ML12326A999

Donald C, Cook, Units 1 and 2 - Enclosure 1, 2 & 4 to AEP-NRC-2012-101, Response to Second-Round RAI Item 54.b, and Submittal of Revised Tables Re the Application for Amendment to Transition to National Fire Protection Association Standard

ML12326A999
Person / Time
Site:	Cook
Issue date:	11/09/2012
From:	Indiana Michigan Power Co
To:	Office of Nuclear Reactor Regulation
References
TAC ME6629, TAC ME6630, AEP-NRC-2012-101
Download: ML12326A999 (74)

Text

Enclosure I to AEP-NRC-2012-101 AFFIRMATION I, Michael H. Carlson, being duly sworn, state that I am Site Support Services Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.Indiana Michigan Power Company Michael H. Carlson Site Support Services Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS q4G- DAY OFK DALm} r, 2012 My Commission Expires L o Enclosure 2 to AEP-NRC-2012-101 Identification of Documents Referenced in this Letter References

1. Letter from M. H. Carlson, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket Nos. 50-315 and 50-316, Request for License Amendment to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," AEP-NRC-2011-1, dated July 1,2011, ADAMS Accession No. ML111188A145.

2. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket Nos. 50-315 and 50-316, Supplement to Request for License Amendment to Adopt National Fire Protection Association (NFPA) 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)," AEP-NRC-2011-62, dated September 2, 2011, ADAMS Accession No. ML 11256A030.

3. Letter from P. S. Tam, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 -Request for Additional Information on the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos.ME6629 AND ME6630)," dated January 27, 2012, ADAMS Accession Nos. ML1 13560709, ML12003A186, and ML12017A251.

4. E-Mail from P. S. Tam, NRC, to H. L. Etheridge, J. R. Waters, M. K. Scarpello, I&M, et al.,"D.C. Cook -Draft RAI re. Transition to NFPA 805, Questions in Health Physics (TAC ME6629 and ME6630)," dated March 22, 2012, ADAMS Accession No.ML12082A043.

5. Letter from M. H. Carlson, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Response to Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805, (TAC Nos. ME6629 AND ME6630)," AEP-NRC-2012-29, dated April 27, 2012, ADAMS Accession No. ML12132A390.

6. Letter from J. P Gebbie, I&M, to NRC Document Control Desk, "Response to Second Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos.ME6629 AND ME6630)," AEP-NRC-2012-47, dated June 29, 2012, ADAMS Accession No.ML12195A013.

7. Letter from M. H. Carlson, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Response to. Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805, (TAC Nos. ME6629 AND ME6630)," AEP-NRC-2012-58, dated August 9, 2012, ADAMS Accession No. ML12242A246.

Enclosure 2 to AEP-NRC-2012-101 Page 2 8. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 -Request for Additional Information on the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos.ME6629 AND ME6630)," dated October 11, 2012, ADAMS Accession No. ML12276A344.

9. Letter from M. H. Carlson, I&M, to NRC Document Control Desk, "Response to Second Round Request for Additional Information Regarding the Application for Amendment to Transition the Fire Protection Program to National Fire Protection Association Standard 805 (TAC Nos. ME6629 and ME6630)," AEP-NRC-2012-92, dated October 15, 2012, ADAMS Accession No. MLI122970218.

Enclosure 4 to AEP-NRC-2012-101 Revision 1 of Transition Report Attachment A, Table B-1, "Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805, Chapter 3)" Changes are indicated by red text and revision bars in the right margin.

Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A A. NEI 04-02 Table B-1 -Transition of Fundamental FPP and Design Elements 146 Pages Revision I Page A-I Revision 1 Page A- 1 Indiana Michiden Power CNP NFPA 805 Transition ReDW -Affachment A Atanchment P -NFP 805 Tabtn B T i F e r c -Anm A Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.1 General This 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. N/A -Section Heading, see sub-sections for any specific compliance statements.

9 N/A N/A -Section Heading, see sub- N/A sections for any specific compliance statements.

3.2 Fire Protection Plan N/A

• N/A N/A -Section Heading, see sub- N/A sections for any specific compliance statements.

3.2.1 Intent

A site-wide fire protection plan shall

• Complies A site-wide fire protection PMI-2270, *Fire Protection Programn, be established.

This plan shall program (FPP) has been Rev. 30, All Sections document management policy and established.

The purpose of the program direction and shall define CNP FPP is to incorporate, FPPM, Rev. 11, Section 3 the responsibilities of those identify and discuss the individuals responsible for the applicable commitments, plan's implementation.

This section documents, administrative establishes the criteria for an controls, departmental integrated combination of responsibilities and activities components, procedures, and which together form the CNP personnel to implement all fire FPP.protection program activities.

elf T" MC_%1 !.tf, 11 Taai Oull .n f0lownmb owl Vallis 1." Revision I Page A-2 Indiana Michidan Power CNP NFPA 805 Transfflon Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.2.2 Management A policy document shall be 0 Complies The FPP procedure defines PMI-2270, 'Fire Protection Program', Policy Direction and prepared that defines management management authority and Rev. 30, All Sections Responsibility authority and responsibilities and responsibilities and establishes establishes the general policy for the general policy for the site FPPM, Rev. 11, Section 3 the site fire protection program. FPP.3.2.2.1 [Management The policy document shall Cormples The Plant Manager is PMI-2270, *Fire Protection Program', Policy on Senior designate the senior management responsible for development, Rev. 30, Section 3.1 Management]

position with immediate authority implementation, and periodic and responsibility for the fire assessment of the CNP FPP. FPPM, Rev. 11, Section 3.7 protection program.3.2.2.2 [Management The policy document shall

• Compli The Fire Protection Program PMI-2270, -Fire Protection Program', Policy on Dally designate a position responsible for Manager is responsible for Rev. 30, Section 3.1.4 Administration]

the daily administration and assuring adequate coordination of the fire protection implementation of the overall FPPM, Rev. 11, Section 3.7 program and its implementation.

FPP.3.2.2.3 [Management The policy document shall define Complies PMI-2270 identifies the various PMI-2270, 'Fire Protection Program', Policy on Interfaces]

the fire protection interfaces with plant positions having the Rev. 30, Section 3.1.4 other organizations and assign authority for implementing the responsibilities for the coordination various areas of the FPP. The FPPM, Rev. 11, Sections 3.7.1.2.1, of activities.

In addition, this policy FPPM identifies interfaces 3.7.1.3.1 and 3.7.1.4.2 document shall identify the various between the FPP and other plant positions having the authority organizations.

for implementing the various areas of the fire protection program.3.2.2.4 [Management The policy document shall identify , Complies The AHJ is identified in CNP PMI-2270, "Fire Protection Program', Policy on AHJ] the appropriate AHJ for the various Procedure PMI-2270 and in the Rev. 30 areas of the fire protection program. FPPM.FPPM, Rev. 11 RTeWvisin M Page A- 13f Revision I Page A-3 Indiana Michican Power CNP NFPA 805 Transition ReDort -Affachment A Atanchment Power PoP anF 805 Trmntsi RNFP r 8 apten A Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.2.3 Procedures Procedures shall be established for 9 Complies implementation of the fire protection program. In addition to procedures 9 Complies with that could be required by other Required Action sections of the standard, the procedures to accomplish the following shall be established:

Complies: Procedures have been established for implementation of the FPP. These procedures accomplish the requirements outlined in the sub-sections of this element PMI-2270, "Fire Protection Program', Rev. 30, All Sections Complies with Required Action: Technical documents and procedures that relate to new FP design and licensing basis (e.g., Fire Protection Program Manual (FPPM), Technical Requirements Manual, Design Basis Document, maintenance and surveillance, configuration control, training and qualification guidelines, Quality Assurance Program Document (QAPD), etc.) will be revised as needed for implementation of NFPA 805.Refer to Implementation Item S-3.10.FPE RAI 59 T~wI~n inO ssCsisjdsg1.2.0 iim2 Reviion Pag A-Revision I Paige A-4 Indiana Michican Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.2.3 Procedures (1)Inspection, testing, and maintenance for fire protection systems and features credited by the fire protection program.e Compies with clarification Complies with clarification:

Procedures have been established for inspection, testing, and maintenance for fire protection systems and features credited by the FPP. Where practical, performance-based surveillance frequencies may be established as described in Electric Power Research Institute (EPRI) Technical Report (TR) 1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features".

PMI-4030, "Technical Specification Surveillance Test Program", Rev. 34, All Sections PMP-2291-PLN-001, "Work Control Activity Planning Process', Rev. 40, All Sections 12-FPP-2270-066 Series 1-EHP-4030-166 Series 2-EHP-4030-266 Series Electric Power Research Institute (EPRI) Technical Report (TR)1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features" 3.2.3 Procedures (2) Compensatory actions implemented

• Complies Procedures have been PMI-2270, "Fire Protection Program", when fire protection systems and established to implement Rev. 30 other systems credited by the fire compensatory actions when fire protection program and this protection systems and other PMP-2291-PLN-001, "Work Control standard cannot perform their systems credited by the FPP Activity Planning Process", Rev. 40, intended function and limits on cannot perform their intended All Sections impairment duration function.12-FPP-2270-066-013, "Control of Inoperable Fire Protection Systems, Structures, or Components", Rev. 1, All Sections 1V3W12 TMMiniU =dmmwm I 0 Vuuien 1.2 Revision 1 Page A-5 Indiana Michigan Power CNP NFPA 805 TransWon Report -Affachtnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.2.3 Procedures (3)Reviews of fire protection program -related performance and trends* Complies with Required Action Procedures have been established for reviewing performance and trends of the FPP.Required Action: The 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 of the Transition Report for details.PMI-4030, "Technical Specification Surveillance Test Program', Rev. 34, Section 3.2.4 PMP-2291-PLN-001, 'Work Control Activity Planning Process', Rev. 40, All Sections CNP Fire Protection Monitoring Program PMP-7034-SAP-001, "Conduct of Self-Assessments", Rev. 20 AR GT2010-13233, "Actions to Support Implementation of NFPA 805'3.2.3 Procedures (4)Reviews of physical plant modifications and procedure changes for impact on the fire protection program.Compies Procedures have been established for reviews of physical plant modifications and procedure changes for impact on the FPP.PMP-5043-CCD-001, 'Configuration Change Determinations', Rev. 28 12-EHP-2270-FPIR-001, 'Fire Protection Program Impact Review', Rev. 1, All Sections PMP-2270-EVL-002, 'Evaluation of Fire Protection Program Changes', Rev. 4, All Sections 12-EHP-2270-EVL-001, 'Preparation and Approval of Fire Protection Technical Evaluations', Rev. 0 OTPT "rDACyl.lltb 1l&O122 Tmi wn l ub Vwms., 1.,.0 Revision I Page A-6 Indiana Michidan Power CNP NFPA 805 Transilion Report -Affachnient A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.2.3 Procedures (5)Long-term maintenance and configuration of the fire protection program° Complies Procedures have been established for long-term maintenance and configuration of the FPP.PMP-5043-CCD-001, "Configuration Change Determinations", Rev. 28 12-EHP-2270-FPIR-001, "Fire Protection Program Impact Review", Rev. 1, AUl Sections PMP-2270-EVL-002, "Evaluation of Fire Protection Program Changes", Rev. 4, All Sections 12-EHP-2270-EVL-001, "Preparation and Approval of Fire Protection Technical Evaluations", Rev. 0"Quality Assurance Program Description', Rev. 20.3.2.3 Procedures (6) Emergency response procedures

• Complies An emergency response PMP-2270-FRP-001, "Fire Response for the plant industrial fire brigade procedure for the plant industrial Plan", Rev. 11, All Sections fire brigade has been established (Fire Pre-Plan).

CNP Fire Pre-Plans, Volumes I, II, and III, Revisions 9, 7, and 12 respectively

3.3 Prevention

A fire prevention program with the

• Complies The CNP FPP establishes, PMI-2270, "Fire Protection ProgramN, goal of preventing a fire from documents, and implements, Rev. 30, Sections 4.3 and 4.4 starting shall be established, specific requirements for fire documented, and implemented as prevention.

The two basic part of the fire protection program. components of fire prevention The two basic components of the are met as described in the sub-fire prevention program shall sections of this element.consist of both of the following:

WW3W12 Trmuilbn DcwnAru sAO imkiW2- 120 Revision 1 Page A-7 Indiana Michican Power CNP NFPA 805 Tranaftn Repod -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3 Prevention (1)Prevention of fires and fire spread by controls on operational activities 0 Compoie CNP procedures establish PMI-2270, "Fire Protection Program-, controls on operation activities in Rev. 30, Section 4.4 order to prevent fires and fire spread. PMP-2270-WBG-001, "Wekling, Burning and Grindin Actiis, Rev.9, Ali Sections 12-PPP-2270-066-01 1, "Fire Watch Activities", Rev. 5. All Sections PMP-2270-CCM-001, "Control of Combustible Materials", Rev. 8, All Sections 3.3 Prevention (2) Design controls that restrict the use

• Complies CNP procedures establish PMI-2270, "Fire Protection Program", of combustible materials design controls that restrict the Rev. 30, Section 4.3 use of combustible materials.

The design control requirements 12-EHP-2270-FPIR-001, "Fire listed in the remainder of this Protection Program Impact Review", section shall be provided as Rev. 1, All Sections described.

NW30M 2 Tfa .I DncoVC.el.m 12.0 RevsionI2 Pagea amm kl A-B .2I Revision I Page A-.8 Indiana Michioan Power CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1 Fire Prevention for Operational Activities The fire prevention program activities shag 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.Comxrplies CNP procedures establish requirements to address the control of Ignition sources and the use of transient combKustzl~e materials during all aspects of plant operations.

These procedures 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.PMI-2270, "Fire Protection Program, Rev. 30, Sections 4.3 and 4.4 PMP-2270-CCM-001, "Control of Combustible Materials", Rev. 8, All Sections 12-FPP-2270-066-012, "Transient Combustible Monitoring", Rev 7, All Sections PMP-2270-WBG-001, "Welding, Burning, and Grinding Activities", Rev.9, All Sections"Quality Assurance Program Description", Rev. 20.3.3.1.1 General Fire The fire prevention activities shall

• Complies Plant procedures for fire Refer to basis documentation in the Prevention Activities include but not be limited to the prevention activities have been sub-sections of this element.foflowing program elements:

implemented.

The procedures address, at a minimum, the FPP elements identified in this section, but are not limited to these elements.

The NFPA 805 code requirements for this element are satisfied.

I&MM2 T"NM n. AýCO b 12A Revision I Page A-9 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.1 General Fire Training on fire safety information e Complies with I&M establishes training GE-1-7O0, "DC Cook General Prevention Activities (1) for all employees and contractors Required Action requirements for all plant Employee Training', Rev. 12 including, as a minimum, personnel, including plant fire familiarization with plant fire prevention procedures, fire Nuclear Energy Institute (NEI) 04-02, prevention procedures, fire reporting, and familiarization "Guidance for Implementing a Risk-reporting, and plant emergency with plant emergency alarms. Informed, Performance-Based Fire alarms Protection Program under 10 CFR Required Action: 50.48(c), Rev. 21 Section K.3 (FAQ Initial General Employee 06-0028)Training (GET) to be verified and updated, after the LAR AR GT2010-13233, "Actions to approval as part of the FPP Support Implementation of NFPA transition to NFPA 805, to 805" include the minimum FPP elements as discussed in Section K to NEI-04-02 (FAQ 06-0028).

Refer to Attachment S of the Transition Report for details.3.3.1.1 General Fire Documented plant inspections

• Complies CNP procedures establish 12-PPP-2270-066-012, "Transient Prevention Activities (2) including provisions for corrective requirements for spot plant Combustible Monitoring", Rev. 7, All actions for conditions where inspections to ensure that Sections unanalyzed fire hazards are combustibles are properly identified controlled and are not allowed to 12-FPP-2270-066-01 1, *Fire Watch accumulate in amounts that are Activities", Rev. 6, Section 4.1.1 in excess of that analyzed in the Fire Hazards Analysis.

Daily tours by the fire brigade are established.

If problems with conditions or combustible loading are identified, corrective actions are required to be taken.F_' CV.1 .lb M&3M2 TViMluM DIO usMM A COO Va I,.0 Revision I Page A-10 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.1 General Fire Administrative controls addressing Prevention Activities (3) the review of plant modifications and maintenance to ensure that both fire hazards and the impact on plant fire protection systems and features are minimized 9 Complies Procedures have been established for reviews of physical plant modifications and maintenance for impact on the FPP.PMP-5043-CCD-OO1, *Configuration Change Determinations", Rev. 29 12-EHP-2270-FPIR-001, "Fire Protection Program Impact Revw", Rev. 1, All Sections PMP-2270-EVL-00, "Evaluation of Fire Protection Program Changes", Rev. 4, All Sections I 2-EHP-2270-EVL-001, -Preparation and Approval of Fire Protection Technical Evaluations, Rev. 0, All Sections I 2-EHP-5040-MOD-009,'Engineering Change Reference Guide", Rev. 27, All Sections MY30M2 TrsuM DNOAM Os, Os V"Mg I 2A Revision I Page A-11I Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.2 Control of Combustible Materials Procedures 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: " Compies" Complies with Required Action Complies: Plant procedures for the control of general housekeeping practices and the control of transient combustibles have been implemented.

The procedures address, at a minimum, the FPP elements identified in this section, but are not mrited to these elements.I&M believes that the NFPA 805 code requirements for this element are satisfied at CNP.Complies with Required Action: Transient combustible free zones will be established in high risk Fire Areas AA40, AA43, AA48, AA50, AA51, and AA52.Refer to Implementation Item S-3.3.PMP-2270-CCM-001, "Control of Cmbustible Materials", Rev. 8, All Sections 12-PPP-2270-066-012, "Transient Combustible Monitoring", Rev. 7, All Sections PMP-2220-HSK-001, "Housekeeping and Material Condition", Rev. 6, Section 4 FPE RAI 59 1~t~fJ/22 C.= V.,i., 1.2.0 RevsioCI ageA4-12G Revision I Page A-12 Indiana Michidan Power CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.2 Control of Combustible Materials (1)Wood used within the power block shall be fisted 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.* Complies" Complies with clarification e Complies with Required Action Complies: All wood smaller than 6 inch by 6 inch used in the power block is required to be fire-retardant treated.Complies with clarification:

Alternate protection methods may be allowed with Fire Protection Coordinator consent including:

a. Applying a fire retardant paint in accordance with manufacturer's direction Complies with Required Action: Procedure PMP-2270-CCM-001,"Control of Combustible Materials", will be revised and training will be required on the requirements of NFPA 805 Section 3.3.1.2(1).

Refer to Implementation Item S-3.16.PMP-2270-CCM-001, "Control of Combustible Materials", Rev. 8, Section 3.5 FPE RAI 10.01 3.3.1.2 Control of Plastic sheeting materials used in

• Complies All sheet plastic used in the PMP-2270-CCM-001, "Control of Combustible Materials the power block shall be fire- power block is required to meet Combustible Materials', Rev. 8, (2) retardant types that have passed the requirements of NFPA 701. Section 3.4 NFPA 701, "Standard Methods of Fire Tests for Flame Propagation of Textiles and Films" WOAC_V1. 1 .Sb 163W=2 TWOMMff DOGsA Aý Cubo siMW 1+/-.2 Revision I Page A-13 Indiana Michigan Power CNP NFPA 805 Transfflon Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.2 Control of Combustible Materials (3)Waste, debris, scrap, packing materials, or other combustibles shafl be removed from an area immediately following the completion of work or at the end of the shift, whichever comes first.* Complies* Compiles with clarification Complies: Whenever possible, equipment or parts shipped or packed in combustible materials are required to be removed from their shipping crates or containers prior to those items being taken into a safety related area. Those items that cannot be removed from shipping/packing materials may be taken into safety related areas when needed, unpacked and the shipping/packing materials immediately removed.PMP-2270-CCM-001, "Control of Combustible Materials", Rev. 8, Section 3.3 PMP-2220-HSK-001, "Housekeeping and Material Conditiona, Rev. 6, Section 4.6.4 12-FPP-2270-066-012, "Transient Combustible Monitoring", Rev. 7, All Sections 12-EHP-2270-FPIR-001, "Potential Fire Protection Impact", Rev. 2, Attachment 1 Complies with clarification:

All waste, debris, scrap, or other combustibles resulting from an activity Is required to be cleaned up, and stored in proper containers or removed from the area during the work activity, upon completing the activity and/or at the end of each work shift. All waste is required to be disposed of in proper containers.

Procedure PMP-2270-CCM-001,"Control of Combustible Materials," provides guidance for limiting the quantity and duration of combustible materials (e.g., debris, packing materials etc.)for safety-related and critical buildings.

These requirements include: (1) a review by the Fire CW _T0CVu 1.+/-lGorjM~12 TfwwW n~m A Code 12A FPE RAI 10 Reviion Pag A-I Revision I Page A-14 Indlene Michigan Powof CNP NFPA 805 Trwmtion Reml -AttadwrieW A Inin Mcia Poe N!FA85Tasto mot-Atcmn Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Protection Supervisor/Designee for Compensatory actions (e.g., fire watch tour, storage in metal container etc.) if anticipated combustibles are to exceed the Fire Hazards Analysis allowable limits and (2) a review by Fire Protection Engineering to assure that all long term/permanent combustibles comply with licensing bases requirements.

Procedure 12-EHP-2270-FPIR-001, Revision 2, Attachment 1, "Potential Fire Protection Impact," provides guidance for review of combustible loading on fire protection/safe shutdown equipment/components and installation activities.

These controls comply with NFPA 805, Section 3.3.1.2 (4), which allows combustible storage to be used if such storage is in a designated storage/staging area with limits placed on the types and quantities of stored materials.

Additionally, CNP has a "Clean As You Go Policy" as described in Procedure PMP-2220-HSK-001,"Housekeeping and material Condition", to preclude in-situ storage of waste, debris, scrap packing materials, or other combustibles as required by NFPA 805.COW_TAC_V.I.eb 1SIU¶ TMEEM UDOWW AmImO 12A Revision I Page A-15 Revision I Page A-15 Indiana Michican Power CNP NFPA 805 Transition Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.2 Control of Combustible storage or staging

• Compiles Transient combustible storage is PMP-2270-CCM-001, "Control of Combustible Materials areas shall be designated, and controlled on the basis of Combustible Materials", Rev 8, All (4) limits shall be established on the physical location and restricted Sections types and quantities of stored to the limitations set forth in the materials.

individual Fire Safety Analysis CNP Fire Safety Analysis Reports Reports. A permit must be acquired to store transient combustible materials outside of designated transient combustible material storage zones.3.3.1.2 Control of Controls on use and storage of Compies with Complies with clarification:

PMP-2270-CCM-001, -Control of Combustible Materials flammable and combustible liquids clarification Plant procedures are in place to Combustible Materials", Rev. 8, (5) shall be in accordance with NFPA control the use and storage of Section 3.9 30, "Flammable and Combustible

• Complies with use of flammable and combustible Uquids Code, or other applicable EEEEs liquids. These controls use "NFPA 30 Code Compliance NFPA standards." NFPA 30 as a developmental Evaluation for Donald C. Cook reference.

Nuclear Plant Unit 1 and 2", Rev. 0, All Sections No other NFPA Standards were determined to be applicable "Donald C. Cook Nuclear Plant NFPA based on guidance in NEI Code Deviations and Justifications", 04-02, section K.1 (FAQ Rev. 2 06-0020).Nuclear Energy Institute (NEI) 04-02, Complies with use of EEEEs: "Guidance for Implementing a Risk-CNP complies with NFPA 30, Informed, Performance-Based Fire 1987 edition, as evaluated in the Protection Program under 10 CFR CNP NFPA 30 Code 50.48(c)", Rev. 2 / Section K.1 (FAQ Compliance Evaluation.

06-0020)iaWOMW Tw O" co m 1,.2I" Revision I Page A-16 Indiana Michigan Power CNP NFPA 805 Transition Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.2 Control of Combustible Materials (6)Controls on use and storage of flammable gases shall be in accordance with applicable NFPA standards.

9 Compiles with clarification

• Complies with use of EEEEs Complies with clarification:

A plant procedure is in place to control use and storage of flammable gases. These controls use NFPA 50A"Standard for Gaseous Hydrogen Systems at Consumer Sites', as a developmental reference.

No other NFPA Standards were determined to be applicable based on guidance in NEI 04-02, section K.1 (FAQ 06-0020).PMP-2270-CCM-001, 'Control of Combustible Materials', Rev. 8, Section 3.10 Engineering Equivalency Evaluation 14.1.1, "CNP Fire Protection Code Conformance Review', Rev. 0 Nuclear Energy Institute (NEI) 04-02,'Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)', Rev. 2 / Section K.1 (FAQ 06-0020)Complies with use of EEEEs: CNP complies with NFPA 50A, 1999 edition, as evaluated in Engineering Equivalency Evaluation 14.1.1.3.3.1.3 Control of Control of Ignition Sources.

• N/A N/A -Section Heading, see sub- N/A Ignition Sources sections for any specific compliance statements.

W1O2 TwMWon C0t VeWW 12.0 Revision I Page A-17 Indiana Michican Power CNP NFPA 805 Transition Repod -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.3.1

[Control of Ignition Sources Code Requirements]

A hot work safety procedure shall be developed, implemented, and periodically updated as necessary in accordance with NFPA 51 B,"Standard for Fire Prevention During Welding, Cutting, and Other Hot Work", and NFPA 241,"Standard for Safeguarding Construction, Alteration, and Demolition Operations." a Complies with clarification

• Complies with use of EEEEs 9 Complies with Required Action Complies with clarification:

A hot work safety procedure and a fire watch procedure have been developed, Implemented, and ae periodically updated as necessary.

Fire watch personnel may have multiple duties.Complies with use of EEEEs: The hot work safety procedure and fire watch procedure comply with the requirements of NFPA 51B, 1971 Edition, and NFPA 241, 2000 Edition, as evaluated in Engineering Equivalency Evaluation 14.1.1.Complies with Required Action: Hot work restriction zones will be established in high risk Fire Areas AA40, AA43, AA48, AA50, AA51, and AA52. Refer to Implementation Item S-3.4.Procedure PMP-2270-WBG-001, "Welding, Burning and Grinding Activities", will be revised and training will be required on discontinuing the use of (1) video cameras for fire watch and (2) use of a single fire watch for multiple hot work activities.

Refer to Implementation Item S-3.15.PMP-2270-WBG-001, "Welding, Burning and Grinding Activities", Rev.9, All Sections 12-FPP-2270-066-01 1, "Fire Watch Activities", Rev. 5, All Sections Engineering Equivalency Evaluation 14.1.1, "CNP Fire Protection Code Conformance Review", Rev. 0 FPE RAI 59 FPE RAI 9.01 ONtTMlOACVvl 1." Reviion Pag A-I Revision I Page A-.18 Indiana Michidan Power CNP NFPA 805 Transition ReDort -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.3.2

[Control of Smoking and other possible

• Complies Smoklig is not allowed in any PMI-2270, "Fire Protection Program*, Ignition Sources sources of ignition shall be plant building or any other Rev. 30, Section 4.4.2 Smoking Umitations]

restricted to properly designated specific area posted as "No and supervised safe areas of the Smoking', per procedure plant. PMI-2270.

Restrictions for other possible Ignition sources are addressed by sections 3.3.1.3.1, 3, and 4.3.3.1.3.3

[Control of Open flames or combustion-

• Complies Precautions and limitations are 12-FPP-2270-066 Series Ignition Sources for generated smoke shall not be listed for all fire protection Leak Testing] permitted for leak or air flow testing. testing procedures.

These 1 -EHP-4030-166 Series precautions and limitations require that there be no 2-EHP-4030-266 Series deviations from the listed test sequence unless specific instructions to the contrary exist within the test procedure.

Test procedures do not use open flames or combustion-generated smoke for leak or air flow testing.CNO1wC_1.1.0b MM2 Tvalftsn DMUMMM Aý Caf uda" 1.U Revision I Page A-19 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.1.3.4

[Control of Ignition sources on Portable Heaters]Plant administrative procedure shall

• Complies control the use of portable electrical heaters in the plant. Portable fuel-

• Complies with fired heaters shall not be permitted Required Action in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.Complies: CNP procedures control the use of portable electrical heaters in the plant. CNP procedures also require that portable fuel-fired heaters are not permitted in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.Complies with Required Action: I&M will establish an alternate approach for Control Room temporary ventilation that, consistent with GDC-3 and NFPA 805 Section 3.3.1.3.4, does not use portable fuel-fired blowers. The alternate approach will be designed to comply with GDC-3, and to assure there is no impact on radiological releases resulting from a fire.Technical Evaluation R1 900-0026-001, "Recovery Action Transition in Support of NFPA 805", Revision 1, will be revised. Refer to Implementation Item S-3.17.PMP-2270-CCM-001, *Control of Combustible Materials', Rev. 8, Section 3.3.15 and 3.3.14 PMI-2270, *Fire Protection Program", Rev. 30 FPE RAI 18.01 oejTW-..IMt TrWM., DOAR 1.2OO .0 I Reison aeA2 Revision I Page A-20 Indiana Michidan Power CNP NFPA 805 Transffion Repoft -Affachtnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.2 Structural Wails, floors, and components

• Complies required to maintain structural integrity shagl be of noncornbusbble

-Complies by previous constructio, as defined in NFPA NRC approval 220, *Standard on Types of Building Construction.

Complies: Interior walls, floors, and structural components are noncombustible.

Noncombustible is defined by NFPA 220-1999 edition, as a material that, in the form in which it is used and under the conditions anticipated, will not ignite, bum, support combustion, or release flammable vapors when subjected to fire or heat.Complies by previous NRC approval: By the response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.1.(d) I&M stated: "Interior wall and structural components, thermal insulation, radiation shielding, and sound proofing are, to the extent possible, noncombustible or have the UL flame spread, smoke, and fuel contribution rating of 25 or less. Where this was not possible, these materials are protected by other means. In the two cases where this occurred (noted below) the following was done: I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, 1/31/77, item D.l.(d)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to License No. DPR-58 and DPR-74, 7/31179, page 17.12-EHP-2270-FPIR-001, -Fire Protection Program Impact Review', Rev. 1, All Sections CWjrAC-.1¶ l Tamnm DMWN" Mceftvwaw 120 lWm 2 Revision 1 Page A-21 Revision 1 Page A-21 Indiana Michigan Power CNP NFPA 805 Tiansition Report -Affachment A Inin ihanPwrCN FA85Tasto Re~rt Atcmn Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Building expansion or seismic gaps were filled in some cases with urethane or styrene foam plastic to act as a seal to prevent infiltration of air or sand, or to act as non-removable forms between concrete pours.In areas where this material violated fire rated walls or where the material, if ignited, could potentially damage adjacent equipment; a fire proofing method was devised by raking out the foam plastic to a four or six inch depth, filling the void with rolled refractory fiber insulation held in place with glass fiber screening and noncombustible silicone adhesive, all of which is covered with a glass fiber reinforced silicone sheet material cemented to the concrete walls with noncombustible silicone adhesive.

Tests of this concept were conducted in March 1975.The test was an ASTM E-1 19 wall test where the refractory fiber/silicone sheet was used to seal a pipe sleeve. After five hours of exposure, the seal was still intact and functional." The NRC Safety Evaluation, dated July 31, 1979 states: "We conclude that the TnM~o 8OWV AOmm8 0fe V40 1.2.0 Revision I Page A-22 Indiana Michigan Power CNP NFPA 805 Transition Report -Affachment A Inin Mcia PoeiN FA85Tasto eot-Atcmn Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document administrative controls [including controls on construction of walls, floors and components required to maintain structural integrity], fire brigade equipment and training conform to the recommendations of the National Fire Protection Association and Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable." The noncombustible features (i.e. the expansion and seismic gap filling materials, the interior wall and structural components, thermal insulation, radiation shielding and sound proofing), as approved by the SE Report, are still installed at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.

These features have not been changed.CWPTAC-%1.1.Gb WVUWWI2 n Aedý Cabd Vatn I2.O Revision I Page A-23 Indiana Michican Power CNP NFPA 805 Transitiari Remd -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.3 Interior Finishes Interior wall or celifng finish classification shall be in accordance with NFPA 101, "Lfe Safety Code', requirements for Class A materials.

Interior floor finishes shall be in accordance with NFPA 101 requirements for Class I interior floor finishes.-Complies by previous NRC approval e Complies with use of EEEEs Complies by previous NRC approval: By the response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.1.(d) I&M stated: "Interior wafi and structural components, thermal insulation, radiation shielding, and sound proofing are, to the extent possible, noncombustible or have the UL flame spread, smoke, and fuel contribution rating of 25 or less.*The NRC Safety Evaluation, dated July 31, 1979 states: We conclude that the administrative controls [including interior wall, ceiling and floor finishes], fire brigade equipment and training conform to the recommendations of the National Fire Protection Association and Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable.*

I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. I and 2, 1/31/77, item D.1.(d)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to License No. DPR-58 and DPR-74, 7131/79, page 17 I&M Letter to NRC, 'Control Room Carpeting', 5130/1986 NRC Safety Evaluation, "Installation of Carpet in the Control Rooms", 6/16/88 Engineering Equivalency Evaluation 11.55, "Flammability of Floor Coating Systems" PMI-2270, "Fire Protection Program', Rev. 30 12-EHP-2270-FPIR-001, "Fire Protection Program Impact Review', Rev. 1, All Sections AR: GT00120103 By letter dated May 30, 1986, I&M informed the NRC that carpeting had been installed in both units' control rooms to dose out human factors concerns as a result of the Detailed Control Room Design CWPWAC-y"At.b IwGOWa2 TMAn COMMM AU Cob' VeWiA 1 2 Revision 1 Page A-24 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Review. The licensee stated that this carpeting had a flame spread rating of 30 which is higher than the 25 recommended by NRC staff guidance.

The carpeting also has a radiant flux rating of .98 watts/cm.The NRC Safety Evaluation,"installation of Carpet in the Control Roomsm, dated June 16, 1988 states: "The carpeting installed in the control room deviates from NRC staff guidance because the flame spread rating is higher than identified in Section D. 1.d of Appendix A to BTP APCSB 9.5-1. The concem is that a fire involving carpeting with a high flame spread could propagate rapidly, potentially damaging safe shutdown equipment and also making the control room uninhabitable.

However, the flame spread of the carpeting installed in the D.C. Cook control rooms is only slightly higher than staff guidance, 30 versus 25.Since the issuance of the staff guidelines, objections have been raised in the fire protection industry regarding the measure of flame spread to evaluate floor CNPITDAC Vl,.1.Gb MUM 12 TnwW Dmm AmmhotWn 1.2.0 Revision I Page A-25 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document coverings.

The test method used to evaluate flame spread, NFPA 255, "Surface Burning Characteristics of Building Materials,'

holds the test specimen upside down in a posion that bears no resemblance to its position when it is installed.

In a effort to correctly assess the flame spread hazard of floor coverings, the concept of radiant flux was used and NFPA 253,'Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source'was developed.

NFPA 253 involves subjecting a horizontal floor covering specimen to a radiant energy flux which decreases along the length of the specimen according to a standard energy flux vs.distance profile. The higher the critical heat flux rating a carpet has, the more resistive it is to flame spread.The subject carpeting has a critical heat flux of .98 watts/cmr(2).

This rating is significantly higher than the minimum of 0.45 watts/cmr(2) used to define a Class I interior finish in NFPA 101, 1Lf Safety Code.N Since the control rooms are continuously manned, fires MM 2 WAI l 1*Revision I Page A-26 Indiana Michioan Power CNP NFPA 805 Transffion Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document would be detected quicky and extinguished using portable fire extinguishers.

Based on the above, there is reasonable assurance that the slightly higher flame spread rating of control room carpeting would not adversely affect plant safety.Based on the above evaluation, the staff finds that the installation of carpeting in the control rooms which has a flame spread rating of 30 is an acceptable deviation from the guidance provided in Appendix A to BTPAPCSB 9.5-1, Section D.1.d." The carpeting, as approved by the SE Report, Is still instafled in the control room at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.

The carpeting features remain unchanged.

Complies with use of EEEEs: Epoxy floor coating is used in some fire areas. This has been evaluated as acceptable via an Engineering Equivalency Evaluation and AR GTOO120103.Tuimni 0w AUmm0i 14 Revision 1 Page A-2 Revision I Page A-27 Indiana Michican Power CNP NFPA 805 Transition Repod -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.4 Insulation Materials Thermal Insilation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

-comples by previous NRC approval Complies: Thermal insulation materials, shieldg materials, ventilation duct materials and soundproofing materials at CNP are of limited combustibility.

Complies by previous NRC approval: By the response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.1.(d) I&M stated: "lInterior wafl and structural components, thermal insulation, radiation shielding, and sound proofing are, to the extent possible, noncombustible or have the UL fame spread, smoke, and fuel contnbuton rating of 25 or les W oere this was not possible, these materkis are protected by other means. In the two cases where this ocarred (noted belo) the following was done: Building expansion or seismic gaps ware filled in some cases with urethane or styrene foam plastic to act as a seal to prevent inftvri of air or sand, or to act as non-removable forms between concrete pours.In areas where this material violated fire rated walls or where ES-PIPE-1007-QCS, "Thermal Insulation", Rev. 3, All Sections 12-THP-6010-RPP-015, "Temporary Shielding", Rev. 7, Section 3.5 ES-HVAC-0804-QCN, "Nuclear Grade Ductwork", Rev. 1, Section 4 ES-HVAC-0806-QCS, "Conventional HVAC Ductwork", Rev. 0, Section 4 I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. I and 2, 1/31/77, item D.1.(d)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to Lcense No. DPR-58 and DPR-74, 7/31/79, page 17 and table 1, item 8.12-EHP-2270-FPIR-001, "Fire Protection Program Impact Review", Rev. 1. All Sections oujTW4_V l1 TW~6u, DmitWA.ns Ob V"W I."6'"2 Revision I Page A-28 Revision I PpA-28 Indiana Michican Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document the material, if Ignited, could potentially damage adjacent equipment; a fire proofing method was devised by raking out the foam plastic to a four or six inch depth, filling the void with rolled refractory fiber insulation held in place with glass fiber screening and noncombustible silicone adhesive, all of which is covered with a glass fiber reinforced silicone sheet material cemented to the concrete walls with noncombustible silicone adhesive.

Tests of this concept were conducted in March 1975.The test was an ASTM E-119 wall test where the refractory fes`Wi ne sheet was used to seal a pipe sleeve. After five hours of exposure, the seal was still intact and functional.

The NRC Safety Evaluation, dated July 31, 1979 states: afe conclude that the adminstrative controls [including controls on thermal insulation, radiation shielding materials, ventilation duct materials and soundproofing materials], fire brigade equipment and training confomn to the recommendations of the National Fire Protection Association and Appendix A to O _W-7DC_.v1.f, 1V~12TMOOM Doom" A COftsmd I" Revision I Page A-29 Revision 1 Page A-29 Indiana Michiban Poyver CNP NFPA 805 TwaNion Repod -AltechmeW A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Branch Technical Position 9.5-1 and are, therefore, acceptable.

The noncombustible features (i.e. the expansion and seismic gap filling materials, the interior wall and structural components, thermal insulation, radiation shielding and sound proofing), as approved by the SE Report, are still used at CNP. There have been no plant modifications or other changes that would invaflidate the basis for approval.

These features have not been changed.3.3.5 Electrical.

Electrical

• NJA N/A -Section Heading, see sub- N/A sections for any specific compliance statementsAmmmCu-te Reiso T1 PUg e AMM COO *UUfn .2 Revision 1 Page A-30 Indiana Michigan Power CNP NFPA 805 TranmWon Report -Affachnwnt A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.5.1 [Electrical Wiring Above Suspended CeiO lg l ]itatons WrIng above suspended celing o Complie by proviou shal be kept to a mr*kiium.

Where NRC approval Installed, electrical wiring shalt 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.By the response to A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.1.(f) I&M stated: "The only locations containing Class I equ~oment with suspended ceaikg are each of the control rooms. The ceiling in this case consists of acoustic metal tiles which are noncombustible, and plastic diffusers (egg crate) under the recessed fluorescent lighting.These diffusers meet the UL 25 fame spread requirements.

I&M response to Appendi A to Brunch Technical Position APCSS 9.5-1 for Units No. 1 and 2, 1/31177, item D.1.(f)NRC Safety Evaluation supporting Amerndet Nos. 31 and 12 to License No. DPR-58 and DPR-74, 7/31/79, page 17 and table 1, item 3.D.I.12-EHP-2270-FPIR-001, *Fire Protection Program Impact Review", Rev. 1, All Sections The NRC Safety Evaluation, dated July 31, 1979 states: We conclude that the adminisrative controls Pncluding controls on wiring above suspended ceirings) fire brigade equipment and trainig conform to the recommendations of the National Fire Phrocto Association and Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable.'

The suspended ceiling configuration (i.e.noncombustible files with diffusers meeting UL 25 flame spread requirements), as approved by the SE Report, is 1UP3OQTt2 T AV .u M Revision I Page A.31 Indiana Michidan Power CNP NFPA 805 TransWon Rewd -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document stil Installed at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.

This configuration has not been changed.3.3.5.2 [Electrical Only metal tray and metal conduits Complies with All exposed electrical raceways ES-CABLE-0221-QCN, *Design and Raceway Construction shall be used for electrical clarification are metal tray or metal conduit. Installation Criteria for Cable, Trough, Limits] raceways.

Thin wall metallic tubing In general, all cable is run and Conduir, Rev. 8, All Sections shall not be used for power, through conduits or trays, with instrumentation, or control cables. the exception of short cable air Nuclear Energy InstUe (NEI) 04-02, Flexible metallic conduits shall only drops. The approximately 3 foot 'Guidance for Implementing a Risk-be used in short lengths to connect air drops align with the guidance Inrfomed, Peformance-Based Fire components.

of Section K.4 to NEI-04-02 Protection Program under 10 CFR (FAQ 06-0021) and are 50.48(c), Rev. 2 I Section K.4 (FAQ therefore acceptable.

06-0021)CWeTWC,1.b 100r12 Tqm,.tn n A0toOWWsWId 1.1*Revision I Page A-32 Indiana Mkhh7an Po"r CNP NFPA 805 Transition Repod -Attachmont A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.5.3 [Electrical Cable Flame Propagation Umits]Electric cable construction shall comply with a flame propagation test as acceptable to the AHJ..Compnles by previous NRC approval Note: the exception to this section is not endorsed by 10 CFR 50.48(c)(2Xv) and has been removed.By the response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.3.(f) I&M stated: "Cables used in Unit I were not required to pass any fire test at time of purchase.

Samples of all cables were subjected to the IPCEA S-19-81 paragraph 6.19.6 vertical flame resisting test. The vertical flame test IPCEA S-19 is adequate to show the flame resistance capability of these cables since they are already in use. All cables passed this test with the exception of 600 volt, unjacketed, power cables using cross linked polyethylene insulation and one type of two conductor control cable supplied by one of the two manufacturers who supplied the cable. This cable is currently installed in Unit I and there are no present plans to replace the cable.Cable insulation materials were selected for their electrical properties, radiation and containment environment resistance at the time of their purchase for Unit 1. Flame resistance properties were not the only factors to consider when Unit I cables were-purchased." I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, 1/31/77, item D.3.(f)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to License No. DPR-58 and DPR-74, 7/31179, page 17.12-EHP-2270-FPIR-001, "Fire Protection Program Impact Review", Rev. 1, All Sections ES-CABLE-j221-QCN, Design and Installation Criteria for Cable, Trough, and Conduit', Rev. 8, All Sections Mor1o TrWuu. DWAM AMM 00ft VW@M I".Revision I Page A-33 Revision I Page A-33 Indiana Michigan Power CNP NFPA 805 Tranmffion Report -Attachment A Inin ihla o e C PN P 0 T... n...ion Re~ .. ......m. .t.Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document"All cables installed in Unit 2 were documented to have passed the vertical flame test of IPCEA S-19-81 Pare. 6.19.6.Power cables used on safety systems within the containment were documented to pass the vertical flame test of IEEE 383.The NRC Safety Evaluation, dated July 31, 1979 states: "We conclude that the administrative controls rincluding cable construction], fire brigade equipment and training conform to the recommendations of the National Fire Protection Association and Appendix A to Branch Technical Position 9.5-1 and are, therefbre, acceptable." The electrical cables, as approved by the SE Report, are still installed at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.Any new cable installed at CNP will be constructed similar or superior to the original cable and meeting the requirements of IEEE-383.CW1OAe 1.1*.I Revisio TsID&wACW Pag 1A-3 Revision I Page A-34 Indiana Michigan Power CNP NFPA 805 Transtion Report -Affachtnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.6 Roofs Metal 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." N Compies by previous NRC approval By the response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2, dated January 31, 1977, item D.1 .(d), I&M stated: The auxiliary building roof at Cook Plant is reinforced concrete over metal pan (Q deck) ceiling. To prevent condensation it was necessary to add urethane foam insulation between the concrete and the metal pan. The foam selected met the UL25 flame spread requirement; however, for additional protection a layer of fire rated gypsum board was installed between the metal pan and the urethane foam. This will protect the foam from an interior building fire which could degrade the foam, liberating combustible gases which can contribute to the intensity and spread of the fire." M&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2,1/31177, item D.1.(d) and (e)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to Ucense No. DPR-58 and DPR-74, 7/31/79, page 17.DCC-CEST-200-QCS, "Auxwiary Building Reroofing Section 07526 Modified Bitfum Sheet Roofing Seismic Class Ill Application", Rev. 0, All 12-EHP-2270-FPIR-001, "Tire Protection Program Impact Review", Rev. 1, All Sections By response to Item D.1.(e), I&M stated: "All roofs at the Cook Plant are of UL Class A and FM Class I construction." The NRC Safety Evaluation, dated July 31, 1979 states: "We conclude that the Rev siCon IPage A- 35.~~~~TWWMml DeftWWMAWMC 1,2JA Revision I Page A-35 Indiana Mkh1ban Power CNP NFPA 805 Transffion Repod -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document administrative controls j'including roof construction], fire brigade equipment and training conform to the recommendations of the National Fire Protection Association and Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable." m The Auxiliary Building roof construction, as approved by the SE Report, is still installed at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.

This feature remains unchanged.

3.3.7 Bulk Flammable Gas Storage Bulk compressed or cryogenic

• Complies with flammable gas storage shall not be clarification permitted inside structures housing systems, equipment, or components important to nuclear safety.Bulk compressed flammable gas PMP-2270-CCM-001, "Control of cylinder storage is located in the Combustible Materials", Rev. 8, Gas Bottle Storage Facility, Section 3.10 which is separated from structures housing systems, Fire Hazards Analysis, Rev. 14 equipment, or components important to nuclear safety. The Engineefn Equivalency Evaluation 3-hour rated concrete wall that 11.11, "Storage of Flammable Gases separates the full bottle storage in Fire Areas AM2A, AA2B, AA3, area of the Gas Cylinder AA34, and Yard-, Rev. 0 Storage Building is a maximum fire loss type firewall.

The combination of the firewall and spatial separation from the south wall of Fire Zones 97 and 98 provides assurance that a gas cylinder fire would not damage safety related equipment cReisonC Pa .I.A3 1030=J2 T~wMamm ]o~mm/@mO~fto

'-ll 12A8 Revision I Page A-36 Indiana Michigan Power CNP NFPA 805 TransWon Rewd -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.7.1 [Bulk Flammable Gas Location Requirements]

Storage 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.9 Complies with clarificaition

• Complies with use of EEEEs Complies with clarification:

PMP-2270-CCM-0O1, *Control of Bulk compressed flammable gas Combustible Materials", Rev. 8, cylinder storage is located in the Section 3.10 Gas Bottle Storage Facility.

The 3-hour rated concrete wall that Fire Hazards Analysis, Rev. 14 separates the full bottle storage area of the Gas Cylinder Engineering Equivalency Evaluation Storage Building is an MR. type 14.1.1, *CNP Fire Protection Code firewall.

The combination of the Conformance Review*, Rev. 0 firewall and spatial separation from the south wall of Fire Zones 97 and 98 provides assurance that a gas cylinder fire would not adversely impact systems, equipment.

or components important to nuclear safety.Complies with use of EEEEs: Hydrogen storage complies with NFPA 50A-1 999 Edition, as evaluated in Engineering Equivalency Evaluation 14.1.1.3.3.7.2 [Bulk Flammable Outdoor hig-pressure flmmable Compies with use of Bulk hydrogen storage is Engineering Equivalency Evaluation Gas Container gas storage containers shall be EEEEs: configured so the that the long 11.11, "Storage of Flammable Gases Restictions]

located so that the long axis is not axis is not pointed at buildings, in Fire Areas AA2A, AA2B, AA3, pointed at buiings. as evaluated in Engineering AA34, and Yard', Rev. 0 Equivalency Evaluation 11.11.T2rtCvtl.b~

loam 2 TWu, DWom"" AOu gcgoo 1.20I Revision 1 Page A-37 Indiana Michigan Power CNP NFPA 805 Transton Repod -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.7.3 [Bulk Flammable Flammable gas storage cyinders Comps flamrmable gas storage PMP-2270-CCM-001, "Control of Gas Cyinder Umitations]

not required for normal operation cylinders not required for normal Combustible Materia, Rev. 8.shall be isolated from the system. operation are either returned to Section 3.10 the gas bottie storage facilitty upon the completion of a job or 12-OHP Procedure Series are isolated from the system.Tmwill, DomlAm 4 ei 1.2.0 Revision 1 Page A..8 Indiana Whiden Power CNP NFPA WS Tmn&ihon Report -Attachment A Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.8 Bulk Storage of Flammable and CobsibeLquid Bulk storage of flamnmable and combustible liquids shall not be pemftd nside structures containing systems, equipment or componert important to nuclear safety. As a minimum, storage and use shafl comply with NFPA 30,"Flammable and Combustible Liquids Code.".-Compie by previous NRC approval* Comples with use of EEEEs Complies: Per plant procedure PMP-2270-CCM-001, "Control of Combustible Materfalsm, the following areas are designated storage for flammable/combustible liquids:* Storage of flammable liquids (NFPA Diamond Rating of 3 or 4) in quantities greater than one gallon per container shall be restricted to the U-1 Flammable Liquids Storage Room located on the 595 level of the Service Building.e Bulk storage of combustible liquids (those having a flash point above 100"F, NFPA Diamond Rating of 2 or less) will be permitted in the U-2 Miscellneous Oil Storage Room located on the 591' level at the south end of the Turbine Building.These areas are separated from systems, equipment, and components important to nuclear safety, by 3-hour fire resistive barriers.Complies by previous NRC approval: By the response to Appendix A to Branch Technical Position PMP-2270-CCM-001, "Control of Combustible Mate , Rev. 7, Section 3.9 Fire Hazards Analysis, Rev. 14 I&M response to Appendix A to Branch Technical Position APCSB 9.5-1 for Units No. 1 and 2. 1/31/77, item D.2.(a)NRC Safety Evaluation supporting Amendment Nos. 31 and 12 to License No. DPR-58 and DPR-74, 7/31/79, page 17."NFPA 30 Code Compliance Evaluation for Donald C. Cook Nuclear Plant Unit I and 2", Rev. 0, 7/25/90, Al"Donald C. Cook Nuclear Plant NFPA Code Deviations and Justifications", Rev. 2,4/12/06 Engineering Equivalency Evaluation 11.16, "Lube Oil Storage Rooms Fire Zones 83 and 95 (AA2A), and 88 and 100 (AA2B) Boundary Evaluation", Rev. 0 Engineering Equivalency Evaluation 11.17, "Diesel Generator Fuel Oil Day Tank Rooms Fire Zones 15 (AA14), 16 (AA15). 18 (AA23) and 19 (AA24)Boundary Evaluation", Rev. 0 Reviion Pag A -139 Revision I Page A-39 Indiana Michican Fým"r CNP NFPA 805 Transition Report -Attachment A Inin Mcka Poe NIFA85TastinRgot-Atcmn Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document APCSB 9.5-1 for Units No. I and 2, dated January 31, 1977, item D.2.(aXI), I&M stated: 'The emergency diesel generator fuel oil day tanks are enclosed in a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated enclosure within each of the diesel generator rooms. The enclosure has 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated walls, floor, ceiling, dooms, and dampe, is equipped with thermally actuated fire detection which operates a fixed autoratic C02 fire suppression system, and also is drained to remove any oil spill." By item D.2.(aX1), I&M stated: "While not safety related or an exposure hazard to safety related equipmerM the turbire generator, its lube oil system, and the area surrounding it are fully fire protected.

This is considered to be the highest fire potential area in a power plant.Area coverage by automatic sprnklers is provi 100%below the main and mezzanine floors Oil lines below the main Floow, even though covered by guard poing, are traced with automatic spray nozzles which also follow cable tray runs and cover the H2 seal oil equipment.

CNP TVAC .Yl1.1m lWwi2 TIm DOmO, AMM Cab. VIISIM 1.2I Revision I Page A-40 Indiana Michi-dan Power CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Lube oil processing and running oi# tank rooms are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated enclosures with automatic C02 and sprinlder fire suppression.

Oil piping above the main floor has fire detection for alarm in the control room and manual preaction water spray operable from the control room. Turbine generator bearings are protected by manual dry chemical piped systems.Portable water hose lines, foam equipment, C02, and dry chemical wheeled and hand portable extinguishers are liberally provided.The entire area is curbed and drained. Heat and smoke vents are provided in the turbine building roof at a I sq.t to 100 sq. ft ratio. Three hour rated firewals cut off each unit below the main floor, the auxTmiy building, service bulding, screenhouse, heating boilers, as well as the lube oi, and running oil tank room." The NRC Safety Evaluation, dated July 31, 1979 states: We conclude that the administrative controls ncluding storage of flammable and combustible liquids], fire brigade equipment and training conform 1w jCdy1.I0 Revisio I Page A -4ob1WM Z Revision 1 PaeA-41 Indiana Michigan Power CNP NFPA 805 Transftn Repod -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document to the reconmendatons of the Natonal Fire Protection Assocai and Appendix A to Branch Technical Position 9.5-1 and are, therefore, acceptable.w The storage configurations of combustible liquids, as approved by the SE Report, are still used at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.

Features remain unchanged.

Complies with use of EEEEs: Storage of flammable and combustible liquids complies with NFPA 30-1987 Edition, as evaluated in the *NFPA 30 Code Evaluation for Donald C. Cook Nuclear Plant Unit I and 2r.The fire baniers of the Lube Oil Storage Rooms have been evaluated in accordance with NFPA 805, section 3.11.2, and by Engineering Equivalency Evaluation 11.16.The fire barriers of the Diesel Generator Fuel Oil Day Tank Rooms have been evaluated in accordance with NFPA 805, section 3.11.2, and by Engineering Equivalency Evaluation 11.17.TOMMlMOOU1 VWMAW 12A Revision 1 PpA..42 Indiana Michigan Power CNP NFPA 805 Transition Repod -Attachinent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.9 Transformers Where provided, transformer oil

• Complies CNP environmental review PMP.60gO.ADM-001, "Environmental collection basins and drain paths documents include requirements Reviews and Survelllance, Rev. 5 shall be periodically inspected to for inspecting transformer oil ensure that they are free of debris collection basins and drain 12-EA-6090-ENV-1 12, "Auxiliary and capable of performing their paths. Building Wastewater Management", design function.

Rev. 2, Section 4.3.6 3.3.10 Hot Pipes and Combustible liquids, including high

• Complies CNP procedures designate PMP-2220-HSK-001, "1-lousekeeping Surfaces flashpoint lubricating oils, shall be storage areas for combustible and Material Condition*, Rev. 6 kept from coming in contact with hot materials, none of which are pipes and surfaces, including around hot pipes and surfaces.

PMP-2270-CCM-001, "Control of insulated pipes and surfaces.

Also, CNP procedures require Combustible Matera, Rev. 8, Administrative controls shall require that piping be dean, well Section 3.2.1 the prompt cleanup of oil on maintained and free of all clutter.insulation.

Procedure PMP-2220-HISK-001 states that plant personnel responsible for area housekeeping.

CI 1DC,1lib RIsion TII D Cage VMW 1.AU Revision I Page A-43 Indiana Michidan Power CNP NFPA 805 Transition Report -Affachtnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document I I 3.3.11 Ek1etal Equipment Adequate clearance, free of combustible material, shall be maintained around energized electrical equipment 0 Complies CNP procedures designate storage areas for combustible materials, none of which are around energized electrical equipment Energized electrical components are maintained free from adjacent combustible material per PMP-2270-CCM-001. Procedure PMP-2220-HSK-001 states that plant personnel are responsible for area housekeeping.

Environmental procedures require the clean up of all oil spills.PMP-2270-CCM-001, *Control of Combustible Materialse, Rev. 8, Section 3.21 and Attachment 1, Section 1.3.2 12-PPP-2270-066-O12, "Translent Combustible Monitori, Rev. 7 PMP-2220-HSK-001, "Housekeeping and Material Condition', Rev. 6 PMP-6090-ADM-001, Environmental Reviews and Survefancen, Rev. 5 Nuclear Energy Institute (NEI) 04-02,"Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)', Rev. 2 1 Section K.5 (FAQ 06-0024)OWLTDAC-.1..vOb TONW"n ~iAMMesCOWNd

1.2.0 Revisi7

1 PageA-Revision I Page A-44 Indiana Michigan Power CNP NFPA 805 Transition Report -Affachinent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.12 Reactor Coolant Pumps For facilities with non-inerted containments, reactor coolant pumps with an external lubricaton system shall be prvided 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.-Compies by previous NRC appval NRC Safety Evaluation dated December 23, 1983, states: "Each unit has four reactor coolant pumps With an oil collection system which drains to a vented closed collection tank. The quanUit of lubricating oil in each pump is 265 gallons;the capacity of the oil collection tank is 275 gallons.The collection tank is arranged such that if a failure of more than one RCP motor lube system occurred, the oil collection tank would over-flow onto the lower containment floor.There are no ignition sources at the floor level of the lower containmenL I&M Letter to NRC, "Fire Protection

-Appendix R Compliance, 7119M19M2 I&M Letter to NRC, *Fire Protection

-10 CFR 50, Appendix R, Section 111.0%, 12/30/1982 NRC Safety Evaluation, -Donald C.Cook Nuclear Power Plant, Unit Nos.I and 2 Fire Protection

-Request for Exemption from requirements of Appendix R to 10 CFR 50, Sections III.G and 111.0", 12=23/1983 Pages 10 and 11, and enclosure 2, pages 15 and 16 The RCP motor lube oil system does not comply with Section 111. because the oil collectio tank is not sized to contain the entire lube oil system inventory.

The RCP motor lube oil system is capable of withstanding the safe shutdown earthquake.

The oil collection tank is provided with sufficient capacity to hold the total lube oil inventory of one reactor coolant pump with margin and is designed so that any ovwflow will be drained to a safe location.0t30M 2 TWMMil OMm l Aým "-"- 1.2A Revftion I Page A-45 CNP NFPA 805 Transtbon Report -Affachment A In..iana .Michi.an Power F Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Based on the above evaluation, the existing RCP motor lube oil collection system provides a level of safety equivalent to the technical requirements of Section /it 0 and, therefore, the exemption should be granted.The oil cdlto tank for the RCP motor lube system, as approved by the SE Report, is still used at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.This feature remains unchanged.

3.3.12 Reactor Coolant The Oi collection system for each Complies As stated In the FPPM, section FPPM, Rev. 11, Section 12.8 Pumps (1) reactor coolant pump shall be 12.8, each RCP is provided with capable of collecting lubricating oil oil collection enclosures to from all potential pressurized and capture oil from potential nonpressurized leakage sites in pressurized and unpressurized each reactor coolant pump oil leakage sites in the lube oil system. system.OIP_Tl wlACt. t~bT Ilmt O si.wu Adlp ob VW 120 Revision 1 Page A-46 Indiana Michigan POver CNP NFPA 805 Transihon Report -Affachment A Atan ichentA Powtr Por anF 805 Trmntso F er A h Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.12 Reactor Coolant Pumps (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.-Complies by previous NRC Safety Evaluation dated NRC approval December 23,1983, states: Each unit has four reactor coolant pumps with an oil collection system which drains to a vented closed collection tank. The quantity of lubricating oil in each pump is 265 gagons;the capacity of the oil collection tank is 275 gallons.I&M Letter to NRC, *Fire Protection

-Appendix R Compliane, 7/19/1982 I&M Letter to NRC, Fire Protection

-10 CFR 50, Appendix R, Section 1I1.0, 12/30/1982 NRC Safety Evaluation, Donald C.Cook Nuclear Power Plant, Unit Nos.I and 2 Fire Protection

-Request for Exemption from requiremrnt of Appendix R to 10 CFR 50, Sections III.G and 1II.O, 12/23/1983 Pages 10 and 11, and enclosure 2, pages 15 and 16 The collection tank is arranged such that if a failure of more than one RCP motor lube system occurred, the oil collection tank would over-flow onto the lower containment floor.There are no ignition sources at the floor level of the lower containment.

The RCP motor lube oil system does not comply with Section 111.0 because the oil collecton tank is not sized to contain the entire lube oil system inventory.

The RCP motor lube oil system is capable of withstanding the safe shutdown earthquake.

The oil collection tank is provided with sufficient capacity to hold the total lube oil inventory of one reactor coolant pump with margin and is designed so that any overflow will be drained to a safe location.TrUMM MMWMAinmaf Vann 1.U Revision I Page A-47 Revision 1 Page A-47 Indiana Michigan Power CNP NFPA 805 Transition Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document Based on the above evaluation, the existn RCP motor lube oil collection system provides a level of safety equivalent to the technical requirements of Section Il1.0 and, therefore, the exemption should be granted." The oil collection tank for the RCP motor lube system, as approved by the SE Report, is still used at CNP. There have been no plant modifications or other changes that would invalidate the basis for approval.This feature remains unchanged.

3.3.12 Reactor Coolant A flame arrestor is required in the Compie A flame arrestor is provided in FPPM, Rev. 11, Section 12.8 Pumps (3) vent If the flash point characteristics the vent.of the oil present the hazard of a fire DB-12-APPR, "American Electric flashback.

Power Nuclear Organization Donald C. Cook Nuclear Plant Design Basis Document for 10 CFR 50 Appendix RO, Rev. 0, Section 4.4 CReiioI ACge f A-4 Revision I Page A-48 Indiana Michigan Power CNP NFPA 805 Transition Report -Affachtnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.3.12 Reactor Coolant Leakage points on a reactor coolant Compiles All leakage points are protected FPPM, Rev. 11, Section 12.8 Pumps (4) pump motor to be protected shall on reactor coolant pump motors.Include but not be limited to the lift DB-12-APPR, "American Electric pump and piping, overflow lines, oil Power Nuclear Organxizon Donald cooler, oil fill and drain lines and C. Cook Nuclear Plant Design Basis plugs, flanged connections on oil Document for 10 CFR 50 Appendix lines, and the oil reservoirs, where R6, Rev. 0, Section 4.4 such features exist on the reactor coolant pumps.3.3.12 Reactor Coolant The collection basin drain fine to the Complies A calculation has been FPPM, Rev. 11, Section 12.8 Pumps (5) collection tank shall be large performed to verify that the RCP enough to accommodate the largest oil collection system is sufficient Engineering and Control Procedure 1-potential oil leak such that oil to permit flow from all of the drip L3-01, Calculation of Flow in RCP Oil leakage does not overflow the pans where the flow is driven by Collection System for Unit 1, Rev. I basin. gravity and resisted by pipe friction.

The calculation also WCAP-10541, Westinghouse Owners verified the adequacy of the Group Report, Reactor Coolant drain piping in the event that the Pump Seal Performance Following a lube oil ift pump discharges Loss of all AC Power*, Rev. 2 directly into Its housing.3.4 Industrial Fire Industrial Fire Brigade.

• N/A N/A -Section Heading, see sub- N/A Brigade sections for any specific compliance statements.

3.4.1 On-Site Fire- On-Site Fire-Fighting Capability.

All

• N/A N/A -Section Heading, see sub- Engineering Equivalency Evaluation Fighting Capability of the following requirements shall sections for any specific 14.1.1, "NFPA 600 Code apply. compliance statements

-See Conformance Review", Rev. 0 NFPA 600 CCR.Reiso2 T1WN POWA geW A-9I Revision I Page A-49 Indiana Michican Power CNP NFPA 805 TiransWon Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.1 On-Site Fire-Fighting Capability (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:

• Complies* Complies by previous NRC approval Complies: A fully staffed, trained, and equipped fire-fighting force is available at all times to control and extinguish all fires on site.This force is required to have a minimum complement of five persons on duty and conforms with the applicable NFPA standards of this element PMI-2270, "Fire Protection Programa, Rev. 30, Section 4.1 PPI-2270, "Fir Brigade Staffing and Response", Rev. 4, Section 4.0"Technical Requirements Manual and Basese, Unit 1: Rev. 1, Unit 2: Rev. 1, Section 10.1, Administrative Controls, Site Fire Brigade, Unit I Rev. 1, Unit 2 Rev. 1.NRC Safety Evaluation supporting License Amendment Nos. 154 and 138 dated April 9, 1991. Page 2, Section 2.0(3).Complies by previous NRC approval: Per the "Technical Requirements Manual and Bases", "The composition of the fire brigade may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected absence provided immediate action is taken to fill the required positions." This provision is allowed by CNP TRM Section 10.1. This provision was approved by the NRC via Unit 1 and Unit 2 Licensee Amendments 154 and 138, respectively, dated April 9, 1991. Therefore, the provision is considered to be previously approved by the NRC.FPE RAI 10 Cap-1DOP,1ttb Tom*"Dw~nf m.W acionw I"0 10OW312 Revision I Page A-SO Revision 1 Page A-50 Indiana Michican Power CNP NFPA 805 Transftion Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3A.1 On-Site Ffre- NFPA 600, *Standard on Industrial 9 Complies with use of Rghting Capability (aX1) Fire Brigades' (interior structural EEEEs fire fighting)° Complies with clarification Complies with use of EEEEI: For Interior fire fighting, CNP coplies with NFPA 600-2000 Edition, Chapter 5. The fire brigade has been reviewed against the requirements of NFPA 600, 2000 Edition, Chapters 2 and 5, as detailed in the CNP 'Fire Protection Code Conformance Review'.Engineering Equivalency Evaluation 14.1.1, 'NFPA 600 Code Conformance Review', Rev. 0 Nuclear Energy Institute (NEI) 04-02,"Guidarnce for Implementing a Risk-Inforled, Performance-Based Fire Protection Program under 10 CFR 50.48(c)', Rev. 21 Section K.6 (FAQ 06-0007)Complies with clarification:

As required, and in accordance with the guidance of Section K to NEI-04-02 (FAQ 06-0007), the CNP Fire Brigade has the ability to control and extinguish exterior fires similarly to interior fires, through the development, review, and maintenance of associated fire emergency plans and fire attack plans; regular training and education; the use of appropriate protective clothing and equipment; and brigade member medical and physical performance requirements; as addressed through compliance with NFPA 600-2000 Edition, Chapters 2 and 5.PPI-2270, 'Fire Brigade Staffing and Response', Rev. 4 Revision I Pagem A-5 Vm1J Revision 1 Page A-51 Indiana Michican Power CNP NFPA 805 Transidon Report -Affechment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.1 On-Site Fire-Fighting Capability (aX2)NFPA 1500, "Standard on Fire Department Occupational Safety and Health Program" oN/A CNP complies with NFPA 600 and as such NFPA 1500 is not applicable to CNP per Section K.6 of NEI 04-02, which states,"The NFPA standards divide fire brigades into two types, based on organization and duties: Industrial fire Brigades" and*Industrial Fire Departments." Practically this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)." Nuclear Energy Institute (NEI) 04-02,"Guidance for Implementing a Risk-Informed, Perkomance-Based Fire Protection Program under 10 CFR 50.48(c)", Rev. 21Section K.6 (FAQ 06-M7)3A.1 On-Site Fire- NFPA 1582, "Standard on Medical 9 N/A Fighting Capability (aX3) Requirements for Fire Fighters and Information for Fire Department Physicians" CNP complies with NFPA 600 and as such NFPA 1582 is not applicable to CNP per Section K(6 of NEI 04-02, which states,"The NFPA standards divide fire brigades into two types, based on organization and duties: "Industrial fire Brigades" and"Industrial Fire Departments." Practically this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)." Nuclear Energy Institute (NEI) 04-02,"Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)", Rev. 2 / Section K.6 (FAQ 06-0007)OWWj~1..vt TMAMMnMWWbAuie,,W I" Revision I Page A-52 Reviso I Page A.,2 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.1 On-Site Fire-Fighting Capability (b)3.4.1 On-Site Fire-Fighting Capality (c)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.During every sh~t, the brigade leader and at lead 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.* Complies e Complies CNP Fire Brigade members have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.CNP meets the exception to (c)Per PMP-2270-FRP-001, -One person from the Operations Department with a reactor operatoes license or equivalent training will advise the Fire Brigade Leader on safety related/safe shutdown and general plant systems in the fire area".PMP-2270-FRP-001, *Fire Response Plan', Rev. 11, Section 3.8.2.PMP-2270-FRP-001, 'Fire Response Plan', Rev. 11, Section 3.3.4(b)Exception to (c): Sufficient training and knowedge shall be permitted to be provided by an operations advisor doeted to industrial fire brigade support.3A.1 On-Site Fire-Fighting Capability (d)The industrial fire brigade shall be e Complies notified Immediately upon verification of a fire.Per CNP procedures, the fire PMP-2270-FRP-001, "Fire Response brigade is immediately notified in Plan", Rev. 11 the event of a fire alarm.CWjMW."t lfb Tiinimn DM I I1co 2ogl 0I 1.m2 Reviion Pag A-5 Revision 1 Page A-53 Indiana Michican Power CNP NFPA 805 TransNon Repod -Affachment A Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.1 On-Site Fire-Fighting Capability (e)Each industrial fire brigade member 9 Complies shall pass an annual physical examination to detemine 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 Per TPDhe0-FP, when selected for initial training, students must complete physical examination requirements as well as a physical ability test. They ar also subject to the requirements of PMP-2281-RES-rO1.

Here, formal respiratory training is required to be completed prior to the Initial use of a respiratory protection device and on an annual basis thereafter.

SPP-2281-HAZ-001, 'Hazardous Material Response Organization and Training, Rev. 4, Section 4.3.TPD-600-FP, 'Fire Protection Traing Program Description, Rev. 4, Section 3.3.4 and Attachment 2.PMP-2281-RES-001, -Control and Use of Respiratory Protection Devices', Rev. 3, Section 3.6.Further, the *Hazardous Material Response Organization and Training states that all HAZMAT qualified individuals shall have had a medical assessment (baseline) and a follow-up assessment every 12 monoths unless the attending physician believes a longer interval (not greater than biennially) is appropriate.

Procedure TPD-600-FP requires'Hazardous Materials

-Technician Level Evolutions' as part of the fire brigade member training, therefore, the members of the fire brigade Is KAZMAT qualified and subject to the requirements of the 'Hazardous Material Response Organization and Training".

O.TMC~v.y1 b lWu i2 Revison IPageA-fI Revision I PaeA-54 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.2 Fire Pre-Plans Current and detailed pro-fie plans shalt 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." Complies" Complies with Required Action Complies: Per Procedure PMI-2270, Fire Pre-Plans that detail all hazardous conditions in certain areas are available to the fire brigade. Refer to Fire Pre-Plans Volumes I, II, and Ill. These Fire Pre-Plans

• describe the fadlity layout, access, contents, construction, hazards, hazardous materials, types and locations of fire protection systems, and other information pertinent to the formulation, planning, and execution of emergency fire response." Complies with Required Action: Pre-fire plans will be revised to reflect changes required to meet the NFPA 805 radioactive release performance criteria.Refer to Implementation Item S-3.7.PMI-2270, "Fire Protection Program*, Rev. 30, Section 4.6 CNP Fire Pre-Plans, Volumes I, I!, and HI, Revisions 9, 7, and 12 respectively FPE RAI 59 CGWTMCj v.1 .1 Rev3ioMn TwIift D PI Amgea vwim AI"5 Revision I Page A-55 Indiana Michidan Power CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.42.1 [Fire Pro-Plan Contents]The plans shall detail the fire area .Comple 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 CNP Fire Pre-Plans contain the following information for each Fire Zone: 9 A graphical representation of the area depicting the fire area configuration

• Combustibles:

A listing of the combustibles in the fire area.9 Hazards: A listing of special hazards including:

Radiological, Substance (e.g., combustible/flammable gases and liquids), and Physical 9 Access/Egress:

The primary access/egress path (and, where available, the alternate path) is described.

& Ventilation System: Installed fixed supply and exhaust ventilation equipment is listed.Routing for manual ventilation of the fire area is described to route smoke products out of the area.* General Notes: The recommended extinguishing agent is listed, based on the primary combustibles in the fire area. Fire brigade training includes choosing the proper extinguishing agent for each type of combustible.

Based on the actual combustibles involved, the proper extinguishing agent would be utilized during the fire event; any CNP Fire Pro-Plans, Volumes I, II, and III, Revisions 9, 7, and 12 respectively aeMWV.1i I TMUM OMWMM AmCbaft VekmI.tm2 Revision I Page A-SO Revision I-56 lrxftne Michigan Power CNP NFPA 805 Tmnsffion Report -AlhmhmW A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document special tactics appropriate for the fire area are Identified (e.g., actuation of fixed suppression systems);

Additional equipment available for fighting fires In the area Is identified, Including fire hose stations, extinguishers and automatic extinguishing system manual release stations, floor drains, sump pumps.eManagement of Plant Systems: Potentially damaged safe shutdown equipment Is listed.3.4.2.2 [Fire Pre-Plan Updates]3.4.2.3 [Fire Pre-Plan Locations]

Pre-fire plans shall be reviewed and

• Complies updated as necessary.

Pre-fire plans shall be available in e Complies the control room and made available to the plant industrial fire brigade.CNP procedures indicate that the Fire Pre-Plans are maintained and updated by the Fire Protection Coordinator.

The Fire Response Plan, PMP-2270-FRP-001 states that the PFPs are located in the control room.PMI-2270, "Fire Protection Program", 2M2/2009, Section 4.6 PMI-2270, -Fire Protection Program', Rev. 30, Section 4.6.1 PMP-2270-FRP-001, 'Fire Response Plan', Rev. 11, Section 3.8.6 CW-W3D1.1.I b Tm~~~af D~iVdVa 12.0 Revision I Page A-57 Revision 1 Page A-57 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.2.4 [Fire Pre-Plan Coordination Needs]Pro-fire plans shall address e Complies with coordination with other plant groups carification during fire emergencies.

Site procedure PMP-2270-FRP-001 is not specifically a fire pre-plan, however, it provides specific instructions for actions required from key groups at CNP supporting fire brigade/fire emergency actions. Detailed response coordination actions are specified for control room personnel and the Security Group. Any other coordination actions would be initiated by control room personnel as needed for any plant emergency.

PMP-2270-FRP-001, TFre Response Plan', Rev. 11, Section 3.8.6 CNP Fire Pre-Plans, Volumes I, II, and II, Revisions 9, 7. and 12 respectively

3.4.3 Training

and Drills Training and Drills. Industrial 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." Compines" Complies with Required Action Complies:

is demonstrated in the subsections to this element, below.Complies with Required Action: Fire brigade training materials will be revised to reflect changes required to meet the NFPA 805 radioactive release performance criteria.

Refer to Implementation Item S-3.7.TPD-600-FP, "Fire Protection Training Program Description*, Rev. 4 FPE RAI 59 3.4.3 Training and Drills Plant Industrial Fire Brigade

• Complies CNP procedures demonstrate TPD-600-FP, "Fire Protection Training (a) Training.

All of the following compliance in the subsections to Program Description", Rev. 4 requirements shall apply. this element, below.tlJW12 Twmelft"M f"Ml coo r*W I" Revision I Page A-58 Indiana Michican Po"r CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.3 Training and Drills (aXI)Plant Industrial fire brigade members shafl 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.

• Complies CNP program description TPD-60-FP has been developed to assure appropriate CNP personnel are capable of fighting fires. This procedure is also used to plan and implement fire dnlls.NFPA 1500 is not applicable to CNP per Section K.6 of NEI 04-02, which states, 'The NFPA standards divide fire brigades into two types, based on organization and duties: 'Industrial Fire Brigades' and'Industrial Fire Departments.'

Practically, this means that a fire fighting organization at a nuclear power plant must comply with either NFPA 600 (for an Industrial Fire Brigade) or both NFPA 1500 and NFPA 1582 (for an Industrial Fire Department)." TPD.600-FP, 'Fire Protection Training Program Description', Rev. 4 Engineering Equivalency Evaluation 14.1.1, 'NFPA 600 Code Conformance Review', Rev. 0 Nuclear Energy Institute (NEI) 04-02,'Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)', Rev. 2 I Section K.6 (FAQ 06-0007)3.4.3 Training and Drills (aX2)Industrial fire brigade members

• Compiles 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.CNP program description TPD-600-FP establishes quarterly classroom training and fire drills for fire brigade members. RP-O-513019 is included as a requirement in TPD-600-FP to train the brigade on radiological fire fighting evolutions.

TPD-600-FP, 'Fire Protection Training Program Description', Rev. 4 RP-O-513019, 'Respond to a Fire in the Restricted Area", Rev. 0 CWlPTOOC-V1.1Me 12 Trmi I AlCdf lI 1.2.U Revision I Page A-59 Indiana Michican Power CNP NFPA 805 Transition Report -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.3 Training and Drlls A written program shall detail the

• Compe The CNP training program TPD-600-FP, "Fire Protection Training (aX3) industrial fire brigade training description details the fire Program Descripfion*, Rev. 4 program. brigade training program.3.4.3 Training and Drills Written records that include but are 9 Complies Records stored in accordance TPD-600-FP, Tire Protection Training (aX4) not limited to initial industrial fire with CNPs Records Program Descrlption, Rev. 4, Section brigade classroom and hands-on Management procedure include 3.8 training, refresher training, special but are not limited to fire brigade training schools attended, dnrll training and qualification TRP-2070-TAP-400-FPP, "Fire Drillso, attendance records, and leadership records. Rev. 1, Section 3.4.1.b training for industrial fire brigades shall be maintained for each PMP-2030-REC-001, "Records industrial fire brigade member. Management7, Rev. 14 3.4.3 Training and Drills Training for Non-Industrial Fire Compies CNP has a dedicated fire PMP-2270-FRP-001, 'Fire Response (b) Brigade Personnel.

Plant personnel brigade and does not have Plan", Rev. 11, Section 3 who respond with the industrial fire personnel responding who are brigade shall be trained as to their not active fire brigade members.responsibilities, potential hazards to One SRO who responds is be encountered, and interfacing trained with the fire brigade.with the industrial fire brigade.3.4.3 Training and Drills Drills. All of the following N/A N/A -Section Heading, see sub- N/A (c) requirements shall apply. sections for any specific compliance statements.

Reio TPagen A-oV.2.0 Revision I Page A-60 Indiana Michican Power CNP NFPA 805 Transftn Repoft -AltaMnw# A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.3 Training and Drills Drills shall be conducted quarterly e Comples Per CNP program description TPD-600-FP, 'Fire Protection Training (c)(1) for each shift to test the response TPD-600-FP, at lest one fire Program Descdptio', Rev. 4, Section capability of the industrial fire drill per quarter shall be held for 3.9.1 brigade. each shift of the fire brigade.Further, per TRP-2070-TRP-2070-TAP-400-FPP, 'Fire Drills', TAP-400-FPP, one drill is Rev. 1, Section 32.-1.b required for each fire brigade shift per quarter.3.4.3 Training and Drills Industrial fire brigade drills shall be

• Compkes TPD-600-FP establishes drill TPD-600-FP, "Fire Protection Training (c)(2) developed to test and challenge instructions.

These drills are Program Description', Rev. 4 industrial fire brigade response, designed to test and challenge including brigade performance as a industrial fire brigade response.

TRP-2070-TAP-400-FPP, 'Fire Drills', team, proper use of equipment, Drill procedures are also Rev. 1, Section 3.3 effective use of pre-fire plans, and established in TRP-2070-coordination with other groups. TAP-400-FPP.

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 drM scenario.3.4.3 Training and Drills Industrial fire brigade drills shall be 9 Complies CNP procedures indicate that TRP-2070-TAP-400-FPP, 'Fire Drills', (c)(3) conducted in various plant areas, the location of the drills is varied Rev. 1, Section 3.2.3.a.3 especially in those areas Identified and some of the drill are to be essential to plant operation conducted in safety significant and to contain significant fire areas.hazards.lMVJW2 TMMiM. oAt 09ft V*Ma 10 Revision 1 Page A-61 Indiana Michican Power CNP NFPA 805 TransiWon Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.3 Training and Drills Drill records shall be maintained

• Complies Per TRP-2070-TAP-400-FPP, TRP-2070-TAP-400-FPP, "Fire Drills", (c)(4) detailing the dill scenario, industrial drill records, which includes all Rev. 1, Section 3A.4.b fire brigade member response, and data sheets listed in the table of ability of the industrial fire brigade to contents, are maintained In PMP-2030-REC-001, "Records perform as a team. accordance with PMP-2030-Management", Rev. 14 REC-001.3.4.3 Training and Drills A critique shall be held and

• Complies A critique is held after each fire TPD-600-FP, "Fire Protection Training (c)(5) documented after each drill. drill per CNP procedures Program Description-, Rev. 4, Section TPD-600-FP and TRP-2070-3.5.1.a.2.a(8)

TAP-400-FPP.

This critique is part of Data Sheet 11 in TRP-2070-TAP-400-FPP, "Fire Drills", TRP-2070-TAP-400-FPP and is Rev. 1, Data Sheet 11 and Section maintained and documented in 3.3.4 accordance with PMP-2030-REC-001. PMP-2030-REC-001, "Records Management", Rev. 14 3.4.4 Fire-Fighting Protective clothing, respiratory

• Complies The clothing and fire fighting 12-FPP-2270-066-023, "Inventory of Equipment protective equipment, radiation tools supplied are discussed In Fire Brigade Personal Protective monitoring equipment, personal 12-FPP-2270-066-023 and 12- Equipment", Rev. 1 dosimeters, and fire suppression FPP-2270-066-005.

These equipment such as hoses, nozzles, supplies conform to NFPA 12-FPP-2270-066-005, "Fire Truck fire extinguishers, and other needed standards.

Inventory and Operability Test", Rev.equipment shall be provided for the 2 industrial fire brigade. This equipment shall conform with the Engineering Equivalency Evaluation applicable NFPA standards.

14.1.1, "NFPA 600 Code Conformance Review", Rev. 0 3.4.5 Off-Site Fire Off-Site Fire Department Interface.

e N/A N/A -Section Heading, see sub- N/A Department Interface sections for any specific compliance statements.

1Zio2 Tr kpm( lb'*,ia 1.P.eA Revision 1 Pag A-62 Indiana Michigan Power CNP NFPA 805 Transftn Report -Aftwhrnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.4.5.1 Mutual Aid Off-site fire authorities shall be

• Complies Offlite resources are available FPPM, Rev. 11, Section 3.14 Agreement offered a plan for their interface through local municipal paid on during fires and related call and full time fire TPD-600-FP, 'Fire Protection Training emergencies on site. departments.

Resource planning Program Description', Rev. 4, Section is available in the Fire Pre- 3.5.1.f.2 Plans, Volume Ill. Drills am conducted at least once per year CNP Fire Pre-Plans, Volumes I, II, with offsite resources.

Mutual and Ill, Revisions 9, 7, and 12 aid agreements have been respectively established with the offsite fire departments.

3.4.5.2 Site-Specific Fire fighters from the off-site fire

• Complies CNP procedures state that the TPD-600-FP, "Fhre Protection Training Training authorities who are expected to offsite fire departments shall be Program Description', Rev. 4, Section respond to a fire at the plant shall included in at least one fire drill 3.5.1.f.2 be offered site-specific training and per calendar year. In addition, shall be invited to participate in a formalized yearly radiation drill at least annually.

protection training is provided for the local fire department 3.4.5.3 Security and Plant security and radiation , Complies Per Plant Procedure TPD-600- TPD-600-FP, "Fire Protection Training Radiation Protection protection plans shall address off- FP, radiation protection Program Description', Rev. 4, Section site fire authority response.

familazation training is 3.5.1.f.3 provided to offsite fire departments once per year. TRP-2070-TAP-400-FPP, 'Fire Drills', Rev. 1. Section 3.3.2.c.CNP Fire Pre-Plans, Volume Ill, Rev.12 3.4.6 Communications An effective emergency

• Complies A fire and emergency radio FPPM, Rev. 11, Section 12.4 communications capability shall be system is provided.

Details of provided for the industrial fire the system design are provided brigade. in Section 12.4 of the FPPM.CNP-lIWC-W1.t.Oh

?lfJW12 Ton" 0t ý Coo Vinitn 1" Revision 1 Page A-63 Indiana Michlban Power CNP NFPA 805 Transition Repod -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5 Water Supply Water Supply.

• N/A N/A -Section Heading, see sub- N/A sections for any specific compliance statements.

3.5.1 [Water Supply A fire protection water supply of

• Complies Section Heading, see Refer to basis documentation in the Flow Code adequate reliability, quantity, and compliance bases below for sub-sections of this element Requirements]

duration shall be provided by one of compliance statements for the two following methods. specific subsections.

3.5.1 [Water Supply Provide a fire protection water

• Complies The fire protection system FPPM, Rev. 11, Section 4.1.2 Flow Code supply of not less than two separate includes two tanks nominally Requirements] (a) 300,000-gal (1,135,500-L) supplies.

sized at 685,000 gallons. The OP-12-5152S, -Fire Protection Water normal tank water level for each Piping at N & S Storage Tanks Units tank is between 612,000 gallons 1 & 2", Rev. 5 and 621,000 gallons. The minimum tank water level in each tank is set at 565,000 gallons.CW-7"DAc-%1.t.Ob 1MOMM2 Twaum, Dn wMtM Cods VWnOM 12.0 Revision I Page A-64 Indiana Michidan Power CNP NFPA 805 Transition ReDort -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.1 [Water Supply Flow Code Requirements] (b)Calculate the fire flow rate for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This fire flow rate shall be based on 500 gpm (1892.5 LJmin)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..N/A This section is not applicable because CNP utilizes the method allowed in subsection (a) to comply with Section 3.5.1.NIA a.'-1m _c .1i l TrmiMM Dn" 0sai 0 ~VaniI."1 112 Rev7isio1 IPae 1" Revision I Page A-65 Indiana Michican Pbwer CNP NFPA 805 Transition Report -Affachnient A Attachment A -NEI 04-02 Table B-I -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.2 [water Supply Tank Code Requirements]

The tanks shall be interconnected 9 Complies such that fire pumps can take suction from either or both. A failure e Compiles with use of in one tank or its piping shall not EEEEs 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 consktent with the demands of the fire service.Complies: The primary fire pumps can take sucti from either of the tanks.The two tanks are isolated by valves so that the failure of one tank will not affect the other tank.The tanks have been designed in accordance with NFPA 22, as specified in DCC-CE-185-QCF.

Complies with use of EEEEs: Non-listed valves are installed in some portions of the fire protection system. These valves have been evaluated to be equivalent to NFPA requirements by Engineering Equivalency Evaluation 12.24.FPPM, Rev. 11, Section 4.1.2 OP-12-5152S, "FIre Protection Water Piping at N & S Storage Tanks Units 1 & 2', Rev. 5 DCC-CE-185-QCF, "Design, Fabrication, and Erection of the Dedicated Fire Protection Water Supply Storage Tanks', Rev. 0, Section 4.1.c 1 Engineering Equivalency Evaluation 12.24, "NFPA 24 -Usted Valve Deviation 12-ZMO-400

& 401", Rev. 0 TUiMMOO 0MIMUScoftVA*" I" 1'Wn2 Reviion Pag A-I Revision I Page A-66 Indiana Michigan Power CNP NFPA 805 Tran&Won Report -Affachnient A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.3 [Water Supply Pump Code Requirements]

Fire pumps, designed and installed 9 Compies 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.CNP is provided with three fire pumps. Any two fire pumps can supply enough water to extinguish a fire on the largest demand system.I&M has committed to NFPA 20 for the installation of fire pumps at CNP. The fire pumps have been reviewed against the requirements of NFPA 20, 1990 Edition, as evaluated in CNP"NFPA Code Deviations and Justifications.

SD-DCC-FP1 06, "Fire Protection System -Water Supply System", Rev.0, Section 8.6.1 Calculation No. MD-12-F1RE-008-S, Rev. 0, Section 8.1 FPPM, Rev. 11, Section 14.1 CNP "NFPA Code Deviations and Justifications*, Rev. 2 QWO 1'- ,i 1.*Revision-." I ag A Revision I Page A-67 Indiana Michican Power CNP NFPA 805 Transihon Report -Affachrnent A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.4 [Water Supply Pump Diversity and Redundancy]

At 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.0Complies Three fire pumps, two of which UFSAR, Section 9.8.1, "Primary and are diesel engine-drive, each of Pegging Pumps", Items a) and b)2,500 gpm capacity are provided as the primary pumps for fire FPPM, Rev. 11, Section 14.3.2 protection of both units. The water supply pumps are SD-DCC-FPI06, TFire Protection installed in accordance with System -Water Supply System-, Pft NFPA 20,1990 Edition, as 0, Section 8.6.1 evaluated in CNP *NFPA Code Deviations and Justificationsm.

Calculation No. MD-12-FIRE-008-S.

I, Any two fire pumps can supply enough water to extinguish a fire on the largest demand system.Rev. 0, Section 8.1 CNP *NFPA Code Deviations and Justifications", Rev. 2 3.5.5 [Water Supply Each pump and its driver and a Complies with use of Each fire pump and its driver RFC-12-3065, -Installation of Pump Separation controls shall be separated from the EEEEs and controls is provided in its Dedicated Water Supply", Rev. 2 Requirements]

remaining fire pumps and from the own room with rated fire rest of the plant by rated fire barriers.

The fire barriers have Engineering Equivalency Evaluation barriers.

been evaluated in accordance 11.38, "Fire Protection Pump House with NFPA 805, section 3.11.2, (Fire Area YD)O, Rev. 0 and by Engineering Equivalency Evaluation 11.38.%~rJ&MD12

'rT# n DMW AM= OW l1.2B Revision 1 Page A-68 Indiana Michigan Power CNP NFPA 805 Transition Report -Attachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.6 [Water Supply Pump Start/Stop Requirements]

3.5.7 [Water Supply Pump Connection Requirements]

Fire pumps shall be provided with a Complies automatic start and manual stop only.Individual fire pump connections to

• Complies the yard fire main loop shall be provided and separated with sectionalizing valves between connecdtis.

All primary pumps are arranged for (1) automatic starting by operation of pressure sensing devices, (2) remote manual start of the fire pumps from switches in either control room and (3)local starting at each pump.They cannot be shutdown until extinguishment of a fire is verified by the control room operators.

Shutdown must be performed at the local fire pump control panels.Fire pump connections to the yard main fire loop are provided with seclonaizing valves between connections.

The three sectionalizing valves shown on the drawing are FP-636, FP-644, and FP-656.Isolating valves with post indicators or curb boxes are Installed in the outdoor loop header so that the entire loop is not disabled should maintenance be required on a small section.FPPM, Rev. 11, Section 4.1.2 Plant Drawing OP-12-5152T, Rev. 10 UFSAR, Section 9.8.1, "Water Distribution", Item b)aWWuV1 .1.~ah2T".NOMM Ae 01Vw&m12.Revision I Page A-69 Indiana Michican Power CNP NFPA 805 Tranwffion ReDoft -Affachment A Attachment A -NEI 04-02 Table B-1 -Transition of Fundamental Fire Protection Program and Design Elements (NFPA 805 Chapter 3)NFPA 805 Element NFPA 805 Requirement Compliance Statement Compliance Basis Reference Document 3.5.8 [Water Supply A method of automatic pressure Complies One 50 gpm electric motor UFSAR, Section 9.8.1, "Primary and Pressure Maintenance maintenance of the fire protection driven pegging pump is provided Pegging Pump", tem d)Limitations]

water system shall be provided and located within the fire pump independent of the fire pumps. house. Its sole purpose is to OP-12-5152A, "Fire Protection

-maintain pressure in the fire Water Piping at Pumps Unit I & 2", protection piping system. Rev. 19 3.5.9 [Water Supply Means shall be provided to Complies Control room signals will alarm FPPM, Rev. 11, Section 4.1.1 Pump Operation immediately notify the control room, when fire pumps are operated.Notification]

or other suitable constantly Plant Procedure 12-attended location, of operation of PPP-4030-066-006, "Three Year Fire fire pumps. Protection Water System Unobstructed Flow Test", Rev. 5, Attachments 1 and 2 3.5.10 [Water Supply An underground yard fire main loop,

• Complies Complies:

Flow Diagram 12-5152 Series Yard Main Code designed and installed in An underground yard fire main Requirements]

accordance with NFPA 24, .Complies with use of loop is installed in accordance RFC-12-3065, "Installation of"Standard for the Installation of EEEEs with NFPA 24. Dedicated Water Supply", Rev. 2 Private Fire Service Mains and Their Appurtenances," shall be Complies with use of EEEEs: DCC-PM-108-QCS, "Installation of installed to furnish anticipated water Non-lited valves are instafled in Underground Rev. 0 requirements.

some portion of the fire protection system. These valves FPPM, Rev. 11, Section 14.3.2 have been evaluated to meet the NFPA requirements by Engineering Equivalency Evaluation Engineering Equivalency 12.24, "NFPA 24 -Listed Valve Evaluation 12.24. Deviation 12-ZMO-400

& 401", Rev. 0 CPJTDO%_vl.IM W30=12 Tram~ 080WýAPmýCýNOWmO 1I" Revision I Page A-70