L-PI-18-005, License Amendment Request to Revise License Condition Associated with Implementation of NFPA 805

License Amendment Request to Revise License Condition Associated with Implementation of NFPA 805

ML18138A402
Person / Time
Site:	Prairie Island
Issue date:	05/18/2018
From:	Sharp S Northern States Power Company, Minnesota, Xcel Energy Inc
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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ML18138A401	List: L-PI-18-005, License Amendment Request to Revise License Condition Associated with Implementation of NFPA 805
References
L-PI-18-005
Download: ML18138A402 (111)

Text

ENCLOSURE 6 CONTAINS SECURITY-RELATED INFORMATION -

WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 1717 Wakonade Drive Welch, MN 55089 ~ Xcel Energy*

RESPONSIBLE BY NATURE ~

800.895.4999 xcelenergy.com May 18, 2018 L-PI-18-005 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 License Amendment Request to Revise License Condition Associated with Implementation of NFPA 805

References:

1) Letter from NSPM to NRC, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors, dated September 28, 2012 (ADAMS Accession No. ML12278A405)

2) Letter from NSPM to NRC, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information (CAC Nos.

ME9734 and ME9735), dated December 14, 2016 (ADAMS Accession No. ML16350A105)

3) Letter from NRC to NSPM, Issuance of Amendments Re: Transition to NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (CAC Nos. ME9734 and ME9735),

dated August 8, 2017 (ADAMS Accession No. ML17163A027)

In Reference 1, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, submitted a license amendment request for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to transition to National Fire Protection Association (NFPA) Standard NFPA 805. In Reference 2, NSPM provided a revised Attachment S, Modifications and Implementation Items, Table S-2, Plant Modifications Committed in its entirety.

Document Control Desk Page 2 The NRC issued a Safety Evaluation (SE) in Reference 3 regarding transition to a risk-informed, performance-based fire protection program in accordance with 10 CFR 50.48(c). The SE included a statement that, "The licensee shall implement the modification to its facility as

• described in Attachment S, Table S-2, 'Plant Modifications Committed"'.

-During implementation of the NFPA 805 program at PINGP, NSPM determined that revisions were required to certain NFPA 805 modifications. Specifically, five modifications in Table S-2 were identified as no longer required. Enclosure 1 to this letter identifies and evaluates each of the proposed changes.

Enclosures 2 and 4 provide marked up versions of Attachments M and S, respectively.

Enclosures 3, 5, and 6 provide clean copies of Attachment M, S, and W, respectively.

Enclosure 6 contains security-related information. Accordingly, NSPM requests that Enclosure 6 be withheld from public disclosure in accordance with 10 CFR 2.390(d)(1).

In order to facilitate efficient planning and use of resources, NSPM_ requests the NRC complete its review of this amendment request in a timeframe commensurate with other licensees' similar amendment requests (approximately six months). Once approved, NSPM requests an implementation period of 60 days.

If additional information is required, please contact Mr. Shane Jurek at (612) 330-5788.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare, under penalty of perjury, that the foregoing is true and correct.

Exec§ o~ M , 8, 2018.

~~

--Scott Sharp 1 Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (6) cc: Administrator, Region 111, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota (without Enclosure 6)

ENCLOSURE 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 Evaluation of the Proposed Change License Amendment Request to Revise Commitment Associated with Implementation of NFPA 805 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 NRC Guidance for Changes to Approved Modifications 2.2 Attachment M Changes 2.3 Attachment S Changes 2.4 Attachment W Changes 2.5 Facility Description

3.0 TECHNICAL EVALUATION

3.1 Charging Pump Suction Pressure Protection Modification 3.2 Panels 136, 137 and 217 Breaker Coordination Modification 3.3 Pressurizer PORVs and Heaters Control Switch Modification 3.4 Cable 2DCA-10 Modification 3.5 Cable 1DCB-18 Modification 3.6 Cumulative Risk Impact of Deleted Modifications

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Subsequent

Enclosures:

Enclosure 2: Attachment M, License Condition Changes (Markup)

Enclosure 3: Attachment M, License Condition Changes (Retyped)

Enclosure 4: Attachment S, Modifications and Implementation Items (Markup)

Enclosure 5: Attachment S, Modifications and Implementation Items (Retyped)

Enclosure 6: Attachment W, Fire PRA Insights Page 1 of 23

L-PI-18-005 NSPM License Amendment Request to Revise Commitment Associated with Implementation of NFPA 805 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, hereby requests an amendment to the Renewed Facility Operating Licenses (RFOLs) for the Prairie Island Nuclear Generating Plant (PINGP),

Units 1 and 2. PINGP RFOL, Paragraph 2.C(4)(c), Transition License Conditions requires NSPM to implement modifications to PINGP as described in Attachment S, Modifications and Implementation Items, Table S-2, Plant Modifications Committed as submitted in Reference 1 to complete the transition to full compliance with 10 CFR 50.48(c). This proposed license amendment request (LAR) changes the above license condition to include a reference to this letter.

The guidance of the March 2, 2016, letter from the NRC to the Nuclear Energy Institute (NEI)

(Reference 2) was used to develop this LAR. NSPM utilizes the guidance in Option A described in Reference 2 because the plant modifications have been evaluated using the accepted fire Probabilistic Risk Assessment (PRA) methods and approaches as summarized in NSPMs NFPA 805 Safety Evaluation dated August 8, 2017 (Reference 3). Accordingly, Attachments M, S, and W of the previously approved NFPA 805 submittal for PINGP were revised. The revisions are based on five changes to Attachment S, Table S-2.

2.0 DETAILED DESCRIPTION 2.1 NRC Guidance for Changes to Approved Modifications In Reference 2, the NRC provided guidance in developing a LAR for licensees wishing to change or remove a plant modification. The NRC provided three options for licensees to provide the necessary information for NRC to review in a timely manner; the most germane option for the NSPM proposed changes to the approved NFPA 805 modifications is Option A.

NRC recommended that the following information be provided for an Option A approval:

i. A summary of all changes to the modifications; ii. A summary of all changes to the PRA models and explanation for each change; iii. New, updated versions in their entirety of: the License Condition (Attachment M), list of plant modifications (Attachment S) and the summarizing area wide change-in-risk result tables (Attachment W); and iv. A statement that the defense-in-depth (DID) and safety margin evaluations associated with the original LAR have been completed on the proposed changes.

Items i, ii, and iv are provided in this Enclosure. Enclosures 2 and 3 provide marked up and re-typed versions of Attachment M, respectively, to reflect the proposed changes to PINGP RFOL paragraphs 2.C(4) and 2.C(4)(c). Enclosures 4 and 5 provide marked up and re-typed versions of Attachment S, respectively, to reflect the proposed removal of five modifications from Page 2 of 23

L-PI-18-005 NSPM Table S-2. Enclosure 6 provides a new version of Attachment W to reflect the changes in the risk calculations associated with deleting the five modifications. Due to the large number of changes to Attachment W, a marked up version is not being supplied and changes will not be identified by revision bars in the right margin.

2.2 Attachment M Changes The current PINGP RFOL Paragraph 2.C(4)(c), Transition License Conditions, Item 2, for each PINGP unit states the following:

The licensee shall implement the modifications to its facility as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI-16-090, dated December 14, 2016, to complete the transition to full compliance with 10 CFR 50.48(c), before the end of the second full operating cycle for each unit after approval of the LAR. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

This LAR proposes revising the PINGP RFOL Paragraph 2.C(4)(c), Transition License Conditions, Item 2, to state the following:

The licensee shall implement the modifications to its facility as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI-18-005, dated May 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c), before the end of the second full operating cycle for each unit after approval of the NFPA 805 License Amendment dated August 8, 2017. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The modification of the Transition License Conditions in PINGP RFOL Paragraph 2.C(4)(c) necessitates further changes in Paragraph 2.C(4), Fire Protection. The current PINGP RFOL Paragraph 2.C(4) for each PINGP unit states the following:

NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 28, 2012 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluation dated August 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change Page 3 of 23

L-PI-18-005 NSPM to a technical specification or a license condition, and the criteria listed below are satisfied.

This LAR proposes revising the PINGP RFOL Paragraph 2.C(4), Fire Protection, to state the following:

NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated September 28, 2012, and May 18, 2018 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluations dated August 8, 2017, and [Safety Evaluation Date]. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

2.3 Attachment S Changes NSPM requests five changes to Attachment S, Table S-2. Specifically, NSPM is requesting the deletion of modifications 15, 20, 27, 30 and 33 from Table S-2. The changes to these five modifications are discussed in detail in sections 3.1 through 3.5, respectively, of this enclosure.

The discussion includes a description of the proposed change, the basis for the change, the risk impacts and the preservation of defense in depth and safety margins.

Several modifications in Table S-2 have been completed since Table S-2 was last submitted in Reference 1. However, the scope of changes to Table S-2 submitted in this document was intentionally limited to only the deletion of the five modifications. Table S-2 was not updated to reflect any modifications which have already been installed and could be transferred to Table S-1.

2.4 Attachment W Changes The PINGP fire PRA model was updated to reflect the deletion of the five modifications from Table S-2. The fire PRA model update included changes related to the following model elements:

Equipment Selection - The equipment selection was updated to include review of required instrumentation for operator actions, screening criteria to determine if instrumentation was required to be modeled in the fault tree, and equipment related to updated cable selection.

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L-PI-18-005 NSPM Fire Induced Risk Model (FIRM) - The FIRM was updated to include changes from the current internal events PRA model (Revision 5.3). The alternate shutdown portions of the FIRM were updated to better reflect operator actions taken after control room abandonment.

Fire Ignition Frequencies - Fire Ignition frequencies were updated according to NUREG-2169, Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database, United States Fire Event Experience Through 2009 (Reference 4).

Cable Selection and Detailed Circuit Failure Analysis - Some components cable selection conservatively included cable that did not fail the credited functions. The cable selection was updated to exclude cables that have no impacts on the credited functions.

For the pressurizer heater circuits, additional analysis was performed to determine which cables could cause spurious operation of relays instead of simply assuming relay contacts were always in the worst-case position.

Circuit Failure Mode Likelihood Analysis (CFMLA) - CFMLA was applied to additional components that were risk-significant.

Scoping and Detailed Fire Modeling - Incorporated the electrical cabinet heat release rates from NUREG-2178, Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire (RACHELLE-FIRE) (Reference 5) and the non-suppression rates in NUREG-2169, EPRI/NRC-RES Fire Human Reliability Analysis Guidelines. The NUREG-2178 obstructed plume method was not incorporated. Some risk-significant raceways (conduits) previously assumed to be everywhere in the fire compartment were identified to be located in specific locations within the fire compartment. The fire scenarios were updated to remove conservative assumptions in risk-significant fire scenarios. The sensitivity study performed for NSPMs response to NFPA 805 PRA RAI 21 in Reference 1 related to NUREG-2180, Determining the Effectiveness, Limitations, and Operator Response for Very Early Warning Fire Detection Systems in Nuclear Facilities (DELORES-VEWFIRE) (Reference 6) was incorporated into the baseline fire PRA model.

Post-Fire Human Reliability Analysis (FHRA) - The FHRA was updated to include some additional operator actions and refine existing actions in accordance with NUREG-1921, EPRI/NRC-RES Fire Human Reliability Analysis Guidelines (Reference 7) guidance.

Also, some new thermal hydraulic analyses were done to support both new fire post-initiation actions and the existing actions.

Fire Risk Quantification - The updated fire PRA model was quantified with the above-listed changes reflecting removal of five NFPA 805 modifications and refinements to several fire PRA elements for the updated baseline fire PRA model (Revision 5.3).

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L-PI-18-005 NSPM The fire PRA notebooks were updated to document all of the above changes.

Additionally, a focused-scope peer review was performed on the cable thermal response methodology contained in Appendix H to NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities (Reference 8) as described in NSPMs response to NFPA 805 PRA RAI 21. The focused-scope peer review also reviewed the PINGP treatment of main control board fires as described in NSPMs response to NFPA 805 PRA RAI 12 (Reference 9) because this was an upgrade from the previous methodology that was used in the 2012 fire PRA peer review. No peer review findings were identified during the focused-scope peer review. The methodology for the main control board fires has not changed since NSPMs response to NFPA 805 PRA RAI 12.

As a result, the risk calculations provided in Attachment W to the NFPA 805 LAR have been updated to reflect the changes to the PRA model. A revised version of Attachment W is provided as Enclosure 6.

2.5 Facility Description PINGP is a two unit plant located on the right (west) bank of the Mississippi River within the city limits of the city of Red Wing, Minnesota. The facility is owned and operated by NSPM.

Each unit at PINGP employs a two-loop pressurized water reactor (PWR) designed and supplied by Westinghouse Electric Corporation. The initial PINGP application for a Construction Permit and Operating License was submitted to the Atomic Energy Commission (AEC) in April 1967. The Final Safety Analysis Report was submitted for application of an Operating License in January 1971. Unit 1 began commercial operation in December 1973 and Unit 2 began commercial operation in December 1974.

The PINGP was designed and constructed to comply with NSPMs understanding of the intent of the AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. PINGP was not licensed to NUREG-0800, Standard Review Plan.

3.0 TECHNICAL EVALUATION

3.1 Charging Pump Suction Pressure Protection Modification Proposed Change:

Delete the proposed modification of the Units 1 and 2 charging pumps described in item 15 on page S-18 of Attachment S, Table S-2, as:

Problem Statement:

Fire-induced damage that could damage cables causing multiple spurious operations [MSOs] resulting in damage to the charging pumps. If fire induced cable damage caused spurious isolation of letdown to the VCT [Volume Control Tank] (CV-31226 and CV-31255) and failure to open the RWST [Refueling Water Page 6 of 23

L-PI-18-005 NSPM Storage Tank] supply (MV-32060) and failure to trip the charging pumps, the 11, 12, 13, 21, 22 and 23 positive displacement charging pumps (MTR 111J-1) and MTR211J-1 could be damaged due to lack of Net Positive Suction Head (NPSH).

Need to prevent unrecoverable damage to credited charging pump due to fire in FA [Fire Area] 13/18 to resolve MSO issue.

Proposed Modification:

Install suction pressure protection for all the charging pumps to ensure adequate NPSH exists to prevent damage to the charging pumps.

Basis for Change:

The modification to install suction pressure protection for charging pumps no longer provides significant risk benefit to warrant the modification because the fire PRA model was updated to better reflect plant system response. The VCT outlet motor operated valves (MV-32061 and MV-32063) will be de-energized to preclude spurious closure in the event of a fire.

Risk Impact Discussion:

This modification was proposed to protect the charging pumps from inadequate NPSH. The normal letdown flow path flows into the VCT is the normal source to the positive displacement charging pumps for the volume control system. Spurious isolation of the letdown flow path would stop the flow into the VCT and level would drop. If the charging pumps are not stopped and the RWST supply valve failed to open on low VCT level, the VCT water inventory would be depleted and the charging pumps would no longer function as intended. The fire PRA model includes an operator action to open the RWST supply to the charging pumps. Once the RWST supply valve is open, the elevation head of the RWST remains larger than the head of the VCT for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at charging pump flow rates. Therefore, closing the VCT outlet valve is not time critical. The fire PRA model was updated to remove credit for the modification by deleting the basic events and fault tree gates that were added to credit the modification. The results remain acceptable and are presented in the new Attachment W tables provided in .

Defense in Depth/Safety Margin Discussion:

Defense in depth involves the following three echelons:

1. Prevent fires from starting;

2. Rapidly detect, control and promptly extinguish those fires that do occur, thereby preventing fire damage; and

3. Providing adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

Page 7 of 23

L-PI-18-005 NSPM Defense in depth is maintained after the deletion of this modification for charging pump suction protection because it does not impact the ability to prevent fires from starting, nor does it impact the ability to rapidly detect, control, and extinguish fires that do occur. An adequate level of fire protection is maintained because the opening of the VCT supply valve breaker will preclude spurious isolation of the VCT supply. Failure of the RWST supply valve to open is still modeled in the fire PRA model.

Safety margins are maintained in the fact that:

Fire detection and fire suppression systems credited in NFPA 805, Chapter 4, have been evaluated to meet the requirements of NFPA 805, Chapter 3, and their associated codes of record for those systems or provided with acceptable alternatives using processes accepted for use by the NRC.

The risk-informed, performance based processes utilized are based upon NFPA 805, as endorsed by the NRC in 10 CFR 50.48(c).

The fire risk evaluation process is in accordance with NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c) (Reference 10), endorsed by NRC Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants (Reference 11), and clarified by Frequently Asked Question (FAQ) 07-0030, Establishing Recovery Actions (Reference 12).

The fire PRA was developed with guidance from NUREG/CR-6850 which was developed jointly between the NRC and the Electric Power Research Institute (EPRI).

The internal events PRA and fire PRA have received a formal industry peer review based on the NEI guidelines, in order to ensure the fire PRA meets the appropriate standards of American Society of Mechanical Engineers (ASME) / American Nuclear Society (ANS) Standard ASME/ANS RA-Sa-2009, Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Applications (Reference 13).

The peer review of the fire PRA model was conducted by a diverse group of PRA practitioners from other PWR plants and industry.

Fire modeling performed in support of the transition has been performed within the fire PRA utilizing codes and standards developed by industry and NRC staff which have been verified and validated in authoritative publications, such as NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications (Reference 14).

Page 8 of 23

L-PI-18-005 NSPM 3.2 Panels 136, 137 and 217 Breaker Coordination Modification Proposed Change:

Delete the proposed modification to Panels 136, 137 and 217 described in item 20 on page S-19 of Attachment S, Table S-2, as:

Problem Statement:

The current Fire PRA Model assumes proper coordination exists for all credited power supplies. Per Fire PRA credited power supplies lack selective coordination.

Proposed Modification:

Install the appropriate fuses and/or breakers to establish proper selective coordination for panels 136, 137, and 217 credited to be coordinated.

Basis for Change:

The fire PRA model was updated to include failure of the un-coordinated load cables as causing a failure of the upstream un-coordinated supply breaker, which causes a loss of power for Panels 136 and 137 that lack selective fuse/breaker coordination. The fire PRA no longer credits a recovery action to transfer the source breaker for Panel 211 or Panel 213 to the Interruptible Panel 217 to restore power to these instrument buses due to a fire in Fire Area 31.

Therefore, electrical coordination of Panel 217 is not required to support these recovery actions.

Risk Impact Discussion:

Panel 217 was previously credited to be an alternate power supply to alternating current (AC)

Instrument Panels 211 and 213 in the event of fire damage to the normal AC power supply to Panels 211 or 213. Panels 211 and 213 support process monitoring indications in the main control room. Loss of power to these panels results in degraded instrumentation. The fire PRA model considers the degraded instrumentation impact in these fire scenarios. Since Panel 217 is no longer credited to re-power Panels 211 and 213 in the event of a fire, the lack of electrical coordination on Panel 217 has no impact for Panels 211 and 213.

Panels 136 and 137 provide AC power to the cooling water strainers backwash controller and the diesel driven cooling water pumps (DDCLPs) fuel oil transfer pumps. Loss of power to the cooling water strainers backwash control results in loss of automatic backwash of the cooling water strainers upon high differential pressure. A calculation was performed and demonstrates this is not a time critical function and the strainers will not significantly obstruct cooling water flow during the mission time. Therefore, recovery actions are no longer required for the cooling water strainers and Panels 136 and 137 are not required to support the cooling water strainers.

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L-PI-18-005 NSPM The diesel fuel oil transfer pumps for the DDCLPs are powered from Panels 136 and 137 and provide fuel oil from underground storage tanks to the 12 DDCLP (Train A) and 22 DDCLP (Train B) day tanks, respectively. There are also three motor driven cooling water pumps (11, 21, and 121) that supply cooling water to the cooling water header. The un-coordinated load cables are mapped to failing the upstream panels in the fire PRA model. Therefore, the impact of lack of coordination is included in the fire PRA model.

The additional risk due to lack of electrical coordination on Panels 136, 137, and 217 has been incorporated into the fire PRA model and the results are included in the new Attachment W tables in Enclosure 6.

Defense in Depth/Safety Margin Discussion:

Defense in depth involves the following three echelons:

1. Prevent fires from starting;

2. Rapidly detect, control and promptly extinguish those fires that do occur, thereby preventing fire damage; and

3. Providing adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

Defense in depth is maintained after the deletion of this modification for breaker coordination because it does not impact the ability to prevent fires from starting, nor does it impact the ability to rapidly detect, control, and extinguish fires that do occur. An adequate level of fire protection is maintained because the impact of the lack of electrical coordination is included in the fire PRA model and the results remain acceptable.

Safety margins are maintained in the fact that:

Fire detection and fire suppression systems credited in NFPA 805, Chapter 4, have been evaluated to meet the requirements of NFPA 805, Chapter 3, and their associated codes of record for those systems or provided with acceptable alternatives using processes accepted for use by the NRC.

The risk-informed, performance based processes utilized are based upon NFPA 805, as endorsed by the NRC in 10 CFR 50.48(c).

The fire risk evaluation process is in accordance with NEI 04-02 as endorsed by RG 1.205 and clarified by FAQ 07-0030.

The fire PRA was developed with guidance from NUREG/CR-6850, which was developed jointly between the NRC and EPRI.

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L-PI-18-005 NSPM The internal events PRA and fire PRA have received a formal industry peer review based on the NEI guidelines, in order to ensure the fire PRA meets the appropriate standards of ASME/ANS RA-Sa-2009.

The peer review of the fire PRA model was conducted by a diverse group of PRA practitioners from other PWR plants and industry.

Fire modeling performed in support of the transition has been performed within the fire PRA utilizing codes and standards developed by industry and NRC staff which have been verified and validated in authoritative publications, such as NUREG 1824.

3.3 Pressurizer PORVs and Heaters Control Switch Modification Proposed Change:

Delete the proposed modification to the Units 1 and 2 pressurizer power operated relief valves (PORVs) and pressurizer heaters described in item 27 on page S-21 of Attachment S, Table S-2, as:

Problem Statement:

A fire in the Control Room (Fire Area 13) or the Relay and Cable Spreading Room (Fire Area 18) could cause spurious opening of valves that could lead to a loss of inventory.

Proposed Modification:

Install switches in the Control Room to isolate Pressurizer PORV, and Pressurizer Heaters.

Basis for Change:

A detailed circuit analysis was performed on the process control inputs to the pressurizer level and pressure control system that provides automatic signals to the pressurizer PORVs and pressurizer heaters. Previously, relays were assumed to be failed in the most adverse position.

Now, the signal and control cables that impact the relays are mapped and only failed in the applicable scenarios. An additional recovery action was credited to manually operate pressurizer heater breakers outside the control room in alternate shutdown procedures after control room abandonment.

Risk Impact Discussion:

The fire PRA model was updated to remove credit for new control room isolation switches, include the detailed circuit analysis for the pressurizer heaters and PORVs, and include credit for recovery actions outside the control room to locally operate pressurizer heater breakers.

Operator action to close the pressurizer PORVs from the control room is credited to isolate Page 11 of 23

L-PI-18-005 NSPM spurious pressure signals if the pressurizer PORVs control switches and cables have not been impacted by the fire. The existing action to isolate pressurizer PORVs outside the main control room is also still credited for alternate shutdown scenarios. The fire PRA results remain acceptable with credit for modification to pressurizer PORVs and heater circuits removed. The results are included in the new Attachment W tables in Enclosure 6.

Defense in Depth/Safety Margin Discussion:

Defense in depth involves the following three echelons:

1. Prevent fires from starting;

2. Rapidly detect, control and promptly extinguish those fires that do occur, thereby preventing fire damage; and

3. Providing adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

Defense in depth is maintained after the deletion of this modification for isolation switch installation because it does not impact the ability to prevent fires from starting, nor does it impact the ability to rapidly detect, control, and extinguish fires that do occur. An adequate level of fire protection is maintained because the spurious operation of the pressurizer PORVs and pressurizer heaters is mitigated by actions outside the main control room to isolate these spurious events and the risk of these actions is included in the fire PRA model.

Safety margins are maintained in the fact that:

Fire detection and fire suppression systems credited in NFPA 805, Chapter 4, have been evaluated to meet the requirements of NFPA 805, Chapter 3, and their associated codes of record for those systems or provided with acceptable alternatives using processes accepted for use by the NRC.

The risk-informed, performance based processes utilized are based upon NFPA 805, as endorsed by the NRC in 10 CFR 50.48(c).

The fire risk evaluation process is in accordance with NEI 04-02 as endorsed by RG 1.205 and clarified by FAQ 07-0030.

The fire PRA was developed with guidance from NUREG/CR-6850, which was developed jointly between the NRC and EPRI.

The internal events PRA and fire PRA have received a formal industry peer review based on the NEI guidelines, in order to ensure the fire PRA meets the appropriate standards of ASME/ANS RA-Sa-2009.

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L-PI-18-005 NSPM The peer review of the fire PRA model was conducted by a diverse group of PRA practitioners from other PWR plants and industry.

Fire modeling performed in support of the transition has been performed within the fire PRA utilizing codes and standards developed by industry and NRC staff which have been verified and validated in authoritative publications, such as NUREG 1824.

3.4 Cable 2DCA-10 Modification Proposed Change:

Delete the proposed modification of Unit 2 cable 2DCA-10 described in item 30 on page S-21 of Attachment S, Table S-2, as:

Problem Statement:

A fire in Fire Area 31 could damage cables that provide DC [Direct Current]

power to vital auxiliaries which impacts risk.

Proposed Modification:

Modify risk significant cable (2DCA-10) from risk significant fire initiators in Fire Areas [sic] 31.

Basis for Change:

Cable 2DCA-10 provides DC power to Unit 2, Train A DC Panel 25, which powers relays that provide automatic start of the 21 Motor Driven Auxiliary Feed Water (AFW) Pump on low steam generator level or Safety Injection (SI) signal, but operators can still start the 21 AFW Pump from the control room. The protection of cable 2DCA-10 was a risk reduction modification and is not a Variance From Deterministic Requirement (VFDR) of NFPA 805 because the 21 AFW Pump remains available from the control room to provide AFW to the steam generators.

Risk Impact Discussion:

The 21 AFW Pump starts due to the following signals:

SI signal Low steam generator level Both main feedwater pumps tripped Anticipated Transient without a Scram (ATWS) Mitigating System Actuation Circuitry (AMSAC) / Diverse Scram System (DSS)

Page 13 of 23

L-PI-18-005 NSPM Manual start by operators The main feedwater system and AMSAC/DSS start signals are not credited in the fire PRA model due to dependency on other systems like Instrument Air and Service Building support systems that are not credited in the fire PRA model. DC power from Panel 25 is required for the AFW start relays for the SI signal and the low steam generator level start signal. Failure of the automatic start signal to the 21 AFW Pump would require operators to manually start the 21 AFW Pump from the control room. The fire PRA results remain acceptable with credit for the modification to cable 2DCA-10 removed and the results are included in the new Attachment W tables in Enclosure 6.

Defense in Depth/Safety Margin Discussion:

Defense in depth involves the following three echelons:

1. Prevent fires from starting;

2. Rapidly detect, control and promptly extinguish those fires that do occur, thereby preventing fire damage; and

3. Providing adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

Defense in depth is maintained after the deletion of this modification for cable 2DCA-10 because it does not impact the ability to prevent fires from starting, nor does it impact the ability to rapidly detect, control, and extinguish fires that do occur. An adequate level of fire protection is maintained because modifications (Table S-2, items 2 and 4) were performed to the Unit 2 AFW system to remove the A Train controls from Fire Area 31. Therefore, the A Train of the AFW system now remains available to provide flow to the steam generators in the event of a fire in Fire Area 31.

Safety margins are maintained in the fact that:

Fire detection and fire suppression systems credited in NFPA 805, Chapter 4, have been evaluated to meet the requirements of NFPA 805, Chapter 3, and their associated codes of record for those systems or provided with acceptable alternatives using processes accepted for use by the NRC.

The risk-informed, performance based processes utilized are based upon NFPA 805, as endorsed by the NRC in 10 CFR 50.48(c).

The fire risk evaluation process is in accordance with NEI 04-02 as endorsed by RG 1.205 and clarified by FAQ 07-0030.

Page 14 of 23

L-PI-18-005 NSPM The fire PRA was developed with guidance from NUREG/CR-6850, which was developed jointly between the NRC and EPRI.

The internal events PRA and fire PRA have received a formal industry peer review based on the NEI guidelines, in order to ensure the fire PRA meets the appropriate standards of ASME/ANS RA-Sa-2009.

The peer review of the fire PRA model was conducted by a diverse group of PRA practitioners from other PWR plants and industry.

Fire modeling performed in support of the transition has been performed within the fire PRA utilizing codes and standards developed by industry and NRC staff which have been verified and validated in authoritative publications, such as NUREG 1824.

3.5 Cable 1DCB-18 Modification Proposed Change:

Delete the proposed modification of Unit 1 cable 1DCB-18 described in item 33 on page S-22 of Attachment S, Table S-2, as:

Problem Statement:

A fire in Fire Area 32 could damage the cable that provides DC control power to PNL-16 [Panel 16] which supports Instrumentation.

Proposed Modification:

Modify cable 1DCB-18 from fire damage in Fire Area 32.

Basis for Change:

Cable 1DCB-18 provides DC power to Unit 1, Train B DC Panel 16, which powers relays that provide automatic start of the 12 Motor Driven AFW Pump on low steam generator level or SI signal, but operators can still start the 12 AFW Pump from the control room. The protection of cable 1DCB-18 was a risk reduction modification and is not a VFDR of NFPA 805 because the 12 AFW Pump remains available from the control room to provide AFW to the steam generators.

Risk Impact Discussion:

The 12 AFW pump starts due to the following signals:

SI signal Low steam generator level Page 15 of 23

L-PI-18-005 NSPM Both main feedwater pumps tripped AMSAC/DSS Manual start by operators The main feedwater system and the AMSAC/DSS start signals are not credited in the fire PRA model due to dependency on other systems like Instrument Air and Service Building support systems that are not credited in the fire PRA model. DC power from Panel 16 is required for the AFW start relays for the SI signal and the low steam generator level start signal. Failure of the automatic start signal to the 12 AFW Pump would require operators to manually start the 12 AFW Pump from the control room. The fire PRA results remain acceptable with credit for the modification to cable 1DCB-18 removed and the results are included in the new Attachment W tables in Enclosure 6.

Defense in Depth/Safety Margin Discussion:

Defense in depth involves the following three echelons:

1. Prevent fires from starting;

2. Rapidly detect, control and promptly extinguish those fires that do occur, thereby preventing fire damage; and

3. Providing adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed.

Defense in depth is maintained after the deletion of this modification for cable 1DCB-18 because it does not impact the ability to prevent fires from starting, nor does it impact the ability to rapidly detect, control, and extinguish fires that do occur. An adequate level of fire protection is maintained because Table S-2 modifications 1 and 3 will ensure the Unit 1 Train B 12 AFW Pump remains available to be manually started from the control room.

Therefore, the AFW system now remains available to provide flow to the steam generators in the event of a fire in Fire Area 32.

Safety margins are maintained in the fact that:

Fire detection and fire suppression systems credited in NFPA 805, Chapter 4, have been evaluated to meet the requirements of NFPA 805, Chapter 3, and their associated codes of record for those systems or provided with acceptable alternatives using processes accepted for use by the NRC.

The risk-informed, performance based processes utilized are based upon NFPA 805, as endorsed by the NRC in 10 CFR 50.48(c).

Page 16 of 23

L-PI-18-005 NSPM The fire risk evaluation process is in accordance with NEI 04-02 as endorsed by RG 1.205 and clarified by FAQ 07-0030.

The fire PRA was developed with guidance from NUREG/CR-6850, which was developed jointly between the NRC and EPRI.

The internal events PRA and fire PRA have received a formal industry peer review based on the NEI guidelines, in order to ensure the fire PRA meets the appropriate standards of ASME/ANS RA-Sa-2009.

The peer review of the fire PRA model was conducted by a diverse group of PRA practitioners from other PWR plants and industry.

Fire modeling performed in support of the transition has been performed within the fire PRA utilizing codes and standards developed by industry and NRC staff which have been verified and validated in authoritative publications, such as NUREG 1824.

3.6 Cumulative Risk Impact of Deleted Modifications The removal of previously committed modifications increases total risk for the variant plant.

This risk increase has been substantially reduced through refinement of fire scenarios as described in Section 2.4 of this enclosure.

The variant plant fire PRA model has been developed without inclusion of the previously committed five modifications. Model refinements were made as needed to lower the quantified risk to acceptable levels without the modifications installed. To determine the delta-risk due to elimination of the modifications, the final variant plant fire PRA model was adjusted to simulate the effects of adding the modifications. The total change in risk is calculated in terms of Core Damage Frequency (CDF) and Large Early Release Frequency (LERF). The results are included in Table 1 below. As shown in the table, the increase in risk associated with the deletion of these modifications is small as defined in RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (Reference 15).

Table 1 - Cumulative Risk Impact Due to Deletion of Five Modifications Unit 1 CDF Unit 1 LERF Unit 2 CDF Unit 2 LERF Fire PRA 6.64E-05 9.64E-07 6.61E-05 9.27E-07 (Variant Plant)

Fire PRA 6.39E-05 9.14E-07 6.38E-05 8.89E-07 (Deleted Modifications Installed)

Delta CDF/LERF 2.5E-06 5.0E-08 2.3E-06 3.8E-08 Page 17 of 23

L-PI-18-005 NSPM

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations (10 CFR) 50.48(c)(3)(ii)

The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensees decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805.

Conclusion 10 CFR 50.48(c)(3) sets the regulatory requirements for complying with NFPA 805.

10 CFR 50.48(c)(3)(ii) requires that all modifications to the fire protection plan necessary for compliance with NFPA 805 be implemented prior to making changes to the fire protection program or the plant as permitted by NFPA 805. The proposed change revises the list of plant modifications, which is not specified by the regulations, required for full implementation of NFPA 805. Therefore, 10 CFR 50.48(c)(3)(ii) will continue to be met.

General Design Criteria As stated in Section 2.5 of this enclosure, PINGP was designed and constructed to comply with NSPMs understanding of the intent of the AEC GDC for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. Therefore, the PINGP Licensing Basis requires conformance to the AEC GDC, as reflected in the PINGP Updated Safety Analysis Report (USAR) Section 1.2. The following AEC GDC is applicable to the proposed changes:

CRITERION 3 - FIRE PROTECTION The reactor facility shall be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potential effects of such events to safety. Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room, and components of engineered safety features.

Conclusion The changes proposed will not result in the introduction of new or different combustible material into PINGP, nor will they impact the fire safe shutdown strategy. The PINGP fire PRA model was used to verify the increase in risk associated with deleting the modifications was acceptably low. Therefore, the criterion listed above, and as described in the PINGP USAR, will continue to be met.

Page 18 of 23

L-PI-18-005 NSPM 4.2 Precedent The NRC approved Amendment Nos. 205 and 201 in a Safety Evaluation dated October 17, 2016 (Reference 16), for the Joseph M. Farley Nuclear Plant in which they revised the NFPA 805 modifications. In its application, the Southern Nuclear Operating Company utilized the guidance of Option A in Reference 2.

4.3 No Significant Hazards Consideration In accordance with the requirements of 10 CFR 50.90, Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requests an amendment to the Renewed Facility Operating Licenses (RFOLs) for the Prairie Island Nuclear Generating Plant (PINGP). Specifically, the proposed amendment would revise RFOL paragraph 2.C(4)(c),

Transition License Conditions, Item 2, to revise existing commitments regarding National Fire Protection Association (NFPA) Standard NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Electric Generation Plants.

NSPM has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of PINGP in accordance with the proposed amendment presents no significant hazards. NSPMs evaluation against each of the criteria in 10 CFR 50.92 follows.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment adds a reference to this letter to the PINGP, Units 1 and 2, RFOLs. The changes encompassed by this proposed amendment are to delete five modifications that are no longer needed from a risk perspective. The revision is based on five changes to Table S-2 proposed in this license amendment request (LAR). The proposed changes have been reviewed in the fire Probabilistic Risk Assessment (PRA) model approved as part of PINGPs transition to NFPA 805 and the results were found to be acceptable. Fire protection defense in depth and adequate safety margins are maintained with the changes proposed in this LAR.

The proposed change does not adversely affect accident initiators or precursors, nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not increase the probability or consequences of an accident as verified by the risk analysis performed.

Page 19 of 23

L-PI-18-005 NSPM Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously identified.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment adds a reference to this letter to the PINGP, Units 1 and 2, RFOLs. The changes encompassed by this proposed amendment are to delete five modifications that are no longer needed from a risk perspective. The revision is based on five changes to Table S-2 proposed in this LAR. The proposed changes have been reviewed in the fire PRA model approved as part of PINGPs transition to NFPA 805 and the results were found to be acceptable. Fire protection defense in depth and adequate safety margins are maintained with the changes proposed in this LAR.

The proposed changes will not result in any new or different kinds of accident from that previously evaluated because it does not change any precursors or equipment that is previously credited for accident mitigation.

Therefore, this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment adds a reference to this letter to the PINGP, Units 1 and 2, RFOLs. The changes encompassed by this proposed amendment are to delete five modifications that are no longer needed from a risk perspective. The revision is based on five changes to Table S-2 proposed in this LAR. The proposed changes have been reviewed in the fire PRA model approved as part of PINGPs transition to NFPA 805 and the results were found to be acceptable. Fire protection defense in depth and adequate safety margins are maintained with the changes proposed in this LAR.

The proposed change does not adversely affect any SSCs credited for accident mitigation. The margins of safety previously evaluated are not significantly affected. The change does not affect the design function or capabilities of any plant systems.

Therefore, the proposed changes will not impact or reduce any margins of safety previously evaluated.

Therefore, this proposed change does not involve a significant reduction in a margin of safety.

Page 20 of 23

L-PI-18-005 NSPM Based on the above evaluation, NSPM concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

NSPM has evaluated the proposed amendment and determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 21 of 23

L-PI-18-005 NSPM

6.0 REFERENCES

1. Letter from NSPM to NRC, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information (CAC Nos. ME9734 and ME9735), dated December 14, 2016 (Agencywide Document Access and Management System (ADAMS) Accession No. ML16350A105)

2. Letter from NRC to NEI, Recommended Content for License Amendment Requests that Seek Changes to License Conditions that were Established in Amendments to Adopt National Fire Protection Association Standard 805 but have yet to be Fully Implemented, dated March 2, 2016 (ADAMS Accession No. ML16015A416)

3. Letter from NRC to NSPM, Issuance of Amendments Re: Transition to NFPA-805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (CAC Nos. ME9734 and ME9735), dated August 8, 2017 (ADAMS Accession No. ML17163A027)

4. NRC NUREG-2169, Nuclear Power Plant Fire Ignition Frequency and Non-Suppression Probability Estimation Using the Updated Fire Events Database, United States Fire Event Experience Through 2009, dated January 2015 (ADAMS Accession No. ML15016A069)

5. NRC NUREG-2178, Refining and Characterizing Heat Release Rates from Electrical Enclosures During Fire (RACHELLE-FIRE), Volume 1: Peak Heat Release Rates and Effect of Obstructed Plume, dated April 2016 (ADAMS Accession No. ML16110A140)

6. NRC NUREG-2180, Determining the Effectiveness, Limitations, and Operator Response for Very Early Warning Fire Detection Systems in Nuclear Faculties (DELORES-VEWFIRE), dated December 2016 (ADAMS Accession No. ML16343A058)

7. NRC NUREG-1921, EPRI/NRC-RES Fire Human Reliability Analysis Guidelines, dated July 2012 (ADAMS Accession No. ML12216A104)

8. NRC NUREG/CR-6850, EPRI/NRC-RES Fire PRA Methodology for Nuclear Power Facilities, Volumes 1 and 2, dated September 2005 (ADAMS Accession Nos.

ML15167A401 and ML15167A411)

9. NSPM Letter to NRC, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors - Response to Request for Additional Information Day Responses, dated June 19, 2015 (ADAMS Accession No. ML15174A139)

Page 22 of 23

L-PI-18-005 NSPM

10. Nuclear Energy Institute Report NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c),

Revision 2, dated April 2008 (ADAMS Accession No. ML081130188)

11. NRC Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, Revision 1, dated December 2009 (ADAMS Accession No. ML092730314)

12. NFPA 805 Frequently Asked Question 07-0030, Establishing Recovery Actions, Revision 5, dated November 4, 2010 (ADAMS Accession No. ML103090602)

13. ASME Standard ASME/ANS RA-Sa-2009, Addenda to ASME /ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, dated February 2, 2009

14. NRC NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications Volume 1: Main Report, dated May 2007 (ADAMS Accession No. ML071650546)

15. NRC Regulatory Guide 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, dated January 2018 (ADAMS Accession No. ML17317A256)

16. Letter from NRC to Southern Nuclear Operating Company, Issuance of Amendments Related to NFPA 805 Supplement (CAC Nos. MF7617 and MF7618), dated October 17, 2016 (ADAMS Accession No. ML16232A000)

Page 23 of 23

ENCLOSURE 2 ATTACHMENT M LICENSE CONDITION CHANGES (Markup) 8 pages follow

Northern States Power - Minnesota Attachment M - License Condition Changes M. License Condition Changes 7 Pages Attached By letter dated April 30, 2014, NSPM provided Attachment M, Revision 1. By letter dated May 24, 2016, NSPM provided a revised insert A for Attachment M, Revision 1.

However, NSPM did not provide a new Revision of Attachment M in its entirety.

Subsequently, the NRC issued the PINGP NFPA 805 amendment with the final revised license condition 2.C.(4) on August 8, 2017. In this submittal, NSPM is providing Attachment M, Revision 2. The pages included herein reflect those issued by the NRC in the NFPA 805 LAR, and are marked up as described in Section 2.2 of Enclosure 1.

PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes NSPM Proposes to replace the current PINGP fire protection license conditions 2.C.(4) for Units 1 and 2 with the standard license condition in Regulatory Position 3.1 of Regulatory Guide 1.205, as modified as shown in the proposed markups that follow.

It is NSPMs understanding that implicit in the replacement of the current license condition, all prior fire protection program SERs and commitments will be superseded in their entirety by the revised license condition.

No other license conditions need to be replaced or revised.

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

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

Marked-up License Condition pages follow.

PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Safeguards Information protected under 10 CFR 73.21, is entitled: Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, submitted by letters dated October 18, 2006, and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company - Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 202 and supplemented by License Amendment No. 212.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated September 28, 2012, and May 18, 2018 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluations dated August 8, 2017, and [Safety Evaluation Date]. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

Renewed Operating License No. DPR-42 Amendment No. -220XXX

_ I PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard.

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Renewed Operating License No. DPR-42 Amendment No. 220 PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated August 8, 2017, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.C.(4)(b)2.

2. The licensee shall implement the modifications to its facility, as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI 090L-PI-18-005, dated December 14, 2016May 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c),

before the end of the second full operating cycle for each unit after approval of the NFPA 805 License Amendment dated August 8, 2017LAR. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Attachment S, Table S-3, Implementation Items, of Northern States Power -

Minnesota letter L-PI-16-090, dated December 14, 2016, within 12 months after NRC approval, with the exception of Implementation Item 20, 66, and 70 which are associated with modifications and will be completed 180 days after modifications are complete.

Renewed Operating License No. DPR-42 Amendment No. -220XXX _ I PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Safeguards Information protected under 10 CFR 73.21, is entitled: Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, submitted by letters dated October 18, 2006 and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company - Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 189 and supplemented by License Amendment No. 200.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated September 28, 2012, and May 18, 2018 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluations dated August 8, 2017, and [Safety Evaluation Date]. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c),

and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must Renewed Operating License No. DPR-60 Amendment No. -207XXX

_ I PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard.

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

Renewed Operating License No. DPR-60 Amendment No. 207 PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated August 8, 2017, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.C.(4)(b)2.

2. The licensee shall implement the modifications to its facility, as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI 090L-PI-18-005, dated December 14, 2016May 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c),

before the end of the second full operating cycle for each unit after approval of the NFPA 805 License Amendment dated August 8, 2017LAR. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Attachment S, Table S-3, Implementation Items, of Northern States Power -

Minnesota letter L-PI-16-090, dated December 14, 2016, within 12 months after NRC approval, with the exception of Implementation Item 20, 66, and 70 which are associated with modifications and will be completed 180 days after modifications are complete.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 204, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

Renewed Operating License No. DPR-60 Amendment No. -207XXX _ I PINGP Page M Revision 2

ENCLOSURE 3 ATTACHMENT M LICENSE CONDITION CHANGES (Retyped) 8 pages follow

Northern States Power - Minnesota Attachment M - License Condition Changes M. License Condition Changes 7 Pages Attached By letter dated April 30, 2014, NSPM provided Attachment M, Revision 1. By letter dated May 24, 2016, NSPM provided a revised insert A for Attachment M, Revision 1.

However, NSPM did not provide a new Revision of Attachment M in its entirety.

Subsequently, the NRC issued the PINGP NFPA 805 amendment with the final revised license condition 2.C.(4) on August 8, 2017. In this submittal, NSPM is providing Attachment M, Revision 2. The pages included herein reflect those issued by the NRC in the NFPA 805 LAR, and are marked up as described in Section 2.2 of Enclosure 1.

PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes NSPM Proposes to replace the current PINGP fire protection license conditions 2.C.(4) for Units 1 and 2 with the standard license condition in Regulatory Position 3.1 of Regulatory Guide 1.205, as modified as shown in the proposed markups that follow.

It is NSPMs understanding that implicit in the replacement of the current license condition, all prior fire protection program SERs and commitments will be superseded in their entirety by the revised license condition.

No other license conditions need to be replaced or revised.

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

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

Marked-up License Condition pages follow.

PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Safeguards Information protected under 10 CFR 73.21, is entitled: Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, submitted by letters dated October 18, 2006, and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company - Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 202 and supplemented by License Amendment No. 212.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated September 28, 2012, and May 18, 2018 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluations dated August 8, 2017, and [Safety Evaluation Date]. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c),

the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

Renewed Operating License No. DPR-42 Amendment No. XXX PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard.

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Renewed Operating License No. DPR-42 Amendment No. 220 PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated August 8, 2017, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.C.(4)(b)2.

2. The licensee shall implement the modifications to its facility, as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI 005, dated May 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c), before the end of the second full operating cycle for each unit after approval of the NFPA 805 License Amendment dated August 8, 2017. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Attachment S, Table S-3, Implementation Items, of Northern States Power -

Minnesota letter L-PI-16-090, dated December 14, 2016, within 12 months after NRC approval, with the exception of Implementation Item 20, 66, and 70 which are associated with modifications and will be completed 180 days after modifications are complete.

Renewed Operating License No. DPR-42 Amendment No. XXX PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes Safeguards Information protected under 10 CFR 73.21, is entitled: Prairie Island Nuclear Generating Plant Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, submitted by letters dated October 18, 2006 and January 10, 2007, and as supplemented by letters dated March 18 and June 2, 2011, and approved by NRC Safety Evaluation dated August 16, 2011.

NSPM shall fully implement and maintain in effect all provisions of the Commission-approved Northern States Power Company - Minnesota (NSPM)

Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The NSPM CSP was approved by License Amendment No. 189 and supplemented by License Amendment No. 200.

(4) Fire Protection NSPM shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated September 28, 2012, and May 18, 2018 (and supplements dated November 8, 2012, December 18, 2012, May 3, 2013, October 17, 2013, April 30, 2014, May 28, 2015, June 19, 2015, October 6, 2015, October 22, 2015, January 20, 2016, May 24, 2016, August 17, 2016, December 14, 2016, and March 6, 2017), and as approved in the safety evaluations dated August 8, 2017, and [Safety Evaluation Date]. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c),

and provided no other regulation, technical specification, license condition, or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

(a) Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.

1. Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must Renewed Operating License No. DPR-60 Amendment No. XXX PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

2. Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for CDF and less than 1x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.

(b) Other Changes that May be Made Without Prior NRC Approval

1. Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is adequate for the hazard.

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

Renewed Operating License No. DPR-60 Amendment No. 207 PINGP Page M Revision 2

Northern States Power - Minnesota Attachment M - License Condition Changes This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensees fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation dated August 8, 2017, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. and 3. below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2.C.(4)(b)2.

2. The licensee shall implement the modifications to its facility, as described in Attachment S, Table S-2, Plant Modifications Committed, in Northern States Power - Minnesota letter L-PI 005, dated May 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c), before the end of the second full operating cycle for each unit after approval of the NFPA 805 License Amendment dated August 8, 2017. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall implement the items listed in Attachment S, Table S-3, Implementation Items, of Northern States Power -

Minnesota letter L-PI-16-090, dated December 14, 2016, within 12 months after NRC approval, with the exception of Implementation Item 20, 66, and 70 which are associated with modifications and will be completed 180 days after modifications are complete.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 204, are hereby incorporated into this license. NSPM shall operate the facility in accordance with the Additional Conditions.

Renewed Operating License No. DPR-60 Amendment No. XXX PINGP Page M Revision 2

ENCLOSURE 4 ATTACHMENT S MODIFICATIONS AND IMPLEMENTATION ITEMS (Markup) 34 pages follow

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items S. Modifications and Implementation Items 33 31 Pages Attached Attachment S, Revision 34, supersedes Attachment S, Revision 23, provided in the RAI response dated May 24, 2016December 14, 2016 PINGP Page S Revision -_

34 I

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

A problem statement, Risk ranking of the modification, An indication if the modification is currently included in the FPRA, Compensatory Measure in place if non-compliant with the Current Licensing Basis, and A risk-informed characterization of the modification and compensatory measure.

The following legend should be used when reviewing the Risk Rank in Tables S-1 and S-2:

o High = Modification would have an appreciable impact on reducing overall fire CDF.

o Medium = Modification would have a measurable impact on reducing overall fire CDF.

o Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.

o N/A = Not modeled in the FPRA, therefore a risk ranking is not provided.

NSPM is requesting two full refueling cycles beyond SE issuance to fully implement modifications. This is, in part, due to the outage strategies implemented at PINGP where only one train is removed from service per outage, per unit. Due to the significant modifications required to transition PINGP to NFPA 805, additional time is necessary to fully implement modifications described in Table S-2.

The Proposed Modification statements in Table S-2 provide a conceptual design to address the Problem Statement. The final design and installation to resolve the Problem Statement will be developed and approved in accordance with Xcel Engineering processes, hence implementation details may vary.

Subsequent to approval of the NFPA 805 amendment on August 8, 2017, NSPM has completed modifications listed in Table S-2. However, those completed modifications have not been moved from Table S-2 to Table S-1 in this revision of Attachment S. This was done in order to limit the changes to Attachment S to only those five modifications which NSPM is requesting to delete in its license amendment request dated May 18, 2018.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 9 Low 1,2 Fire Suppression required for Modified fire suppression No N/A The proposed the Fire PRA was not code systems in the following fire modification reduced risk compliant, as required by areas to resolve NFPA by allowing the Fire PRA NFPA 805, for the following Suppression code deviations to credit fire suppression Fire Areas: FA 18, 41B, 31, & as follows: systems in the listed Fire

32. Areas. Per the 2009 FA 18: Installed an odorizer for ASME PRA Standard, fire the Cardox System. suppression systems must be code compliant if FA 31: Resolved non- they are credited in the compliances with pendant Fire PRA.

sprinkler heads.

FA 32: Resolved non-compliances with pendant sprinkler heads.

FA 41B: Installed missing Sprinkler #229.

FA 41B: Installed Heat Activated Detector (HAD) in the enclosure for the 121 Motor Driven Fire Pump.

FA 41B: Installed a sprinkler head above the Diesel Driven Fire Pump because of a large obstruction.

(Ref: EC 21578)

From Table S-2, Item 9 PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 12 Medium 1,2 A fire in Fire Area 29 could Installed a rated fire barrier Yes N/A This modification reduced damage cables required for between Fire Area 29 and Fire fire risk by providing a operation of Train A Cooling Area 69. rated fire barrier between Water Pumps which supply risk significant cables and cooling water to D1 (Ref: EC 21574) fire initiators.

Emergency Diesel Generator which powers Train A From Table S-2, Item 12 safeguards Bus 15.

A fire in Fire Area 69 could damage cables that supply power to ventilation fans for D2 Emergency Diesel Generator supply to Train B safeguards Bus 16. A fire in Fire Area 69 could also damage cables required for offsite power to Bus 15 and Bus 16.

Fire Area 29 and 69 were defined as separate areas in the 1977 Fire Hazards Analysis that was submitted to the NRC and accepted.

There is an open pathway between Fire Area 29 and 69; therefore the Fire PRA Plant Partitioning combined Fire Area 29 and 69 (along with 8, 14, 27, and 70) into Fire Compartment 8GRP. Risk for Fire Compartment 8GRP was high when all of these areas were combined.

PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 13 Medium 1 A fire in the control room or Wired additional relay contacts Yes N/A This modification reduced relay room could have from the low speed relay in risk by eliminating the caused hot shorts on cables series with indicating light in possibility that a hot short that could spuriously start D1 the control room so that once on a cable in the Control and close the cooling water D1 speed was greater than and Relay Room could supply valve. This condition 250 RPM, the potential hot isolate cooling water to resulted in unrecoverable short on the indicating light in D1 Emergency Diesel damage to the credited the control room is cleared. Generator Emergency Diesel Generator during a fire induced control (Ref: EC 18746) room evacuation.

From Table S-2, Item 13 16 N/A 1,2 The supply ventilation duct Installed a fire damper in the No N/A Not modeled in the between Fire Areas 32 and supply ventilation duct FPRA, therefore a risk 37 did not have a fire damper between FA 32 and 37. ranking was not provided.

and was not code compliant for the Fire PRA, as required (Ref: EC 21572) by NFPA 805.

From Table S-2, Item 16 40 N/A 1, 2 There is a fire protection hose Added a restraint for fire No N/A This modification did not station with insufficient pipe protection hose station WF-9 have an impact of the hangers that did not meet the where the pipe comes through Fire PRA because the requirements of NFPA 14, the floor of the Turbine hose station was still Standpipes and Hose Building. functional.

Systems.

(Ref: EC 18011)

From Table S-2, Item 40 PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 1 High 1 A fire could damage Train Modify equipment in FA 31 to Yes Yes The modifications proposed B 12 Motor Driven Auxiliary ensure that Train A by Items 1-4 will reduce Feedwater Pump equipment is available for fire risk by modifying FAs 31 (MDAFWP) and the control safe shutdown. and 32 to ensure that each switches for the 11 Turbine The controls and associated FA has either A-train or B-Driven Auxiliary Feedwater cables for the Unit 1 Train A train related equipment Pump (TDAFWP) AFWP discharge valves will be unaffected by a fire. This discharge valves (MV- moved to Fire Area 32 so they will limit the number of fire 32238 & MV-32239). Fire are not damaged by a fire in scenarios that could damage to CS-51003 could Fire Area 31. damage both trains of cause spurious closure of equipment.

MV-32238 which would isolate the 11 TDAFWP Compensatory measures in flow to the credited 11 accordance with the Steam Generator. Fire Current Fire Protection damage to control switch Licensing Basis are being CS-51005 could prevent maintained.

closing MV-32239 which could divert the 11 Compensatory measures TDAFWP flow to the non- will continue to remain in credited 12 Steam effect after the NFPA 805 Generator. The NFPA 805 fire protection program Nuclear Safety becomes effective until this Performance Goal Criteria modification is complete.

is not met for Decay Heat Removal.

PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 2 High 2 A fire in FA 31 could Modify equipment in FA 31 to Yes Yes The modifications proposed damage the 22 TDAFWP ensure that Train A by Items 1-4 will reduce (Train B) and damage the equipment is available for fire risk by modifying FAs 31 circuits for the Train A 21 safe shutdown. and 32 to ensure that each MDAFWP (MV-32383 & The controls, MCC power FA has either A-train or B-MV-32384). Fire damage supply, and associated cables train related equipment at the Train A Hot for the Unit 2 Train A AFWP unaffected by a fire. This Shutdown Panel or MCC discharge and suction valves will limit the number of fire 2A1 could affect MV-32383 will be moved out of Fire Area scenarios that could (21 MDAFWP to 21 SG) or 31 so they are not damaged by damage both trains of MV-32384 (21 MDAFWP to a fire in Fire Area 31. The equipment.

22 SG). A fire at MCC 2A1 cables going to Unit 2 Train A could affect MV-32026 (21 AFW discharge valves (MV- Compensatory measures in MDAFWP suction from 32383 and MV-32384) will be accordance with the Cooling Water), MV-32336 modified so that MOV will not Current Fire Protection (21 MDAFWP suction from spuriously close due to a fire in Licensing Basis are being CST), MV-32383 (21 Fire Area 31. maintained.

MDAFWP to 21 SG) and MV-32384 (21 MDAFWP to Compensatory measures 22 SG). The NFPA 805 will continue to remain in Nuclear Safety effect after the NFPA 805 Performance Goal Criteria fire protection program is not met for Decay Heat becomes effective until this Removal. modification is complete.

PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 3 High 1 A fire could damage the 11 Modify equipment in FA 32 to Yes Yes The modifications proposed TDAFWP (Train A) and the ensure that Train B by Items 1-4 will reduce control switches for the 12 equipment is available for fire risk by modifying FAs 31 MDAFWP discharge valves safe shutdown. and 32 to ensure that each (MV-32381 & MV-32382). The controls, MCC power FA has either A-train or B-Fire damage at the Train B supply, and associated cables train related equipment Hot Shutdown Panel or for the Unit 1 B AFWP unaffected by a fire. This MCC 1A2 could affect MV- discharge and suction valves will limit the number of fire 32381 (12 MDAFWP to 11 will be moved out of Fire Area scenarios that could SG) or MV-32382 (12 32 so they are not damaged by damage both trains of MDAFWP to12 SG). A fire a fire in Fire Area 32. The equipment.

at MCC 1A2 could affect cables going to Unit 1 Train B MV-32027 (12 MDAFWP AFW discharge valves (MV- Compensatory measures in suction from Cooling 32381 and MV-32382) will be accordance with the Water), MV-32335 (12 modified so that the MOV will Current Fire Protection MDAFWP suction from not spuriously close due to a Licensing Basis are being CST), MV-32381 (12 fire in Fire Area 32. maintained.

MDAFWP to 11 SG) and MV-32382 (12 MDAFWP to Compensatory measures 12 SG). The NFPA 805 will continue to remain in Nuclear Safety effect after the NFPA 805 Performance Goal Criteria fire protection program is not met for Decay Heat becomes effective until this Removal. modification is complete.

PINGP Page S Revision -_ 34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 4 High 2 A fire could damage the 21 Modify equipment in FA 32 to Yes Yes The modifications proposed MDAFWP (Train A) and the ensure that Train B by Items 1-4 will reduce control switches for the 22 equipment is available for fire risk by modifying FAs 31 TDAFWP discharge valves. safe shutdown. and 32 to ensure that each Fire damage to CS-51605 The controls and associated FA has either A-train or B-could cause spurious cables for the Unit 2 Train B train related equipment closure of MV-32247 which AFWP discharge valves will be unaffected by a fire. This would isolate the 22 moved to Fire Area 31 so they will limit the number of fire TDAFWP flow to the are not damaged by a fire in scenarios that could credited 22 Steam Fire Area 32. damage both trains of Generator. Fire damage to equipment.

control switch CS-51603 could prevent closing MV- Compensatory measures in 32246 which could divert accordance with the the 22 TDAFWP flow to the Current Fire Protection non-credited 21 Steam Licensing Basis are being Generator. The NFPA 805 maintained.

Nuclear Safety Performance Goal Criteria Compensatory measures is not met for Decay Heat will continue to remain in Removal. effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 5 High 1,2 A fire in FA 18, Relay Install Incipient Detection Yes Yes The proposed modification Room could damage both System in the Relay Room that will reduce risk by installing trains of safe shutdown. will continuously sample the an incipient detection Since the risk of Recovery Relay Room air inside the risk system that will notify Actions taken in procedure significant cabinets to identify operators of fires in their F5 App B, Control Room fires based on the detection of incipient state. This Evacuation (Fire) are high, the presence of small amounts reduces the significance of installing a Very Early of products of combustion and, the fire scenarios that could Warning Fire Detection if detected, will sound an alarm lead to control room System (VEWFDS) or in the MCR. abandonment.

Incipient Detection is needed to reduce risk in Compensatory measures in the relay room. accordance with the Current Fire Protection Licensing Basis are being maintained.

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

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 Medium 1, 2 Fire damage to cable 1CX- Reroute the following cables Yes Yes The proposed modification 99 in FA 20 could cause a through FA 58 along the "G" will reduce risk because it loss of the normal power line between 8 and 9 and out of will reroute cables feed from 13 Inverter to FA 20: associated with the 120VAC Panel 113. Loss of - 1CX-99 (Instrument Bus III opposite train of equipment Panel 113 causes CV- (Blue) Panel 113 Normal to another FA. This will 31198 (Charging Line to 11 Power Feed) limit the number of fire Regenerative Heat - 1CW-99 (Instrument Bus II scenarios that could Exchanger CV) to fail open (White) Panel 111 Normal damage both trains of causing diversion of flow Power Feed) equipment.

from RCP seal injection to charging. Loss of Panel Install cable Compensatory measures in 113 causes loss of Control - 1DCA-133 (DC Power supply accordance with the Room indication for to BUS 15 Load Sequencer) Current Fire Protection instrument Loops 1N51 from PNL-11 in FA 33 to BUS- Licensing Basis being (Unit 1 Excore Detection 15 Load Sequencer in FA 81 maintained.

Train A), 1T-450A (Unit 1 that is not routed through Fire RCS Loop A Hot Leg Area 20. Compensatory measures Temperature) and 1T-450B will continue to remain in (Unit 1 RCS Loop A Cold effect after the NFPA 805 Leg Temperature). fire protection program becomes effective until this Modification is needed to modification is complete.

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

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

Modification is needed to protect 1CW-99 (Instrument Bus II (White)

Panel 111 Normal Power Feed).

Fire damage to cable 1CF-35 in FA 20 could cause a loss of Control Room indication for Loop 1L-433 (Unit 1 Pressurizer Level).

Modification to protect cable 1CW-99 from fire damage in FA 20 will ensure Pressurizer Level Indication LOOP 1L-427 remains available in the control room.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 A fire in FA 20 could Re-route conductors from 1C-Cont damage cable 1C-419 419 (Breaker 15-3, Bus 15 which could affect the Offsite Source from 1R ability of BKR 15-3, 1RY Transformer) to cable 15403-B source to Bus 15, to clear which is not routed in Fire Area from the potentially faulted 20.

1RY source to Bus 15.

Local manual action is required to open BKR 15-3 so that Bus 15 can be repowered from the D1 Emergency Diesel Generator.

A fire in FA 32 or 58 could Re-route affected conductors damage cable 1C-333 of cable 1C-333 out of FA 32 affecting the 1RY source to and FA 58 so the 1RY offsite Bus 16, and could damage power supply will be available cable 16408-1, CT11 in FA 32 and FA 58.

source to Bus 16, and cables 1DCB-2 and 1DCB-95 which support the D2 source to Bus 16. A modification to route affected conductors of cable 1C-333 out of fire area 32 and 58 is needed to protect the 1RY source to Bus 16 in fire area 32.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6

Cont A fire in FA 058/073, 695' Modify cable elevation of the Aux 2DCA-105 (DC Power Cable Building could damage from 21 Battery 125V DC cable 2DCA-105 which Panel 27 Train A) from fire provides DC control power induced failure in Fire Area to PNL 27 which provides 058/073.

DC control power to Bus 25 to trip 4 KV breakers.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 8 Low 1, 2 Fire Detection required for Install New Fire Detectors per Yes Yes The proposed the Fire PRA is not code NFPA 72 (Detection) to modification reduces risk compliant, as required by resolve NFPA 72 code by allowing the Fire PRA NFPA 805, for the following deviations in the following to credit fire detection Fire Areas: FA-18, 41B, areas: systems in the listed Fire 58/73, 59/74 Areas. Per the 2009 FA 18: Modify the Ionization ASME PRA Standard, fire Fire Detection system to detection systems must provide two zones of coverage be code compliant if they in the Relay Room and P250 are credited in the Fire Computer Room. Modify the PRA.

CO2 fire suppression system to actuate if both Ionization Compensatory measures zones detect a fire in lieu of in accordance with the heat detectors. Current Fire Protection Licensing Basis are being FA 41B: Relocate detector maintained.

from the exhaust stream of a ventilation duct. Compensatory measures will continue to remain in FA 58/73: Resolve various effect after the NFPA 805 detector code issues based on fire protection program S&L Fire Detector Study, Rev becomes effective until 0, PINGP, Project No: 111973- this modification is 055, 12/20/2008 complete.

FA 59/74:Resolve various detector code issues based on S&L Fire Detector Study., Rev 0, PINGP, Project No: 111973-055, 12/20/2008.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 10 High 1,2 A fire could damage DC Modify 4160 volt switchgear Yes Yes The FPRA assumes control cables for 4 KV control circuits so that faults on coordination of credited breakers which could the control cables will not buses.

cause the tripping control prevent the over-current trip power fuses to clear which relay from protecting the cable This modification ensures would prevent the breaker from over-current conditions there are no secondary from tripping on over- that could lead to cable fires.

current. The fire could then damage and secondary fires or damage the 4 KV power loss of bus coordination. Compensatory measures in cable, but since the breaker accordance with the can't trip, the cable would Current Fire Protection be subjected to an over- Licensing Basis are being current condition up to the maintained.

full fault current available to the bus. If the cable is not Compensatory measures sized large enough to carry will continue to remain in this amount of current, the effect after the NFPA 805 cable could be damaged fire protection program and start a fire in other fire becomes effective until this areas where it is routed. modification is complete.

Affected Breakers:

BKR 15-1, BKR 15-4, BKR 15-5, BKR 15-9, BKR 16-1, BKR 16-5, BKR 16-6, BKR 16-7, BKR 16-10, BKR 16-12, BKR 25-7, BKR 25-8, BKR 25-9, BKR 25-10,BKR 25-13, BKR 26-5, BKR 26-9, BKR 26-11 11 DELETED DELETED DELETED 12 COMPLETED COMPLETED COMPLETED 13 COMPLETED COMPLETED COMPLETED PINGP Page S Revision -_34 I

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 14 Medium 1,2 A fire in FA 13/18 could Modify control circuits for the Yes No This modification will damage cables causing Diesel Driven Cooling Water reduce risk by simplifying multiple spurious Pump to eliminate the current restoration of Cooling operations that could required recovery action of Water to provide cooling to damage D1 Emergency sending an operator to the D1 D1 Emergency Diesel Diesel Generator. If fire Room and Screenhouse. Generator and a backup induced cable damage water supply to the Aux caused multiple spurious Feedwater Pumps.

operations that caused D1 (034-011) to spuriously start with no cooling water (11 MDCLP MTR 13-8, 12 DDCLP 145-392, 21 MDCLP MTR 23-4, 22 DDCLP 245-392) then the EDG could be damaged.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 15 Medium 1, 2 DELETEDFire-induced DELETEDInstall suction Yes Yes DELETEDThe proposed damage that could damage pressure protection for all the modification will reduce risk cables causing multiple charging pumps to ensure by installing suction spurious operations adequate Net Positive Suction pressure protection that will resulting in damage to the Head (NPSH) exists to prevent protect the charging pumps charging pumps. If fire damage to the charging against fires that involve induced cable damage pumps. spurious valve closure and caused spurious isolation other failures that impact of letdown to the VCT (CV- NPSH for the charging 31226 and CV-31255) and pumps.

failure to open the RWST supply (MV-32060) and Compensatory measures in failure to trip the charging accordance with the pumps, the 11, 12, 13, 21, Current Fire Protection 22 and 23 positive Licensing Basis are being displacement charging maintained.

pumps (MTR 111J-1) and MTR 211J-1 could be Compensatory measures damaged due to lack of Net will continue to remain in Positive Suction Head effect after the NFPA 805 (NPSH). Need to prevent fire protection program unrecoverable damage to becomes effective until this credited charging pump modification is complete.

due to fire in FA 13/18 to resolve MSO issue.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 18 High 1, 2 A fire in Fire Area 1, 13, 18, Install new RCP seals that Yes Yes The proposed modification 59, and 71 could cause a would not be subject to will reduce risk by installing loss of all Reactor Coolant excessive leakage if all seal a shutdown RCP Seal Pump (RCP) seal cooling cooling is lost. package. The new seal will by damaging RCP seal have the ability to preclude injection from charging and larger seal leakage rates Component Cooling (CC) during loss of seal cooling water to the Thermal scenarios.

Barrier Heat Exchanger (TBHX). Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being maintained.

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

19 DELETED DELETED DELETED 20 Low 1, 2 DELETEDThe current Fire DELETEDInstall the Yes No DELETEDThe Fire PRA PRA Model assumes appropriate fuses and/or assumes proper proper coordination exists breakers to establish proper coordination of these power for all credited power selective coordination for supplies supplies. Per Fire PRA panels 136, 137, and 217 credited power supplies credited to be coordinated.

lack selective coordination.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 23 Medium 2 A fire in Bus 27 room (Fire Install fuses to provide Yes Yes The Fire PRA assumes Area 127) could damage coordination so that a fire in the proper coordination of DC control power to Bus 25 Bus 27 room will not affect DC these power supplies or Bus 26. control power to Bus 25 or Bus 26.

24 High 1, 2 A fire in the Bus 15 (Fire Provide fuse/breaker Yes No The proposed modification Area 81) or Bus 16 (Fire coordination for the CT11 will reduce risk by ensuring Area 20) room could supply to Bus 15 and Bus 16 one off-site power source damage the cables and bus so that the CT11 source to the safeguards 4 kV Bus duct that supply off-site remains available to Bus 15 if a remains unaffected by a power (CT11 and 1R fire damages Bus 16 or to Bus fire in the event of a fire in transformers) to Bus 15 16 if a fire damages Bus 15. the opposite train and Bus 16 due to common safeguards 4 kV Bus room.

power supply. The Provide fuse/breaker redundant diesel generator coordination for the CT12 remains unaffected by a supply to Bus 25 and Bus 26 fire to re-power the so that the CT12 source unaffected 4 kv safeguards remains available to Bus 25 if a bus (Bus 15 or Bus 16), but fire damages Bus 26 or to Bus risk is higher than desired. 26 if a fire damages Bus 25.

Modify associated control Unit 2 is similar to Unit 1. A cables (1CS-1, 1CS-2, 1CS-3, fire in Fire Area 117, BUS and 1CS-4) so the CT11/CT12 25 or Fire Area 118, BUS source remains available for 26, could damage cables the opposite Bus room.

for both off-site power sources (2RY and CT12 transformer). The redundant Emergency Diesel Generator (D5/D6) remains unaffected by a fire, but the risk is higher than desired.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 25 Medium 1 A fire in Fire Area 32 could Re-power MV-32078 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 32 open MV-32077 and MV- Area 32 to re-gain the ability to does not damage the ability 32078 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

26 Medium 2 A fire in Fire Area 31 could Re-power MV-32180 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 31 open MV-32180 and MV- Area 31 to re-gain the ability to does not damage the ability 32181 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

27 High 1, 2 DELETEDA fire in the DELETEDInstall switches in Yes No DELETEDThis will reduce Control Room (Fire Area the Control Room to isolate risk by providing an

13) or the Relay and Cable Pressurizer PORV, and additional way to isolate Spreading Room (Fire Area Pressurizer Heaters. Pressurizer PORV, and

18) could cause spurious isolating Pressurizer opening of valves that Heaters from the control could lead to a loss of room.

inventory.

28 DELETED DELETED DELETED 29 DELETED DELETED DELETED 30 Medium 2 DELETEDA fire in Fire DELETEDModify risk Yes No DELETEDThis will reduce Area 31 could damage significant cable (2DCA-10) risk by ensuring DC power cables that provide DC from risk significant fire remains available for power to vital auxiliaries initiators in Fire Areas 31. control and instrumentation which impacts risk. for fire in FA 31.

31 DELETED DELETED DELETED 32 Medium 2 A fire in Fire Area 32 could Modify cable 1C-2278 from Yes No This will reduce risk by damage cable 1C-2278 failing 21 Motor Driven Cooling ensuring the availability of which could affect control Water Pump in Fire Area 32. the 21 MDCLP for a fire in for BKR-23-4 which powers FA 32.

the 21 Motor Driven Cooling Water Pump (21 MDCLP).

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 33 1 DELETEDA fire in Fire DELETEDModify cable 1DCB- Yes No DELETEDThis will reduce Medium Area 32 could damage the 18 from fire damage in Fire risk by ensuring the cable that provides DC Area 32. availability of DC power to control power to PNL-16 PNL-16 to provide vital which supports instrumentation.

Instrumentation.

34 Medium 1, 2 A fire in FA 13, 18, 32 or 58 Modify cables to prevent Yes No This will reduce risk by could damage cables and spurious closure from risk making modifications to cause spurious closure of significant fire initiators. reduce the number of fire the Emergency Diesel scenarios that could cause Generator output breaker. fire damage to a 4kV This could cause a lockout safeguards bus.

of the 4kv safeguards Bus which powers one train of safeguards equipment.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 35 Medium 1 A fire in Fire Area 32 or 58 Modify cable 1C-332 from fire Yes Yes The proposed modification could damage cables which damage in Fire Area 32 and 58 will reduce risk because it support operation of the to ensure BUS 16 can be will reroute cables 1RY offsite power sources powered from the 1RY associated with the to BUS 15 (BKR-15-3) and transformer. opposite train of equipment BUS 16 (BKR-16-2). to another FA. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being maintained.

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

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 38 N/A 1, 2 A fire in Fire Areas 31, 32, Install control power fuses for No Yes This modification does not 58/73, 18, or 13 could the control circuits to provide have a significant impact damage control cables for over-current protection for the on the Fire PRA model the 11 or 21 DC DC Emergency Turbine because the 11 and 21 Emergency Turbine Bearing Oil Pumps. Emergency Oil Pumps are Bearing Oil Pump that are not credited. The Fire PRA not adequately fused to model does not directly protect from over-current model common enclosure conditions. The control concerns.

cables could over-heat due to excessive current flow.

Since the cables are routed in multiple fire areas, this is a common enclosure concern.

39 N/A 1, 2 The 121 Motor Driven Fire Modify the Fire Pump alarm in No No This modification does not Pump (MDFP) loss of the control room to include the have an impact on the Fire power alarm is local at the loss of power alarm. PRA because the loss of pump in the screen house power alarm does not and does not currently affect functionality of the alarm to the control room. 121 MDFP. It is an NFPA This does not meet NFPA 805 code compliance 20 requirements. concern.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 41 Medium 1, 2 A fire in Fire Area 13 or 18 Re-wire the torque and limit Yes Yes The proposed modification could damage cables that switches so fire induced will allow the valve to be could over-torque motor damage to cables in FA 13 and locally operated to credit operated valves; MV- 18 cannot bypass the torque this recovery action in the 32006, MV-32010, MV- and limit switches and PRA.

32021, MV-32022, MV- subsequently over-torque the 32238, and MV-32246 MOV. Compensatory measures in which are credited in the accordance with the current Fire PRA to be locally Fire Protection Licensing operated to perform Basis are being Recovery Actions. maintained.

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

42 N/A 1 Wiring above suspended Bring Fire Area 8 Locker No No This modification will ceilings in Fire Area 8 Room, Unit 1, 715 in the restore compliance with Locker Room, Unit 1, 715 southeast corner into NFPA 805 requirements. It in the southeast corner is compliance with NFPA 805, is not modeled in the Fire not in compliance with the Section 3.3.5.1. PRA for risk significance.

requirements of NFPA 805.

Compensatory measures in accordance with the fire protection licensing basis will be maintained until the modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 43 N/A 1, 2 Fire Protection Barriers Upgrade Fire Protection No No This modification will required by NFPA 805 not Barriers required by NFPA 805 restore compliance with in compliance with the to meet the requirements of NFPA 805 requirements. It requirements of NFPA 805. NFPA 805, Section 3.11. is not modeled in the Fire PRA for risk significance.

Compensatory measures in accordance with the fire protection licensing basis will be maintained until the modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3, Implementation Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to implementation of the new NFPA 805 fire protection program. This will occur within the later of twelve (12) months after NRC approval, or twelve months after a refueling outage if one is in progress at the time of approval. Note that Item 20, Item 66 and Item 70 are associated with modifications described in Table S-2 and will be completed 180 days after modifications are complete.

Table S-3 Implementation Items Item Unit Description LAR Section / Source 1 1, 2 Implement monitoring program required by NFPA 805 Section 2.6 4.6.2, Attachment A Section 3.2.3(3) in accordance with NFPA 805 FAQ 10-0059, including a process that reviews the FPP performance and trends in performance.

2 1, 2 Revise plant procedure 5AWI 3.13.3, "Hot Work," to address the Attachment A Section 3.3.1.3.1 following: Attachment A Section 3.3.1.3.3 Attachment D

- Address the requirements for hot tapping. (NFPA 51B-1999, Section 3-5)

- Address the requirements for a fire watch where torch-applied roofing hot work operations are in effect. (NFPA 241-1999, Section 5.1.3.2)

-Address the requirement that open flames or combustion-generated smoke shall not be permitted for leak or air flow testing.

- Consider delaying hot work in the vicinity of risk significant components during High Risk Evolutions 3 1, 2 Revise procedure F5 App J, "Fire Drills," to require that fire Attachment A, Section 3.4.3 (C)(3) brigade drills be conducted in various plant areas.

4 1,2 Perform a calculation to demonstrate that the fire water supply is Attachment A Section 3.5.1 capable of delivering the largest design demand with the hydraulically least demanding portion of fire main loop out of service in accordance with NFPA 805 requirements.

5 N/A DELETED N/A 6 1, 2 Revise procedure F5, Firefighting, Section 7, to include a Section Attachment E 7.5, Control of Spread of Contamination, to address ventilation, floor drains, opening walkways or stairs between areas, and salvage/overhaul activities.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 7 1, 2 Revise Fire Brigade Training Lesson Plans to address the spread Attachment E of contamination during firefighting activities.

8 1, 2 Revise Fire Brigade Training Lesson Plans to identify the Attachment E responsibilities of each brigade member relative to limiting the spread of cross contamination when fighting fires in radiologically controlled areas.

9 1, 2 Revise Fire Brigade Training Lesson Plans to provide sufficient Attachment E details on the impact of fire fighting activities on the potential spread of contamination, and the methods available for mitigating such cross contamination via ventilation and drainage control.

10 1, 2 Revise procedure F5 App A, Fire Strategies, to include Attachment E information on potential cross-contamination for each fire area.

11 1, 2 Revise procedure F5, Firefighting, Section 2.7 to address Attachment E potential access requirements for the Duty RP Tech or Chemist.

12 1, 2 Revise Radiation Protection Continuing Training to address Attachment E control of contamination during firefighting activities.

13 1, 2 Revise procedure F5, App A, Fire Strategies to address the Attachment E ability to utilize the Auxiliary Building Special Ventilation, Containment Internal Cleanup Subsystem, Containment Purge, Containment In-Service Purge, and Shield Building Ventilation System for the removal of potentially contaminated smoke in fire areas identified in Attachment E.

14 N/A DELETED N/A 15 1, 2 Provide a container with booms, portable filtered ventilation, and Attachment E other appropriate equipment for the containment of water in the Low Level Rad Waste Enclosure.

16 1, 2 Provide procedures to utilize a combination of containerization and Attachment E administrative controls to ensure that exposed contaminated waste in the Low Level Rad Waste Enclosure are kept as low as reasonably achievable.

17 1, 2 Revise F5 App F, Fire Hazards Analysis to align with the fire Attachment I area descriptions listed in Attachment I.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 18 N/A DELETED N/A 19 N/A DELETED N/A 20 1, 2 Update the Fire PRA Model, as necessary, after all modifications, 4.8.2 procedure changes, and other risk-relevant items identified in PRA RAI 15.a Tables S-1, S-2, and S-3 are complete and as-built. If the revised Fire PRA indicates an increase in risk metrics such that the RG 1.205 acceptance guidelines are not met, changes will be made such that the Fire PRA results will fall within the acceptance guidelines. These changes may include additional analysis, procedure enhancements, plant modifications, or other changes determined necessary to reduce the overall risk metrics to within the acceptance guidelines.

21 N/A DELETED N/A 22 1, 2 Create new Fire Protection Design Basis Document to reflect 4.7.1 content requirements of NFPA 805.

23 N/A DELETED N/A 24 N/A DELETED N/A 25 1, 2 Provide a Change Evaluation Process procedure in accordance 4.7.2 with the requirements of NFPA 805. Ensure the process includes peer reviews to be performed on changes that are PRA upgrades, as defined in the PRA standard.

26 1, 2 Develop qualification requirements and position-specific training 4.7.3 for personnel involved with the Fire PRA.

27 1, 2 Revise procedure 5AWI 3.13.0, Fire Protection Program, to add 4.3.2 and Attachment D Non Power Operations (NPO) overview, definitions; road map; and risk reduction requirements for all NPO, and High Risk Evolutions (HRE).

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 28 1, 2 Revise GEN-PI-059, 10CFR50, App R, Safe Shutdown Database 4.7.2 Data Verification and other configuration control procedures which govern the various PINGP documents and databases that currently exist (or develop new procedures/processes) to reflect the new NFPA 805 licensing bases requirements.

29 1, 2 Revise system level design basis documents to reflect NFPA 805 4.7.2 requirements and superseding of the old fire protection licensing basis.

30 N/A DELETED N/A 31 N/A DELETED N/A 32 N/A DELETED N/A 33 N/A DELETED N/A 34 1, 2 Revise Design Calculations ENG-EE-177, 194401-2.3-008, 4.5 and Attachment B 12911.6214-E-01 and ENG-EE-013 to support the Fire PRA credited power supply breaker - fuse coordination. Additionally, revise Design Calculation ENG-EE-177 per AR 01342798-02 to support the Loss of DC Control Power Analysis.

35 1, 2 Revise FP-OP-ROM-01, Refueling Outage Management 4.3.2 and Attachment D procedure for inclusion of NPO requirements.

36 N/A DELETED N/A 37 N/A Revise 5AWI 3.13.3, Hot Work to avoid hot work in certain areas N/A during high risk evolutions.

38 1,2 Revise F5 App K, Fire Protection Systems Functional 4.3.2 and Attachment D Requirements to contain the compensatory actions to be implemented should a fire protection system required to be operable during HRE periods be found to be impaired.

39 1,2 Revise EM 3.4.1, Review of Proposed Changes to the Fire 4.3.2 and Attachment D Protection Program to contain guidance to ensure that changes to the fire protection program are reviewed for impact to the NPO requirements and risk reduction actions.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 40 1,2 Revise 5AWI 15.6.1, Shutdown Safety Assessment to contain 4.3.2 and Attachment D discussion on HRE, risk due to fire, NFPA 805 and the NPO requirements as part of risk management.

41 N/A DELETED N/A 42 N/A DELETED N/A 43 N/A DELETED N/A 44 N/A DELETED N/A 45 1 Revise 1C1.6, Shutdown Operations - Unit 1 to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

46 2 Revise 2C1.6, Shutdown Operations - Unit 2 to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

47 1 Revise 1C4.1, RCS Inventory Control Pre-refueling to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

48 2 Revise 2C4.1, RCS Inventory Control Pre-refueling to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

49 1 Revise 1C4.2, RCS Inventory Control - Post Refueling to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

50 2 Revise 2C4.2, RCS Inventory Control - Post Refueling to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 51 1, 2 Revise EM 3.4.3, Safe Shutdown Circuit Analysis to incorporate 4.3.2 and Attachment B applicable details of vendor document EPM-DP-EP-004, as well SSA RAI 03 as the methodology for analyzing twisted pair instrumentation and controls circuits as referenced in EC 20612, PINGP Non-Power/NSCA Operations Review for NFPA 805.

52 1, 2 Develop a calculation titled Nuclear Safety Capability Assessment Attachment B (NSCA) Analysis for Compliance with NFPA 805, to establish a design basis for the NSCA model and supporting analyses.

53 1, 2 Update GEN-PI-055, 10CFR50 Appendix R Manual Action 4.2.1.2 and Attachment T Feasibility Study, to reflect PINGPs transition to NFPA 805, SSA RAI 02 & SSA RAI 04.f including addition of new recovery actions, actions to maintain safe and stable conditions, and to document how the criteria, as defined by FAQ 07-0030, are met.

54 N/A DELETED N/A 55 N/A DELETED N/A 56 N/A DELETED N/A 57 1, 2 Revise procedure F5 App B Control Room Evacuation (Fire) to Attachment G direct the isolation of containment prior to leaving the control Attachment W room, add an optional attachment cross-tie power from opposite Unit if one Unit is in a Station Blackout, and to incorporate credited Recovery Actions.

58 1, 2 Revise F5 App D, Impact of Fire Outside Control/Relay Room as Attachment G and W required to include fire response HFEs in the Fire PRA Model and credited recovery actions from Attachment G.

59 N/A DELETED N/A 60 1, 2 Revise ENG-ME-353, Mechanical MOV Analysis to Support Attachment B IN 92-18 Response to incorporate updated vendor information as identified in AR 01422482.

61 1, 2 Verify that site procedures and compensatory measures for Generic RAI 32, Attachment L control of combustibles agree with assumptions in the Fire PRA.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 62 1, 2 Perform an Evaluation for PNL 117 and PNL 217 to confirm the Attachment D and G loading capacity to supply more than one Instrument Bus.

63 1, 2 Provide procedural guidance to connect a diesel powered portable 4.2.1.2 generator located outside the power block to power a temporary SSA RAI 04 fan for the Main Control Room to maintain safe and stable conditions. Additionally, procedural guidance shall be provided for the operation, maintenance, storage, and refueling of the portable generator and for training and drills.

64 1,2 Update code compliance reviews to document resolution of FPE RAI-06 identified open items.

65 1,2 Develop procedural guidance to provide portable HEPA filters RR RAI-02 strategically located in the Radiological Controlled Area (RCA) that will be available for use based on radiological conditions as monitored by radiation protection personnel and as communicated to the fire brigade leader during fire events.

66 1,2 The PINGP Fire PRA model shall be reviewed using an NRC Updated PRA RAI-15 approved RCP seal model, as well as any exceptions/clarifications included in the NRC approval, to determine if the internal events and Fire PRA require a revision. The Prairie Island internal events and Fire PRA will be updated, if applicable, with the latest RCP seal information. If the updates result in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results.

Compensatory measures established prior to the RCP seal replacement shall remain in place until the calculated risk increase is within RG 1.174 limits.

67 N/A DELETED N/A 68 1, 2 Revise plant procedures to ensure that future wiring installation Attachment L above suspended ceilings in Power Block Areas will conform to NFPA 805 Section 3.3.5.1.

69 1, 2 Enhance the Internal Penetration Seal Program Attachment A PINGP Page S Revision -_

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 70 1, 2 NSPM will update the PINGP Fire PRA model using an NRC PRA RAI 21 approved method for VEWFDS PRA credit. If the update results in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results. Applicable compensatory measures will remain in place until the calculated risk increase is within RG 1.174 limits.

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ENCLOSURE 5 ATTACHMENT S MODIFICATIONS AND IMPLEMENTATION ITEMS (Retyped) 32 pages follow

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items S. Modifications and Implementation Items 31 Pages Attached Attachment S, Revision 4, supersedes Attachment S, Revision 3, provided in the RAI response dated December 14, 2016 PINGP Page S Revision 4

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

A problem statement, Risk ranking of the modification, An indication if the modification is currently included in the FPRA, Compensatory Measure in place if non-compliant with the Current Licensing Basis, and A risk-informed characterization of the modification and compensatory measure.

The following legend should be used when reviewing the Risk Rank in Tables S-1 and S-2:

o High = Modification would have an appreciable impact on reducing overall fire CDF.

o Medium = Modification would have a measurable impact on reducing overall fire CDF.

o Low = Modification would have either an insignificant or no impact on reducing overall fire CDF.

o N/A = Not modeled in the FPRA, therefore a risk ranking is not provided.

NSPM is requesting two full refueling cycles beyond SE issuance to fully implement modifications. This is, in part, due to the outage strategies implemented at PINGP where only one train is removed from service per outage, per unit. Due to the significant modifications required to transition PINGP to NFPA 805, additional time is necessary to fully implement modifications described in Table S-2.

The Proposed Modification statements in Table S-2 provide a conceptual design to address the Problem Statement. The final design and installation to resolve the Problem Statement will be developed and approved in accordance with Xcel Engineering processes, hence implementation details may vary.

Subsequent to approval of the NFPA 805 amendment on August 8, 2017, NSPM has completed modifications listed in Table S-2. However, those completed modifications have not been moved from Table S-2 to Table S-1 in this revision of Attachment S. This was done in order to limit the changes to Attachment S to only those five modifications which NSPM is requesting to delete in its license amendment request dated May 18, 2018.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 9 Low 1,2 Fire Suppression required for Modified fire suppression No N/A The proposed the Fire PRA was not code systems in the following fire modification reduced risk compliant, as required by areas to resolve NFPA by allowing the Fire PRA NFPA 805, for the following Suppression code deviations to credit fire suppression Fire Areas: FA 18, 41B, 31, & as follows: systems in the listed Fire

32. Areas. Per the 2009 FA 18: Installed an odorizer for ASME PRA Standard, fire the Cardox System. suppression systems must be code compliant if FA 31: Resolved non- they are credited in the compliances with pendant Fire PRA.

sprinkler heads.

FA 32: Resolved non-compliances with pendant sprinkler heads.

FA 41B: Installed missing Sprinkler #229.

FA 41B: Installed Heat Activated Detector (HAD) in the enclosure for the 121 Motor Driven Fire Pump.

FA 41B: Installed a sprinkler head above the Diesel Driven Fire Pump because of a large obstruction.

(Ref: EC 21578)

From Table S-2, Item 9 PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 12 Medium 1,2 A fire in Fire Area 29 could Installed a rated fire barrier Yes N/A This modification reduced damage cables required for between Fire Area 29 and Fire fire risk by providing a operation of Train A Cooling Area 69. rated fire barrier between Water Pumps which supply risk significant cables and cooling water to D1 (Ref: EC 21574) fire initiators.

Emergency Diesel Generator which powers Train A From Table S-2, Item 12 safeguards Bus 15.

A fire in Fire Area 69 could damage cables that supply power to ventilation fans for D2 Emergency Diesel Generator supply to Train B safeguards Bus 16. A fire in Fire Area 69 could also damage cables required for offsite power to Bus 15 and Bus 16.

Fire Area 29 and 69 were defined as separate areas in the 1977 Fire Hazards Analysis that was submitted to the NRC and accepted.

There is an open pathway between Fire Area 29 and 69; therefore the Fire PRA Plant Partitioning combined Fire Area 29 and 69 (along with 8, 14, 27, and 70) into Fire Compartment 8GRP. Risk for Fire Compartment 8GRP was high when all of these areas were combined.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-1 Plant Modifications Completed In Comp Risk Informed Item Rank Unit Problem Statement Modification FPRA Measure Characterization 13 Medium 1 A fire in the control room or Wired additional relay contacts Yes N/A This modification reduced relay room could have from the low speed relay in risk by eliminating the caused hot shorts on cables series with indicating light in possibility that a hot short that could spuriously start D1 the control room so that once on a cable in the Control and close the cooling water D1 speed was greater than and Relay Room could supply valve. This condition 250 RPM, the potential hot isolate cooling water to resulted in unrecoverable short on the indicating light in D1 Emergency Diesel damage to the credited the control room is cleared. Generator Emergency Diesel Generator during a fire induced control (Ref: EC 18746) room evacuation.

From Table S-2, Item 13 16 N/A 1,2 The supply ventilation duct Installed a fire damper in the No N/A Not modeled in the between Fire Areas 32 and supply ventilation duct FPRA, therefore a risk 37 did not have a fire damper between FA 32 and 37. ranking was not provided.

and was not code compliant for the Fire PRA, as required (Ref: EC 21572) by NFPA 805.

From Table S-2, Item 16 40 N/A 1, 2 There is a fire protection hose Added a restraint for fire No N/A This modification did not station with insufficient pipe protection hose station WF-9 have an impact of the hangers that did not meet the where the pipe comes through Fire PRA because the requirements of NFPA 14, the floor of the Turbine hose station was still Standpipes and Hose Building. functional.

Systems.

(Ref: EC 18011)

From Table S-2, Item 40 PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 1 High 1 A fire could damage Train Modify equipment in FA 31 to Yes Yes The modifications proposed B 12 Motor Driven Auxiliary ensure that Train A by Items 1-4 will reduce Feedwater Pump equipment is available for fire risk by modifying FAs 31 (MDAFWP) and the control safe shutdown. and 32 to ensure that each switches for the 11 Turbine The controls and associated FA has either A-train or B-Driven Auxiliary Feedwater cables for the Unit 1 Train A train related equipment Pump (TDAFWP) AFWP discharge valves will be unaffected by a fire. This discharge valves (MV- moved to Fire Area 32 so they will limit the number of fire 32238 & MV-32239). Fire are not damaged by a fire in scenarios that could damage to CS-51003 could Fire Area 31. damage both trains of cause spurious closure of equipment.

MV-32238 which would isolate the 11 TDAFWP Compensatory measures in flow to the credited 11 accordance with the Steam Generator. Fire Current Fire Protection damage to control switch Licensing Basis are being CS-51005 could prevent maintained.

closing MV-32239 which could divert the 11 Compensatory measures TDAFWP flow to the non- will continue to remain in credited 12 Steam effect after the NFPA 805 Generator. The NFPA 805 fire protection program Nuclear Safety becomes effective until this Performance Goal Criteria modification is complete.

is not met for Decay Heat Removal.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 2 High 2 A fire in FA 31 could Modify equipment in FA 31 to Yes Yes The modifications proposed damage the 22 TDAFWP ensure that Train A by Items 1-4 will reduce (Train B) and damage the equipment is available for fire risk by modifying FAs 31 circuits for the Train A 21 safe shutdown. and 32 to ensure that each MDAFWP (MV-32383 & The controls, MCC power FA has either A-train or B-MV-32384). Fire damage supply, and associated cables train related equipment at the Train A Hot for the Unit 2 Train A AFWP unaffected by a fire. This Shutdown Panel or MCC discharge and suction valves will limit the number of fire 2A1 could affect MV-32383 will be moved out of Fire Area scenarios that could (21 MDAFWP to 21 SG) or 31 so they are not damaged by damage both trains of MV-32384 (21 MDAFWP to a fire in Fire Area 31. The equipment.

22 SG). A fire at MCC 2A1 cables going to Unit 2 Train A could affect MV-32026 (21 AFW discharge valves (MV- Compensatory measures in MDAFWP suction from 32383 and MV-32384) will be accordance with the Cooling Water), MV-32336 modified so that MOV will not Current Fire Protection (21 MDAFWP suction from spuriously close due to a fire in Licensing Basis are being CST), MV-32383 (21 Fire Area 31. maintained.

MDAFWP to 21 SG) and MV-32384 (21 MDAFWP to Compensatory measures 22 SG). The NFPA 805 will continue to remain in Nuclear Safety effect after the NFPA 805 Performance Goal Criteria fire protection program is not met for Decay Heat becomes effective until this Removal. modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 3 High 1 A fire could damage the 11 Modify equipment in FA 32 to Yes Yes The modifications proposed TDAFWP (Train A) and the ensure that Train B by Items 1-4 will reduce control switches for the 12 equipment is available for fire risk by modifying FAs 31 MDAFWP discharge valves safe shutdown. and 32 to ensure that each (MV-32381 & MV-32382). The controls, MCC power FA has either A-train or B-Fire damage at the Train B supply, and associated cables train related equipment Hot Shutdown Panel or for the Unit 1 B AFWP unaffected by a fire. This MCC 1A2 could affect MV- discharge and suction valves will limit the number of fire 32381 (12 MDAFWP to 11 will be moved out of Fire Area scenarios that could SG) or MV-32382 (12 32 so they are not damaged by damage both trains of MDAFWP to12 SG). A fire a fire in Fire Area 32. The equipment.

at MCC 1A2 could affect cables going to Unit 1 Train B MV-32027 (12 MDAFWP AFW discharge valves (MV- Compensatory measures in suction from Cooling 32381 and MV-32382) will be accordance with the Water), MV-32335 (12 modified so that the MOV will Current Fire Protection MDAFWP suction from not spuriously close due to a Licensing Basis are being CST), MV-32381 (12 fire in Fire Area 32. maintained.

MDAFWP to 11 SG) and MV-32382 (12 MDAFWP to Compensatory measures 12 SG). The NFPA 805 will continue to remain in Nuclear Safety effect after the NFPA 805 Performance Goal Criteria fire protection program is not met for Decay Heat becomes effective until this Removal. modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 4 High 2 A fire could damage the 21 Modify equipment in FA 32 to Yes Yes The modifications proposed MDAFWP (Train A) and the ensure that Train B by Items 1-4 will reduce control switches for the 22 equipment is available for fire risk by modifying FAs 31 TDAFWP discharge valves. safe shutdown. and 32 to ensure that each Fire damage to CS-51605 The controls and associated FA has either A-train or B-could cause spurious cables for the Unit 2 Train B train related equipment closure of MV-32247 which AFWP discharge valves will be unaffected by a fire. This would isolate the 22 moved to Fire Area 31 so they will limit the number of fire TDAFWP flow to the are not damaged by a fire in scenarios that could credited 22 Steam Fire Area 32. damage both trains of Generator. Fire damage to equipment.

control switch CS-51603 could prevent closing MV- Compensatory measures in 32246 which could divert accordance with the the 22 TDAFWP flow to the Current Fire Protection non-credited 21 Steam Licensing Basis are being Generator. The NFPA 805 maintained.

Nuclear Safety Performance Goal Criteria Compensatory measures is not met for Decay Heat will continue to remain in Removal. effect after the NFPA 805 fire protection program becomes effective until this modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 5 High 1,2 A fire in FA 18, Relay Install Incipient Detection Yes Yes The proposed modification Room could damage both System in the Relay Room that will reduce risk by installing trains of safe shutdown. will continuously sample the an incipient detection Since the risk of Recovery Relay Room air inside the risk system that will notify Actions taken in procedure significant cabinets to identify operators of fires in their F5 App B, Control Room fires based on the detection of incipient state. This Evacuation (Fire) are high, the presence of small amounts reduces the significance of installing a Very Early of products of combustion and, the fire scenarios that could Warning Fire Detection if detected, will sound an alarm lead to control room System (VEWFDS) or in the MCR. abandonment.

Incipient Detection is needed to reduce risk in Compensatory measures in the relay room. accordance with the Current Fire Protection Licensing Basis are being maintained.

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

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 Medium 1, 2 Fire damage to cable 1CX- Reroute the following cables Yes Yes The proposed modification 99 in FA 20 could cause a through FA 58 along the "G" will reduce risk because it loss of the normal power line between 8 and 9 and out of will reroute cables feed from 13 Inverter to FA 20: associated with the 120VAC Panel 113. Loss of - 1CX-99 (Instrument Bus III opposite train of equipment Panel 113 causes CV- (Blue) Panel 113 Normal to another FA. This will 31198 (Charging Line to 11 Power Feed) limit the number of fire Regenerative Heat - 1CW-99 (Instrument Bus II scenarios that could Exchanger CV) to fail open (White) Panel 111 Normal damage both trains of causing diversion of flow Power Feed) equipment.

from RCP seal injection to charging. Loss of Panel Install cable Compensatory measures in 113 causes loss of Control - 1DCA-133 (DC Power supply accordance with the Room indication for to BUS 15 Load Sequencer) Current Fire Protection instrument Loops 1N51 from PNL-11 in FA 33 to BUS- Licensing Basis being (Unit 1 Excore Detection 15 Load Sequencer in FA 81 maintained.

Train A), 1T-450A (Unit 1 that is not routed through Fire RCS Loop A Hot Leg Area 20. Compensatory measures Temperature) and 1T-450B will continue to remain in (Unit 1 RCS Loop A Cold effect after the NFPA 805 Leg Temperature). fire protection program becomes effective until this Modification is needed to modification is complete.

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

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

Modification is needed to protect 1CW-99 (Instrument Bus II (White)

Panel 111 Normal Power Feed).

Fire damage to cable 1CF-35 in FA 20 could cause a loss of Control Room indication for Loop 1L-433 (Unit 1 Pressurizer Level).

Modification to protect cable 1CW-99 from fire damage in FA 20 will ensure Pressurizer Level Indication LOOP 1L-427 remains available in the control room.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6 A fire in FA 20 could Re-route conductors from 1C-Cont damage cable 1C-419 419 (Breaker 15-3, Bus 15 which could affect the Offsite Source from 1R ability of BKR 15-3, 1RY Transformer) to cable 15403-B source to Bus 15, to clear which is not routed in Fire Area from the potentially faulted 20.

1RY source to Bus 15.

Local manual action is required to open BKR 15-3 so that Bus 15 can be repowered from the D1 Emergency Diesel Generator.

A fire in FA 32 or 58 could Re-route affected conductors damage cable 1C-333 of cable 1C-333 out of FA 32 affecting the 1RY source to and FA 58 so the 1RY offsite Bus 16, and could damage power supply will be available cable 16408-1, CT11 in FA 32 and FA 58.

source to Bus 16, and cables 1DCB-2 and 1DCB-95 which support the D2 source to Bus 16. A modification to route affected conductors of cable 1C-333 out of fire area 32 and 58 is needed to protect the 1RY source to Bus 16 in fire area 32.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 6

Cont A fire in FA 058/073, 695' Modify cable elevation of the Aux 2DCA-105 (DC Power Cable Building could damage from 21 Battery 125V DC cable 2DCA-105 which Panel 27 Train A) from fire provides DC control power induced failure in Fire Area to PNL 27 which provides 058/073.

DC control power to Bus 25 to trip 4 KV breakers.

7 DELETED DELETED DELETED PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 8 Low 1, 2 Fire Detection required for Install New Fire Detectors per Yes Yes The proposed the Fire PRA is not code NFPA 72 (Detection) to modification reduces risk compliant, as required by resolve NFPA 72 code by allowing the Fire PRA NFPA 805, for the following deviations in the following to credit fire detection Fire Areas: FA-18, 41B, areas: systems in the listed Fire 58/73, 59/74 Areas. Per the 2009 FA 18: Modify the Ionization ASME PRA Standard, fire Fire Detection system to detection systems must provide two zones of coverage be code compliant if they in the Relay Room and P250 are credited in the Fire Computer Room. Modify the PRA.

CO2 fire suppression system to actuate if both Ionization Compensatory measures zones detect a fire in lieu of in accordance with the heat detectors. Current Fire Protection Licensing Basis are being FA 41B: Relocate detector maintained.

from the exhaust stream of a ventilation duct. Compensatory measures will continue to remain in FA 58/73: Resolve various effect after the NFPA 805 detector code issues based on fire protection program S&L Fire Detector Study, Rev becomes effective until 0, PINGP, Project No: 111973- this modification is 055, 12/20/2008 complete.

FA 59/74:Resolve various detector code issues based on S&L Fire Detector Study., Rev 0, PINGP, Project No: 111973-055, 12/20/2008.

9 COMPLETED COMPLETED COMPLETED PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 10 High 1,2 A fire could damage DC Modify 4160 volt switchgear Yes Yes The FPRA assumes control cables for 4 KV control circuits so that faults on coordination of credited breakers which could the control cables will not buses.

cause the tripping control prevent the over-current trip power fuses to clear which relay from protecting the cable This modification ensures would prevent the breaker from over-current conditions there are no secondary from tripping on over- that could lead to cable fires.

current. The fire could then damage and secondary fires or damage the 4 KV power loss of bus coordination. Compensatory measures in cable, but since the breaker accordance with the can't trip, the cable would Current Fire Protection be subjected to an over- Licensing Basis are being current condition up to the maintained.

full fault current available to the bus. If the cable is not Compensatory measures sized large enough to carry will continue to remain in this amount of current, the effect after the NFPA 805 cable could be damaged fire protection program and start a fire in other fire becomes effective until this areas where it is routed. modification is complete.

Affected Breakers:

BKR 15-1, BKR 15-4, BKR 15-5, BKR 15-9, BKR 16-1, BKR 16-5, BKR 16-6, BKR 16-7, BKR 16-10, BKR 16-12, BKR 25-7, BKR 25-8, BKR 25-9, BKR 25-10,BKR 25-13, BKR 26-5, BKR 26-9, BKR 26-11 11 DELETED DELETED DELETED 12 COMPLETED COMPLETED COMPLETED 13 COMPLETED COMPLETED COMPLETED PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 14 Medium 1,2 A fire in FA 13/18 could Modify control circuits for the Yes No This modification will damage cables causing Diesel Driven Cooling Water reduce risk by simplifying multiple spurious Pump to eliminate the current restoration of Cooling operations that could required recovery action of Water to provide cooling to damage D1 Emergency sending an operator to the D1 D1 Emergency Diesel Diesel Generator. If fire Room and Screenhouse. Generator and a backup induced cable damage water supply to the Aux caused multiple spurious Feedwater Pumps.

operations that caused D1 (034-011) to spuriously start with no cooling water (11 MDCLP MTR 13-8, 12 DDCLP 145-392, 21 MDCLP MTR 23-4, 22 DDCLP 245-392) then the EDG could be damaged.

15 DELETED DELETED DELETED 16 COMPLETED COMPLETED COMPLETED 17 DELETED DELETED DELETED PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 18 High 1, 2 A fire in Fire Area 1, 13, 18, Install new RCP seals that Yes Yes The proposed modification 59, and 71 could cause a would not be subject to will reduce risk by installing loss of all Reactor Coolant excessive leakage if all seal a shutdown RCP Seal Pump (RCP) seal cooling cooling is lost. package. The new seal will by damaging RCP seal have the ability to preclude injection from charging and larger seal leakage rates Component Cooling (CC) during loss of seal cooling water to the Thermal scenarios.

Barrier Heat Exchanger (TBHX). Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being maintained.

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

19 DELETED DELETED DELETED 20 DELETED DELETED DELETED 21 DELETED DELETED DELETED 22 DELETED DELETED DELETED 23 Medium 2 A fire in Bus 27 room (Fire Install fuses to provide Yes Yes The Fire PRA assumes Area 127) could damage coordination so that a fire in the proper coordination of DC control power to Bus 25 Bus 27 room will not affect DC these power supplies or Bus 26. control power to Bus 25 or Bus 26.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 24 High 1, 2 A fire in the Bus 15 (Fire Provide fuse/breaker Yes No The proposed modification Area 81) or Bus 16 (Fire coordination for the CT11 will reduce risk by ensuring Area 20) room could supply to Bus 15 and Bus 16 one off-site power source damage the cables and bus so that the CT11 source to the safeguards 4 kV Bus duct that supply off-site remains available to Bus 15 if a remains unaffected by a power (CT11 and 1R fire damages Bus 16 or to Bus fire in the event of a fire in transformers) to Bus 15 16 if a fire damages Bus 15. the opposite train and Bus 16 due to common safeguards 4 kV Bus room.

power supply. The Provide fuse/breaker redundant diesel generator coordination for the CT12 remains unaffected by a supply to Bus 25 and Bus 26 fire to re-power the so that the CT12 source unaffected 4 kv safeguards remains available to Bus 25 if a bus (Bus 15 or Bus 16), but fire damages Bus 26 or to Bus risk is higher than desired. 26 if a fire damages Bus 25.

Modify associated control Unit 2 is similar to Unit 1. A cables (1CS-1, 1CS-2, 1CS-3, fire in Fire Area 117, BUS and 1CS-4) so the CT11/CT12 25 or Fire Area 118, BUS source remains available for 26, could damage cables the opposite Bus room.

for both off-site power sources (2RY and CT12 transformer). The redundant Emergency Diesel Generator (D5/D6) remains unaffected by a fire, but the risk is higher than desired.

25 Medium 1 A fire in Fire Area 32 could Re-power MV-32078 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 32 open MV-32077 and MV- Area 32 to re-gain the ability to does not damage the ability 32078 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 26 Medium 2 A fire in Fire Area 31 could Re-power MV-32180 from an Yes No This will reduce risk by damage cables required to MCC that is not located in Fire ensuring a fire in FA 31 open MV-32180 and MV- Area 31 to re-gain the ability to does not damage the ability 32181 to provide recirculate water from Sump B. to recirculate water from recirculation from Sump B. Sump B.

27 DELETED DELETED DELETED 28 DELETED DELETED DELETED 29 DELETED DELETED DELETED 30 DELETED DELETED DELETED 31 DELETED DELETED DELETED 32 Medium 2 A fire in Fire Area 32 could Modify cable 1C-2278 from Yes No This will reduce risk by damage cable 1C-2278 failing 21 Motor Driven Cooling ensuring the availability of which could affect control Water Pump in Fire Area 32. the 21 MDCLP for a fire in for BKR-23-4 which powers FA 32.

the 21 Motor Driven Cooling Water Pump (21 MDCLP).

33 DELETED DELETED DELETED 34 Medium 1, 2 A fire in FA 13, 18, 32 or 58 Modify cables to prevent Yes No This will reduce risk by could damage cables and spurious closure from risk making modifications to cause spurious closure of significant fire initiators. reduce the number of fire the Emergency Diesel scenarios that could cause Generator output breaker. fire damage to a 4kV This could cause a lockout safeguards bus.

of the 4kv safeguards Bus which powers one train of safeguards equipment.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 35 Medium 1 A fire in Fire Area 32 or 58 Modify cable 1C-332 from fire Yes Yes The proposed modification could damage cables which damage in Fire Area 32 and 58 will reduce risk because it support operation of the to ensure BUS 16 can be will reroute cables 1RY offsite power sources powered from the 1RY associated with the to BUS 15 (BKR-15-3) and transformer. opposite train of equipment BUS 16 (BKR-16-2). to another FA. This will limit the number of fire scenarios that could damage both trains of equipment.

Compensatory measures in accordance with the Current Fire Protection Licensing Basis are being maintained.

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

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 38 N/A 1, 2 A fire in Fire Areas 31, 32, Install control power fuses for No Yes This modification does not 58/73, 18, or 13 could the control circuits to provide have a significant impact damage control cables for over-current protection for the on the Fire PRA model the 11 or 21 DC DC Emergency Turbine because the 11 and 21 Emergency Turbine Bearing Oil Pumps. Emergency Oil Pumps are Bearing Oil Pump that are not credited. The Fire PRA not adequately fused to model does not directly protect from over-current model common enclosure conditions. The control concerns.

cables could over-heat due to excessive current flow.

Since the cables are routed in multiple fire areas, this is a common enclosure concern.

39 N/A 1, 2 The 121 Motor Driven Fire Modify the Fire Pump alarm in No No This modification does not Pump (MDFP) loss of the control room to include the have an impact on the Fire power alarm is local at the loss of power alarm. PRA because the loss of pump in the screen house power alarm does not and does not currently affect functionality of the alarm to the control room. 121 MDFP. It is an NFPA This does not meet NFPA 805 code compliance 20 requirements. concern.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 41 Medium 1, 2 A fire in Fire Area 13 or 18 Re-wire the torque and limit Yes Yes The proposed modification could damage cables that switches so fire induced will allow the valve to be could over-torque motor damage to cables in FA 13 and locally operated to credit operated valves; MV- 18 cannot bypass the torque this recovery action in the 32006, MV-32010, MV- and limit switches and PRA.

32021, MV-32022, MV- subsequently over-torque the 32238, and MV-32246 MOV. Compensatory measures in which are credited in the accordance with the current Fire PRA to be locally Fire Protection Licensing operated to perform Basis are being Recovery Actions. maintained.

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

42 N/A 1 Wiring above suspended Bring Fire Area 8 Locker No No This modification will ceilings in Fire Area 8 Room, Unit 1, 715 in the restore compliance with Locker Room, Unit 1, 715 southeast corner into NFPA 805 requirements. It in the southeast corner is compliance with NFPA 805, is not modeled in the Fire not in compliance with the Section 3.3.5.1. PRA for risk significance.

requirements of NFPA 805.

Compensatory measures in accordance with the fire protection licensing basis will be maintained until the modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 43 N/A 1, 2 Fire Protection Barriers Upgrade Fire Protection No No This modification will required by NFPA 805 not Barriers required by NFPA 805 restore compliance with in compliance with the to meet the requirements of NFPA 805 requirements. It requirements of NFPA 805. NFPA 805, Section 3.11. is not modeled in the Fire PRA for risk significance.

Compensatory measures in accordance with the fire protection licensing basis will be maintained until the modification is complete.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3, Implementation Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to implementation of the new NFPA 805 fire protection program. This will occur within the later of twelve (12) months after NRC approval, or twelve months after a refueling outage if one is in progress at the time of approval. Note that Item 20, Item 66 and Item 70 are associated with modifications described in Table S-2 and will be completed 180 days after modifications are complete.

Table S-3 Implementation Items Item Unit Description LAR Section / Source 1 1, 2 Implement monitoring program required by NFPA 805 Section 2.6 4.6.2, Attachment A Section 3.2.3(3) in accordance with NFPA 805 FAQ 10-0059, including a process that reviews the FPP performance and trends in performance.

2 1, 2 Revise plant procedure 5AWI 3.13.3, "Hot Work," to address the Attachment A Section 3.3.1.3.1 following: Attachment A Section 3.3.1.3.3 Attachment D

- Address the requirements for hot tapping. (NFPA 51B-1999, Section 3-5)

- Address the requirements for a fire watch where torch-applied roofing hot work operations are in effect. (NFPA 241-1999, Section 5.1.3.2)

-Address the requirement that open flames or combustion-generated smoke shall not be permitted for leak or air flow testing.

- Consider delaying hot work in the vicinity of risk significant components during High Risk Evolutions 3 1, 2 Revise procedure F5 App J, "Fire Drills," to require that fire Attachment A, Section 3.4.3 (C)(3) brigade drills be conducted in various plant areas.

4 1,2 Perform a calculation to demonstrate that the fire water supply is Attachment A Section 3.5.1 capable of delivering the largest design demand with the hydraulically least demanding portion of fire main loop out of service in accordance with NFPA 805 requirements.

5 N/A DELETED N/A 6 1, 2 Revise procedure F5, Firefighting, Section 7, to include a Section Attachment E 7.5, Control of Spread of Contamination, to address ventilation, floor drains, opening walkways or stairs between areas, and salvage/overhaul activities.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 7 1, 2 Revise Fire Brigade Training Lesson Plans to address the spread Attachment E of contamination during firefighting activities.

8 1, 2 Revise Fire Brigade Training Lesson Plans to identify the Attachment E responsibilities of each brigade member relative to limiting the spread of cross contamination when fighting fires in radiologically controlled areas.

9 1, 2 Revise Fire Brigade Training Lesson Plans to provide sufficient Attachment E details on the impact of fire fighting activities on the potential spread of contamination, and the methods available for mitigating such cross contamination via ventilation and drainage control.

10 1, 2 Revise procedure F5 App A, Fire Strategies, to include Attachment E information on potential cross-contamination for each fire area.

11 1, 2 Revise procedure F5, Firefighting, Section 2.7 to address Attachment E potential access requirements for the Duty RP Tech or Chemist.

12 1, 2 Revise Radiation Protection Continuing Training to address Attachment E control of contamination during firefighting activities.

13 1, 2 Revise procedure F5, App A, Fire Strategies to address the Attachment E ability to utilize the Auxiliary Building Special Ventilation, Containment Internal Cleanup Subsystem, Containment Purge, Containment In-Service Purge, and Shield Building Ventilation System for the removal of potentially contaminated smoke in fire areas identified in Attachment E.

14 N/A DELETED N/A 15 1, 2 Provide a container with booms, portable filtered ventilation, and Attachment E other appropriate equipment for the containment of water in the Low Level Rad Waste Enclosure.

16 1, 2 Provide procedures to utilize a combination of containerization and Attachment E administrative controls to ensure that exposed contaminated waste in the Low Level Rad Waste Enclosure are kept as low as reasonably achievable.

17 1, 2 Revise F5 App F, Fire Hazards Analysis to align with the fire Attachment I area descriptions listed in Attachment I.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 18 N/A DELETED N/A 19 N/A DELETED N/A 20 1, 2 Update the Fire PRA Model, as necessary, after all modifications, 4.8.2 procedure changes, and other risk-relevant items identified in PRA RAI 15.a Tables S-1, S-2, and S-3 are complete and as-built. If the revised Fire PRA indicates an increase in risk metrics such that the RG 1.205 acceptance guidelines are not met, changes will be made such that the Fire PRA results will fall within the acceptance guidelines. These changes may include additional analysis, procedure enhancements, plant modifications, or other changes determined necessary to reduce the overall risk metrics to within the acceptance guidelines.

21 N/A DELETED N/A 22 1, 2 Create new Fire Protection Design Basis Document to reflect 4.7.1 content requirements of NFPA 805.

23 N/A DELETED N/A 24 N/A DELETED N/A 25 1, 2 Provide a Change Evaluation Process procedure in accordance 4.7.2 with the requirements of NFPA 805. Ensure the process includes peer reviews to be performed on changes that are PRA upgrades, as defined in the PRA standard.

26 1, 2 Develop qualification requirements and position-specific training 4.7.3 for personnel involved with the Fire PRA.

27 1, 2 Revise procedure 5AWI 3.13.0, Fire Protection Program, to add 4.3.2 and Attachment D Non Power Operations (NPO) overview, definitions; road map; and risk reduction requirements for all NPO, and High Risk Evolutions (HRE).

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 28 1, 2 Revise GEN-PI-059, 10CFR50, App R, Safe Shutdown Database 4.7.2 Data Verification and other configuration control procedures which govern the various PINGP documents and databases that currently exist (or develop new procedures/processes) to reflect the new NFPA 805 licensing bases requirements.

29 1, 2 Revise system level design basis documents to reflect NFPA 805 4.7.2 requirements and superseding of the old fire protection licensing basis.

30 N/A DELETED N/A 31 N/A DELETED N/A 32 N/A DELETED N/A 33 N/A DELETED N/A 34 1, 2 Revise Design Calculations ENG-EE-177, 194401-2.3-008, 4.5 and Attachment B 12911.6214-E-01 and ENG-EE-013 to support the Fire PRA credited power supply breaker - fuse coordination. Additionally, revise Design Calculation ENG-EE-177 per AR 01342798-02 to support the Loss of DC Control Power Analysis.

35 1, 2 Revise FP-OP-ROM-01, Refueling Outage Management 4.3.2 and Attachment D procedure for inclusion of NPO requirements.

36 N/A DELETED N/A 37 N/A Revise 5AWI 3.13.3, Hot Work to avoid hot work in certain areas N/A during high risk evolutions.

38 1,2 Revise F5 App K, Fire Protection Systems Functional 4.3.2 and Attachment D Requirements to contain the compensatory actions to be implemented should a fire protection system required to be operable during HRE periods be found to be impaired.

39 1,2 Revise EM 3.4.1, Review of Proposed Changes to the Fire 4.3.2 and Attachment D Protection Program to contain guidance to ensure that changes to the fire protection program are reviewed for impact to the NPO requirements and risk reduction actions.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 40 1,2 Revise 5AWI 15.6.1, Shutdown Safety Assessment to contain 4.3.2 and Attachment D discussion on HRE, risk due to fire, NFPA 805 and the NPO requirements as part of risk management.

41 N/A DELETED N/A 42 N/A DELETED N/A 43 N/A DELETED N/A 44 N/A DELETED N/A 45 1 Revise 1C1.6, Shutdown Operations - Unit 1 to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

46 2 Revise 2C1.6, Shutdown Operations - Unit 2 to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

47 1 Revise 1C4.1, RCS Inventory Control Pre-refueling to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

48 2 Revise 2C4.1, RCS Inventory Control Pre-refueling to contain a 4.3.2 and Attachment D requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

49 1 Revise 1C4.2, RCS Inventory Control - Post Refueling to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

50 2 Revise 2C4.2, RCS Inventory Control - Post Refueling to contain 4.3.2 and Attachment D a requirement to maintain a continuous action to monitor T-Boil until the HRE can be exited then an HRE Risk Reduction Actions exit check list is provided.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 51 1, 2 Revise EM 3.4.3, Safe Shutdown Circuit Analysis to incorporate 4.3.2 and Attachment B applicable details of vendor document EPM-DP-EP-004, as well SSA RAI 03 as the methodology for analyzing twisted pair instrumentation and controls circuits as referenced in EC 20612, PINGP Non-Power/NSCA Operations Review for NFPA 805.

52 1, 2 Develop a calculation titled Nuclear Safety Capability Assessment Attachment B (NSCA) Analysis for Compliance with NFPA 805, to establish a design basis for the NSCA model and supporting analyses.

53 1, 2 Update GEN-PI-055, 10CFR50 Appendix R Manual Action 4.2.1.2 and Attachment T Feasibility Study, to reflect PINGPs transition to NFPA 805, SSA RAI 02 & SSA RAI 04.f including addition of new recovery actions, actions to maintain safe and stable conditions, and to document how the criteria, as defined by FAQ 07-0030, are met.

54 N/A DELETED N/A 55 N/A DELETED N/A 56 N/A DELETED N/A 57 1, 2 Revise procedure F5 App B Control Room Evacuation (Fire) to Attachment G direct the isolation of containment prior to leaving the control Attachment W room, add an optional attachment cross-tie power from opposite Unit if one Unit is in a Station Blackout, and to incorporate credited Recovery Actions.

58 1, 2 Revise F5 App D, Impact of Fire Outside Control/Relay Room as Attachment G and W required to include fire response HFEs in the Fire PRA Model and credited recovery actions from Attachment G.

59 N/A DELETED N/A 60 1, 2 Revise ENG-ME-353, Mechanical MOV Analysis to Support Attachment B IN 92-18 Response to incorporate updated vendor information as identified in AR 01422482.

61 1, 2 Verify that site procedures and compensatory measures for Generic RAI 32, Attachment L control of combustibles agree with assumptions in the Fire PRA.

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Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 62 1, 2 Perform an Evaluation for PNL 117 and PNL 217 to confirm the Attachment D and G loading capacity to supply more than one Instrument Bus.

63 1, 2 Provide procedural guidance to connect a diesel powered portable 4.2.1.2 generator located outside the power block to power a temporary SSA RAI 04 fan for the Main Control Room to maintain safe and stable conditions. Additionally, procedural guidance shall be provided for the operation, maintenance, storage, and refueling of the portable generator and for training and drills.

64 1,2 Update code compliance reviews to document resolution of FPE RAI-06 identified open items.

65 1,2 Develop procedural guidance to provide portable HEPA filters RR RAI-02 strategically located in the Radiological Controlled Area (RCA) that will be available for use based on radiological conditions as monitored by radiation protection personnel and as communicated to the fire brigade leader during fire events.

66 1,2 The PINGP Fire PRA model shall be reviewed using an NRC Updated PRA RAI-15 approved RCP seal model, as well as any exceptions/clarifications included in the NRC approval, to determine if the internal events and Fire PRA require a revision. The Prairie Island internal events and Fire PRA will be updated, if applicable, with the latest RCP seal information. If the updates result in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results.

Compensatory measures established prior to the RCP seal replacement shall remain in place until the calculated risk increase is within RG 1.174 limits.

67 N/A DELETED N/A 68 1, 2 Revise plant procedures to ensure that future wiring installation Attachment L above suspended ceilings in Power Block Areas will conform to NFPA 805 Section 3.3.5.1.

69 1, 2 Enhance the Internal Penetration Seal Program Attachment A PINGP Page S Revision 4

Northern States Power - Minnesota Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 70 1, 2 NSPM will update the PINGP Fire PRA model using an NRC PRA RAI 21 approved method for VEWFDS PRA credit. If the update results in a risk increase greater than RG 1.174, NSPM will take action to reduce the risk results. Applicable compensatory measures will remain in place until the calculated risk increase is within RG 1.174 limits.

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