Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Operations, Inc.; Indian Point Nuclear Generating Unit No. 2; Exemption, 7184-7211 [2012-3124]
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SUMMARY:
BILLING CODE 7515–01–P
[Docket No. 50–247]
Entergy Nuclear Indian Point 2, LLC;
Entergy Nuclear Operations, Inc.;
Indian Point Nuclear Generating Unit
No. 2; Exemption
1.0 Background
Entergy Nuclear Operations, Inc.
(Entergy or the licensee) is the holder of
Facility Operating License No. DPR–
026, which authorizes operation of
Indian Point Nuclear Generating Unit
No. 2 (IP2). 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.
IP2 is a pressurized-water reactor
located approximately 24 miles north of
the New York City boundary line on the
east bank of the Hudson River in
Westchester County, New York.
2.0 Request/Action
Title 10 of the Code of Federal
Regulations (10 CFR) part 50, Section
50.48(b), requires that nuclear power
plants that were licensed to operate
before January 1, 1979, satisfy the
requirements of 10 CFR part 50,
Appendix R, ‘‘Fire Protection Program
for Nuclear Power Facilities Operating
Prior to January 1, 1979,’’ Section III.G,
‘‘Fire protection of safe shutdown
capability.’’ The circuit separation and
protection requirements being
addressed in this request for exemption
are specified in Section III.G.2. Since
IP2 was licensed to operate before
January 1, 1979, IP2 is required to meet
Section lll.G.2 of Appendix R to 10 CFR
part 50.
The underlying purpose of Section
III.G of Appendix R to 10 CFR part 50
is to establish reasonable assurance that
safe shutdown (SSD) of the reactor can
be achieved and maintained in the event
of a postulated fire in any plant area.
Circuits which could cause
maloperation or prevent operation of
redundant trains of equipment required
to achieve and maintain hot shutdown
conditions as a result of fire in a single
fire area must be protected in
accordance with lll.G.2. If conformance
with the technical requirements of
III.G.2 cannot be assured in a specific
fire area, an alternative or dedicated
shutdown capability must be provided
in accordance with Section III.G.3, or an
exemption obtained in accordance with
10 CFR 50.12, ‘‘Specific exemptions.’’
By letter dated March 6, 2009, Entergy
requested an exemption from the
requirements of 10 CFR part 50,
Appendix R, in accordance with 10 CFR
50.12. Specifically, Entergy requested an
exemption to allow the use of Operator
Manual Actions (OMAs) in lieu of
meeting certain technical requirements
of III.G.2 in Fire Areas C, F, H, J, K, P,
and YD of IP2. The table below provides
the dates and topics of the submittals
related to this request.
ADAMS
Accession
Author
Date
Description
Exemption Request
from Appendix R.
Revised Exemption Request.
Entergy ........................
March 6, 2009 .............
Original Submittal ..............................................
ML090770151.
Entergy ........................
October 1, 2009 ...........
NRC .............................
January 20, 2010 .........
Entergy ........................
NRC .............................
May 4, 2010 .................
August 11, 2010 ..........
RAI Response #2 .........
RAI #3 ..........................
RAI Response #3 .........
Entergy ........................
NRC .............................
Entergy ........................
September 29, 2010 ....
December 16, 2010 .....
January 19, 2011 .........
Letter to revise previously submitted information.
Entergy ........................
February 10, 2011 .......
Revision to March 2009 submittal, incorporated
changes to Attachment 2, Technical Basis in
Support of Exemption Request.
Request for information on the overall defensein-depth for each fire zone..
Response to the staff’s January 20, 2010, RAI.
RAI on reactor coolant system makeup, separation distances, etc.
Response to the staff’s August 11, 2010, RAI ..
RAI on reactor coolant system makeup ............
Responses to the staff’s December 16, 2010,
RAI.
Letter updating tables contained in previous
submittals.
ML092810231
Request for Additional
Information (RAI) #1.
RAI Response #1 .........
RAI #2 ..........................
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Subject
Author
Date
Letter to revise previously submitted information.
Entergy ........................
May 26, 2011 ...............
Letter updating tables contained in previous
submittals.
ADAMS
Accession
Description
III.G.2 establishes various protection
options for providing reasonable
assurance that at least one train of
systems, equipment, and cabling
required to achieve and maintain hot
shutdown conditions remains free of
fire damage. In lieu of providing one of
the means specified in the regulation,
Entergy requests an exemption from
lll.G.2 to allow the use of OMAs to
achieve and maintain hot shutdown
conditions in the event of fire in seven
fire areas at IP2, Fire Areas C, F, H, J,
K, P, and YD. The licensee further
subdivides these fire areas into one or
more fire zones for analysis purposes.
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
stated that special circumstances exist
because 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 to operate
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 SSD is
preserved following a fire event. The
regulation intends for licensees to
accomplish this by extending the
concept of defense-in-depth to:
• Prevent fires from starting.
• Rapidly detect, control, and
extinguish promptly those fires that do
occur.
• 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 SSD of the
plant.
Section III.G.2 requires one of the
following means to ensure that a
redundant train of SSD cables and
equipment is free of fire damage, where
redundant trains are located in the same
fire area outside of primary
containment:
a. Separation of cables and equipment
by a fire barrier having a 3-hour rating;
b. Separation of cables and equipment
by a horizontal distance of more than 20
feet with no intervening combustibles or
fire hazards and with fire detectors and
an automatic fire suppression system
installed in the fire area; or
ML11158A197
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.
In its March 6, 2009, and October 1,
2009, submittals, Entergy requested an
exemption from certain technical
requirements of III.G.2 to the extent that
one of the redundant trains of systems
necessary to achieve and maintain hot
shutdown is not maintained free of fire
damage in accordance with one of the
required means prescribed in III.G.2 in
Fire Areas C, F, H, J, K, P, and YD. The
licensee also listed an operator action to
implement emergency operating
procedure (EOP) 2–FR–H.1, ‘‘Response
To Loss Of Secondary Heat Sink.’’ The
NRC does not consider implementing 2–
FR–H.1 an OMA, as actions to establish
reactor coolant system decay heat
removal can be performed from the
control room and there are redundant
trains of equipment located outside of
the fire area of fire origin.
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, which the
licensee has further subdivided into fire
zones. Listed in the order of the fire area
of fire origin, the OMAs included in this
review are as follows:
Area of fire
origin
Area name
Operator manual actions
1 ...................
C ..................
Auxiliary Boiler Feed Pump Room, Elevation 18′–6″ of
the Auxiliary Feed Pump Building.
Implement EOP FR–H.l as directed by EOPs and status trees if necessary to establish alternate secondary heat sink. Action performed from the control
room, so the NRC does not consider this an OMA.
2 ...................
......................
........................................................................................
Operate turbine-driven 22 auxiliary feedwater (AFW)
pump upon reentry to the room following the initial
hour of the fire scenario.
3 ...................
......................
........................................................................................
Open or check open 22 AFW pump steam supply isolation valves PCV–1310A and PCV–1310B.
4 ...................
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OMA#
......................
........................................................................................
Operate 22 AFW pump flow control valves FCV–405A
(discharge to 21 steam generator (SG)), FCV–405B
(discharge to 22 SG), FCV–405C (discharge to 23
SG), and/or FCV–405 to align AFW flow to selected
steam generators.
5 ...................
F ...................
Primary Auxiliary Building and Fan House ....................
Open HCV–142 bypass valve 227 to align charging
pump makeup path to the Reactor Coolant System
(RCS).
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Area of fire
origin
Area name
Operator manual actions
6 ...................
......................
........................................................................................
Align charging pump suction source to the Refueling
Water Storage Tank (RWST).
7 ...................
......................
........................................................................................
Transfer instrument buses 23 and 23A to alternate
power.
8 ...................
H ..................
Vapor (Reactor) Containment Building ..........................
Fail open valves 204A (charging flow to Loop 2 hot
leg) and 204B (charging flow to Loop 1 cold leg) to
align charging pump makeup path to the RCS.
9 ...................
......................
........................................................................................
Activate or enable Alternate Safe Shutdown System
pneumatic instruments (steam generator level, pressurizer pressure and level) at Fan House local control panel.
10 .................
......................
........................................................................................
Enable Alternate Safe Shutdown System source-range
channel and Loop 21 and 22 hot leg (Th) and cold
leg (Tc) temperature channels.
11 .................
J ...................
Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building, Administration Building, Screenwell
House, and Unit 2 Turbine Building.
Trip breakers 52/5A and 52–SAC on Bus 5A and 52/
6A and 52/TAO at Bus 6A and remove control
power fuses.
12 .................
......................
........................................................................................
Transfer Instrument Buses 23 and 23A to emergency
power source.
13 .................
......................
........................................................................................
Align charging pump suction to RWST.
14 .................
K ...................
Auxiliary Feed Pump Building (not including the AFW
Pump Room).
Operate transfer switch EDC5 and close supply breaker at substation 12FD3 to transfer 21 AFW Pump to
Alternate Safe Shutdown System power source.
15 .................
......................
........................................................................................
Open 21 AFW pump recirculation bypass valve BFD–
77.
16 .................
P ...................
Component Cooling Water (CCW) Pump Room ...........
Transfer 23 CCW pump to Alternate Safe Shutdown
System power feed followed by breaker closure at
12FD3.
17 .................
......................
........................................................................................
Start Appendix R Diesel Generator (ARDG) if normal
power and offsite power are lost.
18 .................
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OMA#
YD ................
Outdoor (Yard) Area ......................................................
Open HCV–142 bypass valve 227 to align charging
pump makeup path to RCS.
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. The licensee utilizes
various protective measures to
accomplish the concept of defense-indepth. 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 identified above.
In their March 6, 2009, and October
1, 2009, submittals, 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 because the separation
requirements for equipment and
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electrical circuits required by III.G.2 are
not met. Specifically, the licensee stated
that noncombustible materials have
been used to the maximum extent
practicable and that the introduction of
combustible materials into areas with
safety-related equipment, including Fire
Areas C, F, H, K, and P, is strictly
controlled by administrative
procedures. The administrative
procedures govern the handling, storage,
and limitations for use of ordinary
combustible materials, combustible and
flammable gases and liquids, and other
combustible supplies. In addition,
periodic fire prevention inspections are
performed to assess compliance with
Indian Point’s programs for Control of
Combustibles and Control of Ignition
Sources. The licensee stated that the
administrative controls are described in
the IP2 Fire Protection Program (FPP),
which is incorporated by reference into
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the Updated Final Safety Analysis
Report.
The licensee stated that both
thermoplastic and thermoset lowvoltage power, control, and instrument
cables are installed at IP2. Since the
thermoplastic insulated cables were
manufactured and installed prior to the
issuance of IEEE–383, a standard for
nuclear plant cables, they were not
qualified to that standard. In its May 4,
2010 letter, the licensee stated that these
cables are constructed with an asbestos
glass braid outer jacket which provides
protection from flame spread. In
addition, the licensee stated that the
results of various tests, as well as an
actual fire event during plant
construction, have demonstrated the
ability of this type of thermoplastic
insulated cables to minimize the growth
and spread of cable fires. The licensee
also stated that the likelihood of self-
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ignited cable fires is minimized by
appropriately sized electrical protection
devices (e.g., fuses and circuit breakers).
The licensee stated that all cables
installed after plant construction are
thermoset cables which meet the IEEE–
383 standard. The IEEE–383 standard
includes fire-retardation characteristics.
All of the fire areas in the plant are
comprised of one or more fire zones
consisting of separate compartments or
fire zone delineations based on spatial
separation. In addition, the licensee
stated that the localization of hazards
and combustibles within each fire zone,
combined with the spatial or physical
barrier separation between zones,
provides reasonable assurance that a fire
that occurs within a particular zone will
be confined to that zone. As such, the
licensee provided a characterization of
the defense-in-depth that is present in
each of the fire zones containing
multiple trains of SSD equipment. The
licensee further stated that for each of
the fire zones where OMAs are
performed, the adequacy of non-rated
fire barriers was evaluated to ensure that
they can withstand the hazards
associated with the area. Therefore, this
review evaluates the defense-in-depth
provided in each of the zones of
concern.
In its submittals, the licensee
provided a summary of plant-specific
fire protection features provided for
each fire zone identified in its request
including an account of combustible
loading (both fixed and transient),
ignition sources, detection, suppression,
administrative controls, and identified
any additional fire protection features
that may be unique to the fire zone,
such as electrical raceway fire barriers.
In its responses, the licensee stated that
combustibles and sources of ignition are
tightly controlled by administrative
controls programs and that the areas
included in this exemption are not shop
areas so hot work activities (such as
welding) are infrequent and appropriate
administrative controls (e.g., hot work
permits, fire watch, and supervisory
controls) are in place if hot work
activities do occur. The licensee also
stated that the original installation of
the suppression and detection systems
was accepted by the NRC staff in safety
evaluation reports (SERs) dated January
31, 1979, and a supplement dated
October 31, 1980, and that there are no
code compliance items that present an
adverse impact to the implementation of
the requested OMAs. Within the fire
zones of concern to its request, the
licensee stated that fire-rated assemblies
are only used and credited for intrazone separation of redundant SSD
equipment trains in part of Fire Area F
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(Fire Zone 7A) and part of Fire Area P
(Fire Zone 1). The fire-rated assemblies
consist of a Hemyc Electrical Raceway
Fire Barrier System (ERFBS) and have
been evaluated to ensure they are
adequate for the hazards of the areas of
installation.
Entergy stated that for each of the fire
areas addressed in this evaluation, PostFire Safe Shutdown (PFSSD) is
principally accomplished by remaining
in the Central Control Room (CCR) and
conducting a normal (non-alternative)
shutdown. In all cases, the identified
OMAs mitigate conditions where certain
technical requirements of III.G.2 are not
satisfied.
Entergy further stated that the OMAs
required for achieving and maintaining
hot shutdown conditions are feasible,
reliable, and are not impacted by
environmental conditions (radiation,
lighting, temperature, humidity, smoke,
toxic gas, noise, fire suppression
discharge, etc.) associated with fires in
III.G.2 areas. The feasibility and
reliability of the requested OMAs are
addressed in Section 4.0 of this
evaluation.
NRC Staff Observations
In its May 4, 2010, response to RAI–
07.1, the licensee stated that no credit
was taken for immediate and proactive
OMA response by plant operators upon
the receipt of a fire detection alarm in
any of the identified fire zones. Instead,
the licensee stated that OMAs are
initiated upon the detection of operating
abnormalities or failures caused by a
postulated fire event. In this same
response, the licensee stated that they
conducted exercises using the plant
simulator to evaluate the feasibility of
the OMAs where a fire condition or a
spontaneous reactor trip caused by a fire
was announced at the outset of the
simulation followed by the failure of
discrete components that are subject to
impairment due to fire damage to cables
or components resulting from a fire in
the area of concern. For fires originating
in fire zones lacking fire detection and/
or automatic fire suppression systems,
the NRC staff considers it improbable
that the operators would properly
indentify that the indications were the
result of a fire instead of some other
fault. In addition, the operators would
be delayed in positively identifying the
location of the fire based on these
indirect and ambiguous indicators.
Therefore, for some scenarios involving
fire zones that lack fire detection
systems, operators are unlikely to
identify and respond to a fire event in
a manner that prompts them to perform
certain OMAs prior to a significant
degradation of the plant’s condition.
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This becomes especially relevant for
OMAs that are required to be completed
within a relatively short period of time,
e.g., within about 30 minutes, or have
limited margins available to complete
the required actions.
For OMAs that are required to be
completed within a short period of time,
the NRC staff evaluates if operators can
reliably perform the OMA. In order to be
able to perform OMAs reliably, it is
important that operators are able to
promptly implement any required
action based on clear indications.
Indirect indicators and diagnostic
analysis would result in delayed action
to initiate the appropriate OMAs and
would impair their reliable completion.
For example, loss of control or
indication for a pump or other affected
component could result from the power
supply circuit breaker opening due to an
electrical fault other than a fire, and the
operator might delay taking actions for
a fire while investigating other potential
and more-likely causes. The NRC staff
documented a position on procedures
and training for such actions in Section
4.2.9 of NUREG–1852, ‘‘Demonstrating
the Feasibility and Reliability of
Operator Manual Actions in Response to
Fire,’’ which notes that the procedures
for reactive actions should clearly
describe the indications which prompt
initiation of the actions. Therefore,
where OMAs need to be performed
within a short period of time, fire zones
crediting those OMAs are expected to
have more robust defense-in-depth and
clear, direct procedures than fire zones
that have a significant margin in their
OMA performance times.
In the August 11, 2010 RAI–02.1 and
RAI–06.1, and the December 16, 2010
RAI–01.1, the NRC staff requested that
the licensee describe the spatial
separation between redundant trains of
equipment. However, the licensee’s
responses only provided information
regarding the separation between
ignition sources and safe shutdown
equipment and no information
regarding separation between redundant
trains of equipment within the fire area.
For example, in its September 29, 2010
response to RAI–06.1 the licensee stated
that ‘‘The cables serving valves 204A
and 204B are routed within
Containment (Fire Area H) in raceways
which are not separated by 20 feet at all
locations, nor are other separation
measures as prescribed by III.G.2 (f)
provided.’’ During a clarification call
with the licensee, the licensee did not
provide any dimensional data on train
separation. Without dimensional data
on train separation, the staff has
conservatively assumed that there is no
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discernable separation between
redundant trains of equipment.
In addition, the licensee noted that
the introduction of combustible
materials into most areas included in its
request was limited via administrative
procedures such as EN–DC–161,
‘‘Control of Combustibles.’’ The licensee
stated that Fire Area J did not contain
safety-related systems or components
and was not addressed by this
procedure. The NRC staff notes that the
licensee requested OMAs for Fire Area
J and that alternate shutdown
equipment and several cables associated
with normal safe-shutdown equipment
are located in this area. The licensee
stated that operator rounds are
performed each shift in Fire Area J that
would monitor the presence of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017, ‘‘Plant
Surveillance and Operator Rounds’’ and
EN–MA–132, ‘‘Housekeeping,’’ include
guidance for monitoring general area
cleanliness including monitoring for
accumulations of combustibles. The
NRC staff notes that the combustible
material controls procedures for this fire
area are not as robust as for safetyrelated areas, and therefore results in a
reduction in the defense-in-depth for
the impacted fire zones.
Specific Area or Zone Discussion
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 C—Auxiliary Boiler Feed
Pump Room, Elevation 18′–6″ of the
Auxiliary Feed Pump Building (Fire
Zone 23—Auxiliary Boiler Feed Pump
(ABFP) Room, Elevation 18′–6″)
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3.1.1
Fire Prevention
Fire Area C consists of a single room
(the ABFP Room or the Auxiliary
Feedwater (AFW) Pump Room) and is
designated as Fire Zone 23. Note that
the pumps which supply water to the
steam generators following a reactor trip
are generically known as AFW pumps,
but at IP2 they are also called Auxiliary
Boiler Feed Pumps. The licensee stated
that the fire loading in this area is low
and that fixed combustibles consist of
fire retardant cable insulation. The
licensee stated that small quantities of
lube oil and Class A combustibles are
present but those do not pose a credible
challenge to components of concern
located in the zone. The licensee also
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stated that the ignition sources in the
area consist of cable runs, junction
boxes, motors, pumps, and electrical
panels.
3.1.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 23
does not have a fire suppression system
installed but does have an area-wide,
ionization smoke detection system
installed, which would provide early
notification of a fire and assist in a
prompt fire brigade response. The
licensee also stated that the detection
system was designed and installed in
accordance with National Fire
Protection Association (NFPA) standard
NFPA 72D, 1975 Edition.
3.1.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 23
has a ceiling height of approximately
14′–0″ and an approximate floor area of
1,210 square feet. This fire zone
contains the three AFW pumps (21, 22,
and 23) and their discharge valves used
to supply water to the steam generators
for reactor coolant system decay heat
removal when the normal feedwater
system is not available, such as
following a reactor trip. The licensee
stated that a radiant energy shield is
installed between 21 AFW pump and 23
AFW pump and that the power cables
for 23 AFW pump are wrapped in
Hemyc fire barrier material rated for 30
minutes. The licensee stated that
damage to the control or instrument
cables in the overhead trays could
present an immediate impact on
redundant AFW trains. As discussed in
section 3.0 above, the licensee did not
identify any separation between
credited and redundant trains of
equipment.
3.1.4 OMAs Credited for a Fire in Fire
Area C (Fire Zone 23)
3.1.4.1 OMA #1—Implement 2–FR–
H.1 If Necessary to Establish Alternate
Secondary Heat Sink
The licensee stated that for a worst
case fire scenario, OMAs to restore AFW
functionality would be implemented
after a period of 1 hour following fire
initiation. This time is provided to
extinguish the fire and clear the smoke
from the fire area. In the unlikely event
that control and indication for all three
AFW pumps is lost during the initial
hour of a fire event, the licensee stated
that Emergency Operating Procedure
EOP 2–FR–H.1, ‘‘Response to Loss of
Secondary Heat Sink,’’ can be
implemented to provide the reactor
coolant heat removal function using the
normal feedwater system or feed-and-
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bleed cooling with safety injection
pumps. Since actions to remove reactor
coolant system decay heat can be
performed from the CCR (no OMAs are
required in the field), this action is
included for completeness only. Since
no exemption is being requested, this
OMA is not part of this exemption. In
a letter dated September 14, 1988, the
licensee had described the use of EOP
2–FR–H.1 to the NRC, and by letter
dated January 12, 1989, the NRC staff
concluded that the licensee’s
clarifications to the fire protection
program conformed with NRC fire
protection guidelines and requirements
and were acceptable, so the use of EOP
2–FR–H.1 is considered to already be
part of the licensee’s licensing basis.
3.1.4.2 OMA #2—Operate 22 AFW
Pump (Turbine-Driven)
The licensee stated that all three AFW
pumps are within this area and
associated cables are routed in this area.
According to the licensee, the cables of
concern are typically routed in rigid
steel conduits and located between 8.9
feet and 10.8 feet above the floor. The
OMAs for this area are only needed if
all three AFW pumps are affected by the
fire. The licensee stated that the
diagnostic indicator for this scenario
would be a loss of control or indication
for 22 AFW pump from the CCR or
indication of decreasing level in all
steam generators as viewed at recorders
LR–417, 427, 437, and 447. In the event
that this does occur, OMAs #2, #3, and
#4 are available to operate 22 AFW
Pump. OMA #2 will open PCV–1139 to
admit steam, operate HCV–1118 at the
pump to control speed, and operate
PCV–1213 as necessary to regulate
pump bearing cooling water. Since these
actions are required to be performed in
the zone where the fire occurs, a 60minute waiting period prior to operator
reentry into the area is described in the
submittal. The licensee stated that they
allotted 60 minutes before performing
OMA #2 to allow the fire brigade to
perform its fire fighting operations and
for the area to be made tenable prior to
entering to perform certain OMAs. In
Table RAI–08.1–1 of its February 10,
2011 submittal, the licensee indicated
that the OMA initiator (postulated fireinduced failure) is located in Fire Zone
23 as is the OMA performance location.
The licensee also provided a comment
in the same table establishing the 60minute duration of the waiting period.
If OMA #2 becomes necessary, the
licensee stated that they have assumed
a 60-minute period before re-entering
the fire area, a 4.5-minute diagnosis
period, which is assumed to transpire
during the 60-minute waiting period,
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and that the required time to perform
the action is 22 minutes, which results
in a total required time of 82 minutes.
The licensee is crediting the use of EOP
2–FR–H.1 until OMAs #2, #3, and #4
can be accomplished. Since there is
defense-in-depth including full area fire
detection and limited combustibles, and
EOP 2–FR–H.1 can be used to perform
the reactor coolant system heat removal
function while OMA #2 is being
implemented, the NRC staff finds this
OMA acceptable.
srobinson on DSK4SPTVN1PROD with NOTICES
3.1.4.3 OMA #3—Open or Check Open
22 AFW Pump Steam Supply Isolation
Valves
This OMA is one of the three OMAs
needed to operate the 22 AFW pump, as
described in the previous section. OMA
#3 would open the 22 AFW pump steam
supply pressure control valves PCV–
1310A and PCV–1310B in Fire Area K.
If OMA #3 becomes necessary, the
licensee stated that they have assumed
a 4.5-minute diagnosis period, and that
the required time to perform the action
is 15 minutes, which results in a total
required time of 19.5 minutes. The
licensee is crediting the use of EOP 2–
FR–H.1 until OMAs #2, #3, and #4 can
be accomplished. Since there is defensein-depth including full area fire
detection and limited combustibles, and
EOP 2–FR–H.1 can be used to perform
the reactor coolant system heat removal
function while OMA #3 is being
implemented, the NRC staff finds this
OMA acceptable.
3.1.4.4 OMA #4—Operate 22 AFW
Pump Flow Control Valves To Align
AFW Flow to Selected Steam Generators
This OMA is one of the three OMAs
needed to operate the 22 AFW pump, as
described in the previous sections.
OMA #4 would operate FCV–405A
(discharge to 21 SG) and FCV–405B
(discharge to 22 SG) in the AFW Pump
Room, upon reentry to the room
following the initial 60-minute waiting
period.
If OMA #4 becomes necessary, the
licensee stated that they have assumed
a 60-minute period before re-entering
the fire area, a 4.5-minute diagnosis
period, which is assumed to transpire
during the 60-minute waiting period,
and that the required time to perform
the action is 22 minutes, which results
in a total required time of 82 minutes.
The licensee is crediting the use of EOP
2–FR–H.1 until OMAs #2, #3, and #4
can be accomplished. Since there is
defense-in-depth including full area fire
detection and limited combustibles, and
EOP 2–FR–H.1 can be used to perform
the reactor coolant system heat removal
function while OMA #4 is being
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implemented, the NRC staff finds this
OMA acceptable.
3.2.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 5A)
3.1.5 Conclusion for Fire Area C (Fire
Zone 23)
3.2.4.1 OMA #6—Align Charging
Pump Suction to Refueling Water
Storage Tank (RWST)
The licensee stated that a postulated
fire in Fire Area F could present the
potential for immediate damage to the
one charging pump (there are three
charging pumps) that is normally in
service during power operations by
affecting the source of water to the
suction of the pump. The licensee stated
that the 21 Charging Pump is credited
for accomplishing the RCS makeup
function in the event of fire in Fire Area
F. In the event that the 21 Charging
Pump is in operation during a fire in
Fire Area F, and fire damage causes
valve LCV–112C to spuriously close, the
21 Charging Pump could be damaged
due to a loss of suction. For a fire in Fire
Area F, the licensee stated that
alignment of the charging suction
flowpath to the RWST is established by
OMAs to close valve LCV–112C and
open normally closed manual valve 288,
which provides a bypass path around
valve LCV–112B. To open valve 288, the
licensee stated that operators must
reenter Fire Area F following a fire.
If a fire were to occur in Fire Zone 5A
and cause LCV–112C to spuriously
close, the licensee stated that OMA #6
is available to restore or maintain the
necessary function (RCS makeup) to the
affected equipment (Charging Pumps)
and align charging pump suction to the
RWST by closing the volume control
tank (VCT) outlet valve LCV–112C and
opening RWST manual bypass valve
288. If OMA #6 becomes necessary, the
licensee stated that they have assumed
a 60-minute waiting period before reentering the fire area, a 14-minute
diagnosis period, which is assumed to
transpire during the 60-minute waiting
period, and that the required time to
perform the action is 18 minutes, which
results in a total required time of 78
minutes, while the time available to
restore makeup flow to the RCS is 75
minutes. Therefore, there is insufficient
margin available to perform the OMA
for all fire zones in Fire Area F.
The NRC staff had previously issued
an exemption from III.G.2 for Fire Zone
23 in 1984 (ML003776266). In that
exemption, the NRC staff found that the
low fire load and features such as fire
wrap on the 23 AFW pump cables
justified an exemption. By letter dated
January 12, 1989, the NRC staff
concluded that the licensee’s
clarifications to the fire protection
program, which in part described the
use of EOP 2–FR–H.1, conform with
NRC fire protection guidelines and
requirements and were acceptable. The
NRC staff notes that the fire detection in
this fire zone will clearly alert the
operators to take actions for a fire.
Therefore, the NRC staff concludes that
with the defense-in-depth including full
area fire detection and limited
combustibles, OMAs #2, #3, and #4,
along with EOP 2–FR–H.1, are
acceptable for maintaining the reactor
coolant system heat removal function
and that the III.G.2 exemption for Fire
Zone 23 remains valid.
3.2 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
5A—Sampling Room, Elevation 80′–0″)
3.2.1
Fire Prevention
The licensee stated that the fire
loading in this fire zone is moderate and
that the fixed combustibles are
primarily cable insulation. The licensee
also stated that the ignition sources in
the fire zone consists of cable runs,
junction boxes, and electrical panels.
3.2.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 5A
does not have fire detection or fire
suppression systems installed.
3.2.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 5A
has a ceiling height of approximately
14′–0″ and an approximate floor area of
150 square feet. This fire zone contains
cables which could affect the position of
valves LCV–112B and LCV–112C. These
valves provide water to the suction of
the charging pumps. As discussed in
Section 3.0 above, the licensee could
not demonstrate any separation between
credited and redundant trains of
equipment.
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3.2.5 Conclusion for Fire Area F (Fire
Zone 5A)
Since the licensee described
postulated fire scenarios and Fire Zone
5A lacks an automatic fire detection or
automatic suppression system, and any
discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
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remains free of fire damage or allow
reentry to the area to perform OMAs.
Additionally, OMA #6 cannot be
completed in a timely manner for any
fire in Fire Area F. Thus, OMA #6 does
not provide assurance that safe
shutdown capability will be maintained
following the postulated fire events.
Therefore, the NRC staff finds that the
defense-in-depth is insufficient to
demonstrate reasonable assurance that
safe shutdown can be achieved for a fire
in Fire Zone 5A and that an exemption
from III.G.2 based on OMA #6 cannot be
granted for Fire Zone 5A.
3.3 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone 6–
22 Charging Pump Room, Elevation 80′–
0″)
3.3.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles are cable insulation,
lube oil, and plastic. Transient
combustibles consist of trash, paint,
lube oil, and radiation boundaries. The
licensee also stated that the ignition
source in the area is the 22 charging
pump motor.
3.3.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 6
has an automatic fire detection system
installed but does not have an automatic
fire suppression system installed. The
licensee also stated that the detection
system was designed and installed in
accordance with NFPA 72D, 1975
Edition.
srobinson on DSK4SPTVN1PROD with NOTICES
3.3.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 6
has a ceiling height of approximately
15′–6″ and an approximate floor area of
282 square feet. As discussed in Section
3.0 above, the licensee could not
demonstrate any separation between
credited and redundant trains of
equipment. The licensee stated that
cable YZ1–JB5 associated with valve
LCV–112C and cables PL2–M41 and
PL2–M42 associated with instrument
buses 23 and 23A are located in this
area and that they are located 12 feet,
6.8 feet, and 15.6 feet, respectively, from
the primary ignition source in the zone,
the 22 charging pump motor.
3.3.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 6)
3.3.4.1 OMA #6—Align charging
pump suction to RWST
OMA #6 was evaluated in Sections
3.2.4.1 and 3.2.5 above. As stated in
Section 3.2.4.1, there is insufficient
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margin to perform OMA #6 for any fire
zone in Fire Area F.
3.3.4.2 OMA #7—Transfer Instrument
Buses 23 and 23A to Alternate Power
The licensee stated that if indication
of instrument buses 23 and 23A is lost
in the CCR, OMA #7 may be necessary
to transfer both buses to their alternate
power supply. If OMA #7 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes, while
the time available is 30 minutes, which
results in 22.5 minutes of margin.
3.3.5 Conclusion for Fire Area F (Fire
Zone 6)
Since the licensee described
postulated fire scenarios and Fire Zone
6 lacks an automatic fire suppression
system and any discernable separation
between the credited and redundant
equipment in the area, it is possible that
a fire would not be extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage or allow
reentry to the area to perform OMAs.
The NRC staff finds that the defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
6. OMA #6 was found to be
unacceptable for this fire zone. OMA #7
has insufficient time available
considering the lack of fire suppression
and therefore is unacceptable for this
fire zone. Therefore, the staff finds that
an exemption from III.G.2 based on
these OMAs cannot be granted for Fire
Zone 6.
3.4 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
7A—Corridor, Elevation 80′–0″)
3.4.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles are cable insulation
and electrical cabinets, and that
transient combustibles consist of trash,
flammable liquids, plastic, cellulose,
and radiation boundaries. The licensee
also stated that the ignition sources in
the area consist of cable insulation,
junction boxes, and electrical panels.
3.4.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 7A
has an automatic fire detection system
installed but does not have an automatic
fire suppression system installed. The
licensee also stated that the detection
system was designed and installed in
accordance with NFPA 72D, 1975
Edition.
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3.4.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 7A
has a ceiling height of approximately
16′–0″ and an approximate floor area of
6,000 square feet. The licensee also
stated that the power cable from transfer
switch EDF–9 to 23 component cooling
water CCW pump motor is wrapped
with Hemyc fire barrier material rated
for 30 minutes. As discussed in Section
3.0 above, the licensee could not
demonstrate any separation between
credited and redundant trains of
equipment. The licensee stated that
cable YZ1–JB5 associated with valve
LCV–112C and cables PL2–M41 and
PL2–M42 associated with instrument
buses 23 and 23A are located in this
area.
3.4.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 7A)
3.4.4.1 OMA #6—Align Charging
Pump Suction to RWST
OMA #6 was evaluated in Sections
3.2.4.1 and 3.2.5 above. As stated in
Section 3.2.4.1, there is insufficient
margin to perform OMA #6 for any fire
zone in Fire Area F.
3.4.4.2 OMA #7—Transfer Instrument
Buses 23 and 23A to Alternate Power
The licensee stated that if indication
of instrument buses 23 and 23A is lost
in the CCR, OMA #7 may be necessary
to transfer both buses to their alternate
power supply. If OMA #7 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes, while
the time available is 30 minutes, which
results in 22.5 minutes of margin.
3.4.5 Conclusion for Fire Area F (Fire
Zone 7A)
Since the licensee described
postulated fire scenarios and Fire Zone
7A lacks an automatic fire suppression
system and any discernable separation
between the credited and redundant
equipment in the area, it is possible that
a fire would not be extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage or allow
reentry to the area to perform OMAs.
The NRC staff finds that the defense-indepth is insufficient demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
7A. OMA #6 was found to be
unacceptable for this fire zone. OMA #7
has insufficient time available
considering the lack of fire suppression
and therefore is unacceptable for this
fire zone. Therefore, the staff finds that
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an exemption from III.G.2 based on
these OMAs cannot be granted for Fire
Zone 7A.
that an exemption from III.G.2 based on
OMA #6 cannot be granted for Fire Zone
22A.
3.5 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
22A—Valve Corridor, Elevation 98′–0″)
3.6 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
27A—Corridor, Elevation 98′–0″)
3.5.1
3.6.1 Fire Prevention
The licensee stated that the fire
loading in this area is moderate and that
the fixed combustibles in this zone
consist of cable insulation, vinyl covers,
control cabinets and panels, plastic, and
office supplies and that transient
combustibles consist of trash, rubber,
paint, and radiation boundaries. The
licensee also stated that the ignition
sources in the area consist of cable,
junction boxes, dry transformers, motor
control center (MCC) vertical panels,
and electrical panels.
Fire Prevention
The licensee stated that the fire
loading in this area is low and that there
are no fixed or transient combustibles in
this zone, except for small amounts of
cable insulation. The licensee also
stated that the ignition sources in the
area consist of electrical cabinets.
3.5.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
22A does not have an automatic fire
detection or automatic suppression
system installed.
3.5.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
22A has a ceiling height of
approximately 14′–0″ and an
approximate floor area of 115 square
feet. The licensee stated that if cables for
LCV–112C are affected, it may be
necessary to align an alternate water
supply to the charging pump suction.
The licensee stated that cables
associated with valves LCV–112C and
LCV–112B are located in Fire Zone 22A.
3.5.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 22A)
3.5.4.1 OMA #6—Align charging
pump suction to RWST
OMA #6 was evaluated in Sections
3.2.4.1 and 3.2.5 above. As stated in
Section 3.2.4.1, there is insufficient
margin to perform OMA #6 for any fire
zone in Fire Area F.
srobinson on DSK4SPTVN1PROD with NOTICES
3.5.5 Conclusion for Fire Area F (Fire
Zone 22A)
Since the licensee described
postulated fire scenarios and Fire Zone
22A lacks any automatic fire detection
or automatic suppression system, it is
possible that a fire would not be
extinguished in a reasonable amount of
time to ensure that at least one train of
equipment remains free of fire damage
or allow reentry to the area to perform
OMAs. Additionally, there is
insufficient margin available for the
OMA credited in this area to provide
assurance that safe shutdown capability
will be maintained following the
postulated fire events. Therefore, the
staff finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 22A and
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3.6.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
27A has an automatic fire detection
system installed but does not have an
automatic fire suppression system
installed. The licensee also stated that
the detection system was designed and
installed in accordance with NFPA 72D,
1975 Edition.
3.6.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
27A has a ceiling height of
approximately 15′–0″ and an
approximate floor area of 5,450 square
feet. The licensee stated that cables
associated with valves LCV–112C, LCV–
112B, HCV–142 and 227 are also located
in this fire zone. As discussed in
Section 3.0 above, the licensee could
not demonstrate any separation between
credited and redundant trains of
equipment.
3.6.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 27A)
3.6.4.1 OMA #5—Align Charging
Pump Makeup Path to RCS
The licensee stated that in order to
ensure a reliable charging makeup path
to the reactor coolant system (RCS), airoperated valve HCV–142 must remain
open or bypass valve 227, which is
normally motor-operated and normally
closed, must be opened. The licensee
stated that air-operated valve HCV–142
is assumed to fail closed as designed in
response to a loss of instrument air. The
licensee stated that if HCV–142 were to
close in response to a loss of instrument
air, and cables for valve 227 are
damaged in a manner that causes
normally closed motor-operated valve
227 to remain closed and unable to be
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7191
opened remotely from the CCR, OMA #5
would be used to locally open bypass
valve 227 in Fire Area A to restore or
maintain a reliable charging pump flow
path to the RCS.
If OMA #5 becomes necessary, the
licensee stated that they have assumed
a 60-minute waiting period before reentering the fire area, a 14-minute
diagnosis period, which is assumed to
transpire during the 60-minute waiting
period, and that the required time to
perform the action is 14 minutes, which
provides a total required time of 74
minutes while the time available is 75
minutes, which provides 1 minute of
margin. Although there is fire detection
in this zone, the NRC staff finds that 1
minute of margin is insufficient to
ensure the OMA can be accomplished
reliably. Therefore, the NRC staff finds
that OMA #5 is unacceptable for a fire
which initiates in Fire Zone 27A or for
any fire zone in Fire Area F.
3.6.4.2 OMA #6—Align Charging
Pump Suction to RWST
OMA #6 was evaluated in Sections
3.2.4.1 and 3.2.5 above. As stated in
Section 3.2.4.1, there is insufficient
margin to perform OMA #6 for any fire
zone in Fire Area F.
3.6.5 Conclusion for Fire Area F (Fire
Zone 27A)
Since the licensee described
postulated fire scenarios and Fire Zone
27A lacks an automatic fire suppression
system and any discernable separation
between the credited and redundant
equipment in the area, it is possible that
a fire would not be extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage or allow
reentry to the area to perform OMAs.
Also, the NRC staff finds that OMAs #5
and #6 are unacceptable for a fire which
initiates in Fire Zone 27A or for any fire
zone in Fire Area F. Therefore, the staff
finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 27A and
that an exemption from III.G.2 based on
OMA #5 and #6 cannot be granted for
Fire Zone 27A.
3.7 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
33A—MCC 26AA and MCC 26BB Room,
Elevation 98′–0″)
3.7.1 Fire Prevention
The licensee stated that the fire
loading in this area is moderate and that
the fixed combustibles in this zone
consist of cable insulation and electrical
panels and that transient combustibles
consist of trash, paint, and radiation
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boundaries. The licensee also stated that
the ignition sources in the area consist
of cables, junction boxes, dry
transformers, MCC vertical panels, and
electrical cabinets.
3.7.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
33A does not have an automatic fire
detection or automatic suppression
system installed.
3.7.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
33A has an approximate floor area of
1,122 square feet and is open to Fire
Zone 27A above. The licensee stated
that cables associated with charging
pump makeup valves HCV–142 and 227
are located in this fire zone. As
discussed in Section 3.0 above, the
licensee could not demonstrate any
separation between credited and
redundant trains of equipment.
3.7.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 33A)
3.7.4.1 OMA #5—Align Charging
Pump Makeup Path to RCS
OMA #5 was evaluated in Section
3.6.4.1 above. As stated in Section
3.6.4.1, 1 minute of margin for OMA #5
is too low to credit OMA #5 as being a
reliable method of restoring the charging
pump flow path to the RCS for any fire
zone in Fire Area F.
srobinson on DSK4SPTVN1PROD with NOTICES
3.7.5 Conclusion for Fire Area F (Fire
Zone 33A)
Since the licensee described
postulated fire scenarios and Fire Zone
33A lacks an automatic fire detection
system or automatic suppression
system, and any discernable separation
between the credited and redundant
equipment in the area, it is possible that
a fire would not be extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage or allow
reentry to the area to perform OMAs.
There is insufficient margin available
for OMA #5 for any fire in Fire Area F
to provide assurance that safe shutdown
capability will be maintained following
the postulated fire events. Therefore, the
staff finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 33A and
that an exemption from III.G.2 based on
OMA #5 cannot be granted for Fire Zone
33A.
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3.8 Fire Area F—Primary Auxiliary
Building and Fan House (Fire Zone
59A—Fan House Elevation 72′–0″, 80′–
0″, and 92′–0)
3.8.1 Fire Prevention
The licensee stated that the fire
loading in this area is high and that the
fixed combustibles in this zone consist
of charcoal and cable insulation and
that transient combustibles consist of
trash, paint, and radiation boundaries.
The licensee also stated that the ignition
sources in the area consist of electrical
cabinets.
3.8.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
59A has a partial automatic fire
suppression system installed at the
charcoal filter housings and a partial
automatic fire detection system installed
that consists of Thermistor wire for the
charcoal filters and an ionization
detector outside the charcoal filter
enclosure on the 72′–0″ elevation. The
licensee also stated that the detection
system was designed and installed in
accordance with NFPA 72D, 1967
Edition and the fire suppression system
was designed and installed in
accordance with NFPA 13, 1972 Edition
and NFPA 15, 1969 Edition. The partial
fire detection system may not be
effective at detecting fires in other areas
of this fire zone, as it is located on the
lower level of the fire zone.
3.8.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
59A has an approximate floor area of
1,400 square feet and an approximate
ceiling height of 29′–0″. Fire Zone 59A
contains cable ECD3–EXF6/2, which is
associated with motor-operated valve
227.
3.8.4 OMAs Credited for a Fire in Fire
Area F (Fire Zone 59A)
3.8.4.1 OMA #5—Align Charging
Pump Makeup Path to RCS
OMA #5 was evaluated in Section
3.6.4.1 above. As stated in Section
3.6.4.1, 1 minute of margin for OMA #5
is too low to credit OMA #5 as being a
reliable method of restoring the charging
pump flow path to the RCS for any fire
zone in Fire Area F.
3.8.5 Conclusion for Fire Area F (Fire
Zone 59A)
Since the licensee described
postulated fire scenarios and Fire Zone
59A has a high combustible loading and
lacks an automatic fire detection system
or automatic suppression system
throughout the zone, except where
PO 00000
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installed at the charcoal filters, it is
possible that a fire would not be
detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage or allow
reentry to the area to perform OMAs.
There is insufficient margin available
for OMA #5 for any fire in Fire Area F
to provide assurance that safe shutdown
capability will be maintained following
the postulated fire events. Therefore, the
staff finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 59A and
that an exemption from III.G.2 based on
OMA #5 cannot be granted for Fire Zone
59A.
3.9 Fire Area H—Containment
Building (Fire Zone 70A—23 and 24
Reactor Coolant Pump Area, Elevation
46–0″)
3.9.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation and reactor coolant
pump (RCP) lube oil and that transient
combustibles are administratively
controlled. The licensee also stated that
the ignition sources in the area consist
of cables, junction boxes, and RCP
motors.
3.9.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
70A has a partial automatic fire
detection system installed that consists
of ionization detectors located over
RCPs 23 and 24 but does not have an
automatic fire suppression system. The
licensee also stated that the detection
system was designed and installed in
accordance with NFPA 72D, 1975
Edition.
3.9.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
70A has an approximate floor area of
3,320 square feet and an approximate
ceiling height of 25′–8″. The licensee
also stated that there is an oil collection
system provided for RCPs 23 and 24.
The licensee stated that cable Y15–H50
for valve 204B and cable Y17–H55 for
valve 204A are located in this zone.
Valve 204A is an air-operated valve
which allows charging pump flow to an
RCS hot leg. Valve 204B is an airoperated valve which allows charging
pump flow to an RCS cold leg. The
licensee stated that cables and
components associated with redundant
trains of normal instrumentation
required to support normal safe
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shutdown operations are located in this
zone. The normal safe shutdown
instrumentation potentially affected by
fire includes:
• SG wide range level: LT–417D, LT–
427D, LT–437D, LT–447D
• Pressurizer level: LT–459, LT–460,
LT–461, LT–462
• Source-range neutron monitoring:
N–31, N–32
• RCS loop hot and cold leg
temperatures: TE–411 A/1, TE–413, TE–
422A/1, TE–423, TE–431A/1, TE–433,
TE–440A/1, TE–443
3.9.4 OMAs Credited for a Fire in Fire
Area H (Fire Zone 70A)
srobinson on DSK4SPTVN1PROD with NOTICES
3.9.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
It is possible that a fire in this zone
could result in a loss of a reliable
charging makeup path to the RCS due to
air-operated charging system valves
204A and 204B spuriously closing. The
licensee stated that normal reactor
coolant makeup to the RCS may be
established via hot leg injection through
valve 204A or cold leg injection through
valve 204B and that in order to
accomplish this, normal reactor coolant
makeup air-operated charging system
valves 204A and 204B would need to be
failed open by de-energizing 125VDC
control power in the CCR or by closing
the air supply isolation valve IA–501,
which is outside the containment
building, to isolate instrument air.
Procedure 2–ONOP–FP–001 includes
preemptive actions to establish the
charging makeup path by failing open
charging injection valves 204A and
204B. This is accomplished by removing
DC control power to the valves by
pulling the control power fuses in the
CCR or tripping breakers 5 and 15 on
125 VDC DP 21 and 22, respectively.
Procedure 2–AOP–SSD–1 includes
actions to close the air supply isolation
valve IA–501, and the loss of air
pressure will cause valves 204A and
204B to fail open.
If a fire were to occur and causes
valves 204A and 204B to remain closed,
the licensee stated that OMA #8 is
available to align the charging pump
makeup path to the RCS. If OMA #8
becomes necessary, the licensee stated
that they have assumed a 14-minute
diagnosis period and that the required
time to perform the action is 14
minutes, which results in a total
required time of 28 minutes while the
time available is 75 minutes, which
provides 47 minutes of margin.
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3.9.4.2 OMAs #9 and #10—Activate or
Enable Alternate Safe Shutdown System
Pneumatic Instruments and Enable
Alternate Safe Shutdown System
Source-Range Channel and Loop 21 and
22 hot and cold leg Temperature
Channels
In the event that a fire in Fire Area H
disables redundant trains of normal safe
shutdown instrumentation identified in
Section 3.9.3, the licensee may make
use of OMAs performed in a different
fire area to place in service Alternate
Safe-Shutdown System instruments
which have been separated from the
normal shutdown instruments in
accordance with III.G.2(f). The licensee
also stated that in locations where
normal and alternate shutdown
instrument cables are separated by less
than 20 feet, the cables of the alternate
shutdown instruments are protected by
a radiant energy shield as required to
meet III.G.2(f). The Alternate Safe
Shutdown System instrument channels
include:
• RCP Loop 21 and 22 hot and cold
leg temperature (TE–5139, TE–5140,
TE–5141, TE–5142),
• SG 21 and 22 level (LT–5001, LT–
5002),
• Pressurizer level (LT–3101),
pressurizer pressure (PT–3105), and
• Source range neutron monitoring
(NE–5143)
The licensee stated that cables
associated with Loop 21 and 22 hot and
cold leg temperature channels TE–5139,
5140, 5141, 5142, and source-range
channel NE–5143 are routed into
containment through penetration H20,
and are protected with a radiant energy
shield throughout the containment
annulus area, where they are in
proximity to cable trays or conduits
containing the corresponding normal
RCS loop temperature channels. The
licensee also stated that there are no
cables associated with the balance of the
alternate SSD instruments (LT–5001,
LT–5002, PT–3105, and LT- 3101), since
these channels utilize pneumaticallyoperated transducers. The licensee
stated that the Alternate Safe Shutdown
System pneumatic instrumentation can
be expected to remain operable despite
fire-induced failure of the redundant
electrically-operated instrumentation,
since the Alternate Safe Shutdown
System instruments do not utilize any
electrical components or cables.
In addition, the licensee stated that all
four RCPs are equipped with RCP lube
oil collection systems which capture
any leakage from credible leak sites and
transport it to collection tanks located
outside the bioshield wall in Fire Zone
77A.
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7193
In the event that redundant trains of
normal shutdown instrumentation are
damaged by a fire, OMAs #9 and #10 are
available to activate the following
Alternate Safe Shutdown System
instruments:
• Pneumatic instruments
Æ SG level (LT–5001, LT–5002),
Æ Pressurizer pressure (PT–3105), and
Æ Pressurizer level (LT–3101)
• Source-range channel (NE–5143),
and
• Loop 21 and 22 hot leg (Th) and
cold leg (Tc) temperature channels (TE–
5139, TE–5140, TE–5141, TE–5142)
Procedure 2–AOP–SSD–1 includes
actions to place these Alternate Safe
Shutdown System instruments in
service. If OMAs #9 and #10 become
necessary, the licensee stated that they
have assumed less than 1 minute for
diagnosis, with the normal instruments
assumed to be failed at the start of the
event, and that the required time to
perform the action is 13 minutes for the
pneumatic instruments. The shortest
timeline is to monitor level in the SGs,
which could approach boil-dry
conditions within 34 minutes. This
results in 21 minutes of margin for the
pneumatic instruments. The five
electronic instruments are then
energized by the same operator who
made the pneumatic instruments
operable, so it takes 24 minutes to put
the electronic instruments in service.
However, the electronic instrument
readings are not needed until later in
the scenario. This results in a total
required time of 13 minutes while the
time available is 34 minutes, which
provides 21 minutes of margin.
3.9.5 Conclusion for Fire Area H (Fire
Zone 70A)
Given the low combustible fuel
loading, the oil collection system for the
RCPs, automatic smoke detection
system, large volume of the space, and
preemptive nature of the OMAs, it is
unlikely that a fire would occur and go
undetected and not be extinguished in
a reasonable amount of time to ensure
that at least one train of equipment
necessary for safe shutdown remains
free of fire damage. In the unlikely event
that a fire does occur and causes damage
that necessitates OMAs #8, #9, and #10,
the actions are clear and proceduralized
with 47 minutes of margin for OMA #8
and 21 minutes of margin for OMAs #9
and #10, available to provide assurance
that safe shutdown capability will be
maintained following the postulated fire
events. Therefore, the NRC staff finds
that there is adequate defense-in-depth
provided for Fire Zone 70A and that
OMAs #8, #9, and #10 are acceptable for
the purpose of providing the level of
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protection intended by the regulation,
and that an exemption from III.G.2
based on these OMAs is granted for Fire
Zone 70A.
3.10 Fire Area H—Containment
Building (Fire Zone 71A—21 and 22
Reactor Coolant Pump Area, Elevation
46′–0″)
3.10.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation, RCP lube oil, and
other miscellaneous combustibles and
that transient combustibles are
administratively controlled. The
licensee also stated that the ignition
sources in the area consist of cables,
junction boxes, RCP motors, and pumps.
3.10.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
71A has a partial automatic fire
detection system installed that consists
of ionization detectors located over
RCPs 21 and 22 but does not have an
automatic fire suppression system. The
licensee also stated that the detection
system was designed and installed in
accordance with NFPA 72D, 1975
Edition.
3.10.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
71A has an approximate floor area of
3,320 square feet and an approximate
ceiling height of 25′8″. The licensee also
stated that there is an oil collection
system provided for RCPs 21 and 22.
The licensee stated that cable Y15–H50
for valve 204B and cable Y17–H55 for
valve 204A are located in this zone.
Valve 204A is an air-operated valve
which allows charging pump flow to an
RCS hot leg. Valve 204B is an airoperated valve which allows charging
pump flow to an RCS cold leg. As
discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
srobinson on DSK4SPTVN1PROD with NOTICES
3.10.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 71A)
3.10.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As discussed in Section 3.9.4.1 above,
if a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
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perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.10.5 Conclusion for Fire Area H (Fire
Zone 71A)
Given the low combustible fuel
loading, the oil collection system for the
RCPs, automatic smoke detection
system, large volume of the space, and
preemptive nature of OMA #8, it is
unlikely that a fire would occur and go
undetected and not be extinguished in
a reasonable amount of time to ensure
that at least one train of equipment
necessary for safe shutdown remains
free of fire damage. In the unlikely event
that a fire does occur and causes damage
that necessitates OMA #8, the actions
are clear and proceduralized with 47
minutes of margin available to provide
assurance that safe shutdown capability
will be maintained following the
postulated fire events. Therefore, the
NRC staff finds that there is adequate
defense-in-depth provided for Fire Zone
71A and that OMA #8 is acceptable for
the purpose of providing the level of
protection intended by the regulation,
and that an exemption from III.G.2
based on OMA #8 is granted for Fire
Zone 71A.
3.11.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
3.11 Fire Area H—Containment
Building (Fire Zone 72A—Outer
Annulus, Elevation 46′0″)
3.11.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation and that transient
combustibles are administratively
controlled. The licensee also stated that
the ignition sources in the area consist
of cables.
3.11.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
72A does not have an automatic fire
detection or automatic suppression
system installed.
3.11.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
72A has an approximate floor area of
1,100 square feet and an approximate
ceiling height of 22′0″. The licensee
stated that cables for valve 204B and
valve 204A are located in this zone.
Valve 204A is an air-operated valve
which allows charging pump flow to an
RCS hot leg. Valve 204B is an airoperated valve which allows charging
pump flow to an RCS cold leg. As
discussed in Section 3.0 above, the
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3.11.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 72A)
3.11.5 Conclusion for Fire Area H (Fire
Zone 72A)
Since the licensee described
postulated fire scenarios and Fire Zone
72A lacks an automatic fire detection
system or automatic suppression
system, and any discernable separation
between the credited and redundant
equipment in the area, it is credible that
a fire would not be detected and
extinguished in a reasonable amount of
time to ensure that at least one train of
equipment remains free of fire damage
following a fire event. Although there is
47 minutes of margin available for OMA
#8, Fire Zone 72A still lacks adequate
defense-in-depth. Therefore, the staff
finds that Fire Zone 72A’s defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved. As such, OMA #8 is
unacceptable for the purpose of
providing the level of protection
intended by the regulation and an
exemption from III.G.2 based on OMA
#8 cannot be granted for Fire Zone 72A.
3.12 Fire Area H—Containment
Building (Fire Zone 75A—Outer
Annulus, Elevation 46′–0″)
3.12.1 Fire Prevention
The licensee stated that the fire
loading in this area is moderate and that
the fixed combustibles in this zone
consist of cable insulation and that
transient combustibles are
administratively controlled. The
licensee also stated that the ignition
sources in the area consist of cables and
junction boxes.
3.12.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
75A does not have an automatic fire
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detection or automatic suppression
system installed.
3.12.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
75A has an approximate floor area of
1,100 square feet and an approximate
ceiling height of 22′–0″. The licensee
also stated that the Alternate Safe
Shutdown System instrumentation
cabling is protected with a radiant
energy shield. The licensee stated that
cables and components associated with
redundant trains of normal
instrumentation required to support
normal safe shutdown operations are
located in this zone. The normal safe
shutdown instrumentation potentially
affected by fire in Fire Area H includes:
• SG wide range level: LT–417D, LT–
427D, LT–437D, LT–447D
• Pressurizer level: LT–459, LT–460,
LT–461, LT–462
• Source-range neutron monitoring:
N–31, N–32
• RCS loop hot and cold leg
temperatures: TE–411 A/1, TE–413, TE–
422A/1, TE–423, TE–431A/1, TE–433,
TE–440A/1, TE–443
The licensee stated that cable Y15–
H50 for valve 204B and cable Y17–H55
for valve 204A are located in this zone.
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.12.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 75A)
srobinson on DSK4SPTVN1PROD with NOTICES
3.12.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
3.12.4.2 OMAs #9 and #10—Activate
or Enable Alternate Safe Shutdown
System Pneumatic Instruments and
Enable Alternate Safe Shutdown System
Source-Range Channel and Loop 21 and
22 Hot and Cold Leg Temperature
Channels
As discussed in Section 3.9.4.2 above,
in the event that a fire in Fire Area H
disables redundant trains of normal safe
shutdown instrumentation identified in
Section 3.9.3, the licensee may make
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21:29 Feb 09, 2012
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use of OMAs performed in a different
fire area to place in service Alternate
Safe Shutdown System instruments
which have been separated from the
normal shutdown instruments in
accordance with III.G.2(f). The licensee
also stated that in locations where
normal and alternate shutdown
instrument cables are separated by less
than 20 feet, the cables of the alternate
shutdown instruments are protected by
a radiant energy shield as required to
meet III.G.2(f).
If OMAs #9 and #10 become
necessary, the licensee stated that they
have assumed less than 1 minute for
diagnosis, with the normal instruments
assumed to be failed at the start of the
event, and that the required time to
perform the action is 13 minutes for the
pneumatic instruments. The shortest
timeline is to monitor level in the SGs,
which could approach boil-dry
conditions within 34 minutes. This
results in 21 minutes of margin for the
pneumatic instruments. The five
electronic instruments are then
energized by the same operator who
made the pneumatic instruments
operable, so it takes 24 minutes to put
the electronic instruments in service.
However, the electronic instrument
readings are not needed until later in
the scenario. This results in a total
required time of 13 minutes while the
time available is 34 minutes, which
provides 21 minutes of margin.
3.12.5 Conclusion for Fire Area H (Fire
Zone 75A)
Since the licensee described
postulated fire scenarios and Fire Zone
75A has a moderate combustible fuel
loading, lacks an automatic fire
detection system or automatic
suppression system, and any
discernable separation between the
credited and redundant equipment in
the area, it is credible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 47 minutes
of margin available for OMA #8 and 21
minutes of margin available for OMAs
#9 and #10, Fire Zone 75A still lacks
adequate defense-in-depth. Therefore,
the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 75A and
that OMAs #8, #9, and #10 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation and that an
exemption from III.G.2 based on these
OMAs cannot be granted for Fire Zone
75A.
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7195
3.13 Fire Area H—Containment
Building (Fire Zone 77A—Outer
Annulus)
3.13.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation and that transient
combustibles are administratively
controlled. The licensee also stated that
the ignition sources in the area consist
of cables and junction boxes.
3.13.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
77A does not have an automatic fire
detection or automatic suppression
system installed.
3.13.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
77A has an approximate floor area of
950 square feet and an approximate
ceiling height of 22′–0″. The licensee
stated that cables and components
associated with redundant trains of
normal instrumentation required to
support normal safe shutdown
operations are located in this zone. The
normal safe shutdown instrumentation
potentially affected by fire in Fire Area
H includes:
• SG wide range level: LT–417D, LT–
427D, LT–437D, LT–447D
• Pressurizer level: LT–459, LT–460,
LT–461, LT–462
• Source-range neutron monitoring:
N–31, N–32
• RCS loop hot and cold leg
temperatures: TE–411 A/1, TE–413, TE–
422A/1, TE–423, TE–431A/1, TE–433,
TE–440A/1, TE–443
The licensee stated that cable Y15–
H50 for valve 204B and cable Y17–H55
for valve 204A are located in this zone.
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.13.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 77A)
3.13.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
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minutes, which provides 47 minutes of
margin.
srobinson on DSK4SPTVN1PROD with NOTICES
3.13.4.2 OMAs #9 and #10—Activate
or Enable Alternate Safe Shutdown
System Pneumatic Instruments and
Enable Alternate Safe Shutdown System
Source-Range Channel and Loop 21 and
22 Hot and Cold Leg Temperature
Channels
As discussed in Section 3.9.4.2 above,
in the event that a fire in Fire Area H
disables redundant trains of normal safe
shutdown instrumentation identified in
Section 3.9.3, the licensee may make
use of OMAs performed in a different
fire area to place in service Alternate
Safe-Shutdown System instruments
which have been separated from the
normal shutdown instruments in
accordance with III.G.2(f). The licensee
also stated that in locations where
normal and alternate shutdown
instrument cables are separated by less
than 20 feet, the cables of the alternate
shutdown instruments are protected by
a radiant energy shield as required to
meet III.G.2(f).
If OMAs #9 and #10 become
necessary, the licensee stated that they
have assumed less than 1 minute for
diagnosis, with the normal instruments
assumed to be failed at the start of the
event, and that the required time to
perform the action is 13 minutes for the
pneumatic instruments. The shortest
timeline is to monitor level in the SGs,
which could approach boil-dry
conditions within 34 minutes. This
results in 21 minutes of margin for the
pneumatic instruments. The five
electronic instruments are then
energized by the same operator who
made the pneumatic instruments
operable, so it takes 24 minutes to put
the electronic instruments in service.
However, the electronic instrument
readings are not needed until later in
the scenario. This results in a total
required time of 13 minutes while the
time available is 34 minutes, which
provides 21 minutes of margin.
3.13.5 Conclusion for Fire Area H (Fire
Zone 77A)
Since the licensee described
postulated fire scenarios and Fire Zone
77A lacks an automatic fire detection or
automatic suppression system, and any
discernable separation between the
credited and redundant equipment in
the area, it is credible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 47 minutes
of margin available for OMA #8 and 21
minutes of margin available for OMAs
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#9 and #10, Fire Zone 77A still lacks
adequate defense-in-depth. Therefore,
the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 77A and
that OMAs #8, #9, and #10 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation and that an
exemption from III.G.2 based on these
OMAs cannot be granted for Fire Zone
77A.
3.14 Fire Area H—Containment
Building (Fire Zone 84A–22
Containment Fan Cooler Unit Area,
Elevation 68′–0″)
3.14.1
Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation and that transient
combustibles are administratively
controlled. The licensee also stated that
the ignition sources in the area consist
of cables.
3.14.5 Conclusion for Fire Area H (Fire
Zone 84A)
Since the licensee described
postulated fire scenarios and Fire Zone
84A lacks an automatic fire detection or
automatic suppression system, and any
discernable separation between the
credited and redundant equipment in
the area, it is credible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 47 minutes
of margin available for OMA #8, Fire
Zone 84A still lacks adequate defensein-depth. Therefore, the staff finds that
the defense-in-depth is insufficient to
demonstrate reasonable assurance that
safe shutdown can be achieved for a fire
in Fire Zone 84A and that OMA #8 is
unacceptable for the purpose of
providing the level of protection
intended by the regulation and that an
exemption from III.G.2 based on this
OMA cannot be granted for Fire Zone
84A.
3.14.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
84A does not have an automatic fire
detection or automatic suppression
system installed.
3.15 Fire Area H—Containment
Building (Fire Zone 85A—Incore
Detector Drive Area, Elevation 68′–0″)
3.15.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of cable insulation and that transient
combustibles are administratively
controlled.
3.14.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
84A has an approximate floor area of
910 square feet and an approximate
ceiling height of 27′–0″. The licensee
stated that cable Y15–H50 for valve
204B and cable Y17–H55 for valve 204A
are located in this zone. As discussed in
Section 3.0 above, the licensee could
not demonstrate any separation between
credited and redundant trains of
equipment.
3.14.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 84A)
3.14.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
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3.15.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
85A does not have an automatic fire
detection or automatic suppression
system installed.
3.15.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
85A has an approximate floor area of
560 square feet and an approximate
ceiling height of 27′–0″. The licensee
stated that cable Y15–H50 for valve
204B and cable Y17–H55 for valve 204A
are located in this zone. As discussed in
Section 3.0 above, the licensee could
not demonstrate any separation between
credited and redundant trains of
equipment.
3.15.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 85A)
3.15.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
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to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
3.15.5 Conclusion for Fire Area H (Fire
Zone 85A)
Since the licensee stated that a fire in
this zone could result in a loss of a
reliable charging makeup path to the
RCS and Fire Zone 85A lacks an
automatic fire detection or suppression
system, and any discernable separation
between the credited and redundant
equipment in the area, it is credible that
a fire would not be detected and
extinguished in a reasonable amount of
time to ensure that at least one train of
equipment remains free of fire damage
following a fire event. Although there is
47 minutes of margin available for OMA
#8, Fire Zone 85A still lacks adequate
defense-in-depth. Therefore, the staff
finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 85A and
that OMA #8 is unacceptable for the
purpose of providing the level of
protection intended by the regulation
and that an exemption from III.G.2
based on this OMA cannot be granted
for Fire Zone 85A.
3.16 Fire Area H—Containment
Building (Fire Zone 87A—Outer
Annulus, Elevation 46′–0″)
3.16.1 Fire Prevention
The licensee stated that the fire
loading in this area is low and that the
fixed combustibles in this zone consist
of MCCs and instrument racks and that
transient combustibles are
administratively controlled. The
licensee also stated that the ignition
sources in the area consist of MCCs.
srobinson on DSK4SPTVN1PROD with NOTICES
3.16.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
87A does not have an automatic fire
detection or automatic suppression
system installed.
3.16.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
87A has an approximate floor area of
434 square feet and an approximate
ceiling height of 22′–0″, which is
partially open to the containment dome
at the 95′–0″ elevation. The licensee
stated that cables and components
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associated with redundant trains of
normal instrumentation required to
support normal safe shutdown
operations are located in this zone. The
normal safe shutdown instrumentation
potentially affected by fire in Fire Area
H includes:
• SG wide range level: LT–417D, LT–
427D, LT–437D, LT–447D
• Pressurizer level: LT–459, LT–460,
LT–461, LT–462
• Source-range neutron monitoring:
N–31, N–32
• RCS loop hot and cold leg
temperatures: TE–411 A/1, TE–413, TE–
422A/1, TE–423, TE–431A/1, TE–433,
TE–440A/1, TE–443
The licensee stated that cable Y15–H50
for valve 204B and cable Y17–H55 for
valve 204A are located in this zone. As
discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.16.4 OMAs Credited for a Fire in
Fire Area H (Fire Zone 87A)
3.16.4.1 OMA #8—Align Charging
Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if
a fire were to occur and causes valves
204A and 204B to remain closed, the
licensee stated that OMA #8 is available
to align the charging pump makeup path
to the RCS. If OMA #8 becomes
necessary, the licensee stated that they
have assumed a 14-minute diagnosis
period and that the required time to
perform the action is 14 minutes, which
results in a total required time of 28
minutes while the time available is 75
minutes, which provides 47 minutes of
margin.
3.16.4.2 OMAs #9 and #10—Activate
or Enable Alternate Safe Shutdown
System Pneumatic Instruments and
Enable Alternate Safe Shutdown System
Source-Range Channel and Loop 21 and
22 Hot and Cold Leg Temperature
Channels
As discussed in Section 3.9.4.2 above,
in the event that a fire in Fire Area H
disables redundant trains of normal safe
shutdown instrumentation identified in
Section 3.9.3, the licensee may make
use of OMAs performed in a different
fire area to place in service Alternate
Safe Shutdown System instruments
which have been separated from the
normal shutdown instruments in
accordance with III.G.2(f). The licensee
also stated that in locations where
normal and alternate shutdown
instrument cables are separated by less
than 20 feet, the cables of the alternate
shutdown instruments are protected by
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7197
a radiant energy shield as required to
meet III.G.2(f).
If OMAs #9 and #10 become
necessary, the licensee stated that they
have assumed less than 1 minute for
diagnosis, with the normal instruments
assumed to be failed at the start of the
event, and that the required time to
perform the action is 13 minutes for the
pneumatic instruments. The shortest
timeline is to monitor level in the SGs,
which could approach boil-dry
conditions within 34 minutes. This
results in 21 minutes of margin for the
pneumatic instruments. The five
electronic instruments are then
energized by the same operator who
made the pneumatic instruments
operable, so it takes 24 minutes to put
the electronic instruments in service.
However, the electronic instrument
readings are not needed until later in
the scenario. This results in a total
required time of 13 minutes while the
time available is 34 minutes, which
provides 21 minutes of margin.
3.16.5 Conclusion for Fire Area H (Fire
Zone 87A)
Since the licensee described
postulated fire scenarios and Fire Zone
87A lacks an automatic fire detection or
suppression system, and any
discernable separation between the
credited and redundant equipment in
the area, it is credible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 47 minutes
of margin available for OMA #8 and 21
minutes of margin available for OMAs
#9 and #10, Fire Zone 87A still lacks
adequate defense-in-depth. Therefore,
the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 87A and
that OMAs #8, #9, and #10 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation and that an
exemption from III.G.2 based on these
OMAs cannot be granted for Fire Zone
87A.
3.17 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 17—
Turbine Oil Reservoir Area, Elevation
15′–0″ Unit 2 Turbine Building)
3.17.1
Fire Prevention
The licensee stated that the fire
loading in this area is high and that the
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fixed combustibles in this zone consist
of lube oil, fuel oil, and welding leads
and that transient combustibles consist
of trash, cardboard, lube oil, fiberglass,
rubber, wood, and plastic. The licensee
also stated that the ignition sources in
the area consist of electrical cabinets.
The licensee further stated that since
Fire Area J does not contain safetyrelated structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could challenge fire
safety. In addition, the licensee stated
that procedures OAP–017, ‘‘Plant
Surveillance and Operator Rounds’’ and
EN–MA–132, ‘‘Housekeeping’’ include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.17.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 17
has an automatic thermal fire detection
system installed throughout the zone
and an automatic aqueous foaming foam
spray system installed at the turbine
lube oil reservoir. The licensee also
stated that the detection system was
designed and installed in accordance
with NFPA 72D, 1967 Edition and the
fire suppression system was designed
and installed in accordance with NFPA
16, 1968 Edition.
srobinson on DSK4SPTVN1PROD with NOTICES
3.17.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 17
has an approximate floor area of 968
square feet and an approximate ceiling
height of 37′–0″. The licensee stated that
cable JC2–YA9, which is associated
with Buses 5A and 6A, is routed
through Fire Zones 17, 47A, and 50A
and that ignition sources in the zone
located less than 20 feet horizontally
from cable JC2–YA9 consists of
electrical cabinets, motors, and MCCs.
According to the licensee, the electrical
cabinets are separated from the cable by
approximately 3.8 feet horizontally and
1.9 feet vertically or greater and six
motors are located above the cable
routing separated from the cable by
approximately 2.1 feet horizontally or
greater. The licensee also stated that the
turbine lube oil reservoir is located in
Fire Zone 17. As discussed in Section
3.0 above, the licensee could not
demonstrate any separation between
credited and redundant trains of
equipment.
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Jkt 226001
3.17.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 17)
3.17.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on Bus 5A and 52/6A
and 52/TAO at Bus 6A and Remove
Control Power Fuses
The licensee stated that offsite power
is the preferred lineup for supplying the
480V loads on Buses 2A, 3A, 5A, and
6A. In the event that offsite power is not
available due to fire, the licensee stated
that the Emergency Diesel Generators
(EDGs) are credited to supply 480V
loads on Buses 2A, 3A, 5A, and 6A. The
licensee also stated that a fire in Fire
Zone 17 which damages certain cables
associated with 480V Buses 5A and/or
6A could prevent loading of Buses 5 and
6 from the EDGs, and thereby, result in
a loss of 480V power from the affected
bus(es). Since a fire in Fire Zone 17 may
impact the availability of offsite power,
the licensee stated that they assume
offsite power is unavailable at the start
of the fire event.
In the event that a fire occurs and
damages the cables identified above, the
licensee stated that OMA #11 is
available to restore or maintain power
by tripping breakers 52/5A and 52–SAC
on Bus 5A and Breakers 52/6A and 52/
TAO at Bus 6A in the 480V Switchgear
Room (Fire Area A) and removing their
control power fuses. The licensee stated
that loss of power to the affected buses
is detected by loss of indication in the
CCR. Loss of power to Bus 5A or Bus 6A
causes operators to immediately enter
procedure 2–AOP–480V–1. The
procedure directs operators to locally
inspect the switchgear, at which time
any remaining untripped breakers (i.e.,
52/5A, 52–SAC, 52/6A, 52/TAO) would
be noted and locally tripped as
necessary. If OMA #11 becomes
necessary, the licensee stated that they
have assumed that a loss of offsite
power occurs at the beginning of the fire
event and that the required time to
perform the action is 10 minutes while
the time available is 60 minutes, which
provides 50 minutes of margin. The
NRC staff finds that OMA #11 has
acceptable margin for all fire zones in
Fire Area J.
3.17.5 Conclusion for a Fire in Fire
Area J (Fire Zone 17)
Given the fire detection system,
automatic fire suppression system, and
large volume of the space, it is unlikely
that a fire would occur and go
undetected and not be extinguished in
a reasonable amount of time to ensure
that at least one train of equipment
necessary for safe shutdown remains
free of fire damage. In the unlikely event
that a fire does occur and causes damage
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that necessitates OMA #11, the action is
clear and proceduralized with 50
minutes of margin available to provide
assurance that safe shutdown capability
will be maintained following the
postulated fire events. Therefore, the
NRC staff finds that there is adequate
defense-in-depth provided for Fire Zone
17 and that OMA #11 is acceptable for
the purpose of providing the level of
protection intended by the regulation,
and that an exemption from III.G.2
based on OMA #11 is granted for Fire
Zone 17.
3.18 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 19—Station
Air Compressor Area, Elevation 15′–0″
Unit 2 Turbine Building)
3.18.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
primary fixed combustible in this zone
is lube oil, which is contained in the
turbine lube oil piping system, and that
transient combustibles consist of trash,
cleaning rags, lube oil, and paint. The
licensee also stated that the ignition
sources in the area consist of a motor,
a compressor, and an electrical cabinet.
The licensee further stated that since
Fire Area J does not contain safetyrelated structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could challenge fire
safety. In addition, the licensee stated
that procedures OAP–017, ‘‘Plant
Surveillance and Operator Rounds’’ and
EN–MA–132, ‘‘Housekeeping’’ include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.18.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 19
does not have a fire detection or
automatic fire suppression system
installed.
3.18.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 19
has an approximate floor area of 798
square feet and an approximate ceiling
height of 21′–0″. The licensee stated that
a fire in Fire Area J which damages
certain cables associated with 480V
Buses 5A and/or 6A could prevent
loading of Buses 5A and 6A from the
EDGs, and thereby, result in a loss of
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480VAC power from the affected
bus(es). According to the licensee,
cables associated with Buses 5A and 6A
are located in this fire zone. The
licensee stated that cable AG5–XA5,
which is associated with Bus 5A, is
located in Fire Zone 19. The licensee
also stated that the ignition sources in
the zone located less than 20 feet
horizontally from cable AG5–XA5
consist of seven electrical cabinets, a
150kVA dry transformer, three motors,
and an MCC. According to the licensee,
three electrical cabinets are located
under the cable separated by
approximately 3 feet vertically or
greater, the remaining four electrical
cabinets are separated from the cable by
approximately 2 feet horizontally or
greater, the 150 kVA dry transformer is
separated from the cable by
approximately 1.6 feet horizontally and
6.7 feet vertically, the motors are
separated from the cable by
approximately 4.6 feet horizontally or
greater, and the MCC is separated from
the cable by approximately 7.5 feet
horizontally.
The licensee stated that cables PC9–
XA5/1 and PC9–XA5/2, which are
associated with Bus 5A, are routed
between two junction boxes in Fire
Zone 19 for approximately 2 feet. The
licensee also stated that the ignition
sources in the zones located less than 20
feet horizontally from the cable consist
of three motors, which are all separated
from the cables by approximately 4.6
feet horizontally or greater. The licensee
also stated that cable XA5–WU9,
associated with Bus 5A, is routed in Fire
Zone 19 from east to west terminating
at the Station Air Compressor. The
licensee stated that the ignition sources
in the zone located less than 20 feet
horizontally from the cable consist of
two motors, which are separated from
the cable by approximately 4.6 feet
horizontally or greater. As discussed in
Section 3.0 above, the licensee could
not demonstrate any separation between
credited and redundant trains of
equipment.
srobinson on DSK4SPTVN1PROD with NOTICES
3.18.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 19)
3.18.4.1 OMA #11—Trip Breakers
52/5A and 52–SAC on bus 5A and
52/6A and 52/TAO at bus 6A and
Remove Control Power Fuses.
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
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3.18.5 Conclusion for Fire Area J (Fire
Zone 19)
automatic fire suppression system
installed.
Since the licensee described
postulated fire scenarios and Fire Zone
19 lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11, Fire
Zone 19 still lacks adequate defense-indepth. Therefore, the staff finds that the
defense-in-depth is insufficient to
demonstrate reasonable assurance that
safe shutdown can be achieved for a fire
in Fire Zone 19 and that OMA #11 is
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on this OMA cannot
be granted for Fire Zone 19.
3.19.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 25
has an approximate floor area of 92
square feet and an approximate ceiling
height of 10′–0″. The licensee stated that
cables EDB8–EPB3, EGA9–EDB8/4, and
EGA9–EDB8/5 are routed through Fire
Zone 25 in rigid steel conduit and that
since cables EGA9–EDB8/4 and EGA9–
EDB8/5 originate inside the battery
room at the batteries, there is no
separation between the cables and the
batteries. The licensee also stated that
ignition sources in the zone located less
than 20 feet horizontally from cable
EDB8–EPB3 consist of an MCC, a 45kVA
dry transformer, and two electrical
cabinets. According to the licensee, the
MCC is separated from the cable by
approximately 18.5 feet horizontally,
the transformer is separated from the
cable by approximately 13.6 feet
horizontally, one electrical cabinet is
separated from the cable by
approximately 12.8 feet horizontally,
and the second electrical cabinet is
separated from the cable by
approximately 5.5 feet horizontally. As
discussed in Section 3.0 above, the
licensee could not demonstrate any
separation between credited and
redundant trains of equipment.
3.19 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 25—23
Battery Room, Elevation 33′–0″ of the
Unit 1 Superheater Building)
3.19.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
primary fixed combustibles in this zone
are batteries and cable insulation and
that transient combustibles are
administratively controlled. The
licensee also stated that the ignition
sources in the area consist of batteries
and electrical cabinets. The licensee
further stated that since Fire Area J does
not contain safety-related structures,
systems or components, it is not subject
to the explicit transient combustible
controls of procedure EN–DC–161.
However, operator rounds performed
each shift provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017, ‘‘Plant
Surveillance and Operator Rounds’’ and
EN–MA–132, ‘‘Housekeeping’’ include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.19.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 25
does not have a fire detection or
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3.19.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 25)
3.19.4.1 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 25. If this were to occur,
the licensee stated that OMA #12 is
available to swap Instrument Buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
3.19.5 Conclusion for Fire Area J (Fire
Zone 25)
Since the licensee described
postulated fire scenarios and Fire Zone
25 lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
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that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 22.5
minutes of margin available for OMA
#12, Fire Zone 25 still lacks adequate
defense-in-depth. Therefore, the NRC
staff finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 25 and
that OMA #12 is unacceptable for the
purpose of providing the level of
protection intended by the regulation.
Therefore, the NRC staff finds that an
exemption from III.G.2 based on OMA
#12 cannot be granted for Fire Zone 25.
3.20 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 39A—
Mezzanine Floor, Elevation 36′–9″ Unit
2 Turbine Building)
3.20.1 Fire Prevention
The licensee stated that the fire
loading in this zone is moderate and
that the fixed combustibles in this zone
consist of cable insulation, plastic, and
cellulose and that transient
combustibles in this zone consist of
trash, wood, and lube oil. The licensee
also stated that the ignition sources in
this zone consist of cables, junction
boxes, electrical cabinets, and motors.
The licensee further stated that since
Fire Area J does not contain safetyrelated structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
srobinson on DSK4SPTVN1PROD with NOTICES
3.20.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
39A does not have a fire detection or
automatic fire suppression system
installed.
3.20.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
39A has an approximate floor area of
7,592 square feet and an approximate
ceiling height of 16′–0″. The licensee
stated that cable AG5–XA5, which is
associated with instrument buses 23 and
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Jkt 226001
23A and buses 5A and 6A, is located in
Fire Zone 39A. The licensee also stated
that the ignition sources in the zone
located less than 20 feet horizontally
from cable AG5–XA5 consist of seven
electrical cabinets, a 150 kVA dry
transformer, three motors, and an MCC.
According to the licensee, three
electrical cabinets are located under the
cable separated by approximately 3 feet
vertically or greater, the remaining four
electrical cabinets are separated from
the cable by approximately 2 feet
horizontally or greater, the 150 kVA dry
transformer is separated from the cable
by approximately 1.6 feet horizontally
and 6.7 feet vertically, the motors are
separated from the cable by
approximately 4.6 feet horizontally or
greater, and the MCC is separated from
the cable by approximately 7.5 feet
horizontally. As discussed in Section
3.0 above, the licensee could not
demonstrate any separation between
credited and redundant trains of
equipment.
3.20.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 39A)
3.20.4.1 OMA #11—Trip breakers 52/
5A and 52–SAC on bus 5A and 52/6A
and 52/TAO at bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
3.20.4.2 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 39A. If this were to occur,
the licensee stated that OMA #12 is
available to swap Instrument Buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
3.20.5 Conclusion for Fire Area J (Fire
Zone 39A)
Since the licensee described
postulated fire scenarios and Fire Zone
39A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
PO 00000
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remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11 and
22.5 minutes of margin available for
OMA #12, Fire Zone 39A still lacks
adequate defense-in-depth. Therefore,
the NRC staff finds that the defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
39A and that OMAs #11 and #12 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 39A.
3.21 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 43A—
Ground Floor, Elevation 15–0″ Unit 2
Turbine Building)
3.21.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cable insulation, lube oil, plastic,
wood, electrical panels, and cabinets
and that the transient combustibles in
this zone consist of trash, cardboard
drums, cleaning rags, lube oil, plastic,
fiberglass ladders, and paint. The
licensee also stated that the ignition
sources in this zone consist of cables,
junction boxes, MCC, motors, pumps,
electrical cabinets, high voltage arcing
faults, and an air dryer. The licensee
further stated that since Fire Area J does
not contain safety-related structures,
systems or components, it is not subject
to the explicit transient combustible
controls of procedure EN–DC–161.
However, operator rounds performed
each shift provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.21.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
43A does not have a fire detection or
automatic fire suppression system
installed.
3.21.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
43A has an approximate floor area of
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6,600 square feet and an approximate
ceiling height of 21′–0″. The licensee
stated that cable JC2–YA9, which is
associated with Buses 5A and 6A, is
routed through Fire Zone 43A in a tray
located approximately 15 feet above the
floor and that ignition sources in the
zone located less than 20 feet
horizontally from the cable consist of
two MCCs, an air dryer skid, 6.9 kV
switchgear, and an electrical cabinet.
According to the licensee, the MCCs are
located under the cable routing
separated from the cable by
approximately 7.7 feet vertically, the air
dryer skid is separated from the cable by
approximately 6.1 feet horizontally, the
electrical cabinet is separated from the
cable by approximately 2 feet
horizontally and 9.2 feet vertically, and
the 6.9 kV switchgear is separated from
the cable by approximately 0.7 feet
horizontally and 7.7 feet vertically.
The licensee also stated that cable
AC4–BA6 is routed through Fire Zone
43A in a tray located approximately 12
feet above the floor and that ignition
sources in the zone located less than 20
feet horizontally from the cable consist
of 6.9 kV switchgear and an electrical
cabinet. According to the licensee, the
6.9 kV switchgear is separated from the
cable by zero feet horizontally and
approximately 3.7 feet vertically and the
electrical cabinet is separated from the
cable by approximately 6 feet
horizontally.
The licensee also stated that cable
AA3–BA5 is associated with instrument
buses 23 and 23A and is routed through
Fire Zone 43A in tray located
approximately 14 feet above the floor
and that ignition sources in the zone
located less than 20 feet horizontally
from the cable consist of 6.9 kV
switchgear and an electrical cabinet.
According to the licensee, the 6.9 kV
switchgear is separated from the cable
by approximately 0 feet horizontally
and 5 feet vertically and the electrical
cabinet is separated from the cable by
approximately 3 feet horizontally and
7 feet vertically.
The licensee also stated that cable
AD1–BA8 is associated with instrument
buses 23 and 23A and is routed through
Fire Zone 43A in tray located
approximately 14 feet above the floor
and that ignition sources in the zone
located less than 20 feet horizontally
from the cable consist of 6.9 kV
switchgear and an electrical cabinet.
According to the licensee, the 6.9 kV
switchgear is separated from the cable
by approximately 0 feet horizontally
and 5.6 feet vertically and the electrical
cabinet is separated from the cable by
approximately 6 feet horizontally.
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Jkt 226001
The licensee stated that cable ECE19–
MN3/01, which is associated with valve
LCV–112B, is routed through Fire Zone
43A in a cable tray located
approximately 13 feet above the floor
and that ignition sources in the zone
located less than 20 feet horizontally
from the cable consist of an MCC, an air
dryer skid, 6.9 kV switchgear, a portable
Duraline power station, and an
electrical cabinet. According to the
licensee, the MCC is separated from the
cable by approximately 3.2 feet
horizontally and 0 feet vertically, the air
dryer skid is separated from the cable by
approximately 7.7 feet horizontally and
2.6 feet vertically, the electrical cabinet
is separated from the cable by
approximately 2 feet horizontally and
7.3 feet vertically, the 6.9 kV switchgear
is separated from the cable by
approximately 0.7 feet horizontally and
5.8 feet vertically, and the Duraline
power station is separated from the
cable by approximately 19.5 feet
horizontally.
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.21.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 43A)
3.21.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on Bus 5A and 52/6A
and 52/TAO at Bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
3.21.4.2 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that Instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 43A. If a fire were to occur
and causes a loss of offsite power and
damages the cables identified above, the
licensee stated that OMA #12 is
available to swap Instrument Buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
3.21.4.3 OMA #13—Align Charging
Pump Suction to RWST
The licensee stated that fire-induced
cable damage may render alternate
charging pump suction supply valve
LCV–112B (normally closed RWST
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Fmt 4703
Sfmt 4703
7201
outlet valve) inoperable. In the event
that cable failures have rendered LCV–
112B inoperable, local valve
manipulations are required to support
alignment of the charging pump suction
to the alternate source, the RWST.
If a fire were to occur and renders the
alternate charging pump suction supply
valve LCV–112B inoperable, the
licensee stated that OMA #13 is
available to locally close valve LCV–
112C and open manual valve 288 to
provide a bypass around RWST outlet
valve LCV–112B and provide water to
the charging pump suction. If OMA #13
becomes necessary, the licensee stated
that they have assumed a 14-minute
diagnosis period and that the required
time to perform the action is 18 minutes
while the time available is 75 minutes,
which provides 43 minutes of margin.
3.21.5 Conclusion for Fire Area J (Fire
Zone 43A)
Since the licensee described
postulated fire scenarios and Fire Zone
43A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11, 22.5
minutes of margin available for OMA
#12, and 43 minutes of margin available
for OMA #13, Fire Zone 43A lacks
adequate defense-in-depth. Therefore,
the NRC staff finds that the defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
43A and that OMAs #11, #12, and #13
are unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 43A.
3.22 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 45A—
Ground Floor, Elevation 15–0″ and
3′–3″ of the Unit 2 Turbine Building)
3.22.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cable insulation, lube oil, vinyl
insulation, and hydrogen and that the
transient combustibles in this zone
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consist of trash, cardboard drums, lube
oil, fiberglass ladders, paint, and
radiation boundaries. The licensee also
stated that the ignition sources in this
zone consist of cables, junction boxes,
MCC, motors, pumps, and electrical
cabinets. The licensee further stated that
since Fire Area J does not contain
safety-related structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.22.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
45A does not have a fire detection or
automatic fire suppression system
installed.
srobinson on DSK4SPTVN1PROD with NOTICES
3.22.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
45A has an approximate floor area of
5,380 square feet and an approximate
ceiling height of 12′–4″. The licensee
stated that cable AG5–XA5, which
affects buses 5A and 6A, is located in
Fire Zone 45A and that ignition sources
in the zone located less than 20 feet
horizontally from cable AG5–XA5
consist of seven electrical cabinets, a
150KVA dry transformer, three motors,
and an MCC. According to the licensee,
three electrical cabinets are located
under the cable separated by
approximately 3 feet vertically or
greater, four electrical cabinets are
separated from the cable by
approximately 2 feet horizontally or
greater, the 150KVA dry transformer is
separated from the cable by
approximately 1.6 feet horizontally and
6.7 feet vertically. The motors are
separated from the cable by
approximately 4.6 feet horizontally or
greater, and the MCC is separated from
the cable by approximately 7.5 feet
horizontally. As discussed in Section
3.0 above, the licensee could not
demonstrate any separation between
credited and redundant trains of
equipment.
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Jkt 226001
3.22.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 45A)
3.22.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on Bus 5A and 52/6A
and 52/TAO at Bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
3.22.5 Conclusion for Fire Area J (Fire
Zone 45A)
Since the licensee described
postulated fire scenarios and Fire Zone
45A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11, Fire
Zone 45A still lacks adequate defensein-depth. The NRC staff finds that the
defense-in-depth is insufficient to
demonstrate reasonable assurance that
safe shutdown can be achieved for a fire
in Fire Zone 45A and that OMA #11 is
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on OMA #11 cannot
be granted for Fire Zone 45A.
3.23 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 46A—
Ground Floor, Elevation 12′–0″ and 3′–
3″ Unit 2 Turbine Building)
3.23.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cable insulation and lube oil and that
the transient combustibles in this zone
consist of trash, cleaning rags, lube oil,
and paint. The licensee also stated that
the ignition sources in this zone consist
of cables, junction boxes, motors,
pumps, and electrical cabinets. The
licensee further stated that since Fire
Area J does not contain safety-related
structures, systems or components, it is
not subject to the explicit transient
combustible controls of procedure EN–
DC–161. However, operator rounds
performed each shift provide for the
monitoring of combustibles that could
present an unacceptable fire safety
challenge. In addition, the licensee
PO 00000
Frm 00088
Fmt 4703
Sfmt 4703
stated that procedures OAP–017, ‘‘Plant
Surveillance and Operator Rounds,’’
and EN–MA–132, ‘‘Housekeeping,’’
include guidance for monitoring general
area cleanliness as well as monitoring
for accumulations of combustibles.
3.23.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
46A does not have a fire detection or
automatic fire suppression system
installed.
3.23.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
46A has an approximate floor area of
12,350 square feet and an approximate
ceiling height of 12′–4″. The licensee
stated that cable JC2–YA9, which is
associated with Buses 5A and 6A, is
routed through Fire Zone 46A in a tray
located approximately 15 feet above the
floor and that ignition sources in the
zone located less than 20 feet
horizontally from the cable consist of
two MCCs, an air dryer skid, 6.9kV
switchgear, and an electrical cabinet.
According to the licensee, the MCCs are
located under the cable routing
separated from the cable by
approximately 7.7 feet vertically, the air
dryer skid is separated from the cable by
approximately 6.1 feet horizontally, the
electrical cabinet is separated from the
cable by approximately 2 feet
horizontally and 9.2 feet vertically, and
the 6.9kV switchgear is separated from
the cable by approximately 0.7 feet
horizontally and 7.7 feet vertically.
The licensee also stated that cable
JB1–L91, which is associated with
instrument buses 23 and 23A, is routed
through the Fire Zone 46A.
The licensee also stated that cable
ECE19–MN3/01, which is associated
with valve LCV–112B, is routed through
Fire Zone 46A in a cable tray located
approximately 13 feet above the floor
and that ignition sources in the zone
located less than 20 feet horizontally
from the cable consist of an MCC, an air
dryer skid, 6.9kV switchgear, a portable
Duraline power station, and an
electrical cabinet. According to the
licensee, the MCC is separated from the
cable by approximately 3.2 feet
horizontally and 0 feet vertically, the air
dryer skid is separated from the cable by
approximately 7.7 feet horizontally and
2.6 feet vertically, the electrical cabinet
is separated from the cable by
approximately 2 feet horizontally and
7.3 feet vertically, the 6.9kV switchgear
is separated from the cable by
approximately 0.7 feet horizontally and
5.8 feet vertically, and the Duraline
power station is separated from the
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cable by approximately 19.5 feet
horizontally.
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.23.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 46A)
3.23.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on Bus 5A and 52/6A
and 52/TAO at Bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
srobinson on DSK4SPTVN1PROD with NOTICES
3.23.4.2 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 46A. If this were to occur,
the licensee stated that OMA #12 is
available to swap instrument buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
3.23.4.3 OMA #13—Align Charging
Pump Suction to RWST
The licensee stated that fire-induced
cable damage may render alternate
charging pump suction supply valve
LCV–112B (normally closed RWST
outlet valve) inoperable. In the event
that cable failures have rendered LCV–
112B inoperable, this valve is required
to be opened to support alignment of
charging pump suction to the alternate
source, the RWST.
If a fire were to occur and it renders
alternate charging pump suction supply
valve LCV–112B inoperable, the
licensee stated that OMA #13 is
available to locally close valve LCV–
112C and open manual valve 288 to
provide a bypass around RWST outlet
valve LCV–112B and provide water to
the charging pump suction. If OMA #13
becomes necessary, the licensee stated
that they have assumed a 14-minute
diagnosis period and that the required
time to perform the action is 18 minutes
while the time available is 75 minutes,
which provides 43 minutes of margin.
3.23.5 Conclusion for Fire Area J (Fire
Zone 46A)
Since the licensee described
postulated fire scenarios and Fire Zone
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46A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11, 22.5
minutes of margin available for OMA
#12, and 43 minutes of margin available
for OMA #13, Fire Zone 46A still lacks
adequate defense-in-depth. The NRC
staff finds that the defense-in-depth is
insufficient to demonstrate reasonable
assurance that safe shutdown can be
achieved for a fire in Fire Zone 46A and
that OMAs #11, #12, and #13 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 46A.
3.24 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 47A—
Ground Floor, Elevation 15′–0″ Unit 2
Turbine Building)
3.24.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cable insulation and that the transient
combustibles in this zone consist of
trash, lube oil, rubber hose, and paint.
The licensee also stated that the ignition
sources in this zone consist of cables,
junction boxes, MCC vertical panels,
and electrical cabinets. The licensee
further stated that since Fire Area J does
not contain safety-related structures,
systems or components, it is not subject
to the explicit transient combustible
controls of procedure EN–DC–161.
However, operator rounds performed
each shift provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.24.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
47A does not have a fire detection or
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Sfmt 4703
7203
automatic fire suppression system
installed.
3.24.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
47A has an approximate floor area of
5,175 square feet and an approximate
ceiling height of 37′–0″. The licensee
stated that cable JC2–YA9, which is
associated with Buses 5A and 6A, is
located in Fire Zone 47A in a cable tray
located approximately 8 feet above the
floor and that ignition sources in the
zone located less than 20 feet
horizontally from cable JC2–YA9 consist
of electrical cabinets, motors, and
MCCs. According to the licensee, the
electrical cabinets are separated from
the cable by approximately 3.8 feet
horizontally and 1.9 feet vertically and
the MCCs are located under the cable
separated from the cable by
approximately 0.2 feet vertically. As
discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.24.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 47A)
3.24.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on Bus 5A and 52/6A
and 52/TAO at Bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
3.24.5 Conclusion for Fire Area J (Fire
Zone 47A)
Since the licensee described
postulated fire scenarios and Fire Zone
47A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 50 minutes
of margin available for OMA #11, Fire
Zone 47A still lacks adequate defensein-depth. The NRC staff finds that the
defense-in-depth is insufficient to
demonstrate reasonable assurance that
safe shutdown can be achieved for a fire
in Fire Zone 47A and that OMA #11 is
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on OMA #11 cannot
be granted for Fire Zone 47A.
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3.25 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 50A—
Mezzanine Floor, Elevation 36′–9″ Unit
2 Turbine Building)
3.25.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cables, plastic, cellulose, and office
materials and that the transient
combustibles in this zone consist of
trash, vinyl covers, lube oil, and paint.
The licensee also stated that the ignition
sources in this zone consist of cables,
junction boxes, dry transformers,
motors, pumps, and electrical cabinets.
The licensee further stated that since
Fire Area J does not contain safetyrelated structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
srobinson on DSK4SPTVN1PROD with NOTICES
3.25.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
50A does not have a fire detection or
automatic fire suppression system
installed.
3.25.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
50A has an approximate floor area of
1,550 square feet and an approximate
ceiling height of 16′-0″. The licensee
stated that cable JC2–YA9, which is
associated with Buses 5A and 6A, is
located in Fire Zone 50A in a cable tray
located approximately 8 feet above the
floor and that ignition sources in the
zone located less than 20 feet
horizontally from cable JC2–YA9 consist
of electrical cabinets, motors, and
MCCs. According to the licensee, the
electrical cabinets are separated from
the cable by approximately 3.8 feet
horizontally and 1.9 feet vertically and
a motor is located under the cable
separated by approximately 5.2 feet
vertically. The licensee also stated that
cable AG5–XA5, which is associated
with instrument buses 23 and 23A, is
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routed through the Fire Zone 50A and
that ignition sources in the zone located
less than 20 feet horizontally from the
cable consist of electrical cabinets, a dry
transformer, motors, and an MCC.
According to the licensee, three of the
electrical cabinets are located under the
cable separated from the cable by
approximately 3 feet vertically or
greater, another four electrical cabinets
are separated from the cable by
approximately 2 feet horizontally or
greater, the dry transformer is separated
from the cable by approximately 1.6 feet
horizontally and 6.7 feet vertically, the
motors are separated from the cable by
approximately 4.6 feet horizontally or
greater, and the MCC is separated from
the cable by approximately 7.5 feet
horizontally. As discussed in Section
3.0 above, the licensee did not
demonstrate any separation between
credited and redundant trains of
equipment.
fire event. Although there are 50
minutes of margin available for OMA
#11 and 22.5 minutes of margin
available for OMA #12, Fire Zone 50A
still lacks adequate defense-in-depth.
The NRC staff finds that the defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
50A and that OMAs #11 and #12 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 50A.
3.25.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 50A)
3.26.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that the
fixed combustibles in this zone consist
of cables and that the transient
combustibles in this zone consist of
trash, cardboard drums, a flammable
liquid cabinet, plastic, wood, and paint.
The licensee also stated that the ignition
sources in this zone consist of cables,
junction boxes, dry transformers,
motors, a battery charger, an MCC
vertical panel, and electrical cabinets.
The licensee further stated that since
Fire Area J does not contain safetyrelated structures, systems or
components, it is not subject to the
explicit transient combustible controls
of procedure EN–DC–161. However,
operator rounds performed each shift
provide for the monitoring of
combustibles that could present an
unacceptable fire safety challenge. In
addition, the licensee stated that
procedures OAP–017 (Plant
Surveillance and Operator Rounds) and
EN–MA–132 (Housekeeping) include
guidance for monitoring general area
cleanliness as well as monitoring for
accumulations of combustibles.
3.25.4.1 OMA #11—Trip Breakers 52/
5A and 52–SAC on bus 5A and 52/6A
and 52/TAO at bus 6A and Remove
Control Power Fuses
OMA #11 was evaluated in Section
3.17.4.1 above. As stated in Section
3.17.4.1, OMA #11 has acceptable
margin for all fire zones in Fire Area J.
3.25.4.2 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 50A. If this were to occur,
the licensee stated that OMA #12 is
available to swap Instrument Buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5–minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
3.25.5 Conclusion for Fire Area J (Fire
Zone 50A)
Since the licensee described
postulated fire scenarios and Fire Zone
50A lacks an automatic fire detection or
automatic fire suppression system and a
robust combustible controls program,
and any discernable separation between
the credited and redundant equipment
in the area, it is possible that a fire
would not be detected and extinguished
in a reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
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3.26 Fire Area J—Unit 1 Control Room,
Turbine Building, Superheater Building,
Nuclear Service Building, Chemical
Systems Building, Administration
Building, Screenwell House, and Unit 2
Turbine Building (Fire Zone 270—
General Area of the 33′ Elev. of the Unit
1 Superheater Bldg.)
3.26.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 270
does not have a fire detection or
automatic fire suppression system
installed.
3.26.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 270
has an approximate floor area of 13,000
square feet and an approximate ceiling
height of 19′-0″. The licensee also stated
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that cables EDB8–EPB3, associated with
instrument buses 23 and 23A, are routed
through the Fire Zone 270 in rigid steel
conduit and that ignition sources in the
zone located less than 20 feet
horizontally from the cables consist of
electrical cabinets, a dry transformer,
batteries, and an MCC. According to the
licensee, one of the electrical cabinets is
separated from the cables by
approximately 12.8 feet horizontally,
another electrical cabinet is separated
from the cables by approximately 5.5
feet horizontally, the dry transformer is
separated from the cables by
approximately 13.6 feet horizontally,
the MCC is separated from the cables by
approximately 18.5 feet horizontally,
and there is no separation between the
cables and the batteries since the cables
originate at the batteries.
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
a fire in Fire Zone 270 and that OMA
#12 is unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on OMA #12 cannot
be granted for Fire Zone 270.
3.26.4 OMAs Credited for a Fire in
Fire Area J (Fire Zone 270)
The licensee stated that Fire Zone
60A does not have a fire detection or
automatic fire suppression system
installed.
3.26.4.1 OMA #12—Transfer
Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that Instrument
buses 23 and 23A could experience a
loss of their normal power source (125
VDC power panel 23) as a result of fire
in Fire Zone 270. If this were to occur,
the licensee stated that OMA #12 is
available to swap Instrument Buses 23
and 23A to their backup power source
(MCC–29A). If OMA #12 becomes
necessary, the licensee stated that they
have assumed a 5.5-minute diagnosis
period and that the required time to
perform the action is 2 minutes while
the time available is 30 minutes, which
provides 22.5 minutes of margin.
srobinson on DSK4SPTVN1PROD with NOTICES
3.26.5 Conclusion for Fire Area J (Fire
Zone 270)
Since the licensee described
postulated fire scenarios and Fire Zone
270 lacks a fire detection or automatic
fire suppression system and a robust
combustible controls program, and any
discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there are 22.5
minutes of margin available for OMA
#12, Fire Zone 270 still lacks adequate
defense-in-depth. The NRC staff finds
that the defense-in-depth is insufficient
to demonstrate reasonable assurance
that safe shutdown can be achieved for
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Jkt 226001
3.27 Fire Area K—Auxiliary Feed
Pump Building (not Including the AFW
Pump Room) (Fire Zone 60A—Chemical
Addition Area, Elev. 33′–0″)
3.27.1
Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there are no fixed combustibles in this
zone and that the transient combustibles
in this zone consist of trash, fiber
drums, and paint. The licensee also
stated that the ignition sources in this
zone consist of motors, blowers, and
electrical cabinets.
3.27.2 Detection, Control, and
Extinguishment
3.27.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
60A has an approximate floor area of
1,210 square feet and an approximate
ceiling height of 8′–6″. The licensee
stated that cables LL8–JF5 for FCV–
406A, LL9–JF9 for FCV–406C, JB1–YN9
for FCV–1121, and JB1–PT1/2 and PT1–
A16 associated with 21 AFW pump are
routed through Fire Zone 60A in rigid
steel conduit that runs vertically from
floor to ceiling and that ignition sources
in the zone located less than 20 feet
horizontally from the cables consist of
one electrical cabinet and four motors.
According to the licensee, the electrical
cabinet is separated from the cables by
approximately 7 feet horizontally and
the motors are separated from the cables
by approximately 5.5 feet horizontally
or greater.
The licensee also stated that cables
PU9–JF9 for FCV–406D, PU9–JH1 for
FCV–406B, PU9–JG2 for FCV–406A, and
PU9–JF2 for FCV–406C are routed
through Fire Zone 60A in a combination
of rigid steel conduits and a cable tray
that runs from floor to ceiling and that
ignition sources in the zone located less
than 20 feet horizontally from the cables
consist of two electrical cabinet and four
motors. According to the licensee, the
electrical cabinet is separated from the
cables by approximately 7 feet
horizontally or greater and the motors
are separated from the cables by
approximately 1.6 feet horizontally.
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7205
As discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
3.27.4 OMAs Credited for a Fire in
Fire Area K (Fire Zone 60A)
3.27.4.1 OMA #14—Transfer 21 AFW
Pump to Alternate Safe Shutdown
System Power Source
If a fire were to occur and it causes
damage to the cables associated with the
21 AFW pump normal power supply,
the licensee stated that OMA #14 is
available to operate transfer switch
EDC5 and close the supply breaker at
substation 12FD3 to transfer 21 AFW
pump to the Alternate Safe Shutdown
System power supply. If OMA #14
becomes necessary, the licensee stated
that they have assumed a 4.5-minute
diagnosis period and that the required
time to perform the action is 17 minutes
while the time available is 34 minutes,
which provides 12.5 minutes of margin.
3.27.4.2 OMA #15—Open 21 AFW
Pump Recirculation Bypass Valve
(BFD–77)
If a fire were to occur and it causes
damage to the cables associated with the
21 AFW pump recirculation valve,
FCV–1121, the licensee stated that OMA
#15 is available to open the 21 AFW
pump recirculation bypass valve BFD–
77. If OMA #15 becomes necessary, the
licensee stated that they have assumed
a 4.5-minute diagnosis period and that
the required time to perform the action
is 5 minutes while the time available is
34 minutes, which provides 24.5
minutes of margin.
3.27.5 Conclusion for Fire Area K (Fire
Zone 60A)
Since the licensee described
postulated fire scenarios and Fire Zone
60A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 12.5
minutes of margin available for OMA
#14 and 24.5 minutes of margin
available for OMA #15, Fire Zone 60A
still lacks adequate defense-in-depth.
The NRC staff finds that the defensein-depth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
60A and that OMAs #14 and #15 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
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the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 60A.
3.28 Fire Area K—Auxiliary Feed
Pump Building (not Including the AFW
Pump Room) (Fire Zone 65A—Main
Steam and Feedwater Valve Area 43′–0″,
65′–0″, and 74′–0″)
3.28.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
fixed combustibles in this zone consist
of wood and that the transient
combustibles in this zone consist of
trash and paint. The licensee also stated
that the ignition sources in this zone
consist of a transformer and electrical
cabinets.
3.28.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone
65A does not have a fire detection or
automatic fire suppression system
installed.
3.28.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone
65A has an approximate floor area of
1,210 square feet and an approximate
ceiling height of 43′–0″. The licensee
stated that cables PU9–JF9 for FCV–
406D, PU9–JH1 for FCV–406B, PU9–JG2
for FCV–406A, PU9–JF2 for FCV–406C,
LL8–JF5 for FCV–406A, LL9–JF9 for
FCV–406C, JB1–YN9 for FCV–1121, and
JB1–PT1/2 and PT1–A16 associated
with 21 AFW pump are routed through
Fire Zone 65A in rigid steel conduit that
runs vertically from the floor to a height
of approximately 6.5 feet to 8.5 feet
above the floor before exiting the zone
and that ignition sources in the zone
located less than 20 feet horizontally
from the cables consist of two switches.
According to the licensee, the switches
are separated from the cables by
approximately 2.5 feet horizontally. As
discussed in Section 3.0 above, the
licensee did not demonstrate any
separation between credited and
redundant trains of equipment.
srobinson on DSK4SPTVN1PROD with NOTICES
3.28.4 OMAs Credited for a Fire in
Fire Area K (Fire Zone 65A)
3.28.4.1 OMA #14—Transfer 21 AFW
Pump to Alternate Safe Shutdown
System Power Source
If a fire were to occur and it causes
damage to the cables associated with the
21 AFW pump normal power supply,
the licensee stated that OMA #14 is
available to operate transfer switch
EDC5 and close supply breaker at
substation 12FD3 to transfer 21 AFW
pump to the Alternate Safe Shutdown
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Jkt 226001
System power supply. If OMA #14
becomes necessary, the licensee stated
that they have assumed a 4.5-minute
diagnosis period and that the required
time to perform the action is 17 minutes
while the time available is 34 minutes,
which provides 12.5 minutes of margin.
3.28.4.2 OMA #15—Open 21 AFW
Pump Recirculation Bypass Valve
(BFD–77)
If a fire were to occur and it causes
damage to the cables associated with the
21 AFW pump recirculation valve,
FCV–1121, the licensee stated that OMA
#15 is available to open the 21 AFW
pump recirculation bypass valve BFD–
77. If OMA #15 becomes necessary, the
licensee stated that they have assumed
a 4.5–minute diagnosis period and that
the required time to perform the action
is 5 minutes while the time available is
34 minutes, which provides 24.5
minutes of margin.
3.28.5 Conclusion for Fire Area K (Fire
Zone 65A)
Since the licensee described
postulated fire scenarios and Fire Zone
65A lacks an automatic fire detection or
automatic fire suppression system, and
any discernable separation between the
credited and redundant equipment in
the area, it is possible that a fire would
not be detected and extinguished in a
reasonable amount of time to ensure
that at least one train of equipment
remains free of fire damage following a
fire event. Although there is 12.5
minutes of margin available for OMA
#14 and 24.5 minutes of margin
available for OMA #15, Fire Zone 65A
still lacks adequate defense-in-depth.
The NRC staff finds that the defense-indepth is insufficient to demonstrate
reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone
65A and that OMAs #14 and #15 are
unacceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that an exemption
from III.G.2 based on these OMAs
cannot be granted for Fire Zone 65A.
3.29 Fire Area P—Component Cooling
Pump Room, Elevation 68′–0″—PAB
(Fire Zone 1—Component Cooling
Pump Room, Elevation 68′–0″—PAB)
3.29.1 Fire Prevention
The licensee stated that the fire
loading in this zone is low and that
there are no fixed combustibles in this
zone and that the transient combustibles
in this zone consist of trash, radiation
boundaries, and paint. The licensee also
stated that the ignition sources in this
zone consist of electric motors and
pumps.
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3.29.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 1
has an area-wide, fire detection system
installed but does not have an automatic
fire suppression system installed. The
licensee also stated that the fire
detection system is designed and
installed in accordance with NFPA 72D,
1975 Edition.
3.29.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 1
has an approximate floor area of 710
square feet and an approximate ceiling
height of 12′–0″. The licensee stated that
power supply cables for 21, 22, and 23
component cooling water (CCW) pumps
are located in this zone in rigid steel
conduit for each motor and that the
conduit for 23 CCW Pump is wrapped
with an ERFBS rated for 30 minutes.
The licensee also stated that the pumps
are located approximately 10 feet from
each other and that a radiant energy
shield is installed between the 22 CCW
pump and the 23 CCW pump. In
addition, the licensee stated that the
ignition sources in the zone consist of
the three CCW pumps and two electrical
cabinets. According to the licensee, the
conduits for 21 and 22 CCW pumps are
routed vertically from the motors to
approximately 8.8 feet above the floor
and are separated by approximately 0.5
feet horizontally, the cable for 23 CCW
pump rises vertically from the motor to
approximately 9.5 feet above the floor,
and that the conduit for the 22 CCW
Pump crosses over the 21 CCW Pump.
Also according to the licensee, the
electrical cabinets are separated from
the 21 and 22 CCW pump power cables
by approximately 19.5 feet horizontally
or greater, one of the electrical cabinets
is located directly under the 23 CCW
pump power cable separated by
approximately 5.2 feet vertically, and
the other electrical cabinet is separated
from the 23 CCW pump power conduit
by approximately 3.8 feet horizontally
and 4.1 feet vertically. As discussed in
Section 3.0 above, the licensee did not
demonstrate any separation between
credited and redundant trains of
equipment.
3.29.4 OMAs Credited for a Fire in
Fire Area P (Fire Zone 1)
3.29.4.1 OMA #16—Transfer 23 CCW
Pump to Alternate Safe Shutdown
System Power Feed if Normal Power or
Control Is Lost
The licensee stated that the CCW
pump room contains all three CCW
pumps and that power to the CCW
pumps is normally supplied from the
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480V switchgear. The licensee also
stated that the Alternate Safe Shutdown
System provides the capability to use
individual components as required to
meet specific plant shutdown goals and
that to ensure the availability of at least
one CCW pump for SSD in the event
that the normal power supply is
disabled as a result of a fire, Alternate
Safe Shutdown System power can be
supplied to CCW pump 23 through
manual transfer switch EDF9 which is
hardwired to Alternate Safe Shutdown
System bus 12FD3 at the Alternate Safe
Shutdown System load center, where
starting and stopping 23 CCW pump can
be accomplished.
In the unlikely event that a fire occurs
and causes a loss of all three trains of
normal power, the licensee stated that
OMA #16 is available to align the 23
CCW pump to an alternate power
supply, thereby recovering one of the
redundant CCW trains. If OMA #16
becomes necessary, the licensee stated
that they have assumed a 24-minute
diagnosis period and that the required
time to perform the action is 7 minutes
while the time available is greater than
60 minutes, which provides 29 minutes
of margin.
srobinson on DSK4SPTVN1PROD with NOTICES
3.29.4.2 OMA #17—Start Appendix R
Diesel Generator (ARDG) if Normal
Power and Offsite Power Are Lost
The licensee confirmed that Fire Area
P presents no impact to cables or
components associated with the onsite
power supplied by the safety-related
EDGs 21, 22, and 23. In the event that
it is desired or necessary to utilize the
ARDG, the licensee stated that it would
only be in response to CCR operators
observing the loss of indication for
power availability to all 480V safetyrelated buses. The licensee also stated
that there are no credible fire scenarios
that would necessitate this OMA.
In the unlikely event that a fire occurs
and causes a loss of both normal and
offsite power supply, the licensee stated
that OMA #17 is available to start the
ARDG. If OMA #17 becomes necessary,
the licensee stated that they have
assumed that offsite power is
unavailable at the outset of the event
and that the required time to perform
the action is 17 minutes while the time
available is 60 minutes, which provides
43 minutes of margin.
3.29.5 Conclusion for Fire Area P (Fire
Zone 1)
Given the low combustible fuel
loading, ERFBS and radiant energy
shield noted above, and the automatic
fire detection system, it is unlikely that
a fire would occur and go undetected
and not be extinguished in a reasonable
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amount of time to ensure that at least
one train of equipment necessary for
safe shutdown remains free of fire
damage. For OMA #17, the NRC staff
finds that a fire in Fire Zone 1 should
not affect power availability on the
480V safety-related buses, and therefore
OMA #17 would not be required. In the
unlikely event that a fire does occur and
causes damage that necessitates the use
of OMA #16, there is 29 minutes of
margin available to provide assurance
that safe shutdown capability will be
maintained following the postulated fire
events. The NRC staff had previously
issued an exemption from III.G for Fire
Zone 1 in 1984 (ML003776266). In that
exemption, the NRC staff found that the
low fire load, the fire detection system,
and features such as fire wrap on the 23
CCW pump cables from transfer switch
EDF–9 and the non-combustible fire
barriers in the room justified an
exemption. The NRC staff finds that
there is adequate defense-in-depth
provided for Fire Zone 1 and that OMA
#16 is acceptable for the purpose of
providing the level of protection
intended by the regulation. Therefore,
the NRC staff finds that the previous
III.G.2 exemption for Fire Zone 1
remains valid.
3.30 Fire Area YD—Exterior Yard (Fire
Zone 900—Yard)
3.30.1 Fire Prevention
The licensee stated that this zone is
an outdoor area with minimal fixed
combustibles and that any ignition
sources would be transient in nature.
The licensee also stated that although
this zone contains minimal fixed
combustibles, postulated fire scenarios
would involve transient materials and
ignition sources.
3.30.2 Detection, Control, and
Extinguishment
The licensee stated that Fire Zone 900
does not have a fire detection or
automatic fire suppression system
installed.
3.30.3 Preservation of Safe Shutdown
Capability
The licensee stated that Fire Zone 900
is an outside area with no walls or
ceiling and open to the exterior so it is
unlikely that smoke or heat would
accumulate in the zone to cause damage
to equipment not exposed directly to a
fire. The licensee stated that Fire Zone
900 contains cable ECD3–EXF6/2,
which is associated with motor-operated
valve 227, and is routed outside through
rigid steel conduit from approximately
12 feet above the floor at elevation of 98’
which is also the roof of 80’ elevation
to approximately elevation 104’ where it
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enters the fan house. As discussed in
Section 3.0 above, the licensee did not
demonstrate any separation between
credited and redundant trains of
equipment.
3.30.4 OMAs Credited for a Fire in
Fire Area YD (Fire Zone 900)
3.30.4.1 OMA #18—Align Charging
Pump Makeup Path to RCS
The licensee stated that in order to
ensure a reliable charging makeup path
to the RCS, air-operated valve HCV–142
must remain open or motor-operated
bypass valve 227, which is normally
closed, must be opened and that airoperated valve HCV–142 is assumed to
fail closed as designed in response to a
loss of instrument air. The licensee
stated that OMA #18 is only required if
normal flowpath valve HCV–142 fails
closed and that spurious isolation of the
charging makeup path to the RCS is
identified in the CCR by operators
confirming that a charging pump is in
operation, but pressurizer level is
decreasing. Since no CCR pressurizer
level indicating channels have cables
routed through Fire Area YD, the CCR
indication of pressurizer level can be
expected to remain unaffected and
operable in the event of a fire in Fire
Zone 900.
In the unlikely event that a fire occurs
and causes damage to cable ECD3–
EXF6/2 and causes HCV–142 to close in
response to a loss of instrument air, the
licensee stated that OMA #18 is
available to align charging makeup path
to RCS by manually opening bypass
valve 227 to mitigate a spuriously
closed HCV–142 and restore or maintain
a reliable charging makeup path to the
RCS. If OMA #18 becomes necessary,
the licensee stated that they have
assumed a 14-minute diagnosis period
and that the required time to perform
the action is 14 minutes while the time
available is greater than 75 minutes,
which provides 47 minutes of margin.
3.30.5 Conclusion for Fire Area YD
(Fire Zone 900)
Given the low combustible fuel
loading and outdoor nature of the zone,
it is unlikely that a fire would occur and
damage cable ECD3–EXF6/2. In the
unlikely event that a fire does occur and
causes damage that necessitates the use
of OMA #18, there is 47 minutes of
margin available to provide assurance
that safe shutdown capability will be
maintained following the postulated fire
events. The NRC staff finds that there is
adequate defense-in-depth provided for
Fire Zone 900 and that OMA #18 is
acceptable for the purpose of providing
the level of protection intended by the
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regulation. Therefore, the NRC staff
finds that an exemption from III.G.2
based on OMA #18 is granted for Fire
Zone 900.
srobinson on DSK4SPTVN1PROD with NOTICES
4.0 Feasibility and Reliability of the
Operator Manual Actions
Based on Section 3.0 above, several
areas where OMAs are credited were
found acceptable. The OMAs credited in
those areas were then evaluated for
feasibility and reliability. This analysis
postulates that OMAs may be necessary
to assure SSD capability in addition to
the traditional fire protection features
described above. NUREG–1852,
‘‘Demonstrating the Feasibility and
Reliability of Operator Manual Actions
in Response to Fire,’’ provides criteria
and associated technical bases for
evaluating the feasibility and reliability
of post-fire OMAs in nuclear power
plants. The following provides the
licensee’s justification for the OMAs
specified in this exemption.
4.1 Bases for Establishing Feasibility
The licensee’s analysis addresses
factors such as environmental concerns,
equipment functionality and
accessibility, available indications,
communications, portable equipment,
personnel protection equipment,
procedures and training, and staffing
and demonstrations. In its submittals,
the licensee stated that environmental
factors such as radiation, lighting,
temperature, humidity, smoke, toxic
gas, noise, and fire suppression
discharge were evaluated and found to
not represent a negative impact on the
operators’ abilities to complete the
OMAs. The licensee stated that normal
radiation conditions within the areas of
concern will not be adversely affected
by the fire and subsequent spurious
equipment operation. The licensee also
confirmed that each of the OMA
locations addressed by this exemption
are provided with emergency lighting
that illuminates both the potential
ingress and egress paths and the
component requiring OMA
manipulation.
The licensee also confirmed that
temperature and humidity conditions
will not challenge the operators
performing the OMAs. Additionally, the
licensee indicated that heat and smoke
or gas generation from a fire will not
impact the operator performing the
OMAs. For those specific cases in which
it is necessary to reenter the fire area no
less than 1 hour after the postulated fire
event, the licensee stated that sufficient
time is available to initiate smoke/heat
venting through fixed ventilation
systems and augmented by portable
smoke ejectors, consistent with the Pre-
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Fire Plans, to ensure operator
habitability to implement the necessary
OMAs. In addition, the licensee stated
that pre-staged self-contained breathing
apparatus (SCBA), sufficient to equip
the full operating crew, are available for
deployment in response to post-fire
environmental conditions.
The licensee stated that equipment
credited for implementation of OMAs
was reviewed to ensure it is accessible,
available, and not damaged by the
affects of the fire. Where ladders are
required for access to components to
perform OMAs, appropriate ladders are
staged in accordance with plant
procedures and the presence of these
ladders is verified periodically in
accordance with plant surveillance
procedures. Any tools that are required
in support of post-fire hot shutdown
OMAs are pre-staged at the locations
where they would be used. These
consist of common tools such as
wrenches, banding cutters, and pliers.
Where special tools or equipment are
required, the licensee stated that they
are designated for post-fire cold
shutdown repairs, and the necessary
tools and supplies are pre-staged in
designated locations. The staging of
necessary tools is confirmed via
periodic surveillance.
In addition, the licensee indicated
that procedures are in place, in the form
of fire response procedures, to ensure
that clear and accessible instructions on
how to perform the manual actions are
available to the operators. The licensee
stated that 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 post-fire operator
manual actions are clearly defined in
procedures 2–ONOP–FP–001 and 2–
AOP–SSD–1. Most OMAs required for
the lll.G.2 fire areas are directed by OffNormal Operating Procedure 2–ONOP–
FP–001. Where CCR controls and
indications are not assured to be reliably
operable, the licensee stated that
sufficiently detailed guidance is
provided in procedure 2–AOP–SSD–1 to
direct the operators to an alternate
component or operating method that is
assured to be available and viable for
the specific fire scenario under
consideration. Initial and periodic
requalification operator training is
provided on these procedures,
consistent with standard licensed and
non-licensed operator training
programs.
The licensee stated that key
diagnostic instrumentation is expected
to remain available in the CCR to alert
operators to implement the contingency
OMAs as credited in the IP2 Appendix
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R SSD Analysis. Key indicators that
trigger the need for local operator
intervention for the credited set of
OMAs include not only the RCS and
secondary system instrumentation, but
also the failure of components to
respond or reliably indicate status in the
CCR. The licensee further stated that
based on field notes compiled from
simulator exercises in which bounding
fire area scenarios were modeled, the
available CCR instruments and
indicators, combined with operator
response in accordance with EOPs,
AOPs, fire SSD procedures, and other
supporting procedures, are sufficient to
ensure timely diagnosis of conditions
requiring the dispatch of operator(s) to
perform the credited OMAs outside the
CCR. With the exception of those OMAs
found to lack adequate time margin, the
NRC staff determined that diagnosis and
initiation times, in conjunction with the
available margin, were acceptable.
With regard to communications, the
licensee stated that reliance is placed on
radios for communication between plant
operators during a post-fire shutdown
event. Radio repeaters are located
outside the protected area and are not
subject to disruption caused by fire
events within the protected area. The
repeaters are also equipped with
uninterruptible power supplies to
ensure continued operation in the event
of the loss of normal power to the
buildings in which they are located.
Field verifications of radio system
functionality have validated that
communications between the
designated control and monitoring
locations are feasible and reliable.
The licensee stated that the manual
action sequences in all of the lll.G.2
areas are considered to be bounded by
the sequences represented by alternate
shutdown (lll.G.3) Fire Area A. With
regard to staffing, the licensee stated
that timed field walkthroughs of
Abnormal Operating Procedure 2–AOP–
SSD–1 have been performed to validate
that the number of operators available
on the watch staff (7) can safely
accomplish all required actions within
the required time period to meet
Appendix R SSD performance goals.
The licensee stated that the broad set of
OMAs required in implementing
alternate shutdown procedure 2–AOP–
SSD–1 bounds the smaller set of manual
actions credited for coping with lll.G.2
fire area scenarios and that most OMAs
required for the lll.G.2 fire areas are
directed by Off-Normal Operating
Procedure 2–ONOP–FP–001.
Additionally, the licensee stated that
post-fire OMAs have been validated
through timed operator walkthroughs,
using as the basis an enveloping
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prescribed time limits is within the
capability of the standard IP2 operating
crew. The licensee further stated that in
addition to the validation of key OMAs
credited in alternate SSD procedure
2–AOP–SSD–1, the plant simulator was
utilized to perform evaluations of
bounding lll.G.2 fire scenarios, and
based on the field notes compiled from
these exercises, there is reasonable
assurance that conditions requiring the
implementation of the identified OMAs
can be identified and mitigated in a
sufficiently timely manner to ensure
Appendix R performance goals are met.
However, certain OMAs were found to
lack adequate margin due to the prompt
nature of the action or because the NRC
staff concluded there was a lack of time
available to perform an OMA where
reentry to a fire area is required. These
cases are indicated below.
scenario addressed by 2–AOP–SSD–1.
When utilizing 2–AOP–SSD–1, the most
challenging set of local manual operator
actions (number of actions and time
sensitivity of actions) is presented to the
operations shift crew, and this set of
actions is considered to adequately
bound the limited set of manual actions
that are credited in 2–ONOP–FP–001.
The licensee also stated that the timed
walkthroughs of 2–AOP–SSD–1 have
consistently demonstrated that the key
SSD tasks (e.g., restoration of RCS
makeup; restoration of AFW to SGs;
mitigation of key potential spurious
actuation concerns) can be
accomplished in a timely manner to
meet the Appendix R SSD performance
goals.
The licensee stated that none of the
OMA operating locations are difficult to
access, and the required operations are
straightforward manual actions that do
not require any special tools, processes,
or unique personal capabilities.
Specifically, the OMAs entail:
• Manual operation of valves (manual
valves, as well as operation of airoperated valves and motor-operated
valves via hand wheels or installed
jacking devices).
• Local manual trip or closure of
circuit breakers.
• Manual control of the turbinedriven AFW pump.
The licensee further stated that none
of the requested OMAs involve complex
instruction sets, the installation or
removal of jumpers, or any actions
requiring uniquely specialized
knowledge or fine motor skills. The
OMA task assignments are within the
capability of any licensed operator or
nuclear plant operator, as applicable to
his or her responsibility set. As such,
the challenge presented for completion
of these basic tasks within the
4.2
Feasibility
The licensee’s analysis demonstrates
that, with exceptions, the OMAs can be
diagnosed and executed within the
amount of time available to complete
them. The licensee’s analysis also
demonstrates that various factors, as
discussed above, have been considered
to address uncertainties in estimating
the time available. The licensee stated
that the credited OMAs have been
demonstrated to be feasible through
timed evolutions performed using a
combination of simulator drills and
dispatch of operators to simulate
performance of the OMAs within the
physical plant. In most cases, the OMAs
are completed, with margin remaining,
within the time constraints established
by the supporting SSD thermalhydraulic analyses. The licensee stated
that the time values have been shown to
be consistently achievable, and the
operations resource demand required to
OMA
ID 2
Fire area
Fire zones 1
C ..................
23 .............................
support any one of the fire area
scenarios is a fraction of the 7-operator
complement available to support an
SSD scenario. However, OMA #6
requires operators to reenter a fire area
following a fire event to perform an
OMA and the licensee failed to account
for the 60-minute waiting period in their
required time. Because of this, this
OMA was determined to be infeasible
and has been noted as such in the table
below. The available margin is indicated
as a negative number where an OMA
credited in a particular area was found
to be infeasible and therefore unreliable
as well. Other OMAs were determined
to be feasible but not reliable since only
nominal margin is available to complete
them.
The following table summarizes the
‘‘required time’’ versus ‘‘available time’’
for each OMA. The indicated ‘‘required
time’’ is the time needed to complete all
actions that may be required as a result
of fire in each of the identified fire
zones and includes diagnosis time,
implementation time, and uncertainty
time. The indicated ‘‘available time’’ is
the time by which the action must be
completed in order to meet the
assumptions in plant analyses. The NRC
staff finds that the required time to
perform the actions is reasonable as the
licensee has verified these times in
simulator scenarios and by simulating
performance in the plant. Where reentry
to a fire area is required to perform an
OMA, a 60-minute waiting period is
also included in the required time and
the diagnosis period for these instances
was assumed to occur concurrent with
the waiting period. Finally, the times
noted below should be considered with
the understanding that the manual
actions are a fall back in the unlikely
event that the fire protection defense-indepth features are insufficient.
Required time
(min) 3
OMA summary
Available time
(min)
Available
margin
(min)
NA
NA
Operate turbine-driven 22AFW pump .........
82
>60
5 >0
Open 22 AFW pump steam supply isolation valves PCV–1310A and PCV–
1310B..
19.5
>60
>40.5
4
srobinson on DSK4SPTVN1PROD with NOTICES
NA
3
Operate TDAFW flow valves FCV–
405A,B,C and/or D to align TDAFW to
selected SGs.
82
>60
5 >0
27A, 33A, 59A ..........
5
Align Charging flow to RCS ........................
74
75
61
5A, 6, 7A, 22A, 27A
6
Align Charging Suction To RWST ..............
78
75
6 ¥3
6, 7A .........................
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Implement EOP 2–FR–H.l ..........................
2
F ..................
41
7
Transfer Inst. Buses 23/23A to alternate
power.
7.5
30
22.5
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OMA
ID 2
Available
margin
(min)
Required time
(min) 3
Available time
(min)
Align charging pump makeup path to RCS
28
75
47
9
Enable Alternate Safe Shutdown System
Pneumatic Instruments.
13
34
21
10
Enable Alternate Safe Shutdown System
source range channel.
23
34
11
17,19 39A, 43A, 45A,
46A, 47A, 50A.
11
Trip breakers 52/5A and 52–SAC on Bus
5A and 52/6A and 52/TAO on Bus 6A
and remove control power fuses.
10
60
50
25, 39A, 43A, 46A,
50A, 270.
12
Transfer Inst. Buses 23/23A to alternate
power.
7.5
30
22.5
43A, 46A ..................
13
Align charging pump suction source to
RWST.
32
75
43
60A 65A ...................
14
Transfer 21 AFW to Alternate Safe Shutdown System power source.
21.5
34
12.5
15
Open 21 AFW recirc. bypass valve BFD–
77.
9.5
34
24.5
16
Transfer 23 CCW pump to Alternate Safe
Shutdown System power.
31
>60
29
17
Start ARDG if normal power and offsite
power are lost.
17
60
43
18
Align charging pump makeup path to RCS
28
75
47
Fire area
Fire zones 1
H ..................
70A, 71 A, 72A, 75A,
77A, 84A, 85A,
87A.
8
70A, 75A, 77A, 87A
J ...................
K ..................
P ..................
YD ...............
1 ...............................
900 ...........................
OMA summary
1 Fire
Areas are areas of fire origin; Indicated Fire Zones contain the cables or equipment whose damage due to fire may require implementation of the OMAs.
2 Operator Action ID designators (1, 2, 3 etc.) were assigned by the NRR reviewer.
3 Total of simulator-based diagnosis was added to the field-based time to travel to the OMA location, complete the OMA, confirm the action,
and notify the CCR of completion as well as the 60-minute waiting period as discussed above.
4 Action A—Implementation of EOP 2–FR–H.l is not a requested OMA since these are proceduralized control room actions– identified here for
completeness only.
5 Operators use procedure EOP 2–FR–H.1 to extend the available time.
6 OMAs determined to be infeasible or unreliable.
srobinson on DSK4SPTVN1PROD with NOTICES
4.3
Reliability
As stated in NUREG–1852, for a
feasible action to be performed reliably,
it should be shown that there is
adequate time available to account for
uncertainties not only in estimates of
the time available, but also in estimates
of how long it takes to diagnose and
execute the OMAs (e.g., as based, at
least in part, on a plant demonstration
of the action under non-fire conditions).
To confirm reliability, for each fire area
having the potential to initiate the need
for an OMA, the licensee considered
uncertainties associated with estimating
how long it takes to diagnose and
execute operator manual actions.
Where the licensee demonstrated that
adequate margin was available, the
required completion times noted in the
table above provide reasonable
assurance that the OMAs can reliably be
performed under a wide range of
conceivable conditions by different
plant crews because the completion
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times, in conjunction with the available
time margins associated with each
action and other installed fire protection
features, account for sources of
uncertainty such as variations in fire
and plant conditions, factors unable to
be recreated in demonstrations and
human-centered factors. As noted in the
table above, several of the OMAs
included in this review were found to
be reliable because there is adequate
time available to account for
uncertainties not only in estimates of
the time available, but also in estimates
of how long it takes to diagnose a fire
and execute the OMAs (e.g., as based, at
least in part, on a plant demonstration
of the actions under non-fire
conditions). However, OMA #6 was
found to be infeasible and therefore
unreliable as well. Other OMAs were
determined to be feasible but not
reliable since only nominal margin is
available to complete them. The OMA
found to be infeasible and unreliable is
indicated by a negative available margin
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value in the table above and those
OMAs found to be feasible but
unreliable are those indicated by
footnote #6 to the table above but with
a positive available margin value.
4.4 Summary of Defense-in-Depth and
Operator Manual Actions
In summary, the defense-in-depth
concept for a fire in the fire areas
included in the table below provides a
level of safety that results in the
unlikely occurrence of fires; rapid
detection, control, and extinguishment
of fires that do occur; and the protection
of structures, systems, and components
important to safety. For these particular
fire zones and the OMAs credited in
them and found acceptable in Sections
3.0 and 4.0 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 SSD capability in the event of
a fire in the analyzed fire areas. The
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remaining zones included in the
licensee’s request were found to provide
an inadequate level of defense-in-depth
or safety margin and as such the
requested OMAs for these zones are not
approved for permanent use. The table
below summarizes which fire zones are
granted exemptions from III.G.2.
Fire zone
Area of fire
origin
Exemption approved for this
fire zone
23 ..............
C ....................
5A ..............
6 ................
7A ..............
22A ............
27A ............
33A ............
59A ............
70A ............
71A ............
72A ............
75A ............
77A ............
84A ............
85A ............
87A ............
17 ..............
19 ..............
25 ..............
39A ............
43A ............
45A ............
46A ............
47A ............
50A ............
270 ............
60A ............
65A ............
1 ................
F ....................
F ....................
F ....................
F ....................
F ....................
F ....................
F ....................
H ....................
H ....................
H ....................
H ....................
H ....................
H ....................
H ....................
H ....................
J .....................
J .....................
J .....................
J .....................
J .....................
J .....................
J .....................
J .....................
J .....................
J .....................
K ....................
K ....................
P ....................
900 ............
YD .................
Previous exemption remains valid
No
No
No
No
No
No
No
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
Previous exemption remains valid
Yes
srobinson on DSK4SPTVN1PROD with NOTICES
4.5
Authorized by Law
This exemption would allow IP2 to
rely on specific OMAs, as discussed in
Sections 3.0 and 4.0 above, in
conjunction with the other installed fire
protection features, to ensure that at
least one means of achieving and
maintaining safe shutdown remains
available during and following a
postulated fire event, as part of its fire
protection program, in lieu of meeting
the requirements specified in III.G.2 for
a fire in the analyzed fire zones. 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, as limited by the
staff’s analysis will not result in a
violation of the Atomic Energy Act of
1954, as amended, or the Commission’s
regulations. Therefore, the exemption is
authorized by law.
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21:29 Feb 09, 2012
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4.6 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 safe
shutdown remains available during and
following a postulated fire event. Based
on the above, no new accident
precursors are created by the use of the
specific OMAs, in conjunction with the
other installed fire protection features,
in response to a fire in the analyzed fire
zones. Therefore, the probability of
postulated accidents is not increased.
Also based on the above, the
consequences of postulated accidents
are not increased. Therefore, there is no
undue risk to public health and safety.
4.7 Consistent With Common Defense
and Security
This exemption would allow IP2 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 zones, discussed
above, in lieu of meeting the
requirements specified in III.G.2. This
change to the operation of the plant has
no relation to security issues. Therefore,
the common defense and security is not
diminished by this exemption.
4.8 Special Circumstances
One of the special circumstances
described in 10 CFR 50.12(a)(2)(ii) is
that the application of the regulation is
not necessary to achieve the underlying
purpose of the rule. The underlying
purpose of 10 CFR part 50, Appendix R,
Section III.G is to ensure that at least
one means of achieving and maintaining
safe shutdown remains available during
and following a postulated fire event.
While the licensee does not comply
with the explicit requirements of
Section III.G.2, the approved OMAs, in
conjunction with the other installed fire
protection features, provide a method to
ensure that a train of equipment
necessary to achieve and maintain safe
shutdown of the plant will be available
in the event of a fire in these fire zones.
The NRC staff concludes that the
application of the regulation is not
necessary to achieve the underlying
purpose of the rule for the plant
configurations approved in this
exemption. Therefore special
circumstances exist, as required by 10
CFR 50.12(a)(2)(ii), that warrant the
issuance of this exemption.
5.0 Conclusion
Based on all of the features of the
defense-in-depth concept discussed for
the fire zones listed in Section 4.4 of
this exemption, the NRC staff concludes
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Fmt 4703
Sfmt 4703
7211
that the use of specific OMAs found
acceptable in Sections 3.0 and 4.0 of
this evaluation, in these particular
instances and in conjunction with the
other installed fire protection features,
in lieu of strict compliance with the
requirements of III.G.2, will allow IP2 to
meet the underlying purpose of the rule
for those fire zones. The use of other
specific OMAs in certain fire zones were
found to be not acceptable, as discussed
in Sections 3.0 and 4.0 of this
evaluation, and as such, are not
approved by this exemption.
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 Entergy
an exemption from the requirements of
Section III.G.2 of Appendix R of 10 CFR
part 50, to utilize the OMAs approved
above at IP2.
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 (76 FR 74832).
This exemption is effective upon
issuance.
Dated at Rockville, Maryland this first day
of February, 2012.
For the Nuclear Regulatory Commission.
Michele G. Evans,
Director, Division of Operating Reactor
Licensing, Office of Nuclear Reactor
Regulation.
[FR Doc. 2012–3124 Filed 2–9–12; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
[Docket No. 72–26; NRC–2011–0110]
Pacific Gas and Electric Company,
Diablo Canyon Independent Spent Fuel
Storage Installation; Notice of
Issuance of Amendment to Materials
License No. SNM–2511
Nuclear Regulatory
Commission.
ACTION: Notice of issuance of license
amendment.
AGENCY:
John
Goshen, Project Manager, Division of
Spent Fuel Storage and Transportation,
Office of Nuclear Material Safety and
Safeguards, Mail Stop EBB–3D–02M,
U.S. Nuclear Regulatory Commission,
Washington, DC 20555–0001.
FOR FURTHER INFORMATION CONTACT:
E:\FR\FM\10FEN1.SGM
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]]>Agencies
[Federal Register Volume 77, Number 28 (Friday, February 10, 2012)]
[Notices]
[Pages 7184-7211]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-3124]
=======================================================================
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
[Docket No. 50-247]
Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Operations,
Inc.; Indian Point Nuclear Generating Unit No. 2; Exemption
1.0 Background
Entergy Nuclear Operations, Inc. (Entergy or the licensee) is the
holder of Facility Operating License No. DPR-026, which authorizes
operation of Indian Point Nuclear Generating Unit No. 2 (IP2). 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.
IP2 is a pressurized-water reactor located approximately 24 miles
north of the New York City boundary line on the east bank of the Hudson
River in Westchester County, New York.
2.0 Request/Action
Title 10 of the Code of Federal Regulations (10 CFR) part 50,
Section 50.48(b), requires that nuclear power plants that were licensed
to operate before January 1, 1979, satisfy the requirements of 10 CFR
part 50, Appendix R, ``Fire Protection Program for Nuclear Power
Facilities Operating Prior to January 1, 1979,'' Section III.G, ``Fire
protection of safe shutdown capability.'' The circuit separation and
protection requirements being addressed in this request for exemption
are specified in Section III.G.2. Since IP2 was licensed to operate
before January 1, 1979, IP2 is required to meet Section lll.G.2 of
Appendix R to 10 CFR part 50.
The underlying purpose of Section III.G of Appendix R to 10 CFR
part 50 is to establish reasonable assurance that safe shutdown (SSD)
of the reactor can be achieved and maintained in the event of a
postulated fire in any plant area. Circuits which could cause
maloperation or prevent operation of redundant trains of equipment
required to achieve and maintain hot shutdown conditions as a result of
fire in a single fire area must be protected in accordance with
lll.G.2. If conformance with the technical requirements of III.G.2
cannot be assured in a specific fire area, an alternative or dedicated
shutdown capability must be provided in accordance with Section
III.G.3, or an exemption obtained in accordance with 10 CFR 50.12,
``Specific exemptions.''
By letter dated March 6, 2009, Entergy requested an exemption from
the requirements of 10 CFR part 50, Appendix R, in accordance with 10
CFR 50.12. Specifically, Entergy requested an exemption to allow the
use of Operator Manual Actions (OMAs) in lieu of meeting certain
technical requirements of III.G.2 in Fire Areas C, F, H, J, K, P, and
YD of IP2. The table below provides the dates and topics of the
submittals related to this request.
----------------------------------------------------------------------------------------------------------------
Subject Author Date Description ADAMS Accession
----------------------------------------------------------------------------------------------------------------
Exemption Request from Entergy......... March 6, 2009... Original Submittal... ML090770151.
Appendix R.
Revised Exemption Request..... Entergy......... October 1, 2009. Revision to March ML092810231
2009 submittal,
incorporated changes
to Attachment 2,
Technical Basis in
Support of Exemption
Request.
Request for Additional NRC............. January 20, 2010 Request for ML100150128
Information (RAI) 1. information on the
overall defense-in-
depth for each fire
zone..
RAI Response 1....... Entergy......... May 4, 2010..... Response to the ML101320230
staff's January 20,
2010, RAI..
RAI 2................ NRC............. August 11, 2010. RAI on reactor ML102180331
coolant system
makeup, separation
distances, etc.
RAI Response 2....... Entergy......... September 29, Response to the ML102930237
2010. staff's August 11,
2010, RAI.
RAI 3................ NRC............. December 16, RAI on reactor ML103500204
2010. coolant system
makeup.
RAI Response 3....... Entergy......... January 19, 2011 Responses to the ML110310013
staff's December 16,
2010, RAI.
Letter to revise previously Entergy......... February 10, Letter updating ML110540321
submitted information. 2011. tables contained in
previous submittals.
[[Page 7185]]
Letter to revise previously Entergy......... May 26, 2011.... Letter updating ML11158A197
submitted information. tables contained in
previous submittals.
----------------------------------------------------------------------------------------------------------------
III.G.2 establishes various protection options for providing
reasonable assurance that at least one train of systems, equipment, and
cabling required to achieve and maintain hot shutdown conditions
remains free of fire damage. In lieu of providing one of the means
specified in the regulation, Entergy requests an exemption from lll.G.2
to allow the use of OMAs to achieve and maintain hot shutdown
conditions in the event of fire in seven fire areas at IP2, Fire Areas
C, F, H, J, K, P, and YD. The licensee further subdivides these fire
areas into one or more fire zones for analysis purposes.
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 stated that
special circumstances exist because 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
to operate 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 SSD is preserved following a fire event. The regulation
intends for licensees to accomplish this by extending the concept of
defense-in-depth to:
Prevent fires from starting.
Rapidly detect, control, and extinguish promptly those
fires that do occur.
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 SSD of the plant.
Section III.G.2 requires one of the following means to ensure that
a redundant train of SSD cables and equipment is free of fire damage,
where redundant trains are located in the same fire area outside of
primary containment:
a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
b. Separation of cables and equipment by a horizontal distance of
more than 20 feet with no intervening combustibles or fire hazards and
with fire detectors and an automatic fire suppression system installed
in the fire area; or
c. Enclosure of cables and equipment of one redundant train in a
fire barrier having a 1-hour rating and with fire detectors and an
automatic fire suppression system installed in the fire area.
In its March 6, 2009, and October 1, 2009, submittals, Entergy
requested an exemption from certain technical requirements of III.G.2
to the extent that one of the redundant trains of systems necessary to
achieve and maintain hot shutdown is not maintained free of fire damage
in accordance with one of the required means prescribed in III.G.2 in
Fire Areas C, F, H, J, K, P, and YD. The licensee also listed an
operator action to implement emergency operating procedure (EOP) 2-FR-
H.1, ``Response To Loss Of Secondary Heat Sink.'' The NRC does not
consider implementing 2-FR-H.1 an OMA, as actions to establish reactor
coolant system decay heat removal can be performed from the control
room and there are redundant trains of equipment located outside of the
fire area of fire origin.
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, which the licensee
has further subdivided into fire zones. Listed in the order of the fire
area of fire origin, the OMAs included in this review are as follows:
------------------------------------------------------------------------
Area of fire Operator manual
OMA origin Area name actions
------------------------------------------------------------------------
1................ C................ Auxiliary Boiler Implement EOP FR-
Feed Pump Room, H.l as directed
Elevation 18'- by EOPs and
6'' of the status trees if
Auxiliary Feed necessary to
Pump Building. establish
alternate
secondary heat
sink. Action
performed from
the control
room, so the
NRC does not
consider this
an OMA.
-----------------
2................ ................. ................ Operate turbine-
driven 22
auxiliary
feedwater (AFW)
pump upon
reentry to the
room following
the initial
hour of the
fire scenario.
-----------------
3................ ................. ................ Open or check
open 22 AFW
pump steam
supply
isolation
valves PCV-
1310A and PCV-
1310B.
-----------------
4................ ................. ................ Operate 22 AFW
pump flow
control valves
FCV-405A
(discharge to
21 steam
generator
(SG)), FCV-405B
(discharge to
22 SG), FCV-
405C (discharge
to 23 SG), and/
or FCV-405 to
align AFW flow
to selected
steam
generators.
------------------------------------------------------------------------
5................ F................ Primary Open HCV-142
Auxiliary bypass valve
Building and 227 to align
Fan House. charging pump
makeup path to
the Reactor
Coolant System
(RCS).
-----------------
[[Page 7186]]
6................ ................. ................ Align charging
pump suction
source to the
Refueling Water
Storage Tank
(RWST).
-----------------
7................ ................. ................ Transfer
instrument
buses 23 and
23A to
alternate
power.
------------------------------------------------------------------------
8................ H................ Vapor (Reactor) Fail open valves
Containment 204A (charging
Building. flow to Loop 2
hot leg) and
204B (charging
flow to Loop 1
cold leg) to
align charging
pump makeup
path to the
RCS.
-----------------
9................ ................. ................ Activate or
enable
Alternate Safe
Shutdown System
pneumatic
instruments
(steam
generator
level,
pressurizer
pressure and
level) at Fan
House local
control panel.
-----------------
10............... ................. ................ Enable Alternate
Safe Shutdown
System source-
range channel
and Loop 21 and
22 hot leg (Th)
and cold leg
(Tc)
temperature
channels.
------------------------------------------------------------------------
11............... J................ Unit 1 Control Trip breakers 52/
Room, Turbine 5A and 52-SAC
Building, on Bus 5A and
Superheater 52/6A and 52/
Building, TAO at Bus 6A
Nuclear Service and remove
Building, control power
Chemical fuses.
Systems
Building,
Administration
Building,
Screenwell
House, and Unit
2 Turbine
Building.
-----------------
12............... ................. ................ Transfer
Instrument
Buses 23 and
23A to
emergency power
source.
-----------------
13............... ................. ................ Align charging
pump suction to
RWST.
------------------------------------------------------------------------
14............... K................ Auxiliary Feed Operate transfer
Pump Building switch EDC5 and
(not including close supply
the AFW Pump breaker at
Room). substation
12FD3 to
transfer 21 AFW
Pump to
Alternate Safe
Shutdown System
power source.
-----------------
15............... ................. ................ Open 21 AFW pump
recirculation
bypass valve
BFD-77.
------------------------------------------------------------------------
16............... P................ Component Transfer 23 CCW
Cooling Water pump to
(CCW) Pump Room. Alternate Safe
Shutdown System
power feed
followed by
breaker closure
at 12FD3.
-----------------
17............... ................. ................ Start Appendix R
Diesel
Generator
(ARDG) if
normal power
and offsite
power are lost.
------------------------------------------------------------------------
18............... YD............... Outdoor (Yard) Open HCV-142
Area. bypass valve
227 to align
charging pump
makeup path to
RCS.
------------------------------------------------------------------------
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. 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 identified above.
In their March 6, 2009, and October 1, 2009, submittals, 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
because the separation requirements for equipment and electrical
circuits required by III.G.2 are not met. Specifically, the licensee
stated that noncombustible materials have been used to the maximum
extent practicable and that the introduction of combustible materials
into areas with safety-related equipment, including Fire Areas C, F, H,
K, and P, is strictly controlled by administrative procedures. The
administrative procedures govern the handling, storage, and limitations
for use of ordinary combustible materials, combustible and flammable
gases and liquids, and other combustible supplies. In addition,
periodic fire prevention inspections are performed to assess compliance
with Indian Point's programs for Control of Combustibles and Control of
Ignition Sources. The licensee stated that the administrative controls
are described in the IP2 Fire Protection Program (FPP), which is
incorporated by reference into the Updated Final Safety Analysis
Report.
The licensee stated that both thermoplastic and thermoset low-
voltage power, control, and instrument cables are installed at IP2.
Since the thermoplastic insulated cables were manufactured and
installed prior to the issuance of IEEE-383, a standard for nuclear
plant cables, they were not qualified to that standard. In its May 4,
2010 letter, the licensee stated that these cables are constructed with
an asbestos glass braid outer jacket which provides protection from
flame spread. In addition, the licensee stated that the results of
various tests, as well as an actual fire event during plant
construction, have demonstrated the ability of this type of
thermoplastic insulated cables to minimize the growth and spread of
cable fires. The licensee also stated that the likelihood of self-
[[Page 7187]]
ignited cable fires is minimized by appropriately sized electrical
protection devices (e.g., fuses and circuit breakers). The licensee
stated that all cables installed after plant construction are thermoset
cables which meet the IEEE-383 standard. The IEEE-383 standard includes
fire-retardation characteristics.
All of the fire areas in the plant are comprised of one or more
fire zones consisting of separate compartments or fire zone
delineations based on spatial separation. In addition, the licensee
stated that the localization of hazards and combustibles within each
fire zone, combined with the spatial or physical barrier separation
between zones, provides reasonable assurance that a fire that occurs
within a particular zone will be confined to that zone. As such, the
licensee provided a characterization of the defense-in-depth that is
present in each of the fire zones containing multiple trains of SSD
equipment. The licensee further stated that for each of the fire zones
where OMAs are performed, the adequacy of non-rated fire barriers was
evaluated to ensure that they can withstand the hazards associated with
the area. Therefore, this review evaluates the defense-in-depth
provided in each of the zones of concern.
In its submittals, the licensee provided a summary of plant-
specific fire protection features provided for each fire zone
identified in its request including an account of combustible loading
(both fixed and transient), ignition sources, detection, suppression,
administrative controls, and identified any additional fire protection
features that may be unique to the fire zone, such as electrical
raceway fire barriers. In its responses, the licensee stated that
combustibles and sources of ignition are tightly controlled by
administrative controls programs and that the areas included in this
exemption are not shop areas so hot work activities (such as welding)
are infrequent and appropriate administrative controls (e.g., hot work
permits, fire watch, and supervisory controls) are in place if hot work
activities do occur. The licensee also stated that the original
installation of the suppression and detection systems was accepted by
the NRC staff in safety evaluation reports (SERs) dated January 31,
1979, and a supplement dated October 31, 1980, and that there are no
code compliance items that present an adverse impact to the
implementation of the requested OMAs. Within the fire zones of concern
to its request, the licensee stated that fire-rated assemblies are only
used and credited for intra-zone separation of redundant SSD equipment
trains in part of Fire Area F (Fire Zone 7A) and part of Fire Area P
(Fire Zone 1). The fire-rated assemblies consist of a Hemyc Electrical
Raceway Fire Barrier System (ERFBS) and have been evaluated to ensure
they are adequate for the hazards of the areas of installation.
Entergy stated that for each of the fire areas addressed in this
evaluation, Post-Fire Safe Shutdown (PFSSD) is principally accomplished
by remaining in the Central Control Room (CCR) and conducting a normal
(non-alternative) shutdown. In all cases, the identified OMAs mitigate
conditions where certain technical requirements of III.G.2 are not
satisfied.
Entergy further stated that the OMAs required for achieving and
maintaining hot shutdown conditions are feasible, reliable, and are not
impacted by environmental conditions (radiation, lighting, temperature,
humidity, smoke, toxic gas, noise, fire suppression discharge, etc.)
associated with fires in III.G.2 areas. The feasibility and reliability
of the requested OMAs are addressed in Section 4.0 of this evaluation.
NRC Staff Observations
In its May 4, 2010, response to RAI-07.1, the licensee stated that
no credit was taken for immediate and proactive OMA response by plant
operators upon the receipt of a fire detection alarm in any of the
identified fire zones. Instead, the licensee stated that OMAs are
initiated upon the detection of operating abnormalities or failures
caused by a postulated fire event. In this same response, the licensee
stated that they conducted exercises using the plant simulator to
evaluate the feasibility of the OMAs where a fire condition or a
spontaneous reactor trip caused by a fire was announced at the outset
of the simulation followed by the failure of discrete components that
are subject to impairment due to fire damage to cables or components
resulting from a fire in the area of concern. For fires originating in
fire zones lacking fire detection and/or automatic fire suppression
systems, the NRC staff considers it improbable that the operators would
properly indentify that the indications were the result of a fire
instead of some other fault. In addition, the operators would be
delayed in positively identifying the location of the fire based on
these indirect and ambiguous indicators. Therefore, for some scenarios
involving fire zones that lack fire detection systems, operators are
unlikely to identify and respond to a fire event in a manner that
prompts them to perform certain OMAs prior to a significant degradation
of the plant's condition. This becomes especially relevant for OMAs
that are required to be completed within a relatively short period of
time, e.g., within about 30 minutes, or have limited margins available
to complete the required actions.
For OMAs that are required to be completed within a short period of
time, the NRC staff evaluates if operators can reliably perform the
OMA. In order to be able to perform OMAs reliably, it is important that
operators are able to promptly implement any required action based on
clear indications. Indirect indicators and diagnostic analysis would
result in delayed action to initiate the appropriate OMAs and would
impair their reliable completion. For example, loss of control or
indication for a pump or other affected component could result from the
power supply circuit breaker opening due to an electrical fault other
than a fire, and the operator might delay taking actions for a fire
while investigating other potential and more-likely causes. The NRC
staff documented a position on procedures and training for such actions
in Section 4.2.9 of NUREG-1852, ``Demonstrating the Feasibility and
Reliability of Operator Manual Actions in Response to Fire,'' which
notes that the procedures for reactive actions should clearly describe
the indications which prompt initiation of the actions. Therefore,
where OMAs need to be performed within a short period of time, fire
zones crediting those OMAs are expected to have more robust defense-in-
depth and clear, direct procedures than fire zones that have a
significant margin in their OMA performance times.
In the August 11, 2010 RAI-02.1 and RAI-06.1, and the December 16,
2010 RAI-01.1, the NRC staff requested that the licensee describe the
spatial separation between redundant trains of equipment. However, the
licensee's responses only provided information regarding the separation
between ignition sources and safe shutdown equipment and no information
regarding separation between redundant trains of equipment within the
fire area. For example, in its September 29, 2010 response to RAI-06.1
the licensee stated that ``The cables serving valves 204A and 204B are
routed within Containment (Fire Area H) in raceways which are not
separated by 20 feet at all locations, nor are other separation
measures as prescribed by III.G.2 (f) provided.'' During a
clarification call with the licensee, the licensee did not provide any
dimensional data on train separation. Without dimensional data on train
separation, the staff has conservatively assumed that there is no
[[Page 7188]]
discernable separation between redundant trains of equipment.
In addition, the licensee noted that the introduction of
combustible materials into most areas included in its request was
limited via administrative procedures such as EN-DC-161, ``Control of
Combustibles.'' The licensee stated that Fire Area J did not contain
safety-related systems or components and was not addressed by this
procedure. The NRC staff notes that the licensee requested OMAs for
Fire Area J and that alternate shutdown equipment and several cables
associated with normal safe-shutdown equipment are located in this
area. The licensee stated that operator rounds are performed each shift
in Fire Area J that would monitor the presence of combustibles that
could present an unacceptable fire safety challenge. In addition, the
licensee stated that procedures OAP-017, ``Plant Surveillance and
Operator Rounds'' and EN-MA-132, ``Housekeeping,'' include guidance for
monitoring general area cleanliness including monitoring for
accumulations of combustibles. The NRC staff notes that the combustible
material controls procedures for this fire area are not as robust as
for safety-related areas, and therefore results in a reduction in the
defense-in-depth for the impacted fire zones.
Specific Area or Zone Discussion
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 C--Auxiliary Boiler Feed Pump Room, Elevation 18'-6'' of
the Auxiliary Feed Pump Building (Fire Zone 23--Auxiliary Boiler Feed
Pump (ABFP) Room, Elevation 18'-6'')
3.1.1 Fire Prevention
Fire Area C consists of a single room (the ABFP Room or the
Auxiliary Feedwater (AFW) Pump Room) and is designated as Fire Zone 23.
Note that the pumps which supply water to the steam generators
following a reactor trip are generically known as AFW pumps, but at IP2
they are also called Auxiliary Boiler Feed Pumps. The licensee stated
that the fire loading in this area is low and that fixed combustibles
consist of fire retardant cable insulation. The licensee stated that
small quantities of lube oil and Class A combustibles are present but
those do not pose a credible challenge to components of concern located
in the zone. The licensee also stated that the ignition sources in the
area consist of cable runs, junction boxes, motors, pumps, and
electrical panels.
3.1.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 23 does not have a fire
suppression system installed but does have an area-wide, ionization
smoke detection system installed, which would provide early
notification of a fire and assist in a prompt fire brigade response.
The licensee also stated that the detection system was designed and
installed in accordance with National Fire Protection Association
(NFPA) standard NFPA 72D, 1975 Edition.
3.1.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 23 has a ceiling height of
approximately 14'-0'' and an approximate floor area of 1,210 square
feet. This fire zone contains the three AFW pumps (21, 22, and 23) and
their discharge valves used to supply water to the steam generators for
reactor coolant system decay heat removal when the normal feedwater
system is not available, such as following a reactor trip. The licensee
stated that a radiant energy shield is installed between 21 AFW pump
and 23 AFW pump and that the power cables for 23 AFW pump are wrapped
in Hemyc fire barrier material rated for 30 minutes. The licensee
stated that damage to the control or instrument cables in the overhead
trays could present an immediate impact on redundant AFW trains. As
discussed in section 3.0 above, the licensee did not identify any
separation between credited and redundant trains of equipment.
3.1.4 OMAs Credited for a Fire in Fire Area C (Fire Zone 23)
3.1.4.1 OMA 1--Implement 2-FR-H.1 If Necessary to Establish
Alternate Secondary Heat Sink
The licensee stated that for a worst case fire scenario, OMAs to
restore AFW functionality would be implemented after a period of 1 hour
following fire initiation. This time is provided to extinguish the fire
and clear the smoke from the fire area. In the unlikely event that
control and indication for all three AFW pumps is lost during the
initial hour of a fire event, the licensee stated that Emergency
Operating Procedure EOP 2-FR-H.1, ``Response to Loss of Secondary Heat
Sink,'' can be implemented to provide the reactor coolant heat removal
function using the normal feedwater system or feed-and-bleed cooling
with safety injection pumps. Since actions to remove reactor coolant
system decay heat can be performed from the CCR (no OMAs are required
in the field), this action is included for completeness only. Since no
exemption is being requested, this OMA is not part of this exemption.
In a letter dated September 14, 1988, the licensee had described the
use of EOP 2-FR-H.1 to the NRC, and by letter dated January 12, 1989,
the NRC staff concluded that the licensee's clarifications to the fire
protection program conformed with NRC fire protection guidelines and
requirements and were acceptable, so the use of EOP 2-FR-H.1 is
considered to already be part of the licensee's licensing basis.
3.1.4.2 OMA 2--Operate 22 AFW Pump (Turbine-Driven)
The licensee stated that all three AFW pumps are within this area
and associated cables are routed in this area. According to the
licensee, the cables of concern are typically routed in rigid steel
conduits and located between 8.9 feet and 10.8 feet above the floor.
The OMAs for this area are only needed if all three AFW pumps are
affected by the fire. The licensee stated that the diagnostic indicator
for this scenario would be a loss of control or indication for 22 AFW
pump from the CCR or indication of decreasing level in all steam
generators as viewed at recorders LR-417, 427, 437, and 447. In the
event that this does occur, OMAs 2, 3, and 4
are available to operate 22 AFW Pump. OMA 2 will open PCV-1139
to admit steam, operate HCV-1118 at the pump to control speed, and
operate PCV-1213 as necessary to regulate pump bearing cooling water.
Since these actions are required to be performed in the zone where the
fire occurs, a 60-minute waiting period prior to operator reentry into
the area is described in the submittal. The licensee stated that they
allotted 60 minutes before performing OMA 2 to allow the fire
brigade to perform its fire fighting operations and for the area to be
made tenable prior to entering to perform certain OMAs. In Table RAI-
08.1-1 of its February 10, 2011 submittal, the licensee indicated that
the OMA initiator (postulated fire-induced failure) is located in Fire
Zone 23 as is the OMA performance location. The licensee also provided
a comment in the same table establishing the 60-minute duration of the
waiting period.
If OMA 2 becomes necessary, the licensee stated that they
have assumed a 60-minute period before re-entering the fire area, a
4.5-minute diagnosis period, which is assumed to transpire during the
60-minute waiting period,
[[Page 7189]]
and that the required time to perform the action is 22 minutes, which
results in a total required time of 82 minutes. The licensee is
crediting the use of EOP 2-FR-H.1 until OMAs 2, 3,
and 4 can be accomplished. Since there is defense-in-depth
including full area fire detection and limited combustibles, and EOP 2-
FR-H.1 can be used to perform the reactor coolant system heat removal
function while OMA 2 is being implemented, the NRC staff finds
this OMA acceptable.
3.1.4.3 OMA 3--Open or Check Open 22 AFW Pump Steam Supply
Isolation Valves
This OMA is one of the three OMAs needed to operate the 22 AFW
pump, as described in the previous section. OMA 3 would open
the 22 AFW pump steam supply pressure control valves PCV-1310A and PCV-
1310B in Fire Area K.
If OMA 3 becomes necessary, the licensee stated that they
have assumed a 4.5-minute diagnosis period, and that the required time
to perform the action is 15 minutes, which results in a total required
time of 19.5 minutes. The licensee is crediting the use of EOP 2-FR-H.1
until OMAs 2, 3, and 4 can be accomplished.
Since there is defense-in-depth including full area fire detection and
limited combustibles, and EOP 2-FR-H.1 can be used to perform the
reactor coolant system heat removal function while OMA 3 is
being implemented, the NRC staff finds this OMA acceptable.
3.1.4.4 OMA 4--Operate 22 AFW Pump Flow Control Valves To
Align AFW Flow to Selected Steam Generators
This OMA is one of the three OMAs needed to operate the 22 AFW
pump, as described in the previous sections. OMA 4 would
operate FCV-405A (discharge to 21 SG) and FCV-405B (discharge to 22 SG)
in the AFW Pump Room, upon reentry to the room following the initial
60-minute waiting period.
If OMA 4 becomes necessary, the licensee stated that they
have assumed a 60-minute period before re-entering the fire area, a
4.5-minute diagnosis period, which is assumed to transpire during the
60-minute waiting period, and that the required time to perform the
action is 22 minutes, which results in a total required time of 82
minutes. The licensee is crediting the use of EOP 2-FR-H.1 until OMAs
2, 3, and 4 can be accomplished. Since there
is defense-in-depth including full area fire detection and limited
combustibles, and EOP 2-FR-H.1 can be used to perform the reactor
coolant system heat removal function while OMA 4 is being
implemented, the NRC staff finds this OMA acceptable.
3.1.5 Conclusion for Fire Area C (Fire Zone 23)
The NRC staff had previously issued an exemption from III.G.2 for
Fire Zone 23 in 1984 (ML003776266). In that exemption, the NRC staff
found that the low fire load and features such as fire wrap on the 23
AFW pump cables justified an exemption. By letter dated January 12,
1989, the NRC staff concluded that the licensee's clarifications to the
fire protection program, which in part described the use of EOP 2-FR-
H.1, conform with NRC fire protection guidelines and requirements and
were acceptable. The NRC staff notes that the fire detection in this
fire zone will clearly alert the operators to take actions for a fire.
Therefore, the NRC staff concludes that with the defense-in-depth
including full area fire detection and limited combustibles, OMAs
2, 3, and 4, along with EOP 2-FR-H.1, are
acceptable for maintaining the reactor coolant system heat removal
function and that the III.G.2 exemption for Fire Zone 23 remains valid.
3.2 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
5A--Sampling Room, Elevation 80'-0'')
3.2.1 Fire Prevention
The licensee stated that the fire loading in this fire zone is
moderate and that the fixed combustibles are primarily cable
insulation. The licensee also stated that the ignition sources in the
fire zone consists of cable runs, junction boxes, and electrical
panels.
3.2.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 5A does not have fire detection
or fire suppression systems installed.
3.2.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 5A has a ceiling height of
approximately 14'-0'' and an approximate floor area of 150 square feet.
This fire zone contains cables which could affect the position of
valves LCV-112B and LCV-112C. These valves provide water to the suction
of the charging pumps. As discussed in Section 3.0 above, the licensee
could not demonstrate any separation between credited and redundant
trains of equipment.
3.2.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 5A)
3.2.4.1 OMA 6--Align Charging Pump Suction to Refueling Water
Storage Tank (RWST)
The licensee stated that a postulated fire in Fire Area F could
present the potential for immediate damage to the one charging pump
(there are three charging pumps) that is normally in service during
power operations by affecting the source of water to the suction of the
pump. The licensee stated that the 21 Charging Pump is credited for
accomplishing the RCS makeup function in the event of fire in Fire Area
F. In the event that the 21 Charging Pump is in operation during a fire
in Fire Area F, and fire damage causes valve LCV-112C to spuriously
close, the 21 Charging Pump could be damaged due to a loss of suction.
For a fire in Fire Area F, the licensee stated that alignment of the
charging suction flowpath to the RWST is established by OMAs to close
valve LCV-112C and open normally closed manual valve 288, which
provides a bypass path around valve LCV-112B. To open valve 288, the
licensee stated that operators must reenter Fire Area F following a
fire.
If a fire were to occur in Fire Zone 5A and cause LCV-112C to
spuriously close, the licensee stated that OMA 6 is available
to restore or maintain the necessary function (RCS makeup) to the
affected equipment (Charging Pumps) and align charging pump suction to
the RWST by closing the volume control tank (VCT) outlet valve LCV-112C
and opening RWST manual bypass valve 288. If OMA 6 becomes
necessary, the licensee stated that they have assumed a 60-minute
waiting period before re-entering the fire area, a 14-minute diagnosis
period, which is assumed to transpire during the 60-minute waiting
period, and that the required time to perform the action is 18 minutes,
which results in a total required time of 78 minutes, while the time
available to restore makeup flow to the RCS is 75 minutes. Therefore,
there is insufficient margin available to perform the OMA for all fire
zones in Fire Area F.
3.2.5 Conclusion for Fire Area F (Fire Zone 5A)
Since the licensee described postulated fire scenarios and Fire
Zone 5A lacks an automatic fire detection or automatic suppression
system, and any discernable separation between the credited and
redundant equipment in the area, it is possible that a fire would not
be detected and extinguished in a reasonable amount of time to ensure
that at least one train of equipment
[[Page 7190]]
remains free of fire damage or allow reentry to the area to perform
OMAs. Additionally, OMA 6 cannot be completed in a timely
manner for any fire in Fire Area F. Thus, OMA 6 does not
provide assurance that safe shutdown capability will be maintained
following the postulated fire events. Therefore, the NRC staff finds
that the defense-in-depth is insufficient to demonstrate reasonable
assurance that safe shutdown can be achieved for a fire in Fire Zone 5A
and that an exemption from III.G.2 based on OMA 6 cannot be
granted for Fire Zone 5A.
3.3 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 6-
22 Charging Pump Room, Elevation 80'-0'')
3.3.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles are cable insulation, lube oil, and
plastic. Transient combustibles consist of trash, paint, lube oil, and
radiation boundaries. The licensee also stated that the ignition source
in the area is the 22 charging pump motor.
3.3.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 6 has an automatic fire
detection system installed but does not have an automatic fire
suppression system installed. The licensee also stated that the
detection system was designed and installed in accordance with NFPA
72D, 1975 Edition.
3.3.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 6 has a ceiling height of
approximately 15'-6'' and an approximate floor area of 282 square feet.
As discussed in Section 3.0 above, the licensee could not demonstrate
any separation between credited and redundant trains of equipment. The
licensee stated that cable YZ1-JB5 associated with valve LCV-112C and
cables PL2-M41 and PL2-M42 associated with instrument buses 23 and 23A
are located in this area and that they are located 12 feet, 6.8 feet,
and 15.6 feet, respectively, from the primary ignition source in the
zone, the 22 charging pump motor.
3.3.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 6)
3.3.4.1 OMA 6--Align charging pump suction to RWST
OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above.
As stated in Section 3.2.4.1, there is insufficient margin to perform
OMA 6 for any fire zone in Fire Area F.
3.3.4.2 OMA 7--Transfer Instrument Buses 23 and 23A to
Alternate Power
The licensee stated that if indication of instrument buses 23 and
23A is lost in the CCR, OMA 7 may be necessary to transfer
both buses to their alternate power supply. If OMA 7 becomes
necessary, the licensee stated that they have assumed a 5.5-minute
diagnosis period and that the required time to perform the action is 2
minutes, while the time available is 30 minutes, which results in 22.5
minutes of margin.
3.3.5 Conclusion for Fire Area F (Fire Zone 6)
Since the licensee described postulated fire scenarios and Fire
Zone 6 lacks an automatic fire suppression system and any discernable
separation between the credited and redundant equipment in the area, it
is possible that a fire would not be extinguished in a reasonable
amount of time to ensure that at least one train of equipment remains
free of fire damage or allow reentry to the area to perform OMAs. The
NRC staff finds that the defense-in-depth is insufficient to
demonstrate reasonable assurance that safe shutdown can be achieved for
a fire in Fire Zone 6. OMA 6 was found to be unacceptable for
this fire zone. OMA 7 has insufficient time available
considering the lack of fire suppression and therefore is unacceptable
for this fire zone. Therefore, the staff finds that an exemption from
III.G.2 based on these OMAs cannot be granted for Fire Zone 6.
3.4 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
7A--Corridor, Elevation 80'-0'')
3.4.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles are cable insulation and electrical
cabinets, and that transient combustibles consist of trash, flammable
liquids, plastic, cellulose, and radiation boundaries. The licensee
also stated that the ignition sources in the area consist of cable
insulation, junction boxes, and electrical panels.
3.4.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 7A has an automatic fire
detection system installed but does not have an automatic fire
suppression system installed. The licensee also stated that the
detection system was designed and installed in accordance with NFPA
72D, 1975 Edition.
3.4.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 7A has a ceiling height of
approximately 16'-0'' and an approximate floor area of 6,000 square
feet. The licensee also stated that the power cable from transfer
switch EDF-9 to 23 component cooling water CCW pump motor is wrapped
with Hemyc fire barrier material rated for 30 minutes. As discussed in
Section 3.0 above, the licensee could not demonstrate any separation
between credited and redundant trains of equipment. The licensee stated
that cable YZ1-JB5 associated with valve LCV-112C and cables PL2-M41
and PL2-M42 associated with instrument buses 23 and 23A are located in
this area.
3.4.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 7A)
3.4.4.1 OMA 6--Align Charging Pump Suction to RWST
OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above.
As stated in Section 3.2.4.1, there is insufficient margin to perform
OMA 6 for any fire zone in Fire Area F.
3.4.4.2 OMA 7--Transfer Instrument Buses 23 and 23A to
Alternate Power
The licensee stated that if indication of instrument buses 23 and
23A is lost in the CCR, OMA 7 may be necessary to transfer
both buses to their alternate power supply. If OMA 7 becomes
necessary, the licensee stated that they have assumed a 5.5-minute
diagnosis period and that the required time to perform the action is 2
minutes, while the time available is 30 minutes, which results in 22.5
minutes of margin.
3.4.5 Conclusion for Fire Area F (Fire Zone 7A)
Since the licensee described postulated fire scenarios and Fire
Zone 7A lacks an automatic fire suppression system and any discernable
separation between the credited and redundant equipment in the area, it
is possible that a fire would not be extinguished in a reasonable
amount of time to ensure that at least one train of equipment remains
free of fire damage or allow reentry to the area to perform OMAs. The
NRC staff finds that the defense-in-depth is insufficient demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 7A. OMA 6 was found to be unacceptable for this fire
zone. OMA 7 has insufficient time available considering the
lack of fire suppression and therefore is unacceptable for this fire
zone. Therefore, the staff finds that
[[Page 7191]]
an exemption from III.G.2 based on these OMAs cannot be granted for
Fire Zone 7A.
3.5 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
22A--Valve Corridor, Elevation 98'-0'')
3.5.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that there are no fixed or transient combustibles in this zone, except
for small amounts of cable insulation. The licensee also stated that
the ignition sources in the area consist of electrical cabinets.
3.5.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 22A does not have an automatic
fire detection or automatic suppression system installed.
3.5.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 22A has a ceiling height of
approximately 14'-0'' and an approximate floor area of 115 square feet.
The licensee stated that if cables for LCV-112C are affected, it may be
necessary to align an alternate water supply to the charging pump
suction. The licensee stated that cables associated with valves LCV-
112C and LCV-112B are located in Fire Zone 22A.
3.5.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 22A)
3.5.4.1 OMA 6--Align charging pump suction to RWST
OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above.
As stated in Section 3.2.4.1, there is insufficient margin to perform
OMA 6 for any fire zone in Fire Area F.
3.5.5 Conclusion for Fire Area F (Fire Zone 22A)
Since the licensee described postulated fire scenarios and Fire
Zone 22A lacks any automatic fire detection or automatic suppression
system, it is possible that a fire would not be extinguished in a
reasonable amount of time to ensure that at least one train of
equipment remains free of fire damage or allow reentry to the area to
perform OMAs. Additionally, there is insufficient margin available for
the OMA credited in this area to provide assurance that safe shutdown
capability will be maintained following the postulated fire events.
Therefore, the staff finds that the defense-in-depth is insufficient to
demonstrate reasonable assurance that safe shutdown can be achieved for
a fire in Fire Zone 22A and that an exemption from III.G.2 based on OMA
6 cannot be granted for Fire Zone 22A.
3.6 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
27A--Corridor, Elevation 98'-0'')
3.6.1 Fire Prevention
The licensee stated that the fire loading in this area is moderate
and that the fixed combustibles in this zone consist of cable
insulation, vinyl covers, control cabinets and panels, plastic, and
office supplies and that transient combustibles consist of trash,
rubber, paint, and radiation boundaries. The licensee also stated that
the ignition sources in the area consist of cable, junction boxes, dry
transformers, motor control center (MCC) vertical panels, and
electrical panels.
3.6.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 27A has an automatic fire
detection system installed but does not have an automatic fire
suppression system installed. The licensee also stated that the
detection system was designed and installed in accordance with NFPA
72D, 1975 Edition.
3.6.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 27A has a ceiling height of
approximately 15'-0'' and an approximate floor area of 5,450 square
feet. The licensee stated that cables associated with valves LCV-112C,
LCV-112B, HCV-142 and 227 are also located in this fire zone. As
discussed in Section 3.0 above, the licensee could not demonstrate any
separation between credited and redundant trains of equipment.
3.6.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 27A)
3.6.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
The licensee stated that in order to ensure a reliable charging
makeup path to the reactor coolant system (RCS), air-operated valve
HCV-142 must remain open or bypass valve 227, which is normally motor-
operated and normally closed, must be opened. The licensee stated that
air-operated valve HCV-142 is assumed to fail closed as designed in
response to a loss of instrument air. The licensee stated that if HCV-
142 were to close in response to a loss of instrument air, and cables
for valve 227 are damaged in a manner that causes normally closed
motor-operated valve 227 to remain closed and unable to be opened
remotely from the CCR, OMA 5 would be used to locally open
bypass valve 227 in Fire Area A to restore or maintain a reliable
charging pump flow path to the RCS.
If OMA 5 becomes necessary, the licensee stated that they
have assumed a 60-minute waiting period before re-entering the fire
area, a 14-minute diagnosis period, which is assumed to transpire
during the 60-minute waiting period, and that the required time to
perform the action is 14 minutes, which provides a total required time
of 74 minutes while the time available is 75 minutes, which provides 1
minute of margin. Although there is fire detection in this zone, the
NRC staff finds that 1 minute of margin is insufficient to ensure the
OMA can be accomplished reliably. Therefore, the NRC staff finds that
OMA 5 is unacceptable for a fire which initiates in Fire Zone
27A or for any fire zone in Fire Area F.
3.6.4.2 OMA 6--Align Charging Pump Suction to RWST
OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above.
As stated in Section 3.2.4.1, there is insufficient margin to perform
OMA 6 for any fire zone in Fire Area F.
3.6.5 Conclusion for Fire Area F (Fire Zone 27A)
Since the licensee described postulated fire scenarios and Fire
Zone 27A lacks an automatic fire suppression system and any discernable
separation between the credited and redundant equipment in the area, it
is possible that a fire would not be extinguished in a reasonable
amount of time to ensure that at least one train of equipment remains
free of fire damage or allow reentry to the area to perform OMAs. Also,
the NRC staff finds that OMAs 5 and 6 are
unacceptable for a fire which initiates in Fire Zone 27A or for any
fire zone in Fire Area F. Therefore, the staff finds that the defense-
in-depth is insufficient to demonstrate reasonable assurance that safe
shutdown can be achieved for a fire in Fire Zone 27A and that an
exemption from III.G.2 based on OMA 5 and 6 cannot be
granted for Fire Zone 27A.
3.7 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
33A--MCC 26AA and MCC 26BB Room, Elevation 98'-0'')
3.7.1 Fire Prevention
The licensee stated that the fire loading in this area is moderate
and that the fixed combustibles in this zone consist of cable
insulation and electrical panels and that transient combustibles
consist of trash, paint, and radiation
[[Page 7192]]
boundaries. The licensee also stated that the ignition sources in the
area consist of cables, junction boxes, dry transformers, MCC vertical
panels, and electrical cabinets.
3.7.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 33A does not have an automatic
fire detection or automatic suppression system installed.
3.7.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 33A has an approximate floor
area of 1,122 square feet and is open to Fire Zone 27A above. The
licensee stated that cables associated with charging pump makeup valves
HCV-142 and 227 are located in this fire zone. As discussed in Section
3.0 above, the licensee could not demonstrate any separation between
credited and redundant trains of equipment.
3.7.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 33A)
3.7.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
OMA 5 was evaluated in Section 3.6.4.1 above. As stated in
Section 3.6.4.1, 1 minute of margin for OMA 5 is too low to
credit OMA 5 as being a reliable method of restoring the
charging pump flow path to the RCS for any fire zone in Fire Area F.
3.7.5 Conclusion for Fire Area F (Fire Zone 33A)
Since the licensee described postulated fire scenarios and Fire
Zone 33A lacks an automatic fire detection system or automatic
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is possible that a fire would
not be extinguished in a reasonable amount of time to ensure that at
least one train of equipment remains free of fire damage or allow
reentry to the area to perform OMAs. There is insufficient margin
available for OMA 5 for any fire in Fire Area F to provide
assurance that safe shutdown capability will be maintained following
the postulated fire events. Therefore, the staff finds that the
defense-in-depth is insufficient to demonstrate reasonable assurance
that safe shutdown can be achieved for a fire in Fire Zone 33A and that
an exemption from III.G.2 based on OMA 5 cannot be granted for
Fire Zone 33A.
3.8 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone
59A--Fan House Elevation 72'-0'', 80'-0'', and 92'-0)
3.8.1 Fire Prevention
The licensee stated that the fire loading in this area is high and
that the fixed combustibles in this zone consist of charcoal and cable
insulation and that transient combustibles consist of trash, paint, and
radiation boundaries. The licensee also stated that the ignition
sources in the area consist of electrical cabinets.
3.8.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 59A has a partial automatic fire
suppression system installed at the charcoal filter housings and a
partial automatic fire detection system installed that consists of
Thermistor wire for the charcoal filters and an ionization detector
outside the charcoal filter enclosure on the 72'-0'' elevation. The
licensee also stated that the detection system was designed and
installed in accordance with NFPA 72D, 1967 Edition and the fire
suppression system was designed and installed in accordance with NFPA
13, 1972 Edition and NFPA 15, 1969 Edition. The partial fire detection
system may not be effective at detecting fires in other areas of this
fire zone, as it is located on the lower level of the fire zone.
3.8.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 59A has an approximate floor
area of 1,400 square feet and an approximate ceiling height of 29'-0''.
Fire Zone 59A contains cable ECD3-EXF6/2, which is associated with
motor-operated valve 227.
3.8.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 59A)
3.8.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
OMA 5 was evaluated in Section 3.6.4.1 above. As stated in
Section 3.6.4.1, 1 minute of margin for OMA 5 is too low to
credit OMA 5 as being a reliable method of restoring the
charging pump flow path to the RCS for any fire zone in Fire Area F.
3.8.5 Conclusion for Fire Area F (Fire Zone 59A)
Since the licensee described postulated fire scenarios and Fire
Zone 59A has a high combustible loading and lacks an automatic fire
detection system or automatic suppression system throughout the zone,
except where installed at the charcoal filters, it is possible that a
fire would not be detected and extinguished in a reasonable amount of
time to ensure that at least one train of equipment remains free of
fire damage or allow reentry to the area to perform OMAs. There is
insufficient margin available for OMA 5 for any fire in Fire
Area F to provide assurance that safe shutdown capability will be
maintained following the postulated fire events. Therefore, the staff
finds that the defense-in-depth is insufficient to demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 59A and that an exemption from III.G.2 based on OMA
5 cannot be granted for Fire Zone 59A.
3.9 Fire Area H--Containment Building (Fire Zone 70A--23 and 24 Reactor
Coolant Pump Area, Elevation 46-0'')
3.9.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation
and reactor coolant pump (RCP) lube oil and that transient combustibles
are administratively controlled. The licensee also stated that the
ignition sources in the area consist of cables, junction boxes, and RCP
motors.
3.9.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 70A has a partial automatic fire
detection system installed that consists of ionization detectors
located over RCPs 23 and 24 but does not have an automatic fire
suppression system. The licensee also stated that the detection system
was designed and installed in accordance with NFPA 72D, 1975 Edition.
3.9.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 70A has an approximate floor
area of 3,320 square feet and an approximate ceiling height of 25'-8''.
The licensee also stated that there is an oil collection system
provided for RCPs 23 and 24. The licensee stated that cable Y15-H50 for
valve 204B and cable Y17-H55 for valve 204A are located in this zone.
Valve 204A is an air-operated valve which allows charging pump flow to
an RCS hot leg. Valve 204B is an air-operated valve which allows
charging pump flow to an RCS cold leg. The licensee stated that cables
and components associated with redundant trains of normal
instrumentation required to support normal safe
[[Page 7193]]
shutdown operations are located in this zone. The normal safe shutdown
instrumentation potentially affected by fire includes:
SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
Pressurizer level: LT-459, LT-460, LT-461, LT-462
Source-range neutron monitoring: N-31, N-32
RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
3.9.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 70A)
3.9.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
It is possible that a fire in this zone could result in a loss of a
reliable charging makeup path to the RCS due to air-operated charging
system valves 204A and 204B spuriously closing. The licensee stated
that normal reactor coolant makeup to the RCS may be established via
hot leg injection through valve 204A or cold leg injection through
valve 204B and that in order to accomplish this, normal reactor coolant
makeup air-operated charging system valves 204A and 204B would need to
be failed open by de-energizing 125VDC control power in the CCR or by
closing the air supply isolation valve IA-501, which is outside the
containment building, to isolate instrument air.
Procedure 2-ONOP-FP-001 includes preemptive actions to establish
the charging makeup path by failing open charging injection valves 204A
and 204B. This is accomplished by removing DC control power to the
valves by pulling the control power fuses in the CCR or tripping
breakers 5 and 15 on 125 VDC DP 21 and 22, respectively. Procedure 2-
AOP-SSD-1 includes actions to close the air supply isolation valve IA-
501, and the loss of air pressure will cause valves 204A and 204B to
fail open.
If a fire were to occur and causes valves 204A and 204B to remain
closed, the licensee stated that OMA 8 is available to align
the charging pump makeup path to the RCS. If OMA 8 becomes
necessary, the licensee stated that they have assumed a 14-minute
diagnosis period and that the required time to perform the action is 14
minutes, which results in a total required time of 28 minutes while the
time available is 75 minutes, which provides 47 minutes of margin.
3.9.4.2 OMAs 9 and 10--Activate or Enable Alternate
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe
Shutdown System Source-Range Channel and Loop 21 and 22 hot and cold
leg Temperature Channels
In the event that a fire in Fire Area H disables redundant trains
of normal safe shutdown instrumentation identified in Section 3.9.3,
the licensee may make use of OMAs performed in a different fire area to
place in service Alternate Safe-Shutdown System instruments which have
been separated from the normal shutdown instruments in accordance with
III.G.2(f). The licensee also stated that in locations where normal and
alternate shutdown instrument cables are separated by less than 20
feet, the cables of the alternate shutdown instruments are protected by
a radiant energy shield as required to meet III.G.2(f). The Alternate
Safe Shutdown System instrument channels include:
RCP Loop 21 and 22 hot and cold leg temperature (TE-5139,
TE-5140, TE-5141, TE-5142),
SG 21 and 22 level (LT-5001, LT-5002),
Pressurizer level (LT-3101), pressurizer pressure (PT-
3105), and
Source range neutron monitoring (NE-5143)
The licensee stated that cables associated with Loop 21 and 22 hot
and cold leg temperature channels TE-5139, 5140, 5141, 5142, and
source-range channel NE-5143 are routed into containment through
penetration H20, and are protected with a radiant energy shield
throughout the containment annulus area, where they are in proximity to
cable trays or conduits containing the corresponding normal RCS loop
temperature channels. The licensee also stated that there are no cables
associated with the balance of the alternate SSD instruments (LT-5001,
LT-5002, PT-3105, and LT- 3101), since these channels utilize
pneumatically-operated transducers. The licensee stated that the
Alternate Safe Shutdown System pneumatic instrumentation can be
expected to remain operable despite fire-induced failure of the
redundant electrically-operated instrumentation, since the Alternate
Safe Shutdown System instruments do not utilize any electrical
components or cables.
In addition, the licensee stated that all four RCPs are equipped
with RCP lube oil collection systems which capture any leakage from
credible leak sites and transport it to collection tanks located
outside the bioshield wall in Fire Zone 77A.
In the event that redundant trains of normal shutdown
instrumentation are damaged by a fire, OMAs 9 and 10
are available to activate the following Alternate Safe Shutdown System
instruments:
Pneumatic instruments
[cir] SG level (LT-5001, LT-5002),
[cir] Pressurizer pressure (PT-3105), and
[cir] Pressurizer level (LT-3101)
Source-range channel (NE-5143), and
Loop 21 and 22 hot leg (Th) and cold leg (Tc) temperature
channels (TE-5139, TE-5140, TE-5141, TE-5142)
Procedure 2-AOP-SSD-1 includes actions to place these Alternate
Safe Shutdown System instruments in service. If OMAs 9 and
10 become necessary, the licensee stated that they have
assumed less than 1 minute for diagnosis, with the normal instruments
assumed to be failed at the start of the event, and that the required
time to perform the action is 13 minutes for the pneumatic instruments.
The shortest timeline is to monitor level in the SGs, which could
approach boil-dry conditions within 34 minutes. This results in 21
minutes of margin for the pneumatic instruments. The five electronic
instruments are then energized by the same operator who made the
pneumatic instruments operable, so it takes 24 minutes to put the
electronic instruments in service. However, the electronic instrument
readings are not needed until later in the scenario. This results in a
total required time of 13 minutes while the time available is 34
minutes, which provides 21 minutes of margin.
3.9.5 Conclusion for Fire Area H (Fire Zone 70A)
Given the low combustible fuel loading, the oil collection system
for the RCPs, automatic smoke detection system, large volume of the
space, and preemptive nature of the OMAs, it is unlikely that a fire
would occur and go undetected and not be extinguished in a reasonable
amount of time to ensure that at least one train of equipment necessary
for safe shutdown remains free of fire damage. In the unlikely event
that a fire does occur and causes damage that necessitates OMAs
8, 9, and 10, the actions are clear and
proceduralized with 47 minutes of margin for OMA 8 and 21
minutes of margin for OMAs 9 and 10, available to
provide assurance that safe shutdown capability will be maintained
following the postulated fire events. Therefore, the NRC staff finds
that there is adequate defense-in-depth provided for Fire Zone 70A and
that OMAs 8, 9, and 10 are acceptable for
the purpose of providing the level of
[[Page 7194]]
protection intended by the regulation, and that an exemption from
III.G.2 based on these OMAs is granted for Fire Zone 70A.
3.10 Fire Area H--Containment Building (Fire Zone 71A--21 and 22
Reactor Coolant Pump Area, Elevation 46'-0'')
3.10.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation,
RCP lube oil, and other miscellaneous combustibles and that transient
combustibles are administratively controlled. The licensee also stated
that the ignition sources in the area consist of cables, junction
boxes, RCP motors, and pumps.
3.10.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 71A has a partial automatic fire
detection system installed that consists of ionization detectors
located over RCPs 21 and 22 but does not have an automatic fire
suppression system. The licensee also stated that the detection system
was designed and installed in accordance with NFPA 72D, 1975 Edition.
3.10.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 71A has an approximate floor
area of 3,320 square feet and an approximate ceiling height of 25'8''.
The licensee also stated that there is an oil collection system
provided for RCPs 21 and 22. The licensee stated that cable Y15-H50 for
valve 204B and cable Y17-H55 for valve 204A are located in this zone.
Valve 204A is an air-operated valve which allows charging pump flow to
an RCS hot leg. Valve 204B is an air-operated valve which allows
charging pump flow to an RCS cold leg. As discussed in Section 3.0
above, the licensee did not demonstrate any separation between credited
and redundant trains of equipment.
3.10.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 71A)
3.10.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As discussed in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75 minutes,
which provides 47 minutes of margin.
3.10.5 Conclusion for Fire Area H (Fire Zone 71A)
Given the low combustible fuel loading, the oil collection system
for the RCPs, automatic smoke detection system, large volume of the
space, and preemptive nature of OMA 8, it is unlikely that a
fire would occur and go undetected and not be extinguished in a
reasonable amount of time to ensure that at least one train of
equipment necessary for safe shutdown remains free of fire damage. In
the unlikely event that a fire does occur and causes damage that
necessitates OMA 8, the actions are clear and proceduralized
with 47 minutes of margin available to provide assurance that safe
shutdown capability will be maintained following the postulated fire
events. Therefore, the NRC staff finds that there is adequate defense-
in-depth provided for Fire Zone 71A and that OMA 8 is
acceptable for the purpose of providing the level of protection
intended by the regulation, and that an exemption from III.G.2 based on
OMA 8 is granted for Fire Zone 71A.
3.11 Fire Area H--Containment Building (Fire Zone 72A--Outer Annulus,
Elevation 46'0'')
3.11.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation
and that transient combustibles are administratively controlled. The
licensee also stated that the ignition sources in the area consist of
cables.
3.11.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 72A does not have an automatic
fire detection or automatic suppression system installed.
3.11.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 72A has an approximate floor
area of 1,100 square feet and an approximate ceiling height of 22'0''.
The licensee stated that cables for valve 204B and valve 204A are
located in this zone. Valve 204A is an air-operated valve which allows
charging pump flow to an RCS hot leg. Valve 204B is an air-operated
valve which allows charging pump flow to an RCS cold leg. As discussed
in Section 3.0 above, the licensee did not demonstrate any separation
between credited and redundant trains of equipment.
3.11.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 72A)
3.11.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75 minutes,
which provides 47 minutes of margin.
3.11.5 Conclusion for Fire Area H (Fire Zone 72A)
Since the licensee described postulated fire scenarios and Fire
Zone 72A lacks an automatic fire detection system or automatic
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is credible that a fire would
not be detected and extinguished in a reasonable amount of time to
ensure that at least one train of equipment remains free of fire damage
following a fire event. Although there is 47 minutes of margin
available for OMA 8, Fire Zone 72A still lacks adequate
defense-in-depth. Therefore, the staff finds that Fire Zone 72A's
defense-in-depth is insufficient to demonstrate reasonable assurance
that safe shutdown can be achieved. As such, OMA 8 is
unacceptable for the purpose of providing the level of protection
intended by the regulation and an exemption from III.G.2 based on OMA
8 cannot be granted for Fire Zone 72A.
3.12 Fire Area H--Containment Building (Fire Zone 75A--Outer Annulus,
Elevation 46'-0'')
3.12.1 Fire Prevention
The licensee stated that the fire loading in this area is moderate
and that the fixed combustibles in this zone consist of cable
insulation and that transient combustibles are administratively
controlled. The licensee also stated that the ignition sources in the
area consist of cables and junction boxes.
3.12.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 75A does not have an automatic
fire
[[Page 7195]]
detection or automatic suppression system installed.
3.12.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 75A has an approximate floor
area of 1,100 square feet and an approximate ceiling height of 22'-0''.
The licensee also stated that the Alternate Safe Shutdown System
instrumentation cabling is protected with a radiant energy shield. The
licensee stated that cables and components associated with redundant
trains of normal instrumentation required to support normal safe
shutdown operations are located in this zone. The normal safe shutdown
instrumentation potentially affected by fire in Fire Area H includes:
SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
Pressurizer level: LT-459, LT-460, LT-461, LT-462
Source-range neutron monitoring: N-31, N-32
RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
The licensee stated that cable Y15-H50 for valve 204B and cable
Y17-H55 for valve 204A are located in this zone. As discussed in
Section 3.0 above, the licensee did not demonstrate any separation
between credited and redundant trains of equipment.
3.12.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 75A)
3.12.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75 minutes,
which provides 47 minutes of margin.
3.12.4.2 OMAs 9 and 10--Activate or Enable Alternate
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold
Leg Temperature Channels
As discussed in Section 3.9.4.2 above, in the event that a fire in
Fire Area H disables redundant trains of normal safe shutdown
instrumentation identified in Section 3.9.3, the licensee may make use
of OMAs performed in a different fire area to place in service
Alternate Safe Shutdown System instruments which have been separated
from the normal shutdown instruments in accordance with III.G.2(f). The
licensee also stated that in locations where normal and alternate
shutdown instrument cables are separated by less than 20 feet, the
cables of the alternate shutdown instruments are protected by a radiant
energy shield as required to meet III.G.2(f).
If OMAs 9 and 10 become necessary, the licensee
stated that they have assumed less than 1 minute for diagnosis, with
the normal instruments assumed to be failed at the start of the event,
and that the required time to perform the action is 13 minutes for the
pneumatic instruments. The shortest timeline is to monitor level in the
SGs, which could approach boil-dry conditions within 34 minutes. This
results in 21 minutes of margin for the pneumatic instruments. The five
electronic instruments are then energized by the same operator who made
the pneumatic instruments operable, so it takes 24 minutes to put the
electronic instruments in service. However, the electronic instrument
readings are not needed until later in the scenario. This results in a
total required time of 13 minutes while the time available is 34
minutes, which provides 21 minutes of margin.
3.12.5 Conclusion for Fire Area H (Fire Zone 75A)
Since the licensee described postulated fire scenarios and Fire
Zone 75A has a moderate combustible fuel loading, lacks an automatic
fire detection system or automatic suppression system, and any
discernable separation between the credited and redundant equipment in
the area, it is credible that a fire would not be detected and
extinguished in a reasonable amount of time to ensure that at least one
train of equipment remains free of fire damage following a fire event.
Although there is 47 minutes of margin available for OMA 8 and
21 minutes of margin available for OMAs 9 and 10,
Fire Zone 75A still lacks adequate defense-in-depth. Therefore, the
staff finds that the defense-in-depth is insufficient to demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 75A and that OMAs 8, 9, and 10 are
unacceptable for the purpose of providing the level of protection
intended by the regulation and that an exemption from III.G.2 based on
these OMAs cannot be granted for Fire Zone 75A.
3.13 Fire Area H--Containment Building (Fire Zone 77A--Outer Annulus)
3.13.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation
and that transient combustibles are administratively controlled. The
licensee also stated that the ignition sources in the area consist of
cables and junction boxes.
3.13.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 77A does not have an automatic
fire detection or automatic suppression system installed.
3.13.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 77A has an approximate floor
area of 950 square feet and an approximate ceiling height of 22'-0''.
The licensee stated that cables and components associated with
redundant trains of normal instrumentation required to support normal
safe shutdown operations are located in this zone. The normal safe
shutdown instrumentation potentially affected by fire in Fire Area H
includes:
SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
Pressurizer level: LT-459, LT-460, LT-461, LT-462
Source-range neutron monitoring: N-31, N-32
RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
The licensee stated that cable Y15-H50 for valve 204B and cable
Y17-H55 for valve 204A are located in this zone. As discussed in
Section 3.0 above, the licensee did not demonstrate any separation
between credited and redundant trains of equipment.
3.13.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 77A)
3.13.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75
[[Page 7196]]
minutes, which provides 47 minutes of margin.
3.13.4.2 OMAs 9 and 10--Activate or Enable Alternate
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold
Leg Temperature Channels
As discussed in Section 3.9.4.2 above, in the event that a fire in
Fire Area H disables redundant trains of normal safe shutdown
instrumentation identified in Section 3.9.3, the licensee may make use
of OMAs performed in a different fire area to place in service
Alternate Safe-Shutdown System instruments which have been separated
from the normal shutdown instruments in accordance with III.G.2(f). The
licensee also stated that in locations where normal and alternate
shutdown instrument cables are separated by less than 20 feet, the
cables of the alternate shutdown instruments are protected by a radiant
energy shield as required to meet III.G.2(f).
If OMAs 9 and 10 become necessary, the licensee
stated that they have assumed less than 1 minute for diagnosis, with
the normal instruments assumed to be failed at the start of the event,
and that the required time to perform the action is 13 minutes for the
pneumatic instruments. The shortest timeline is to monitor level in the
SGs, which could approach boil-dry conditions within 34 minutes. This
results in 21 minutes of margin for the pneumatic instruments. The five
electronic instruments are then energized by the same operator who made
the pneumatic instruments operable, so it takes 24 minutes to put the
electronic instruments in service. However, the electronic instrument
readings are not needed until later in the scenario. This results in a
total required time of 13 minutes while the time available is 34
minutes, which provides 21 minutes of margin.
3.13.5 Conclusion for Fire Area H (Fire Zone 77A)
Since the licensee described postulated fire scenarios and Fire
Zone 77A lacks an automatic fire detection or automatic suppression
system, and any discernable separation between the credited and
redundant equipment in the area, it is credible that a fire would not
be detected and extinguished in a reasonable amount of time to ensure
that at least one train of equipment remains free of fire damage
following a fire event. Although there is 47 minutes of margin
available for OMA 8 and 21 minutes of margin available for
OMAs 9 and 10, Fire Zone 77A still lacks adequate
defense-in-depth. Therefore, the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone 77A and that OMAs 8,
9, and 10 are unacceptable for the purpose of
providing the level of protection intended by the regulation and that
an exemption from III.G.2 based on these OMAs cannot be granted for
Fire Zone 77A.
3.14 Fire Area H--Containment Building (Fire Zone 84A-22 Containment
Fan Cooler Unit Area, Elevation 68'-0'')
3.14.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation
and that transient combustibles are administratively controlled. The
licensee also stated that the ignition sources in the area consist of
cables.
3.14.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 84A does not have an automatic
fire detection or automatic suppression system installed.
3.14.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 84A has an approximate floor
area of 910 square feet and an approximate ceiling height of 27'-0''.
The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55
for valve 204A are located in this zone. As discussed in Section 3.0
above, the licensee could not demonstrate any separation between
credited and redundant trains of equipment.
3.14.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 84A)
3.14.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75 minutes,
which provides 47 minutes of margin.
3.14.5 Conclusion for Fire Area H (Fire Zone 84A)
Since the licensee described postulated fire scenarios and Fire
Zone 84A lacks an automatic fire detection or automatic suppression
system, and any discernable separation between the credited and
redundant equipment in the area, it is credible that a fire would not
be detected and extinguished in a reasonable amount of time to ensure
that at least one train of equipment remains free of fire damage
following a fire event. Although there is 47 minutes of margin
available for OMA 8, Fire Zone 84A still lacks adequate
defense-in-depth. Therefore, the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone 84A and that OMA 8 is
unacceptable for the purpose of providing the level of protection
intended by the regulation and that an exemption from III.G.2 based on
this OMA cannot be granted for Fire Zone 84A.
3.15 Fire Area H--Containment Building (Fire Zone 85A--Incore Detector
Drive Area, Elevation 68'-0'')
3.15.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of cable insulation
and that transient combustibles are administratively controlled.
3.15.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 85A does not have an automatic
fire detection or automatic suppression system installed.
3.15.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 85A has an approximate floor
area of 560 square feet and an approximate ceiling height of 27'-0''.
The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55
for valve 204A are located in this zone. As discussed in Section 3.0
above, the licensee could not demonstrate any separation between
credited and redundant trains of equipment.
3.15.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 85A)
3.15.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available
[[Page 7197]]
to align the charging pump makeup path to the RCS. If OMA 8
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the
action is 14 minutes, which results in a total required time of 28
minutes while the time available is 75 minutes, which provides 47
minutes of margin.
3.15.5 Conclusion for Fire Area H (Fire Zone 85A)
Since the licensee stated that a fire in this zone could result in
a loss of a reliable charging makeup path to the RCS and Fire Zone 85A
lacks an automatic fire detection or suppression system, and any
discernable separation between the credited and redundant equipment in
the area, it is credible that a fire would not be detected and
extinguished in a reasonable amount of time to ensure that at least one
train of equipment remains free of fire damage following a fire event.
Although there is 47 minutes of margin available for OMA 8,
Fire Zone 85A still lacks adequate defense-in-depth. Therefore, the
staff finds that the defense-in-depth is insufficient to demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 85A and that OMA 8 is unacceptable for the purpose
of providing the level of protection intended by the regulation and
that an exemption from III.G.2 based on this OMA cannot be granted for
Fire Zone 85A.
3.16 Fire Area H--Containment Building (Fire Zone 87A--Outer Annulus,
Elevation 46'-0'')
3.16.1 Fire Prevention
The licensee stated that the fire loading in this area is low and
that the fixed combustibles in this zone consist of MCCs and instrument
racks and that transient combustibles are administratively controlled.
The licensee also stated that the ignition sources in the area consist
of MCCs.
3.16.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 87A does not have an automatic
fire detection or automatic suppression system installed.
3.16.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 87A has an approximate floor
area of 434 square feet and an approximate ceiling height of 22'-0'',
which is partially open to the containment dome at the 95'-0''
elevation. The licensee stated that cables and components associated
with redundant trains of normal instrumentation required to support
normal safe shutdown operations are located in this zone. The normal
safe shutdown instrumentation potentially affected by fire in Fire Area
H includes:
SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
Pressurizer level: LT-459, LT-460, LT-461, LT-462
Source-range neutron monitoring: N-31, N-32
RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55
for valve 204A are located in this zone. As discussed in Section 3.0
above, the licensee did not demonstrate any separation between credited
and redundant trains of equipment.
3.16.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 87A)
3.16.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
As stated in Section 3.9.4.1 above, if a fire were to occur and
causes valves 204A and 204B to remain closed, the licensee stated that
OMA 8 is available to align the charging pump makeup path to
the RCS. If OMA 8 becomes necessary, the licensee stated that
they have assumed a 14-minute diagnosis period and that the required
time to perform the action is 14 minutes, which results in a total
required time of 28 minutes while the time available is 75 minutes,
which provides 47 minutes of margin.
3.16.4.2 OMAs 9 and 10--Activate or Enable Alternate
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold
Leg Temperature Channels
As discussed in Section 3.9.4.2 above, in the event that a fire in
Fire Area H disables redundant trains of normal safe shutdown
instrumentation identified in Section 3.9.3, the licensee may make use
of OMAs performed in a different fire area to place in service
Alternate Safe Shutdown System instruments which have been separated
from the normal shutdown instruments in accordance with III.G.2(f). The
licensee also stated that in locations where normal and alternate
shutdown instrument cables are separated by less than 20 feet, the
cables of the alternate shutdown instruments are protected by a radiant
energy shield as required to meet III.G.2(f).
If OMAs 9 and 10 become necessary, the licensee
stated that they have assumed less than 1 minute for diagnosis, with
the normal instruments assumed to be failed at the start of the event,
and that the required time to perform the action is 13 minutes for the
pneumatic instruments. The shortest timeline is to monitor level in the
SGs, which could approach boil-dry conditions within 34 minutes. This
results in 21 minutes of margin for the pneumatic instruments. The five
electronic instruments are then energized by the same operator who made
the pneumatic instruments operable, so it takes 24 minutes to put the
electronic instruments in service. However, the electronic instrument
readings are not needed until later in the scenario. This results in a
total required time of 13 minutes while the time available is 34
minutes, which provides 21 minutes of margin.
3.16.5 Conclusion for Fire Area H (Fire Zone 87A)
Since the licensee described postulated fire scenarios and Fire
Zone 87A lacks an automatic fire detection or suppression system, and
any discernable separation between the credited and redundant equipment
in the area, it is credible that a fire would not be detected and
extinguished in a reasonable amount of time to ensure that at least one
train of equipment remains free of fire damage following a fire event.
Although there is 47 minutes of margin available for OMA 8 and
21 minutes of margin available for OMAs 9 and 10,
Fire Zone 87A still lacks adequate defense-in-depth. Therefore, the
staff finds that the defense-in-depth is insufficient to demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 87A and that OMAs 8, 9, and 10 are
unacceptable for the purpose of providing the level of protection
intended by the regulation and that an exemption from III.G.2 based on
these OMAs cannot be granted for Fire Zone 87A.
3.17 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 17--Turbine Oil Reservoir Area, Elevation 15'-0'' Unit 2
Turbine Building)
3.17.1 Fire Prevention
The licensee stated that the fire loading in this area is high and
that the
[[Page 7198]]
fixed combustibles in this zone consist of lube oil, fuel oil, and
welding leads and that transient combustibles consist of trash,
cardboard, lube oil, fiberglass, rubber, wood, and plastic. The
licensee also stated that the ignition sources in the area consist of
electrical cabinets. The licensee further stated that since Fire Area J
does not contain safety-related structures, systems or components, it
is not subject to the explicit transient combustible controls of
procedure EN-DC-161. However, operator rounds performed each shift
provide for the monitoring of combustibles that could challenge fire
safety. In addition, the licensee stated that procedures OAP-017,
``Plant Surveillance and Operator Rounds'' and EN-MA-132,
``Housekeeping'' include guidance for monitoring general area
cleanliness as well as monitoring for accumulations of combustibles.
3.17.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 17 has an automatic thermal fire
detection system installed throughout the zone and an automatic aqueous
foaming foam spray system installed at the turbine lube oil reservoir.
The licensee also stated that the detection system was designed and
installed in accordance with NFPA 72D, 1967 Edition and the fire
suppression system was designed and installed in accordance with NFPA
16, 1968 Edition.
3.17.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 17 has an approximate floor area
of 968 square feet and an approximate ceiling height of 37'-0''. The
licensee stated that cable JC2-YA9, which is associated with Buses 5A
and 6A, is routed through Fire Zones 17, 47A, and 50A and that ignition
sources in the zone located less than 20 feet horizontally from cable
JC2-YA9 consists of electrical cabinets, motors, and MCCs. According to
the licensee, the electrical cabinets are separated from the cable by
approximately 3.8 feet horizontally and 1.9 feet vertically or greater
and six motors are located above the cable routing separated from the
cable by approximately 2.1 feet horizontally or greater. The licensee
also stated that the turbine lube oil reservoir is located in Fire Zone
17. As discussed in Section 3.0 above, the licensee could not
demonstrate any separation between credited and redundant trains of
equipment.
3.17.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 17)
3.17.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
The licensee stated that offsite power is the preferred lineup for
supplying the 480V loads on Buses 2A, 3A, 5A, and 6A. In the event that
offsite power is not available due to fire, the licensee stated that
the Emergency Diesel Generators (EDGs) are credited to supply 480V
loads on Buses 2A, 3A, 5A, and 6A. The licensee also stated that a fire
in Fire Zone 17 which damages certain cables associated with 480V Buses
5A and/or 6A could prevent loading of Buses 5 and 6 from the EDGs, and
thereby, result in a loss of 480V power from the affected bus(es).
Since a fire in Fire Zone 17 may impact the availability of offsite
power, the licensee stated that they assume offsite power is
unavailable at the start of the fire event.
In the event that a fire occurs and damages the cables identified
above, the licensee stated that OMA 11 is available to restore
or maintain power by tripping breakers 52/5A and 52-SAC on Bus 5A and
Breakers 52/6A and 52/TAO at Bus 6A in the 480V Switchgear Room (Fire
Area A) and removing their control power fuses. The licensee stated
that loss of power to the affected buses is detected by loss of
indication in the CCR. Loss of power to Bus 5A or Bus 6A causes
operators to immediately enter procedure 2-AOP-480V-1. The procedure
directs operators to locally inspect the switchgear, at which time any
remaining untripped breakers (i.e., 52/5A, 52-SAC, 52/6A, 52/TAO) would
be noted and locally tripped as necessary. If OMA 11 becomes
necessary, the licensee stated that they have assumed that a loss of
offsite power occurs at the beginning of the fire event and that the
required time to perform the action is 10 minutes while the time
available is 60 minutes, which provides 50 minutes of margin. The NRC
staff finds that OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.17.5 Conclusion for a Fire in Fire Area J (Fire Zone 17)
Given the fire detection system, automatic fire suppression system,
and large volume of the space, it is unlikely that a fire would occur
and go undetected and not be extinguished in a reasonable amount of
time to ensure that at least one train of equipment necessary for safe
shutdown remains free of fire damage. In the unlikely event that a fire
does occur and causes damage that necessitates OMA 11, the
action is clear and proceduralized with 50 minutes of margin available
to provide assurance that safe shutdown capability will be maintained
following the postulated fire events. Therefore, the NRC staff finds
that there is adequate defense-in-depth provided for Fire Zone 17 and
that OMA 11 is acceptable for the purpose of providing the
level of protection intended by the regulation, and that an exemption
from III.G.2 based on OMA 11 is granted for Fire Zone 17.
3.18 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 19--Station Air Compressor Area, Elevation 15'-0'' Unit 2
Turbine Building)
3.18.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that the primary fixed combustible in this zone is lube oil, which is
contained in the turbine lube oil piping system, and that transient
combustibles consist of trash, cleaning rags, lube oil, and paint. The
licensee also stated that the ignition sources in the area consist of a
motor, a compressor, and an electrical cabinet. The licensee further
stated that since Fire Area J does not contain safety-related
structures, systems or components, it is not subject to the explicit
transient combustible controls of procedure EN-DC-161. However,
operator rounds performed each shift provide for the monitoring of
combustibles that could challenge fire safety. In addition, the
licensee stated that procedures OAP-017, ``Plant Surveillance and
Operator Rounds'' and EN-MA-132, ``Housekeeping'' include guidance for
monitoring general area cleanliness as well as monitoring for
accumulations of combustibles.
3.18.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 19 does not have a fire
detection or automatic fire suppression system installed.
3.18.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 19 has an approximate floor area
of 798 square feet and an approximate ceiling height of 21'-0''. The
licensee stated that a fire in Fire Area J which damages certain cables
associated with 480V Buses 5A and/or 6A could prevent loading of Buses
5A and 6A from the EDGs, and thereby, result in a loss of
[[Page 7199]]
480VAC power from the affected bus(es). According to the licensee,
cables associated with Buses 5A and 6A are located in this fire zone.
The licensee stated that cable AG5-XA5, which is associated with Bus
5A, is located in Fire Zone 19. The licensee also stated that the
ignition sources in the zone located less than 20 feet horizontally
from cable AG5-XA5 consist of seven electrical cabinets, a 150kVA dry
transformer, three motors, and an MCC. According to the licensee, three
electrical cabinets are located under the cable separated by
approximately 3 feet vertically or greater, the remaining four
electrical cabinets are separated from the cable by approximately 2
feet horizontally or greater, the 150 kVA dry transformer is separated
from the cable by approximately 1.6 feet horizontally and 6.7 feet
vertically, the motors are separated from the cable by approximately
4.6 feet horizontally or greater, and the MCC is separated from the
cable by approximately 7.5 feet horizontally.
The licensee stated that cables PC9-XA5/1 and PC9-XA5/2, which are
associated with Bus 5A, are routed between two junction boxes in Fire
Zone 19 for approximately 2 feet. The licensee also stated that the
ignition sources in the zones located less than 20 feet horizontally
from the cable consist of three motors, which are all separated from
the cables by approximately 4.6 feet horizontally or greater. The
licensee also stated that cable XA5-WU9, associated with Bus 5A, is
routed in Fire Zone 19 from east to west terminating at the Station Air
Compressor. The licensee stated that the ignition sources in the zone
located less than 20 feet horizontally from the cable consist of two
motors, which are separated from the cable by approximately 4.6 feet
horizontally or greater. As discussed in Section 3.0 above, the
licensee could not demonstrate any separation between credited and
redundant trains of equipment.
3.18.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 19)
3.18.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on bus 5A and
52/6A and 52/TAO at bus 6A and Remove Control Power Fuses.
OMA 11 was evaluated in Section 3.17.4.1 above. As stated
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.18.5 Conclusion for Fire Area J (Fire Zone 19)
Since the licensee described postulated fire scenarios and Fire
Zone 19 lacks an automatic fire detection or automatic fire suppression
system, and any discernable separation between the credited and
redundant equipment in the area, it is possible that a fire would not
be detected and extinguished in a reasonable amount of time to ensure
that at least one train of equipment remains free of fire damage
following a fire event. Although there is 50 minutes of margin
available for OMA 11, Fire Zone 19 still lacks adequate
defense-in-depth. Therefore, the staff finds that the defense-in-depth
is insufficient to demonstrate reasonable assurance that safe shutdown
can be achieved for a fire in Fire Zone 19 and that OMA 11 is
unacceptable for the purpose of providing the level of protection
intended by the regulation. Therefore, the NRC staff finds that an
exemption from III.G.2 based on this OMA cannot be granted for Fire
Zone 19.
3.19 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 25--23 Battery Room, Elevation 33'-0'' of the Unit 1
Superheater Building)
3.19.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that the primary fixed combustibles in this zone are batteries and
cable insulation and that transient combustibles are administratively
controlled. The licensee also stated that the ignition sources in the
area consist of batteries and electrical cabinets. The licensee further
stated that since Fire Area J does not contain safety-related
structures, systems or components, it is not subject to the explicit
transient combustible controls of procedure EN-DC-161. However,
operator rounds performed each shift provide for the monitoring of
combustibles that could present an unacceptable fire safety challenge.
In addition, the licensee stated that procedures OAP-017, ``Plant
Surveillance and Operator Rounds'' and EN-MA-132, ``Housekeeping''
include guidance for monitoring general area cleanliness as well as
monitoring for accumulations of combustibles.
3.19.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 25 does not have a fire
detection or automatic fire suppression system installed.
3.19.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 25 has an approximate floor area
of 92 square feet and an approximate ceiling height of 10'-0''. The
licensee stated that cables EDB8-EPB3, EGA9-EDB8/4, and EGA9-EDB8/5 are
routed through Fire Zone 25 in rigid steel conduit and that since
cables EGA9-EDB8/4 and EGA9-EDB8/5 originate inside the battery room at
the batteries, there is no separation between the cables and the
batteries. The licensee also stated that ignition sources in the zone
located less than 20 feet horizontally from cable EDB8-EPB3 consist of
an MCC, a 45kVA dry transformer, and two electrical cabinets. According
to the licensee, the MCC is separated from the cable by approximately
18.5 feet horizontally, the transformer is separated from the cable by
approximately 13.6 feet horizontally, one electrical cabinet is
separated from the cable by approximately 12.8 feet horizontally, and
the second electrical cabinet is separated from the cable by
approximately 5.5 feet horizontally. As discussed in Section 3.0 above,
the licensee could not demonstrate any separation between credited and
redundant trains of equipment.
3.19.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 25)
3.19.4.1 OMA 12--Transfer Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument buses 23 and 23A could
experience a loss of their normal power source (125 VDC power panel 23)
as a result of fire in Fire Zone 25. If this were to occur, the
licensee stated that OMA 12 is available to swap Instrument
Buses 23 and 23A to their backup power source (MCC-29A). If OMA
12 becomes necessary, the licensee stated that they have
assumed a 5.5-minute diagnosis period and that the required time to
perform the action is 2 minutes while the time available is 30 minutes,
which provides 22.5 minutes of margin.
3.19.5 Conclusion for Fire Area J (Fire Zone 25)
Since the licensee described postulated fire scenarios and Fire
Zone 25 lacks an automatic fire detection or automatic fire suppression
system, and any discernable separation between the credited and
redundant equipment in the area, it is possible that a fire would not
be detected and extinguished in a reasonable amount of time to ensure
[[Page 7200]]
that at least one train of equipment remains free of fire damage
following a fire event. Although there is 22.5 minutes of margin
available for OMA 12, Fire Zone 25 still lacks adequate
defense-in-depth. Therefore, the NRC staff finds that the defense-in-
depth is insufficient to demonstrate reasonable assurance that safe
shutdown can be achieved for a fire in Fire Zone 25 and that OMA
12 is unacceptable for the purpose of providing the level of
protection intended by the regulation. Therefore, the NRC staff finds
that an exemption from III.G.2 based on OMA 12 cannot be
granted for Fire Zone 25.
3.20 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 39A--Mezzanine Floor, Elevation 36'-9'' Unit 2 Turbine
Building)
3.20.1 Fire Prevention
The licensee stated that the fire loading in this zone is moderate
and that the fixed combustibles in this zone consist of cable
insulation, plastic, and cellulose and that transient combustibles in
this zone consist of trash, wood, and lube oil. The licensee also
stated that the ignition sources in this zone consist of cables,
junction boxes, electrical cabinets, and motors. The licensee further
stated that since Fire Area J does not contain safety-related
structures, systems or components, it is not subject to the explicit
transient combustible controls of procedure EN-DC-161. However,
operator rounds performed each shift provide for the monitoring of
combustibles that could present an unacceptable fire safety challenge.
In addition, the licensee stated that procedures OAP-017 (Plant
Surveillance and Operator Rounds) and EN-MA-132 (Housekeeping) include
guidance for monitoring general area cleanliness as well as monitoring
for accumulations of combustibles.
3.20.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 39A does not have a fire
detection or automatic fire suppression system installed.
3.20.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 39A has an approximate floor
area of 7,592 square feet and an approximate ceiling height of 16'-0''.
The licensee stated that cable AG5-XA5, which is associated with
instrument buses 23 and 23A and buses 5A and 6A, is located in Fire
Zone 39A. The licensee also stated that the ignition sources in the
zone located less than 20 feet horizontally from cable AG5-XA5 consist
of seven electrical cabinets, a 150 kVA dry transformer, three motors,
and an MCC. According to the licensee, three electrical cabinets are
located under the cable separated by approximately 3 feet vertically or
greater, the remaining four electrical cabinets are separated from the
cable by approximately 2 feet horizontally or greater, the 150 kVA dry
transformer is separated from the cable by approximately 1.6 feet
horizontally and 6.7 feet vertically, the motors are separated from the
cable by approximately 4.6 feet horizontally or greater, and the MCC is
separated from the cable by approximately 7.5 feet horizontally. As
discussed in Section 3.0 above, the licensee could not demonstrate any
separation between credited and redundant trains of equipment.
3.20.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 39A)
3.20.4.1 OMA 11--Trip breakers 52/5A and 52-SAC on bus 5A and
52/6A and 52/TAO at bus 6A and Remove Control Power Fuses
OMA 11 was evaluated in Section 3.17.4.1 above. As stated
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.20.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument buses 23 and 23A could
experience a loss of their normal power source (125 VDC power panel 23)
as a result of fire in Fire Zone 39A. If this were to occur, the
licensee stated that OMA 12 is available to swap Instrument
Buses 23 and 23A to their backup power source (MCC-29A). If OMA
12 becomes necessary, the licensee stated that they have
assumed a 5.5-minute diagnosis period and that the required time to
perform the action is 2 minutes while the time available is 30 minutes,
which provides 22.5 minutes of margin.
3.20.5 Conclusion for Fire Area J (Fire Zone 39A)
Since the licensee described postulated fire scenarios and Fire
Zone 39A lacks an automatic fire detection or automatic fire
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is possible that a fire would
not be detected and extinguished in a reasonable amount of time to
ensure that at least one train of equipment remains free of fire damage
following a fire event. Although there is 50 minutes of margin
available for OMA 11 and 22.5 minutes of margin available for
OMA 12, Fire Zone 39A still lacks adequate defense-in-depth.
Therefore, the NRC staff finds that the defense-in-depth is
insufficient to demonstrate reasonable assurance that safe shutdown can
be achieved for a fire in Fire Zone 39A and that OMAs 11 and
12 are unacceptable for the purpose of providing the level of
protection intended by the regulation. Therefore, the NRC staff finds
that an exemption from III.G.2 based on these OMAs cannot be granted
for Fire Zone 39A.
3.21 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 43A--Ground Floor, Elevation 15-0'' Unit 2 Turbine Building)
3.21.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that the fixed combustibles in this zone consist of cable insulation,
lube oil, plastic, wood, electrical panels, and cabinets and that the
transient combustibles in this zone consist of trash, cardboard drums,
cleaning rags, lube oil, plastic, fiberglass ladders, and paint. The
licensee also stated that the ignition sources in this zone consist of
cables, junction boxes, MCC, motors, pumps, electrical cabinets, high
voltage arcing faults, and an air dryer. The licensee further stated
that since Fire Area J does not contain safety-related structures,
systems or components, it is not subject to the explicit transient
combustible controls of procedure EN-DC-161. However, operator rounds
performed each shift provide for the monitoring of combustibles that
could present an unacceptable fire safety challenge. In addition, the
licensee stated that procedures OAP-017 (Plant Surveillance and
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for
monitoring general area cleanliness as well as monitoring for
accumulations of combustibles.
3.21.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 43A does not have a fire
detection or automatic fire suppression system installed.
3.21.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 43A has an approximate floor
area of
[[Page 7201]]
6,600 square feet and an approximate ceiling height of 21'-0''. The
licensee stated that cable JC2-YA9, which is associated with Buses 5A
and 6A, is routed through Fire Zone 43A in a tray located approximately
15 feet above the floor and that ignition sources in the zone located
less than 20 feet horizontally from the cable consist of two MCCs, an
air dryer skid, 6.9 kV switchgear, and an electrical cabinet. According
to the licensee, the MCCs are located under the cable routing separated
from the cable by approximately 7.7 feet vertically, the air dryer skid
is separated from the cable by approximately 6.1 feet horizontally, the
electrical cabinet is separated from the cable by approximately 2 feet
horizontally and 9.2 feet vertically, and the 6.9 kV switchgear is
separated from the cable by approximately 0.7 feet horizontally and 7.7
feet vertically.
The licensee also stated that cable AC4-BA6 is routed through Fire
Zone 43A in a tray located approximately 12 feet above the floor and
that ignition sources in the zone located less than 20 feet
horizontally from the cable consist of 6.9 kV switchgear and an
electrical cabinet. According to the licensee, the 6.9 kV switchgear is
separated from the cable by zero feet horizontally and approximately
3.7 feet vertically and the electrical cabinet is separated from the
cable by approximately 6 feet horizontally.
The licensee also stated that cable AA3-BA5 is associated with
instrument buses 23 and 23A and is routed through Fire Zone 43A in tray
located approximately 14 feet above the floor and that ignition sources
in the zone located less than 20 feet horizontally from the cable
consist of 6.9 kV switchgear and an electrical cabinet. According to
the licensee, the 6.9 kV switchgear is separated from the cable by
approximately 0 feet horizontally and 5 feet vertically and the
electrical cabinet is separated from the cable by approximately 3 feet
horizontally and 7 feet vertically.
The licensee also stated that cable AD1-BA8 is associated with
instrument buses 23 and 23A and is routed through Fire Zone 43A in tray
located approximately 14 feet above the floor and that ignition sources
in the zone located less than 20 feet horizontally from the cable
consist of 6.9 kV switchgear and an electrical cabinet. According to
the licensee, the 6.9 kV switchgear is separated from the cable by
approximately 0 feet horizontally and 5.6 feet vertically and the
electrical cabinet is separated from the cable by approximately 6 feet
horizontally.
The licensee stated that cable ECE19-MN3/01, which is associated
with valve LCV-112B, is routed through Fire Zone 43A in a cable tray
located approximately 13 feet above the floor and that ignition sources
in the zone located less than 20 feet horizontally from the cable
consist of an MCC, an air dryer skid, 6.9 kV switchgear, a portable
Duraline power station, and an electrical cabinet. According to the
licensee, the MCC is separated from the cable by approximately 3.2 feet
horizontally and 0 feet vertically, the air dryer skid is separated
from the cable by approximately 7.7 feet horizontally and 2.6 feet
vertically, the electrical cabinet is separated from the cable by
approximately 2 feet horizontally and 7.3 feet vertically, the 6.9 kV
switchgear is separated from the cable by approximately 0.7 feet
horizontally and 5.8 feet vertically, and the Duraline power station is
separated from the cable by approximately 19.5 feet horizontally.
As discussed in Section 3.0 above, the licensee did not demonstrate
any separation between credited and redundant trains of equipment.
3.21.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 43A)
3.21.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
OMA 11 was evaluated in Section 3.17.4.1 above. As stated
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.21.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that Instrument buses 23 and 23A could
experience a loss of their normal power source (125 VDC power panel 23)
as a result of fire in Fire Zone 43A. If a fire were to occur and
causes a loss of offsite power and damages the cables identified above,
the licensee stated that OMA 12 is available to swap
Instrument Buses 23 and 23A to their backup power source (MCC-29A). If
OMA 12 becomes necessary, the licensee stated that they have
assumed a 5.5-minute diagnosis period and that the required time to
perform the action is 2 minutes while the time available is 30 minutes,
which provides 22.5 minutes of margin.
3.21.4.3 OMA 13--Align Charging Pump Suction to RWST
The licensee stated that fire-induced cable damage may render
alternate charging pump suction supply valve LCV-112B (normally closed
RWST outlet valve) inoperable. In the event that cable failures have
rendered LCV-112B inoperable, local valve manipulations are required to
support alignment of the charging pump suction to the alternate source,
the RWST.
If a fire were to occur and renders the alternate charging pump
suction supply valve LCV-112B inoperable, the licensee stated that OMA
13 is available to locally close valve LCV-112C and open
manual valve 288 to provide a bypass around RWST outlet valve LCV-112B
and provide water to the charging pump suction. If OMA 13
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the
action is 18 minutes while the time available is 75 minutes, which
provides 43 minutes of margin.
3.21.5 Conclusion for Fire Area J (Fire Zone 43A)
Since the licensee described postulated fire scenarios and Fire
Zone 43A lacks an automatic fire detection or automatic fire
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is possible that a fire would
not be detected and extinguished in a reasonable amount of time to
ensure that at least one train of equipment remains free of fire damage
following a fire event. Although there is 50 minutes of margin
available for OMA 11, 22.5 minutes of margin available for OMA
12, and 43 minutes of margin available for OMA 13,
Fire Zone 43A lacks adequate defense-in-depth. Therefore, the NRC staff
finds that the defense-in-depth is insufficient to demonstrate
reasonable assurance that safe shutdown can be achieved for a fire in
Fire Zone 43A and that OMAs 11, 12, and 13
are unacceptable for the purpose of providing the level of protection
intended by the regulation. Therefore, the NRC staff finds that an
exemption from III.G.2 based on these OMAs cannot be granted for Fire
Zone 43A.
3.22 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 45A--Ground Floor, Elevation 15-0'' and 3'-3'' of the Unit 2
Turbine Building)
3.22.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that the fixed combustibles in this zone consist of cable insulation,
lube oil, vinyl insulation, and hydrogen and that the transient
combustibles in this zone
[[Page 7202]]
consist of trash, cardboard drums, lube oil, fiberglass ladders, paint,
and radiation boundaries. The licensee also stated that the ignition
sources in this zone consist of cables, junction boxes, MCC, motors,
pumps, and electrical cabinets. The licensee further stated that since
Fire Area J does not contain safety-related structures, systems or
components, it is not subject to the explicit transient combustible
controls of procedure EN-DC-161. However, operator rounds performed
each shift provide for the monitoring of combustibles that could
present an unacceptable fire safety challenge. In addition, the
licensee stated that procedures OAP-017 (Plant Surveillance and
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for
monitoring general area cleanliness as well as monitoring for
accumulations of combustibles.
3.22.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 45A does not have a fire
detection or automatic fire suppression system installed.
3.22.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 45A has an approximate floor
area of 5,380 square feet and an approximate ceiling height of 12'-4''.
The licensee stated that cable AG5-XA5, which affects buses 5A and 6A,
is located in Fire Zone 45A and that ignition sources in the zone
located less than 20 feet horizontally from cable AG5-XA5 consist of
seven electrical cabinets, a 150KVA dry transformer, three motors, and
an MCC. According to the licensee, three electrical cabinets are
located under the cable separated by approximately 3 feet vertically or
greater, four electrical cabinets are separated from the cable by
approximately 2 feet horizontally or greater, the 150KVA dry
transformer is separated from the cable by approximately 1.6 feet
horizontally and 6.7 feet vertically. The motors are separated from the
cable by approximately 4.6 feet horizontally or greater, and the MCC is
separated from the cable by approximately 7.5 feet horizontally. As
discussed in Section 3.0 above, the licensee could not demonstrate any
separation between credited and redundant trains of equipment.
3.22.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 45A)
3.22.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
OMA 11 was evaluated in Section 3.17.4.1 above. As stated
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.22.5 Conclusion for Fire Area J (Fire Zone 45A)
Since the licensee described postulated fire scenarios and Fire
Zone 45A lacks an automatic fire detection or automatic fire
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is possible that a fire would
not be detected and extinguished in a reasonable amount of time to
ensure that at least one train of equipment remains free of fire damage
following a fire event. Although there is 50 minutes of margin
available for OMA 11, Fire Zone 45A still lacks adequate
defense-in-depth. The NRC staff finds that the defense-in-depth is
insufficient to demonstrate reasonable assurance that safe shutdown can
be achieved for a fire in Fire Zone 45A and that OMA 11 is
unacceptable for the purpose of providing the level of protection
intended by the regulation. Therefore, the NRC staff finds that an
exemption from III.G.2 based on OMA 11 cannot be granted for
Fire Zone 45A.
3.23 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater
Building, Nuclear Service Building, Chemical Systems Building,
Administration Building, Screenwell House, and Unit 2 Turbine Building
(Fire Zone 46A--Ground Floor, Elevation 12'-0'' and 3'-3'' Unit 2
Turbine Building)
3.23.1 Fire Prevention
The licensee stated that the fire loading in this zone is low and
that the fixed combustibles in this zone consist of cable insulation
and lube oil and that the transient combustibles in this zone consist
of trash, cleaning rags, lube oil, and paint. The licensee also stated
that the ignition sources in this zone consist of cables, junction
boxes, motors, pumps, and electrical cabinets. The licensee further
stated that since Fire Area J does not contain safety-related
structures, systems or components, it is not subject to the explicit
transient combustible controls of procedure EN-DC-161. However,
operator rounds performed each shift provide for the monitoring of
combustibles that could present an unacceptable fire safety challenge.
In addition, the licensee stated that procedures OAP-017, ``Plant
Surveillance and Operator Rounds,'' and EN-MA-132, ``Housekeeping,''
include guidance for monitoring general area cleanliness as well as
monitoring for accumulations of combustibles.
3.23.2 Detection, Control, and Extinguishment
The licensee stated that Fire Zone 46A does not have a fire
detection or automatic fire suppression system installed.
3.23.3 Preservation of Safe Shutdown Capability
The licensee stated that Fire Zone 46A has an approximate floor
area of 12,350 square feet and an approximate ceiling height of 12'-
4''. The licensee stated that cable JC2-YA9, which is associated with
Buses 5A and 6A, is routed through Fire Zone 46A in a tray located
approximately 15 feet above the floor and that ignition sources in the
zone located less than 20 feet horizontally from the cable consist of
two MCCs, an air dryer skid, 6.9kV switchgear, and an electrical
cabinet. According to the licensee, the MCCs are located under the
cable routing separated from the cable by approximately 7.7 feet
vertically, the air dryer skid is separated from the cable by
approximately 6.1 feet horizontally, the electrical cabinet is
separated from the cable by approximately 2 feet horizontally and 9.2
feet vertically, and the 6.9kV switchgear is separated from the cable
by approximately 0.7 feet horizontally and 7.7 feet vertically.
The licensee also stated that cable JB1-L91, which is associated
with instrument buses 23 and 23A, is routed through the Fire Zone 46A.
The licensee also stated that cable ECE19-MN3/01, which is
associated with valve LCV-112B, is routed through Fire Zone 46A in a
cable tray located approximately 13 feet above the floor and that
ignition sources in the zone located less than 20 feet horizontally
from the cable consist of an MCC, an air dryer skid, 6.9kV switchgear,
a portable Duraline power station, and an electrical cabinet. According
to the licensee, the MCC is separated from the cable by approximately
3.2 feet horizontally and 0 feet vertically, the air dryer skid is
separated from the cable by approximately 7.7 feet horizontally and 2.6
feet vertically, the electrical cabinet is separated from the cable by
approximately 2 feet horizontally and 7.3 feet vertically, the 6.9kV
switchgear is separated from the cable by approximately 0.7 feet
horizontally and 5.8 feet vertically, and the Duraline power station is
separated from the
[[Page 7203]]
cable by approximately 19.5 feet horizontally.
As discussed in Section 3.0 above, the licensee did not demonstrate
any separation between credited and redundant trains of equipment.
3.23.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 46A)
3.23.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
OMA 11 was evaluated in Section 3.17.4.1 above. As stated
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire
zones in Fire Area J.
3.23.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to
Emergency Power Source
The licensee stated that instrument buses 23 and 23A could
experience a loss of their normal power source (125 VDC power panel 23)
as a result of fire in Fire Zone 46A. If this were to occur, the
licensee stated that OMA 12 is available to swap instrument
buses 23 and 23A to their backup power source (MCC-29A). If OMA
12 becomes necessary, the licensee stated that they have
assumed a 5.5-minute diagnosis period and that the required time to
perform the action is 2 minutes while the time available is 30 minutes,
which provides 22.5 minutes of margin.
3.23.4.3 OMA 13--Align Charging Pump Suction to RWST
The licensee stated that fire-induced cable damage may render
alternate charging pump suction supply valve LCV-112B (normally closed
RWST outlet valve) inoperable. In the event that cable failures have
rendered LCV-112B inoperable, this valve is required to be opened to
support alignment of charging pump suction to the alternate source, the
RWST.
If a fire were to occur and it renders alternate charging pump
suction supply valve LCV-112B inoperable, the licensee stated that OMA
13 is available to locally close valve LCV-112C and open
manual valve 288 to provide a bypass around RWST outlet valve LCV-112B
and provide water to the charging pump suction. If OMA 13
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the
action is 18 minutes while the time available is 75 minutes, which
provides 43 minutes of margin.
3.23.5 Conclusion for Fire Area J (Fire Zone 46A)
Since the licensee described postulated fire scenarios and Fire
Zone 46A lacks an automatic fire detection or automatic fire
suppression system, and any discernable separation between the credited
and redundant equipment in the area, it is possible that a fire would
not be detected and extinguished in a reasonable amount of time to
ensure that at least one train of equipment remains free of fire damage
following a fire event. Although there is 50 minutes of margin
available for OMA 
