptions. However, the team determined that assumptions were stated or implied in the various notebooks which were not addressed. The uncertainty intervals associated with parameter uncertainties were estimated and an estimate of the uncertainty interval of the CDF results was prepared. Some potential sources of uncertainty were neglected.

Referenced SR QU-E4 states: "For each source of model uncertainty and related assumption identified in QU-E1 and QU-E2, respectively, IDENTIFY how the PRA model is affected (e.g., introduction of a new basic event, changes to basic event probabilities, change in success criterion, introduction of a new initiating event) [Note (1)]." This referenced element has not been satisfied. There are a number of assumptions and sources of uncertainty whose impact was not provided. LERF sources of model uncertainty were identified and characterized similar to CDF. Discussion related to CDF above applies equally to LERF. Current CC: Not Met

The resolution of this finding involves reviewing the Fire PRA documentation and including all assumptions in the Uncertainty and Sensitivity notebook. Completing this analysis is not expected to have an affect on the Fire PRA results, but a better understanding of the sources of uncertainty. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. UNC-A2 Not Met This SR says: INCLUDE the treatment of uncertainties, including their documentation, as called out in SRs PRM-A4, FQ-F1, IGN-A10, IGN-B5, FSS-E3, FSS-E4, FSS-H5, FSS-H9, and CF-A2 and that required by performing Part 2 referenced requirements throughout this Standard. Several of these back Current CC: Not Met The resolution of this finding involves reviewing the Fire PRA documentation to identify each Northern States Power - Minnesota Attachment V - Fire PRA Quality PINGP Page V-53 Table V-2 Fire PRA-Summary of Category I and Not Met SRs SR Capability Category Topic Status referenced requirements were not met. Statistical representations of the uncertainty intervals for the parameters used for modeling significant fire scenarios were identified for HRA, data, and ignition frequencies. However uncertainty information was not provided for other parameters, such as generic modeling factors. No characterization of uncertainties associated with cable routing was identified. source of uncertainty and characterize how it could impact the Fire PRA in the Uncertainty and Sensitivity notebook. Completing this analysis is not expected to have an affect on the Fire PRA results, but a better understanding of the sources of uncertainty. This finding is considered open until the Fire PRA notebooks are updated to completely address the issue. Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-1 W. Fire PRA Insights 31 Pages Attached Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-2 W.1 Fire PRA Overall 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. The risk insights generated were useful in identifying areas where specific contributors might be mitigated via modification. A detailed description of significant risk sequences associated with the fire initiating events that individually represent any sequences contributing more than 1% of the calculated fire risk for the plant was prepared for the purposes of gaining these insights which included the contribution from MSO combinations. These insights are provided in Tables W-1 through W-4. Fire scenarios were selected based on the definition of 'significant accident sequence' from RG 1.200, Revision 2: Significant accident sequence: A significant sequence is one of the set of sequences, defined at the functional or systemic level that, when ranked, compose 95% of the CDF or the LERF/LRF, or that individually contribute more than ~1% to the CDF or LERF/LRF. There are 38 fire scenarios comprising 71% of the total Unit 1 fire CDF that contribute more than 1% to the total on an individual basis. These scenarios are presented in Table W-1. There are 12 fire scenarios comprising 63% of the total Unit 1 fire LERF that contribute more than 1% to the total on an individual basis. These scenarios are presented in Table W-2. There are 28 fire scenarios comprising 56% of the total Unit 2 fire CDF that contribute more than 1% to the total on an individual basis. These scenarios are presented in Table W-3. There are 28 fire scenarios comprising 72% of the total Unit 2 fire LERF that contribute more than 1% to the total on an individual basis. These scenarios are presented in Table W-4. For each scenario, Tables W-1 through W-4 identify a Conditional Core Damage Probability (CCDP) and Conditional Large Early Release Probability (CLERP) which are combined with a Fire Ignition Frequency (IF) to determine CDF and LERF values. W.2 Risk Change Due to NFPA 805 Transition In accordance with the guidance in Regulatory Position 2.2.4.2 of RG 1.205 Revision 1: "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." Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-3 The PINGP fire area risk summary is provided in Tables W-5 (Unit 1) and W-6 (Unit 2). Delta CDF and Delta LERF From Tables W-5 and W-6, the total additional risk due to recovery actions is:

• 9.00E-06/rx-yr / 8.69E-07/rx-yr, respectively for Unit 1 CDF and LERF* 8.87E-06/rx-yr / 9.57E-07/rx-yr, respectively for Unit 2 CDF and LERFThis risk increase due to Recovery Actions shown above is below the threshold for Region II of RG 1.174, Revision 2 Figures 4 and 5, which are 1E-5/rx-yr (DCDF) and 1E-6/rx-yr (DLERF). In addition, plant modifications were identified that reduce the cumulative DCDF and DLERF. The credit for these modifications is included in both variant and compliant cases in Tables W-5 and W-6. These modifications were incorporated into the Fire PRA Model to reduce the overall risk. Incorporation of these modifications also eliminated much of the risk impact for several Variances from Deterministic Requirements (VFDRs). The risk benefit from these modifications can be used to offset the additional risk due to recovery actions shown above. The risk benefit was estimated within a sensitivity study by eliminating two modifications (low leakage RCP seals and incipient detection for cabinets in the Relay Room (FA18)) from the variant case. The resulting risk reduction due to including these modifications is shown below:
• 2.50E-04/rx-yr / 2.35E-05/rx-yr, respectively for Unit 1 CDF and LERF* 2.41E-04/rx-yr / 3.10E-05/rx-yr, respectively for Unit 2 CDF and LERFWhen risk reduction from these modifications is combined with the additional risk due to recovery actions, the result is a net risk decrease associated with the transition to NFPA 805. Therefore, the total change in risk associated with the transition to NFPA 805 represents a risk decrease, and the acceptance criteria of RG 1.174 are met. Total CDF and LERF Although not required for a net risk decrease, total plant risk is estimated in order to provide additional perspective.

The total plant risk is lower than the RG 1.174 limits for total plant risk of 1E-04/yr for CDF or 1E-05/yr for LERF. More specifically, the total plant risk estimated by summing the contributions from internal events (including internal floods), fires, and estimates for external events yield a total plant CDF and LERF of approximately 8.43E-05/rx-yr / 4.00E-06/rx-yr, respectively for Unit 1 and 9.84E-05/rx-yr / 7.15E-06/rx-yr, respectively for Unit 2. These numbers are below the 1E-04/yr and 1E-05/yr thresholds for CDF and LERF, respectively.

Both the internal events and internal flooding contribution to total plant risk are values from a sensitivity study that credits a plant modification and procedure changes that are listed in Attachment S. These changes include installation of Shutdown Reactor Coolant Pump seals, development of a process to depressurize the Reactor Coolant Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-4 System and use alternate low pressure makeup sources. Without crediting these described changes, the total plant risk would exceed the RG 1.174 limits noted above. Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-5 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1FDS-8GRP-FA69 Turbine Building Ground Floor & Mezzanine Floors Unit 1 695, 715 10.05% Full compartment burn of FA 69; initiator results in damage to cables supporting Unit 1 4kV Bus 16 and both offsite supplies to both Bus 15 and 16, 12 MDAFW pump. Dominant sequences include failure of D1 EDG and failure of operator action to cross-tie Unit 2 4kV buses to Unit 1 (SBO), followed by failure of operator action to trip the RCPs and failure of the RCP shutdown seal to successfully actuate. 1.93E-04 2.70E-02 5.20E-06 U1-MCR-FS-EC-14-CDF Main Control Room - Electrical Cabinet - 14 6.07% Fire initiated in MCR Panel 1PLP that is successfully suppressed but that fails all panel equipment; includes failure of SG pressure instrumentation supporting AFW manual start and control; core damage occurs with operator failure to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 2.47E-02 1.27E-04 3.14E-06 U1FDS-22 480V Safeguards Switchgear (Bus 121) 4.93% Full compartment burn of FC 22; initiator results in loss of 480V AC Buses 121 and 122 as well as loss of 12 CC pump and 12 AFW pump. Dominant core damage sequences involve failure of either the operators to manually start the 11 AFW pump, or failure of the pump to start or run, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 1.99E-03 1.28E-03 2.55E-06 U1FDS-20 Unit 1 4.16 KV Safeguards Swgr (Bus 16) 3.81% Full compartment burn of FC 20; initiator results in loss of 4kV AC Bus 16. Dominant core damage sequences involve failure of either the operators to manually start the 11 AFW pump, or failure of the pump to start or run, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 2.20E-03 8.94E-04 1.97E-06 U1FDS-32 B Train Hot Shutdown Panel & Air Compressor/Aux Feedwater Room 2.49% Transient fire leading to hot gas layer in FC 32 (or other fires with failure of automatic suppression) leading to full room burn; initiator results in loss of power to 4kV Bus 15, the CT and D2 sources to Bus 16, and OCT failures on Bus 25; dominant sequences include random failure of the Bus 16 load sequencer or Bus 16 circuit breaker failures to open resulting in failure of bus voltage restoration (SBO with inability to restore power from offsite). 2.87E-04 4.50E-03 1.29E-06 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-6 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1FDS-81 4.16 KV Safeguard Switchgear Room (Bus 15) 1.78% Full compartment burn of FC 81; initiator results in loss of 4kV AC Bus 15 and loss of both offsite sources to Unit 1. Dominant core damage sequences involve failure of D2 EDG to start or run and failure of the operators to perform Bus 16 manual voltage restoration from Bus 26 (SBO), together with failure of the local manual operator action to control SG level or failure of the RCP shutdown seal to successfully actuate, resulting in an unrecoverable RCP seal LOCA. 1.02E-03 9.07E-04 9.22E-07 U1FDS-28 Yardgroup 1.78% Full compartment burn of FC 28; initiator results in a loss of the 1RY and 2RY transformers supply to safeguards 4kV buses on both units, as well as the loss of non-safeguards 4kV buses 13, 14, 23, and 24. Dominant sequences include failure of the operators to manually start AFW and to cross-tie to the Unit 2 (21) motor-driven AFW pump (or random failures of 12 MDAFWP occur), and the operators fail to successfully initiate bleed and feed RCS cooling. 3.52E-05 2.61E-02 9.19E-07 U1FDS-18-1002-00 Relay and Cable Spreading Room - 1002 1.66% Computer room cabinet fire with successful suppression; initiator results in loss of 11 and 12 CC pump trains, 11 and 12 RHR pump trains, and 4kV non-safeguards buses 13 and 23, and spurious opening of CV-31121 and CV-31124 (Unit 1 and Unit 2 condenser makeup from the CSTs). Dominant sequences include failure of the operator response action to isolate CV-31121 and CV-31124, and failure to align Cooling Water to the AFW pumps when the CST supply is lost. 6.56E-04 1.31E-03 8.60E-07 U1-MCR-FS-TRAN-20-CDF Main Control Room - Transient - 20 1.59% MCR transient fire impacting all offsite power sources to 4kV buses 15 and 16, bus sequencers and D1 and D2 EDGs; overcurrent trips fail bus cross-tie from Unit 2 4kV buses (SBO). Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 9.01E-01 9.14E-07 8.24E-07 U1FDS-18-1077-00 Relay and Cable Spreading Room - 1077 1.58% Fire initiated in Relay Room 120V AC Panel 112 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.49E-02 3.28E-05 8.18E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-7 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1FDS-18-1003-00 Relay and Cable Spreading Room - 1003 1.56% Fire initiated in Relay Room Panel 1AP1 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.45E-02 3.28E-05 8.05E-07 U1FDS-18-1004-00 Relay and Cable Spreading Room - 1004 1.56% Fire initiated in Relay Room Panel 1AP2 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.45E-02 3.28E-05 8.05E-07 U1FDS-18-1032-00 Relay and Cable Spreading Room - 1032 1.56% Fire initiated in Relay Room Panel 2AP2 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.45E-02 3.28E-05 8.05E-07 U1-MCR-FS-TRAN-22-CDF Main Control Room - Transient - 22 1.52% MCR transient fire impacting 11, 12, 22 Cooling Water (CL) pumps. Dominant core damage sequences involve MCR abandonment and failure fo the operators to successfully perform alternate shutdown from outside the MCR. 8.27E-04 9.53E-04 7.89E-07 U1FDS-8GRP-69GRP Turbine Building - 69GRP 1.44% Full compartment burn of 69GRP; initiator results in damage to cables supporting D2 EDG and both offsite supplies to both Bus 15 and 16; dominant sequences include failure of D1 EDG and failure of operator action to cross-tie Unit 2 4kV buses to Unit 1 (SBO), followed by failure of operator action to trip the RCPs and failure of the RCP shutdown seal to successfully actuate. 5.75E-05 1.30E-02 7.47E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-8 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1FDS-8GRP-ALL Unit 1 and Unit 2 Turbine Buildings El. 679©, 695©, 715© 1.30% T/G oil or H2 fire with failure of fire detection or suppression resulting in catastrophic failure of the turbine and loss of all credited equipment in the Turbine Building (8GRP); initiator causes loss of cables and other support equipment leading to loss of all sources to all 4kV AC buses (EDG D5 remains available to repower Bus 25 via manual operator action). Dominant sequences include successful action to re-power Bus 25 followed by failure to repower Bus 15 from Bus 25 (SBO) and operator failure to control level in Unit 1 SGs prior to offsite power restoration. 4.73E-05 1.42E-02 6.71E-07 U1FDS-34 Battery Room 12 1.28% Full compartment burn of FC 34; initiator results in loss of 125V DC Bus 12. Dominant core damage sequences involve failure of either the operators to manually start the 11 AFW pump, or failure of the pump to start or run, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 9.34E-04 7.07E-04 6.60E-07 U1-MCR-FS-TRAN-15-CDF Main Control Room - Transient - 15 1.27% MCR transient fire impacting U1 charging, letdown, and safety injection (SI). Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 2.34E-04 2.81E-03 6.57E-07 U1-MCR-FS-TRAN-14-CDF Main Control Room - Transient - 14 1.27% MCR transient fire impacting Unit 1 AFW system and pressurizer PORVs. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 2.31E-04 2.84E-03 6.56E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 9 1.24% MCR transient fire impacting panels 1RCS1, 1CVCS2, and 1PLP. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 2.53E-02 2.55E-05 6.44E-07 U1-MCR-FS-TRAN-13-CDF Main Control Room - Transient - 13 1.24% MCR transient fire impacting panels 1CVCS2, 1PLP and 1SD. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 2.48E-02 2.59E-05 6.43E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-9 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1FDS-41GRP Screenhouse (General Area) 1.21% Full compartment burn of 41GRP (either detection or suppression failure); results in loss of all Cooling Water (CL), Circulating Water (CW), 4kV Bus 23, and spurious closure of RHR discharge control valves to low head injection. Dominant sequences include consequential loss of offsite power followed by failure of operator action to cross-tie Unit 1 4kV buses to Unit 2 (SBO), AFW success but offsite power is not recovered in time to prevent core uncovery and core damage. 8.45E-05 7.40E-03 6.25E-07 U1-MCR-FS-TRAN-18-CDF Main Control Room - Transient - 18 1.18% MCR transient fire impacting Unit 2 Charging, Letdown, and Safety Injection (SI). Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.29E-05 1.86E-02 6.12E-07 U1FDS-8GRP-FA8 Turbine Deck (Units 1 & 2) 735 1.18% Full compartment burn of FA 8; initiator results in a loss of non-safeguards 480V Bus 260, and control power to non-safeguards 4kV Bus 11 (11 RCP and 11 FW pump). Dominant sequences include failure of the operators to manually start AFW and to cross-tie to the Unit 2 (21) motor-driven AFW pump (or the 21 MDAFWP is unavailable due to preventive maintenance), and the operators fail to successfully initiate bleed and feed RCS cooling. 1.85E-05 3.30E-02 6.09E-07 U1-MCR-FS-TRAN-19-CDF Main Control Room - Transient - 19 1.17% MCR transient fire impacting Unit 2 AFW system and pressurizer PORVs. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.29E-05 1.84E-02 6.05E-07 U1-MCR-FS-TRAN-21-CDF Main Control Room - Transient - 21 1.17% MCR transient fire impacting all offsite power sources to 4kV buses 25 and 26, bus sequencers and D5 and D6 EDGs; overcurrent trips fail bus cross-tie from Unit 1 4kV buses (SBO). Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.95E-05 1.53E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 6 1.17% MCR transient fire impacting Nuclear Instrumentation Protection Channel III, 24MR and panels 2G, 2M, 1R, 1M and 1G. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-10 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1-MCR-FS-TRAN CDF Main Control Room - Transient - 7 1.17% MCR transient fire impacting Nuclear Instrumentation Protection Channels I, II, III, and IV, and panels 2G, 2M, 1R, 1M and 1G. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 8 1.17% MCR transient fire impacting Rack #21, panel 1RCS1, and the Incore Detector Panel. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 2 1.17% MCR transient fire impacting panels 2RCS1, 2CVCS2, and 2PLP. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 1 1.17% MCR transient fire impacting RMS cabinets I and II, panel 1RCS1, and the Incore Detector Panel. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 3 1.17% MCR transient fire impacting panels 2CVCS2, 2PLP and 2SD. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 4 1.17% MCR transient fire impacting panels 2PLP and 2SD and 2B1 Protection Set II and III. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN CDF Main Control Room - Transient - 5 1.17% MCR transient fire impacting panels 2SD, 2B1 Protection Set II and III and 2R1 Protection Set I and IV. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN-10-CDF Main Control Room - Transient - 10 1.17% MCR transient fire impacting panels Protection Set I and IV and Panel 1SD. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-11 Table W-1 Fire Initiating Events for Unit 1 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U1-MCR-FS-TRAN-11-CDF Main Control Room - Transient - 11 1.17% MCR transient fire impacting the Incore Detector Panel and Nuclear Instrumentation Protection Channel III. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1-MCR-FS-TRAN-12-CDF Main Control Room - Transient - 12 1.17% MCR transient fire impacting the Incore Detector Panel and Nuclear Instrumentation Protection Channels I, II, III, and IV. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 3.31E-05 1.83E-02 6.05E-07 U1FDS-31 "A" Train Hot Shutdown Panel & Air Compressor/Aux. Feedwater Pump Room 1.11% Full compartment burn of FA 31; initiator results in loss of 2RY transformer, damage to cables supporting all power sources to Unit 1 4kV Bus 16 and the CT-11 offsite supply to Bus 15; loss of Cooling Water (CL) header B and Train B AFW; dominant sequences include failure of the AFW supply to Unit 1 SGs (due to spurious closure of 11 AFW pump discharge MOVs and operator failure to re-open them, or failure of the operator to manually start AFW), and failure of operator action to initiate RCS bleed and feed cooling. 2.19E-04 2.62E-03 5.75E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-12 Table W-2 Fire Initiating Events for Unit 1 LERF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution CLERP IF LERF U1-MCR-FS-TRAN-15-LERF Main Control Room - Transient - 15 19.65% 1.05E-05 5.77E-02 6.07E-07 U1-MCR-FS-TRAN-21-LERF Main Control Room - Transient - 21 19.57% 1.30E-06 4.66E-01 6.05E-07 U1FDS-8GRP-FA69-L Turbine Building Ground Floor & Mezzanine Floors Unit 1 695, 715 5.53% 6.43E-06 2.66E-02 1.71E-07 U1-MCR-FS-EC-14-LERF Main Control Room - Electrical Cabinet 1PLP 4.75% 1.11E-03 1.33E-04 1.47E-07 U1FDS-22-L 480V Safeguards Switchgear (Bus 121) 715 3.53% 8.52E-05 1.28E-03 1.09E-07 U1FDS-20-L Unit 1 4.16 KV Safeguards Swgr, (Bus 16) 715 2.40% 8.31E-05 8.94E-04 7.43E-08 U1FDS-32-L "B" Train Hot Shutdown Panel & Air Compressor/Aux Feedwater Room 695 1.91% 1.36E-05 4.35E-03 5.90E-08 U1FDS-18-1077-00-L Relay and Cable Spreading Room - 1077 1.24% 1.17E-03 3.28E-05 3.82E-08 U1FDS-18-1003-00-L Relay and Cable Spreading Room - 1003 1.22% 1.15E-03 3.28E-05 3.76E-08 U1FDS-18-1004-00-L Relay and Cable Spreading Room - 1004 1.22% 1.15E-03 3.28E-05 3.76E-08 U1FDS-18-1032-00-L Relay and Cable Spreading Room - 1032 1.22% 1.15E-03 3.28E-05 3.76E-08 U1FDS-18-1002-00-L Relay and Cable Spreading Room - 1002 1.18% 2.79E-05 1.31E-03 3.66E-08 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-13 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-8GRP-FA70 Turbine Building Ground Floor & Mezzanine Floors Unit 2 695, 715 5.18% Full compartment burn of FA 70; initiator results in damage to cables supporting normal offsite supply to Unit 2 4kV Bus 25 (2RY transformer), loss of both Bus 25 and 26 load sequencers and loss of the 22 AFW pump; dominant sequences include random failure of 21 AFW pump (or operator failure to restore offsite power to Bus 25 via the CT12 source) with failure of operator action to cross-tie 12 AFW pump to Unit 2 (or random failure of 12 AFW pump), followed by failure of operator action to initiate RCS bleed and feed cooling. 1.19E-04 2.85E-02 3.38E-06 U2-MCR-FS-EC-10-CDF Main Control Room - Electrical Cabinet - 10 4.82% Fire initiated in MCR Panel 2PLP that is successfully suppressed but that fails all panel equipment; includes failure of SG pressure instrumentation supporting AFW manual start and control; core damage occurs with operator failure to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 2.48E-02 1.27E-04 3.14E-06 U2FDS-58GRP-004 Aux Building Ground Floor - 004 3.68% Full compartment burn of 58GRP-004; initiator results in damage to cables supporting all AC sources to Unit 2 4kV Bus 25, all offsite AC sources to 4kV Bus 26, and 22 RHR pump; dominant sequences include random failure of 22 AFW pump (or operator failure to manually initiate AFW). 3.63E-03 6.61E-04 2.40E-06 U2FDS-118 4KV Bus 26; MCC 2TA2 Room 3.53% Full compartment burn of FC 118; initiator results in loss of Unit 2 4kV Bus 26, all offsite AC sources to 4kV Bus 25, and loss of 21 RHR train; dominant sequences include random failure of 21 AFW pump (or operator failure to manually initiate AFW) together with operator failure to initiate RCS bleed and feed cooling, or D5 EDG failure with failure of the operators to provide power to Bus 25 through the bus-tie to Unit 1 Bus 15 (SBO) and failure of either operator action to locally control level in the SGs prior offsite power recovery, or failure of the RCP shutdown seal followed by failure to trip the RCPs leading to a large, unrecoverable RCP seal LOCA. 1.93E-03 1.19E-03 2.30E-06 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-14 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-8GRP-ALL Unit 1 and Unit 2 Turbine Buildings El. 679©, 695©, 715© 3.19% T/G oil or H2 fire with failure of fire detection or suppression resulting in catastrophic failure of the turbine and loss of all credited equipment in the Turbine Building (8GRP); initiator causes loss of cables and other support equipment leading to loss of all sources to all 4kV AC buses (EDG D5 remains available to repower Bus 25 via manual operator action), and loss of the 22 turbine-driven AFW pump. Dominant sequences include failure of operator action to re-power Bus 25 from D5 (SBO) leading to an unrecoverable RCP seal LOCA. 1.46E-04 1.42E-02 2.08E-06 U2FDS-59GRP-053 Aux Building Mezzanine Level - 053 2.76% Full compartment burn of 59GRP-053; initiator results in loss of 2RY transformer, OCT failures of Bus 26 breakers for 22 RHR, SI and CC pumps, D6 EDG and bus-tie breaker to Bus 16; failure of both pressurizer PORVs open function, and loss of 22 AFW pump; dominant sequences include random failure of 21 AFW pump (or operator failure to manually initiate AFW) and failure of operator action to locally cross-tie the 12 AFW pump to Unit 2 (or random failures of the 12 AFW pump) or common-cause failure of the 12 and 21 AFW pumps. 6.87E-03 2.62E-04 1.80E-06 U2FDS-22 480V Safeguards Switchgear (Bus 121) 2.68% Full compartment burn of FC 22; initiator results in loss of 4kV AC Buses 25 and 26 load sequencers, loss of control power to Bus 26, loss of non-safeguards 4kV buses 21, 22, 23, and 24, as well as loss of 22 AFW pump and loss of control power for starting the D6 EDG and 22 CL pump. Dominant core damage sequences involve failure of either the operators to manually start the 21 AFW pump, or failure of the pump to start or run, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. 1.37E-03 1.28E-03 1.75E-06 U2-MCR-FS-TRAN-19-CDF Main Control Room - Transient - 19 2.36% MCR transient fire impacting Unit 2 AFW system and pressurizer PORVs. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR, or successful suppression of the fire (precluding MCR abandonment) but failure of operator action to cross-tie the 12 motor-driven AFW pump to Unit 2 (or random failures of the 12 AFW pump). 1.58E-01 9.72E-06 1.54E-06 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-15 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-80 480V Safeguards Switchgear (Bus 111) 1.93% Full compartment burn of FC 80; initiator results in loss of safeguards 480V AC Buses 111 and 112, loss of the 4kV AC Bus 25 and 26 load sequencers, unavailability of the Bus 25 to Bus 15 bus-tie due to OCT trips, and loss of non-safeguards 4kV buses 21, 22, 23, and 24, as well as loss of the 12 CL pump. Dominant sequences include consequential loss of offsite power (SBO), where AFW is successful but offsite power is not recovered in time to prevent core uncovery and core damage. 9.55E-04 1.32E-03 1.26E-06 U2FDS-101GRP D5 Diesel Generator Rooms 1.67% Full compartment burn of FC 101GRP; initiator results in loss of all sources of power to safeguards 4kV AC Bus 25 except the preferred source (2RY), loss of the Bus 25 load sequencer, loss of most safeguards loads on Bus 25 and the bus-tie to Bus 15 due to OCT trips, and loss of safeguards 480V buses 211 and 212. Dominant sequences include failure of either the operators to manually start the 22 AFW pump, or failure of the pump to start or run, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. Other risk significant sequences include failure of the operators to manually start the 22 CC pump (auto-start not credited in the Fire PRA), with pressurizer PORV lift following the initial plant transient and failure to reseat resulting in an unrecoverable small LOCA; and random failures of 480V Bus 221. 4.24E-04 2.57E-03 1.09E-06 U2FDS-59GRP-014 Aux Building Mezzanine Level - 014 1.66% Full compartment burn of FC 59GRP-014; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for both pressurizer PORVs, and loss of the AFW pump supply to the Unit 2 SGs due to instrumentation failures. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 3.29E-02 3.28E-05 1.08E-06 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-16 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-59GRP-051 Aux Building Mezzanine Level - 051 1.62% Full compartment burn of FC 59GRP-051; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for pressurizer PORV CV-31233, loss of 21 RWST instrumentation, and loss of the AFW pump supply to the Unit 2 SGs due to instrumentation failures. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 3.23E-02 3.28E-05 1.06E-06 U2FDS-58GRP-002 Aux Building Ground Floor - 002 1.58% Full compartment burn of FDS-58GRP-002; initiator results in loss of all sources of power to safeguards 4kV AC Bus 25 and the 2RY transformer, loss of the Bus 25 load sequencer, loss of most safeguards loads on Bus 25 and the bus-tie to Bus 15 due to OCT trips, loss of safeguards 480V buses 211 and 212, and loss of both pressurizer PORVs. Dominant sequences include failure of either the operators to manually start the 22 AFW pump, or failure of the pump to start or run, together with failure of the operator action to manually cross-tie the 12 AFW pump to the Unit 2 SGs (or random failures of the 12 AFW pump). 1.11E-03 9.24E-04 1.03E-06 U2FDS-102GRP D6 Diesel Generator Rooms 1.52% Full compartment burn of FC 102GRP; initiator results in loss of all sources of power to safeguards 4kV AC Bus 26 , loss of the Bus 26 load sequencer, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, and loss of safeguards 480V buses 221 and 222. Dominant sequences include failure of either the operators to manually initiate AFW, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. Other risk significant sequences include failure of the operators to manually start the 21 CC pump (auto-start not credited in the Fire PRA), with pressurizer PORV lift following the initial plant transient and failure to reseat resulting in an unrecoverable small LOCA; and random failures of 480V Bus 211. 3.63E-04 2.73E-03 9.91E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-17 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-59GRP-073 Aux Building Mezzanine Level - 073 1.50% Full compartment burn of FC 59GRP-073; initiator results in loss of 2RY transformer, loss of D6 source to safeguards 4kV AC Bus 26 and most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for one pressurizer PORV (CV-31233), and loss of the 22 AFW pump supply to the Unit 2 SGs due to instrumentation failures. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 4.55E-03 2.15E-04 9.79E-07 U2FDS-28 Yardgroup 1.48% Full compartment burn of FC 28; initiator results in a loss of the 1RY and 2RY transformers supply to safeguards 4kV buses on both units, as well as the loss of non-safeguards 4kV buses 13, 14, 23, and 24. Dominant sequences include failure of the operators to manually start AFW and to cross-tie to the Unit 1 (12) motor-driven AFW pump (or random failures of 12 MDAFWP occur), and the operators fail to successfully initiate bleed and feed RCS cooling. 3.71E-05 2.61E-02 9.68E-07 U2FDS-8GRP-70GRP-1 Turbine Building - 70GRP-1 1.39% Full compartment burn of 70GRP-1; initiator results in loss of 2RY transformer, loss of both Bus 25 and 26 load sequencers, loss of control power to 4kV safeguards Bus 26 and D6 diesel generator, and loss of 22 AFW pump; dominant sequences include random failure of 21 AFW pump (or operator failure to restore offsite power to Bus 25 via the CT12 source) with failure of operator action to cross-tie 12 AFW pump to Unit 2 (or random failure of 12 AFW pump), followed by failure of operator action to initiate RCS bleed and feed cooling, or random failures of the SI system or RCS PORVs. 9.88E-05 9.16E-03 9.05E-07 U2FDS-110 D6 Normal MCC & Cable Tray Area (Grounding Cabinet) 1.38% Full compartment burn of FC 110; initiator results in loss of Unit 2 4kV Bus 26, all offsite AC sources to 4kV Bus 25, and loss of 21 RHR train; dominant sequences include random failure of 21 AFW pump (or operator failure to manually initiate AFW) together with operator failure to initiate RCS bleed and feed cooling, or D5 EDG failure with failure of the operators to provide power to Bus 25 through the bus-tie to Unit 1 Bus 15 (SBO) and failure of either operator action to locally control level in the SGs prior offsite power recovery, or failure of the RCP shutdown seal followed by failure to trip the RCPs leading to a large, unrecoverable RCP seal LOCA. 1.80E-03 4.98E-04 8.97E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-18 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-59GRP-008 Aux Building Mezzanine Level - 008 1.33% Full compartment burn of FC 59GRP-008; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for one pressurizer PORV (CV-31233), and loss of the 22 AFW pump. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 2.64E-02 3.28E-05 8.66E-07 U2FDS-18-1088-00 Relay and Cable Spreading Room - 1088 1.25% Fire initiated in Relay Room 120V AC Panel 212 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control (but only one channel each, AFW remains available); dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.50E-02 3.28E-05 8.19E-07 U2-MCR-FS-TRAN-21-CDF Main Control Room - Transient - 21 1.25% MCR transient fire impacting all offsite power sources to 4kV buses 25 and 26, bus sequencers and D5 and D6 EDGs; overcurrent trips fail bus cross-tie from Unit 1 4kV buses (SBO). Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 1.05E-01 7.77E-06 8.17E-07 U2FDS-18-1031-00 Relay and Cable Spreading Room - 1031 1.23% Fire initiated in Relay Room Panel 2AP1 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.46E-02 3.28E-05 8.05E-07 U2FDS-18-1068-00 Relay and Cable Spreading Room - 1068 1.23% Fire initiated in Relay Room Panel AC24 that is successfully suppressed (incipient detection and manual suppression success) but that fails all panel equipment; initiator fails SG pressure instrumentation supporting AFW manual start and control; dominant core damage sequences involve operator failure to initiate bleed and feed RCS cooling or transfer to high head recirculation. 2.46E-02 3.28E-05 8.05E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-19 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2FDS-122 480V Bus 221/222 Room 1.22% Full compartment burn of FC 122; initiator results in loss of Unit 2 480V Buses 221 and 222, 125V DC Panel 22, D6 EDG source to 4kV Bus 26, and 22 AFW pump. Dominant sequences include failure of either the operators to manually start 21 AFW pump, together with failure of the operator action to either to initiate bleed and feed RCS cooling or to perform transfer to high head recirculation. Other risk significant sequences include failure of the operators to manually start CC flow (auto-start not credited in the Fire PRA), with pressurizer PORV lift following the initial plant transient and failure to reseat resulting in an unrecoverable small LOCA; and random failures of 480V Bus 211. 3.44E-04 2.32E-03 7.97E-07 U2FDS-59GRP-013 Aux Building Mezzanine Level - 013 1.17% Full compartment burn of FC 59GRP-013; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for both pressurizer PORVs, and loss of the 22 AFW pump. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 1.16E-02 6.56E-05 7.64E-07 U2FDS-59GRP-019 Aux Building Mezzanine Level - 019 1.11% Full compartment burn of FC 59GRP-019; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for one pressurizer PORV (CV-31233), and loss of the 22 AFW pump. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 2.20E-02 3.28E-05 7.22E-07 U2FDS-59GRP-048 Aux Building Mezzanine Level - 048 1.08% Full compartment burn of FC 59GRP-048; initiator results in loss of 2RY transformer, D6 source to safeguards 4kV AC Bus 26, loss of most safeguards loads on Bus 26 and the bus-tie to Bus 16 due to OCT trips, loss of safeguards 480V MCCs 2A2, 2KA2 and 2LA2, failure of the open function for one pressurizer PORV (CV-31233), and loss of the 22 AFW pump. Dominant sequences include failure of either the operators to manually cross-tie the 12 AFW pump to the Unit 2 SGs, or random failures of the pump to start or run. 3.27E-03 2.15E-04 7.02E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-20 Table W-3 Fire Initiating Events for Unit 2 CDF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution Risk insights CCDP IF CDF U2-MCR-FS-TRAN-18-CDF Main Control Room - Transient - 18 1.02% MCR transient fire impacting Unit 2 Charging pumps and spurious operation of SI MOVs, failing high head recirculation. Dominant core damage sequences involve MCR abandonment and failure for the operators to successfully perform alternate shutdown from outside the MCR. 9.13E-04 7.25E-04 6.62E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-21 Table W-4 Fire Initiating Events for Unit 2 LERF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution CLERP IF LERF U2-MCR-FS-TRAN-21-LERF Main Control Room - Transient - 21 10.30% 6.30E-03 9.89E-05 6.23E-07 U2-MCR-FS-TRAN-15-LERF Main Control Room - Transient - 15 10.10% 2.04E-06 3.00E-01 6.11E-07 U2FDS-59GRP-053-L Aux Building Mezzanine Level - 053 4.56% 1.05E-03 2.62E-04 2.76E-07 U2-MCR-FS-EC-10-LERF Main Control Room - Electrical Cabinet 2PLP 4.07% 1.89E-03 1.30E-04 2.46E-07 U2FDS-8GRP-FA70-L Turbine Building Ground Floor & Mezzanine Floors Unit 2 695, 715 3.47% 7.47E-06 2.81E-02 2.10E-07 U2FDS-58GRP-004-L Aux Building Ground Floor - 004 3.06% 2.80E-04 6.61E-04 1.85E-07 U2FDS-59GRP-014-L Aux Building Mezzanine Level - 014 2.76% 5.09E-03 3.28E-05 1.67E-07 U2FDS-59GRP-051-L Aux Building Mezzanine Level - 051 2.73% 5.03E-03 3.28E-05 1.65E-07 U2FDS-8GRP-ALL-L Turbine Deck (Units 1 & 2) 2.68% 1.14E-05 1.42E-02 1.62E-07 U2FDS-59GRP-008-L Aux Building Mezzanine Level - 008 2.22% 4.09E-03 3.28E-05 1.34E-07 U2FDS-118-L 4KV Bus 26; MCC 2TA2 Room 718 2.02% 1.03E-04 1.19E-03 1.22E-07 U2FDS-22-L 480V Safeguards Switchgear (Bus 121) 715 1.98% 9.38E-05 1.28E-03 1.20E-07 U2FDS-80-L 480V Safeguard Switchgear Room (Bus 111) 715 1.97% 9.02E-05 1.32E-03 1.19E-07 U2FDS-59GRP-013-L Aux Building Mezzanine Level - 013 1.93% 1.78E-03 6.56E-05 1.17E-07 U2-MCR-FS-TRAN-19-LERF Main Control Room - Transient - 19 1.88% 8.95E-03 1.27E-05 1.14E-07 U2FDS-59GRP-019-L Aux Building Mezzanine Level - 019 1.85% 3.41E-03 3.28E-05 1.12E-07 U2FDS-59GRP-048-L Aux Building Mezzanine Level - 048 1.79% 5.02E-04 2.15E-04 1.08E-07 U2FDS-59GRP-060-L Aux Building Mezzanine Level - 060 1.57% 1.15E-04 8.23E-04 9.49E-08 U2FDS-59GRP-047-L Aux Building Mezzanine Level - 047 1.29% 3.64E-04 2.15E-04 7.82E-08 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-22 Table W-4 Fire Initiating Events for Unit 2 LERF Representing > 1% Contribution to the Calculated Fire Risk Scenario Description Contribution CLERP IF LERF U2FDS-58GRP-002-L Aux Building Ground Floor - 002 1.24% 8.13E-05 9.24E-04 7.51E-08 U2FDS-59GRP-073-L Aux Building Mezzanine Level - 073 1.24% 3.49E-04 2.15E-04 7.51E-08 U2FDS-101GRP-L D5 Diesel Generator Rooms 1.16% 2.72E-05 2.57E-03 7.00E-08 U2FDS-8GRP-70GRP L Turbine Building - 70GRP-1 1.14% 7.53E-06 9.16E-03 6.90E-08 U2FDS-102GRP-L D6 Diesel Generator Rooms 1.14% 2.52E-05 2.73E-03 6.87E-08 U2FDS-18-1088-00-L Relay and Cable Spreading Room - 1088 1.06% 1.95E-03 3.28E-05 6.39E-08 U2FDS-18-1031-00-L Relay and Cable Spreading Room - 1031 1.04% 1.92E-03 3.28E-05 6.29E-08 U2FDS-18-1068-00-L Relay and Cable Spreading Room - 1068 1.04% 1.92E-03 3.28E-05 6.29E-08 U2FDS-59GRP-062-L Aux Building Mezzanine Level - 062 1.02% 4.46E-04 1.38E-04 6.16E-08 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-23 Table W-5 PINGP Unit 1 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Containment Unit 1 4.2.4.2 1.32E-07 / 4.24E-09 Yes No N/A N/A Ventilation Fan Room, Units 1 & 2 4.2.4.2 1.71E-07 / 3.80E-09 Yes Yes 1.71E-07 / 3.80E-09 1.71E-07 / 3.80E-09 Water Chiller Room 4.2.3.2 2.78E-08 / 6.51E-10 No No N/A N/A Fuel Handling Area 4.2.3.2 2.48E-07 / 6.86E-09 No No N/A N/A Old Administration Building 4.2.3.2 screened No No N/A N/A Old Administration Building, HVAC Equipment Area 4.2.3.2 / No No N/A N/A Old Administration Building, Office Area 4.2.3.2 screened No No N/A N/A Turbine Building 4.2.3.2 7.82E-06 / 2.68E-07 No No N/A N/A Train A Event Monitoring Equipment Room 4.2.4.2 1.24E-07 / 4.34E-09 Yes Yes 1.24E-07 / 4.34E-09 1.24E-07 / 4.34E-09 Unit 1 Normal Switchgear & Control Rod Drive Room 4.2.3.2 2.21E-07 / 6.33E-09 No No N/A N/A OSC Room 4.2.3.2 1.25E-08 / 3.34E-10 No No N/A N/A Control Room 4.2.4.2 2.00E-05 / 1.87E-06 Yes Yes 8.03E-06 / 8.36E-07 8.03E-06 / 8.36E-07 Working Material, Lunch Room 4.2.3.2 / No No N/A N/A Access Control 4.2.3.2 9.30E-08 / 3.46E-09 No No N/A N/A Train B Event Monitoring Equipment Room 4.2.3.2 2.06E-08 / 1.89E-10 No No N/A N/A Unit 2 Normal Switchgear Room & Control Rod Drive Room 4.2.3.2 1.12E-07 / 2.75E-09 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-24 Table W-5 PINGP Unit 1 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Relay & Cable Spreading Room 4.2.4.2 4.69E-06 / 2.09E-07 Yes Yes 2.78E-08 / 2.04E-09 2.78E-08 / 2.04E-09 Unit 1 4.16kV Safeguards Switchgear (Bus 16) 4.2.4.2 1.97E-06 / 7.43E-08 Yes Yes / / 480V Safeguards Switchgear (Bus 121) 4.2.4.2 2.55E-06 / 1.09E-07 Yes Yes / / Oil Storage Area 4.2.3.2 screened No No N/A N/A Diesel Generator 1 Room 4.2.3.3 1.37E-07 / 4.76E-09 Yes No N/A N/A Diesel Generator 2 Room 4.2.3.2 1.12E-07 / 3.84E-09 No No N/A N/A Water Conditioning Equipment Area 4.2.3.2 9.91E-08 / 2.29E-09 No No N/A N/A Transformers 4.2.3.2 9.19E-07 / 3.20E-08 No No N/A N/A Administration Building Elect & Piping Room #1 4.2.4.2 5.58E-10 / 0 Yes Yes 5.58E-10 / 0 5.58E-10 / 0 Administration Building Elect & Piping Room #2 4.2.4.2 7.15E-08 / 2.36E-09 Yes Yes 7.15E-08 / 2.36E-09 7.15E-08 / 2.36E-09 A Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room 4.2.4.2 5.94E-07 / 2.54E-08 Yes Yes / / B Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room 4.2.4.2 1.30E-06 / 5.93E-08 Yes Yes / / Battery Room 11 4.2.3.2 3.11E-07 / 1.21E-08 No No N/A N/A Battery Room 12 4.2.3.2 1.04E-06 / 4.49E-08 No No N/A N/A Battery Room 21 4.2.3.2 3.36E-08 / 6.71E-10 No No N/A N/A Battery Room 22 4.2.3.2 2.59E-07 / 1.06E-08 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-25 Table W-5 PINGP Unit 1 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Unit 1 480V Normal Switchgear Room 4.2.4.2 1.44E-07 / 4.04E-09 Yes Yes 1.44E-07 / 4.04E-09 1.44E-07 / 4.04E-09 Unit 2 480V Normal Switchgear Room 4.2.4.2 9.93E-08 / 2.75E-09 Yes Yes 9.93E-08 / 2.75E-09 9.93E-08 / 2.75E-09 Screenhouse (General Area) 4.2.3.2 / No No N/A N/A Screenhouse (DDCLP Rooms) 4.2.4.2 3.33E-07 / 1.41E-08 Yes Yes 3.33E-07 / 1.41E-08 3.33E-07 / 1.41E-08 Screenhouse Basement Below Grade 4.2.4.2 6.47E-07 / 2.54E-08 Yes Yes / / Cooling Tower Equipment House and Transformers 4.2.3.2 2.70E-07 / 8.60E-09 No No N/A N/A Gas House 4.2.3.2 screened No No N/A N/A Auxiliary Building Ground Floor Units 1 and 2 4.2.4.2 1.57E-07 / 6.75E-09 Yes Yes / / Auxiliary Building Mezzanine Level Units 1 and 2 4.2.4.2 3.50E-07 / 2.18E-08 No No N/A N/A Aux Building Operating Level Unit 1 4.2.3.2 1.65E-07 / 5.58E-09 No No N/A N/A Aux Building Anti "C" Clothing Area 4.2.3.2 Included in FA 4 - - - - Filter Room 4.2.3.2 1.39E-08 / 3.51E-10 No No N/A N/A Aux Building Low Level Decay Area Unit 1 4.2.3.2 1.11E-08 / 2.86E-10 No No N/A N/A Spent Fuel Pool Heat Exchanger & Pumps 4.2.3.2 included in FA 60 - - - - D3 Lunch Room 4.2.4.2 2.12E-08 / 5.73E-10 Yes Yes / / Containment and Containment Annulus Unit 2 4.2.3.2 N/A N/A N/A N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-26 Table W-5 PINGP Unit 1 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Auxiliary Building Operating Level Unit 2 4.2.3.2 1.56E-08 / 2.62E-10 No No N/A N/A Auxiliary Building Low Level Decay Area Unit 2 4.2.3.2 3.49E-09 / 5.36E-11 No No N/A N/A Waste Gas Compressor Area 4.2.3.2 2.55E-08 / 5.33E-10 No No N/A N/A 480V Safeguard Switchgear Room (Bus 112) 4.2.3.2 5.07E-08 / 1.56E-09 No No N/A N/A 480V Safeguard Switchgear Room (Bus 111) 4.2.4.2 2.54E-07 / 8.48E-09 Yes Yes / / 4.16KV Safeguard Switchgear Room (Bus 15) 4.2.4.2 9.22E-07 / 2.74E-08 Yes Yes / / 480V Safeguard Switchgear Room (Bus 122) 4.2.3.2 5.06E-08 / 1.55E-09 No No N/A N/A Operators Lounge 4.2.3.2 1.82E-08 / 5.50E-10 No No N/A N/A Counting Room and Labs 4.2.3.2 1.94E-08 / 4.73E-10 No No N/A N/A Hold-up Tank Area/Demineralizer Area 4.2.3.2 1.73E-08 / 1.86E-09 No No N/A N/A Intake Screenhouse 4.2.3.2 1.93E-07 / 5.45E-09 No No N/A N/A Guard House 4.2.3.2 included in FA 28 - - - - Emergency Generator Building 4.2.3.2 screened No No N/A N/A Water Chiller Room Unit 2 4.2.3.2 2.93E-08 / 6.83E-10 No No N/A N/A Service Building/Computer Room 4.2.3.2 9.81E-08 / 3.10E-09 No No N/A N/A D5 Diesel Generator Building 4.2.4.2 3.91E-07 / 1.14E-08 Yes Yes / / D6 Diesel Generator Building 4.2.3.2 3.77E-07 / 1.09E-08 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-27 Table W-5 PINGP Unit 1 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs #21 D5/D6 Fuel Oil Receiving Tank (South of D6 Room) 4.2.3.2 included in FA 28 - - - - Emergency Diesel Generator 3 & 4 Building 4.2.3.2 included in FA 28 - - New Administration Building 4.2.3.2 screened No No Total 5.17E-05 / 3.09E-06 9.00E-06 / 8.69E-07 Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-28 Table W-6 PINGP Unit 2 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Containment Unit 1 4.2.4.2 N/A N/A N/A N/A N/A Ventilation Fan Room, Units 1 & 2 4.2.4.2 1.31E-07 / 5.11E-09 Yes Yes 1.31E-07 / 5.11E-09 1.31E-07 / 5.11E-09 Water Chiller Room 4.2.3.2 2.80E-08 / 1.17E-09 No No N/A N/A Fuel Handling Area 4.2.3.2 2.46E-07 / 1.14E-08 No No N/A N/A Old Administration Building 4.2.3.2 screened - - - - Old Administration Building, HVAC Equipment Area 4.2.3.2 / No No N/A N/A Old Administration Building, Office Area 4.2.3.2 screened - - - - Turbine Building 4.2.3.2 7.69E-06 / 5.19E-07 No No N/A N/A Train A Event Monitoring Equipment Room 4.2.4.2 2.35E-08 / 4.63E-10 Yes Yes 2.35E-08 / 4.63E-10 2.35E-08 / 4.63E-10 Unit 1 Normal Switchgear & Control Rod Drive Room 4.2.3.2 1.27E-07 / 5.08E-09 No No N/A N/A OSC Room 4.2.3.2 1.26E-08 / 5.55E-10 No No N/A N/A Control Room 4.2.4.2 2.09E-05 / 2.17E-06 Yes Yes 8.10E-06 / 9.00E-07 8.10E-06 / 9.00E-07 Working Material, Lunch Room 4.2.3.2 / No No N/A N/A Access Control 4.2.3.2 2.95E-08 / 1.63E-09 No No N/A N/A Train B Event Monitoring Equipment Room 4.2.3.2 2.22E-08 / 4.47E-10 No No N/A N/A Unit 2 Normal Switchgear Room & Control Rod Drive Room 4.2.3.2 3.22E-07 / 1.48E-08 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-29 Table W-6 PINGP Unit 2 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Relay & Cable Spreading Room 4.2.4.2 3.00E-06 / 2.18E-07 Yes Yes 2.81E-08 / 3.46E-09 2.81E-08 / 3.46E-09 Unit 1 4.16 KV Safeguards Switchgear, (Bus 16) 4.2.4.2 4.29E-08 / 1.46E-09 Yes Yes / / 480V Safeguards Switchgear (Bus 121) 4.2.4.2 1.75E-06 / 1.20E-07 Yes Yes / / Oil Storage Area 4.2.3.2 screened - - - - Diesel Generator 1 Room 4.2.3.3 7.61E-08 / 4.09E-09 Yes No N/A N/A Diesel Generator 2 Room 4.2.3.2 7.51E-08 / 4.06E-09 No No N/A N/A Water Conditioning Equipment Area 4.2.3.2 8.47E-08 / 3.31E-09 No No N/A N/A Transformers 4.2.3.2 9.68E-07 / 5.33E-08 No No N/A N/A Administration Building Elect & Piping Room #1 4.2.4.2 5.13E-10 / 0 Yes Yes 5.13E-10 / 0 5.13E-10 / 0 Administration Building Elect & Piping Room #2 4.2.4.2 5.36E-08 / 3.01E-09 Yes Yes 5.36E-08 / 3.01E-09 5.36E-08 / 3.01E-09 A Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room 4.2.4.2 7.51E-07 / 5.00E-08 Yes Yes 9.95E-08 / 7.29E-09 9.95E-08 / 7.29E-09 B Train Hot Shutdown Panel & Air Compressor/Auxiliary Feedwater Room 4.2.4.2 1.58E-07 / 1.08E-08 Yes Yes / / Battery Room 11 4.2.3.2 2.76E-07 / 1.66E-08 No No N/A N/A Battery Room 12 4.2.3.2 1.94E-08 / 5.49E-10 No No N/A N/A Battery Room 21 4.2.3.2 2.83E-07 / 1.67E-08 No No N/A N/A Battery Room 22 4.2.3.2 2.59E-07 / 1.85E-08 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-30 Table W-6 PINGP Unit 2 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Unit 1 480V Normal Switchgear Room 4.2.4.2 1.26E-07 / 6.20E-09 Yes Yes 1.26E-07 / 6.20E-09 1.26E-07 / 6.20E-09 Unit 2 480V Normal Switchgear Room 4.2.4.2 8.33E-08 / 4.11E-09 Yes Yes 8.33E-08 / 4.11E-09 8.33E-08 / 4.11E-09 Screenhouse (General Ara) 4.2.3.2 / No No N/A N/A Screenhouse (DDCLP Rooms) 4.2.4.2 7.05E-08 / 2.66E-09 Yes Yes 7.05E-08 / 2.66E-09 7.05E-08 / 2.66E-09 Screenhouse Basement Below Grade 4.2.4.2 5.73E-08 / 1.68E-09 Yes Yes / / Cooling Tower Equipment House and Transformers 4.2.3.2 2.69E-07 / 1.42E-08 No No N/A N/A Gas House 4.2.3.2 screened - - - - Aux Building Ground Floor Units 1 and 2 4.2.4.2 3.54E-06 / 2.67E-07 Yes Yes / / Auxiliary Building Mezzanine Level Units 1 and 2 4.2.4.2 1.24E-06 / 1.90E-07 Yes Yes 1.50E-07 / 2.43E-08 1.50E-07 / 2.43E-08 Aux Building Operating Level Unit 1 4.2.3.2 1.67E-08 / 4.50E-10 No No N/A N/A Aux Building Anti "C" Clothing Area 4.2.3.2 Included in FA 4 - - - - Filter Room 4.2.3.2 1.40E-08 / 5.93E-10 No No N/A N/A Aux Building Low Level Decay Area Unit 1 693 4.2.3.2 1.10E-08 / 4.72E-10 No No N/A N/A Spent Fuel Pool Heat Exchanger & Pumps 4.2.3.2 included in FA 60 - - N/A N/A D3 Lunch Room 4.2.4.2 1.57E-07 / 9.19E-09 Yes Yes / / Containment and Containment Annulus Unit 2 4.2.4.2 3.55E-08 / 2.06E-09 Yes No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-31 Table W-6 PINGP Unit 2 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs Auxiliary Building Operating Level Unit 2 4.2.3.2 1.70E-07 / 1.01E-08 No No N/A N/A Auxiliary Building Low Level Decay Area Unit 2 4.2.3.2 3.53E-09 / 7.29E-11 No No N/A N/A Waste Gas Compressor Area 4.2.3.2 2.60E-08 / 9.85E-10 No No N/A N/A 480V Safeguard Switchgear Room (Bus 112) 4.2.3.2 3.08E-08 / 1.34E-09 No No N/A N/A 480V Safeguard Switchgear Room (Bus 111) 4.2.4.2 1.26E-06 / 1.19E-07 Yes Yes / / 4.16KV Safeguard Switchgear Room (Bus 15) 4.2.4.2 3.93E-08 / 1.59E-09 Yes Yes / / 480V Safeguard Switchgear Room (Bus 122) 4.2.3.2 3.08E-08 / 1.34E-09 No No N/A N/A Operators Lounge 4.2.3.2 1.83E-08 / 9.41E-10 No No N/A N/A Counting Room and Labs 4.2.3.2 1.96E-08 / 7.94E-10 No No N/A N/A Hold-up Tank Area/Demineralizer Area 4.2.3.2 1.13E-08 / 1.53E-09 No No N/A N/A Intake Screenhouse 4.2.3.2 1.94E-07 / 9.29E-09 No No N/A N/A Guard House 4.2.3.2 included in FA 28 - - - - Emergency Generator Building 4.2.3.2 screened - - - - Water Chiller Room Unit 2 4.2.3.2 2.96E-08 / 1.23E-09 No No N/A N/A Service Building/Computer Room 4.2.3.2 3.86E-07 / 1.71E-08 No No N/A N/A D5 Diesel Generator Building 4.2.4.2 2.35E-06 / 1.38E-07 Yes Yes / / D6 Diesel Generator Building 4.2.3.2 5.19E-06 / 2.96E-07 No No N/A N/A Northern States Power - Minnesota Attachment W - Fire PRA Insights PINGP Page W-32 Table W-6 PINGP Unit 2 Fire Area Risk Summary Fire Area Area Description NFPA 805 Basis Fire Area CDF/LERF VFDR (Yes/No) RAs Fire Risk Eval CDF/LERF Additional Risk of RAs #21 D5/D6 Fuel Oil Receiving Tank (South of D6 Room) 4.2.3.2 included in FA 28 - - - - Emergency Diesel Generator 3 & 4 Building 4.2.3.2 included in FA 28 - - - - New Administration Building 4.2.3.2 screened - - - - Total 6.51E-05 / 6.05E-06 8.87E-06 / 9.57E-07 Notes for Tables W-5 and W-6 Where "screened" appears in the Fire Area CDF/LERF column, it indicates that all fire compartments in the fire area were qualitatively screened per the methodology in Task 4 of NUREG/CR-6850. The symbol designates CDF and LERF values that are insignificant because of their low numerical value. In most cases, the CDF and LERF values were not determined because the cutsets were below the truncation limit for quantification. The CDF and LERF values for all recovery actions are included as part of the FRE CDF and LERF values. Thus, the column "Additional risk of RAs" shows the contribution of recovery actions to the FRE CDF and LERF values and is not a separate, extra risk. It can be seen that for some fire areas, the FRE CDF and LERF value is dominated by the additional risk of recovery actions, or can be attributed in its entirety to such recovery actions. In a few cases, VFDRs were identified in a fire area that were resolved by proposed modifications. For these areas, an FRE was not quantified.]]