Exelon Generation Company, LLC and PSEG Nuclear, LLC Peach Bottom Atomic Power Station Unit Nos. 2 and 3; Exemption, 6423-6430 [E9-2615]
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Federal Register / Vol. 74, No. 25 / Monday, February 9, 2009 / Notices
NUCLEAR REGULATORY
COMMISSION
[Docket Nos. 50–277 and 50–278; NRC–
2009–0033]
Exelon Generation Company, LLC and
PSEG Nuclear, LLC Peach Bottom
Atomic Power Station Unit Nos. 2 and
3; Exemption
1.0
Background
The Exelon Generation Company
(Exelon, the licensee in addition to
PSEG Nuclear, LLC) is the holder of
Facility Operating License Nos. DPR–44
and DPR–56 which authorize operation
of the Peach Bottom Atomic Power
Station (PBAPS) Units 2 and 3. The
licenses provide, among other things,
that the facility is subject to all rules,
regulations, and orders of the U.S.
Nuclear Regulatory Commission (NRC,
the Commission) now or hereafter in
effect.
The facility consists of two boilingwater reactors located in York and
Lancaster Counties, Pennsylvania.
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2.0
Request/Action
Title 10 of the Code of Federal
Regulations (10 CFR), Part 50, Section
50.48, requires that nuclear power
plants that were licensed before January
1, 1979, must satisfy the requirements of
10 CFR part 50, Appendix R, Section
III.G, ‘‘Fire protection of safe shutdown
capability.’’ PBAPS Units 2 and 3 were
licensed to operate prior to January 1,
1979. As such, the licensee’s Fire
Protection Program (FPP) must satisfy
the established fire protection features
of 10 CFR part 50, Appendix R, Section
III.G. NRC Regulatory Information
Summary (RIS) 2006–10, ‘‘Regulatory
Expectations with Appendix R
Paragraph III.G.2, Operator Manual
Actions,’’ noted that NRC inspections
identified that some licensees had relied
upon operator manual actions, instead
of the options specified in 10 CFR part
50, Appendix R, Section III.G.2 as a
permanent solution to resolve issues
related to Thermo-Lag 330–1 fire
barriers.
In a letter dated October 5, 2007
(Agencywide Documents Access and
Management System (ADAMS)
Accession Number ML072820129), the
licensee identified 25 operator manual
actions that were previously included in
correspondence with the NRC and
found acceptable in a fire protectionrelated Safety Evaluation (SE) dated
September 16, 1993 (ADAMS Accession
Number ML081690220). However, RIS
2006–10 identifies that an exemption
under 10 CFR 50.12 is necessary for use
of the manual actions in lieu of the
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requirements of 10 CFR part 50,
Appendix R, Section III.G.2 even if the
NRC previously issued an SE that found
the manual actions acceptable. This
exemption provides the formal vehicle
for NRC approval for the use of the
specified operator manual actions
instead of the options specified in 10
CFR part 50, Appendix R, Section III.G.2
for PBAPS Units 2 and 3.
In summary, by letter dated October 5,
2007, and supplemental letters dated
May 1, 2008, and December 11, 2008
(ADAMS Accession Numbers
ML081220873 and ML083470170)
responding to the NRC staff’s request for
additional information, Exelon
submitted a request for exemption from
10 CFR Part 50, Appendix R, Section
III.G, ‘‘Fire Protection of Safe Shutdown
Capability,’’ for the use of 25 operator
manual actions as described in Table 1
in lieu of the requirements specified in
Section III.G.2.
3.0
Discussion
Pursuant to 10 CFR 50.12, the
Commission may, upon application by
any interested person or upon its own
initiative, grant exemptions from the
requirements of 10 CFR Part 50 when:
(1) the exemptions are authorized by
law, will not present an undue risk to
public health or safety, and are
consistent with the common defense
and security; and (2) when special
circumstances are present. One of these
special circumstances, described in 10
CFR 50.12(a)(2)(ii), is that the
application of the regulation in the
particular circumstances would not
serve the underlying purpose of the
rule, or is not necessary to achieve the
underlying purpose of the rule.
The underlying purpose of 10 CFR
part 50, Appendix R, Section III.G.2 is
to ensure that one of the redundant
trains necessary to achieve and maintain
hot shutdown conditions remains free of
fire damage in the event of a fire.
Section III.G.2 provides the following
means to ensure that a redundant train
of safe shutdown cables and equipment
is free of fire damage, where redundant
trains are located in the same fire area
outside of primary containment:
a. Separation of cables and equipment
by a fire barrier having a 3-hour rating;
b. Separation of cables and equipment
by a horizontal distance of more than 20
feet with no intervening combustibles or
fire hazards and with fire detectors and
an automatic fire suppression system
installed in the fire area; or
c. Enclosure of cables and equipment
of one redundant train in a fire barrier
having a 1-hour rating and with fire
detectors and an automatic fire
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6423
suppression system installed in the fire
area.
Exelon indicated that the operator
manual actions listed in their October 5,
2007, exemption request are those that
were previously included in
correspondence with the NRC and were
found acceptable in a Fire Protection SE
dated September 16, 1993 (ADAMS
Accession Number ML081690220). The
introductory letter to this SE states, in
part,
The NRC staff has completed a review of
the ‘‘Fire Protection Program’’ document
through Revision 4 as well as certain other
documents related to the implementation of
Appendix R requirements. The enclosed
safety evaluation (SE) concludes that the safe
shutdown capability at Peach Bottom, as
described in the PBAPS Fire Protection
Program, with approved exemptions, satisfies
the requirements of Section III.G and III.L of
Appendix R to 10 CFR Part 50.
Section 2.6 titled ‘‘Manual
Operations,’’ of the September 16, 1993,
SE states, in part,
Each of the four shutdown methods
identified by the licensee in the FPP,
(Methods A, B, C, and D), require that
manual actions be performed outside of the
control room to achieve shutdown following
fires in certain fire areas. Table A–4 of the
FPP describes the manual operations that
may be required and the fire areas that may
require manual actions. [* * *] Based on the
review conducted as part of Inspection
Report 87–30 and the closure of Open Item
87–30–02, the NRC staff finds the manual
operations described in the FPP acceptable.
A cross reference between Table A–4
of the PBAPS Units 2 and 3 FPP,
Revision 3, titled ‘‘Operations that may
be Required to be Performed Outside the
Control Room,’’ and the operator
manual actions identified in the October
5, 2007, Request for Exemption was
provided in table format in the May 1,
2008, Response to Request for
Additional Information. This
information is provided in Table 1 of
this exemption titled, ‘‘Cross-Reference
Between Peach Bottom Fire Protection
Program, Revision 3, Table A–4 and
Operator Manual Actions.’’ There are a
total of 25 operator manual actions
listed in the exemption that occur in 11
different fire areas.
Exelon indicated in the May 1, 2008,
Response to Request for Additional
Information that in several cases, certain
individual operator manual actions that
were approved in the SE are divided
into separate tasks for clarity as part of
the exemption request. Also, in several
cases, additional tasks are specified. The
additional tasks are listed when the
tasks are performed in a different room
from the main action. Exelon states that
this was done to clearly identify the
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areas in which the manual actions are
performed and are not new actions that
did not previously exist.
In the December 11, 2008, Response
to Request for Additional Information,
the licensee outlined the approach that
was taken to evaluate and assess the
effectiveness of the operator manual
actions included in the request. The
cross-reference information provided in
Table 1 provides an explanation for
where each operator manual action is
located and the role of the actions in
achieving safe shutdown. The response
also contains a discussion and
justification for why the operator
manual actions are appropriate for
maintaining consistency with the intent
of Section III.G.2 of Appendix R.
The NRC staff reviewed the licensee’s
evaluation in support of the subject
exemption request for the use of
operator manual actions in lieu of the
requirements specified in Section III.G.2
of Appendix R, and concluded that
given the existing fire protection
features in the affected fire zones,
Exelon continues to meet the underlying
purpose of 10 CFR Part 50, Appendix R,
Section III.G.2 for the PBAPS Units 2
and 3 fire areas described in Table 1.
The following technical evaluation
provides the basis for this conclusion.
3.1 Fire Prevention
Fire areas 2, 6S, 13N, 13S, 26, 38, 54
and 57 all have limited or low
combustible fuel loading (equivalent fire
severity of less than 45 minutes) and fire
areas 4, 50 and 58 have low to moderate
combustible fuel loading (equivalent fire
severity of less than 105 minutes). Fire
area 50 also contains some individual
rooms, such as the lube oil rooms, that
include high combustible fuel loading
(equivalent fire severity of greater than
105 minutes). Areas with moderate or
greater fuel loading have adequate
detection and suppression systems
appropriate for the hazard as described
below.
The primary fixed ignition sources in
the areas are limited to cables and
electrical equipment. It is noted that in
all areas where a postulated fire
included an electrical cable fire, all
exposed cables have fire retardant
insulation material and that the use of
wood is restricted to fire retardant wood
(except for large cribbing).
The NRC staff finds that for all of the
areas related to this exemption, the level
of fire protection combined with the
limited fuel load and minimal ignition
sources in the fire areas associated with
this exemption results in a low
likelihood of a fire occurring and
spreading to adjacent fire areas or
equipment.
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3.2 Detection, Control and
Suppression
The NRC staff evaluated the fire
detection, control and suppression
systems associated with the areas
related to this exemption. All fire areas
included in this exemption have smoke
detection systems installed. Fire areas 4,
13S, 26, 38, 54, 57 and 58 have full-area
smoke detection coverage. Fire area 2 is
provided with smoke or heat detection
in most rooms with the exception of
some of the radwaste pump and tank
rooms that are locked high radiation
areas. Fire areas 6S and 13N have smoke
detection coverage on each elevation
except the refueling floor, where there
are no cables associated with safe
shutdown. Fire area 50 has smoke and/
or heat detection systems installed in
certain individual rooms within the
turbine building to address specific fire
hazards.
Fire areas 2, 4, 38, 57 and 58 also have
full-area automatic fire suppression
systems installed to mitigate any
specific or elevated fire hazards in those
areas. An example of a specific or
elevated fire hazard would be the cable
insulation, lube oil, charcoal filters or
trash/paper noted as being postulated
fires in fire area 2. These fire hazards are
mitigated by the installation of carbon
dioxide systems in each High Pressure
Coolant lnjection pump room, preaction sprinklers over the motor
generator set lube oil pumps, wet pipe
sprinklers in the radwaste trash area and
water spray for the charcoal filters that
are part of the standby gas treatment
system. Fire Area 57 is equipped with
a pre-action sprinkler system to protect
the corridor that passes between the 4kV
bus rooms and the radwaste building.
Fire area 50 has fire detection and
local automatic fire suppression systems
installed in specific areas to suppress
fires that may occur at the specific
hazard source or to protect access
through the area. For example, the
licensee noted in the December 11,
2008, Response to Request for
Additional Information, that some high
combustible fuel load areas, such as the
lube oil, moisture separator, feed pump
rooms, turbine bearings and the
common hatch area, are located in fire
area 50 and that these spaces were
equipped with wet-pipe sprinkler
systems. The licensee also noted that
the hydrogen seal skid on each unit is
equipped with an automatic deluge
system and that a pre-action sprinkler
system is installed over the 13kV
switchgear cabinets in fire area 50.
The NRC staff finds that for the areas
described in the request for exemption,
the fire detection, control and
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suppression systems are adequate to
mitigate any specific or elevated fire
hazards in those areas.
3.3 Preservation of Safe Shutdown
Capability
The NRC staff has evaluated the
feasibility review provided by the
licensee in the December 11, 2008,
Response to Request for Additional
Information. The feasibility review
documents that procedures are in place,
in the form of Transient Response
Implementing Plan procedures, to
ensure that clear and accessible
instructions on how to perform the
manual actions are available to the
operators. Several potential
environmental concerns are also
evaluated, such as radiation levels,
temperature/humidity conditions and
the ventilation configuration and fire
effects that the operators may encounter
during certain emergency scenarios. The
licensee’s feasibility review concluded
that the operator manual actions were
feasible because the operators
performing the manual actions would
not be exposed to adverse or untenable
conditions during any particular
operator manual action procedure or
during the time to perform the
procedure.
The NRC staff reviewed the required
operator manual action completion time
limits versus the time before the action
becomes critical to safely shutting down
the unit as presented in the feasibility
analyses. In one case the action must be
completed within 30 minutes. This
action is identified in Table 1 as 30S546
and requires an operator to travel from
the control room to the cable spreading
room and perform the action of
operating a key switch. The combined
time to complete the travel and
specified action requires a total of 5
minutes. Given the low complexity of
this action the NRC staff finds that this
action is feasible. In addition, the fire
areas described in this exemption are
separated from adjacent fire areas by
fire-rated barriers or water curtains to
provide a level of compartmentalization
between the fire areas and/or buildings.
This compartmentalization helps to
ensure that fires will not spread to
adjacent fire areas and that any fire
damage will be limited to the fire area
of origin. The NRC staff finds that there
is a sufficient amount of time available
to complete the proposed operator
manual actions specified in Table 1 of
this exemption.
3.4
Evaluation
As stated in 10 CFR Part 50,
Appendix R, Section II:
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The fire protection program shall extend
the concept of defense-in-depth to fire
protection with the following objectives:
1. To prevent fires from starting,
2. To detect rapidly, control, and
extinguish promptly those fires that do occur,
and
3. To provide protection for structures,
systems, and components important to safety
so that a fire that is not promptly
extinguished by the fire suppression
activities will not prevent the safe shutdown
of the plant.
The NRC staff has evaluated the
elements of defense-in-depth used for
fire protection at PBAPS, applicable to
the fire zones under review. Based upon
consideration of the limited fire ignition
sources and fire hazards in the affected
areas, and the existing fire protection
measures at PBAPS, the NRC staff
concludes that objective one of defensein-depth is adequately met.
Based on the evaluation of fire
detection and suppression systems
provided in the affected fire zones, the
NRC staff determined that any
postulated fire is expected to be
promptly detected by the available
automatic fire detection systems in the
associated fire areas. The available fire
detection and suppression equipment in
these fire areas ensure that a postulated
fire will not be left unchallenged. In
addition, all fire areas are separated
from adjacent fire areas by fire-rated
barriers or water curtains to provide a
level of compartmentalization between
the fire areas and/or buildings. This
compartmentalization helps to ensure
that fires will not spread to adjacent fire
areas and that any fire damage will be
limited to the fire area of origin. In
addition, when fires are contained in
the fire area of origin, the licensee has
demonstrated that the manual actions
are feasible. Therefore, the NRC staff
concludes that objectives 2 and 3 of
defense-in-depth are adequately met.
Therefore, the NRC staff concludes
that the requested exemption to use
operator manual actions in lieu of the
requirements of 10 CFR Part 50,
Appendix R, Section III.G.2 is consistent
with the defense-in-depth methodology
necessary at nuclear power plants and
will not impact PBAPS post-fire safeshutdown capability.
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3.5
Authorized by Law
This exemption would allow PBAPS
the use of operator manual actions in
lieu of meeting the requirements
specified in 10 CFR Part 50, Appendix
R, Section III.G.2. As stated above, 10
CFR 50.12 allows the NRC to grant
exemptions from the requirements of 10
CFR Part 50. The NRC staff has
determined that granting of the
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licensee’s proposed exemption will not
result in a violation of the Atomic
Energy Act of 1954, as amended, or the
Commission’s regulations because
special circumstances exist that warrant
the use of the operator manual actions
to achieve safe shutdown. Therefore, the
exemption is authorized by law.
3.6 No Undue Risk to Public Health
and Safety
The underlying purpose of 10 CFR
part 50, Appendix R, Section III.G.2 is
to ensure that one of the redundant
trains necessary to achieve and maintain
hot shutdown conditions remains free of
fire damage in the event of a fire. Based
on the existing fire barriers, fire
detectors, automatic and manual fire
suppression equipment, fire protection
requirements, and the absence of
significant combustible loads and
ignition sources in the fire areas
associated with this exemption, the NRC
staff has concluded that application of
10 CFR part 50, Appendix R, Section
III.G.2 for these fire areas is not
necessary to achieve the underlying
purpose of this regulation.
The NRC staff has determined that the
exemption to allow PBAPS the use of
operator manual actions in lieu of the
requirements specified in 10 CFR part
50, Appendix R, Section III.G.2 does not
increase the probability or consequences
of previously evaluated accidents. This
determination is based on the NRC staff
finding that the operator manual actions
are not the sole form of protection relied
upon due to the other fire protection
features in place and the manual actions
are considered feasible and provide safe
shutdown capability following a fire.
The combination of the operator manual
actions, in conjunction with all of the
measures and systems discussed above,
results in an adequate level of
protection. No new accident initiators
are created by allowing use of operator
manual actions in the fire areas
identified in the exemption and the
probability of postulated accidents is
not increased. Similarly, the
consequences of postulated accidents
are not increased. Therefore, there is no
undue risk (since risk is probability
multiplied by consequences) to public
health and safety.
3.7 Consistent With Common Defense
and Security
The proposed exemption would allow
PBAPS the use of specific operator
manual actions in lieu of meeting the
requirements specified in 10 CFR part
50, Appendix R, Section III.G.2. This
change, to the operation of the plant,
has no relation to security issues nor
does it diminish the level of safety from
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6425
what was intended by the requirements
contained in Section III.G.2. Therefore,
the common defense and security is not
impacted by this exemption.
3.8
Special Circumstances
One of the special circumstances
described in 10 CFR 50.12(a)(2)(ii) is
that the application of the regulation is
not necessary to achieve the underlying
purpose of the rule. The underlying
purpose of 10 CFR Part 50, Appendix R,
Section III.G.2 is to ensure that one of
the redundant trains necessary to
achieve and maintain hot shutdown
conditions remains free of fire damage
in the event of a fire. For the fire areas
specified in Table 1 of this exemption,
the NRC staff finds that the operator
manual actions are feasible and can be
reliably performed and the existing
configuration described herein will
ensure that a redundant train necessary
to achieve and maintain safe shutdown
of the plant will remain free of fire
damage in the event of a fire in these
fire zones. Since the underlying purpose
of 10 CFR part 50, Appendix R, Section
III.G is achieved, the special
circumstances required by 10 CFR
50.12(a)(2)(ii) for the granting of an
exemption from 10 CFR part 50,
Appendix R, Section III.G.2 exist.
4.0
Conclusion
Accordingly, the Commission has
determined that, pursuant to 10 CFR
50.12(a), the exemption is authorized by
law, will not present an undue risk to
the public health and safety, and is
consistent with the common defense
and security. Also, special
circumstances are present such that
application of the regulation in these
particular circumstances is not
necessary to achieve the underlying
purpose of the rule. Therefore, the
Commission hereby grants Exelon an
exemption from the requirements of
Section III.G.2 of Appendix R of 10 CFR
Part 50, to PBAPS Units 2 and 3 for the
25 operator manual actions specified in
Table 1.
Pursuant to 10 CFR 51.32, the
Commission has determined that the
granting of this exemption will not have
a significant effect on the quality of the
human environment (74 FR 5191).
This exemption is effective upon
issuance.
Dated at Rockville, Maryland, this 30th day
of January 2009.
For the Nuclear Regulatory Commission
Joseph G. Giitter,
Director, Division of Operating Reactor
Licensing, Office of Nuclear Reactor
Regulation.
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TABLE 1—CROSS–REFERENCE BETWEEN PEACH BOTTOM FIRE PROTECTION PROGRAM, REVISION 3, TABLE A–4 AND
OPERATOR MANUAL ACTIONS
Operator
manual
action
number
Table
A–4
cross
reference
1 ..............
2AP35 ....
Defeat 2A residual
heat removal (RHR)
pump (2AP35) trip
signal generated by
fire damage to Unit
3 RHR Logic.
2 ..............
2BS456 ..
Transfer 125 VDC
Battery Charger
2BD003 from normal source (E224–
T–B) to its alternate
source (E234–T–B)
due to fire damage.
3 ..............
2DS456 ..
Fire affected
component
information
Transfer 125 VDC
Battery Charger
2DD003 from normal source (E424–
W–A) to its alternate source (E234–
T–B) due to fire
damage.
4 ..............
3BP35 ....
Defeat 3B RHR pump
(3BP35) trip signal
generated by fire
damage to Unit 2
RHR logic.
5 ..............
30S546 ..
6 ..............
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Initiating
fire area
(FA)
External wiring (located in the initiating fire areas) to
the Unit 3 RHR
logic in panel
30C33 (located in
Room (Rm) 302, FA
25).
Loss of power (due to
fire damage in initiating fire areas) to
125 VDC Battery
Charger 2BD003
(located in Rm 226,
FA 36).
Purpose
3AS456 ..
Transfer instrument
power supplies from
normal source
(panel 30Y050) to
alternate power
source (panel
20Y033) due to fire
damage.
Transfer 125 VDC
Battery Charger
3AD003 from its
normal power
source (E134–T–B)
to its alternate
power source
(E124–T–B) due to
fire damage.
Loss of power (due to
fire damage in initiating fire areas) to
125 VDC Battery
Charger 2DD003
(located in Rm 226,
FA 36).
Actions
Action
locations
Notes
2, 57 .......
Install U3 plug-in test
switch 3–10A–J1B
at Panel 30C33.
Cable Spreading
Room, Rm 302, FA
25.
Note 1
Note 2
2, 4, 6S,
57.
1. Verify Breaker 52–
6011 at E234–T–B
is closed prior to
operating switch
2BS456.
1. E–23 Bus Room,
Rm 263, FA 35.
Note 1
Note 4
2. Operate switch
2BS456 to restore
power for Battery
Charger 2BD003
from an alternate
power source.
1. Verify Breaker 52–
6022 at E234–T–B
is closed prior to
operating switch
2DS456.
2. E–42 Bus Room,
Rm 226, FA 36.
2. Operate switch
2DS456 to restore
power for Battery
Charger 2DD003
from an alternate
power source.
Install U2 plug–in test
switch into test jack
2–10A–J1A at panel
20C32.
2. E–42 Bus Room,
Rm 226, FA 36.
2, 6S, 38,
57.
1. E–23 Bus Room,
Rm 263, FA 35.
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2, 57 .......
13N ........
Operate key switch
30S546 to restore
power to instrument
panel from 20Y033.
Cable Spreading
Room, Rm 302, FA
25.
Loss of power (due to
fire damage in initiating fire area) to
125 VDC Battery
Charger 3AD003
(located in Rm 261,
FA 32).
13N ........
1. Verify Breaker 52–
5934 at E124–T–B
is closed prior to
operating switch
3AS456.
1. E–12 Bus Room,
Rm 227, FA 39.
2. Operate switch
3AS456 to restore
power for Battery
Charger 3AD003
from an alternate
power source.
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External wiring (located in initiating
fire areas) to the
Unit 2 RHR logic in
panel 20C32 (located in Rm 302,
FA 25).
Loss of power (due to
fire in initiating fire
area) to instrument
power supply panel
30Y050 (located in
Rm 302, FA 25).
2. E–33 Bus Room,
Rm 261, FA 32.
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Cable Spreading
Room, Rm 302, FA
25.
Note 1
Note 4
Note 5
Note 1
Note 2
Note 4
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TABLE 1—CROSS–REFERENCE BETWEEN PEACH BOTTOM FIRE PROTECTION PROGRAM, REVISION 3, TABLE A–4 AND
OPERATOR MANUAL ACTIONS—Continued
Operator
manual
action
number
Table
A–4
cross
reference
7 ..............
3CS456 ..
Fire affected
component
information
Initiating
fire area
(FA)
Loss of power (due to
fire damage in initiating fire areas) to
125 VDC Battery
Charger 3CD003
(located in Rm 261,
FA 32).
13N, 13S,
26, 57,
58.
Purpose
Notes
9 ..............
10 ............
11 ............
MO3–10–
89A.
MO–2486
MO–2486
MO–3486
Manually operate
MO–3–10–089A if
electrical operating
capability is lost due
to fire damage.
Manually operate
valve MO–2486
upon loss of electrical operating capability due to fire
damage.
Locally operate MO–
2486 from the MCC
if the fire has
caused loss of remote operating capability.
Manually operate
valve MO–3486
upon loss of electrical operating capability due to fire
damage.
Loss of power (due to
fire damage in the
initiating fire area)
to MO–3–10–089A,
3A RHR Heat Exchanger High Pressure Service Water
Heat Outlet (located
in Rm 156, FA 2).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–2486, High
Pressure Service
Water Normal Discharge Valve (located in Rm 815,
FA 54).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–2486, High
Pressure Service
Water Normal Discharge Valve (located in Rm 815,
FA 54).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3486, High
Pressure Service
Water Normal Discharge Valve (located in Rm 815,
FA 54).
13N ........
1. Verify Breaker 52–
5911 at E124–T–B
is closed prior to
operating switch
3CS456.
1. E–12 Bus Room,
Rm 227, FA 39.
2. Operate switch
3CS456 to restore
power for Battery
Charger 3CD003
from an alternate
power source.
1. Open breaker 52–
3623 at E134–W–A.
2. E–33 Bus Room,
Rm 261, FA 32.
2. Manually open
MO–3–10–089A.
8 ..............
Transfer 125 VDC
Battery Charger
3CD003 from its
normal power
source (E334–R–B)
to its alternate
power source
(E124–T–B) due to
fire damage.
Action
locations
Actions
2. U3 RHR Pump
Room, Rm 156, FA
2.
1. E2 Diesel Generator Room, Rm 817,
FA 45.
Note 7
2. Cardox Room, Rm
815, FA 54.
1 and 2. E2 Diesel
Generator Room,
Rm 817, FA 45.
Note 1
50, 54 .....
1. Open breaker 52–
5442 at E234–D–A.
4, 38, 57
2. Manually open
MO–2486.
1. Open breaker 52–
5442 at E234–D–A.
50, 54 .....
2. Open valve using
contactor at MCC.
1. Open breaker 52–
5441 at E234–D–A.
sroberts on PROD1PC70 with NOTICES
2. Manually open
MO–3486.
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1
3
4
6
1. U3 RBCCW Room,
Rm 162, FA 2.
1. E2 Diesel Generator Room, Rm 817,
FA 45.
2. Cardox Room, Rm
815, FA 54.
09FEN1
Note
Note
Note
Note
Note 7
6428
Federal Register / Vol. 74, No. 25 / Monday, February 9, 2009 / Notices
TABLE 1—CROSS–REFERENCE BETWEEN PEACH BOTTOM FIRE PROTECTION PROGRAM, REVISION 3, TABLE A–4 AND
OPERATOR MANUAL ACTIONS—Continued
Operator
manual
action
number
Table
A–4
cross
reference
12 ............
MO–3486
Initiating
fire area
(FA)
Actions
14 ............
15 ............
16 ............
17 ............
VerDate Nov<24>2008
MO2–10–
034A.
MO2–10–
039A.
MO3–10–
034A.
MO3–10–
039A.
MO2–10–
034B.
Locally operate MO–
3486 from the motor
control center
(MCC) if the fire has
caused loss of remote operating capability.
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3486, High
Pressure Service
Water Normal Discharge Valve (located in Rm 815,
FA 54).
57, 58 .....
1. Open breaker 52–
5441 at E234–D–A.
Action
locations
Notes
Manually open valve
MO–2–10–034A if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–2–10–039A if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–3–10–034A if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–3–10–039A if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–2–10–034B if
electrical operating
capability is lost due
to fire damage.
16:35 Feb 06, 2009
Jkt 217001
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–2–10–34A,
RHR Loop A Full
Flow Test Valve (located in Rm 1, FA
5).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–2–10–039A,
RHR Loop A Torus
Header Valve (located in Rm 1, FA
5).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3–10–34A,
RHR Loop A Full
Flow Test Valve (located in Rm 37, FA
12).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3–10–039A,
RHR Loop A Torus
Header Valve (located in Rm 37, FA
12).
Loss of power (due to
fire damage in the
initiating fire area)
to MO–2–10–034B,
RHR Loop B Full
Flow Test Valve (located in Rm 1, FA
5).
PO 00000
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Fmt 4703
1 and 2. E2 Diesel
Generator Room,
Rm 817, FA 45.
Note 1
Note 3
4, 57 ......
2. Open valve using
contactor at MCC.
1. Open breaker 52–
3832 at E324–R–B.
1. U2 Reactor Bldg,
Rm 212, FA 6S.
Note 1
4, 57 ......
2. Manually open
MO–2–10–034A.
1. Open breaker 52–
3831 at E324–R–B.
2. U2 Torus Room,
Rm 1, FA 5.
1. U2 Reactor Bldg,
Rm 212, FA 6S.
Note 1
13N, 26 ..
2. Manually open
MO–2–10–039A.
1. Open breaker 52–
3832 at E334–R–B.
2. U2 Torus Room,
Rm 1, FA 5.
1. U3 Reactor Bldg,
Rm 257, FA 13S.
13N, 26 ..
2. Manually open
MO–3–10–034A.
1. Open breaker 52–
3831 at E334–R–B.
2. U3 Torus Room,
Rm 37, FA 12.
1. U3 Reactor Bldg,
Rm 257, FA 13S.
6S ..........
2. Manually open
MO–3–10–039A.
1. Open breaker 52–
3933 at E424–W–A.
2. U3 Torus Room,
Rm 37, FA 12.
1. U2 RBCCW Room,
Rm 105, FA 2.
2. Manually open
MO–2–10–34B.
13 ............
sroberts on PROD1PC70 with NOTICES
Fire affected
component
information
Purpose
2. U2 Torus Room,
Rm 1, FA 5.
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09FEN1
6429
Federal Register / Vol. 74, No. 25 / Monday, February 9, 2009 / Notices
TABLE 1—CROSS–REFERENCE BETWEEN PEACH BOTTOM FIRE PROTECTION PROGRAM, REVISION 3, TABLE A–4 AND
OPERATOR MANUAL ACTIONS—Continued
Operator
manual
action
number
Table
A–4
cross
reference
18 ............
MO2–10–
039B.
MO2–10–
89D.
Initiating
fire area
(FA)
Actions
Action
locations
Loss of power (due to
fire damage in the
initiating fire area)
to MO–2–10–039B,
RHR Loop B Torus
Header Valve, (located in Rm 1, FA
5).
6S ..........
1. Open breaker 52–
3942 at E424–W–A.
1. U2 RBCCW Room,
Rm 105, FA 2.
6S ..........
2. Manually open
MO–2–10–39B.
1. Open breaker 52–
3931 at E424–W–A.
2. U2 Torus Room,
Rm 1, FA 5.
1. U2 RBCCW Room,
Rm 105, FA 2.
2. Manually open
MO–2–10–89D.
19 ............
Fire affected
component
information
Note 1
Note 3
Note 1
Note 3
Purpose
Manually open valve
MO–2–10–039B if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–2–10–089D if
electrical operating
capability is lost due
to fire damage.
Loss of power (due to
fire damage in the
initiating fire area)
to MO–2–10–089D,
2D RHR Heat Exchanger High Pressure Service Water
Outlet Valve (located in Rm 104,
FA 2).
21 ............
22 ............
sroberts on PROD1PC70 with NOTICES
23 ............
MO3–10–
034B.
MO3–10–
039B.
MO3–10–
89D.
MO2–10–
25B.
Manually open valve
MO–3–10–034B if
electrical operating
capability is lost due
to fire damage.
Manually open valve
MO–3–10–039B if
electrical operating
capability is lost due
to fire damage.
Manually operate
MO–3–10–089D if
electrical operating
capability is lost due
to fire damage.
Manually operate
MO–2–10–025B if
electrical operating
capability is lost due
to fire damage.
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3–10–034B,
RHR Loop B Full
Flow Test Valve (located in Rm 37, FA
12).
Loss of power (due to
fire damage in the
initiating fire areas)
to MO–3–10–039B,
RHR Loop B Torus
Header Valve (located in Rm 37, FA
12).
Loss of power (due to
fire damage in the
initiating fire area)
to MO–3–10–089D,
3D RHR Heat Exchanger High Pressure Service Water
Outlet Valve (located in Rm 159,
FA 10).
Loss of power (due to
fire damage in the
initiating fire area)
to MO–2–10–025B,
RHR Loop B Inboard Discharge
Valve (located in
Rm 204, FA 6N).
2, 57, 58
1. Open breaker 52–
3933 at E434–R–B.
2, 57, 58
2. Manually open
MO–3–10–34B.
1. Open breaker 52–
3942 at E434–R–B.
2. U3 Torus Room,
Rm 37, FA 12.
1. U3 Reactor Bldg,
Rm 250, FA 13N.
58 ...........
2. Manually open
MO–3–10–39B.
1. Open breaker 52–
3931 at E434–R–B.
2. U3 Torus Room,
Rm 37, FA 12.
1. U3 Reactor Bldg,
Rm 250, FA 13N.
2. Manually open
MO–3–10–089D.
20 ............
2. U2 RHR Pump
Room, Rm 104, FA
2.
1. U3 Reactor Bldg,
Rm 250, FA 13N.
2. U3 RHR Pump
Room, Rm 159, FA
10.
1. U2 Reactor Bldg,
Rm 205, FA 6N.
6S ..........
1. Open breaker 52–
25B02 at
N210025B, LPCI
Swing Bus B.
2. Manually open
MO–2–10–025B.
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09FEN1
2. U2 Reactor Bldg,
Rm 204, FA 6N.
Notes
Note 3
6430
Federal Register / Vol. 74, No. 25 / Monday, February 9, 2009 / Notices
TABLE 1—CROSS–REFERENCE BETWEEN PEACH BOTTOM FIRE PROTECTION PROGRAM, REVISION 3, TABLE A–4 AND
OPERATOR MANUAL ACTIONS—Continued
Operator
manual
action
number
Table
A–4
cross
reference
24 ............
MO3–10–
25A.
25 ............
MO3–10–
25B.
Fire affected
component
information
Initiating
fire area
(FA)
Loss of power (due to
fire damage in the
initiating fire area)
to MO–3–10–25A
RHR Loop A Inboard Discharge
Valve (located in
Rm 248, FA 13S).
13N ........
Purpose
Manually operate
MO–3–10–025A if
electrical operating
capability is lost due
to fire damage.
Manually operate
MO–3–10–025B if
electrical operating
capability is lost due
to fire damage.
Loss of power (due to
fire damage in the
initiating fire area)
to MO–3–10–025B,
RHR Loop B Inboard Discharge
Valve (located in
Rm 249, FA 13N).
13S ........
Action
locations
Actions
1. Open breaker 52–
25A02 at
N310025A, LPCI
Swing Bus A.
1. U3 Reactor Bldg,
Rm 257, FA 13S.
2. Manually open
valve MO–3–10–
025A.
1. Open breaker 52–
25B02 at N310025B
LPCI Swing Bus B.
Notes
2. U3 Reactor Bldg,
Rm 248, FA 13S.
1 and 2. U3 Reactor
Bldg, Rm 250, FA
13N.
2. Open MO–3–10–
025B from MCC
Contactor.
Table Notes:
Note 1: Fire Area 57 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 2: This action has been slightly modified from that described in the original submittal to make the action simpler to perform, but the action
location, timing and outcome are the same. The original action was to reach inside the logic cabinet and physically manipulate a relay. A plug–in
switch was fabricated so the operator would not have to handle an energized relay. The outcome is the same (the relay is actuated).
Note 3: Fire Area 58 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 4: When the station procedures were developed, an initial step of verification of the breaker position (closed) of the alternate power
source was added. Appendix R permits the assumption that equipment that is not fire affected will be in its expected position. So verification of
this breaker position is not required for Appendix R compliance. Operations determined that they wanted to add a step to verify the position of
the breaker as a precaution. This extra step was added to this Table since the action is performed in a different fire area than the steps associated with operating the switch. It is important to show that all actions taken by the operators are not in the same fire area where the fire is postulated.
Note 5: Fire Area 2 was omitted from the table in Revision 4. Fire Area 2 is listed in the revision 0, 1 and 2 tables. Fire Area 2 (which subsequently was split into Fire Area 2, 57 and 58) fire guide has always contained the attachment to transfer 125 VDC battery charger 2DD003 from
the normal to the backup source.
Note 6: Fire Area 4 no longer credits use of this manual action.
Note 7: The action to manually open MO–2486 and MO–3486 (physically open the valve at the valve itself) is performed in the same fire area
as the initiating fire area. There is 150 minutes (2.5 hours) between the start of the event and when the valve is to be opened. A fire in the
Cardox Room will be extinguished and the smoke vented from the area long before the action needs to be performed. The operators will not
have any delay or need Self Contained Breathing Apparatus to perform this action.
General Note: Table A–4 Revision 4 was a summary of information that was in the Peach Bottom Cable/Raceway analysis. This program deleted a ‘‘zero’’ that padded many component numbers, and some hyphens. The component number provided in the above table uses the correct
nomenclature that is also used in the post–fire shutdown fire guides, safe shutdown calculations and plant labels.
power plant whose 10-mile Emergency
Planning Zone lies within the State of
Texas.
NUCLEAR REGULATORY
COMMISSION
Response, Office of Nuclear Security
and Incident Response, U.S. Nuclear
Regulatory Commission, Washington,
DC 20555. Telephone: (301) 415–6411;
fax number: (301) 415–6382; e-mail:
Robert.Stransky@nrc.gov.
[NRC–2009–0049]
SUPPLEMENTARY INFORMATION:
This MOU is effective January 23,
2009.
I. Introduction
III. Further Information
This notice is to advise the public of
the issuance of a Final Memorandum of
Understanding (MOU) between the U.S.
Nuclear Regulatory Commission (NRC)
and the State of Texas. The MOU
provides the basis for mutually
agreeable procedures whereby the State
of Texas may utilize the NRC
Emergency Response Data System
(ERDS) to receive data during an
emergency at a commercial nuclear
Documents related to this action,
including the application for
amendment and supporting
documentation, are available
electronically at the NRC’s Electronic
Reading Room at https://www.nrc.gov/
reading-rm/adams.html. From this site,
you can access the NRC’s Agencywide
Document Access and Management
System (ADAMS), which provides text
and image files of NRC’s public
[FR Doc. E9–2615 Filed 2–6–09; 8:45 am]
BILLING CODE 7590–01–P
sroberts on PROD1PC70 with NOTICES
Final Memorandum of Understanding
Between the U.S. Nuclear Regulatory
Commission and the State of Texas
AGENCY: Nuclear Regulatory
Commission.
ACTION: Notice.
FOR FURTHER INFORMATION CONTACT:
Robert Stransky, Senior Emergency
Response Coordinator, Operations
Branch, Division of Preparedness and
VerDate Nov<24>2008
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II. Effective Date
E:\FR\FM\09FEN1.SGM
09FEN1
]]>Agencies
[Federal Register Volume 74, Number 25 (Monday, February 9, 2009)]
[Notices]
[Pages 6423-6430]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-2615]
[[Page 6423]]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-277 and 50-278; NRC-2009-0033]
Exelon Generation Company, LLC and PSEG Nuclear, LLC Peach Bottom
Atomic Power Station Unit Nos. 2 and 3; Exemption
1.0 Background
The Exelon Generation Company (Exelon, the licensee in addition to
PSEG Nuclear, LLC) is the holder of Facility Operating License Nos.
DPR-44 and DPR-56 which authorize operation of the Peach Bottom Atomic
Power Station (PBAPS) Units 2 and 3. The licenses provide, among other
things, that the facility is subject to all rules, regulations, and
orders of the U.S. Nuclear Regulatory Commission (NRC, the Commission)
now or hereafter in effect.
The facility consists of two boiling-water reactors located in York
and Lancaster Counties, Pennsylvania.
2.0 Request/Action
Title 10 of the Code of Federal Regulations (10 CFR), Part 50,
Section 50.48, requires that nuclear power plants that were licensed
before January 1, 1979, must satisfy the requirements of 10 CFR part
50, Appendix R, Section III.G, ``Fire protection of safe shutdown
capability.'' PBAPS Units 2 and 3 were licensed to operate prior to
January 1, 1979. As such, the licensee's Fire Protection Program (FPP)
must satisfy the established fire protection features of 10 CFR part
50, Appendix R, Section III.G. NRC Regulatory Information Summary (RIS)
2006-10, ``Regulatory Expectations with Appendix R Paragraph III.G.2,
Operator Manual Actions,'' noted that NRC inspections identified that
some licensees had relied upon operator manual actions, instead of the
options specified in 10 CFR part 50, Appendix R, Section III.G.2 as a
permanent solution to resolve issues related to Thermo-Lag 330-1 fire
barriers.
In a letter dated October 5, 2007 (Agencywide Documents Access and
Management System (ADAMS) Accession Number ML072820129), the licensee
identified 25 operator manual actions that were previously included in
correspondence with the NRC and found acceptable in a fire protection-
related Safety Evaluation (SE) dated September 16, 1993 (ADAMS
Accession Number ML081690220). However, RIS 2006-10 identifies that an
exemption under 10 CFR 50.12 is necessary for use of the manual actions
in lieu of the requirements of 10 CFR part 50, Appendix R, Section
III.G.2 even if the NRC previously issued an SE that found the manual
actions acceptable. This exemption provides the formal vehicle for NRC
approval for the use of the specified operator manual actions instead
of the options specified in 10 CFR part 50, Appendix R, Section III.G.2
for PBAPS Units 2 and 3.
In summary, by letter dated October 5, 2007, and supplemental
letters dated May 1, 2008, and December 11, 2008 (ADAMS Accession
Numbers ML081220873 and ML083470170) responding to the NRC staff's
request for additional information, Exelon submitted a request for
exemption from 10 CFR Part 50, Appendix R, Section III.G, ``Fire
Protection of Safe Shutdown Capability,'' for the use of 25 operator
manual actions as described in Table 1 in lieu of the requirements
specified in Section III.G.2.
3.0 Discussion
Pursuant to 10 CFR 50.12, the Commission may, upon application by
any interested person or upon its own initiative, grant exemptions from
the requirements of 10 CFR Part 50 when: (1) the exemptions are
authorized by law, will not present an undue risk to public health or
safety, and are consistent with the common defense and security; and
(2) when special circumstances are present. One of these special
circumstances, described in 10 CFR 50.12(a)(2)(ii), is that the
application of the regulation in the particular circumstances would not
serve the underlying purpose of the rule, or is not necessary to
achieve the underlying purpose of the rule.
The underlying purpose of 10 CFR part 50, Appendix R, Section
III.G.2 is to ensure that one of the redundant trains necessary to
achieve and maintain hot shutdown conditions remains free of fire
damage in the event of a fire. Section III.G.2 provides the following
means to ensure that a redundant train of safe shutdown cables and
equipment is free of fire damage, where redundant trains are located in
the same fire area outside of primary containment:
a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
b. Separation of cables and equipment by a horizontal distance of
more than 20 feet with no intervening combustibles or fire hazards and
with fire detectors and an automatic fire suppression system installed
in the fire area; or
c. Enclosure of cables and equipment of one redundant train in a
fire barrier having a 1-hour rating and with fire detectors and an
automatic fire suppression system installed in the fire area.
Exelon indicated that the operator manual actions listed in their
October 5, 2007, exemption request are those that were previously
included in correspondence with the NRC and were found acceptable in a
Fire Protection SE dated September 16, 1993 (ADAMS Accession Number
ML081690220). The introductory letter to this SE states, in part,
The NRC staff has completed a review of the ``Fire Protection
Program'' document through Revision 4 as well as certain other
documents related to the implementation of Appendix R requirements.
The enclosed safety evaluation (SE) concludes that the safe shutdown
capability at Peach Bottom, as described in the PBAPS Fire
Protection Program, with approved exemptions, satisfies the
requirements of Section III.G and III.L of Appendix R to 10 CFR Part
50.
Section 2.6 titled ``Manual Operations,'' of the September 16,
1993, SE states, in part,
Each of the four shutdown methods identified by the licensee in
the FPP, (Methods A, B, C, and D), require that manual actions be
performed outside of the control room to achieve shutdown following
fires in certain fire areas. Table A-4 of the FPP describes the
manual operations that may be required and the fire areas that may
require manual actions. [* * *] Based on the review conducted as
part of Inspection Report 87-30 and the closure of Open Item 87-30-
02, the NRC staff finds the manual operations described in the FPP
acceptable.
A cross reference between Table A-4 of the PBAPS Units 2 and 3 FPP,
Revision 3, titled ``Operations that may be Required to be Performed
Outside the Control Room,'' and the operator manual actions identified
in the October 5, 2007, Request for Exemption was provided in table
format in the May 1, 2008, Response to Request for Additional
Information. This information is provided in Table 1 of this exemption
titled, ``Cross-Reference Between Peach Bottom Fire Protection Program,
Revision 3, Table A-4 and Operator Manual Actions.'' There are a total
of 25 operator manual actions listed in the exemption that occur in 11
different fire areas.
Exelon indicated in the May 1, 2008, Response to Request for
Additional Information that in several cases, certain individual
operator manual actions that were approved in the SE are divided into
separate tasks for clarity as part of the exemption request. Also, in
several cases, additional tasks are specified. The additional tasks are
listed when the tasks are performed in a different room from the main
action. Exelon states that this was done to clearly identify the
[[Page 6424]]
areas in which the manual actions are performed and are not new actions
that did not previously exist.
In the December 11, 2008, Response to Request for Additional
Information, the licensee outlined the approach that was taken to
evaluate and assess the effectiveness of the operator manual actions
included in the request. The cross-reference information provided in
Table 1 provides an explanation for where each operator manual action
is located and the role of the actions in achieving safe shutdown. The
response also contains a discussion and justification for why the
operator manual actions are appropriate for maintaining consistency
with the intent of Section III.G.2 of Appendix R.
The NRC staff reviewed the licensee's evaluation in support of the
subject exemption request for the use of operator manual actions in
lieu of the requirements specified in Section III.G.2 of Appendix R,
and concluded that given the existing fire protection features in the
affected fire zones, Exelon continues to meet the underlying purpose of
10 CFR Part 50, Appendix R, Section III.G.2 for the PBAPS Units 2 and 3
fire areas described in Table 1. The following technical evaluation
provides the basis for this conclusion.
3.1 Fire Prevention
Fire areas 2, 6S, 13N, 13S, 26, 38, 54 and 57 all have limited or
low combustible fuel loading (equivalent fire severity of less than 45
minutes) and fire areas 4, 50 and 58 have low to moderate combustible
fuel loading (equivalent fire severity of less than 105 minutes). Fire
area 50 also contains some individual rooms, such as the lube oil
rooms, that include high combustible fuel loading (equivalent fire
severity of greater than 105 minutes). Areas with moderate or greater
fuel loading have adequate detection and suppression systems
appropriate for the hazard as described below.
The primary fixed ignition sources in the areas are limited to
cables and electrical equipment. It is noted that in all areas where a
postulated fire included an electrical cable fire, all exposed cables
have fire retardant insulation material and that the use of wood is
restricted to fire retardant wood (except for large cribbing).
The NRC staff finds that for all of the areas related to this
exemption, the level of fire protection combined with the limited fuel
load and minimal ignition sources in the fire areas associated with
this exemption results in a low likelihood of a fire occurring and
spreading to adjacent fire areas or equipment.
3.2 Detection, Control and Suppression
The NRC staff evaluated the fire detection, control and suppression
systems associated with the areas related to this exemption. All fire
areas included in this exemption have smoke detection systems
installed. Fire areas 4, 13S, 26, 38, 54, 57 and 58 have full-area
smoke detection coverage. Fire area 2 is provided with smoke or heat
detection in most rooms with the exception of some of the radwaste pump
and tank rooms that are locked high radiation areas. Fire areas 6S and
13N have smoke detection coverage on each elevation except the
refueling floor, where there are no cables associated with safe
shutdown. Fire area 50 has smoke and/or heat detection systems
installed in certain individual rooms within the turbine building to
address specific fire hazards.
Fire areas 2, 4, 38, 57 and 58 also have full-area automatic fire
suppression systems installed to mitigate any specific or elevated fire
hazards in those areas. An example of a specific or elevated fire
hazard would be the cable insulation, lube oil, charcoal filters or
trash/paper noted as being postulated fires in fire area 2. These fire
hazards are mitigated by the installation of carbon dioxide systems in
each High Pressure Coolant lnjection pump room, pre-action sprinklers
over the motor generator set lube oil pumps, wet pipe sprinklers in the
radwaste trash area and water spray for the charcoal filters that are
part of the standby gas treatment system. Fire Area 57 is equipped with
a pre-action sprinkler system to protect the corridor that passes
between the 4kV bus rooms and the radwaste building.
Fire area 50 has fire detection and local automatic fire
suppression systems installed in specific areas to suppress fires that
may occur at the specific hazard source or to protect access through
the area. For example, the licensee noted in the December 11, 2008,
Response to Request for Additional Information, that some high
combustible fuel load areas, such as the lube oil, moisture separator,
feed pump rooms, turbine bearings and the common hatch area, are
located in fire area 50 and that these spaces were equipped with wet-
pipe sprinkler systems. The licensee also noted that the hydrogen seal
skid on each unit is equipped with an automatic deluge system and that
a pre-action sprinkler system is installed over the 13kV switchgear
cabinets in fire area 50.
The NRC staff finds that for the areas described in the request for
exemption, the fire detection, control and suppression systems are
adequate to mitigate any specific or elevated fire hazards in those
areas.
3.3 Preservation of Safe Shutdown Capability
The NRC staff has evaluated the feasibility review provided by the
licensee in the December 11, 2008, Response to Request for Additional
Information. The feasibility review documents that procedures are in
place, in the form of Transient Response Implementing Plan procedures,
to ensure that clear and accessible instructions on how to perform the
manual actions are available to the operators. Several potential
environmental concerns are also evaluated, such as radiation levels,
temperature/humidity conditions and the ventilation configuration and
fire effects that the operators may encounter during certain emergency
scenarios. The licensee's feasibility review concluded that the
operator manual actions were feasible because the operators performing
the manual actions would not be exposed to adverse or untenable
conditions during any particular operator manual action procedure or
during the time to perform the procedure.
The NRC staff reviewed the required operator manual action
completion time limits versus the time before the action becomes
critical to safely shutting down the unit as presented in the
feasibility analyses. In one case the action must be completed within
30 minutes. This action is identified in Table 1 as 30S546 and requires
an operator to travel from the control room to the cable spreading room
and perform the action of operating a key switch. The combined time to
complete the travel and specified action requires a total of 5 minutes.
Given the low complexity of this action the NRC staff finds that this
action is feasible. In addition, the fire areas described in this
exemption are separated from adjacent fire areas by fire-rated barriers
or water curtains to provide a level of compartmentalization between
the fire areas and/or buildings. This compartmentalization helps to
ensure that fires will not spread to adjacent fire areas and that any
fire damage will be limited to the fire area of origin. The NRC staff
finds that there is a sufficient amount of time available to complete
the proposed operator manual actions specified in Table 1 of this
exemption.
3.4 Evaluation
As stated in 10 CFR Part 50, Appendix R, Section II:
[[Page 6425]]
The fire protection program shall extend the concept of defense-
in-depth to fire protection with the following objectives:
1. To prevent fires from starting,
2. To detect rapidly, control, and extinguish promptly those
fires that do occur, and
3. To provide protection for structures, systems, and components
important to safety so that a fire that is not promptly extinguished
by the fire suppression activities will not prevent the safe
shutdown of the plant.
The NRC staff has evaluated the elements of defense-in-depth used
for fire protection at PBAPS, applicable to the fire zones under
review. Based upon consideration of the limited fire ignition sources
and fire hazards in the affected areas, and the existing fire
protection measures at PBAPS, the NRC staff concludes that objective
one of defense-in-depth is adequately met.
Based on the evaluation of fire detection and suppression systems
provided in the affected fire zones, the NRC staff determined that any
postulated fire is expected to be promptly detected by the available
automatic fire detection systems in the associated fire areas. The
available fire detection and suppression equipment in these fire areas
ensure that a postulated fire will not be left unchallenged. In
addition, all fire areas are separated from adjacent fire areas by
fire-rated barriers or water curtains to provide a level of
compartmentalization between the fire areas and/or buildings. This
compartmentalization helps to ensure that fires will not spread to
adjacent fire areas and that any fire damage will be limited to the
fire area of origin. In addition, when fires are contained in the fire
area of origin, the licensee has demonstrated that the manual actions
are feasible. Therefore, the NRC staff concludes that objectives 2 and
3 of defense-in-depth are adequately met.
Therefore, the NRC staff concludes that the requested exemption to
use operator manual actions in lieu of the requirements of 10 CFR Part
50, Appendix R, Section III.G.2 is consistent with the defense-in-depth
methodology necessary at nuclear power plants and will not impact PBAPS
post-fire safe-shutdown capability.
3.5 Authorized by Law
This exemption would allow PBAPS the use of operator manual actions
in lieu of meeting the requirements specified in 10 CFR Part 50,
Appendix R, Section III.G.2. As stated above, 10 CFR 50.12 allows the
NRC to grant exemptions from the requirements of 10 CFR Part 50. The
NRC staff has determined that granting of the licensee's proposed
exemption will not result in a violation of the Atomic Energy Act of
1954, as amended, or the Commission's regulations because special
circumstances exist that warrant the use of the operator manual actions
to achieve safe shutdown. Therefore, the exemption is authorized by
law.
3.6 No Undue Risk to Public Health and Safety
The underlying purpose of 10 CFR part 50, Appendix R, Section
III.G.2 is to ensure that one of the redundant trains necessary to
achieve and maintain hot shutdown conditions remains free of fire
damage in the event of a fire. Based on the existing fire barriers,
fire detectors, automatic and manual fire suppression equipment, fire
protection requirements, and the absence of significant combustible
loads and ignition sources in the fire areas associated with this
exemption, the NRC staff has concluded that application of 10 CFR part
50, Appendix R, Section III.G.2 for these fire areas is not necessary
to achieve the underlying purpose of this regulation.
The NRC staff has determined that the exemption to allow PBAPS the
use of operator manual actions in lieu of the requirements specified in
10 CFR part 50, Appendix R, Section III.G.2 does not increase the
probability or consequences of previously evaluated accidents. This
determination is based on the NRC staff finding that the operator
manual actions are not the sole form of protection relied upon due to
the other fire protection features in place and the manual actions are
considered feasible and provide safe shutdown capability following a
fire. The combination of the operator manual actions, in conjunction
with all of the measures and systems discussed above, results in an
adequate level of protection. No new accident initiators are created by
allowing use of operator manual actions in the fire areas identified in
the exemption and the probability of postulated accidents is not
increased. Similarly, the consequences of postulated accidents are not
increased. Therefore, there is no undue risk (since risk is probability
multiplied by consequences) to public health and safety.
3.7 Consistent With Common Defense and Security
The proposed exemption would allow PBAPS the use of specific
operator manual actions in lieu of meeting the requirements specified
in 10 CFR part 50, Appendix R, Section III.G.2. This change, to the
operation of the plant, has no relation to security issues nor does it
diminish the level of safety from what was intended by the requirements
contained in Section III.G.2. Therefore, the common defense and
security is not impacted by this exemption.
3.8 Special Circumstances
One of the special circumstances described in 10 CFR
50.12(a)(2)(ii) is that the application of the regulation is not
necessary to achieve the underlying purpose of the rule. The underlying
purpose of 10 CFR Part 50, Appendix R, Section III.G.2 is to ensure
that one of the redundant trains necessary to achieve and maintain hot
shutdown conditions remains free of fire damage in the event of a fire.
For the fire areas specified in Table 1 of this exemption, the NRC
staff finds that the operator manual actions are feasible and can be
reliably performed and the existing configuration described herein will
ensure that a redundant train necessary to achieve and maintain safe
shutdown of the plant will remain free of fire damage in the event of a
fire in these fire zones. Since the underlying purpose of 10 CFR part
50, Appendix R, Section III.G is achieved, the special circumstances
required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption
from 10 CFR part 50, Appendix R, Section III.G.2 exist.
4.0 Conclusion
Accordingly, the Commission has determined that, pursuant to 10 CFR
50.12(a), the exemption is authorized by law, will not present an undue
risk to the public health and safety, and is consistent with the common
defense and security. Also, special circumstances are present such that
application of the regulation in these particular circumstances is not
necessary to achieve the underlying purpose of the rule. Therefore, the
Commission hereby grants Exelon an exemption from the requirements of
Section III.G.2 of Appendix R of 10 CFR Part 50, to PBAPS Units 2 and 3
for the 25 operator manual actions specified in Table 1.
Pursuant to 10 CFR 51.32, the Commission has determined that the
granting of this exemption will not have a significant effect on the
quality of the human environment (74 FR 5191).
This exemption is effective upon issuance.
Dated at Rockville, Maryland, this 30th day of January 2009.
For the Nuclear Regulatory Commission
Joseph G. Giitter,
Director, Division of Operating Reactor Licensing, Office of Nuclear
Reactor Regulation.
[[Page 6426]]
Table 1--Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Actions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fire affected
Operator manual Table A-4 cross Purpose component Initiating fire Actions Action locations Notes
action number reference information area (FA)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1................ 2AP35............ Defeat 2A residual External wiring 2, 57........... Install U3 plug-in Cable Spreading Note 1
heat removal (RHR) (located in the test switch 3-10A- Room, Rm 302, FA Note 2
pump (2AP35) trip initiating fire J1B at Panel 30C33. 25.
signal generated areas) to the Unit
by fire damage to 3 RHR logic in
Unit 3 RHR Logic. panel 30C33
(located in Room
(Rm) 302, FA 25).
2................ 2BS456........... Transfer 125 VDC Loss of power (due 2, 4, 6S, 57.... 1. Verify Breaker 1. E-23 Bus Room, Note 1
Battery Charger to fire damage in 52-6011 at E234-T- Rm 263, FA 35. Note 4
2BD003 from normal initiating fire B is closed prior
source (E224-T-B) areas) to 125 VDC to operating
to its alternate Battery Charger switch 2BS456.
source (E234-T-B) 2BD003 (located in
due to fire damage. Rm 226, FA 36).
2. Operate switch 2. E-42 Bus Room, ............
2BS456 to restore Rm 226, FA 36.
power for Battery
Charger 2BD003
from an alternate
power source.
3................ 2DS456........... Transfer 125 VDC Loss of power (due 2, 6S, 38, 57... 1. Verify Breaker 1. E-23 Bus Room, Note 1
Battery Charger to fire damage in 52-6022 at E234-T- Rm 263, FA 35. Note 4
2DD003 from normal initiating fire B is closed prior Note 5
source (E424-W-A) areas) to 125 VDC to operating
to its alternate Battery Charger switch 2DS456.
source (E234-T-B) 2DD003 (located in
due to fire damage. Rm 226, FA 36).
2. Operate switch 2. E-42 Bus Room,
2DS456 to restore Rm 226, FA 36.
power for Battery
Charger 2DD003
from an alternate
power source.
4................ 3BP35............ Defeat 3B RHR pump External wiring 2, 57........... Install U2 plug-in Cable Spreading Note 1
(3BP35) trip (located in test switch into Room, Rm 302, FA Note 2
signal generated initiating fire test jack 2-10A- 25.
by fire damage to areas) to the Unit J1A at panel 20C32.
Unit 2 RHR logic. 2 RHR logic in
panel 20C32
(located in Rm
302, FA 25).
5................ 30S546........... Transfer instrument Loss of power (due 13N............. Operate key switch Cable Spreading
power supplies to fire in 30S546 to restore Room, Rm 302, FA
from normal source initiating fire power to 25.
(panel 30Y050) to area) to instrument panel
alternate power instrument power from 20Y033.
source (panel supply panel
20Y033) due to 30Y050 (located in
fire damage. Rm 302, FA 25).
6................ 3AS456........... Transfer 125 VDC Loss of power (due 13N............. 1. Verify Breaker 1. E-12 Bus Room, Note 4
Battery Charger to fire damage in 52-5934 at E124-T- Rm 227, FA 39.
3AD003 from its initiating fire B is closed prior
normal power area) to 125 VDC to operating
source (E134-T-B) Battery Charger switch 3AS456.
to its alternate 3AD003 (located in
power source (E124- Rm 261, FA 32).
T-B) due to fire
damage.
2. Operate switch 2. E-33 Bus Room,
3AS456 to restore Rm 261, FA 32.
power for Battery
Charger 3AD003
from an alternate
power source.
[[Page 6427]]
7................ 3CS456........... Transfer 125 VDC Loss of power (due 13N, 13S, 26, 1. Verify Breaker 1. E-12 Bus Room, Note 1
Battery Charger to fire damage in 57, 58. 52-5911 at E124-T- Rm 227, FA 39. Note 3
3CD003 from its initiating fire B is closed prior Note 4
normal power areas) to 125 VDC to operating Note 6
source (E334-R-B) Battery Charger switch 3CS456.
to its alternate 3CD003 (located in
power source (E124- Rm 261, FA 32).
T-B) due to fire
damage.
2. Operate switch 2. E-33 Bus Room,
3CS456 to restore Rm 261, FA 32.
power for Battery
Charger 3CD003
from an alternate
power source.
8................ MO3-10-89A....... Manually operate MO- Loss of power (due 13N............. 1. Open breaker 52- 1. U3 RBCCW Room,
3-10-089A if to fire damage in 3623 at E134-W-A. Rm 162, FA 2.
electrical the initiating
operating fire area) to MO-3-
capability is lost 10-089A, 3A RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water Heat
Outlet (located in
Rm 156, FA 2).
2. Manually open MO- 2. U3 RHR Pump
3-10-089A. Room, Rm 156, FA 2.
9................ MO-2486.......... Manually operate Loss of power (due 50, 54.......... 1. Open breaker 52- 1. E2 Diesel Note 7
valve MO-2486 upon to fire damage in 5442 at E234-D-A. Generator Room, Rm
loss of electrical the initiating 817, FA 45.
operating fire areas) to MO-
capability due to 2486, High
fire damage. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Manually open MO- 2. Cardox Room, Rm
2486. 815, FA 54.
10............... MO-2486.......... Locally operate MO- Loss of power (due 4, 38, 57....... 1. Open breaker 52- 1 and 2. E2 Diesel Note 1
2486 from the MCC to fire damage in 5442 at E234-D-A. Generator Room, Rm
if the fire has the initiating 817, FA 45.
caused loss of fire areas) to MO-
remote operating 2486, High
capability. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Open valve using
contactor at MCC.
11............... MO-3486.......... Manually operate Loss of power (due 50, 54.......... 1. Open breaker 52- 1. E2 Diesel Note 7
valve MO-3486 upon to fire damage in 5441 at E234-D-A. Generator Room, Rm
loss of electrical the initiating 817, FA 45.
operating fire areas) to MO-
capability due to 3486, High
fire damage. Pressure Service
Water Normal
Discharge Valve
(located in Rm
815, FA 54).
2. Manually open MO- 2. Cardox Room, Rm
3486. 815, FA 54.
[[Page 6428]]
12............... MO-3486.......... Locally operate MO- Loss of power (due 57, 58.......... 1. Open breaker 52- 1 and 2. E2 Diesel Note 1
3486 from the to fire damage in 5441 at E234-D-A. Generator Room, Rm Note 3
motor control the initiating 817, FA 45.
center (MCC) if fire areas) to MO-
the fire has 3486, High
caused loss of Pressure Service
remote operating Water Normal
capability. Discharge Valve
(located in Rm
815, FA 54).
2. Open valve using
contactor at MCC.
13............... MO2-10-034A...... Manually open valve Loss of power (due 4, 57........... 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1
MO-2-10-034A if to fire damage in 3832 at E324-R-B. Rm 212, FA 6S.
electrical the initiating
operating fire areas) to MO-
capability is lost 2-10-34A, RHR Loop
due to fire damage. A Full Flow Test
Valve (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-034A. Rm 1, FA 5.
14............... MO2-10-039A...... Manually open valve Loss of power (due 4, 57........... 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1
MO-2-10-039A if to fire damage in 3831 at E324-R-B. Rm 212, FA 6S.
electrical the initiating
operating fire areas) to MO-
capability is lost 2-10-039A, RHR
due to fire damage. Loop A Torus
Header Valve
(located in Rm 1,
FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-039A. Rm 1, FA 5.
15............... MO3-10-034A...... Manually open valve Loss of power (due 13N, 26......... 1. Open breaker 52- 1. U3 Reactor Bldg,
MO-3-10-034A if to fire damage in 3832 at E334-R-B. Rm 257, FA 13S.
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-34A, RHR Loop
due to fire damage. A Full Flow Test
Valve (located in
Rm 37, FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-034A. Rm 37, FA 12.
16............... MO3-10-039A...... Manually open valve Loss of power (due 13N, 26......... 1. Open breaker 52- 1. U3 Reactor Bldg,
MO-3-10-039A if to fire damage in 3831 at E334-R-B. Rm 257, FA 13S.
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-039A, RHR
due to fire damage. Loop A Torus
Header Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-039A. Rm 37, FA 12.
17............... MO2-10-034B...... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-034B if to fire damage in 3933 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-034B, RHR Loop
due to fire damage. B Full Flow Test
Valve (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-34B. Rm 1, FA 5.
[[Page 6429]]
18............... MO2-10-039B...... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-039B if to fire damage in 3942 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-039B, RHR Loop
due to fire damage. B Torus Header
Valve, (located in
Rm 1, FA 5).
2. Manually open MO- 2. U2 Torus Room,
2-10-39B. Rm 1, FA 5.
19............... MO2-10-89D....... Manually open valve Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 RBCCW Room,
MO-2-10-089D if to fire damage in 3931 at E424-W-A. Rm 105, FA 2.
electrical the initiating
operating fire area) to MO-2-
capability is lost 10-089D, 2D RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water
Outlet Valve
(located in Rm
104, FA 2).
2. Manually open MO- 2. U2 RHR Pump
2-10-89D. Room, Rm 104, FA 2.
20............... MO3-10-034B...... Manually open valve Loss of power (due 2, 57, 58....... 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1
MO-3-10-034B if to fire damage in 3933 at E434-R-B. Rm 250, FA 13N. Note 3
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-034B, RHR
due to fire damage. Loop B Full Flow
Test Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-34B. Rm 37, FA 12.
21............... MO3-10-039B...... Manually open valve Loss of power (due 2, 57, 58....... 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1
MO-3-10-039B if to fire damage in 3942 at E434-R-B. Rm 250, FA 13N. Note 3
electrical the initiating
operating fire areas) to MO-
capability is lost 3-10-039B, RHR
due to fire damage. Loop B Torus
Header Valve
(located in Rm 37,
FA 12).
2. Manually open MO- 2. U3 Torus Room,
3-10-39B. Rm 37, FA 12.
22............... MO3-10-89D....... Manually operate MO- Loss of power (due 58.............. 1. Open breaker 52- 1. U3 Reactor Bldg, Note 3
3-10-089D if to fire damage in 3931 at E434-R-B. Rm 250, FA 13N.
electrical the initiating
operating fire area) to MO-3-
capability is lost 10-089D, 3D RHR
due to fire damage. Heat Exchanger
High Pressure
Service Water
Outlet Valve
(located in Rm
159, FA 10).
2. Manually open MO- 2. U3 RHR Pump
3-10-089D. Room, Rm 159, FA
10.
23............... MO2-10-25B....... Manually operate MO- Loss of power (due 6S.............. 1. Open breaker 52- 1. U2 Reactor Bldg,
2-10-025B if to fire damage in 25B02 at N210025B, Rm 205, FA 6N.
electrical the initiating LPCI Swing Bus B.
operating fire area) to MO-2-
capability is lost 10-025B, RHR Loop
due to fire damage. B Inboard
Discharge Valve
(located in Rm
204, FA 6N).
2. Manually open MO- 2. U2 Reactor Bldg,
2-10-025B. Rm 204, FA 6N.
[[Page 6430]]
24............... MO3-10-25A....... Manually operate MO- Loss of power (due 13N............. 1. Open breaker 52- 1. U3 Reactor Bldg,
3-10-025A if to fire damage in 25A02 at N310025A, Rm 257, FA 13S.
electrical the initiating LPCI Swing Bus A.
operating fire area) to MO-3-
capability is lost 10-25A RHR Loop A
due to fire damage. Inboard Discharge
Valve (located in
Rm 248, FA 13S).
2. Manually open 2. U3 Reactor Bldg,
valve MO-3-10-025A. Rm 248, FA 13S.
25............... MO3-10-25B....... Manually operate MO- Loss of power (due 13S............. 1. Open breaker 52- 1 and 2. U3 Reactor
3-10-025B if to fire damage in 25B02 at N310025B Bldg, Rm 250, FA
electrical the initiating LPCI Swing Bus B. 13N.
operating fire area) to MO-3-
capability is lost 10-025B, RHR Loop
due to fire damage. B Inboard
Discharge Valve
(located in Rm
249, FA 13N).
2. Open MO-3-10-
025B from MCC
Contactor.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table Notes:
Note 1: Fire Area 57 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 2: This action has been slightly modified from that described in the original submittal to make the action simpler to perform, but the action
location, timing and outcome are the same. The original action was to reach inside the logic cabinet and physically manipulate a relay. A plug-in
switch was fabricated so the operator would not have to handle an energized relay. The outcome is the same (the relay is actuated).
Note 3: Fire Area 58 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.
Note 4: When the station procedures were developed, an initial step of verification of the breaker position (closed) of the alternate power source was
added. Appendix R permits the assumption that equipment that is not fire affected will be in its expected position. So verification of this breaker
position is not required for Appendix R compliance. Operations determined that they wanted to add a step to verify the position of the breaker as a
precaution. This extra step was added to this Table since the action is performed in a different fire area than the steps associated with operating
the switch. It is important to show that all actions taken by the operators are not in the same fire area where the fire is postulated.
Note 5: Fire Area 2 was omitted from the table in Revision 4. Fire Area 2 is listed in the revision 0, 1 and 2 tables. Fire Area 2 (which subsequently
was split into Fire Area 2, 57 and 58) fire guide has always contained the attachment to transfer 125 VDC battery charger 2DD003 from the normal to
the backup source.
Note 6: Fire Area 4 no longer credits use of this manual action.
Note 7: The action to manually open MO-2486 and MO-3486 (physically open the valve at the valve itself) is performed in the same fire area as the
initiating fire area. There is 150 minutes (2.5 hours) between the start of the event and when the valve is to be opened. A fire in the Cardox Room
will be extinguished and the smoke vented from the area long before the action needs to be performed. The operators will not have any delay or need
Self Contained Breathing Apparatus to perform this action.
General Note: Table A-4 Revision 4 was a summary of information that was in the Peach Bottom Cable/Raceway analysis. This program deleted a ``zero''
that padded many component numbers, and some hyphens. The component number provided in the above table uses the correct nomenclature that is also used
in the post-fire shutdown fire guides, safe shutdown calculations and plant labels.
[FR Doc. E9-2615 Filed 2-6-09; 8:45 am]
BILLING CODE 7590-01-P
