Exelon Generation Company, LLC, Oyster Creek Nuclear Generating Station; Exemption, 19488-19510 [2011-8318]
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
feasible and reliable OMAs that together
demonstrate the licensee’s ability to
preserve or maintain safe shutdown
capability in the event of a fire in the
analyzed fire areas.
Authorized by Law
This exemption would allow PBAPS
to rely on OMAs, 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 FPP, in lieu of meeting the
requirements specified in III.G.2 for a
fire in the analyzed fire areas. 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 this
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.
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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. Based
on the above, no new accident
precursors are created by the use of the
specific OMAs, in conjunction with the
other installed fire protection features,
in response to a fire in the analyzed fire
areas. Thus, 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.
Consistent with Common Defense and
Security
The proposed exemption would allow
PBAPS to credit the use of the specific
OMAs, in conjunction with the other
installed fire protection features, in
response to a fire in the analyzed fire
areas, discussed above, in lieu of
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.
Special Circumstances
Pursuant to 10 CFR 50.12(a)(2)(ii)
special circumstances are present
whenever application of the regulation
in the particular circumstances is not
necessary to achieve the underlying
purpose of the rule. The underlying
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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 utilize the OMAs discussed
above at PBAPS.
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 58445).
This exemption is effective upon
issuance.
Dated at Rockville, Maryland, this 30th day
of March 2011.
For The Nuclear Regulatory Commission.
Joseph G. Giitter,
Director, Division of Operating Reactor
Licensing, Office of Nuclear Reactor
Regulation.
[FR Doc. 2011–8317 Filed 4–6–11; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
[Docket No. 50–219; NRC–2010–0200]
Exelon Generation Company, LLC,
Oyster Creek Nuclear Generating
Station; Exemption
1.0
Background
Exelon Generation Company, LLC
(Exelon or the licensee) is the holder of
Facility Operating License No. DPR–16
that authorizes operation of the Oyster
Creek Nuclear Generating Station
(Oyster Creek). 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 or the Commission)
now or hereafter in effect.
The facility consists of a boiling-water
reactor located in Ocean County, New
Jersey.
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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.’’ Oyster Creek was licensed
to operate prior to January 1, 1979. As
such, the licensee’s Fire Protection
Program must provide the established
level of protection as intended by
Section III.G of 10 CFR Part 50,
Appendix R.
By letter dated March 4, 2009,
‘‘Request for Exemption from 10 CFR 50,
Appendix R, Section III.G, ‘Fire
Protection of Safe Shutdown Capability
(Phase 2)’ ’’ available at Agencywide
Documents Access and Management
System (ADAMS), Accession No.
ML090640225, and supplemented by
letter dated April 2, 2010, ‘‘Response to
Request for Additional Information
Request for Exemption from 10 CFR Part
50, Appendix R, Section III.G, ‘Fire
Protection of Safe Shutdown
Capability’ ’’ (ADAMS Accession No.
ML100920370), the licensee requested
an exemption for Oyster Creek from
certain technical requirements of 10
CFR Part 50, Appendix R, Section III.G.2
(III.G.2) for the use of operator manual
actions (OMAs) in lieu of meeting the
circuit separation and protection
requirements contained in III.G.2 for the
following 22 plant areas: CW–FA–14,
OB–FA–9, OB–FZ–6A, OB–FZ–6B, OB–
FZ–8A, OB–FZ–8B, OB–FZ–8C, OB–
FZ–10A, RB–FZ–1D, RB–FZ–1E, RB–
FZ–1F3, RB–FZ–1F5, RB–FZ–1G, TB–
FA–3A, TB–FA–26, TB–FZ–11B, TB–
FZ–11C, TB–FZ–11D, TB–FZ–11E, TB–
FZ–11F, TB–FZ–11H, and Yard. The 22
plant areas noted above are the subject
of this exemption.
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. The licensee
has stated that special circumstances are
present in that the application of the
regulation in this particular
circumstance is not necessary to achieve
the underlying purpose of the rule,
which is consistent with the language
included in 10 CFR 50.12(a)(2)(ii).
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
In their March 4, 2009, and April 2,
2010, letters, the licensee discussed
financial implications associated with
plant modifications that may be
necessary to comply with the regulation.
Section 50.12(a)2(iii) of 10 CFR states
that 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
Section III.G of 10 CFR Part 50,
Appendix R, 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 10 CFR Part 50,
Appendix R, Section III.G.2 (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:
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 has requested an exemption
from the requirements of III.G.2 for
Oyster Creek to the extent that
redundant trains of systems necessary to
achieve and maintain hot shutdown are
not maintained free of fire damage in
accordance with one of the required
means prescribed in III.G.2.
Each OMA included in this review
consists of a sequence of tasks that
occur in various fire areas. The OMAs
are initiated upon confirmation of a fire
in a particular fire area. Table 1 lists, in
the order of the fire area of fire origin,
the OMAs included in this review.
TABLE 1
Area name
1 ..........
CW–FA–14 ............
Circulatory Water Intake .................
2 ..........
OB–FA–9 ...............
Office Building (Bldg.) Elev. 23′-6″,
35′-0″, 46′-6″.
3 ..........
OB–FZ–6A .............
Office Bldg. ‘‘A’’ 480V Switchgear
(SWGR) Room Elev. 23′-6″.
4 ..........
OB–FZ–6B .............
Office Bldg. ‘‘B’’ 480V SWGR Room
Elev. 23′-6″.
5 ..........
OB–FZ–8A .............
6 ..........
OB–FZ–8B .............
Office Bldg. Reactor Recirculation
Motor Generator (MG) Set Room
Elev. 23′-6″.
Office Bldg. Mechanical Equipment
Room Elev. 35′-0″.
7 ..........
OB–FZ–8C ............
8 ..........
OB–FZ–10A ...........
9 ..........
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Area of fire origin
RB–FZ–1D .............
Office Bldg. A/B Battery Room,
Tunnel and Electrical Tray Room
Elev. 35′-0″.
Office Bldg. Monitor and Change
Room Area and Operations Support Area Elev. 35′-0″ & 46′-6″.
Reactor Bldg. Elev. 51′-3″ ..............
10 ........
RB–FZ–1E .............
Reactor Building Elev. 23′-6″ ..........
11 ........
RB–FZ–1F3 ...........
Reactor Bldg. Northwest Corner
Elev.-19′-6″.
12 ........
RB–FZ–1F5 ...........
Reactor Bldg. Torus Room Elev.
-19′-6″.
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Actions
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–36
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–36
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
Provide makeup control air to the accumulator for V–11–34
the Isolation Condenser makeup line due to the loss of
strument air.
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TABLE 1—Continued
Area of fire origin
Area name
Actions
13 ........
RB–FZ–1G ............
Reactor Bldg. Shutdown Cooling
Room Elev. 38′-0″ & 51′-3″.
14 ........
TB–FA–3A .............
Turbine Bldg. 4160V Emergency
SWGR Vault 1C Elev. 23′-6″.
15 ........
TB–FA–26 .............
Turbine Bldg. 125V DC Battery
Room C Elev. 23′-6″.
Provide makeup control air to the accumulator for V–11–34 for
the Isolation Condenser makeup line due to the loss of instrument air.
Provide makeup control air to the accumulator for V–11–34 for
the Isolation Condenser makeup line due to the loss of instrument air.
Trip Field Breakers for Recirculation Pumps MG Set so that the
Fuel Zone Level Indicators can be used.
Provide Fire Water to Isolation Condenser shell by operating
valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to
loss of power (contingency action).
Manually control 480V USS 1B2 Breakers for control rod drive
(CRD) Pump NC08B and 1B2M from Remote Shutdown
Panel due to control circuit damage.
Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).
Check Isolation Condenser Shell level locally due to loss of
power (contingency action).
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Manually control 480V Unit Substation (USS) 1B2 Breakers for
CRD Pump NC08B and 1B2M from Remote Shutdown Panel
due to control circuit damage.
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Trip Field Breakers for Recirculation Pumps MG Set so that the
Fuel Zone Level Indicators can be used.
Provide Fire Water to Isolation Condenser shell by operating
valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to
loss of power (contingency action).
Manually control 480V USS 1B2 Breakers for CRD Pump
NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.
Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).
Check Isolation Condenser Shell level locally due to loss of
power (contingency action).
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Trip Field Breakers for Recirculation Pumps MG Set so that the
Fuel Zone Level Indicators can be used.
Provide Fire Water to Isolation Condenser shell by operating
valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to
loss of power (contingency action).
Manually control 480V USS 1B2 Breakers for CRD Pump
NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.
Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).
Check Isolation Condenser Shell level locally due to loss of
power (contingency action).
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Manually control 480V USS 1B2 Breakers for CRD Pump
NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
Provide makeup control air to the accumulator for V–11–36 for
the Isolation Condenser makeup line due to the loss of instrument air.
16 ........
TB–FZ–11B ...........
Turbine Bldg. Lube Oil Storage, Purification and Pumping Area Elev.
0′-0″, 27′-0″, and 36′-0″.
.........
17 ........
18 ........
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19 ........
TB–FZ–11C ...........
TB–FZ–11D ...........
TB–FZ–11E ...........
Turbine Bldg. SWGR Room 1A and
1B Elev. 23′-6″.
Turbine Bldg. Basement
South End Elev. 3′-6″.
Floor
Turbine Bldg. Condenser Bay Area
Elev. 0′-0″.
20 ........
TB–FZ–11F ...........
Turbine Bldg. Feedwater
Room Elev. 0′-0″ & 3′-6″.
21 ........
TB–FZ–11H ...........
Turbine Bldg. Demineralizer Tank
and Steam Jet Air Ejector Area
Elev. 3′-6″ & 23′-6″.
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3
18
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TABLE 1—Continued
Area of fire origin
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22 ........
Area name
Actions
Yard .......................
Office Bldg. Roof, Turbine Bldg.
Roof, and All Remaining Outside
Areas.
Manually open V–15–237, throttle V–15–30 while monitoring
flow at FI–225–2 and close V–15–52 to establish CRD flow
to Reactor due to the loss of instrument air to the CRD Flow
Control Valve.
Provide makeup control air to the accumulator for V–11–34 for
the Isolation Condenser makeup line due to the loss of instrument air.
In their submittals the licensee
described elements of their fire
protection program that provide their
justification that the concept of defensein-depth that is in place in the above fire
areas is consistent with that intended by
the regulation. To accomplish this, the
licensee utilizes various protective
measures to accomplish the concept of
defense-in-depth. Specifically, the
licensee stated that the purpose of their
request was to credit the use of OMAs,
in conjunction with other defense-indepth features, in lieu of the separation
and protective measures required by
III.G.2 for a fire in the fire areas stated
above.
In their April 2, 2010, letter the
licensee provided an analysis that
described how fire prevention is
addressed for each of the fire areas for
which the OMAs may be required. The
licensee developed a Fire Hazards
Analysis (FHA) for each fire area or
zone identified in its exemption request.
For each fire area or zone, the FHA
describes the physical location and
arrangement of equipment, combustible
loading, ignition sources, fire protection
features, and proximity of redundant
safe shutdown equipment to in situ
hazards and identifies deviations from
fire protection codes and previously
approved exemptions. In addition, for
each fire area or zone, the licensee’s
response includes a tabulation of
potential ignition sources as well as the
equipment that may exhibit high energy
arcing faults. For each fire area or zone,
the FHA states that the fire protection
configuration achieves a level of
protection commensurate with that
intended by III.G.2.
The 22 areas or zones identified in the
request have administratively limited
combustible fuel loading with fuel
sources consisting primarily of cable
insulation and limited floor based
combustibles except areas OB–FZ–6A,
OB–FZ–6B, and TB–FZ–11B, which
contain quantities of transformer liquid
or lubricating oil. Combustible fuel
loading in most areas is classified as low
by the licensee while Fire Areas OB–
FZ–6A and OB–FZ–6B have been
classified as having a moderate
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combustible fuel loading and TB–FZ–
11B has been classified as having a high
combustible fuel loading. In addition,
the licensee has stated that they
maintain a robust administrative
program (e.g., hot work permits, fire
watches for hot work, and supervisory
controls) to limit and control transient
combustible materials and ignition
sources in the areas. The fire areas
included in the exemption are not shop
areas so hot work activities are
infrequent and the administrative
control programs are in place if hot
work activities do occur.
The licensee also stated that 98% of
the Oyster Creek cables are jacketed
with Vulkene, which passes the
horizontal flame test of the
Underwriter’s Laboratory, therefore
reducing the likelihood of the cables
themselves contributing to a fire hazard.
Furthermore, the areas or zones are of
noncombustible construction with
typical utilities installed lighting,
ventilation, etc., and 3-hour fire
resistance-rated barriers normally used
to provide fire resistive separation
between adjacent fire areas. In some
cases, barriers with a fire resistance
rating of less than 3 hours are credited,
but exemptions have been approved or
the licensee has stated they have
performed engineering evaluations in
accordance with Generic Letter 86–10 to
demonstrate that the barriers are
sufficient for the hazard. Walls
separating rooms and zones within fire
areas are typically constructed of heavy
concrete. This compartmentalization of
the areas reduces the likelihood for fire
events in a particular area to spread to
or impact other adjacent areas.
Many fire areas included in this
exemption have automatic detection
systems installed, although the licensee
indicated that not all systems are
installed in accordance with a
recognized standard with regard to
spacing in all areas. In such cases, the
licensee has stated that the detectors are
located near equipment such that they
are likely to detect a fire. Upon
detecting smoke, the detectors initiate
an alarm in the constantly staffed
control room. In addition to the
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17
automatic suppression systems noted
below, equipment operators are trained
fire brigade members and may identify
and manually suppress or extinguish a
fire using the portable fire extinguishers
and manual hose stations located
throughout the fire areas if a fire is
identified in its early stages of growth.
The licensee stated that the postulated
fire events that may require the use of
the OMAs would include multiple
failures of various components or
equipment. In most cases, it is
considered unlikely that the sequence of
events required to necessitate the OMAs
would fully evolve because of the fire
prevention, fire protection, and physical
separation features in place. However,
in the event that the sequence does
evolve, the OMAs are available to
provide assurance that safe shutdown
can be achieved. For each of the fire
areas included in this exemption, the
postulated fire scenarios and pertinent
details are summarized in Table 2
below.
Each of the fire areas or zones
included in this exemption is analyzed
below with regard to how the concept
of defense-in-depth is achieved for each
area or zone and the role of the OMAs
in the overall level of safety provided
for each area or zone.
3.1 CW–FA–14 Circulatory Water
Intake
3.1.1
Fire Prevention
The licensee stated that combustible
loading is not tracked in this area since
it is an outside area. The licensee also
stated that the primary combustible
materials in the area are transformer
liquid and electrical motors; although
the amount is not quantified since the
area is open to the atmosphere with no
walls or ceiling to contain the heat or
smoke that may be produced during a
fire event. Additionally, the main
combustible in this area that could
result in the need for the OMAs is Dow
Corning 561 Silicon transformer liquid,
which the licensee states has
characteristics that minimize the
likelihood of a fire involving the
insulating liquid itself.
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
3.1.2 Detection, Control, and
Extinguishment
CW–FA–14 is not equipped with
automatic fire detection or suppression
systems but since it is an outdoor area
with no walls or ceiling, it is not
expected that such systems would
enhance this element of defense-indepth in this area since the area is open
to the atmosphere with no walls or
ceiling to contain the heat or smoke that
may be produced during a fire event.
However, the licensee stated that a
security tower monitors this area
continuously. Therefore, any fire of
significance would likely be detected
and responded to appropriately by the
station fire brigade. Manual suppression
is also provided by a fire hydrant and
fire hose house located approximately
75 feet from the principal fire hazards.
3.1.3 Preservation of Safe Shutdown
Capability
Since Fire Area CW–FA–14 is an
outdoor space with no walls or ceiling,
smoke and heat would not accumulate
within the fire area to cause damage to
components remote to the initiating fire
or obstruct operator actions.
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3.1.4
Area
OMAs Credited for a Fire in This
3.1.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
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19:53 Apr 06, 2011
Jkt 223001
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the main steam
isolation valves (MSIVs) will close, as
well as multiple air-operated valves
changing state. Additionally, reactor
pressure vessel (RPV) level indication is
also available for all fire areas or zones.
All of these indications would help the
operator diagnose the loss of instrument
air and initiate mitigating procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.1.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and open nature of the area, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.2 OB–FA–9 Office Bldg. Elev. 23′-6″,
35′-0″, 46′-6″,
3.2.1
Fire Prevention
The licensee has classified the fire
loading in this fire area as low. The
licensee also stated that the major
combustibles in the multiplexer (MUX)
corridor, which is within OC–FA–9, are
cable insulation and a wood ceiling on
top of the MUX enclosure, which is
within the MUX corridor.
3.2.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FA–9 has
a partial area coverage wet pipe
sprinkler system installed. The licensee
further stated that the area is not
provided with a detection system but
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Fmt 4703
Sfmt 4703
that there is an installed detection
system in the main hallways and inside
of the MUX corridor and that it is a high
traffic area so a fire would likely be
detected by personnel. The wet pipe
sprinkler system, when actuated, will
alarm in the control room to notify
operators of a potential fire event.
Extinguishment of a fire in the majority
of this area will be accomplished by the
plant fire brigade.
3.2.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FA–9 has
a ceiling height of approximately 10′-6″,
and an approximate floor area of 513
square feet in the MUX corridor where
the safe shutdown equipment is located
so it is unlikely that smoke and heat
would accumulate at the height of the
safe shutdown equipment and cause a
failure due to fire damage.
3.2.4
Area
OMAs Credited for a Fire in this
3.2.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
E:\FR\FM\07APN1.SGM
07APN1
Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.2.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and volume of the space, it is unlikely
that a fire would occur and go
undetected or unsuppressed by the
sprinkler system noted above, or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.3 OB–FZ–6A Office Bldg. ‘‘A’’ 480V
Switchgear (SWGR) Room Elev. 23′-6″,
mstockstill on DSKH9S0YB1PROD with NOTICES
3.3.1
Fire Prevention
The licensee stated that the fire
loading in this zone is moderate and
that there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the main combustibles in this area are
cable insulation (approximately 81% of
loading) and Dow Corning 561 Silicon
transformer liquid (approximately 15%
of loading). The transformer liquid has
characteristics that minimize the
likelihood of a fire involving the
insulating liquid itself.
3.3.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FZ–6A
has an automatic smoke detection
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19:53 Apr 06, 2011
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system, a total flooding automatic Halon
1301 System, and manual fire fighting
capabilities (portable extinguishers and
hose stations).
3.3.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FA–6A
has a ceiling height of approximately
10′-8″, and an approximate floor area of
1157 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
3.3.4 OMAs Credited for a Fire in this
Zone
3.3.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
PO 00000
Frm 00187
Fmt 4703
Sfmt 4703
19493
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.3.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or Halon system noted
above, or personnel, and damage the
safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.4 OB–FZ–6B Office Building ‘‘B’’
480V SWGR Room Elev. 23′-6″,
3.4.1 Fire Prevention
The licensee stated that the fire
loading in this zone is moderate and
that there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the main combustibles in this area are
cable insulation (approximately 28% of
loading), Thermo-Lag (approximately
29% of loading) and Dow Corning 561
Silicon transformer liquid
(approximately 31% of loading). The
transformer liquid has characteristics
that minimize the likelihood of a fire
involving the insulating liquid itself.
3.4.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FZ–6B
has an automatic smoke detection
system, a total flooding Halon 1301
System, and manual fire fighting
capabilities (portable extinguishers and
hose stations).
3.4.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FA–6B
has a ceiling height of approximately
10′-8″ and an approximate floor area of
679 square feet so it is unlikely that
E:\FR\FM\07APN1.SGM
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
3.4.4 OMAs Credited for a Fire in This
Zone
mstockstill on DSKH9S0YB1PROD with NOTICES
3.4.4.1 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
VerDate Mar<15>2010
19:53 Apr 06, 2011
Jkt 223001
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
and heat would accumulate at the
height of the safe shutdown equipment
and cause a failure due to fire damage.
3.4.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or Halon system noted
above, or personnel, and damage the
safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #18
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.5.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
3.5 OB–FZ–8A Office Bldg. Reactor
Recirculation MG Set Room & OB–FZ–
8B Mechanical Equipment Room Elev.
23′-6″ & 35′-0″
3.5.1 Fire Prevention
Fire Zones OB–FZ–8A and 8B are
evaluated together for the combustible
loading and fire safe shutdown analysis.
The licensee stated that the fire loading
in this zone is low and that there is an
administrative controls program in
place to limit additional combustible
materials and sources of ignition. The
licensee also stated that there are
minimal combustibles in Fire Zone OB–
FZ–8B. The major combustibles in Fire
Zone OB–FZ–8A are lubricating oil
(approximately 83% of loading) and
cable insulation (approximately 13% of
loading).
3.5.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FZ–8A
has a partial wet-pipe sprinkler system
with a flow alarm that notifies the
control room and that the area does not
have a smoke detection system however,
a duct smoke detector is located in the
exhaust duct of fan EF–1–20. Since
operation of the sprinkler system will
alarm in the control room, prompt
notification of and response by, the fire
brigade for any required manual fire
fighting activities is expected.
3.5.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FZ–8A
has a ceiling height of approximately
10′-10″ and an approximate floor area of
2128 square feet and OB–FZ–8B has a
ceiling height of approximately 11′-0″
and an approximate floor area of 479
square feet so it is unlikely that smoke
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Fmt 4703
Sfmt 4703
3.5.4
Area
OMAs Credited for a Fire in This
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
E:\FR\FM\07APN1.SGM
07APN1
Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.5.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or sprinkler systems
noted above, or personnel, and damage
the safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment in this zone, combined with
the ability of OMA #17 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provides adequate assurance that safe
shutdown capability is maintained.
3.6 OB–FZ–8C Office Bldg. A/B Battery
Room, Tunnel and Electrical Tray Room
Elev. 35′-0″
3.6.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in Fire Zone
OB–FZ–8C are electrolyte-filled plastic
battery cases and racks (approximately
56% of loading) and cable insulation
(approximately 39% of loading).
3.6.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FZ–8C
has a fixed, total-flooding, Halon 1301
extinguishing system, area-wide smoke
detection that is installed at the ceiling
level and cross-zoned to sound a local
alarm, and an alarm in the control room
upon actuation of one detector.
Actuation of a second detector will
sound a local alarm, discharge the
Halon system, trip supply and exhaust
fans, and close dampers.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.6.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FZ–8C
has a ceiling height of approximately
11′-0″ and an approximate floor area of
1292 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
VerDate Mar<15>2010
19:53 Apr 06, 2011
Jkt 223001
3.6.4 OMAs Credited for a Fire in This
Zone
3.6.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
PO 00000
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Fmt 4703
Sfmt 4703
19495
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.6.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or Halon systems noted
above, or personnel, and damage the
safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.7 OB–FZ–10A Office Bldg. Monitor
and Change Room and Operations
Support Area Elev. 35′-0″ & 46′-6″
3.7.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
cable insulation (approximate 27% of
loading), rubber flooring (approximately
31% of loading), miscellaneous plastics
(approximately 17% of loading) and
protective clothing supplies
(approximately 20% of loading).
However, since the protective clothing
have been placed in metal cans with
self-closing lids they are no longer
considered a contribution to the
combustibles in this area.
3.7.2 Detection, Control, and
Extinguishment
The licensee stated that OB–FZ–10A
has an area-wide smoke detection
system and a wet-pipe automatic
sprinkler system installed throughout
the area. In addition, a hose station
located nearby, outside the control
room, provides manual suppression
capability.
3.7.3 Preservation of Safe Shutdown
Capability
The licensee stated that OB–FZ–10A
has a ceiling height of approximately
13′-0″ and an approximate floor area of
2019 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
E:\FR\FM\07APN1.SGM
07APN1
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mstockstill on DSKH9S0YB1PROD with NOTICES
3.7.4
Area
Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
OMAs Credited for a Fire in This
3.7.4.1 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 29
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minutes, while the time available is 300
minutes, which provides a 241-minute
margin.
3.7.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or sprinkler systems
noted above, or personnel, and damage
the safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #18
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.8 RB–FZ–1D Reactor Bldg. Elev.
51′-3″
3.8.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the main combustible in this area is
attributed to cable insulation
(approximately 84% of loading).
3.8.2 Detection, Control, and
Extinguishment
The licensee stated that RB–FZ–1D
has an area-wide smoke detection
system and an automatic fixed deluge
water spray system installed over cable
trays and open hatches. The deluge
suppression system protecting safety
related cable trays is automatically
activated by a cross-zoned detection
system consisting of linear heat
detection wire located on top of the
cables in each original safety related
cable tray and smoke detectors are
located in each beam pocket at the
ceiling.
3.8.3 Preservation of Safe Shutdown
Capability
The licensee stated that RB–FZ–1D
has a ceiling height of approximately
21′-0″ and an approximate floor area of
9,100 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
PO 00000
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Fmt 4703
Sfmt 4703
3.8.4
Area
OMAs Credited for a Fire in This
3.8.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
E:\FR\FM\07APN1.SGM
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
3.8.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or localized water
deluge systems noted above, or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.9
3″
RB–FZ–1E Reactor Bldg. Elev. 51′-
3.9.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the main combustible in this area is
attributed to cable insulation
(approximately 84% of loading).
3.9.2 Detection, Control, and
Extinguishment
The licensee stated that RB–FZ–1E
has an area-wide smoke detection
system and an automatic fixed deluge
water spray system installed over cable
trays and open hatches. The deluge
suppression system protecting safety
related cable trays is automatically
activated by a cross-zoned detection
system consisting of linear heat
detection wire located on top of the
cables in each original safety related
cable tray and smoke detectors are
located in each beam pocket at the
ceiling.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.9.3 Preservation of Safe Shutdown
Capability
The licensee stated that RB–FZ–1E
has a ceiling height of approximately
26′-9″ and an approximate floor area of
12,140 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
3.9.4 OMAs Credited for a Fire in This
Zone
3.9.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
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occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.9.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or localized water
deluge systems noted above, or
PO 00000
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Fmt 4703
Sfmt 4703
19497
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.10 RB–FZ–1F3 Reactor Bldg.
Northwest Corner Elev. -19′-6″
3.10.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
cable insulation (approximately 58% of
loading), ladders (approximately 16% of
loading) and lubricating oil in pumps
(approximately 16% of loading).
3.10.2 Detection, Control, and
Extinguishment
The licensee stated that RB–FZ–1F3
has smoke detectors which alarm locally
and in the control room installed over
hazards rather than mounted at the
ceiling. Fire extinguishers are also
provided for manual fire fighting
backup. Hose lines are available from
outside hydrants and hose houses.
3.10.3 Preservation of Safe Shutdown
Capability
The licensee stated that RB–FZ–1F3
has a ceiling height of approximately
41′-6″ and an approximate floor area of
560 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
3.10.4 OMAs Credited for a Fire in
This Zone
3.10.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
E:\FR\FM\07APN1.SGM
07APN1
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.10.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection system or personnel
and damage the safe shutdown
equipment. The low likelihood of
damage to safe shutdown equipment
due to a fire in this area, combined with
the ability of OMA #17 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provides adequate assurance that safe
shutdown capability is maintained.
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3.11 RB–FZ–1F5 Reactor Bldg. Torus
Room Elev. -19′-6″
3.11.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
cable insulation (approximately 19% of
loading) and gratings (approximately
76% of loading). The grating, which is
the largest plastic material in this area,
has a low flame spread rating (less than
25).
3.11.2 Detection, Control, and
Extinguishment
The licensee stated that RB–FZ–1F5
does not have detection or suppression
systems. However, due to the limited
combustible loading and the nature of
the combustibles, a fire in this zone is
not expected to be of significant size or
duration.
3.11.3 Preservation of Safe Shutdown
Capability
The licensee stated that RB–FZ–1F5 is
a voluminous area with an approximate
floor area of 11,450 square feet and a
ceiling height of approximately 41′-6″
therefore, it is unlikely that smoke and
heat from a fire in the area would
accumulate at the location of the
instrument air line and cause a loss of
instrument air.
3.11.4 OMAs Credited for a Fire in
This Zone
3.11.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
PO 00000
Frm 00192
Fmt 4703
Sfmt 4703
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.11.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and the large volume of the area, it is
unlikely that a fire would occur and go
undetected or unsuppressed by
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.12 RB–FZ–1G Reactor Bldg.
Shutdown Cooling Room Elev. 38′-0″ &
51′-3″
3.12.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
E:\FR\FM\07APN1.SGM
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combustible materials and sources of
ignition. The licensee also stated that
the main combustibles in this area are
cable insulation (approximately 12% of
loading), plastic (approximately 57% of
loading) and Class A combustibles
(approximately 14% of loading). The
grating, which is the majority of the
plastic material in this area, has a low
flame spread rating (less than 25).
3.12.2 Detection, Control, and
Extinguishment
The licensee stated that RB–FZ–1G is
provided with a smoke detection system
that alarms locally and in the control
room to provide prompt notification of
a potential fire event.
3.12.3 Preservation of Safe Shutdown
Capability
The licensee stated that RB–FZ–1G
has a ceiling height of approximately
21′, measured from the 51′-3″ elevation,
and an approximate floor area of 1,609
square feet so it is unlikely that smoke
and heat would accumulate at the
height of the safe shutdown equipment
and cause a failure due to fire damage.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.12.4 OMAs Credited for a Fire in
This Area
3.12.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
VerDate Mar<15>2010
19:53 Apr 06, 2011
Jkt 223001
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.12.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection system or personnel
and damage the safe shutdown
equipment. The low likelihood of
damage to safe shutdown equipment
due to a fire in this area, combined with
the ability of OMA #17 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provides adequate assurance that safe
shutdown capability is maintained.
3.13 TB–FA–3A Turbine Bldg. 4160V
Emergency Switchgear Vault 1C Elev.
23′-6″
3.13.1
Fire Prevention
The licensee stated that the fire
loading in this area is low and that there
is an administrative controls program in
place to limit additional combustible
materials and sources of ignition. The
licensee also stated that there are
minimal amounts of cable insulation
(approximately 5% of loading)
miscellaneous plastic (approximately
73% of loading) and class A
combustibles such as paper for
procedures (approximately 20% of
loading) in this area.
PO 00000
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Fmt 4703
Sfmt 4703
19499
3.13.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FA–3A is
provided with an area-wide smoke
detection system and a total-flooding,
manually actuated CO2 system.
3.13.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FA–3A
has a ceiling height of approximately 21′
and an approximate floor area of 336
square feet so it is unlikely that smoke
and heat would accumulate at the
height of the safe shutdown equipment
and cause a failure due to fire damage.
3.13.4 OMAs Credited for a Fire in
This Area
3.13.4.1 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
E:\FR\FM\07APN1.SGM
07APN1
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.13.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or CO2 systems, or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMA #17
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.14 TB–FA–26 Turbine Bldg. 125V DC
Battery Room C Elev. 23′-6″
3.14.1
Fire Prevention
The licensee stated that the fire
loading in this area is moderate and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
plastic, which is contributed by the
battery cases (approximately 92% of
loading) and cable insulation
(approximately 6% of loading).
mstockstill on DSKH9S0YB1PROD with NOTICES
3.14.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FA–26
has an area-wide automatic pre-action
sprinkler system and an area-wide
smoke detection system installed.
3.14.3 Preservation of Safe Shutdown
Capability
The licensee stated that there are no
specific cables in this fire area
associated with the OMAs identified for
Fire Area TB–FA–26 and that the only
fire safe shutdown component and cable
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located in this fire area is associated
with the ‘‘C’’ battery.
3.14.4 OMAs Credited for a Fire in
This Area
The licensee stated that this fire area
is wholly contained within Fire Zone
TB–FZ–11C (A and B 4160V Room) and
that all cables to TB–FA–26 must
traverse TB–FZ–11C. Therefore, TB–
FA–26 and TB–FZ–11C were analyzed
together for safe shutdown purposes and
the OMAs are duplicated for these two
plant areas. Refer to Section 3.16 below
for the discussion of OMAs #1, #2, #3,
#7, #8, and #18.
3.14.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and lack of multiple safe shutdown
trains in this area, it is unlikely that a
fire would occur and go undetected or
unsuppressed by the smoke detection or
sprinkler systems, or personnel, and
damage the safe shutdown equipment.
The low likelihood of damage to safe
shutdown equipment due to a fire in
this area, combined with the ability of
OMAs #1, #2, #3, #7, #8, and #18 to
manipulate the plant in the event of a
fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.15 TB–FZ–11B Turbine Bldg. Lube
Oil Storage, Purification and Pumping
Area Elev. 0′-0″, 27′-0″, and 36′-0″
3.15.1 Fire Prevention
The licensee stated that the fire
loading in this zone is high and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
lubricating oil (approximately 99% of
loading) and cable insulation
(approximately 0.3% of loading).
3.15.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FZ–11B
has automatic suppression systems
installed over principal combustibles
and a rate of rise/fixed temperature fire
detection system installed at the lube oil
tank. A closed head automatic sprinkler
system protects cable trays and open
head water spray deluge system protects
oil handling equipment and the oil
storage tank. Thermal detectors are
located in close proximity to the lube oil
tank so that a lube oil fire would be
quickly detected, which in turn would
activate the deluge system for
extinguishment. Additionally, the
licensee stated that there are fire
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extinguishers provided throughout the
zone and that aqueous film-forming
foam (AFFF) is staged in the Fire
Brigade van for use if necessary.
3.15.3 Preservation of Safe Shutdown
Capability
The licensee stated that the ceiling
heights in the area are approximately 9′0″ in the basement hallway,
approximately 19′-0″ in the basement
stairs, approximately 26′-0″ on the first
floor of the area, and approximately 42′0″ on the second floor of the area.
Additionally, the licensee stated that the
floor area, measured at the 0′-0″
elevation is approximately 3175 square
feet.
3.15.4 OMAs Credited for a Fire in
This Zone
3.15.4.1 OMA #3—Manually Control
480V USS 1B2 Breakers for CRD Pump
at Remote Shutdown Panel
In order for OMA #3 to be necessary,
the credited and redundant cables
would have to be damaged due to a fire.
The licensee stated that these cables are
located in the same tray with additional
cables and are generally located
approximately 14 feet above the floor.
The licensee also stated that the cables
pass over the top of potential ignition
sources MCC 1A12 and MCC 1B12 and
that the cables are located
approximately 6 feet above these
ignition sources. Additionally, the lube
oil tanks are located below the cables,
although not directly below, with a
distance of approximately 26 feet
separating the cables and the tanks. The
cables are also located approximately 20
feet from ignition sources MCC 1A12A
and 1B12A.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #3 is available
to manually control the 480V USS 1B2
Breakers for CRD Pump NC08B and
1B2M from the Remote Shutdown Panel
due to control circuit damage. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 8 minutes while the time
available is 180 minutes, which
provides a 142-minute margin.
3.15.4.2 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
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many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.15.5 Conclusion
Although the fire loading is high, the
limited ignition sources, large volume of
the space, and the detection and
suppression system make it unlikely
that a fire would occur and go
undetected or unsuppressed and
damage the safe shutdown equipment.
Additionally, the availability of fire
extinguishers and AFFF, which is
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effective against oil based fires, provides
an augmented ability to suppress a fire
prior to damaging safe shutdown
equipment. The low likelihood of
damage to safe shutdown equipment
due to a fire in this zone, combined with
the ability of OMAs #3 and #18 to
manipulate the plant in the event of a
fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.16 TB–FZ–11C Turbine Bldg. 4160V
SWGR Room 1A and 1B Elev. 23′-6″
3.16.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the main combustible loading is
attributed to cable insulation
(approximately 73% of loading) and
plastic (approximately 17% of loading).
3.16.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FZ–11C
has an area-wide smoke detection
system and an area-wide automatic
fixed pre-action sprinkler system
(except in the small caged area located
to the east of Fire Area TB–FA–3A)
installed.
3.16.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FZ–11C
has a ceiling height of approximately
21′-8″ and an approximate floor area of
2666 square feet so it is unlikely that
smoke and heat would accumulate at
the height of the safe shutdown
equipment and cause a failure due to
fire damage.
3.16.4 OMAs Credited for a Fire in
This Area
3.16.4.1 OMA #1—Trip Field Breakers
for Recirculation Pumps MG Set
In order for OMA #1 to be necessary,
damage to the 1A and 1B 4160V
Switchgear Cabinets and the ‘‘C’’ Battery
distribution panel, or the associated
control wiring, would have to occur due
to a fire and prevent tripping of the
4160V motor-generator set breakers. The
licensee stated that these cables are
located in the same tray with additional
cables and are generally located at least
17 feet above the floor. The licensee also
stated that the tray passes over the top
of potential ignition source ‘‘B’’ 4160V
switchgear and that the cables are
located approximately 9 feet above this
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19501
ignition source and 3 feet above the isophase bus duct at their closest point.
In the unlikely event that a fire does
occur and damages the credited and
redundant equipment, OMA #1 is
available to trip the field breakers for
the recirculation pumps motor-generator
set so that the Fuel Zone Level
Indicators can be used. The licensee
also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 8
minutes while the time available is 30
minutes, which provides a 12-minute
margin.
3.16.4.2 OMA #2—Align Fire Water to
Isolation Condenser
In order for OMA #2 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. The
licensee also stated that these cables are
located in the same tray with additional
cables and are generally located at least
17 feet above the floor and that the tray
passes over the top of potential ignition
source ‘‘B’’ 4160V switchgear and that
the cables are located approximately 9
feet above this ignition source and 3 feet
above the iso-phase bus duct at their
closest point.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #2 is available
to provide fire water to the isolation
condenser shell by operating valves V–
9–2099, V–11–49, V–11–63, and V–11–
41 due to loss of power. The licensee
also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 13
minutes while the time available is 45
minutes, which provides a 22-minute
margin.
3.16.4.3 OMA #3—Manually Control
480V USS 1B2 Breakers for CRD Pump
at Remote Shutdown Panel
In order for OMA #3 to be necessary,
the credited and redundant cables
would have to be damaged due to a fire.
The licensee stated that these cables are
located in the same tray with additional
cables and are generally located at least
17 feet above the floor. The licensee also
stated that the tray passes over the top
of potential ignition source ‘‘B’’ 4160V
switchgear and that the cables are
located approximately 9 feet above this
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ignition source and 3 feet above the isophase bus duct at their closest point.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #3 is available
to manually control the 480V USS 1B2
Breakers for CRD Pump NC08B and
1B2M from the Remote Shutdown Panel
due to control circuit damage. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 8 minutes while the time
available is 180 minutes, which
provides a 142-minute margin.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.16.4.4 OMA #7—Provide Makeup to
Isolation Condenser via V–11–36
In order for OMA #7 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. The
licensee also stated that these cables are
located in the same tray with additional
cables and are generally located at least
17 feet above the floor and that the tray
passes over the top of potential ignition
source ‘‘B’’ 4160V switchgear and that
the cables are located approximately 9
feet above this ignition source and 3 feet
above the iso-phase bus duct at their
closest point.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–11–36 to provide
makeup to Isolation Condenser due to
loss of power. The licensee also stated
that they have assumed a 10-minute
diagnosis period and that the required
time to perform the action is 16 minutes
while the time available is 45 minutes,
which provides a 19-minute margin.
3.16.4.5 OMA #8—Locally Check
Isolation Condenser Shell Level
In order for OMA #8 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. The
licensee also stated that these cables are
located in the same tray with additional
cables and are generally located at least
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17 feet above the floor and that the tray
passes over the top of potential ignition
source ‘‘B’’ 4160V switchgear and that
the cables are located approximately 9
feet above this ignition source and 3 feet
above the iso-phase bus duct at their
closest point.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #8 is available
to check the isolation condenser shell
level locally due to loss of power. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 16 minutes while the time
available is 45 minutes, which provides
a 19-minute margin.
3.16.4.6 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the main
MSIVs will close, as well as multiple
air-operated valves changing state.
Additionally, RPV level indication will
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not be compromised by a fire in any
zone or area. All of these indications
would help the operator diagnose the
loss of instrument air and initiate
mitigating procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.16.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
smoke detection or sprinkler systems
noted above, or personnel, and damage
the safe shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMAs #1,
#2, #3, #7, #8, and #18 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provide adequate assurance that safe
shutdown capability is maintained.
3.17 TB–FZ–11D Turbine Bldg.
Basement Floor South End Elev. 3′-6″
3.17.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
cable insulation (approximately 29% of
loading), Dow Corning 561 Silicon
transformer liquid (approximately 15%
of loading) and lubricating oil
(approximately 40% of loading).
3.17.2 Detection, Control, and
Extinguishment
The licensee stated that an automatic
wet-pipe sprinkler system and an
automatic water spray system located at
the hydrogen seal oil unit are installed
in the area.
3.17.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FZ–11D
has a ceiling height of approximately 19′
and an approximate floor area of 9668
square feet so it is unlikely that smoke
and heat would accumulate at the
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height of the safe shutdown equipment
and cause a failure due to fire damage.
3.17.4 OMAs Credited for a Fire in
This Zone
mstockstill on DSKH9S0YB1PROD with NOTICES
3.17.4.1 OMA #1—Trip Field Breakers
for Recirculation Pumps MG Set
In order for OMA #1 to be necessary,
damage to the 1A and 1B 4160V
Switchgear Cabinets and the ‘‘C’’ Battery
distribution panel, or the associated
control wiring, would have to occur due
to a fire and prevent tripping of the
4160V MG set breakers. The licensee
stated that these cables are located in
the same tray with additional cables and
are generally located at least 15 feet
above the floor. The primary
combustible fuel load in the area is the
cables themselves and storage of
transient combustibles is limited due to
a sump and abandoned acid/caustic
tanks located in the area.
The licensee also stated that the
primary ignition sources in the area near
the cable trays are the Turbine Building
Closed Cooling Water Pumps and USS
1A1 and its associated transformer
(4160V to 480V transformer). However,
the Turbine Building Closed Cooling
Water Pumps contain less than 5 gallons
of oil and are enclosed in metal casings
and the cable tray containing the cables
is approximately 13 feet from the top of
the pumps/motors. The top of USS 1A1
and its associated transformer are
located approximately 30 feet
diagonally from the credited cables and
approximately 15 feet diagonally from
the redundant cables. Additionally,
there is a concrete ceiling beam, with a
water curtain sprinkler system attached,
which would provide some shielding
for the cables from potential products of
combustion generated by this ignition
source. Sprinkler heads are also located
in a ceiling pocket between the concrete
ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and damages the credited and
redundant equipment, OMA #1 is
available to trip the field breakers for
the recirculation pumps MG Set so that
the fuel zone level indicators can be
used. The licensee also stated that they
have assumed a 10-minute diagnosis
period and that the required time to
perform the action is 8 minutes while
the time available is 30 minutes, which
provides a 12-minute margin.
3.17.4.2 OMA #2—Align Fire Water to
Isolation Condenser
In order for OMA #2 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
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licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. In
addition, the licensee stated that these
cables are located in the same tray with
additional cables and are generally
located at least 15 feet above the floor.
The primary combustible fuel load in
the area is the cables themselves and
storage of transient combustibles is
limited due to a sump and abandoned
acid/caustic tanks located in the area.
The licensee also stated that the
primary ignition sources in the area near
the cable trays are the Turbine Building
Closed Cooling Water Pumps and USS
1A1 and its associated transformer
(4160V to 480V transformer). However,
the Turbine Building Closed Cooling
Water Pumps contain less than 5 gallons
of oil and are enclosed in metal casings
and the cable tray containing the cables
is approximately 13 feet from the top of
the pumps/motors. The top of USS 1A1
and its associated transformer are
located approximately 30 feet
diagonally from the credited cables and
approximately 15 feet diagonally from
the redundant cables. Additionally,
there is a concrete ceiling beam, with a
water curtain sprinkler system attached,
which would provide some shielding
for the cables from potential products of
combustion generated by this ignition
source. Sprinkler heads are also located
in a ceiling pocket between the concrete
ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #2 is available
to provide fire water to the isolation
condenser shell by operating valves V–
9–2099, V–11–49, V–11–63, and V–11–
41 due to loss of power. The licensee
also stated that they have assumed a
10-minute diagnosis period and that the
required time to perform the action is 13
minutes while the time available is 45
minutes, which provides a 22-minute
margin.
3.17.4.3 OMA #3—Manually Control
480V USS 1B2 Breakers for CRD Pump
at Remote Shutdown Panel
In order for OMA #3 to be necessary,
the credited and redundant cables
would have to be damaged due to a fire.
The licensee stated that these cables are
located in the same tray with additional
cables and are generally located at least
15 feet above the floor. The primary
combustible fuel load in the area is the
cables themselves and storage of
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19503
transient combustibles is limited due to
a sump and abandoned acid/caustic
tanks located in the area.
The licensee also stated that the
primary ignition sources in the area near
the cable trays are the Turbine Building
Closed Cooling Water Pumps and
USS 1A1 and its associated transformer
(4160V to 480V transformer). However,
the Turbine Building Closed Cooling
Water Pumps contain less than 5 gallons
of oil and are enclosed in metal casings
and the cable tray containing the cables
is approximately 13 feet from the top of
the pumps/motors. The top of USS 1A1
and its associated transformer are
located approximately 30 feet
diagonally from the credited cables and
approximately 15 feet diagonally from
the redundant cables. Additionally,
there is a concrete ceiling beam, with a
water curtain sprinkler system attached,
which would provide some shielding
for the cables from potential products of
combustion generated by this ignition
source. Sprinkler heads are also located
in a ceiling pocket between the concrete
ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #3 is available
to manually control the 480V USS 1B2
Breakers for CRD Pump NC08B and
1B2M from the Remote Shutdown Panel
due to control circuit damage. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 8 minutes while the time
available is 180 minutes, which
provides a 142-minute margin.
3.17.4.4 OMA #7—Provide Makeup to
Isolation Condenser via V–11–36
In order for OMA #7 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. In
addition, the licensee stated that these
cables are located in the same tray with
additional cables and are generally
located at least 15 feet above the floor.
The primary combustible fuel load in
the area is the cables themselves and
storage of transient combustibles is
limited due to a sump and abandoned
acid/caustic tanks located in the area.
The licensee also stated that the
primary ignition sources in the area near
the cable trays are the Turbine Building
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mstockstill on DSKH9S0YB1PROD with NOTICES
Closed Cooling Water Pumps and
USS 1A1 and its associated transformer
(4160V to 480V transformer). However,
the Turbine Building Closed Cooling
Water Pumps contain less than 5 gallons
of oil and are enclosed in metal casings
and the cable tray containing the cables
is approximately 13 feet from the top of
the pumps/motors. The top of USS 1A1
and its associated transformer are
located approximately 30 feet
diagonally from the credited cables and
approximately 15 feet diagonally from
the redundant cables. Additionally,
there is a concrete ceiling beam, with a
water curtain sprinkler system attached,
which would provide some shielding
for the cables from potential products of
combustion generated by this ignition
source. Sprinkler heads are also located
in a ceiling pocket between the concrete
ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–11–36 to provide
makeup to Isolation Condenser due to
loss of power. The licensee also stated
that they have assumed a 10-minute
diagnosis period and that the required
time to perform the action is 16 minutes
while the time available is 45 minutes,
which provides a 19-minute margin.
3.17.4.5 OMA #8—Locally Check
Isolation Condenser Shell Level
In order for OMA #8 to be necessary,
loss of the ‘‘B’’ train of power would
have to occur due to a fire causing a loss
of both condensate transfer pumps. The
licensee stated that this OMA is
dependent on the LSP–1D OMA, which
was included in the licensee’s Phase 1
request, and would not be required
unless the OMA at the LSP–1D is
required and access is not immediately
available. As such, this OMA is
considered a contingency action. In
addition, the licensee stated that these
cables are located in the same tray with
additional cables and are generally
located at least 15 feet above the floor.
The primary combustible fuel load in
the area is the cables themselves and
storage of transient combustibles is
limited due to a sump and abandoned
acid/caustic tanks located in the area.
The licensee also stated that the
primary ignition sources in the area near
the cable trays are the Turbine Building
Closed Cooling Water Pumps and USS
1A1 and its associated transformer
(4160V to 480V transformer). However,
the Turbine Building Closed Cooling
Water Pumps contain less than 5 gallons
of oil and are enclosed in metal casings
and the cable tray containing the cables
is approximately 13 feet from the top of
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the pumps/motors. The top of USS 1A1
and its associated transformer are
located approximately 30 feet
diagonally from the credited cables and
approximately 15 feet diagonally from
the redundant cables. Additionally,
there is a concrete ceiling beam, with a
water curtain sprinkler system attached,
which would provide some shielding
for the cables from potential products of
combustion generated by this ignition
source. Sprinkler heads are also located
in a ceiling pocket between the concrete
ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #8 is available
to check the isolation condenser shell
level locally due to loss of power. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 16 minutes while the time
available is 45 minutes, which provides
a 19-minute margin.
3.17.4.6 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
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panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.17.5
Conclusion
Given the limited amount of
combustible materials, ignition sources
and the volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
suppression systems noted above, or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMAs #1,
#2, #3, #7, #8, and #18 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provides adequate assurance that safe
shutdown capability is maintained.
3.18 TB–FZ–11E Turbine Bldg.
Condenser Bay Area Elev. 0′-″0
3.18.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles in this area are
cable insulation (approximately 40% of
loading) and plastic (approximately
59% of loading). The grating, which is
the largest plastic material in this area,
is dispersed throughout this fire zone
(not concentrated) and has a low flame
spread (less than 25). The licensee also
stated that this Fire Zone is
procedurally controlled as a transient
combustible free area while the plant is
operating and that this area is a high
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radiation area during plant operation
and is not normally accessed.
available is 180 minutes, which
provides a 142-minute margin.
3.18.2 Detection, Control, and
Extinguishment
The licensee stated that a closed head
automatic sprinkler and spray systems
protect the south end basement area and
the hydrogen seal oil unit. An
exemption was granted from the
requirements of Appendix R Section
III.G.2 in safety evaluations dated March
24, 1986, and June 25, 1990, for not
having fixed fire detection in this area.
The primary basis for this exemption
was the presence of the automatic wet
pipe sprinkler system and low fire
loading. The Condenser Bay is
procedurally controlled as a transient
combustible free area in while the plant
is operating. If a fire did occur, the flow
alarm would notify the control room of
any sprinkler system activation.
Extinguishment of a fire can be
accomplished by the automatic fixed
suppression system and the plant fire
brigade. A closed head automatic
sprinkler system was recently expanded
to provide fire suppression over the
cables in cable trays in the northeast
side of the condenser bay.
3.18.4.2 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
3.18.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FZ–11E
has a ceiling height of at least 40′ and
an approximate floor area of 26,427
square feet so it is unlikely that smoke
and heat would accumulate at the
height of the safe shutdown equipment
and cause a failure due to fire damage.
mstockstill on DSKH9S0YB1PROD with NOTICES
3.18.4 OMAs Credited for a Fire in
This Zone
3.18.4.1 OMA #3—Manually Control
480V USS 1B2 Breakers for CRD Pump
at Remote Shutdown Panel
In order for OMA #3 to be necessary,
the credited and redundant cables
would have to be damaged due to a fire.
The licensee stated that these cables are
located in the same tray with additional
cables and are generally located
approximately 40 feet above the floor.
With the exception of the cables
themselves, there are no other ignition
sources or combustibles located near the
cables.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #3 is available
to manually control the 480V USS 1B2
Breakers for CRD Pump NC08B and
1B2M from the Remote Shutdown Panel
due to control circuit damage. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 8 minutes while the time
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minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.18.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
suppression system noted above or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMAs #3
and #18 to manipulate the plant in the
event of a fire that damages safe
shutdown equipment, provides
adequate assurance that safe shutdown
capability is maintained.
3.19 TB–FZ–11F Turbine Bldg.
Feedwater Pump Room Elev. 0′-0″ & 3′6″
3.19.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustible load consists of
cable insulation (approximately 15% of
loading), lubricating oil (approximately
39% of loading), rubber (approximately
21% of loading) and plastics
(approximately 17% of loading). The
licensee states that the majority of the
combustible loading attributed to rubber
and plastic was due to the storage of
hoses that are now no longer in the area.
3.19.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FZ–11F
has an area-wide thermal fire detection
system. Extinguishment of the fire will
be accomplished by the plant fire
brigade.
3.19.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FZ–11F
has a ceiling height of approximately 16′
in approximately 70% of the area and
approximately 19′-6″ in the remainder
of the area. With an approximate floor
area of 5650 square feet, it is unlikely
that smoke and heat would accumulate
at the height of the safe shutdown
equipment and cause a failure due to
fire damage.
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mstockstill on DSKH9S0YB1PROD with NOTICES
3.19.4 OMAs Credited for a Fire in
This Zone
3.19.4.1 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
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minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.19.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
thermal detection system noted above or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #18
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.20 TB–FZ–11H Turbine Bldg.
Demineralizer Tank and Steam Jet Air
Ejector Area Elev. 3′-6″ & 23′-6″
3.20.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there is an administrative controls
program in place to limit additional
combustible materials and sources of
ignition. The licensee also stated that
the major combustibles are cable
insulation (approximately 23% of
loading), ladders and other
miscellaneous plastics (approximately
55% of loading) and miscellaneous
ordinary combustibles.
3.20.2 Detection, Control, and
Extinguishment
The licensee stated that TB–FZ–11H
has a partial area thermal fire detector
system. The system alarms locally and
in the control room. Manual
extinguishment of fire will be
accomplished by the plant fire brigade.
3.20.3 Preservation of Safe Shutdown
Capability
The licensee stated that TB–FZ–11H
has a ceiling height of approximately 7′0″, measured at the 3′-6″ elevation, and
approximately 19′-0″, measured at the
23′-6″ elevation with an approximate
floor area of 3,944 square feet and 4,366
square feet, respectively, so it is
unlikely that smoke and heat would
accumulate at the height of the safe
shutdown equipment and cause a
failure due to fire damage.
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3.20.4 OMAs Credited for a Fire in
This Area
3.20.4.1 OMA #18—Provide Makeup
Air to Isolation Condenser Valve V–11–
36 Accumulator
In order for OMA #18 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–36 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #18
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–36 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #18 is
available to provide makeup control air
to the accumulator for V–11–36 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #18
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
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minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.20.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
thermal detection system noted above or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this zone,
combined with the ability of OMA #18
to manipulate the plant in the event of
a fire that damages safe shutdown
equipment, provides adequate assurance
that safe shutdown capability is
maintained.
3.21
3.21.1
Yard
Fire Prevention
The licensee stated that no specific
quantification of fire loading was
considered necessary for the Yard area
since it is an outdoor area with no
ceiling or physical boundaries to
contain heat and smoke from a fire
event.
3.21.2 Detection, Control, and
Extinguishment
The licensee stated that there is no
fire detection or fixed fire suppression
systems installed in this area but that
manual suppression is provided by a
hose station from the office building and
by fire hydrants located throughout the
Yard area.
3.21.3 Preservation of Safe Shutdown
Capability
Since the Yard area is an outdoor
space with no walls or ceiling, smoke
and heat would not accumulate within
the fire area to cause damage to
components remote to the initiating fire
or obstruct operator actions.
3.21.4 OMAs Credited for a Fire in
This Area
mstockstill on DSKH9S0YB1PROD with NOTICES
3.21.4.1 OMA #12—Establish CRD
Flow to Reactor
In order for OMA #12 to be necessary,
a loss of instrument air to the CRD flow
control valve would have to occur due
to fire damage. The licensee stated that
the normal CRD flow control valve is a
single component without a redundant
counterpart. Because of this, a manual
bypass is provided to maintain flow
around the CRD flow control valves that
fail closed upon loss of instrument air
or control cable damage.
In the unlikely event that a fire does
occur and causes the normal flow
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control valve to be unavailable due to a
loss of instrument air or cable damage,
OMA #12 is available to manually open
V–15–237, throttle V–15–30 while
monitoring flow at FI–225–2, and close
V–15–52 to establish CRD flow to the
reactor. Furthermore, OMA #12 would
only be necessary if the Isolation
Condenser/CRD systems are utilized for
hot shutdown. If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 30-minute diagnosis
period and that the required time to
perform the action is 15 minutes, while
the time available is 204 minutes, which
provides a 159-minute margin.
3.21.4.2 OMA #17—Provide Makeup
Air to Isolation Condenser Valve V–11–
34 Accumulator
In order for OMA #17 to be necessary,
a loss of instrument air to the isolation
condenser valve V–11–34 would have to
occur due to fire damage. The licensee
stated that they conservatively assume
that instrument air is lost for all
Appendix R fires based on the fact that
instrument air lines run throughout
many areas of the plant. The licensee’s
analysis assumes that the air line could
potentially fail in approximately 45
minutes when exposed to the postulated
fire.
The licensee also stated that OMA #17
connects a high pressure air cylinder to
the accumulator of Condensate Transfer
System valve V–11–34 and that these
air-operated valves are used to control
makeup to the isolation condensers.
Each valve is provided with an air
accumulator that provides a minimum
of six full cycles. As a result, this OMA
is only necessary to ensure long-term
operation of these valves and makeup to
the isolation condensers. Further, this
OMA would only be necessary if the
plant had to remain in hot shutdown for
an extended time. This scenario is
unlikely for this particular area since
the plant would likely reach cold
shutdown before the action is required.
In addition, the licensee stated that
they maintain a fire support procedure
(ABN–35, ‘‘Loss of Instrument Air’’) that
provides guidance to perform this OMA
if instrument air is lost and indicates
that there are four annunciator alarm
windows that monitor instrument air
pressure, plus a pressure gauge on a
panel in the control room for instrument
air pressure. If all of these instruments
are not available, then ABN–35 further
indicates that the control rods will start
to drift into the core and the MSIVs will
close, as well as multiple air-operated
valves changing state. Additionally,
RPV level indication will not be
compromised by a fire in any zone or
area. All of these indications would
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19507
help the operator diagnose the loss of
instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does
occur and causes a loss of instrument air
to the air-operated valves, OMA #17 is
available to provide makeup control air
to the accumulator for V–11–34 for the
isolation condenser makeup line due to
the loss of instrument air. If OMA #17
becomes necessary, the licensee stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 26
minutes, while the time available is 300
minutes, which provides a 244-minute
margin.
3.21.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
unlikely that a fire would occur and go
undetected or unsuppressed by the
thermal detection system noted above or
personnel, and damage the safe
shutdown equipment. The low
likelihood of damage to safe shutdown
equipment due to a fire in this area,
combined with the ability of OMAs #12
and #17 to manipulate the plant in the
event of a fire that damages safe
shutdown equipment, provides
adequate assurance that safe shutdown
capability is maintained.
3.22 Feasibility and Reliability of the
Operator Manual Actions
This analysis postulates that OMAs
may be needed to assure safe shutdown
capability in addition to the traditional
fire protection features described above.
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 Oyster Creek
analysis of these criteria for justifying
the OMAs specified in this exemption.
3.22.1 Bases for Establishing
Feasibility and Reliability
Using NUREG–1852, the NRC staff
has evaluated the feasibility and
reliability review provided by the
licensee in the April 2, 2010, Response
to Request for Additional Information.
For an OMA to be considered feasible,
the required actions must be
proceduralized, any equipment that is
needed to implement the OMA is
available, the environments in which
the OMA is to be performed must
permit the action, and the time taken to
diagnose the need for the OMA and
implement it (time required) must be
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
less than the time in which the OMA
must be completed (time available).
3.22.2 Feasibility
The feasibility review provided by the
licensee documents that procedures are
in place, in the form of fire response
procedures, to ensure that clear and
accessible instructions on how to
perform the manual actions are
available to the operators. All of the
requested OMAs are directed by plant
procedures, and the operators are
trained in the use of the procedures.
Specifically, the licensee stated that
procedure ABN–29, Plant Fires, is
entered whenever a fire or indication of
a fire occurs on the main fire alarm
panel in the control room or at any local
fire alarm panel. In addition to
dispatching a radio-equipped operator
to the alarming location, ABN–29 also
directs that the fire brigade be
dispatched whenever a fire suppression
system has actuated (sprinkler, deluge,
Halon, or CO2) or a fire is confirmed. In
addition, the licensee stated that ABN–
29 directs immediate entry into the Fire
Support Procedure (FSP) for the affected
fire area as soon as the existence of a fire
is confirmed. The licensee states that
the following indications or symptoms
are considered examples of a confirmed
fire:
• Fire detection alarm and equipment
malfunction indication or alarms within
the same area;
• Fire pump start and either sprinkler
flow alarm or deluge flow alarm;
• Gaseous suppression system
actuation;
• Report from the field of an actual
smoke condition or actual fire
condition; or
• Fire detection alarm with follow up
confirmation by field operator.
Entering the FSP means that the
operator will review the FSP, identify
equipment that could be affected,
identify equipment that will be
available, monitor plant equipment from
the control room and communicate with
the fire brigade leader. Based on the
symptoms received in the control room
and the feedback from the fire brigade
leader, the operator will decide using
the procedure what mitigating actions
are necessary. In the event that a plant
shutdown has occurred before the FSP
is entered, the operator will still enter
the FSP based on the fire and initiate
the OMAs as appropriate. OMAs that
are considered ‘‘prompt’’ (i.e., those that
must be done within 45 minutes or less)
are identified in both ABN–29 and in
the applicable FSPs as an item requiring
immediate attention. The operators are
trained to perform prompt actions first
and prioritize them based upon existing
plant conditions. The FSPs are based on
the worst-case loss considerations by
assuming all fire damage occurs
instantaneously and thus all operator
manual actions will be required. The
use of the Emergency Operating
Procedures in conjunction with the
applicable FSPs will permit the use of
any mitigating system available first,
and if a desired system is not available,
the FSP provides a contingency action
to restore the system or provide another
means to perform the function. Operator
training, including simulator
demonstrations and plant walk downs,
has been performed to ensure
consistency in operator and team
response for each OMA.
The licensee evaluated several
potential environmental concerns, 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
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 licensee stated that
OMAs required for achieving and
maintaining hot shutdown conditions
are not impacted by environmental
conditions associated with fires in the
fire area identified in the request. Each
of the safe shutdown calculations that
provide the technical basis for the FSPs
contains a timeline for operator actions
for the specific fire area. In addition, the
licensee stated that the equipment
needed to implement OMAs remains
available and the fire areas remain
accessible during or following the event.
The licensee’s analysis demonstrates
that, for the expected scenarios, the
OMAs can be diagnosed and executed
within the amount of time available to
complete them. 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 OMAs included in this review are
feasible because there is adequate time
available for the operator to perform the
required OMAs to achieve and maintain
hot shutdown following a postulated
fire event. Table 2 summarizes the
‘‘required’’ verses ‘‘available’’ times for
each OMA. The licensee has included
any diagnosis time as part of the
required time for performing a
particular action. Where an action has
multiple times or contingencies
associated with the ‘‘available’’
completion time, the lesser time is used.
This is approach is considered to
represent a conservative approach to
analyzing the timelines associated with
each of the OMAs with regard to the
feasibility and reliability of the actions
included in this exemption. The
licensee provided a discussion of the
times and circumstances associated
with each of the actions in their March
3, 2009, and April 2, 2010,
correspondence.
TABLE 2
Required
time
(min)
Available
time
(min)
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OMA
Fire area/zone of fire origin
OMA
location
1 ...............
2 ...............
3 ...............
7 ...............
8 ...............
9 ...............
17 .............
TB–FA–26, TB–FZ–11C, and TB–FZ–11D ...............................................
TB–FA–26, TB–FZ–11C, and TB–FZ–11D ...............................................
TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, and TB–FZ–11E ....
TB–FA–26, TB–FZ–11C, and TB–FZ–11D ...............................................
TB–FA–26, TB–FZ–11C, and TB–FZ–11D ...............................................
Yard ...........................................................................................................
CW–FA–14, OB–FZ–6A, OB–FZ–8A, OB–FZ–8B, OB–FZ–8C, OB–FA–
9, RB–FZ–1D, RB–FZ–1E, RB–FZ–1F3, RB–FZ–1F5, RB–FZ–1G,
TB–FA–3A, and Yard.
OB–FZ–6B, TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, TB–
FZ–11E, TB–FZ–11F, and TB–FZ–11H.
OB–FZ–10A ...............................................................................................
OB–FZ–8A
RB–FZ–1E
OB–FZ–6B
RB–FZ–1B
DG–FA–17
RB–FZ–1E
RB–FZ–1B
18
23
38
26
26
45
56
30
45
180
45
45
204
300
12
22
142
19
19
159
244
RB–FZ–1B
56
300
244
....................
38
60
22
18 .............
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mstockstill on DSKH9S0YB1PROD with NOTICES
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. The NRC staff recognizes that,
in some cases the time required neared
the time available for an OMA. The NRC
staff, however, also recognizes that there
are conservatisms built in to these time
estimates such as adding in the entire
time assumed to diagnose the need for
an OMA where in reality, the actual
time take would likely be less.
The NRC staff notes that, in one case,
an OMA must be completed within 30
minutes (i.e., it is considered a prompt
action). This action is identified as
OMA #1 and requires an operator to trip
the field breakers for the recirculation
pumps MG set so that the Fuel Zone
Level Indicators can be used. The action
may be required as a result of fire in
TB–FA–26, TB–FZ–11C, or TB–FZ–11D.
The symptom for this action is the
inability to trip the Recirculation Pumps
from the control room and this is
detected using the associated pump
breaker indicating lights, alarms and
flow indications. The Fire Support
Procedures direct the operator to trip
the pumps using the pump control
switches or the Recirculation Pump Trip
circuitry (two trip coils for pumps). If
both of these methods fail on one or
more pumps, the guidance is given to
trip the pumps from the 4160V
Switchgear 1A and 1B located outside
the control room in Fire Area TB–FZ–
11C. Only one operator would be
required and it would take
approximately 13 minutes for access to
the area and to perform the action of
tripping the breakers. Given the low
complexity of this action, the NRC staff
finds that there is a sufficient amount of
time available to complete the proposed
operator manual actions.
3.23 Reliability
The completion times noted in the
table above provide reasonable
assurance that the OMAs can reliably be
performed under a wide range of
conceivable conditions by different
plant crews. This is because the time
margins associated with each action and
other installed fire protection features,
account for sources of uncertainty such
as variations in fire and plant
conditions, factors unable to be
recreated in demonstrations and humancentered factors. Therefore, the OMAs
included in this review are 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.
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19:53 Apr 06, 2011
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This is based, in part, on a plant
demonstration of the actions under nonfire conditions.
3.24 Summary of Defense-in-Depth
and Operator Manual Actions
In summary, the defense-in-depth
concept for a fire in the fire areas
discussed above provides a level of
safety that limits the occurrence of fires
and results in rapid detection, control
and extinguishment of fires that do
occur and the protection of structures,
systems and components important to
safety. It should be understood that the
OMAs are a fall back in the unlikely
event that the fire protection defense-indepth features are insufficient. In most
cases, there is no credible fire scenario
that would necessitate the performance
of these OMAs. As discussed above, the
licensee has provided preventative and
protective measures in addition to
feasible and reliable OMAs that together
demonstrate the licensee’s ability to
preserve or maintain safe shutdown
capability in the event of a fire in the
analyzed fire areas.
3.25 Authorized by Law
This exemption would allow Oyster
Creek to rely on OMAs, 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 requirements specified in
10 CFR Part 50, Appendix R, Section
III.G.2 for a fire in the analyzed fire
areas. 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 this 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.
3.26 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. Based
on the above evaluation, the NRC staff
finds that the plant features, as
described in the March 3, 2009,
submittal, as supplemented by letter
dated April 2, 2010, should limit the
occurrence and impacts of any fire that
may occur. This, combined with the
ability of the OMAs to place and
maintain the plant in a safe condition in
the event of a fire that does damage safe
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19509
shutdown equipment, provides
adequate protection of public health and
safety. Therefore, there is no undue risk
to public health and safety.
3.27 Consistent With Common Defense
and Security
This exemption would allow Oyster
Creek to credit the use of the specific
OMAs, in conjunction with the other
installed fire protection features, in
response to a fire in the analyzed fire
areas, discussed above, in lieu of
meeting the requirements specified in
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 of III.G.2. Therefore, the
common defense and security is not
diminished by this exemption.
3.28
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 is to ensure that at least
one means of achieving and maintaining
hot shutdown remains available during
and following a postulated fire event.
While the licensee does not comply
with the explicit requirements of III.G.2,
specifically, they do meet the
underlying purpose of 10 CFR Part 50,
Appendix R, and Section III.G as a
whole. Therefore, special circumstances
exist that warrant the issuance of this
exemption 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, is
consistent with the common defense
and security and that special
circumstances are present to warrant
issuance of the exemption. 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 utilize the OMAs discussed
above at Oyster Creek.
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 33656).
This exemption is effective upon
issuance.
Dated at Rockville, Maryland, this 30th day
of March 2011.
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Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices
For the Nuclear Regulatory Commission.
Robert A. Nelson,
Acting Director, Division of Operating Reactor
Licensing, Office of Nuclear Reactor
Regulation.
[FR Doc. 2011–8318 Filed 4–6–11; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
[NRC–2011–0075]
Notice of Availability (NOA) of the
Models For Plant-Specific Adoption of
Technical Specifications Task Force
(TSTF) Traveler TSTF–422, Revision 2,
‘‘Change In Technical Specifications
End States (CE NPSD–1186),’’ For
Combustion Engineering (CE)
Pressurized Water Reactor (PWR)
Plants Using the Consolidated Line
Item Improvement Process (CLIIP)
U.S. Nuclear Regulatory
Commission (NRC).
ACTION: Notice of Availability.
AGENCY:
The NRC is announcing the
availability of the model application
(with model no significant hazards
consideration (NSHC) determination)
and model safety evaluation (SE) for
plant-specific adoption of TSTF
Traveler TSTF–422, Revision 2, ‘‘Change
in Technical Specifications End States
(CE NPSD–1186),’’ for CE plants using
the CLIIP. TSTF–422, Revision 2, is
available in the Agencywide Documents
Access and Management System
(ADAMS) under Accession Number
ML093570241. TSTF–422, Revision 2,
modifies the Required Action with the
preferred end state with the addition of
a Note to prohibit the use of the
provisions of Limiting Condition for
Operation 3.0.4.a to enter the end state
Mode within the Applicability during
startup. The Bases of each Required
Action is revised to describe the Note.
This model SE will facilitate expedited
approval of plant-specific adoption of
TSTF–422, Revision 2. Please note, this
NOA supersedes in its entirety the NOA
for TSTF–422, Revision 1, published in
the Federal Register on July 5, 2005 (70
FR 38729–38731, ADAMS Package
Accession Number ML051650144).
You can access publicly available
documents related to this notice using
the following methods:
NRC’s Public Document Room (PDR):
The public may examine and have
copied, for a fee, publicly available
documents at the NRC’s PDR, Public
File Area O1 F21, One White Flint
North, 11555 Rockville Pike, Rockville,
Maryland.
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SUMMARY:
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NRC’s Agencywide Documents Access
and Management System (ADAMS):
Publicly available documents created or
received at the NRC are available
electronically at the NRC’s Electronic
Reading Room at https://www.nrc.gov/
reading-rm/adams.html. From this page,
the public can gain entry into the
ADAMS, which provides text and image
files of NRC’s public documents. If you
do not have access to the ADAMS, or if
there are problems in accessing the
documents located in the ADAMS,
contact the NRC’s PDR reference staff at
1–800–397–4209, 301–415–4737, or by
e-mail to pdr.resource@nrc.gov.
The model application (with model
NSHC determination) and model SE for
plant-specific adoption of TSTF–422,
Revision 2, are available electronically
under ADAMS Accession Number
ML103270197. No comments were
received to the Notice of Opportunity
for Public Comment announced in the
Federal Register on May 4, 2005 (70 FR
23238).
Federal Rulemaking Web site:
Supporting materials related to this
notice can be found at https://
www.regulations.gov by searching on
Docket ID: NRC–2011–0075.
FOR FURTHER INFORMATION CONTACT:
Ravinder Grover, Technical
Specifications Branch, Mail Stop: O–7
C2A, Division of Inspection and
Regional Support, Office of Nuclear
Reactor Regulation, U.S. Nuclear
Regulatory Commission, Washington,
DC 20555–0001; telephone: 301–415–
2166 or e-mail;
Ravinder.Grover@nrc.gov or Ms.
Michelle C. Honcharik, Senior Project
Manager, Licensing Processes Branch,
Mail Stop: O–12 D1, Division of Policy
and Rulemaking, Office of Nuclear
Reactor Regulation, U.S. Nuclear
Regulatory Commission, Washington,
DC 20555–0001; telephone: 301–415–
1774 or e-mail at:
Michelle.Honcharik@nrc.gov.
SUPPLEMENTARY INFORMATION: TSTF–
422, Revision 2, is applicable to all CE
PWR plants. Licensees opting to apply
for this TS change are responsible for
reviewing the NRC staff’s model SE,
referencing the applicable technical
justifications, and providing any
necessary plant-specific information.
The NRC will process each amendment
application responding to this NOA
according to applicable NRC rules and
procedures.
The proposed models do not prevent
licensees from requesting an alternate
approach or proposing changes other
than those proposed in TSTF–422,
Revision 2. However, significant
deviations from the approach
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recommended in this notice or the
inclusion of additional changes to the
license require additional NRC staff
review. This may increase the time and
resources needed for the review or
result in NRC staff rejection of the
license amendment request (LAR).
Licensees desiring significant deviations
or additional changes should instead
submit an LAR that does not claim to
adopt TSTF–422, Revision 2.
Dated at Rockville, Maryland, this 22nd
day of March, 2011.
For the Nuclear Regulatory Commission.
John R. Jolicoeur,
Chief, Licensing Processes Branch, Division
of Policy and Rulemaking, Office of Nuclear
Reactor Regulation .
[FR Doc. 2011–8310 Filed 4–6–11; 8:45 am]
BILLING CODE 7590–01–P
PENSION BENEFIT GUARANTY
CORPORATION
Proposed Submission of Information
Collection for OMB Review; Comment
Request; Disclosure of Termination
Information
Pension Benefit Guaranty
Corporation.
ACTION: Notice of intent to request
extension of OMB approval.
AGENCY:
Pension Benefit Guaranty
Corporation (‘‘PBGC’’) intends to request
that the Office of Management and
Budget (‘‘OMB’’) extend approval, under
the Paperwork Reduction Act of 1995, of
a collection of information on the
disclosure of termination information
under its regulations for distress
terminations, 29 CFR part 4041, Subpart
C, and for PBGC-initiated terminations
under 29 CFR part 4042 (OMB control
number 1212–0065; expires October 31,
2011). This notice informs the public of
PBGC’s intent and solicits public
comment on the collection of
information.
SUMMARY:
Comments should be submitted
by June 6, 2011.
ADDRESSES: Comments may be
submitted by any of the following
methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the Web
site instructions for submitting
comments.
• E-mail:
paperwork.comments@pbgc.gov.
• Fax: 202–326–4224.
• Mail or Hand Delivery: Legislative
and Regulatory Department, Pension
Benefit Guaranty Corporation, 1200 K
Street, NW., Washington, DC 20005–
4026.
DATES:
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]]>Agencies
[Federal Register Volume 76, Number 67 (Thursday, April 7, 2011)]
[Notices]
[Pages 19488-19510]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-8318]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
[Docket No. 50-219; NRC-2010-0200]
Exelon Generation Company, LLC, Oyster Creek Nuclear Generating
Station; Exemption
1.0 Background
Exelon Generation Company, LLC (Exelon or the licensee) is the
holder of Facility Operating License No. DPR-16 that authorizes
operation of the Oyster Creek Nuclear Generating Station (Oyster
Creek). 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 or the Commission) now or hereafter in
effect.
The facility consists of a boiling-water reactor located in Ocean
County, New Jersey.
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.'' Oyster Creek was licensed to operate prior to January 1,
1979. As such, the licensee's Fire Protection Program must provide the
established level of protection as intended by Section III.G of 10 CFR
Part 50, Appendix R.
By letter dated March 4, 2009, ``Request for Exemption from 10 CFR
50, Appendix R, Section III.G, `Fire Protection of Safe Shutdown
Capability (Phase 2)' '' available at Agencywide Documents Access and
Management System (ADAMS), Accession No. ML090640225, and supplemented
by letter dated April 2, 2010, ``Response to Request for Additional
Information Request for Exemption from 10 CFR Part 50, Appendix R,
Section III.G, `Fire Protection of Safe Shutdown Capability' '' (ADAMS
Accession No. ML100920370), the licensee requested an exemption for
Oyster Creek from certain technical requirements of 10 CFR Part 50,
Appendix R, Section III.G.2 (III.G.2) for the use of operator manual
actions (OMAs) in lieu of meeting the circuit separation and protection
requirements contained in III.G.2 for the following 22 plant areas: CW-
FA-14, OB-FA-9, OB-FZ-6A, OB-FZ-6B, OB-FZ-8A, OB-FZ-8B, OB-FZ-8C, OB-
FZ-10A, RB-FZ-1D, RB-FZ-1E, RB-FZ-1F3, RB-FZ-1F5, RB-FZ-1G, TB-FA-3A,
TB-FA-26, TB-FZ-11B, TB-FZ-11C, TB-FZ-11D, TB-FZ-11E, TB-FZ-11F, TB-FZ-
11H, and Yard. The 22 plant areas noted above are the subject of this
exemption.
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. The licensee has stated
that special circumstances are present in that the application of the
regulation in this particular circumstance is not necessary to achieve
the underlying purpose of the rule, which is consistent with the
language included in 10 CFR 50.12(a)(2)(ii).
[[Page 19489]]
In their March 4, 2009, and April 2, 2010, letters, the licensee
discussed financial implications associated with plant modifications
that may be necessary to comply with the regulation.
Section 50.12(a)2(iii) of 10 CFR states that 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 Section III.G of 10 CFR
Part 50, Appendix R, 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 10 CFR Part 50, Appendix R, Section III.G.2
(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:
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 has requested an exemption from the requirements of III.G.2
for Oyster Creek to the extent that redundant trains of systems
necessary to achieve and maintain hot shutdown are not maintained free
of fire damage in accordance with one of the required means prescribed
in III.G.2.
Each OMA included in this review consists of a sequence of tasks
that occur in various fire areas. The OMAs are initiated upon
confirmation of a fire in a particular fire area. Table 1 lists, in the
order of the fire area of fire origin, the OMAs included in this
review.
TABLE 1
----------------------------------------------------------------------------------------------------------------
OMA
Area of fire origin Area name Actions
----------------------------------------------------------------------------------------------------------------
1................... CW-FA-14................. Circulatory Water Intake. Provide makeup control 17
air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
2................... OB-FA-9.................. Office Building (Bldg.) Provide makeup control 17
Elev. 23'-6'', 35'-0'', air to the accumulator
46'-6''. for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
3................... OB-FZ-6A................. Office Bldg. ``A'' 480V Provide makeup control 17
Switchgear (SWGR) Room air to the accumulator
Elev. 23'-6''. for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
4................... OB-FZ-6B................. Office Bldg. ``B'' 480V Provide makeup control 18
SWGR Room Elev. 23'-6''. air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
5................... OB-FZ-8A................. Office Bldg. Reactor Provide makeup control 17
Recirculation Motor air to the accumulator
Generator (MG) Set Room for V-11-34 for the
Elev. 23'-6''. Isolation Condenser
makeup line due to the
loss of instrument air.
6................... OB-FZ-8B................. Office Bldg. Mechanical Provide makeup control 17
Equipment Room Elev. 35'- air to the accumulator
0''. for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
7................... OB-FZ-8C................. Office Bldg. A/B Battery Provide makeup control 17
Room, Tunnel and air to the accumulator
Electrical Tray Room for V-11-34 for the
Elev. 35'-0''. Isolation Condenser
makeup line due to the
loss of instrument air.
8................... OB-FZ-10A................ Office Bldg. Monitor and Provide makeup control 18
Change Room Area and air to the accumulator
Operations Support Area for V-11-36 for the
Elev. 35'-0'' & 46'-6''. Isolation Condenser
makeup line due to the
loss of instrument air.
9................... RB-FZ-1D................. Reactor Bldg. Elev. 51'- Provide makeup control 17
3''. air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
10.................. RB-FZ-1E................. Reactor Building Elev. Provide makeup control 17
23'-6''. air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
11.................. RB-FZ-1F3................ Reactor Bldg. Northwest Provide makeup control 17
Corner Elev.-19'-6''. air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
12.................. RB-FZ-1F5................ Reactor Bldg. Torus Room Provide makeup control 17
Elev. -19'-6''. air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
[[Page 19490]]
13.................. RB-FZ-1G................. Reactor Bldg. Shutdown Provide makeup control 17
Cooling Room Elev. 38'- air to the accumulator
0'' & 51'-3''. for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
14.................. TB-FA-3A................. Turbine Bldg. 4160V Provide makeup control 17
Emergency SWGR Vault 1C air to the accumulator
Elev. 23'-6''. for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
15.................. TB-FA-26................. Turbine Bldg. 125V DC Trip Field Breakers for 1
Battery Room C Elev. 23'- Recirculation Pumps MG
6''. Set so that the Fuel
Zone Level Indicators
can be used.
Provide Fire Water to 2
Isolation Condenser
shell by operating
valves V-9-2099, V-11-
49, V-11-63 and V-11-41
due to loss of power
(contingency action).
Manually control 480V USS 3
1B2 Breakers for control
rod drive (CRD) Pump
NC08B and 1B2M from
Remote Shutdown Panel
due to control circuit
damage.
Manually open V-11-36 to 7
provide makeup to
Isolation Condenser due
to loss of power
(contingency action).
Check Isolation Condenser 8
Shell level locally due
to loss of power
(contingency action).
Provide makeup control 18
air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
16.................. TB-FZ-11B................ Turbine Bldg. Lube Oil Manually control 480V 3
Storage, Purification Unit Substation (USS)
and Pumping Area Elev. 1B2 Breakers for CRD
0'[dash]0'', 27'-0'', Pump NC08B and 1B2M from
and 36'-0''. Remote Shutdown Panel
due to control circuit
damage.
Provide makeup control 18
air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
17.................. TB-FZ-11C................ Turbine Bldg. SWGR Room Trip Field Breakers for 1
1A and 1B Elev. 23'-6''. Recirculation Pumps MG
Set so that the Fuel
Zone Level Indicators
can be used.
Provide Fire Water to 2
Isolation Condenser
shell by operating
valves V-9-2099, V-11-
49, V-11-63 and V-11-41
due to loss of power
(contingency action).
Manually control 480V USS 3
1B2 Breakers for CRD
Pump NC08B and 1B2M from
Remote Shutdown Panel
due to control circuit
damage.
Manually open V-11-36 to 7
provide makeup to
Isolation Condenser due
to loss of power
(contingency action).
Check Isolation Condenser 8
Shell level locally due
to loss of power
(contingency action).
Provide makeup control 18
air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
18.................. TB-FZ-11D................ Turbine Bldg. Basement Trip Field Breakers for 1
Floor South End Elev. 3'- Recirculation Pumps MG
6''. Set so that the Fuel
Zone Level Indicators
can be used.
Provide Fire Water to 2
Isolation Condenser
shell by operating
valves V-9-2099, V-11-
49, V-11-63 and V-11-41
due to loss of power
(contingency action).
Manually control 480V USS 3
1B2 Breakers for CRD
Pump NC08B and 1B2M from
Remote Shutdown Panel
due to control circuit
damage.
Manually open V-11-36 to 7
provide makeup to
Isolation Condenser due
to loss of power
(contingency action).
Check Isolation Condenser 8
Shell level locally due
to loss of power
(contingency action).
Provide makeup control 18
air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
19.................. TB-FZ-11E................ Turbine Bldg. Condenser Manually control 480V USS 3
Bay Area Elev. 0'-0''. 1B2 Breakers for CRD
Pump NC08B and 1B2M from
Remote Shutdown Panel
due to control circuit
damage.
Provide makeup control 18
air to the accumulator
for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
20.................. TB-FZ-11F................ Turbine Bldg. Feedwater Provide makeup control 18
Pump Room Elev. 0'-0'' & air to the accumulator
3'-6''. for V-11-36 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
21.................. TB-FZ-11H................ Turbine Bldg. Provide makeup control 18
Demineralizer Tank and air to the accumulator
Steam Jet Air Ejector for V-11-36 for the
Area Elev. 3'-6'' & 23'- Isolation Condenser
6''. makeup line due to the
loss of instrument air.
[[Page 19491]]
22.................. Yard..................... Office Bldg. Roof, Manually open V-15-237, 9
Turbine Bldg. Roof, and throttle V-15-30 while
All Remaining Outside monitoring flow at FI-
Areas. 225-2 and close V-15-52
to establish CRD flow to
Reactor due to the loss
of instrument air to the
CRD Flow Control Valve.
Provide makeup control 17
air to the accumulator
for V-11-34 for the
Isolation Condenser
makeup line due to the
loss of instrument air.
----------------------------------------------------------------------------------------------------------------
In their submittals the licensee described elements of their fire
protection program that provide their justification that the concept of
defense-in-depth that is in place in the above fire areas is consistent
with that intended by the regulation. To accomplish this, the licensee
utilizes various protective measures to accomplish the concept of
defense-in-depth. Specifically, the licensee stated that the purpose of
their request was to credit the use of OMAs, in conjunction with other
defense-in-depth features, in lieu of the separation and protective
measures required by III.G.2 for a fire in the fire areas stated above.
In their April 2, 2010, letter the licensee provided an analysis
that described how fire prevention is addressed for each of the fire
areas for which the OMAs may be required. The licensee developed a Fire
Hazards Analysis (FHA) for each fire area or zone identified in its
exemption request. For each fire area or zone, the FHA describes the
physical location and arrangement of equipment, combustible loading,
ignition sources, fire protection features, and proximity of redundant
safe shutdown equipment to in situ hazards and identifies deviations
from fire protection codes and previously approved exemptions. In
addition, for each fire area or zone, the licensee's response includes
a tabulation of potential ignition sources as well as the equipment
that may exhibit high energy arcing faults. For each fire area or zone,
the FHA states that the fire protection configuration achieves a level
of protection commensurate with that intended by III.G.2.
The 22 areas or zones identified in the request have
administratively limited combustible fuel loading with fuel sources
consisting primarily of cable insulation and limited floor based
combustibles except areas OB-FZ-6A, OB-FZ-6B, and TB-FZ-11B, which
contain quantities of transformer liquid or lubricating oil.
Combustible fuel loading in most areas is classified as low by the
licensee while Fire Areas OB-FZ-6A and OB-FZ-6B have been classified as
having a moderate combustible fuel loading and TB-FZ-11B has been
classified as having a high combustible fuel loading. In addition, the
licensee has stated that they maintain a robust administrative program
(e.g., hot work permits, fire watches for hot work, and supervisory
controls) to limit and control transient combustible materials and
ignition sources in the areas. The fire areas included in the exemption
are not shop areas so hot work activities are infrequent and the
administrative control programs are in place if hot work activities do
occur.
The licensee also stated that 98% of the Oyster Creek cables are
jacketed with Vulkene, which passes the horizontal flame test of the
Underwriter's Laboratory, therefore reducing the likelihood of the
cables themselves contributing to a fire hazard. Furthermore, the areas
or zones are of noncombustible construction with typical utilities
installed lighting, ventilation, etc., and 3-hour fire resistance-rated
barriers normally used to provide fire resistive separation between
adjacent fire areas. In some cases, barriers with a fire resistance
rating of less than 3 hours are credited, but exemptions have been
approved or the licensee has stated they have performed engineering
evaluations in accordance with Generic Letter 86-10 to demonstrate that
the barriers are sufficient for the hazard. Walls separating rooms and
zones within fire areas are typically constructed of heavy concrete.
This compartmentalization of the areas reduces the likelihood for fire
events in a particular area to spread to or impact other adjacent
areas.
Many fire areas included in this exemption have automatic detection
systems installed, although the licensee indicated that not all systems
are installed in accordance with a recognized standard with regard to
spacing in all areas. In such cases, the licensee has stated that the
detectors are located near equipment such that they are likely to
detect a fire. Upon detecting smoke, the detectors initiate an alarm in
the constantly staffed control room. In addition to the automatic
suppression systems noted below, equipment operators are trained fire
brigade members and may identify and manually suppress or extinguish a
fire using the portable fire extinguishers and manual hose stations
located throughout the fire areas if a fire is identified in its early
stages of growth.
The licensee stated that the postulated fire events that may
require the use of the OMAs would include multiple failures of various
components or equipment. In most cases, it is considered unlikely that
the sequence of events required to necessitate the OMAs would fully
evolve because of the fire prevention, fire protection, and physical
separation features in place. However, in the event that the sequence
does evolve, the OMAs are available to provide assurance that safe
shutdown can be achieved. For each of the fire areas included in this
exemption, the postulated fire scenarios and pertinent details are
summarized in Table 2 below.
Each of the fire areas or zones included in this exemption is
analyzed below with regard to how the concept of defense-in-depth is
achieved for each area or zone and the role of the OMAs in the overall
level of safety provided for each area or zone.
3.1 CW-FA-14 Circulatory Water Intake
3.1.1 Fire Prevention
The licensee stated that combustible loading is not tracked in this
area since it is an outside area. The licensee also stated that the
primary combustible materials in the area are transformer liquid and
electrical motors; although the amount is not quantified since the area
is open to the atmosphere with no walls or ceiling to contain the heat
or smoke that may be produced during a fire event. Additionally, the
main combustible in this area that could result in the need for the
OMAs is Dow Corning 561 Silicon transformer liquid, which the licensee
states has characteristics that minimize the likelihood of a fire
involving the insulating liquid itself.
[[Page 19492]]
3.1.2 Detection, Control, and Extinguishment
CW-FA-14 is not equipped with automatic fire detection or
suppression systems but since it is an outdoor area with no walls or
ceiling, it is not expected that such systems would enhance this
element of defense-in-depth in this area since the area is open to the
atmosphere with no walls or ceiling to contain the heat or smoke that
may be produced during a fire event. However, the licensee stated that
a security tower monitors this area continuously. Therefore, any fire
of significance would likely be detected and responded to appropriately
by the station fire brigade. Manual suppression is also provided by a
fire hydrant and fire hose house located approximately 75 feet from the
principal fire hazards.
3.1.3 Preservation of Safe Shutdown Capability
Since Fire Area CW-FA-14 is an outdoor space with no walls or
ceiling, smoke and heat would not accumulate within the fire area to
cause damage to components remote to the initiating fire or obstruct
operator actions.
3.1.4 OMAs Credited for a Fire in This Area
3.1.4.1 OMA 17--Provide Makeup Air to Isolation Condenser
Valve V-11-34 Accumulator
In order for OMA 17 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-34 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 17 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-34 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a panel in the control room for
instrument air pressure. If all of these instruments are not available,
then ABN-35 further indicates that the control rods will start to drift
into the core and the main steam isolation valves (MSIVs) will close,
as well as multiple air-operated valves changing state. Additionally,
reactor pressure vessel (RPV) level indication is also available for
all fire areas or zones. All of these indications would help the
operator diagnose the loss of instrument air and initiate mitigating
procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 17 is available
to provide makeup control air to the accumulator for V-11-34 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 17 becomes necessary, the licensee stated that they have
assumed a 30-minute diagnosis period and that the required time to
perform the action is 26 minutes, while the time available is 300
minutes, which provides a 244-minute margin.
3.1.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and open nature of the area, it is unlikely that a fire would
occur and go undetected or unsuppressed by the personnel, and damage
the safe shutdown equipment. The low likelihood of damage to safe
shutdown equipment due to a fire in this area, combined with the
ability of OMA 17 to manipulate the plant in the event of a
fire that damages safe shutdown equipment, provides adequate assurance
that safe shutdown capability is maintained.
3.2 OB-FA-9 Office Bldg. Elev. 23'-6'', 35'-0'', 46'-6'',
3.2.1 Fire Prevention
The licensee has classified the fire loading in this fire area as
low. The licensee also stated that the major combustibles in the
multiplexer (MUX) corridor, which is within OC-FA-9, are cable
insulation and a wood ceiling on top of the MUX enclosure, which is
within the MUX corridor.
3.2.2 Detection, Control, and Extinguishment
The licensee stated that OB-FA-9 has a partial area coverage wet
pipe sprinkler system installed. The licensee further stated that the
area is not provided with a detection system but that there is an
installed detection system in the main hallways and inside of the MUX
corridor and that it is a high traffic area so a fire would likely be
detected by personnel. The wet pipe sprinkler system, when actuated,
will alarm in the control room to notify operators of a potential fire
event. Extinguishment of a fire in the majority of this area will be
accomplished by the plant fire brigade.
3.2.3 Preservation of Safe Shutdown Capability
The licensee stated that OB-FA-9 has a ceiling height of
approximately 10'-6'', and an approximate floor area of 513 square feet
in the MUX corridor where the safe shutdown equipment is located so it
is unlikely that smoke and heat would accumulate at the height of the
safe shutdown equipment and cause a failure due to fire damage.
3.2.4 OMAs Credited for a Fire in this Area
3.2.4.1 OMA 17--Provide Makeup Air to Isolation Condenser
Valve V-11-34 Accumulator
In order for OMA 17 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-34 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 17 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-34 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time. This scenario is unlikely for this particular area since
the plant would likely reach cold shutdown before the action is
required.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a
[[Page 19493]]
panel in the control room for instrument air pressure. If all of these
instruments are not available, then ABN-35 further indicates that the
control rods will start to drift into the core and the MSIVs will
close, as well as multiple air-operated valves changing state.
Additionally, RPV level indication will not be compromised by a fire in
any zone or area. All of these indications would help the operator
diagnose the loss of instrument air and initiate mitigating procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 17 is available
to provide makeup control air to the accumulator for V-11-34 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 17 becomes necessary, the licensee stated that they have
assumed a 30-minute diagnosis period and that the required time to
perform the action is 26 minutes, while the time available is 300
minutes, which provides a 244-minute margin.
3.2.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and volume of the space, it is unlikely that a fire would
occur and go undetected or unsuppressed by the sprinkler system noted
above, or personnel, and damage the safe shutdown equipment. The low
likelihood of damage to safe shutdown equipment due to a fire in this
area, combined with the ability of OMA 17 to manipulate the
plant in the event of a fire that damages safe shutdown equipment,
provides adequate assurance that safe shutdown capability is
maintained.
3.3 OB-FZ-6A Office Bldg. ``A'' 480V Switchgear (SWGR) Room Elev. 23'-
6'',
3.3.1 Fire Prevention
The licensee stated that the fire loading in this zone is moderate
and that there is an administrative controls program in place to limit
additional combustible materials and sources of ignition. The licensee
also stated that the main combustibles in this area are cable
insulation (approximately 81% of loading) and Dow Corning 561 Silicon
transformer liquid (approximately 15% of loading). The transformer
liquid has characteristics that minimize the likelihood of a fire
involving the insulating liquid itself.
3.3.2 Detection, Control, and Extinguishment
The licensee stated that OB-FZ-6A has an automatic smoke detection
system, a total flooding automatic Halon 1301 System, and manual fire
fighting capabilities (portable extinguishers and hose stations).
3.3.3 Preservation of Safe Shutdown Capability
The licensee stated that OB-FA-6A has a ceiling height of
approximately 10'-8'', and an approximate floor area of 1157 square
feet so it is unlikely that smoke and heat would accumulate at the
height of the safe shutdown equipment and cause a failure due to fire
damage.
3.3.4 OMAs Credited for a Fire in this Zone
3.3.4.1 OMA 17--Provide Makeup Air to Isolation Condenser
Valve V-11-34 Accumulator
In order for OMA 17 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-34 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 17 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-34 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a panel in the control room for
instrument air pressure. If all of these instruments are not available,
then ABN-35 further indicates that the control rods will start to drift
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will
not be compromised by a fire in any zone or area. All of these
indications would help the operator diagnose the loss of instrument air
and initiate mitigating procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 17 is available
to provide makeup control air to the accumulator for V-11-34 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 17 becomes necessary, the licensee stated that they have
assumed a 30-minute diagnosis period and that the required time to
perform the action is 26 minutes, while the time available is 300
minutes, which provides a 244-minute margin.
3.3.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and the volume of the space, it is unlikely that a fire would
occur and go undetected or unsuppressed by the smoke detection or Halon
system noted above, or personnel, and damage the safe shutdown
equipment. The low likelihood of damage to safe shutdown equipment due
to a fire in this zone, combined with the ability of OMA 17 to
manipulate the plant in the event of a fire that damages safe shutdown
equipment, provides adequate assurance that safe shutdown capability is
maintained.
3.4 OB-FZ-6B Office Building ``B'' 480V SWGR Room Elev. 23'-6'',
3.4.1 Fire Prevention
The licensee stated that the fire loading in this zone is moderate
and that there is an administrative controls program in place to limit
additional combustible materials and sources of ignition. The licensee
also stated that the main combustibles in this area are cable
insulation (approximately 28% of loading), Thermo-Lag (approximately
29% of loading) and Dow Corning 561 Silicon transformer liquid
(approximately 31% of loading). The transformer liquid has
characteristics that minimize the likelihood of a fire involving the
insulating liquid itself.
3.4.2 Detection, Control, and Extinguishment
The licensee stated that OB-FZ-6B has an automatic smoke detection
system, a total flooding Halon 1301 System, and manual fire fighting
capabilities (portable extinguishers and hose stations).
3.4.3 Preservation of Safe Shutdown Capability
The licensee stated that OB-FA-6B has a ceiling height of
approximately 10'-8'' and an approximate floor area of 679 square feet
so it is unlikely that
[[Page 19494]]
smoke and heat would accumulate at the height of the safe shutdown
equipment and cause a failure due to fire damage.
3.4.4 OMAs Credited for a Fire in This Zone
3.4.4.1 OMA 18--Provide Makeup Air to Isolation Condenser
Valve V-11-36 Accumulator
In order for OMA 18 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-36 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 18 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-36 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a panel in the control room for
instrument air pressure. If all of these instruments are not available,
then ABN-35 further indicates that the control rods will start to drift
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will
not be compromised by a fire in any zone or area. All of these
indications would help the operator diagnose the loss of instrument air
and initiate mitigating procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 18 is available
to provide makeup control air to the accumulator for V-11-36 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 18 becomes necessary, the licensee stated that they have
assumed a 30-minute diagnosis period and that the required time to
perform the action is 26 minutes, while the time available is 300
minutes, which provides a 244-minute margin.
3.4.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and the volume of the space, it is unlikely that a fire would
occur and go undetected or unsuppressed by the smoke detection or Halon
system noted above, or personnel, and damage the safe shutdown
equipment. The low likelihood of damage to safe shutdown equipment due
to a fire in this area, combined with the ability of OMA 18 to
manipulate the plant in the event of a fire that damages safe shutdown
equipment, provides adequate assurance that safe shutdown capability is
maintained.
3.5 OB-FZ-8A Office Bldg. Reactor Recirculation MG Set Room & OB-FZ-8B
Mechanical Equipment Room Elev. 23'-6'' & 35'-0''
3.5.1 Fire Prevention
Fire Zones OB-FZ-8A and 8B are evaluated together for the
combustible loading and fire safe shutdown analysis. The licensee
stated that the fire loading in this zone is low and that there is an
administrative controls program in place to limit additional
combustible materials and sources of ignition. The licensee also stated
that there are minimal combustibles in Fire Zone OB-FZ-8B. The major
combustibles in Fire Zone OB-FZ-8A are lubricating oil (approximately
83% of loading) and cable insulation (approximately 13% of loading).
3.5.2 Detection, Control, and Extinguishment
The licensee stated that OB-FZ-8A has a partial wet-pipe sprinkler
system with a flow alarm that notifies the control room and that the
area does not have a smoke detection system however, a duct smoke
detector is located in the exhaust duct of fan EF-1-20. Since operation
of the sprinkler system will alarm in the control room, prompt
notification of and response by, the fire brigade for any required
manual fire fighting activities is expected.
3.5.3 Preservation of Safe Shutdown Capability
The licensee stated that OB-FZ-8A has a ceiling height of
approximately 10'-10'' and an approximate floor area of 2128 square
feet and OB-FZ-8B has a ceiling height of approximately 11'-0'' and an
approximate floor area of 479 square feet so it is unlikely that smoke
and heat would accumulate at the height of the safe shutdown equipment
and cause a failure due to fire damage.
3.5.4 OMAs Credited for a Fire in This Area
3.5.4.1 OMA 17--Provide Makeup Air to Isolation Condenser
Valve V-11-34 Accumulator
In order for OMA 17 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-34 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 17 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-34 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time. This scenario is unlikely for this particular area since
the plant would likely reach cold shutdown before the action is
required.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a panel in the control room for
instrument air pressure. If all of these instruments are not available,
then ABN-35 further indicates that the control rods will start to drift
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will
not be compromised by a fire in any zone or area. All of these
indications would help the operator diagnose the loss of instrument air
and initiate mitigating procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 17 is available
to provide makeup control air to the accumulator for V-11-34 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 17
[[Page 19495]]
becomes necessary, the licensee stated that they have assumed a 30-
minute diagnosis period and that the required time to perform the
action is 26 minutes, while the time available is 300 minutes, which
provides a 244-minute margin.
3.5.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and the large volume of the space, it is unlikely that a fire
would occur and go undetected or unsuppressed by the smoke detection or
sprinkler systems noted above, or personnel, and damage the safe
shutdown equipment. The low likelihood of damage to safe shutdown
equipment in this zone, combined with the ability of OMA 17 to
manipulate the plant in the event of a fire that damages safe shutdown
equipment, provides adequate assurance that safe shutdown capability is
maintained.
3.6 OB-FZ-8C Office Bldg. A/B Battery Room, Tunnel and Electrical Tray
Room Elev. 35'-0''
3.6.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that there is an administrative controls program in place to limit
additional combustible materials and sources of ignition. The licensee
also stated that the major combustibles in Fire Zone OB-FZ-8C are
electrolyte-filled plastic battery cases and racks (approximately 56%
of loading) and cable insulation (approximately 39% of loading).
3.6.2 Detection, Control, and Extinguishment
The licensee stated that OB-FZ-8C has a fixed, total-flooding,
Halon 1301 extinguishing system, area-wide smoke detection that is
installed at the ceiling level and cross-zoned to sound a local alarm,
and an alarm in the control room upon actuation of one detector.
Actuation of a second detector will sound a local alarm, discharge the
Halon system, trip supply and exhaust fans, and close dampers.
3.6.3 Preservation of Safe Shutdown Capability
The licensee stated that OB-FZ-8C has a ceiling height of
approximately 11'-0'' and an approximate floor area of 1292 square feet
so it is unlikely that smoke and heat would accumulate at the height of
the safe shutdown equipment and cause a failure due to fire damage.
3.6.4 OMAs Credited for a Fire in This Zone
3.6.4.1 OMA 17--Provide Makeup Air to Isolation Condenser
Valve V-11-34 Accumulator
In order for OMA 17 to be necessary, a loss of instrument
air to the isolation condenser valve V-11-34 would have to occur due to
fire damage. The licensee stated that they conservatively assume that
instrument air is lost for all Appendix R fires based on the fact that
instrument air lines run throughout many areas of the plant. The
licensee's analysis assumes that the air line could potentially fail in
approximately 45 minutes when exposed to the postulated fire.
The licensee also stated that OMA 17 connects a high
pressure air cylinder to the accumulator of Condensate Transfer System
valve V-11-34 and that these air-operated valves are used to control
makeup to the isolation condensers. Each valve is provided with an air
accumulator that provides a minimum of six full cycles. As a result,
this OMA is only necessary to ensure long-term operation of these
valves and makeup to the isolation condensers. Further, this OMA would
only be necessary if the plant had to remain in hot shutdown for an
extended time. This scenario is unlikely for this particular area since
the plant would likely reach cold shutdown before the action is
required.
In addition, the licensee stated that they maintain a fire support
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance
to perform this OMA if instrument air is lost and indicates that there
are four annunciator alarm windows that monitor instrument air
pressure, plus a pressure gauge on a panel in the control room for
instrument air pressure. If all of these instruments are not available,
then ABN-35 further indicates that the control rods will start to drift
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will
not be compromised by a fire in any zone or area. All of these
indications would help the operator diagnose the loss of instrument air
and initiate mitigating procedures.
In the unlikely event that a fire does occur and causes a loss of
instrument air to the air-operated valves, OMA 17 is available
to provide makeup control air to the accumulator for V-11-34 for the
isolation condenser makeup line due to the loss of instrument air. If
OMA 17 becomes necessary, the licensee stated that they have
assumed a 30-minute diagnosis period and that the required time to
perform the action is 26 minutes, while the time available is 300
minutes, which provides a 244-minute margin.
3.6.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and the large volume of the space, it is unlikely that a fire
would occur and go undetected or unsuppressed by the smoke detection or
Halon systems noted above, or personnel, and damage the safe shutdown
equipment. The low likelihood of damage to safe shutdown equipment due
to a fire in this zone, combined with the ability of OMA 17 to
manipulate the plant in the event of a fire that damages safe shutdown
equipment, provides adequate assurance that safe shutdown capability is
maintained.
3.7 OB-FZ-10A Office Bldg. Monitor and Change Room and Operations
Support Area Elev. 35'-0'' & 46'-6''
3.7.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that there is an administrative controls program in place to limit
additional combustible materials and sources of ignition. The licensee
also stated that the major combustibles in this area are cable
insulation (approximate 27% of loading), rubber flooring (approximately
31% of loading), miscellaneous plastics (approximately 17% of loading)
and protective clothing supplies (approximately 20% of loading).
However, since the protective clothing have been placed in metal cans
with self-closing lids they are no longer considered a contribution to
the combustibles in this area.
3.7.2 Detection, Control, and Extinguishment
The licensee stated that OB-FZ-10A has an area-wide smoke detection
system and a wet-pipe automatic sprinkler system installed throughout
the area. In addition, a hose station located nearby, outside the
control room, provides manual suppression capability.
3.7.3 Preservation of Safe Shutdown Ca
