Exelon Generation Company, LLC; Three Mile Island Nuclear Station, Unit No. 1; Exemption, 38845-38850 [2010-16352]
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Federal Register / Vol. 75, No. 128 / Tuesday, July 6, 2010 / Notices
this section if the requirements of Part
V are met.
(p) Exemption Audit. An ‘‘exemption
audit’’ of a plan must consist of the
following:
(1) A review of the written policies
and procedures adopted by the QPAM
pursuant to section V(b) for consistency
with each of the objective requirements
of this exemption (as described in
section VI(q)).
(2) A test of a representative sample
of the plan’s transactions during the
audit period that is sufficient in size and
nature to afford the auditor a reasonable
basis:
(A) To make specific findings
regarding whether the QPAM is in
compliance with (i) the written policies
and procedures adopted by the QPAM
pursuant to section VI(q) of the
exemption and (ii) the objective
requirements of the exemption; and
(B) To render an overall opinion
regarding the level of compliance of the
INHAM’s program with section
VI(p)(2)(A)(i) and (ii) of the exemption.
(3) A determination as to whether the
QPAM has satisfied the definition of an
QPAM under the exemption; and
(4) Issuance of a written report
describing the steps performed by the
auditor during the course of its review
and the auditor’s findings.
(q) For purposes of section VI(p), the
written policies and procedures must
describe the following objective
requirements of the exemption and the
steps adopted by the QPAM to assure
compliance with each of these
requirements:
(1) The definition of a QPAM in
section VI(a).
(2) The requirement of sections V(a)
and I(c) regarding the discretionary
authority or control of the QPAM with
respect to the plan assets involved in
the transaction, in negotiating the terms
of the transaction and with respect to
the decision on behalf of the investment
fund to enter into the transaction.
(3) For a transaction described in Part
I:
(A) That the transaction is not entered
into with any person who is excluded
from relief under section I(a), section
I(d), or section I(e),
(B) that the transaction is not
described in any of the class exemptions
listed in section I(b),
(4) If the transaction is described in
section III:
(A) That the amount of space covered
by the lease does not exceed the
limitations described in section III(a);
and
(B) That no commission or other fee
is paid by the investment fund as
described in section III(d).
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Signed at Washington, DC, this 29th day of
June, 2010.
Ivan L. Strasfeld
Director, Office of Exemption Determinations,
Employee Benefits Security Administration,
U.S. Department of Labor.
[FR Doc. 2010–16302 Filed 7–2–10; 8:45 am]
BILLING CODE 4510–29–P
NATIONAL AERONAUTICS AND
SPACE ADMINISTRATION
[Notice: (10–073)]
Notice of Information Collection
AGENCY: National Aeronautics and
Space Administration (NASA).
ACTION: Notice of information collection.
SUMMARY: The National Aeronautics and
Space Administration, as part of its
continuing effort to reduce paperwork
and respondent burden, invites the
general public and other Federal
agencies to take this opportunity to
comment on proposed and/or
continuing information collections, as
required by the Paperwork Reduction
Act of 1995 (Pub. L. 104–13, 44 U.S.C.
3506(c)(2)(A)).
DATES: All comments should be
submitted within 60 calendar days from
the date of this publication.
ADDRESSES: All comments should be
addressed to Brenda J. Maxwell, Office
of the Chief Information Officer, Mail
Suite 2S71, National Aeronautics and
Space Administration, Washington, DC
20546–0001.
FOR FURTHER INFORMATION CONTACT:
Requests for additional information or
copies of the information collection
instrument(s) and instructions should
be directed to Brenda J. Maxwell, Office
of the Chief Information Officer, NASA
Headquarters, 300 E Street, SW., Mail
Suite 2S71, Washington, DC 20546,
(202) 358–4616,
brenda.maxwell@nasa.gov.
SUPPLEMENTARY INFORMATION:
I. Abstract
The NASA Office of Public Affairs
wants an electronic method to provide
scheduling and notification of NASA
events that allow them to track and
manage these requests for events.
II. Method of Collection
Electronic.
III. Data
Title: Special Events Guest System
(SEGS).
OMB Number: (2700–0073).
Type of Review: Revision of a
currently approved collection.
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38845
Affected Public: Individuals or
households.
Estimated Number of Respondents:
11,000.
Estimated Time per Response:
Voluntary.
Estimated Total Annual Burden
Hours: 1,100.
Estimated Total Annual Cost: $0.
IV. Requests for Comments
Comments are invited on: (1) Whether
the proposed collection of information
is necessary for the proper performance
of the functions of NASA, including
whether the information collected has
practical utility; (2) the accuracy of
NASA’s estimate of the burden
(including hours and cost) of the
proposed collection of information; (3)
ways to enhance the quality, utility, and
clarity of the information to be
collected; and (4) ways to minimize the
burden of the collection of information
on respondents, including automated
collection techniques or the use of other
forms of information technology.
Brenda J. Maxwell,
NASA PRA Clearance Officer.
[FR Doc. 2010–16215 Filed 7–2–10; 8:45 am]
BILLING CODE 7510–13–P
NUCLEAR REGULATORY
COMMISSION
[Docket No. 50–289; NRC–2010–0221]
Exelon Generation Company, LLC;
Three Mile Island Nuclear Station, Unit
No. 1; Exemption
1.0
Background
Exelon Generation Company, LLC
(Exelon, the licensee) is the holder of
Facility Operating License No. DPR–50
which authorizes operation of the Three
Mile Island Nuclear Station, Unit 1
(TMI–1). The license provides, 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 a pressurizedwater reactor (PWR) located in Dauphin
County, 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.’’ TMI–1 was licensed to
operate prior to January 1, 1979. As
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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.
TMI–1 proposes to utilize an operator
manual action (OMA) in lieu of meeting
the circuit separation and/or protection
requirements contained in 10 CFR part
50, appendix R, section III.G.2 (III.G.2),
which requires ensuring that one of the
redundant trains of systems necessary to
achieve and maintain hot shutdown is
maintained free of fire damage. In this
case, the OMA is proposed for a fire
occurring in Fire Zone 6 of the plant’s
Auxiliary Building (AB–FZ–6). The
prescribed action involves opening a
breaker and manually opening valve
MU–V–36 within 40 minutes to support
maintaining a makeup pump minimum
recirculation path. By letter dated
December 30, 1986 (ADAMS Legacy
Library Accession No. 8701090216), this
OMA was previously approved by the
NRC; however, the time requirement has
been shortened, necessitating this
exemption.
In summary, by letter dated March 3,
2009 (Agencywide Documents Access
and Management System (ADAMS)
Accession No. ML090630134), as
supplemented by letter dated March 15,
2010 (ADAMS Accession No.
ML100750093), Exelon requested an
exemption for TMI–1 from certain
technical requirements of III.G.2 for the
use of an OMA in lieu of meeting the
circuit separation and/or protection
requirements contained in III.G.2 for
AB–FZ–6.
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. These
circumstances include the special
circumstances that the application of
the regulation is not necessary to
achieve the underlying purpose of the
rule.
In its March 15, 2010, letter, the
licensee discussed financial
implications associated with plant
modifications that may be necessary to
comply with the regulation. If such
costs have been shown to be
significantly in excess of those
contemplated at the time the regulation
was adopted, or are significantly in
excess of those incurred by others
similarly situated, this may be
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considered a basis for considering an
exemption request. However, financial
implications were not considered in the
regulatory review of their request since
no substantiation was provided
regarding such financial implications.
Even though no financial substantiation
was provided, the licensee did submit
sufficient regulatory basis to support a
technical review of their exemption
request in that the application of the
regulation in this particular
circumstance is not necessary to achieve
the underlying purpose of the rule.
In accordance with 10 CFR 50.48(b),
nuclear power plants licensed before
January 1, 1979, are required to meet
section III.G, of 10 CFR part 50,
appendix R. The underlying purpose of
10 CFR part 50, appendix R, section
III.G is to ensure that the ability to
achieve and maintain safe shutdown is
preserved following a fire event. The
regulation intends for licensees to
accomplish this by extending the
concept of defense-in-depth to:
(1) Prevent fires from starting;
(2) Rapidly detect, control, and
extinguish promptly those fires that do
occur;
(3) 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 stated purpose of 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 requires one of 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:
(1) Separation of cables and
equipment by a fire barrier having a 3hour rating;
(2) 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
(3) 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 has requested an exemption
from the requirements of III.G.2 for
TMI–1 to the extent that one of the
redundant trains of systems necessary to
achieve and maintain hot shutdown is
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not maintained free of fire damage in
accordance with one of the required
means, for a fire occurring in Fire Zone
AB–FZ–6 in the Auxiliary Building. In
its March 15, 2010, response to the
NRC’s request for additional
information, the licensee stated that the
purpose of its request was to credit the
use of an OMA, in conjunction with
other forms of defense-in-depth, in lieu
of the separation and protective
measures required by III.G.2 for a fire in
Fire Zone AB–FZ–6. Specifically, Fire
Zone AB–FZ–6 is not protected
throughout by an automatic fire
suppression system and rated fire
barriers or 20 feet of spatial separation
are not provided between the redundant
equipment. The OMA entails locally
opening a feeder breaker (1P 480V
Switchgear Unit 4C) located in Fire
Zone CB–FA–2a and a valve (MU–V–
36), which is located in Fire Zone AB–
FZ–3, to establish a makeup pump
recirculation flow path.
In summary, TMI–1 does not meet the
requirements of III.G.2 for a fire in Fire
Zone AB–FZ–6 and an OMA may be
necessary to achieve and maintain hot
shutdown capability. The licensee also
indicated that the only credible scenario
for a fire in Fire Zone AB–FZ–6 that
may require the need to manually open
valve MU–V–36 is as follows: the fire
must initiate within the MU–V–36
breaker compartment of the 1A
Engineered Safeguards Valve (ESV)
motor control center (MCC), cause a
fault on an energized circuit to make
MU–V–36 close, cause power failure of
the 1A ESV MCC, spread to and damage
the instrument air tubing causing valves
MU–V–18 and MU–V–20 to close, and
cause failure of the 1B ESV MCC power
circuit, which is contained within a 4inch galvanized steel conduit.
See Section 3.3 below for additional
details addressing the spatial separation
between cables and instrument air
tubing. In addition, the TMI–1 analysis
assumes that fire damage may occur
immediately upon first detection of the
fire to all components in the fire area.
The licensee stated that after
confirmation of a fire, the fire abnormal
operating procedure (AOP) for Fire Zone
AB–FZ–6 would be entered.
The licensee has described in its
initial request, and subsequent
documents, elements of the fire
protection program that provide
justification that the concept of defensein-depth that is in place in Fire Zone
AB–FZ–6 is consistent with that
intended by the regulation. To
accomplish this, the licensee provides
various forms of protection in order to
maintain the concept of defense-in-
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depth. The licensee’s approach is
discussed below.
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3.1 Fire Prevention
The licensee has stated that it has an
administrative controls program in
place to control ignition sources, hot
work activities (activities such as
welding or grinding), in situ and
transient combustibles, and fire system
impairments. The administrative
controls program is described in the
TMI–1 Updated Final Safety Analysis
Report (UFSAR) and in the Fire Hazards
Analysis Report (FHAR), which is
incorporated by reference into the
UFSAR. Transient combustibles are
restricted in Fire Zone AB–FZ–6 and
particularly in the 1A ESV MCC area.
In addition to these measures, the
licensee has stated that the power and
control cables with voltages up to 480V
AC and 480/120V in the fire zone are
thermoset (Kerite with ethylene
propylene rubber (EPR) insulation).
Thermoset cables are resistant to selfignited cable fires and are not
considered to represent an ignition
source. Other ignition sources in the
area consist of control power
transformers inside the 1A ESV MCC.
The licensee also stated that the
transformers are contained within the
metal-clad MCC housing and contain no
combustible or flammable liquids and
that the control cables are located in
open trays while the 480V power cables
are in conduit or use armor jacketed
cable. Therefore, due to limited ignition
sources and the cables installed in
conduit and armored jacketed cables,
flame propagation is not expected to
present a hazard.
3.2 Detection, Control and
Extinguishment
Fire Zone AB–FZ–6 is provided with
a ceiling-mounted photoelectric smoke
detection system, which is connected to
the Auxiliary Building fire detection
panel, located near the 1A ESV MCC.
The licensee has indicated that if smoke
is detected, a local horn and strobe light
are actuated at the fire alarm panel as
well as in the control room. There are
two smoke detectors located within a
few feet horizontally and approximately
13 feet vertically above the 1A ESV
MCC. The smoke detection system is
designed and installed in accordance
with National Fire Protection
Association (NFPA) 72D (1975),
‘‘Proprietary Protective Signaling
Systems for Guard, Fire Alarm and
Supervisory Service,’’ and NFPA 72E
(1978), ‘‘Automatic Fire Detectors.’’
A hose reel, with at least 100 feet of
hose, is provided in adjacent Fire Zone
AB–FZ–9. The hose reel is less than 100
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feet from the 1A ESV MCC area or any
other area in Fire Zone AB–FZ–6. The
hose reels were designed and installed
in accordance with NFPA 14 (1978),
‘‘Standpipe and Hose Systems,’’ and
have electrically-safe fog nozzles
installed, which make them safe to use
in the vicinity of electrical equipment.
Portable dry chemical and carbon
dioxide fire extinguishers are also
permanently mounted in Fire Zone AB–
FZ–6 and adjacent fire zones. These
extinguishers have been installed in
accordance with NFPA 10, ‘‘Standard for
Portable Fire Extinguishers.’’ The
licensee stated that all fire protection
equipment is maintained in accordance
with the site FPP to ensure operability.
A water curtain is provided for fire
protection of the zone boundary
between Fire Zones AB–FZ–6 and AB–
FZ–7. The pre-action water curtain
system between Fire Zones AB–FZ–6
and AB–FZ–7 is actuated by the crosszone smoke detection system but is not
credited for fire suppression within Fire
Zone AB–FZ–6. The water curtain is
only provided for fire protection of the
zone boundary between Fire Zones AB–
FZ–6 and AB–FZ–7 and all other
openings are sealed with material
having at least a 1-hour fire rating.
The remaining zone boundaries
consist of reinforced concrete walls,
floors and ceilings. The south boundary
and portion of the ceiling are not
adjacent to any other plant areas. The
remainder of the ceiling adjacent to the
chemical addition area and Emergency
Safeguards Features (ESF) Ventilation
Room is a 3-hour fire barrier. Most of
the north boundary is adjacent to Fire
Zone AB–FZ–7 with an open passage,
discussed above, between the zones.
The remainder of the north boundary is
adjacent to the Reactor Building, which
is a 3-hour rated fire barrier. The east
boundary is adjacent to Fire Zones FH–
FZ–1 and FH–FZ–2 and is made of
reinforced concrete. A 3-hour rated fire
barrier is provided on the floor where
this zone is adjacent to Fire Zones AB–
FZ–2a, AB–FZ–2b and AB–FZ–2c. An
automatic pre-action system is located
in Fire Zone AB–FZ–4 where the floor
of Fire Zone AB–FZ–6 is adjacent to
Fire Zone AB–FZ–4.
3.3 Preservation of Safe Shutdown
Capability
The licensee has stated that the
postulated fire event that may require
the OMA to open MU–V–36 would
include at least four independent
failures to occur; two of which are
sequence dependent (i.e., MU–V–36 hot
short occurs prior to loss of MCC) as
described below:
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38847
• While 1A ESV MCC is energized,
the fire causes a hot short (within 1A
ESV MCC), which establishes proper
voltage in the closing circuit and causes
MU–V–36 to travel closed (MU–V–36
control cable CQ232A).
• After MU–V–36 is closed, the fire
causes loss of 1A ESV MCC (cable LP8
within MCC), which is located in the
fire zone. This eliminates remote control
of MU–V–16A and MU–V–16B and
would isolate the ‘A’ train emergency
makeup (High Pressure Injection [HPI])
flow path (valves normally closed).
• The fire causes a loss of integrity of
the 1⁄4-inch outside diameter copper
tubing which causes a sufficient
reduction in the Auxiliary Building
instrument air supply pressure for MU–
V–18 to close and eventually for MU–
V–20 to close. Loss of control of MU–
V–18 eliminates the use of the normal
Reactor Coolant System (RCS) makeup
flow path and depressurization of the
MU–V–20 actuator would cause seal
injection flow to the RCP to be isolated.
• Fire causes loss of power to 1B ESV
MCC (cable LS7A). This eliminates
remote control of MU–V–16C and MU–
V–16D and would eliminate the ‘B’ train
emergency makeup (HPI) flow path as
an alternate means of RCS makeup
(valves normally closed).
In order for a fire to cause MU–V–36
to close, the licensee has indicated that
‘‘ * * * the fire must cause an intracable hot short between a normally
energized conductor in multi-conductor
cable CQ232A and the conductor that
picks up the closing coil. This would
short out the remote control switch and
energize the closing coil for MU–V–36.
The fire must maintain this hot short
without grounding the circuit and
blowing the control power fuses or
otherwise causing a loss of control
power, such as loss of the main 1A ESV
MCC power cable LP8. The MU–V–36
circuits of concern are located within
the MCC breaker compartment along
with the control power fuses. It is
unlikely that a fire could sufficiently
damage cable CQ232A insulation and
short the proper conductors to energize
the closing coil for MU–V–36 prior to
blowing the control power fuses.
Because the fire must cause a hot short
to close MU–V–36 prior to loss of
control power, the most likely fire
ignition location within Fire Zone AB–
FZ–6 is in the MU–V–36 breaker
compartment. Fires in other areas of 1A
ESV MCC would be likely to trip the
main bus breaker or otherwise damage
the 1A ESV MCC power cable LP8 prior
to affecting MU–V–36 circuits.’’
Next, the licensee has indicated that
‘‘[t]he primary combustible in Fire Zone
AB–FZ–6 is 1A ESV MCC and
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associated cables * * * [t]he tubing
closest to 1A ESV MCC is 1⁄4-inch
outside diameter tubing used for testing
reactor building pressure switches. This
tubing is at least 6 feet from the MCC
with no intervening combustibles. The
loss of integrity of these 1⁄4-inch outside
diameter tubing lines may not be
sufficient to exceed the capacity of the
instrument air supply and reduce the
instrument air supply pressure to MU–
V–18 (normal RCS makeup isolation
valve) below 60 psig [pounds per square
inch gauge]. Both instrument air
compressors are unaffected by a fire in
Fire Zone AB–FZ–6 and would attempt
to maintain the instrument air supply to
MU–V–18. The loss of instrument air
system integrity occurs in a section
supplied through 3⁄8-inch regulators and
1⁄4-inch outside diameter tubing. The
main instrument air system distribution
headers are 2-inch lines. This specific
failure may not be sufficient to reduce
the air supply pressure to MU–V–18
enough to prevent adequate RCS
makeup flow. The next closest copper
tubing in Fire Zone AB–FZ–6 is against
the containment wall. This tubing is
further separated from 1A ESV MCC by
at least 10 feet of distance with no
intervening combustibles. Based on the
existing separation with no intervening
combustibles and outside diameter of
the instrument air lines within Fire
Zone AB–FZ–6, it is unlikely that a fire
in 1A ESV MCC would cause a loss of
Auxiliary Building instrument air
pressure.’’
The licensee further indicated that
‘‘[t]he power cable for 1B ESV MCC
(LS7A) is routed through Fire Zone AB–
FZ–6. The cable comes through the 1hour-rated wall (similar to UL-tested
configuration U–410) separating Fire
Zones AB–FZ–6a and AB–FZ–6 in 4inch galvanized steel conduit as it
passes through the area near 1A ESV
MCC. As it turns away from 1A ESV
MCC (at least 6 feet of separation with
no intervening combustibles), it exits
the conduit and enters a tray (via a
splice box). There is at least 12 feet of
vertical separation with no intervening
combustibles between the top of 1A ESV
MCC and the 4-inch conduit that holds
LS7A. Based on the existing separation
and conduit protection, it is unlikely
that the 1B ESV MCC power cable
would be damaged, even if 1A ESV
MCC were fully consumed in a fire.’’
Additionally, the Auxiliary Building
ventilation system is not credited for
smoke removal. If the primary safe
shutdown (SSD) operator becomes
aware of smoke in the Auxiliary
Building, the operator will don a selfcontained breathing apparatus (SCBA)
to perform actions when directed by the
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control room. Two SCBAs are staged
near the primary operator station on
Auxiliary Building 305’ elevation. All
operators assigned to fire brigade or SSD
duties are qualified to use a SCBA.
Validation exercises have been
performed to demonstrate that operators
can reliably don a SCBA in less than 3
minutes.
Given the lack of combustibles,
separation of cables described above,
and the sequence of events required, it
is unlikely that the OMA to open MU–
V–36 would be required. It is also likely
that a fire would be detected and
suppressed before the sequence of
events and failures described above
fully evolved. In the unlikely
occurrence that the sequence does fully
evolve, the OMA is available to provide
assurance that safe shutdown can be
achieved.
3.4 Feasibility and Reliability of the
OMAs
This analysis postulates that the
features described in Sections 3.1, 3.2
and 3.3, are not sufficient to assure safe
shutdown capability. The licensee has
proposed an OMA to be performed in
addition to the above discussed fire
protection features.
NUREG–1852, ‘‘Demonstrating the
Feasibility and Reliability of Operator
Manual Actions in Response to Fire,’’
provides criteria and associated
technical bases for evaluating the
feasibility and reliability of post-fire
OMAs in nuclear power plants. The
following provides the TMI–1 analysis
of these criteria for justifying the OMA
specified in this request for Fire Zone
AB–FZ–6.
3.4.1 Bases for Establishing Feasibility
and Reliability
The licensee’s analysis addresses
factors such as environmental concerns,
equipment functionality and
accessibility, available indications,
communications, portable equipment,
personnel protection equipment,
procedures and training, staffing and
demonstrations.
In their March 3, 2009, letter, and
further supported by their March 15,
2010, letter, the licensee stated that
environmental considerations such as
radiological concerns, emergency
lighting, temperature and humidity
conditions and smoke and toxic gases
were evaluated and found to not
represent a negative impact on the
operators’ abilities to complete the
OMA. The licensee stated that radiation
levels expected during travel to or at the
OMA location in the Auxiliary Building
are minimal with dose rates that would
be less than 10 millirem per hour. The
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licensee also confirmed that sufficient
emergency lighting exists at the areas
where actions are performed and along
the travel routes to the areas. The
licensee has stated that operators also
have access to 8-hour battery-powered
portable lights, as well. The licensee
also has confirmed that temperature and
humidity conditions will not challenge
the operators performing the OMA. The
licensee stated that radio and page
communications are available for this
OMA. Additionally, the licensee
indicated that heat and smoke or gas
generation from the fire will not impact
the operator performing the OMA. This
is further supported by the fact that the
location of the postulated fire event is
in a different fire zone than the
locations for where actions are
performed.
The licensee stated that the
functionality of equipment and cables
needed to perform the required OMA is
documented in the OMA procedures,
which reflect equipment availability
and provide specific direction where
functionality of equipment and cables
may be compromised by fire. In
addition, in-plant OMA walk downs
were performed and demonstrated that
the OMA equipment was accessible.
The physical location of the
components where the OMA is to be
performed is identified in the fire AOPs
and where components cannot be
operated from the floor, installed
ladders or portable ladders are
provided. Other than keys, portable
lighting, and portable ladders, the
operators use no other additional
support equipment. The fire AOPs
identify when a key is required to
perform the OMA. Keys required by
operators are in the possession of the
operator and the specific key number
required for the OMA is identified in
the fire AOP.
With regard to available indications,
the licensee has stated that available
diagnostic instrumentation is listed in
the fire AOP for each fire area; however,
instrumentation or indications are
generally not relied upon to perform the
OMA. Explicit steps in the fire AOPs
direct the operators on how to perform
the OMA such that one train of available
indications is always available for a fire
in a given fire area or zone. The licensee
stated that the OMA does not require
any indication to support completion of
the OMA; however, lack of indication
may be used to initiate an action and
that successful accomplishment of the
OMA is directly observable by the
operator performing the OMA. The
successful completion of the action is
then reported to the Control Room
operators. Additionally, emergency
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makeup flow indication is available for
a fire in Fire Zone AB–FZ–6.
With regard to communications, the
licensee stated that TMI–1 has portable
radio and installed phones available as
part of the normal plant
communications available between the
Control Room and the operators and the
radio and phone systems are robustly
designed such that they should be
available following most fire scenarios.
If the various communication systems
are not available, the method of
communication will be face-to-face or
using radios via line-of-sight (i.e., no
repeaters). The licensee simulated faceto-face communication was simulated
by having operators start the manual
action from directly outside the Control
Room. Task completion is normally
reported by portable hand held radio or
installed phones but may also be
reported by face-to-face communication
if plant communication systems are not
available. The General Announcing
System, Operations Radio System, Plant
Telephone System, Sound Powered
Phone System, and Face-to-Face
Communications are all available to
Control Room operators and operators
performing OMAs.
The licensee stated that operators
performing the OMA are provided with
standard personal protective equipment
(PPE), including hardhat, gloves, and
protective glasses. In the unlikely event
that smoke conditions would require
SCBAs to be worn, the plant equipment
operators are qualified to wear SCBAs
and the SCBAs are staged at strategic
locations in the plant with additional
SCBAs in the fire brigade locker.
The licensee stated that fire AOPs
have been developed for each fire area
or zone and that the fire AOPs are
staged in certain strategic locations that
are easily accessible to the operators.
The individual procedures are
presented in a standardized procedure
format that the operators are familiar
with. The fire AOPs contain both
preventive actions to prevent potential
adverse fire effects, as well as reactive
actions to direct timely action if a fire
causes a particular adverse condition
(i.e., valve spuriously opens or closes).
The procedures for individual fire areas
are used in conjunction with the
symptom-based (reactive) Emergency
Operating Procedures (EOPs) and other
symptom-based AOPs to provide a
combined preventive (fire AOPs) and
reactive (EOPs and all AOPs, including
fire) approach to achieve safe shutdown
following a fire. The individual fire area
shutdown procedures provide the
operators with information as to the
available equipment (including
instrumentation) that can be relied upon
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14:52 Jul 02, 2010
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following a fire. The fire AOP
procedures provide specific guidance to
the operators as to what equipment
could be affected by the fire and are
written in order of time criticality (i.e.,
the most time critical actions are in the
front of the procedure) to ensure that the
actions are taken within the analyzed
time required in the safe shutdown
analysis.
With regard to staffing and
demonstrations, the licensee stated that
three qualified operators are available to
perform the manual action at all times
and that demonstrations were
performed in the TMI–1 plant simulator
and in the plant by operator walk downs
to show that the OMAs can be
performed within the times as described
in the safe shutdown analysis.
3.4.2
Feasibility
The licensee’s analysis demonstrates
that, for the expected scenario, the
OMAs can be diagnosed and executed
in 19 minutes while the time available
to complete them is 40 minutes. The
licensee stated that the 40-minute time
limit itself is a conservative measure
since recent testing on the MU–V–20
backup air supply demonstrated that
MU–V–20 would only stay open for
approximately 75 minutes. The
licensee’s analysis also demonstrates
that various factors, as discussed above,
have been considered to address
uncertainties in estimating the time
available. Therefore, the OMA included
in this review is feasible because there
is adequate time available for the
operator to perform the required manual
actions to achieve and maintain hot
shutdown following a fire in Fire Zone
AB–FZ–6.
3.4.3
Reliability
The stated completion time of 19
minutes provides reasonable assurance
that the OMA can reliably be performed
under a wide range of conceivable
conditions by different plant crews
because it, in conjunction with the 21minute margin and other installed fire
protection features, accounts for sources
of uncertainty such as variations in fire
and plant conditions, factors unable to
be recreated in demonstrations and
human-centered factors. Therefore, the
OMA included in this review is reliable
because there is adequate time available
to account for uncertainties not only in
estimates of the time available, but also
in estimates of how long it takes to
diagnose a fire and execute the OMAs
(e.g., as based, at least in part, on a plant
demonstration of the actions under
nonfire conditions).
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38849
3.5 Defense-In-Depth Summary
In summary, the defense-in-depth
concept for a fire in Fire Zone AB–FZ–
6 provides a level of safety that results
in the unlikely occurrence of fires; rapid
detection, control, and extinguishment
of fires that do occur; and the protection
of structures, systems, and components
important to safety. As discussed above,
in the unlikely event of a fire that
challenges safe shutdown capability, the
licensee has provided preventative and
protective measures in addition to a
feasible and reliable OMA that together
demonstrate the licensee’s ability to
preserve or maintain safe shutdown
capability at TMI–1 in the event of a fire
in Fire Zone AB–FZ–6.
3.6 Authorized by Law
This exemption would allow TMI–1
to utilize an OMA, in conjunction with
the other installed fire protection
features, to ensure that at least one
means of achieving and maintaining hot
shutdown remains available during and
following a postulated fire event, as part
of its fire protection program, in lieu of
meeting the circuit separation and/or
protection requirements specified in
III.G.2 for a fire in Fire Zone AB–FZ–6.
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.
Therefore, the exemption is authorized
by law.
3.7 No Undue Risk to Public Health
and Safety
The underlying purpose of 10 CFR
part 50, appendix R, section III.G is to
ensure that at least one means of
achieving and maintaining hot
shutdown remains available during and
following a postulated fire event.
Because the use of the specific OMA, in
conjunction with the other installed fire
protection features, only impacts the
response to the specific Fire Zone AB–
FZ–6 scenario described above, the
probability of postulated accidents is
not increased. Also, based on the above,
the consequences of postulated
accidents are not increased. Therefore,
there is no undue risk to public health
and safety.
3.8 Consistent With Common Defense
and Security
The proposed exemption would allow
TMI–1 to utilize a specific OMA, in
conjunction with the other installed fire
protection features, in response to a fire
in Fire Zone AB–FZ–6 in lieu of
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meeting the requirements specified in
III.G.2. This change, to the operation of
the plant, has no relation to security
issues. Therefore, the common defense
and security is not diminished by this
exemption.
3.9 Special Circumstances
Special circumstances in accordance
with 10 CFR 50.12(a)(2)(ii) are present
whenever application of the regulation
in the particular circumstances is not
necessary to achieve the underlying
purpose of the rule. The underlying
purpose of 10 CFR Part 50, Appendix R,
Section III.G is to ensure that at least
one means of achieving and maintaining
hot shutdown remains available during
and following a postulated fire event.
Therefore, since the underlying purpose
of Appendix R, Section III.G is
achieved, the special circumstances for
granting an exemption from 10 CFR Part
50, Appendix R, Section III.G exist, as
required by 10 CFR 50.12(a)(2)(ii).
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. 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 TMI–1 for the OMA
discussed above.
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 (75 FR 36700).
This exemption is effective upon
issuance.
Dated at Rockville, Maryland, this 28th day
of June 2010.
For The Nuclear Regulatory Commission.
Joseph G. Giitter,
Director, Division of Operating Reactor
Licensing, Office of Nuclear Reactor
Regulation.
[FR Doc. 2010–16352 Filed 7–2–10; 8:45 am]
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BILLING CODE 7590–01–P
OFFICE OF SCIENCE AND
TECHNOLOGY POLICY
NNI Strategic Plan 2010; Request for
Information
ACTION:
Notice.
SUMMARY: The purpose of this RFI is to
enhance the value of the National
Nanotechnology Initiative (NNI) by
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14:52 Jul 02, 2010
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reaching out to the nanotechnology
stakeholder community for specific
input for the next NNI Strategic Plan to
be published in December 2010. This
RFI refers to the NNI Goals identified
from the 2007 Strategic Plan (https://
www.nano.gov/
NNI_Strategic_Plan_2007.pdf) as a
starting point for questions covering
themes such as research priorities,
investment, coordination, partnerships,
evaluation, and policy.
RFI Response Instructions: The White
House Office of Science and Technology
Policy is interested in responses that
address one or more of the following
Questions below that are broadly
categorized under Goals and Objectives;
Research Priorities; Investment;
Coordination and Partnerships;
Evaluation; and Policy as related to the
NNI. When submitting your response,
please indicate: (1) The question(s) you
are answering, and (2) which of the four
NNI goals to which it applies. Please be
specific and concise.
Responses to this RFI should be
submitted by 11:59 p.m. Eastern Time
on August 15, 2010. (Submissions prior
to the July 13–14, 2010 ‘‘NNI Strategic
Plan Stakeholder Workshop’’ (https://
www.nano.gov/html/meetings/
NNISPWorkshop/) may also
inform dialogues at this event.)
Responses to this RFI must be delivered
electronically in the body of or as an
attachment to an e-mail sent to
NNIStrategy@ostp.gov. Additionally,
OSTP intends to stage an online public
comment event July 13–August 15, 2010
to solicit input on the NNI Strategic
Plan. For details on this online event,
see https://www.whitehouse.gov/ostp/
NNIStrategy/.
Responses to this notice are not offers
and cannot be accepted by the
Government to form a binding contract
or issue a grant. Information obtained as
a result of this RFI may be used by the
government for program planning on a
non-attribution basis. Do not include
any information that might be
considered proprietary or confidential.
Background Information
What is the NNI? The National
Nanotechnology Initiative (NNI) is a
U.S. Government research and
development (R&D) program of 25
agencies working together toward the
common challenging vision of a future
in which the ability to understand and
control matter at the nanoscale leads to
a revolution in technology and industry
that benefits society. The combined,
coordinated efforts of these agencies
have accelerated discovery,
development, and deployment of
nanotechnology towards agency
PO 00000
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missions and the broader national
interest. Established in 2001, the NNI
involves nanotechnology-related
activities by the 25 member agencies, 15
of which have budgets for
nanotechnology R&D for 2011.
The NNI is managed within the
framework of the National Science and
Technology Council (NSTC), the
Cabinet-level council by which the
President coordinates science and
technology across the Federal
Government and interfaces with other
sectors. The Nanoscale Science,
Engineering, and Technology (NSET)
Subcommittee of the NSTC coordinates
planning, budgeting, program
implementation, and review of the NNI.
The NSET Subcommittee is composed
of senior representatives from agencies
participating in the NNI (https://
www.nano.gov).
NNI Goals: The December 2007 NNI
Strategic Plan (https://www.nano.gov/
NNI_Strategic_Plan_2007.pdf) specifies
four overarching, crosscutting goals
towards achieving the overall vision of
the NNI:
Goal 1: Advance a world-class
nanotechnology research and
development program. The NNI ensures
United States leadership in
nanotechnology research and
development by stimulating discovery
and innovation. This program expands
the boundaries of knowledge and
develops technologies through a
comprehensive program of research and
development. The NNI agencies invest
at the frontiers and intersections of
many disciplines, including biology,
chemistry, engineering, materials
science, and physics. The interest in
nanotechnology arises from its potential
to significantly impact numerous fields,
including aerospace, agriculture, energy,
the environment, healthcare,
information technology, homeland
security, national defense, and
transportation systems.
Goal 2: Foster the transfer of new
technologies into products for
commercial and public benefit.
Nanotechnology contributes to United
States competitiveness by improving
existing products and processes and by
creating new ones. The NNI implements
strategies that maximize the economic
benefits of its investments in
nanotechnology, based on
understanding the fundamental science
and responsibly translating this
knowledge into practical applications.
Goal 3: Develop and sustain
educational resources, a skilled
workforce, and the supporting
infrastructure and tools to advance
nanotechnology. A skilled science and
engineering workforce, leading-edge
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]]>Agencies
[Federal Register Volume 75, Number 128 (Tuesday, July 6, 2010)]
[Notices]
[Pages 38845-38850]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-16352]
=======================================================================
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
[Docket No. 50-289; NRC-2010-0221]
Exelon Generation Company, LLC; Three Mile Island Nuclear
Station, Unit No. 1; Exemption
1.0 Background
Exelon Generation Company, LLC (Exelon, the licensee) is the holder
of Facility Operating License No. DPR-50 which authorizes operation of
the Three Mile Island Nuclear Station, Unit 1 (TMI-1). The license
provides, 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 a pressurized-water reactor (PWR) located
in Dauphin County, 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.'' TMI-1 was licensed to operate prior to January 1, 1979.
As
[[Page 38846]]
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.
TMI-1 proposes to utilize an operator manual action (OMA) in lieu
of meeting the circuit separation and/or protection requirements
contained in 10 CFR part 50, appendix R, section III.G.2 (III.G.2),
which requires ensuring that one of the redundant trains of systems
necessary to achieve and maintain hot shutdown is maintained free of
fire damage. In this case, the OMA is proposed for a fire occurring in
Fire Zone 6 of the plant's Auxiliary Building (AB-FZ-6). The prescribed
action involves opening a breaker and manually opening valve MU-V-36
within 40 minutes to support maintaining a makeup pump minimum
recirculation path. By letter dated December 30, 1986 (ADAMS Legacy
Library Accession No. 8701090216), this OMA was previously approved by
the NRC; however, the time requirement has been shortened,
necessitating this exemption.
In summary, by letter dated March 3, 2009 (Agencywide Documents
Access and Management System (ADAMS) Accession No. ML090630134), as
supplemented by letter dated March 15, 2010 (ADAMS Accession No.
ML100750093), Exelon requested an exemption for TMI-1 from certain
technical requirements of III.G.2 for the use of an OMA in lieu of
meeting the circuit separation and/or protection requirements contained
in III.G.2 for AB-FZ-6.
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. These circumstances include
the special circumstances that the application of the regulation is not
necessary to achieve the underlying purpose of the rule.
In its March 15, 2010, letter, the licensee discussed financial
implications associated with plant modifications that may be necessary
to comply with the regulation. If such costs have been shown to be
significantly in excess of those contemplated at the time the
regulation was adopted, or are significantly in excess of those
incurred by others similarly situated, this may be considered a basis
for considering an exemption request. However, financial implications
were not considered in the regulatory review of their request since no
substantiation was provided regarding such financial implications. Even
though no financial substantiation was provided, the licensee did
submit sufficient regulatory basis to support a technical review of
their exemption request in that the application of the regulation in
this particular circumstance is not necessary to achieve the underlying
purpose of the rule.
In accordance with 10 CFR 50.48(b), nuclear power plants licensed
before January 1, 1979, are required to meet section III.G, of 10 CFR
part 50, appendix R. The underlying purpose of 10 CFR part 50, appendix
R, section III.G is to ensure that the ability to achieve and maintain
safe shutdown is preserved following a fire event. The regulation
intends for licensees to accomplish this by extending the concept of
defense-in-depth to:
(1) Prevent fires from starting;
(2) Rapidly detect, control, and extinguish promptly those fires
that do occur;
(3) 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 stated purpose of 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 requires one of 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:
(1) Separation of cables and equipment by a fire barrier having a
3-hour rating;
(2) 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
(3) 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 has requested an exemption from the requirements of III.G.2
for TMI-1 to the extent that one of the redundant trains of systems
necessary to achieve and maintain hot shutdown is not maintained free
of fire damage in accordance with one of the required means, for a fire
occurring in Fire Zone AB-FZ-6 in the Auxiliary Building. In its March
15, 2010, response to the NRC's request for additional information, the
licensee stated that the purpose of its request was to credit the use
of an OMA, in conjunction with other forms of defense-in-depth, in lieu
of the separation and protective measures required by III.G.2 for a
fire in Fire Zone AB-FZ-6. Specifically, Fire Zone AB-FZ-6 is not
protected throughout by an automatic fire suppression system and rated
fire barriers or 20 feet of spatial separation are not provided between
the redundant equipment. The OMA entails locally opening a feeder
breaker (1P 480V Switchgear Unit 4C) located in Fire Zone CB-FA-2a and
a valve (MU-V-36), which is located in Fire Zone AB-FZ-3, to establish
a makeup pump recirculation flow path.
In summary, TMI-1 does not meet the requirements of III.G.2 for a
fire in Fire Zone AB-FZ-6 and an OMA may be necessary to achieve and
maintain hot shutdown capability. The licensee also indicated that the
only credible scenario for a fire in Fire Zone AB-FZ-6 that may require
the need to manually open valve MU-V-36 is as follows: the fire must
initiate within the MU-V-36 breaker compartment of the 1A Engineered
Safeguards Valve (ESV) motor control center (MCC), cause a fault on an
energized circuit to make MU-V-36 close, cause power failure of the 1A
ESV MCC, spread to and damage the instrument air tubing causing valves
MU-V-18 and MU-V-20 to close, and cause failure of the 1B ESV MCC power
circuit, which is contained within a 4-inch galvanized steel conduit.
See Section 3.3 below for additional details addressing the spatial
separation between cables and instrument air tubing. In addition, the
TMI-1 analysis assumes that fire damage may occur immediately upon
first detection of the fire to all components in the fire area. The
licensee stated that after confirmation of a fire, the fire abnormal
operating procedure (AOP) for Fire Zone AB-FZ-6 would be entered.
The licensee has described in its initial request, and subsequent
documents, elements of the fire protection program that provide
justification that the concept of defense-in-depth that is in place in
Fire Zone AB-FZ-6 is consistent with that intended by the regulation.
To accomplish this, the licensee provides various forms of protection
in order to maintain the concept of defense-in-
[[Page 38847]]
depth. The licensee's approach is discussed below.
3.1 Fire Prevention
The licensee has stated that it has an administrative controls
program in place to control ignition sources, hot work activities
(activities such as welding or grinding), in situ and transient
combustibles, and fire system impairments. The administrative controls
program is described in the TMI-1 Updated Final Safety Analysis Report
(UFSAR) and in the Fire Hazards Analysis Report (FHAR), which is
incorporated by reference into the UFSAR. Transient combustibles are
restricted in Fire Zone AB-FZ-6 and particularly in the 1A ESV MCC
area.
In addition to these measures, the licensee has stated that the
power and control cables with voltages up to 480V AC and 480/120V in
the fire zone are thermoset (Kerite with ethylene propylene rubber
(EPR) insulation). Thermoset cables are resistant to self-ignited cable
fires and are not considered to represent an ignition source. Other
ignition sources in the area consist of control power transformers
inside the 1A ESV MCC. The licensee also stated that the transformers
are contained within the metal-clad MCC housing and contain no
combustible or flammable liquids and that the control cables are
located in open trays while the 480V power cables are in conduit or use
armor jacketed cable. Therefore, due to limited ignition sources and
the cables installed in conduit and armored jacketed cables, flame
propagation is not expected to present a hazard.
3.2 Detection, Control and Extinguishment
Fire Zone AB-FZ-6 is provided with a ceiling-mounted photoelectric
smoke detection system, which is connected to the Auxiliary Building
fire detection panel, located near the 1A ESV MCC. The licensee has
indicated that if smoke is detected, a local horn and strobe light are
actuated at the fire alarm panel as well as in the control room. There
are two smoke detectors located within a few feet horizontally and
approximately 13 feet vertically above the 1A ESV MCC. The smoke
detection system is designed and installed in accordance with National
Fire Protection Association (NFPA) 72D (1975), ``Proprietary Protective
Signaling Systems for Guard, Fire Alarm and Supervisory Service,'' and
NFPA 72E (1978), ``Automatic Fire Detectors.''
A hose reel, with at least 100 feet of hose, is provided in
adjacent Fire Zone AB-FZ-9. The hose reel is less than 100 feet from
the 1A ESV MCC area or any other area in Fire Zone AB-FZ-6. The hose
reels were designed and installed in accordance with NFPA 14 (1978),
``Standpipe and Hose Systems,'' and have electrically-safe fog nozzles
installed, which make them safe to use in the vicinity of electrical
equipment. Portable dry chemical and carbon dioxide fire extinguishers
are also permanently mounted in Fire Zone AB-FZ-6 and adjacent fire
zones. These extinguishers have been installed in accordance with NFPA
10, ``Standard for Portable Fire Extinguishers.'' The licensee stated
that all fire protection equipment is maintained in accordance with the
site FPP to ensure operability.
A water curtain is provided for fire protection of the zone
boundary between Fire Zones AB-FZ-6 and AB-FZ-7. The pre-action water
curtain system between Fire Zones AB-FZ-6 and AB-FZ-7 is actuated by
the cross-zone smoke detection system but is not credited for fire
suppression within Fire Zone AB-FZ-6. The water curtain is only
provided for fire protection of the zone boundary between Fire Zones
AB-FZ-6 and AB-FZ-7 and all other openings are sealed with material
having at least a 1-hour fire rating.
The remaining zone boundaries consist of reinforced concrete walls,
floors and ceilings. The south boundary and portion of the ceiling are
not adjacent to any other plant areas. The remainder of the ceiling
adjacent to the chemical addition area and Emergency Safeguards
Features (ESF) Ventilation Room is a 3-hour fire barrier. Most of the
north boundary is adjacent to Fire Zone AB-FZ-7 with an open passage,
discussed above, between the zones. The remainder of the north boundary
is adjacent to the Reactor Building, which is a 3-hour rated fire
barrier. The east boundary is adjacent to Fire Zones FH-FZ-1 and FH-FZ-
2 and is made of reinforced concrete. A 3-hour rated fire barrier is
provided on the floor where this zone is adjacent to Fire Zones AB-FZ-
2a, AB-FZ-2b and AB-FZ-2c. An automatic pre-action system is located in
Fire Zone AB-FZ-4 where the floor of Fire Zone AB-FZ-6 is adjacent to
Fire Zone AB-FZ-4.
3.3 Preservation of Safe Shutdown Capability
The licensee has stated that the postulated fire event that may
require the OMA to open MU-V-36 would include at least four independent
failures to occur; two of which are sequence dependent (i.e., MU-V-36
hot short occurs prior to loss of MCC) as described below:
While 1A ESV MCC is energized, the fire causes a hot short
(within 1A ESV MCC), which establishes proper voltage in the closing
circuit and causes MU-V-36 to travel closed (MU-V-36 control cable
CQ232A).
After MU-V-36 is closed, the fire causes loss of 1A ESV
MCC (cable LP8 within MCC), which is located in the fire zone. This
eliminates remote control of MU-V-16A and MU-V-16B and would isolate
the `A' train emergency makeup (High Pressure Injection [HPI]) flow
path (valves normally closed).
The fire causes a loss of integrity of the \1/4\-inch
outside diameter copper tubing which causes a sufficient reduction in
the Auxiliary Building instrument air supply pressure for MU-V-18 to
close and eventually for MU-V-20 to close. Loss of control of MU-V-18
eliminates the use of the normal Reactor Coolant System (RCS) makeup
flow path and depressurization of the MU-V-20 actuator would cause seal
injection flow to the RCP to be isolated.
Fire causes loss of power to 1B ESV MCC (cable LS7A). This
eliminates remote control of MU-V-16C and MU-V-16D and would eliminate
the `B' train emergency makeup (HPI) flow path as an alternate means of
RCS makeup (valves normally closed).
In order for a fire to cause MU-V-36 to close, the licensee has
indicated that `` * * * the fire must cause an intra-cable hot short
between a normally energized conductor in multi-conductor cable CQ232A
and the conductor that picks up the closing coil. This would short out
the remote control switch and energize the closing coil for MU-V-36.
The fire must maintain this hot short without grounding the circuit and
blowing the control power fuses or otherwise causing a loss of control
power, such as loss of the main 1A ESV MCC power cable LP8. The MU-V-36
circuits of concern are located within the MCC breaker compartment
along with the control power fuses. It is unlikely that a fire could
sufficiently damage cable CQ232A insulation and short the proper
conductors to energize the closing coil for MU-V-36 prior to blowing
the control power fuses. Because the fire must cause a hot short to
close MU-V-36 prior to loss of control power, the most likely fire
ignition location within Fire Zone AB-FZ-6 is in the MU-V-36 breaker
compartment. Fires in other areas of 1A ESV MCC would be likely to trip
the main bus breaker or otherwise damage the 1A ESV MCC power cable LP8
prior to affecting MU-V-36 circuits.''
Next, the licensee has indicated that ``[t]he primary combustible
in Fire Zone AB-FZ-6 is 1A ESV MCC and
[[Page 38848]]
associated cables * * * [t]he tubing closest to 1A ESV MCC is \1/4\-
inch outside diameter tubing used for testing reactor building pressure
switches. This tubing is at least 6 feet from the MCC with no
intervening combustibles. The loss of integrity of these \1/4\-inch
outside diameter tubing lines may not be sufficient to exceed the
capacity of the instrument air supply and reduce the instrument air
supply pressure to MU-V-18 (normal RCS makeup isolation valve) below 60
psig [pounds per square inch gauge]. Both instrument air compressors
are unaffected by a fire in Fire Zone AB-FZ-6 and would attempt to
maintain the instrument air supply to MU-V-18. The loss of instrument
air system integrity occurs in a section supplied through \3/8\-inch
regulators and \1/4\-inch outside diameter tubing. The main instrument
air system distribution headers are 2-inch lines. This specific failure
may not be sufficient to reduce the air supply pressure to MU-V-18
enough to prevent adequate RCS makeup flow. The next closest copper
tubing in Fire Zone AB-FZ-6 is against the containment wall. This
tubing is further separated from 1A ESV MCC by at least 10 feet of
distance with no intervening combustibles. Based on the existing
separation with no intervening combustibles and outside diameter of the
instrument air lines within Fire Zone AB-FZ-6, it is unlikely that a
fire in 1A ESV MCC would cause a loss of Auxiliary Building instrument
air pressure.''
The licensee further indicated that ``[t]he power cable for 1B ESV
MCC (LS7A) is routed through Fire Zone AB-FZ-6. The cable comes through
the 1-hour-rated wall (similar to UL-tested configuration U-410)
separating Fire Zones AB-FZ-6a and AB-FZ-6 in 4-inch galvanized steel
conduit as it passes through the area near 1A ESV MCC. As it turns away
from 1A ESV MCC (at least 6 feet of separation with no intervening
combustibles), it exits the conduit and enters a tray (via a splice
box). There is at least 12 feet of vertical separation with no
intervening combustibles between the top of 1A ESV MCC and the 4-inch
conduit that holds LS7A. Based on the existing separation and conduit
protection, it is unlikely that the 1B ESV MCC power cable would be
damaged, even if 1A ESV MCC were fully consumed in a fire.''
Additionally, the Auxiliary Building ventilation system is not
credited for smoke removal. If the primary safe shutdown (SSD) operator
becomes aware of smoke in the Auxiliary Building, the operator will don
a self-contained breathing apparatus (SCBA) to perform actions when
directed by the control room. Two SCBAs are staged near the primary
operator station on Auxiliary Building 305' elevation. All operators
assigned to fire brigade or SSD duties are qualified to use a SCBA.
Validation exercises have been performed to demonstrate that operators
can reliably don a SCBA in less than 3 minutes.
Given the lack of combustibles, separation of cables described
above, and the sequence of events required, it is unlikely that the OMA
to open MU-V-36 would be required. It is also likely that a fire would
be detected and suppressed before the sequence of events and failures
described above fully evolved. In the unlikely occurrence that the
sequence does fully evolve, the OMA is available to provide assurance
that safe shutdown can be achieved.
3.4 Feasibility and Reliability of the OMAs
This analysis postulates that the features described in Sections
3.1, 3.2 and 3.3, are not sufficient to assure safe shutdown
capability. The licensee has proposed an OMA to be performed in
addition to the above discussed fire protection features.
NUREG-1852, ``Demonstrating the Feasibility and Reliability of
Operator Manual Actions in Response to Fire,'' provides criteria and
associated technical bases for evaluating the feasibility and
reliability of post-fire OMAs in nuclear power plants. The following
provides the TMI-1 analysis of these criteria for justifying the OMA
specified in this request for Fire Zone AB-FZ-6.
3.4.1 Bases for Establishing Feasibility and Reliability
The licensee's analysis addresses factors such as environmental
concerns, equipment functionality and accessibility, available
indications, communications, portable equipment, personnel protection
equipment, procedures and training, staffing and demonstrations.
In their March 3, 2009, letter, and further supported by their
March 15, 2010, letter, the licensee stated that environmental
considerations such as radiological concerns, emergency lighting,
temperature and humidity conditions and smoke and toxic gases were
evaluated and found to not represent a negative impact on the
operators' abilities to complete the OMA. The licensee stated that
radiation levels expected during travel to or at the OMA location in
the Auxiliary Building are minimal with dose rates that would be less
than 10 millirem per hour. The licensee also confirmed that sufficient
emergency lighting exists at the areas where actions are performed and
along the travel routes to the areas. The licensee has stated that
operators also have access to 8-hour battery-powered portable lights,
as well. The licensee also has confirmed that temperature and humidity
conditions will not challenge the operators performing the OMA. The
licensee stated that radio and page communications are available for
this OMA. Additionally, the licensee indicated that heat and smoke or
gas generation from the fire will not impact the operator performing
the OMA. This is further supported by the fact that the location of the
postulated fire event is in a different fire zone than the locations
for where actions are performed.
The licensee stated that the functionality of equipment and cables
needed to perform the required OMA is documented in the OMA procedures,
which reflect equipment availability and provide specific direction
where functionality of equipment and cables may be compromised by fire.
In addition, in-plant OMA walk downs were performed and demonstrated
that the OMA equipment was accessible. The physical location of the
components where the OMA is to be performed is identified in the fire
AOPs and where components cannot be operated from the floor, installed
ladders or portable ladders are provided. Other than keys, portable
lighting, and portable ladders, the operators use no other additional
support equipment. The fire AOPs identify when a key is required to
perform the OMA. Keys required by operators are in the possession of
the operator and the specific key number required for the OMA is
identified in the fire AOP.
With regard to available indications, the licensee has stated that
available diagnostic instrumentation is listed in the fire AOP for each
fire area; however, instrumentation or indications are generally not
relied upon to perform the OMA. Explicit steps in the fire AOPs direct
the operators on how to perform the OMA such that one train of
available indications is always available for a fire in a given fire
area or zone. The licensee stated that the OMA does not require any
indication to support completion of the OMA; however, lack of
indication may be used to initiate an action and that successful
accomplishment of the OMA is directly observable by the operator
performing the OMA. The successful completion of the action is then
reported to the Control Room operators. Additionally, emergency
[[Page 38849]]
makeup flow indication is available for a fire in Fire Zone AB-FZ-6.
With regard to communications, the licensee stated that TMI-1 has
portable radio and installed phones available as part of the normal
plant communications available between the Control Room and the
operators and the radio and phone systems are robustly designed such
that they should be available following most fire scenarios. If the
various communication systems are not available, the method of
communication will be face-to-face or using radios via line-of-sight
(i.e., no repeaters). The licensee simulated face-to-face communication
was simulated by having operators start the manual action from directly
outside the Control Room. Task completion is normally reported by
portable hand held radio or installed phones but may also be reported
by face-to-face communication if plant communication systems are not
available. The General Announcing System, Operations Radio System,
Plant Telephone System, Sound Powered Phone System, and Face-to-Face
Communications are all available to Control Room operators and
operators performing OMAs.
The licensee stated that operators performing the OMA are provided
with standard personal protective equipment (PPE), including hardhat,
gloves, and protective glasses. In the unlikely event that smoke
conditions would require SCBAs to be worn, the plant equipment
operators are qualified to wear SCBAs and the SCBAs are staged at
strategic locations in the plant with additional SCBAs in the fire
brigade locker.
The licensee stated that fire AOPs have been developed for each
fire area or zone and that the fire AOPs are staged in certain
strategic locations that are easily accessible to the operators. The
individual procedures are presented in a standardized procedure format
that the operators are familiar with. The fire AOPs contain both
preventive actions to prevent potential adverse fire effects, as well
as reactive actions to direct timely action if a fire causes a
particular adverse condition (i.e., valve spuriously opens or closes).
The procedures for individual fire areas are used in conjunction with
the symptom-based (reactive) Emergency Operating Procedures (EOPs) and
other symptom-based AOPs to provide a combined preventive (fire AOPs)
and reactive (EOPs and all AOPs, including fire) approach to achieve
safe shutdown following a fire. The individual fire area shutdown
procedures provide the operators with information as to the available
equipment (including instrumentation) that can be relied upon following
a fire. The fire AOP procedures provide specific guidance to the
operators as to what equipment could be affected by the fire and are
written in order of time criticality (i.e., the most time critical
actions are in the front of the procedure) to ensure that the actions
are taken within the analyzed time required in the safe shutdown
analysis.
With regard to staffing and demonstrations, the licensee stated
that three qualified operators are available to perform the manual
action at all times and that demonstrations were performed in the TMI-1
plant simulator and in the plant by operator walk downs to show that
the OMAs can be performed within the times as described in the safe
shutdown analysis.
3.4.2 Feasibility
The licensee's analysis demonstrates that, for the expected
scenario, the OMAs can be diagnosed and executed in 19 minutes while
the time available to complete them is 40 minutes. The licensee stated
that the 40-minute time limit itself is a conservative measure since
recent testing on the MU-V-20 backup air supply demonstrated that MU-V-
20 would only stay open for approximately 75 minutes. The licensee's
analysis also demonstrates that various factors, as discussed above,
have been considered to address uncertainties in estimating the time
available. Therefore, the OMA included in this review is feasible
because there is adequate time available for the operator to perform
the required manual actions to achieve and maintain hot shutdown
following a fire in Fire Zone AB-FZ-6.
3.4.3 Reliability
The stated completion time of 19 minutes provides reasonable
assurance that the OMA can reliably be performed under a wide range of
conceivable conditions by different plant crews because it, in
conjunction with the 21-minute margin and other installed fire
protection features, accounts for sources of uncertainty such as
variations in fire and plant conditions, factors unable to be recreated
in demonstrations and human-centered factors. Therefore, the OMA
included in this review is reliable because there is adequate time
available to account for uncertainties not only in estimates of the
time available, but also in estimates of how long it takes to diagnose
a fire and execute the OMAs (e.g., as based, at least in part, on a
plant demonstration of the actions under nonfire conditions).
3.5 Defense-In-Depth Summary
In summary, the defense-in-depth concept for a fire in Fire Zone
AB-FZ-6 provides a level of safety that results in the unlikely
occurrence of fires; rapid detection, control, and extinguishment of
fires that do occur; and the protection of structures, systems, and
components important to safety. As discussed above, in the unlikely
event of a fire that challenges safe shutdown capability, the licensee
has provided preventative and protective measures in addition to a
feasible and reliable OMA that together demonstrate the licensee's
ability to preserve or maintain safe shutdown capability at TMI-1 in
the event of a fire in Fire Zone AB-FZ-6.
3.6 Authorized by Law
This exemption would allow TMI-1 to utilize an OMA, in conjunction
with the other installed fire protection features, to ensure that at
least one means of achieving and maintaining hot shutdown remains
available during and following a postulated fire event, as part of its
fire protection program, in lieu of meeting the circuit separation and/
or protection requirements specified in III.G.2 for a fire in Fire Zone
AB-FZ-6. 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. Therefore, the exemption is authorized by
law.
3.7 No Undue Risk to Public Health and Safety
The underlying purpose of 10 CFR part 50, appendix R, section III.G
is to ensure that at least one means of achieving and maintaining hot
shutdown remains available during and following a postulated fire
event. Because the use of the specific OMA, in conjunction with the
other installed fire protection features, only impacts the response to
the specific Fire Zone AB-FZ-6 scenario described above, the
probability of postulated accidents is not increased. Also, based on
the above, the consequences of postulated accidents are not increased.
Therefore, there is no undue risk to public health and safety.
3.8 Consistent With Common Defense and Security
The proposed exemption would allow TMI-1 to utilize a specific OMA,
in conjunction with the other installed fire protection features, in
response to a fire in Fire Zone AB-FZ-6 in lieu of
[[Page 38850]]
meeting the requirements specified in III.G.2. This change, to the
operation of the plant, has no relation to security issues. Therefore,
the common defense and security is not diminished by this exemption.
3.9 Special Circumstances
Special circumstances in accordance with 10 CFR 50.12(a)(2)(ii) are
present whenever application of the regulation in the particular
circumstances is not necessary to achieve the underlying purpose of the
rule. The underlying purpose of 10 CFR Part 50, Appendix R, Section
III.G is to ensure that at least one means of achieving and maintaining
hot shutdown remains available during and following a postulated fire
event. Therefore, since the underlying purpose of Appendix R, Section
III.G is achieved, the special circumstances for granting an exemption
from 10 CFR Part 50, Appendix R, Section III.G exist, as required by 10
CFR 50.12(a)(2)(ii).
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.
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
TMI-1 for the OMA discussed above.
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 (75 FR 36700).
This exemption is effective upon issuance.
Dated at Rockville, Maryland, this 28th day of June 2010.
For The Nuclear Regulatory Commission.
Joseph G. Giitter,
Director, Division of Operating Reactor Licensing, Office of Nuclear
Reactor Regulation.
[FR Doc. 2010-16352 Filed 7-2-10; 8:45 am]
BILLING CODE 7590-01-P
