Exelon Generation Company, LLC; Oyster Creek Nuclear Generating Station; Exemption, 19795-19817 [2011-8405]
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Federal Register / Vol. 76, No. 68 / Friday, April 8, 2011 / Notices
NUREG–1496, July 1997
(ML042310492, ML042320379, and
ML042330385).
2. Martinson, Tracey A., University of
Alaska-Fairbanks, Licensee letter
requesting release of incinerator,
July 30, 2008 (ML082420967).
3. NRC, Request for additional
information, June 4, 2009
(ML091560189).
4. Martinson, Tracey A., University of
Alaska-Fairbanks, Proposed
decommissioning plan, July 12,
2009 (ML110310647).
5. NRC, License amendment, August 12,
2009 (ML092240357).
6. Martinson, Tracey A., University of
Alaska-Fairbanks, Final status
survey report, November 16, 2009
(ML093641107).
If you do not have access to ADAMS
or if there are problems in accessing the
documents located in ADAMS, contact
the NRC Public Document Room (PDR)
Reference staff at 1–800–397–4209 or
301–415–4737 or by e-mail to
pdr.resource@nrc.gov.
These documents may also be viewed
electronically on the public computers
located at the NRC’s Public Document
Room (PDR), O–1F21, One White Flint
North, 11555 Rockville Pike, Rockville,
MD 20852. The PDR reproduction
contractor will copy documents for a
fee.
Dated at Arlington, Texas this 31st day of
March 2011.
For the Nuclear Regulatory Commission.
Jack E. Whitten,
Chief, Nuclear Materials Safety Branch B,
Division of Nuclear Materials Safety, Region
IV.
[FR Doc. 2011–8419 Filed 4–7–11; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
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 (FPP) must provide the
established level of protection as
intended by Section III.G of 10 CFR part
50, Appendix R.
By letter dated March 3, 2009,
‘‘Request for Exemption from 10 CFR 50,
Appendix R, Section III.G, ‘Fire
Protection of Safe Shutdown Capability
(Phase 1)’ ’’ available at Agencywide
Documents Access and Management
System (ADAMS), Accession No.
ML090630132, and supplemented by
letter dated April 2, 2010, ‘‘Response to
Request for Additional Information
Request for Exemption from 10 CFR 50,
Appendix R, Section III.G, ‘Fire
Protection of Safe Shutdown
Capability’ ’’ (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 21
plant Fire 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,
and TB–FZ–11H. These 21 plant areas
are the subject of this exemption.
[Docket No. 50–219; NRC–2010–0320]
3.0
Exelon Generation Company, LLC;
Oyster Creek Nuclear Generating
Station; Exemption
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,
srobinson on DSKHWCL6B1PROD with NOTICES
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.
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Discussion
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19795
which is consistent with the language
included in 10 CFR 50.12(a)(2)(ii).
In their March 3, 2009, and April 2,
2010, letters, the licensee discussed
financial implications associated with
plant modifications that may be
necessary to comply with the regulation.
10 CFR 50.12(a)2(iii) 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. 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
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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 of fire origin
1
2
3
4
5
6
7
CW–FA–14 ......
OB–FA–9 ........
OB–FZ–6A ......
OB–FZ–6B ......
OB–FZ–8A ......
OB–FZ–8B ......
OB–FZ–8C ......
Area name
Actions
Circulatory Water Intake .................................................
Manually open valve (V) V–9–2099 and V–11–49 and
close V–11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Office Building (Bldg.) Elev. 23′-6″, 35′-0″, 46′-6″ .........
Office Bldg. ‘‘A’’ 480V Switchgear (SWGR) Room Elev.
23′-6″.
Office Bldg. ‘‘B’’ 480V SWGR Room Elev. 23′-6″ ..........
Office Bldg. Reactor Recirculation Motor Generator
(MG) Set Room Elev. 23′-6″.
Office Bldg. Mechanical Equipment Room Elev. 35′-0″
Office Bldg. A/B Battery Room, Tunnel and Electrical
Tray Room Elev. 35′-0″.
Locally read Condensate Storage Tank level at level indicator (LI) LI–424–993 due to damage to control circuits.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Locally read condensate storage tank (CST) level at
LI–424–993 due to damage to control circuits.
Use Remote Shutdown Panel (RSP) to control equipment: RSP, Control Rod Drive (CRD) Hydraulic
Pump NC08B and 480V USS 1B2 Incoming breaker
(Operate USS 1B2/CRD Transfer Switch (Partial initiation) to ‘‘Alternate’’ and operate Control Switches for
USS–1B2 Main Breaker and B CRD Pump).
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI) FI–225–2 and close V–15–52.
Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Locally read Condensate Storage Tank level at LI–
424–993 due to damage to control circuits.
Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Use Local Shutdown Panels to control equipment as
follows: LSP–1A2, CRD Hydraulic PP NC08A and
480V USS 1A2 Incoming breaker (Operate transfer
switch ‘‘Alternate’’ and operate Control Switch for
USS–1A2 Main Breaker 1A2M and A CRD Pump).
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Trip all five Reactor Recirculation Pumps (NG01–A,
NG01–B, NG01–C, NG01D and NG01E). Also, lockout the 4160V breakers using local switch.
OMA
No.
7
12
2
12
2
9
12
7
12
7
12
7
12
2
7
8
12
16
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8
OB–FZ–10A ....
Office Bldg. Monitor and Change Room Area and Operations Support Area Elev. 35′-0″ & 46′-6″.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
12
9
RB–FZ–1D ......
Reactor Bldg. Elev. 51′-3″ ..............................................
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52;.
12
10
RB–FZ–1E ....
Reactor Building Elev. 23′-6″ ..........................................
Read CRD local flow gauge FI–225–998 .......................
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
11
12
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TABLE 1—Continued
Area of fire origin
Area name
Actions
OMA
No.
11
RB–FZ–1F3 ...
Reactor Bldg. Northwest Corner Elev.-19′-6″ .................
Open Core Spray System II manual valves V–20–1
and V–20–2 and close V–20–4.
13
12
RB–FZ–1F5 ...
Reactor Bldg. Torus Room Elev. -19′-6″ ........................
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
12
13
RB–FZ–1G ....
Reactor Bldg. Shutdown Cooling Room Elev. 38′-0″ &
51′-3″.
Read CRD local flow gauge FI–225–998 .......................
11
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
12
14
TB–FA–3A .....
Turbine Bldg. 4160V Emergency SWGR Vault 1C Elev.
23′-6″.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
12
15
TB–FA–26 .....
Turbine Bldg. 125V DC Battery Room C Elev. 23′-6″ ...
Manually trip 4160V 1D Breakers and control USS 1B2
and 1B3 480V Breakers locally at LSP–1D.
Manually control 1B3M Breaker from LSP–1B3 .............
Manually re-close motor control center (MCC) 1B32
Feeder Breaker at USS 1B3.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
1
16
17
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18
19
TB–FZ–11B ...
TB–FZ–11C ...
TB–FZ–11D ...
TB–FZ–11E ...
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Turbine Bldg. Lube Oil Storage, Purification and Pumping Area Elev. 0′-0″, 27′-0″, and 36′-0″.
Turbine Bldg. SWGR Room 1A and 1B Elev. 23′-6″ .....
Turbine Bldg. Basement Floor South End Elev. 3′-6″ ....
Turbine Bldg. Condenser Bay Area Elev. 0′-0″ ..............
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Manually trip 4160V 1D Breakers and control USS 1B2
and 1B3 480V Breakers locally at LSP–1D.
Locally read Condensate Storage Tank level at LI–
424–993.
Manually control 1B3M Breaker from LSP–1B3 .............
Local Shutdown Panels used to control equipment as
follows: LSP–1B32 Condensate Transfer Pump 1–2
(Operate transfer switch to ‘‘Alternate’’ and operate
Control Switch for Condensate Transfer Pump 1–2).
Manually re-close MCC 1B32 Feeder Breaker at USS
1B3.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Trip all five Reactor Recirculation Pumps (NG01–A,
NG01–B, NG01–C, NG01D and NG01E). Also, lockout the 4160V breakers using local switch.
Manually trip 4160V 1D Breakers and control USS 1B2
and 1B3 480V Breakers locally at LSP–1D.
Manually control 1B3M Breaker from LSP–1B3 .............
Manually re-close MCC 1B32 Feeder Breaker at USS
1B3.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Manually trip 4160V 1D Breakers and control USS 1B2
and 1B3 480V Breakers locally at LSP–1D.
Manually control 1B3M Breaker from LSP–1B3 .............
Local Shutdown Panels are used to control equipment
as follows: LSP–DG2, EDG2 and its Switchgear (Operate transfer Switches (3 total) to ‘‘Alternate’’ and
operate Control Switch on Diesel Panel to start diesel).
Manually re-close MCC 1B32 Feeder Breaker at USS
1B3.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Manually trip 4160V 1D Breakers and control USS 1B2
and 1B3 480V Breakers locally at LSP–1D.
Locally read Condensate Storage Tank level at LI–
424–993.
Manually control 1B3M Breaker from LSP–1B3 .............
Local Shutdown Panels used to control equipment as
follows: LSP–1B32 Condensate Transfer Pump 1–2
(Operate transfer switch to ‘‘Alternate’’ and operate
Control Switch for Condensate Transfer Pump 1–2).
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6
12
1
2
3
4
6
12
16
1
3
6
12
1
3
5
6
12
1
2
3
4
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TABLE 1—Continued
Area of fire origin
Area name
Actions
Local Shutdown Panels are used to control equipment
as follows: LSP–DG2, EDG2 and its Switchgear (Operate transfer Switches (3 total) to ‘‘Alternate’’ and
operate Control Switch on Diesel Panel to start diesel).
Manually re-close MCC 1B32 Feeder Breaker at USS
1B3.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Trip all five Reactor Recirculation Pumps (NG01–A,
NG01–B, NG01–C, NG01D and NG01E) Also, lockout the 4160V breakers using the 69 Switch.
20
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21
TB–FZ–11F ...
TB–FZ–11H ...
Turbine Bldg. Feedwater Pump Room Elev. 0′-0″ & 3′6″.
Turbine Bldg. Demineralizer Tank and Steam Jet Air
Ejector Area Elev. 3′-6″ & 23′-6″.
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
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Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
Manually open V–9–2099 and V–11–49 and close V–
11–63 and V–11–41.
Manually open V–15–237, throttle V–15–30 using local
flow indicator (FI–225–2) and close V–15–52.
protection commensurate with that
intended by III.G.2.
The 21 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, OB–FZ–6B, and TB–FA–26
have been classified as having 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 (UL), 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
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OMA
No.
5
6
12
16
7
12
7
12
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,
‘‘Implementation of Fire Protection
Requirements,’’ 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
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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 the table
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 Fire Area 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.
srobinson on DSKHWCL6B1PROD with 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 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.
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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
Area
OMAs Credited for a Fire in This
3.1.4.1 OMA #7—Align the Fire Water
System to the Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. Unit
Substation Transformer (USS) 1B3 is
located in the outside area on the west
side of the power block on a raised
concrete foundation that sits
approximately 5 feet above grade. USS
1B3 is considered as a potential ignition
source as well as its associated adjacent
transformer, USS 1A3, which is located
approximately 15 feet west of USS 1B3.
Both of these unit substations are
located approximately 20 feet from any
plant operating equipment (e.g.,
circulating water pump motor, etc.).
Additionally, the need to perform this
OMA would likely be apparent in the
control room based on the loads that are
lost (e.g., control room ventilation,
service water pump, etc.) and a fire at
USS 1B3 would be visible from the
security tower monitoring the area.
In the unlikely event that a fire does
occur and causes the loss of USS 1B3 or
its associated cables, OMA #7 is
available to manually open V–9–2099
and V–11–49 and close V–11–63 and V–
11–41 to align the fire water system for
make-up water to Isolation Condenser
‘‘B’’ since there is no power (‘‘B’’ Train)
available to the Condensate Transfer
System. 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.
3.1.4.2 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
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.
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The licensee also 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
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.
The licensee stated that OMA #12
essentially duplicates the Emergency
Operating Procedure (EOP) actions for
reactor pressure vessel (RPV) level
control. Therefore, if a fire did occur
and was not immediately discovered,
any delay in the entry into the
appropriate Fire Support Procedure
(FSP) or delay in suppression of the fire
would not significantly affect the
performance of this OMA, since the
EOPs would direct the same action to be
performed if required.
3.1.5
Conclusion
Given the combustion resistant
properties of the most probable
combustible materials, limited ignition
sources, and open nature of the area, it
is unlikely that a fire would occur, go
undetected or unsuppressed by station
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 #7
and #12 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 Fire Area 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 OB–FA–9 has
an administrative fire loading limit of
less than 1.5 hours as determined by the
time-temperature curve contained in
American Society of Testing and
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Materials standard E119, ‘‘Standard Test
Methods for Fire Tests of Building
Construction and Materials’’ (ASTM
E119), and 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 an area-wide 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 the MUX
corridor within 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.
srobinson on DSKHWCL6B1PROD with NOTICES
3.2.4
Area
OMAs Credited for a Fire in This
3.2.4.1 OMA #2—Read Condensate
Storage Tank (CST) Local Level
Indicator LI–424–993
In order for OMA #2 to be necessary,
the primary CST level indicator (5F–27)
would have to fail as a result of the fire.
Should this occur, indication can only
be obtained by reading the local
indicator (LI–424–993) located at the
CST. The licensee stated that the safe
shutdown success path structure,
system, or component (SSC) cable for
the level indicator is routed in a cable
tray located approximately 12 feet above
the floor in this area (MUX corridor).
The cable enters the room in the
northwest corner and is routed in a
cable tray for approximately 15 feet. It
then air drops vertically down into the
MUX enclosure. The credited cable is
routed in a cable tray with other cables
and is routed through the wooden
ceiling, which also has some rubber
piping insulation on top of the ceiling,
thus putting the cable in close proximity
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to in situ combustibles. However, there
are no ignition sources in this area.
Therefore, due to the lack of ignition
sources, it is not expected that a fire
would occur in this area and it is
unlikely that the OMA would be
required.
In the unlikely event that a fire does
occur and causes the loss of the primary
CST level indicator, OMA #2 is
available to locally read CST level at the
local level indicator, LI–424–993. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 7 minutes while the time
available is 73 minutes, which provides
a 36-minute margin.
3.3 OB–FZ–6A Office Bldg. ‘‘A’’ 480V
Switchgear (SWGR) Room Elev. 23′–6″
3.2.4.2 OMA #12—Establish Control
Rod Drive (CRD) Flow to Reactor
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).
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
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.
3.2.5
Conclusion
Given the limited amount of
combustible materials, ignition sources,
and sufficient 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 OMAs #2
and #12 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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3.3.1 Fire Prevention
The licensee has classified the fire
loading in this fire zone as moderate.
The licensee also stated that this area
has an administrative fire loading limit
of less than 3 hours as determined by
the ASTM E119 time-temperature curve.
The main combustibles in this area are
cable insulation (approximately 81% of
loading) and Dow Corning 561 Silicon
transformer liquid (approximately 15%
of loading). Additionally, the
transformer liquid has characteristics
that minimize the likelihood of a fire
involving the insulating liquid itself.
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 #2—Read Condensate
Storage Tank Local Level Indicator LI–
424–993
In order for OMA #2 to be necessary,
the primary CST level indicator (5F–27)
would have to fail as a result of the fire.
Should this occur, indication can only
be obtained by reading the local
indicator (LI–424–993) located at the
CST. The licensee stated that the safe
shutdown success path cable for the
level indicator is routed in a conduit
that leaves a 120 VAC distribution panel
and travels approximately 5 feet
vertically to a cable tray that is
approximately 9 feet above the floor.
The cable is routed with other cables in
the cable tray for approximately 15 feet
at which point the cable tray travels up
through the ceiling. The liquid filled
transformer is located approximately 10
feet north of the cable. However, there
is a partial non-rated concrete block
wall between the transformer and cable
tray that would provide some protection
of direct flame impingement or radiant
heat transfer on the cable tray. The
ignition sources in this fire zone consist
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of enclosed metal electrical cabinets
(120 VAC and 125 VDC circuits) and the
liquid filled transformer (4160 VAC to
480 VAC).
In the unlikely event that a fire does
occur and damages the primary CST
level indicator, OMA #2 is available to
locally read CST level at local indicator
LI–424–993. The licensee also stated
that they have assumed a 30-minute
diagnosis period and that the required
time to perform the action is 7 minutes
while the time available is 73 minutes,
which provides a 36-minute margin.
srobinson on DSKHWCL6B1PROD with NOTICES
3.3.4.2 OMA #9—Manually Control
480V Breakers From Remote Shutdown
Panel
In order for OMA #9 to be necessary,
damage to the credited and redundant
cables would have to occur due to a fire.
The licensee stated that the credited and
redundant cables are located in the
same cable tray with additional cables
and that the tray is located
approximately 7 feet above the floor.
Other than the cables themselves, the
primary combustible in this area is a
liquid filled transformer, which is
located approximately 7 feet from the
cable tray. The licensee also stated that
the ignition sources in this fire zone
consist of electrical cabinets (120 VAC
and 125 VDC circuits) and the liquid
filled transformer (4160 VAC to 480
VAC). The electrical cabinets are
enclosed metal cabinets, which are
located approximately 2 feet from the
credited and redundant cables in some
locations.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #9 is available
to manually control the 480V USS 1B2
breakers for CRD Pump NC08B and
1B2M from the Remote Shutdown
Panel. The licensee also stated that they
have assumed a 30-minute diagnosis
period and that the required time to
perform the action is 13 minutes while
the time available is 180 minutes, which
provides a 137-minute margin.
3.3.4.3 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
control valve to be unavailable due to a
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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.
3.3.5 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 OMAs #2,
#9, and #12 to manipulate the plant in
the event of a fire that damages safe
shutdown equipment, provide adequate
assurance that safe shutdown capability
is maintained.
3.4 OB–FZ–6B Office Building ‘‘B’’
480V SWGR Room Elev. 23′–6″
3.4.1 Fire Prevention
The licensee has classified the fire
loading in this fire zone as moderate.
The licensee also stated that this area
has an administrative fire loading limit
of less than 2 hours as determined by
the ASTM E119 time-temperature curve.
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). Also,
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
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19801
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 #7—Align the Fire Water
System to the Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. Motor
control center (MCC) 1B21 is located
approximately 5 feet from USS 1B2. The
licensee indicated that a credited power
cable for the static charger enters the fire
zone through the ceiling of the corridor
and then enters the main portion of the
room through the north wall
approximately 9 feet above the floor. It
then runs east and down into MCC
1B21. The cable is located
approximately 2 feet above the potential
ignition source, USS 1B2, and runs
directly into ignition source MCC 1B21.
The credited power cable for MCC 1B21
is routed from USS 1B2 to MCC 1B21
in a cable tray. This cable tray runs
approximately 10 feet above the floor
and approximately 2 feet above the
potential ignition sources, USS 1B2 and
MCC 1B21, but it also enters into both
as indicated above. However, both of
these ignition sources are contained in
enclosed metal cabinets and are not
high voltage. The cable tray is also
located approximately 10 feet from the
ignition source of the USS 1B2
transformer, which is located near the
west end of the room.
The licensee also indicated that the
‘‘A’’ train of power is credited and
available for this fire zone and that the
redundant cable is associated with the
‘‘C’’ battery charger, which is fire
wrapped with a 1-hour barrier in this
fire zone. It is unlikely that a fire would
develop and cause damage to multiple
redundant pieces of equipment given
the spatial relationship between the
credited equipment and ignition
sources, the presence of the automatic
Halon system, and the protected ‘‘C’’
battery charger cable.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–9–2099 and V–11–
49 and close V–11–63 and V–11–41 to
align the fire water system for make-up
water to Isolation Condenser ‘‘B’’ since
there is no power (‘‘B’’ Train) available
to the Condensate Transfer System. 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
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available is 45 minutes, which provides
a 22-minute margin.
3.4.4.2 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
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.
In the unlikely event that a fire does
occur and damages multiple redundant
trains, OMAs #7 and #12 are available
to align the fire water system to the
isolation condenser and establish CRD
flow. The locations of these OMAs are
in separate fire areas from Fire Area
OB–FZ–6B so a fire in Fire Area OB–
FZ–6B would not impact the locations
of the actions.
srobinson on DSKHWCL6B1PROD with NOTICES
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 zone,
combined with the ability of OMAs #7
and #12 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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3.5 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 (FSSD)
analysis due to the lack of rated fire
barriers between the zones. The licensee
has classified the fire loading in these
fire zones as low. The licensee also
stated that these fire zones have an
administrative fire loading limit of less
than 45 minutes as determined by the
ASTM E119 time-temperature curve.
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
these Zones
3.5.4.1 OMA #7—Align the Fire Water
System to the Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. The
licensee indicated that the cable for the
125 VDC control power is in conduit
that enters this zone through the ceiling
in the northwest corner and then travels
south along the ceiling near the west
wall approximately 9 feet above the
floor and approximately 7 feet from the
primary ignition sources in the area, the
motor-generator (MG) Sets, and then
leaves through the floor, where it runs
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within 2 feet of the ‘‘E’’ MG–Set. The
licensee also indicated that the ‘‘A’’ train
of power is credited and available for
this fire zone and that the redundant
cable is associated with the ‘‘C’’ battery
and this cable is not located in this fire
zone.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–9–2099 and V–11–
49 and close V–11–63 and V–11–41 to
align the fire water system for make-up
water to Isolation Condenser ‘‘B’’ since
there is no power (‘‘B’’ Train) available
to the Condensate Transfer System. 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.
3.5.4.2 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
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.
3.5.5 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 due to a fire in this zone,
combined with the ability of OMAs #7
and #12 to manipulate the plant in the
event of a fire that damages safe
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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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this fire zone
has an administrative fire loading limit
of less than 1.5 hours as determined by
the ASTM E119 time-temperature curve.
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.
srobinson on DSKHWCL6B1PROD with NOTICES
3.6.4 OMAs Credited for a Fire in This
Zone
3.6.4.1 OMA #2—Read Condensate
Storage Tank Local Level Indicator LI–
424–993
In order for OMA #2 to be necessary,
damage to the primary CST level
indicator (5F–27) cable would have to
occur due to a fire. Should this occur,
indication can only be obtained by
reading the local indicator (LI–424–993)
located at the CST. Although there is no
redundant train of equipment for the
credited source of obtaining CST level
Indication, the licensee stated that the
tray containing the credited train is
located in the Electric Tray Room
portion of the zone, which is separated
from the main battery room by a cable
tunnel that is approximately 25 feet
long. The licensee also stated that the
credited cable runs in a cable tray with
other cables, thus putting it in close
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proximity to in-situ hazards, however,
due to the size and use of the room,
there are no other credible hazards
including transient combustibles.
In the unlikely event that a fire does
occur and causes the loss of the primary
CST level indicator, OMA #2 is
available to locally read CST level at the
local level indicator, LI–424–993. The
licensee also stated that they have
assumed a 30-minute diagnosis period
and that the required time to perform
the action is 7 minutes while the time
available is 73 minutes, which provides
a 36-minute margin.
3.6.4.2 OMA #7—Align Fire Water to
Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. The
licensee indicated that the credited
cable is located in the A/B Battery Room
portion (main portion) of this fire zone
and that the credited cable runs in a
conduit that begins at 125V DC
Distribution Panel B. The cable is routed
in a conduit that runs approximately 1
foot above a series of vertical cable
trays, approximately 8 feet above the ‘‘B’’
MG Set, and approximately 3 feet over
the top of the 125V DC ‘‘B’’ Distribution
Center. However, the ‘‘B’’ MG Set is not
normally energized since the static
charger is utilized normally for charging
the ‘‘B’’ Battery. The licensee also
indicated that the battery banks are
another potential ignition source in the
room but that they are located greater
than 15 feet from the particular conduit
in question but that the failure of the
battery itself may also require the OMA.
The ‘‘A’’ train of power is credited and
available for this fire zone. The
redundant cable, ‘‘C’’ battery, ‘‘C’’
Distribution center, etc. are not located
in this fire zone.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–9–2099 and V–11–
49 and close V–11–63 and V–11–41 to
align the fire water system for make-up
water to Isolation Condenser ‘‘B’’ since
there is no power (‘‘B’’ Train) available
to the Condensate Transfer System. 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.
3.6.4.3 OMA #8—Manually Control
USS 1A2 ‘‘A’’ CRD Pump & 1A2M From
LSP–1A2
In order for OMA #8 to be necessary,
damage to the credited control cables,
1A2M & A CRD Pump, and the
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redundant control cables, 1B2M and B
CRD Pump, would have to occur due to
a fire. The licensee stated that the
credited and redundant cables are run
in the same cable tray with additional
cables in the Electric Tray Room portion
of this fire area and are separated from
the main battery room by a cable tunnel
that is approximately 25-feet long. With
the exception of the cables themselves,
there are no other combustibles or
ignition sources and the storage of
transient combustibles in this portion of
the fire zone is remote since it is a small
room with only one door for access or
egress.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #8 is available
to manually control the 480V USS 1A2
breakers for ‘‘A’’ CRD Pump and 1A2M
from LSP–1A2. 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 60 minutes,
which provides a 22-minute margin.
3.6.4.4 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
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.
3.6.4.5 OMA #16—Manually Trip Rx
Recirculation Pumps at 4160V
Switchgear
In order for OMA #16 to be necessary,
damage to the credited cables for
tripping the recirculation pumps or the
loss of the 125 VDC ‘‘B’’ Battery and ‘‘B’’
Distribution Center would have to occur
due to a fire. The licensee stated that the
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cable tray configuration in the A/B
Battery Room is a series of vertical trays
closely stacked together and that the
trays containing the required equipment
are located approximately 4 feet from
the ‘‘B’’ MG Set. However, the ‘‘B’’ MG
Set is not normally energized since the
static charger is utilized normally for
charging the ‘‘B’’ Battery. The licensee
also stated that other than the cables
themselves, there are no other
combustibles or ignition sources in the
area and that the placement of transient
combustibles is remote since access is
limited and the rooms are small in size.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #16 is available
to manually trip Reactor Recirculation
Pumps (‘‘A,’’ ‘‘C,’’ and ‘‘E’’) 4160V
Switchgear 1A and 1B. 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 30
minutes, which provides a 7-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 OMAs #2,
#7, #8, #12, and #16 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″
srobinson on DSKHWCL6B1PROD with NOTICES
3.7.1
Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
The major combustibles in this area are
cable insulation (approximately 27% of
loading), rubber flooring (approximately
31% of loading), miscellaneous plastics
(approximately 15% of loading) and
protective clothing supplies
(approximately 20% of loading).
However, since the protective clothing
supplies have been placed in metal cans
with self-closing lids they are no longer
considered a contribution to the
combustibles in this area.
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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.
3.7.4 OMAs Credited for a Fire in This
Zone
3.7.4.1 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
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 18 minutes, while
the time available is 204 minutes, which
provides a 156-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 #12
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Sfmt 4703
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
3″
RB–FZ–1D Reactor Bldg. Elev. 51′–
3.8.1 Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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 safetyrelated 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 trays 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.
3.8.4 OMAs Credited for a Fire in This
Zone
3.8.4.1 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
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
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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.
3.8.5 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 zone,
combined with the ability of OMA #12
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 RB–FZ–1E Reactor Bldg. Elev.
51′-3″
srobinson on DSKHWCL6B1PROD with NOTICES
3.9.1 Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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 safetyrelated 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 trays and smoke detectors are
located in each beam pocket at the
ceiling.
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
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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 #11—Locally Read CRD
Flow Gauge FI–225–998
In order for OMA #11 to be necessary,
the normal local gauge for CRD flow, FI–
225–2, would have to be damaged by
fire. The licensee stated that there are no
in-situ combustibles present in the
immediate area surrounding the gauge
and that the placement of transient
combustibles is remote since the gauge
is surrounded by piping and tubing. The
licensee also stated that the nearest
ignition source is MCC 1A21B, which is
located approximately 8 feet from the
flow gauge. However, the solid steel rear
of the MCC faces the flow gauge making
it highly unlikely that this potential
ignition source would adversely impact
the flow gauge.
OMA #11 would require re-entry into
Fire Zone RB–FZ–1E to manually
control CRD System valves V–15–237,
V–15–30, and V–15–52 located in this
fire zone while monitoring flow at FI–
225–998 to establish CRD flow to the
reactor due to the loss of instrument air
to the CRD flow control valve. Fusing of
the unprotected CRD valves by heat
from a fire resulting in the valves
becoming inoperable is not considered
credible because of the low fire loading,
the provision of automatic fire detection
and suppression capability and the heat
sink capability of the water filled piping
connected to the valve. Operation of one
of the valves that is in close proximity
to these valves was previously approved
in the exemption discussed above.
In the unlikely event that a fire occurs
and this flow gauge becomes
unreadable, OMA #11 is available to
locally read flow gauge FI–225–998,
which is the redundant instrument that
provides the same data and is mounted
on an instrument rack located in Fire
Zone RB–FZ–1D. The licensee also
stated that they have assumed a 30minute diagnosis period and that the
required time to perform the action is
100 minutes, including a 90-minute
allowance before re-entry, while the
time available is 204 minutes, which
provides a 74-minute margin.
3.9.4.2 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
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19805
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
control valve to be unavailable due to a
loss of instrument air or cable damage,
OMA #12 is available to reenter RB–FZ–
1E and 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 100 minutes,
including a 90-minute allowance before
re-entry, while the time available is 204
minutes, which provides a 74-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
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 #11
and #12 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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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
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3.11 RB–FZ–1F5 Reactor Bldg. Torus
Room Elev. -19′-6″
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 #13—Manually Align
Core Spray to CST To Provide Reactor
Coolant Makeup
In order for OMA #13 to be necessary,
both CRD pumps located in this area
would have to become damaged due to
a fire. The licensee stated that the
pumps are separated by a horizontal
distance of approximately 6 feet and
that the associated cables and conduits
are in close proximity to each other. The
licensee also stated that the primary
ignition sources in the area, aside from
the pumps themselves, are located
approximately 18 feet from the CRD
pumps.
In the unlikely event that a fire occurs
and causes damage to both pumps,
OMA #13 is available to re-enter this
fire zone and manually open Core Spray
valves V–20–1 and V–20–2 and close V–
20–4 (V–20–2 and V–20–4 are located in
Fire Zone RB–FZ–1F2) to provide
Reactor Coolant Makeup from the CST
for Fire Zone RB–FZ–1F3. The licensee
also stated that they have assumed a 30minute diagnosis period and that the
required time to perform the action is 35
minutes while the time available is 204
minutes, which provides a 139-minute
margin.
srobinson on DSKHWCL6B1PROD 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 zone, combined with
the ability of OMA #13 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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3.11.1 Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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 a detection or
suppression systems. The NRC staff
finds that the, because of the low
amount of combustible material in the
area and low flame spread rating of the
majority of this material, 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 11450 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 #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
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
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Sfmt 4703
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.
3.11.5
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 zone,
combined with the ability of OMA #12
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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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 1609
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.
3.12.4 OMAs Credited for a Fire in
This Zone
3.12.4.1 OMA #11—Locally Read CRD
Flow Gauge FI–225–998
In order for OMA #11 to be necessary,
the normal local gauge for CRD flow, FI–
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225–2, located in Fire Zone RB–FZ–1E
or its associated cables, would have to
be damaged by fire. The licensee stated
that there are no in-situ combustibles
present in the immediate area
surrounding the gauge and that the
placement or storage of transient
combustibles is remote since the gauge
is surrounded by piping and tubing. The
licensee also stated that the nearest
ignition source is MCC 1A21B, which is
located approximately 8 feet from the
flow gauge. However, the solid steel rear
of the MCC faces the flow gauge making
it highly unlikely that this potential
ignition source would adversely impact
the flow gauge.
In the unlikely event that a fire occurs
and this flow gauge becomes
unreadable, OMA #11 is available to
locally read flow gauge FI–225–998,
which is the redundant instrument that
provides the same data and is mounted
on an instrument rack located in Fire
Zone RB–FZ–1D. The licensee also
stated that they have assumed a 30minute diagnosis period and that the
required time to perform the action is
100 minutes, including a 90-minute
allowance before re-entry, while the
time available is 204 minutes, which
provides a 74-minute margin.
srobinson on DSKHWCL6B1PROD with NOTICES
3.12.4.2 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
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 100 minutes,
including a 90-minute allowance before
re-entry, while the time available is 204
minutes, which provides a 74-minute
margin.
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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 zone, combined with
the ability of OMAs #11 and #12 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 has classified the fire
loading in this fire area as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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.
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 #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.
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In the unlikely event that a fire does
occur and causes the normal flow
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.
3.13.5 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 #12
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 has classified the fire
loading in this fire area as moderate.
The licensee also stated that this area
has an administrative fire loading limit
of less than 90 minutes as determined
by the ASTM E119 time-temperature
curve. 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).
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.
Additionally, the licensee identified
that the battery cases are filled with
water which would provide some
resistance to combustion of the cases.
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
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FSSD component and cable located in
this fire area is associated with the ‘‘C’’
battery. Additionally, per the Oyster
Creek Updated Final Safety Analysis
Report, Section 8.3.2.4, the ‘‘B’’ 125V DC
distribution system is redundant to the
‘‘C’’ system and the two systems are
physically independent.
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 NRC staff’s evaluation of the
feasibility of OMAs #1, #3, #6, and #12,
which are common to both areas.
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, #3, #6, and #12 to manipulate
the plant in the event of a fire that
damages safe shutdown equipment,
provides adequate assurance that safe
shutdown capability is maintained.
srobinson on DSKHWCL6B1PROD with NOTICES
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 has classified the fire
loading in this fire zone as high. The
licensee also stated that this fire zone
has administrative controls such that
additional combustible materials are not
introduced into this zone and defensein-depth features to control a potential
oil fire in this zone. The major
combustibles in this area are lubricating
oil (approximately 99% of loading) and
cable insulation (approximately 0.3% of
loading). The amount of oil contained in
the lube oil storage tanks in this fire
zone results in a combustible loading of
approximately 14 hours.
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
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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
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 3,175 square
feet.
3.15.4 OMAs Credited for a Fire in
This Zone
3.15.4.1 OMA #1—Manually Trip
4160V 1D Breakers and Control USS
1B2 & 1B3 Breakers Locally at LSP–1D
In order for OMA #1 to be necessary,
damage to the credited and redundant
cables would have to occur 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 #1 is available
to manually trip the 4160V 1D breakers
and control USS 1B2 and the 1B3 480V
breakers locally at LSP–1D. The licensee
also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 19
minutes while the time available is 45
minutes, which provides a 16-minute
margin.
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3.15.4.2 OMA #2—Read Condensate
Storage Tank Local Level Indicator LI–
424–993
In order for OMA #2 to be necessary,
damage to the primary CST level
indicator (5F–27) cable would have to
occur due to a fire. The licensee stated
that this cable is located approximately
20 feet above the floor and that the
nearest primary ignition source in the
area, the lube oil tank, is located
approximately 7 feet below the cable.
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 primary CST
level indicator, OMA #2 is available to
locally read CST level at the local
indicator, LI–424–993, located at the
CST. The licensee also stated that they
have assumed a 30-minute diagnosis
period and that the required time to
perform the action is 7 minutes while
the time available is 73 minutes, which
provides a 36-minute margin.
3.15.4.3 OMA #3—Manually Control
1B3M Breaker at LSP–1B3
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 1B3M breaker
locally from LSP–1B3. The licensee also
stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 10
minutes while the time available is 45
minutes, which provides a 25-minute
margin.
3.15.4.4 OMA #4—Manually Control
Condensate Transfer Pump 1–2 from
LSP–1B32
In order for OMA #4 to be necessary,
damage to the credited and redundant
cables for the Condensate Transfer
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Pump 1–2 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 20 feet above the
floor and approximately 7 feet above the
lube oil tank.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #4 is available
to manually control Condensate
Transfer Pump 1–2 locally from LSP–
1B32. The licensee also stated that they
have assumed a 10-minute diagnosis
period and that the required time to
perform the action is 10 minutes while
the time available is 45 minutes, which
provides a 25-minute margin.
srobinson on DSKHWCL6B1PROD with NOTICES
3.15.4.5 OMA #6—Manually Reclose
Feeder Breaker MCC 1B32 at USS 1B3
In order for OMA #6 to be necessary,
power to USS 1B3 or the 1B 4160V
switchgear would have to be lost 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 causes a loss of power to USS
1B3 or a loss of the 1B 4160V
switchgear, OMA #6 is available to
manually re-close Feeder Breaker MCC
1B32 at USS 1B3 due to an under
voltage trip. The licensee also stated
that they have assumed a 10-minute
diagnosis period and that the required
time to perform the action is 6 minutes
while the time available is 45 minutes,
which provides a 29-minute margin.
3.15.4.6 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.
3.15.4.7 OMA #16—Manually Trip Rx
Recirculation Pumps at 4160V
Switchgear
In order for OMA #16 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 #16 is available
to manually trip Reactor Recirculation
Pumps (‘‘A,’’ ‘‘B,’’ ‘‘C,’’ ‘‘D’’ and ‘‘E’’)
4160V Switchgear 1A and 1B. 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 30 minutes, which provides
a 7-minute margin.
3.15.5 Conclusion
Although the fire loading for this zone
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
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
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the ability of OMAs #1, #2, #3, #4, #6,
#12, and #16 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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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
installed (except in the small caged area
located to the east of Fire Area TB–FA–
3A).
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 Zone
3.16.4.1 OMA #1—Manually Trip
4160V 1D Breakers and Control USS
1B2 & 1B3 Breakers Locally at LSP–1D
In order for OMA #1 to be necessary,
the credited cables for USS 1B2 and 1B3
4160V breakers and the redundant
cables for USS 1A2 and 1A3 breakers
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
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 #1 is available
to manually trip the 4160V 1D breakers
and control USS 1B2 and the 1B3 480V
breakers locally at LSP–1D. The licensee
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also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 24
minutes while the time available is 45
minutes, which provides an 11-minute
margin.
srobinson on DSKHWCL6B1PROD with NOTICES
3.16.4.3 OMA #3—Manually Control
1B3M Breaker at LSP–1B3
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
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 1B3M breaker
locally from LSP–1B3. The licensee also
stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 10
minutes while the time available is 45
minutes, which provides a 25-minute
margin.
3.16.4.5 OMA #6—Manually Reclose
Feeder Breaker MCC 1B32 at USS 1B3
In order for OMA #6 to be necessary,
power to USS 1B3 or the 1B 4160V
switchgear would have to be lost 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 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 causes a loss of power to USS
1B3 or a loss of the 1B 4160V
switchgear, OMA #6 is available to
manually re-close Feeder Breaker MCC
1B32 at USS 1B3 due to an under
voltage trip. The licensee also stated
that they have assumed a 10-minute
diagnosis period and that the required
time to perform the action is 6 minutes
while the time available is 45 minutes,
which provides a 29-minute margin.
3.16.4.6 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
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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
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.
3.16.5
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 zone,
combined with the ability of OMAs #1,
#3, #6, and #12 to manipulate the plant
in the event of a fire that damages safe
shutdown equipment, provides
adequate assurance that safe shutdown
capability is maintained.
3.17 TB–FZ–11D Turbine Bldg.
Basement Floor South End Elev. 3′-6″
3.17.1
Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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.
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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
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
3.17.4.1 OMA #1—Manually Trip
4160V 1D Breakers and Control USS
1B2 & 1B3 Breakers Locally at LSP–1D
In order for OMA #1 to be necessary,
the credited cables for USS 1B2 and 1B3
4160V breakers and the redundant
cables for USS 1A2 and 1A3 breakers
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
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 #1 is available
to manually trip the 4160V 1D breakers
and control USS 1B2 and the 1B3 480V
breakers locally at LSP–1D. The licensee
also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 24
minutes while the time available is 45
minutes, which provides an 11-minute
margin.
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3.17.4.2 OMA #3—Manually Control
1B3M Breaker at LSP–1B3
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
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 1B3M breaker
locally from LSP–1B3. The licensee also
stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 10
minutes while the time available is 45
minutes, which provides a 25-minute
margin.
srobinson on DSKHWCL6B1PROD with NOTICES
3.17.4.3 OMA #5—Manually Control
Diesel Generator #2 from LSP–DG2
In order for OMA #5 to be necessary,
damage to the credited and redundant
cables for Diesel Generator #1 and #2
would have to occur due to a fire. The
licensee stated that the credited and
redundant cables are located in the
same cable trays, in some areas, with
additional cables and that the cable
trays are approximately 17 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.
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The licensee also stated that the
primary ignition sources in the area are
the Turbine Building Closed Cooling
Water Pumps and USS 1A1 and its
associated transformer. The licensee
stated that the Turbine Building Closed
Cooling Water Pumps contain less than
5 gallons of oil, are enclosed in metal
casings, and are located approximately
13 feet from the cable tray containing
the credited and redundant cables.
Additionally, USS 1A1 and its
associated transformer are located
approximately 8 feet directly below
some of the credited cables for Diesel
Generator #2, however, the redundant
cables are approximately 25 feet from
this portion of the credited cables.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #5 is available
to manually control Emergency Diesel
Generator #2 from LSP–DG2. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 14 minutes while the time
available is 45 minutes, which provides
a 21-minute margin.
3.17.4.4 OMA #6—Manually Reclose
Feeder Breaker MCC 1B32 at USS 1B3
In order for OMA #6 to be necessary,
power to USS 1B3 or the 1B 4160V
switchgear would have to be lost 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 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
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ceiling beam and the USS 1A1 and
transformer.
In the unlikely event that a fire does
occur and causes a loss of power to USS
1B3 or loss of the 1B 4160V switchgear,
OMA #6 is available to manually reclose Feeder Breaker MCC1B32 at USS
1B3 due to an under voltage trip. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 6 minutes while the time
available is 45 minutes, which provides
a 29-minute margin.
3.17.4.5 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
although the USSs powering the air
compressors are located 35 feet apart
from each other, the power cables are
located in the same cable trays for at
least 45 feet and 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
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.
3.17.5 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,
#3, #5, #6, and #12 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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3.18 TB–FZ–11E Turbine Bldg.
Condenser Bay Area Elev. 0′-0″
3.18.4 OMAs Credited for a Fire in
This Zone
3.18.1
3.18.4.1 OMA #1—Manually Trip
4160V 1D Breakers and Control USS
1B2 & 1B3 Breakers Locally at LSP–1D
In order for OMA #1 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 #1 is available
to manually trip the 4160V 1D breakers
and control USS 1B2 and the 1B3 480V
breakers locally at LSP–1D. The licensee
also stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 19
minutes while the time available is 45
minutes, which provides a 16-minute
margin.
Fire Prevention
The licensee has classified the fire
loading in this fire zone as low. The
licensee also stated that this Fire Zone
is procedurally controlled as a transient
combustible free area while the plant is
operating. This area is a high radiation
area during plant operation and is not
normally accessed. The zone has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
The major combustibles in this area are
cable insulation (approximately 40% of
loading) and plastic (approximately
59% of loading). Plastic grating, which
is the largest plastic material in this
zone, is dispersed throughout this fire
zone (not concentrated) and has a low
flame spread (less than 25).
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 (SEs) dated
March 24, 1986, and June 25, 1990, for
not having fixed fire detection in this
area. The primary basis for this
exemption is the presence of the
automatic wet pipe sprinkler system,
low fire loading and the 1-hour barrier
protection for safe shutdown circuits.
Also, the flow alarm will notify the
control room of any sprinkler system
activation. Since the Condenser Bay is
procedurally controlled as a transient
combustible free area in procedure OP–
AA–201–009 while the plant is
operating. Extinguishment of a fire will
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.
srobinson on DSKHWCL6B1PROD with NOTICES
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 26427
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.
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3.18.4.2 OMA #2—Read Condensate
Storage Tank Local Level Indicator LI–
424–993
In order for OMA #2 to be necessary,
damage to the primary CST level
indicator (5F–27) cable would have to
occur due to a fire. The licensee stated
that this cable is located approximately
16 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 primary CST
level indicator, OMA #2 is available to
locally read CST level at the local
indicator, LI–424–993, located at the
CST. The licensee also stated that they
have assumed a 30-minute diagnosis
period and that the required time to
perform the action is 7 minutes while
the time available is 73 minutes, which
provides a 36-minute margin.
3.18.4.3 OMA #3—Manually Control
1B3M Breaker at LSP–1B3
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
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redundant cables, OMA #3 is available
to manually control the 1B3M breaker
locally from LSP–1B3. The licensee also
stated that they have assumed a 10minute diagnosis period and that the
required time to perform the action is 10
minutes while the time available is 45
minutes, which provides a 25-minute
margin.
3.18.4.4 OMA #4—Manually Control
Condensate Transfer Pump 1–2 From
LSP–1B32
In order for OMA #4 to be necessary,
damage to the credited and redundant
cables for the Condensate Transfer
Pump 1–2 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 18 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 #4 is available
to manually control Condensate
Transfer Pump 1–2 locally from LSP–
1B32. The licensee also stated that they
have assumed a 10-minute diagnosis
period and that the required time to
perform the action is 10 minutes while
the time available is 45 minutes, which
provides a 25-minute margin.
3.18.4.5 OMA #5—Manually Control
Diesel Generator #2 from LSP–DG2
In order for OMA #5 to be necessary,
damage to the credited and redundant
cables would have to occur due to a fire.
The licensee stated that the credited and
redundant cables are located in separate
cable trays separated by a horizontal
distance of at least 90 feet. The licensee
also stated that there are no ignition
sources near the redundant cables and
that the primary ignition sources that
could affect the credited cables are the
moisture separator drain pumps and
area sump pumps, which are located on
the floor approximately 20 feet
horizontally and 17 feet vertically from
the credited cables.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #5 is available
to manually control Emergency Diesel
Generator #2 from LSP–DG2. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 14 minutes while the time
available is 45 minutes, which provides
a 21-minute margin.
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srobinson on DSKHWCL6B1PROD with NOTICES
3.18.4.6 OMA #6—Manually Reclose
Feeder Breaker MCC 1B32 at USS 1B3
In order for OMA #6 to be necessary,
power to USS 1B3 or the 1B 4160V
switchgear would have to be lost due to
a fire. The licensee stated that the cables
that could cause the loss of USS 1B3 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 causes a loss of power to USS
1B3 or loss of the 1B 4160V switchgear,
OMA #6 is available to manually reclose Feeder Breaker MCC 1B32 at USS
1B3 due to an under voltage trip. The
licensee also stated that they have
assumed a 10-minute diagnosis period
and that the required time to perform
the action is 6 minutes while the time
available is 45 minutes, which provides
a 29-minute margin.
3.18.4.7 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
although the USSs powering the air
compressors are located 35 feet apart
from each other, the power cables are
located in the same cable trays for at
least 45 feet and 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
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.
3.18.4.8 OMA #16—Manually Trip Rx
Recirculation Pumps at 4160V
Switchgear
In order for OMA #16 to be necessary,
the credited and redundant cables
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would have to be damaged due to a fire.
The licensee stated that the credited
cables for tripping the recirculation
pumps are located in the same tray, or
adjacent 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 #16 is available
to manually trip Reactor Recirculation
Pumps (‘‘A,’’ ‘‘B,’’ ‘‘C,’’ ‘‘D’’ and ‘‘E’’)
4160V Switchgear 1A and 1B. 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 30 minutes, which provides
a 7-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 #1,
#2, #3, #4, #5, #6, #12, and #16 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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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 which 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
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19813
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 5,650 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.
3.19.4 OMAs Credited for a Fire in
This Area
3.19.4.1 OMA #7—Align Fire Water to
Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. The
loss of the ‘‘B’’ Train of power is
attributed to the fact that the 125 VDC
control power could be lost to the 1D
4160V Switchgear or the 1D 4160V main
breaker could trip due to cables that
traverse through this fire zone. The
licensee stated that the cables for the
125 VDC control power and the control
circuit for the 1D main breaker are
contained in separate conduits but are
routed within approximately 6 inches of
each other in a portion of this zone and
that the conduits are located
approximately 5 to 18 feet above the
floor. Additionally, the licensee stated
that the 125 VDC control cable leaves
the zone through the east wall into Fire
Zone RB–FZ–1F2 while the 1D main
breaker control cable continues along
the east wall near the floor through the
remaining portion of this zone and rises
up to approximately 6 feet from the
floor where it exits the zone.
The licensee also stated that the
primary ignition sources in the area are
the feedwater pumps and motors, which
are located approximately 10 feet from
the conduits. Transient combustibles are
controlled by administrative procedures
and although the accumulation of
transient combustibles along the east
wall of the area could potentially impact
the cables, the majority of the conduits
are routed such that it would be
unlikely that a fire in this area would
adversely impact the cables in the
conduit. The ‘‘A’’ train of power is
credited and available for this fire zone.
The redundant cable, ‘‘C’’ battery, ‘‘C’’
Distribution center, etc. are not located
in this fire zone.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
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to manually open V–9–2099 and V–11–
49 and close V–11–63 and V–11–41 to
align the fire water system for make-up
water to Isolation Condenser ‘‘B’’ since
there is no power (‘‘B’’ Train) available
to the Condensate Transfer System. 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.
3.19.4.2 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
although the USSs powering the air
compressors are located 35 feet apart
from each other, the power cables are
located in the same cable trays for at
least 45 feet and 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
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.
srobinson on DSKHWCL6B1PROD with NOTICES
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 OMAs #7
and #12 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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3.20 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 has classified the fire
loading in this fire zone as low. The
licensee also stated that this area has an
administrative fire loading limit of less
than 30 minutes as determined by the
ASTM E119 time-temperature curve.
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.
3.20.4 OMAs Credited for a Fire in
This Area
3.20.4.1 OMA #7—Align Fire Water to
Isolation Condenser
In order for OMA #7 to be necessary,
the loss of the ‘‘B’’ Train of power would
have to occur due to fire damage. The
loss of the ‘‘B’’ Train of power is
attributed to the fact that the 125 VDC
control power could be lost to the 1D
4160V Switchgear or the 1D 4160V main
breaker could trip due to cables that
traverse through this fire zone. The
licensee stated that the cables for the
125 VDC control power and the control
circuit for the 1D main breaker are
contained in separate conduits but are
routed within approximately 6 inches of
each other in a portion of this zone and
that the conduits are located
approximately 5 to 6 feet above the
floor. Additionally, the licensee stated
that the total length of the conduits in
this area is approximately 20 feet.
The licensee also stated that there are
no ignition sources in the area and that
combustible loading is limited since the
area is a stairway area. Transient
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combustibles are controlled by
administrative procedures and although
the accumulation of transient
combustibles below the conduits could
potentially impact the cables, it is
unlikely because the area is a stairway
and part of the floor is blocked by a
large ventilation duct. The ‘‘A’’ train of
power is credited and available for this
fire zone. The redundant cable, ‘‘C’’
battery, ‘‘C’’ Distribution center, etc. are
not located in this fire zone.
In the unlikely event that a fire does
occur and damages the credited and
redundant cables, OMA #7 is available
to manually open V–9–2099 and V–11–
49 and close V–11–63 and V–11–41 to
align the fire water system for make-up
water to Isolation Condenser ‘‘B’’ since
there is no power (‘‘B’’ Train) available
to the Condensate Transfer System. 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.
3.20.4.2 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
although the USSs powering the air
compressors are located 35 feet apart
from each other, the power cables are
located in the same cable trays for at
least 45 feet and 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
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.
3.20.5 Conclusion
Given the limited amount of
combustible materials, ignition sources,
and large volume of the space, it is
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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 OMAs #7
and #12 to manipulate the plant in the
event of a fire that damages safe
shutdown equipment, provides
adequate assurance that safe shutdown
capability is maintained.
srobinson on DSKHWCL6B1PROD with NOTICES
3.21 Feasibility of the Operator
Manual Actions
This analysis postulates that OMAs
may, in some scenarios, 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.
However, Exelon states that the OMAs
identified in its Phase 1 request were
previously found acceptable in fire
protection SEs dated March 24, 1986
and June 25, 1990, and, therefore, do not
need to meet the reliability criteria
specified in NUREG–1852,
‘‘Demonstrating the Feasibility and
Reliability of Operator Manual Actions
in Response to Fire,’’ dated October
2007. The NRC staff finds that the SEs
referenced by the licensee, in addition
to the feasibility review contained in
this SE, provide the necessary
information to determine the feasibility
and reliability of the OMAs.
3.21.1 Bases for Establishing
Feasibility
Using NUREG–1852, the NRC staff
has evaluated the feasibility 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 less than the time in which the OMA
must be completed (time available).
3.21.2 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
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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
abnormal operating 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 radioequipped 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, CO2) or a fire
is confirmed. In addition, the licensee
stated that ABN–29 directs immediate
entry into the 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 EOPs in conjunction with the
applicable FSPs will permit the use of
any mitigating system available first,
and if a desired system is not available,
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19815
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 states 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.
In one instance, OMA 12, the licensee
identified that an operator may need to
re-enter Fire Zone RB–FZ–1E (i.e.,
perform part of an OMA in the affected
fire zone) to manually manipulate three
2-inch CRD System valves V–15–237,
V–15–30, and V–15–52 that are
physically located within 4 feet of each
other within the spray area of the
automatic localized fixed water spray
deluge system installed in this fire zone.
An exemption was granted in SE dated
June 25, 1990, for not providing either
additional separation from in-situ
combustibles or protection for CRD
System valve V–15–30. This exemption
was granted on the basis that: (1) There
are 204 minutes following a scram
before this action would need to be
completed and this action and only
requires 15 minutes to complete; (2) any
fires in that area are unlikely to render
the valve inoperable; (3) the valves are
within the spray area of an automatic
fixed water spray deluge system. Since
valves V–15–237, V–15–52, and V–15–
30 are physically within 4 feet of each
other the NRC staff considers the
technical basis of the exemption to be
equally valid for these two additional
valves.
The licensee’s analysis demonstrates
that, for the expected scenarios, the
OMAs can be diagnosed and executed
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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’’ versus ‘‘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 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)
Margin
(min)
OMA
Fire area/zone of fire origin
OMA location
1 ........
TB–FA–26, TB–FZ–11B, TB–FZ–11E .................................
TB–FA–3B .............................
29
45
16
Yard .......................................
34
37
45
73
11
36
CW–FA–14 ............................
20
45
25
MT–FA–12 ............................
DG–FA–17 ............................
CW–FA–14 ............................
20
24
16
45
45
45
25
21
29
RB–FZ–1E ............................
23
45
22
38
43
130
45
60
180
204
204
22
137
74
159
48
204
156
130
65
23
204
204
30
74
139
7
2 ........
3 ........
4 ........
5 ........
6 ........
7 ........
8 ........
9 ........
11 ......
12 ......
TB–FZ–11C, TB–FZ–11D ....................................................
OB–FA–9, OB–FZ–6A, OB–FZ–8C, TB–FZ–11B, TB–FZ–
11E.
TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, TB–
FZ–11E.
TB–FZ–11B, TB–FZ–11E .....................................................
TB–FZ–11D, TB–FZ–11E .....................................................
TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, TB–
FZ–11E.
OB–FZ–6B, OB–FZ–8A, OB–FZ–8B, OB–FZ–8C, TB–FZ–
11F, TB–FZ–11H, CW–FA–14.
OB–FZ–8C ............................................................................
OB–FZ–6A ............................................................................
RB–FZ–1E, RB–FZ–1G ........................................................
RB–FZ–1D, RB–FZ–1F5, TB–FA–3A, OB–FZ–6A, OB–FZ–
6B, OB–FZ–8A, OB–FZ–8B, OB–FZ–8C, OB–FA–9, TB–
FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, TB–FZ–
11E, TB–FZ–11F, TB–FZ–11H, CW–FA–14.
OB–FZ–6A
OB–FZ–6B
RB–FZ–1D
RB–FZ–1E
............................
............................
............................
............................
OB–FZ–10A ..........................................................................
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13 ......
16 ......
RB–FZ–1E, RB–FZ–1G ........................................................
RB–FZ–1F3 ..........................................................................
TB–FZ–11B, TB–FZ–11E, OB–FZ–8C ................................
The NRC staff reviewed the required
OMA 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 #16 and requires an operator to
manually trip the Reactor Recirculation
Pumps ‘‘A,’’ ‘‘B,’’ ‘‘C,’’ ‘‘D’’ and ‘‘E’’ at the
4160V Switchgear 1A and 1B. The
action may be required as a result of fire
in OB–FZ–8C, TB–FZ–11B, or TB–FZ–
11E. The symptom for this action is the
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RB–FZ–1F2 ...........................
TB–FZ–11C ...........................
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
OMAs.
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3.22 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.
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3.23 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 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.
3.24 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
shutdown equipment, provides
adequate protection of public health and
safety. Therefore, there is no undue risk
to public health and safety.
srobinson on DSKHWCL6B1PROD with NOTICES
3.25 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.
3.26 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
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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 (74 FR 36274).
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. 2011–8405 Filed 4–7–11; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
[NRC–2009–0345]
Final Regulatory Guide: Issuance,
Availability
Nuclear Regulatory
Commission.
AGENCY:
Notice of issuance and
availability of Regulatory Guide (RG)
5.79, ‘‘Protection of Safeguards
Information.’’
ACTION:
FOR FURTHER INFORMATION CONTACT:
Robert Norman, U.S. Nuclear Regulatory
Commission, Washington, DC 20555–
0001, telephone: 301–415–2278 or email: Robert.Norman@nrc.gov.
SUPPLEMENTARY INFORMATION:
PO 00000
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I. Introduction
The U.S. Nuclear Regulatory
Commission (NRC or Commission) is
issuing a new guide in the agency’s
‘‘Regulatory Guide’’ series. This series
was developed to describe and make
available to the public information such
as methods that are acceptable to the
NRC staff for implementing specific
parts of the agency’s regulations,
techniques that the staff uses in
evaluating specific problems or
postulated accidents, and data that the
staff needs in its review of applications
for permits and licenses.
Regulatory Guide (RG) 5.79
‘‘Protection of Safeguards Information,’’
was issued August 6, 2009 as a Draft
Regulatory Guide (DG) for public
comment under the temporary
identification number DG–5034. RG
5.79 is a new regulatory guide which
describes methods the staff of the NRC
consider acceptable to implement the
general performance requirements
specified in Title 10, Section 73.21(a)(i)
and (ii), of the Code of Federal
Regulations, ‘‘Protection of Safeguards
Information: Performance
Requirements,’’ (10 CFR 73.21) that
establish, implement, and maintain an
information protection system that
includes the applicable measures for
safeguards information (SGI) specified
in 10 CFR 73.22, ‘‘Protection of
Safeguards Information: Specific
Requirements,’’ or 10 CFR 73.23,
‘‘Protection of Safeguards Information—
Modified Handling: Specific
Requirements.’’ This guide applies to all
licensees, certificate holders, applicants,
or other persons who produce, receive,
or acquire SGI (including SGI with the
designation or marking: ‘‘Safeguards
Information—Modified Handling’’ (SGI–
M)).
The guidance and criteria contained
in this document pertain to the
protection of SGI as defined in 10 CFR
part 73, ‘‘Physical Protection of Plants
and Materials.’’ It is intended to assist
licensees and other persons who
produce, receive, or acquire SGI to
establish an information protection
system that addresses (1) information to
be protected, (2) conditions for access,
(3) protection while in use or storage, (4)
preparing and marking documents or
other matter, (5) reproduction of matter
containing SGI, (6) external
transmission of documents and
material, (7) processing SGI on
electronic systems, (8) removal from the
SGI category, and (9) destruction of
matter containing SGI.
10 CFR 73.21 ‘‘Protection of
Safeguards Information: Performance
Requirements,’’ requires, in part, that
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]]>Agencies
[Federal Register Volume 76, Number 68 (Friday, April 8, 2011)]
[Notices]
[Pages 19795-19817]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-8405]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
[Docket No. 50-219; NRC-2010-0320]
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 (FPP) must
provide the established level of protection as intended by Section
III.G of 10 CFR part 50, Appendix R.
By letter dated March 3, 2009, ``Request for Exemption from 10 CFR
50, Appendix R, Section III.G, `Fire Protection of Safe Shutdown
Capability (Phase 1)' '' available at Agencywide Documents Access and
Management System (ADAMS), Accession No. ML090630132, and supplemented
by letter dated April 2, 2010, ``Response to Request for Additional
Information Request for Exemption from 10 CFR 50, Appendix R, Section
III.G, `Fire Protection of Safe Shutdown Capability' '' (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 21 plant Fire 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, and TB-FZ-11H. These 21
plant areas 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).
In their March 3, 2009, and April 2, 2010, letters, the licensee
discussed financial implications associated with plant modifications
that may be necessary to comply with the regulation. 10 CFR
50.12(a)2(iii) 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. 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
[[Page 19796]]
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 of fire origin Area name Actions OMA No.
------------------------------------------------------------------------
1 CW-FA-14............... Circulatory Water Manually open 7
Intake. valve (V) V-9-
2099 and V-11-49
and close V-11-
63 and V-11-41.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
2 OB-FA-9................ Office Building Locally read 2
(Bldg.) Elev. Condensate
23'-6'', 35'- Storage Tank
0'', 46'-6''. level at level
indicator (LI)
LI-424-993 due
to damage to
control circuits.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
3 OB-FZ-6A............... Office Bldg. Locally read 2
``A'' 480V condensate
Switchgear storage tank
(SWGR) Room (CST) level at
Elev. 23'-6''. LI-424-993 due
to damage to
control circuits.
Use Remote 9
Shutdown Panel
(RSP) to control
equipment: RSP,
Control Rod
Drive (CRD)
Hydraulic Pump
NC08B and 480V
USS 1B2 Incoming
breaker (Operate
USS 1B2/CRD
Transfer Switch
(Partial
initiation) to
``Alternate''
and operate
Control Switches
for USS-1B2 Main
Breaker and B
CRD Pump).
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
4 OB-FZ-6B............... Office Bldg. Manually open V-9- 7
``B'' 480V SWGR 2099 and V-11-49
Room Elev. 23'- and close V-11-
6''. 63 and V-11-41.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI)
FI-225-2 and
close V-15-52.
------------------------------------------------------------------------
5 OB-FZ-8A............... Office Bldg. Manually open V-9- 7
Reactor 2099 and V-11-49
Recirculation and close V-11-
Motor Generator 63 and V-11-41.
(MG) Set Room
Elev. 23'-6''.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
6 OB-FZ-8B............... Office Bldg. Manually open V-9- 7
Mechanical 2099 and V-11-49
Equipment Room and close V-11-
Elev. 35'-0''. 63 and V-11-41.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
7 OB-FZ-8C............... Office Bldg. A/B Locally read 2
Battery Room, Condensate
Tunnel and Storage Tank
Electrical Tray level at LI-424-
Room Elev. 35'- 993 due to
0''. damage to
control circuits.
Manually open V-9- 7
2099 and V-11-49
and close V-11-
63 and V-11-41.
Use Local 8
Shutdown Panels
to control
equipment as
follows: LSP-
1A2, CRD
Hydraulic PP
NC08A and 480V
USS 1A2 Incoming
breaker (Operate
transfer switch
``Alternate''
and operate
Control Switch
for USS-1A2 Main
Breaker 1A2M and
A CRD Pump).
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
Trip all five 16
Reactor
Recirculation
Pumps (NG01-A,
NG01-B, NG01-C,
NG01D and
NG01E). Also,
lockout the
4160V breakers
using local
switch.
------------------------------------------------------------------------
8 OB-FZ-10A.............. Office Bldg. Manually open V- 12
Monitor and 15-237, throttle
Change Room Area V-15-30 using
and Operations local flow
Support Area indicator (FI-
Elev. 35'-0'' & 225-2) and close
46'-6''. V-15-52.
------------------------------------------------------------------------
9 RB-FZ-1D............... Reactor Bldg. Manually open V- 12
Elev. 51'-3''. 15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52;.
------------------------------------------------------------------------
10 RB-FZ-1E.............. Reactor Building Read CRD local 11
Elev. 23'-6''. flow gauge FI-
225-998.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
[[Page 19797]]
11 RB-FZ-1F3............. Reactor Bldg. Open Core Spray 13
Northwest Corner System II manual
Elev.-19'-6''. valves V-20-1
and V-20-2 and
close V-20-4.
------------------------------------------------------------------------
12 RB-FZ-1F5............. Reactor Bldg. Manually open V- 12
Torus Room Elev. 15-237, throttle
-19'-6''. V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
13 RB-FZ-1G.............. Reactor Bldg. Read CRD local 11
Shutdown Cooling flow gauge FI-
Room Elev. 38'- 225-998.
0'' & 51'-3''.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
14 TB-FA-3A.............. Turbine Bldg. Manually open V- 12
4160V Emergency 15-237, throttle
SWGR Vault 1C V-15-30 using
Elev. 23'-6''. local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
15 TB-FA-26.............. Turbine Bldg. Manually trip 1
125V DC Battery 4160V 1D
Room C Elev. 23'- Breakers and
6''. control USS 1B2
and 1B3 480V
Breakers locally
at LSP-1D.
Manually control 3
1B3M Breaker
from LSP-1B3.
Manually re-close 6
motor control
center (MCC)
1B32 Feeder
Breaker at USS
1B3.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
16 TB-FZ-11B............. Turbine Bldg. Manually trip 1
Lube Oil 4160V 1D
Storage, Breakers and
Purification and control USS 1B2
Pumping Area and 1B3 480V
Elev. 0'-0'', Breakers locally
27'-0'', and 36'- at LSP-1D.
0''.
Locally read 2
Condensate
Storage Tank
level at LI-424-
993.
Manually control 3
1B3M Breaker
from LSP-1B3.
Local Shutdown 4
Panels used to
control
equipment as
follows: LSP-
1B32 Condensate
Transfer Pump 1-
2 (Operate
transfer switch
to ``Alternate''
and operate
Control Switch
for Condensate
Transfer Pump 1-
2).
Manually re-close 6
MCC 1B32 Feeder
Breaker at USS
1B3.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
Trip all five 16
Reactor
Recirculation
Pumps (NG01-A,
NG01-B, NG01-C,
NG01D and
NG01E). Also,
lockout the
4160V breakers
using local
switch.
------------------------------------------------------------------------
17 TB-FZ-11C............. Turbine Bldg. Manually trip 1
SWGR Room 1A and 4160V 1D
1B Elev. 23'-6''. Breakers and
control USS 1B2
and 1B3 480V
Breakers locally
at LSP-1D.
Manually control 3
1B3M Breaker
from LSP-1B3.
Manually re-close 6
MCC 1B32 Feeder
Breaker at USS
1B3.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
18 TB-FZ-11D............. Turbine Bldg. Manually trip 1
Basement Floor 4160V 1D
South End Elev. Breakers and
3'-6''. control USS 1B2
and 1B3 480V
Breakers locally
at LSP-1D.
Manually control 3
1B3M Breaker
from LSP-1B3.
Local Shutdown 5
Panels are used
to control
equipment as
follows: LSP-
DG2, EDG2 and
its Switchgear
(Operate
transfer
Switches (3
total) to
``Alternate''
and operate
Control Switch
on Diesel Panel
to start diesel).
Manually re-close 6
MCC 1B32 Feeder
Breaker at USS
1B3.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
19 TB-FZ-11E............. Turbine Bldg. Manually trip 1
Condenser Bay 4160V 1D
Area Elev. 0'- Breakers and
0''. control USS 1B2
and 1B3 480V
Breakers locally
at LSP-1D.
Locally read 2
Condensate
Storage Tank
level at LI-424-
993.
Manually control 3
1B3M Breaker
from LSP-1B3.
Local Shutdown 4
Panels used to
control
equipment as
follows: LSP-
1B32 Condensate
Transfer Pump 1-
2 (Operate
transfer switch
to ``Alternate''
and operate
Control Switch
for Condensate
Transfer Pump 1-
2).
[[Page 19798]]
Local Shutdown 5
Panels are used
to control
equipment as
follows: LSP-
DG2, EDG2 and
its Switchgear
(Operate
transfer
Switches (3
total) to
``Alternate''
and operate
Control Switch
on Diesel Panel
to start diesel).
Manually re-close 6
MCC 1B32 Feeder
Breaker at USS
1B3.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
Trip all five 16
Reactor
Recirculation
Pumps (NG01-A,
NG01-B, NG01-C,
NG01D and NG01E)
Also, lockout
the 4160V
breakers using
the 69 Switch.
------------------------------------------------------------------------
20 TB-FZ-11F............. Turbine Bldg. Manually open V-9- 7
Feedwater Pump 2099 and V-11-49
Room Elev. 0'- and close V-11-
0'' & 3'-6''. 63 and V-11-41.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
21 TB-FZ-11H............. Turbine Bldg. Manually open V-9- 7
Demineralizer 2099 and V-11-49
Tank and Steam and close V-11-
Jet Air Ejector 63 and V-11-41.
Area Elev. 3'-
6'' & 23'-6''.
Manually open V- 12
15-237, throttle
V-15-30 using
local flow
indicator (FI-
225-2) and close
V-15-52.
------------------------------------------------------------------------
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 21 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, OB-FZ-6B, and TB-FA-26 have been
classified as having 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 (UL), 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, ``Implementation
of Fire Protection Requirements,'' 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
[[Page 19799]]
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 the table 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 Fire Area 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.
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 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 7--Align the Fire Water System to the Isolation
Condenser
In order for OMA 7 to be necessary, the loss of the ``B''
Train of power would have to occur due to fire damage. Unit Substation
Transformer (USS) 1B3 is located in the outside area on the west side
of the power block on a raised concrete foundation that sits
approximately 5 feet above grade. USS 1B3 is considered as a potential
ignition source as well as its associated adjacent transformer, USS
1A3, which is located approximately 15 feet west of USS 1B3. Both of
these unit substations are located approximately 20 feet from any plant
operating equipment (e.g., circulating water pump motor, etc.).
Additionally, the need to perform this OMA would likely be apparent in
the control room based on the loads that are lost (e.g., control room
ventilation, service water pump, etc.) and a fire at USS 1B3 would be
visible from the security tower monitoring the area.
In the unlikely event that a fire does occur and causes the loss of
USS 1B3 or its associated cables, OMA 7 is available to
manually open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to
align the fire water system for make-up water to Isolation Condenser
``B'' since there is no power (``B'' Train) available to the Condensate
Transfer System. 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.
3.1.4.2 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 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 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 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.
The licensee stated that OMA 12 essentially duplicates the
Emergency Operating Procedure (EOP) actions for reactor pressure vessel
(RPV) level control. Therefore, if a fire did occur and was not
immediately discovered, any delay in the entry into the appropriate
Fire Support Procedure (FSP) or delay in suppression of the fire would
not significantly affect the performance of this OMA, since the EOPs
would direct the same action to be performed if required.
3.1.5 Conclusion
Given the combustion resistant properties of the most probable
combustible materials, limited ignition sources, and open nature of the
area, it is unlikely that a fire would occur, go undetected or
unsuppressed by station 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 7
and 12 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 Fire Area OB-FA-9--Office Bldg. Elev. 23[foot]-6,
35[foot]-0, 46[foot]-6
3.2.1 Fire Prevention
The licensee has classified the fire loading in this fire area as
low. The licensee also stated that OB-FA-9 has an administrative fire
loading limit of less than 1.5 hours as determined by the time-
temperature curve contained in American Society of Testing and
[[Page 19800]]
Materials standard E119, ``Standard Test Methods for Fire Tests of
Building Construction and Materials'' (ASTM E119), and 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 an area-wide 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 the MUX corridor within 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 2--Read Condensate Storage Tank (CST) Local Level
Indicator LI-424-993
In order for OMA 2 to be necessary, the primary CST level
indicator (5F-27) would have to fail as a result of the fire. Should
this occur, indication can only be obtained by reading the local
indicator (LI-424-993) located at the CST. The licensee stated that the
safe shutdown success path structure, system, or component (SSC) cable
for the level indicator is routed in a cable tray located approximately
12 feet above the floor in this area (MUX corridor). The cable enters
the room in the northwest corner and is routed in a cable tray for
approximately 15 feet. It then air drops vertically down into the MUX
enclosure. The credited cable is routed in a cable tray with other
cables and is routed through the wooden ceiling, which also has some
rubber piping insulation on top of the ceiling, thus putting the cable
in close proximity to in situ combustibles. However, there are no
ignition sources in this area. Therefore, due to the lack of ignition
sources, it is not expected that a fire would occur in this area and it
is unlikely that the OMA would be required.
In the unlikely event that a fire does occur and causes the loss of
the primary CST level indicator, OMA 2 is available to locally
read CST level at the local level indicator, LI-424-993. The licensee
also stated that they have assumed a 30-minute diagnosis period and
that the required time to perform the action is 7 minutes while the
time available is 73 minutes, which provides a 36-minute margin.
3.2.4.2 OMA 12--Establish Control Rod Drive (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 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.
3.2.5 Conclusion
Given the limited amount of combustible materials, ignition
sources, and sufficient 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 OMAs 2 and 12
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 has classified the fire loading in this fire zone as
moderate. The licensee also stated that this area has an administrative
fire loading limit of less than 3 hours as determined by the ASTM E119
time-temperature curve. The main combustibles in this area are cable
insulation (approximately 81% of loading) and Dow Corning 561 Silicon
transformer liquid (approximately 15% of loading). Additionally, 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 2--Read Condensate Storage Tank Local Level
Indicator LI-424-993
In order for OMA 2 to be necessary, the primary CST level
indicator (5F-27) would have to fail as a result of the fire. Should
this occur, indication can only be obtained by reading the local
indicator (LI-424-993) located at the CST. The licensee stated that the
safe shutdown success path cable for the level indicator is routed in a
conduit that leaves a 120 VAC distribution panel and travels
approximately 5 feet vertically to a cable tray that is approximately 9
feet above the floor. The cable is routed with other cables in the
cable tray for approximately 15 feet at which point the cable tray
travels up through the ceiling. The liquid filled transformer is
located approximately 10 feet north of the cable. However, there is a
partial non-rated concrete block wall between the transformer and cable
tray that would provide some protection of direct flame impingement or
radiant heat transfer on the cable tray. The ignition sources in this
fire zone consist
[[Page 19801]]
of enclosed metal electrical cabinets (120 VAC and 125 VDC circuits)
and the liquid filled transformer (4160 VAC to 480 VAC).
In the unlikely event that a fire does occur and damages the
primary CST level indicator, OMA 2 is available to locally
read CST level at local indicator LI-424-993. The licensee also stated
that they have assumed a 30-minute diagnosis period and that the
required time to perform the action is 7 minutes while the time
available is 73 minutes, which provides a 36-minute margin.
3.3.4.2 OMA 9--Manually Control 480V Breakers From Remote
Shutdown Panel
In order for OMA 9 to be necessary, damage to the credited
and redundant cables would have to occur due to a fire. The licensee
stated that the credited and redundant cables are located in the same
cable tray with additional cables and that the tray is located
approximately 7 feet above the floor. Other than the cables themselves,
the primary combustible in this area is a liquid filled transformer,
which is located approximately 7 feet from the cable tray. The licensee
also stated that the ignition sources in this fire zone consist of
electrical cabinets (120 VAC and 125 VDC circuits) and the liquid
filled transformer (4160 VAC to 480 VAC). The electrical cabinets are
enclosed metal cabinets, which are located approximately 2 feet from
the credited and redundant cables in some locations.
In the unlikely event that a fire does occur and damages the
credited and redundant cables, OMA 9 is available to manually
control the 480V USS 1B2 breakers for CRD Pump NC08B and 1B2M from the
Remote Shutdown Panel. The licensee also stated that they have assumed
a 30-minute diagnosis period and that the required time to perform the
action is 13 minutes while the time available is 180 minutes, which
provides a 137-minute margin.
3.3.4.3 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 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.
3.3.5 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 OMAs 2,
9, and 12 to manipulate the plant in the event of a
fire that damages safe shutdown equipment, provide adequate assurance
that safe shutdown capability is maintained.
3.4 OB-FZ-6B Office Building ``B'' 480V SWGR Room Elev. 23'-6''
3.4.1 Fire Prevention
The licensee has classified the fire loading in this fire zone as
moderate. The licensee also stated that this area has an administrative
fire loading limit of less than 2 hours as determined by the ASTM E119
time-temperature curve. 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). Also, 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 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 7--Align the Fire Water System to the Isolation
Condenser
In order for OMA 7 to be necessary, the loss of the ``B''
Train of power would have to occur due to fire damage. Motor control
center (MCC) 1B21 is located approximately 5 feet from USS 1B2. The
licensee indicated that a credited power cable for the static charger
enters the fire zone through the ceiling of the corridor and then
enters the main portion of the room through the north wall
approximately 9 feet above the floor. It then runs east and down into
MCC 1B21. The cable is located approximately 2 feet above the potential
ignition source, USS 1B2, and runs directly into ignition source MCC
1B21. The credited power cable for MCC 1B21 is routed from USS 1B2 to
MCC 1B21 in a cable tray. This cable tray runs approximately 10 feet
above the floor and approximately 2 feet above the potential ignition
sources, USS 1B2 and MCC 1B21, but it also enters into both as
indicated above. However, both of these ignition sources are contained
in enclosed metal cabinets and are not high voltage. The cable tray is
also located approximately 10 feet from the ignition source of the USS
1B2 transformer, which is located near the west end of the room.
The licensee also indicated that the ``A'' train of power is
credited and available for this fire zone and that the redundant cable
is associated with the ``C'' battery charger, which is fire wrapped
with a 1-hour barrier in this fire zone. It is unlikely that a fire
would develop and cause damage to multiple redundant pieces of
equipment given the spatial relationship between the credited equipment
and ignition sources, the presence of the automatic Halon system, and
the protected ``C'' battery charger cable.
In the unlikely event that a fire does occur and damages the
credited and redundant cables, OMA 7 is available to manually
open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to align the
fire water system for make-up water to Isolation Condenser ``B'' since
there is no power (``B'' Train) available to the Condensate Transfer
System. 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
[[Page 19802]]
available is 45 minutes, which provides a 22-minute margin.
3.4.4.2 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 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.
In the unlikely event that a fire does occur and damages multiple
redundant trains, OMAs 7 and 12 are available to
align the fire water system to the isolation condenser and establish
CRD flow. The locations of these OMAs are in separate fire areas from
Fire Area OB-FZ-6B so a fire in Fire Area OB-FZ-6B would not impact the
locations of the actions.
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 zone, combined with the ability of OMAs 7
and 12 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 (FSSD) analysis due to the
lack of rated fire barriers between the zones. The licensee has
classified the fire loading in these fire zones as low. The licensee
also stated that these fire zones have an administrative fire loading
limit of less than 45 minutes as determined by the ASTM E119 time-
temperature curve. 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 these Zones
3.5.4.1 OMA 7--Align the Fire Water System to the Isolation
Condenser
In order for OMA 7 to be necessary, the loss of the ``B''
Train of power would have to occur due to fire damage. The licensee
indicated that the cable for the 125 VDC control power is in conduit
that enters this zone through the ce
