Millstone Power Station, Unit 2; Exemption, 43382-43405 [2012-17735]

Download as PDF 43382 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices Revision 2, by relocating the closure times for MSIVs, FIVs, FCVs, and associated bypass valves to the Technical Requirements Manual (TRM). The availability of TSTF–491, Revision 2, was announced in the Federal Register on December 29, 2006 (71 FR 78472), as part of the Consolidated Line Item Improvement Process (CLIIP). Date of issuance: June 29, 2012. Effective date: As of the date of issuance and shall be implemented within 120 days from the date of issuance. Amendment Nos.: Unit 1—157; Unit 2—157. Facility Operating License Nos. NPF– 87 and NPF–89: The amendments revised the Facility Operating Licenses and Technical Specifications. Date of initial notice in Federal Register: January 24, 2012 (77 FR 3511). The Commission’s related evaluation of the amendments is contained in a Safety Evaluation dated June 29, 2012. No significant hazards consideration comments received: No. South Carolina Electric and Gas Company, South Carolina Public Service Authority, Docket No. 50–395, Virgil C. Summer Nuclear Station, Unit 1, Fairfield County, South Carolina sroberts on DSK5SPTVN1PROD with NOTICES Date of application for amendment: October 12, 2011. Brief description of amendment: The amendment authorizes revision of the Final Safety Analysis Report (FSAR) to reflect deletion of five high head safety injection (HHSI) containment isolation valves from the local leak rate test program on the basis that they are in lines that are closed outside of containment. Date of issuance: July 9, 2012. Effective date: This license amendment is effective as of the date of its issuance. Amendment No.: 191. Renewed Facility Operating License No. NPF–12: Amendment revises the License. Date of initial notice in Federal Register: December 13, 2011 (76 FR 77570). The Commission’s related evaluation of the amendment is contained in a Safety Evaluation dated July 9, 2012. No significant hazards consideration comments received: No. Tennessee Valley Authority, Docket No. 50–328, Sequoyah Nuclear Plant, Unit 2, Hamilton County, Tennessee Date of application for amendment: July 15, 2011, as supplemented on October 20, 2011 (TS–SQN–2011–01). Brief description of amendment: The proposed amendment revised the VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 Technical Specifications (TSs) requirements for steam generator (SG) tube inspections to reflect the replacement steam generators (RSGs) to be installed during refueling outage 18 presently scheduled for the fall of 2012. Previous changes to the TSs to reflect the Technical Specification Task Force (TSTF) Standard Technical Specification Traveler, TSTF–449, ‘‘Steam Generator Tube Integrity,’’ Revision 4, were approved by the U.S. Nuclear Regulatory Commission (NRC) on May 22, 2007. The changes proposed in this amendment reflect the inspection requirements of TSTF–449, Revision 4. The RSG tubes will be made of Alloy 690 thermally treated (TT) material, and the existing SGs have Alloy 600 tubes. The revisions to TSs are required because the inspection frequency for Alloy 690 TT tube material, as defined in TSTF–449, differs from the inspection frequency for Alloy 600, and the tube repair processes and products in the existing TSs are not applicable to the RSGs. Date of issuance: July 10, 2012. Effective date: As of the date of issuance and shall be implemented upon startup from fall 2012 refueling outage after completing the installation of new steam generators. Amendment No.: 323. Facility Operating License No. DPR– 79: Amendment revised the TSs. Date of initial notice in Federal Register: September 6, 2011 (76 FR 55131). The supplement letter dated October 20, 2011, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff’s original proposed no significant hazards consideration determination. The Commission’s related evaluation of the amendment is contained in a Safety Evaluation dated July 10, 2012. No significant hazards consideration comments received: No. Dated at Rockville, Maryland, this 13th day of July 2012. For the Nuclear Regulatory Commission. Michele G. Evans, Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation. [FR Doc. 2012–17869 Filed 7–23–12; 8:45 am] BILLING CODE 7590–01–P PO 00000 Frm 00155 Fmt 4703 Sfmt 4703 NUCLEAR REGULATORY COMMISSION [Docket No. 50–336; NRC–2012–0158] Millstone Power Station, Unit 2; Exemption 1.0 Background Dominion Nuclear Connecticut, Inc., (the licensee, Dominion) is the holder of Renewed Facility Operating License No. DPR–65, which authorizes operation of the Millstone Power Station, Unit 2 (MPS2). 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. MPS2 shares the site with Millstone Power Station Unit 1, a permanently defueled boiling water reactor nuclear unit, and Millstone Power Station Unit 3, a pressurized water reactor. The facility is located in Waterford, Connecticut, approximately 3.2 miles west southwest of New London, CT. This exemption applies to MPS2 only. The other units, Units 1 and 3, are not part of this exemption. 2.0 Request/Action Title 10 of the Code of Federal Regulations (10 CFR) 50.48, requires that nuclear power plants that were licensed 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.’’ MPS2 was licensed to operate prior to January 1, 1979. As such, the licensee’s Fire Protection Program (FPP) must provide the established level of protection as intended by Section III.G of 10 CFR Part 50, Appendix R. By letter dated June 30, 2011, ‘‘Request for Exemption from 10 CFR Part 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability’’ available at Agencywide Documents Access and Management System (ADAMS), Accession No. ML11188A213, and supplemented by letter dated February 29, 2012, ‘‘Response to Request for Additional Information Request for Exemption from 10 CFR Part 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability’’ (ADAMS Accession No. ML12069A016), the licensee requested an exemption for MPS2, from certain technical requirements of 10 CFR Part 50, Appendix R, Section III.G.2 (III.G.2) for the use of operator manual actions (OMAs) in lieu of meeting the circuit E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices separation and protection requirements contained in III.G.2 for fire areas: R–2/Fire Hazards Analysis (FHA) Zone A–8C, Zone A–8D, Zone A–13, Zone T–8, Zone T–10; R–4/FHA Zone A–6A, Zone A–6B; R–5/FHA Zone A–8A; R–6/FHA Zone A–3; R–7/FHA Zone A–15; R–8/FHA Zone A–16; R–9/FHA Zone A–20; R–10/FHA Zone A–21; R–12/FHA Zone T–4; R–13/FHA Zone T–6; R–14/FHA Zone T–7, Zone T–9; R–15/FHA Zone C–1; R–17/FHA Zone A–10A, Zone A–10B, and Zone A–10C. 3.0 Discussion Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when: (1) The exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent with the common defense and security; and (2) when special circumstances are present. The licensee has stated that special circumstances are present in that the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule, which is consistent with the language included in 10 CFR 50.12(a)(2)(ii). The licensee further states that the OMAs included in the exemption request provide assurance that one train of systems necessary to achieve and maintain hot shutdown will remain available in the event of a fire. In accordance with 10 CFR 50.48(b), nuclear power plants licensed before January 1, 1979, are required to meet Section III.G, of 10 CFR Part 50, Appendix R. The underlying purpose of Section III.G of 10 CFR Part 50, Appendix R, is to ensure that the ability to achieve and maintain safe shutdown is preserved following a fire event. The regulation intends for licensees to accomplish this by extending the concept of defense-in-depth to: a. Prevent fires from starting; b. Rapidly detect, control, and extinguish promptly those fires that do occur; c. Provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant. The stated purpose of III.G.2 is to ensure that in the event of a fire, one of the redundant trains necessary to achieve and maintain hot shutdown conditions remains free of fire damage. III.G.2 requires one of the following means to ensure that a redundant train of safe shutdown cables and equipment is free of fire damage, where redundant trains are located in the same fire area outside of primary containment: a. Separation of cables and equipment by a fire barrier having a 3-hour rating; 43383 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. The licensee stated that the OMAs addressed in the exemption request are those contained in the MPS2 Appendix R Compliance Report. The licensee stated that the MPS2 Appendix R Compliance Report was submitted to the NRC for review on May 29, 1987 (ADAMS Legacy Library Accession No. 8706120088, available at NRC Public Document Room) and found acceptable by an NRC safety evaluation report (SER) dated July 17, 1990 (ADAMS Accession No. ML012880391), but that the SER did not specifically address the OMAs. Each OMA included in this review consists of a sequence of tasks that need to be performed in various fire areas. The OMAs are initiated upon confirmation of a fire in a particular fire area. Table 1 lists the OMAs included in this review (OMAs are listed in the order they are conducted for a fire originating in a particular area). Some OMAs are listed more than once, if they are needed for fires that originate in different areas. TABLE 1 Area name Actions Fire Area R–2 ........... West Penetration Area, Motor Control Center B61, and the Facility Z2 Upper 4.16kV Switchgear Room and Cable Vault. Pull Control Power Fuses and Ensure Breaker A305 is Open ... OMA 12 Operate Valve 2–MS–190A to Transition from Main Steam Safety Valves. Check Local Condensate Storage Tank Level Indication at LIS– 5489. Open Breaker to Fail Valve 2–CH–517 Closed .......................... Check Local Level Indication at LI–206A .................................... Check Local Boric Acid Storage Tank Level Indication at LI– 208A. Open Valve 2–CH–429 to Establish Charging Flow Path .......... Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. Open Valve 2–CS–13.1B to Establish Charging Pump Suction from Refueling Water Storage Tank. sroberts on DSK5SPTVN1PROD with NOTICES Area of fire origin OMA 10 Fire Area R–4 ........... Fire Area R–5 ........... VerDate Mar<15>2010 Charging Pump Cubicles ........................... ‘‘A’’ Safeguards Room (High Pressure Safety Injection/Low Pressure Safety Injection). 21:06 Jul 23, 2012 Jkt 226001 PO 00000 Frm 00156 OMA OMA 20 OMA 6 OMA 18 OMA 19 OMA 2 OMA 1 OMA 8 Control at Panel C–10 Until Loss of Air, Operate Valve 2–MS– 190B to Transition from Main Steam Safety Valves. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. OMA 11 Operate Valve 2–MS–190A to Transition from MSSVs .............. OMA 10 Fmt 4703 Sfmt 4703 E:\FR\FM\24JYN1.SGM 24JYN1 OMA 1 43384 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices TABLE 1—Continued Area of fire origin Area name Actions OMA Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. Fire Area R–7 ........... Fire Area R–8 ........... Fire Area R–9 ........... Fire Area R–10 ......... Fire Area R–12 ......... Fire Area R–13 ......... sroberts on DSK5SPTVN1PROD with NOTICES Fire Area R–14 ......... Fire Area R–15 ......... VerDate Mar<15>2010 ‘‘B’’ Safeguards Room (Low Pressure Safety Injection). Diesel Generator Room A ......................... Diesel Generator Room B ......................... Facility Z1 Direct Current Switchgear Room and Battery Room. Facility Z2 Direct Current Room and Battery Room. Equipment Turbine Driven Auxiliary Feedwater Pump Pump Pit. West (Facility Z1) 480 VAC Switchgear Room. Facility Z1 Lower 4.16kV Room and Cable Vault. Switchgear Containment Building ................................ 21:06 Jul 23, 2012 Jkt 226001 PO 00000 Frm 00157 Operate Valve 2–MS–190A to Transition from Main Steam Safety Valves. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. OMA 10 Control at Panel C–10 Until Loss of Air, Operate Valve 2–MS– 190B to Transition from Main Steam Safety Valves. Open Valve 2–CH–508 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–509 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. OMA 11 Operate Valve 2–MS–190A to Transition from Main Steam Safety Valves. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. Check Local Condensate Storage Tank Level Indication at LIS– 5489. OMA 10 Open Valve 2–CH–508 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–509 to Obtain Charging Pump Suction from Boric Acid Storage Tank. OMA 4 Check Local Condensate Storage Tank Level Indication at LIS– 5489. Check Local Boric Acid Storage Tank Level Indication at LI– 206A. Check Local Boric Acid Storage Tank Level Indication at LI– 208A. OMA 20 Operate Valve 2–MS–190A to Transition from Main Steam Safety Valves. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. OMA 10 Operate Valve SV–4188 from Panel C–10 ................................. OMA 22 Operate Speed Control Circuit H–21 from Panel C–10 to Control Turbine Driven Auxiliary Feedwater Pump Speed. Check Local Condensate Storage Tank Level Indication at LIS– 5489. Pull Control Power Fuses and Ensure Breaker A406 is Open ... Close Breaker DV2021 at Panel DV20 ....................................... Open Valve 2–CH–508 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–509 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Operate Pump P18C from Panel C–10 ....................................... Fire Area R–6 ........... OMA 1 OMA 17 Open Valve 2–CH–508 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–509 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Pull Control Power Fuses and Ensure Breaker A410 is Open to Isolate Required Bus. Pull Control Power Fuses and Ensure Breaker A408 is Open to Isolate Required Bus. Pull Control Power Fuses and Ensure Breaker A401 is Closed to Power Bus from the Emergency Diesel Generator. Pull Control Power Fuses and Ensure Breaker A411 is Open to Isolate Required Bus. Close Breaker DV2021 at Panel DV20 ....................................... Operate Valve 2–MS–190A to Transition from Main Steam Safety Valves. Fmt 4703 Sfmt 4703 E:\FR\FM\24JYN1.SGM 24JYN1 OMA 1 OMA 4 OMA 5 OMA 1 OMA 1 OMA 20 OMA 5 OMA 18 OMA 19 OMA 1 OMA 20 OMA 16 OMA 24 OMA 4 OMA 5 OMA 21 OMA 4 OMA 5 OMA 14 OMA 13 OMA 23 OMA 15 OMA 24 OMA 10 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices 43385 TABLE 1—Continued Area of fire origin Area name Actions OMA Control at Panel C–10 Until Loss of Air, Operate Valve 2–MS– 190B to Transition from Main Steam Safety Valves. Open Breaker to Fail Valve 2–CH–517 Closed .......................... Open Breaker to Fail Valve 2–CH–519 Open to Establish Charging Flow Path. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. sroberts on DSK5SPTVN1PROD with NOTICES Fire Area R–17 ......... East Penetration Area ............................... The designation Z1 and Z2 are used throughout this exemption. The licensee stated that the 4.16 kV subsystems are divided into two specific ‘‘Facilities’’ and that Facility Z1 or Z1 Power begins with load center 24C which powers one train of Engineered Safety Features (ESFs) and is provided with an emergency power supply by the ‘‘A’’ Emergency Diesel Generator (EDG) while Facility Z2 begins with load center 24D and powers a redundant second train of ESF and is provided with an emergency power supply by the ‘‘B’’ EDG. The licensee also stated that vital power and control cables fall mainly into two redundancy classifications; Channel Z1 and Channel Z2 and that in a few cases there is also a Channel Z5, which is a system that can be transferred from one source to another. The licensee further stated that, Facility Z1 would be synonymous with ‘‘A’’ train while Facility Z2 would be synonymous with ‘‘B’’ train. The licensee stated that their exemption request is provided in accordance with the information contained in Regulatory Issue Summary (RIS) 2006–10, ‘‘Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions,’’ which states that an approved 10 CFR 50.12 exemption is required for all OMAs, even those accepted in a previously issued NRC SER. Dominion has requested an exemption from the requirements of III.G.2 for MPS2 to the extent that one of the redundant trains of systems necessary to achieve and maintain hot shutdown is not maintained free of fire damage in accordance with one of the required means, for a fire occurring in the following fire areas: R–2 West Penetration Area, Motor Control Center (MCC) B61, and the VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 Control at Panel C–10 Until Loss of Air, Operate Valve 2–MS– 190B to Transition from Main Steam Safety Valves. Open Valve 2–CH–508 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–509 to Obtain Charging Pump Suction from Boric Acid Storage Tank. Open Valve 2–CH–192 to Establish Charging Pump Suction from Refueling Water Storage Tank. Facility Z2 Upper 4.16kV Switchgear Room and Cable Vault; R–4 Charging Pump Cubicles; R–5 ‘‘A’’ Safeguards Room; R–6 ‘‘B’’ Safeguards Room; R–7 Diesel Generator Room ‘‘A’’; R–8 Diesel Generator Room ‘‘B’’; R–9 Facility Z1 DC Switchgear Room and Battery Room; R–10 Facility Z2 DC Switchgear Room and Battery Room; R–12 Turbine Driven Auxiliary Feedwater Pump Pit; R–13 West 480 VAC Switchgear Room; R–14 Facility Z1 Lower 4.16kV Switchgear Room and Cable Vault; R–15 Containment Building; R–17 East Penetration Area. The licensee stated that the OMAs are credited for the III.G.2 deficiencies, such as having only a single safe shutdown train, lack of separation between redundant trains, lack of detection and automatic suppression in the fire area or a combination of those deficiencies. The NRC staff notes that having only a single safe shutdown train is not uncommon to this plant design. Single train systems at MPS2 include Instrument Air (IA), ‘‘A’’ and ‘‘B’’ Boric Acid Storage Tank (BAST) Control Room (CR) level indication, Condensate Storage Tank (CST) CR level indication, suction-side flow to the Charging Pumps from the Refueling Water Storage Tank (RWST), auxiliary spray to the Pressurizer, and Charging Pump discharge to the Reactor Coolant System (RCS). The licensee also stated that they have evaluated/modified all motor operated valves (MOVs) relied upon by OMAs consistent with NRC Information Notice (IN) 92–18 (February 28, 1992) which detailed the potential for fires to damage MOVs that are required for safe shutdown so that they can no longer be remotely or manually operated and that as a result of this evaluation and PO 00000 Frm 00158 Fmt 4703 Sfmt 4703 OMA 11 OMA 6 OMA 7 OMA 1 OMA 11 OMA 4 OMA 5 OMA 1 modifications, the possibility that the desired result was not obtained is minimized. The licensee further stated that all the equipment operated to perform these OMAs are not fire affected and therefore are reasonably expected to operate as designed with one exception being in fire area R–4 concerning the performance of OMA 1 (see section 3.2.4.1.1) The licensee further stated that valve 2–CH–192 could be fire affected, however, it is an (air operated valve (AOV) that fails closed on loss of IA or power and is normally closed and that a fire event in this area will not cause this valve to be driven beyond its stops and that the valve will not be overtourqued. The licensee further stated that operating valve 2–CH–192 is not required until the BASTs are nearly depleted; a minimum of 72 minutes after charging is reestablished (which is not required until 180 minutes) and that a fire directly impacting valve 2–CH–429 would result in the valve failing in the desired open position. In their submittals, the licensee described elements of their FPP that provide their justification that the concept of defense-in-depth that is in place in the above fire areas is consistent with that intended by the regulation. To accomplish this, the licensee utilizes various protective measures to accomplish the concept of defense-in-depth. Specifically, the licensee stated that the purpose of their request was to credit the use of OMAs, in conjunction with other defense-indepth features, in lieu of the separation and protective measures required by III.G.2. Their approach is discussed below. 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. E:\FR\FM\24JYN1.SGM 24JYN1 sroberts on DSK5SPTVN1PROD with NOTICES 43386 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices Unless noted otherwise below, all of the fire areas included in this exemption have a combustible fuel load that is considered to be low, with fuel sources consisting primarily of fire retardant cable insulation and limited floor based combustibles. The licensee also stated that two of the fire areas (R–7/FHA Zone A–15 and R–8/FHA Zone A–16) have high combustible loading consisting of fuel oil and lube oil and that automatic pre-action fire suppression systems are provided in these areas. The licensee further stated that two other fire areas (R–17/FHA Zone A–10A and R–12/FHA Zone T–4) contain negligible combustible loading, with combustibles in these areas consisting of Class A combustibles and lube oil. There are no high energy ignition sources located in the areas except as noted in fire areas R– 2 and R–14. The fire areas included in the exemption request are not shop areas so hot work activities are infrequent with administrative control (e.g., hot work permits, fire watch, and supervisory controls) programs in place if hot work activities do occur. The administrative controls are described in the Millstone FPP, which is incorporated into the Updated Final Safety Analysis Report. The licensee stated that the storage of combustibles is administratively controlled by the site’s FPP procedures to limit the effects of transient fire exposures on the plant and in addition, hot work (i.e., welding, cutting, grinding) is also administratively controlled by site FPP procedure CM– AA–FPA–100. The licensee indicated that their FPP uses the concept of defense-in-depth, both procedurally and physically, to meet the following objectives: 1. Prevent fires from starting; 2. Rapidly detect, control, and extinguish promptly, those fires that do occur; and, 3. Provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant. The licensee also stated that the integration of the program, personnel, and procedures, which are then collectively applied to the facility, reinforce the defense in-depth aspect of the FPP and that strict enforcement of ignition source and transient combustible control activities (through permitting), and monthly fire prevention inspections by the site Fire Marshal ensure that this work is actively monitored to prevent fires. The MPS Fire Brigade consists of a minimum of a Shift Leader and four Fire Brigade personnel. The affected unit (MPS2 or MPS3) supplies an advisor, VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 who is a qualified Plant Equipment Operator (PEO). The advisor provides direction and support concerning plant operations and priorities. Members of the Fire Brigade are trained in accordance with MPS, Station Procedure TQ–1, Personnel Qualification and Training. Fire Brigade personnel are responsible for responding to all fires, fire alarms, and fire drills and to ensure availability, a minimum of a Shift Leader and four Fire Brigade personnel remain in the Owner Controlled Area and do not engage in any activity which would require a relief in order to respond to a fire. The licensee further stated that the responding Fire Brigade lead may request the Shift Manager (SM) augment the on-shift five member Fire Brigade with outside resources from the Town of Waterford Fire Department which has a letter of agreement with MPS, to respond to the site (when requested) in the event of a fire emergency or rescue and will attempt to control the situation with available resources. MPS2 has been divided into fire areas, as described in the MPS FPP. Threehour fire barriers are normally used to provide fire resistive separation between adjacent fire areas. In some cases, barriers with a fire resistance rating of less than three hours are credited but exemptions have been approved or engineering evaluations performed in accordance with Generic Letter 86–10 to demonstrate that the barriers are sufficient for the hazard. Walls separating rooms within fire areas are typically constructed of heavy concrete. The licensee stated that in general, fire rated assemblies separating Appendix R fire areas meet Underwriters Laboratories/Factory Mutual (UL/FM) design criteria and the requirements of American Society of Testing Materials (ASTM) E–119, ‘‘Fire Test of Building Construction and Materials’’ for 3-hour rated fire assemblies. The licensee also stated that openings created in fire rated assemblies are sealed utilizing penetration seal details that have been tested in accordance with ASTM E–119 and are qualified for a 3-hour fire rating, in addition, fireproof coating of structural steel conforms to UL–Listed recognized details and is qualified for a 3-hour fire rating. The licensee further stated that fire dampers are UL–Listed and have been installed in accordance with the requirements of National Fire Protection Association (NFPA) 90A, ‘‘Standard for the Installation of Air Conditioning and Ventilation Systems,’’ and that the code of record for fire dampers is either the version in effect at the time of original plant construction PO 00000 Frm 00159 Fmt 4703 Sfmt 4703 (late 1960s) or the 1985 edition. The licensee further stated that fire doors are UL–Listed and have been installed in accordance with NFPA 80, ‘‘Standard for Fire Doors and Windows’’ in effect at the time of plant construction (late 1960s). The licensee provided a discussion of the impacts of any Generic Letter (GL) 86–10 evaluations and/or exemptions on the fire areas included in this exemption request. For all the areas with GL 86–10 evaluations and/or other exemptions, the licensee stated that none of the issues addressed by the evaluations would adversely impact, through the spread of fire or products of combustion, plant areas where OMAs are performed or the respective travel paths necessary to reach these areas. The licensee also stated that there are no adverse impacts on the ability to perform OMAs and that the conclusions of the GL 86–10 evaluations and the exemption requests would remain valid with the OMAs in place. In addition to these boundaries, the licensee provided a hazard analysis that described how detection, control, and extinguishment of fires are addressed for each of the fire areas for which the OMAs may be needed. Unless noted otherwise below, fire areas are provided with ionization smoke detectors. The licensee stated that the smoke and heat detection systems were designed and installed using the guidance of the requirements set forth in several NFPA standards including the 1967, 1979, and 1986 Editions of NFPA 72D, ‘‘Standard for the Installation, Maintenance and Use of Proprietary Protective Signaling Systems for Watchman, Fire Alarm and Supervisory Service,’’ and the 1978 and 1984 Editions of NFPA 72E, ‘‘Standard on Automatic Fire Detectors.’’ Upon detecting smoke or fire, the detectors initiate an alarm in the CR enabling Fire Brigade response. The licensee stated that in most cases, no automatic fire suppression systems are provided in the areas included in this exemption request except for plant areas with significant quantities of combustibles, such as lube oil. Automatic fire suppression systems have also been installed in areas with one-hour barrier walls and one-hour rated electrical raceway encapsulation. The licensee stated that fire suppression systems were designed in general compliance with, and to meet the intent of the requirements of several NFPA standards depending on the type of system including the 1985 Edition of NFPA 13, ‘‘Standard for the Installation of Sprinkler Systems,’’ the 1985 Edition of NFPA 15, ‘‘Standard for Water Spray E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices Fixed Systems For Fire Protection,’’ and the 1987 Edition of NFPA 12A, ‘‘Standard on Halon 1301 Fire Extinguishing Systems.’’ The licensee stated that in general, fire extinguishers and hose stations have been installed in accordance with the requirements of the 1968 Edition of NPFA 10, ‘‘Standard for the Installation of Portable Fire Extinguishers’’ and the 1978 Edition of NFPA 14, ‘‘Standard for the Installation of Standpipe and Hose Systems,’’ respectively. The licensee stated that Equipment Operators are trained Fire Brigade members and would likely identify and manually suppress or extinguish a fire using the portable fire extinguishers and manual hose stations located either in or adjacent to, or both, these fire areas. Each of the fire areas included in this exemption is analyzed below with regard to how the concept of defense-indepth is achieved for each area and the role of the OMAs in the overall level of safety provided for each area. 3.1 Fire Area R–2, West Cable Vault, Upper 6.9 and 4.16kV Switchgear Rooms, 480V MCC B61 and B41A Enclosure, West Piping Penetration Area, West Electrical Penetration Area 3.1.1 Fire Prevention The licensee stated that the West Cable Vault, the Upper 6.9 and 4.16 kV Switchgear Room, the 480V MCC B61 and B41A Enclosure, and the West Piping Penetration Area have low combustible loading that predominantly consists of cable insulation and that potential ignition sources for these areas includes electrical faults. The licensee stated that the West Electrical Penetration Area has low to moderate combustible loading that includes small amounts of plastics and cellulosic materials and that potential ignition sources include electrical faults. sroberts on DSK5SPTVN1PROD with NOTICES 3.1.2 Detection, Control and Extinguishment The licensee stated that the West Cable Vault is provided with an automatic wet-pipe sprinkler system designed to protect structural steel in this area from the adverse affects of a fire, and also protected by an ionization smoke detection system that alarms at the main fire alarm panel in the CR. In addition, the licensee stated that the vertical cable chase that leads down the Auxiliary Building (AB) cable vault is protected by an automatic deluge spray system which is actuated by a crosszoned smoke detection system that alarms at a local panel and at the main fire alarm panel in the CR. The licensee VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 also stated that a fire in the West Cable Vault that could potentially impact a cable of concern would likely involve cable insulation and result from an electrical fault and that combustibles in this area consist predominantly of Institute of Electrical and Electronics Engineers (IEEE) 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics (not self-igniting or capable of propagating flame after pilot ignition source is removed). The licensee also stated that were a cable fire to occur in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade and that in the unlikely event the fire advanced beyond its incipient stage, it would actuate the installed automatic wet-pipe suppression system which consists of sprinklers located in each beam pocket and provides reasonable assurance that a cable tray fire in this area will be controlled and confined to the immediate area of origin, and will limit fire exposure/damage. The licensee stated that the Upper 6.9 and 4.16kV Switchgear Room has ionization smoke detection located directly over each switchgear cabinet that alarms at the main fire alarm panel in the CR. The licensee further stated that a fire in the Upper 6.9 and 4.16 kV Switchgear Room that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or failure of Bus 25B, which is located several feet away from the subject cable tray and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that in the unlikely event of a fire, it would be rapidly detected by the ionization smoke detection system installed in the area and that the smoke detection system, which consists of an ionization smoke detector located directly over each switchgear cabinet in the area, will aid in providing prompt Fire Brigade response. The licensee stated that the 480V MCC B61 and B41A enclosures are provided with ionization smoke detection that alarms at a local panel and at the main fire alarm panel in the CR. The licensee also stated that the steel enclosure of the MCC room is protected by a wet pipe water spray system in lieu of a three hour fire barrier. The licensee further stated that a fire in the 480 V MCC B61 and B41A enclosures that could potentially impact any cables of concern would likely PO 00000 Frm 00160 Fmt 4703 Sfmt 4703 43387 involve cable insulation resulting from an electrical fault or failure of one of the MCC’s located in the room and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that a failure of MCC B– 41B could also serve as an ignition source and that an MCC failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables despite the fact that the subject cable trays are located approximately 6–8’ above the MCC. The smoke detection system, which consists of an ionization smoke detector located directly over MCC B61, will aid in providing prompt Fire Brigade response. The licensee stated that the West Piping Penetration Area is provided with an ionization smoke detection system, which alarms at a local panel and at the main fire alarm panel in the CR. The licensee further stated that a fire in the West Piping Penetration area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring, outside of a switchgear failure, which could act as a pilot ignition source for the cable insulation and that a switchgear failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. The licensee stated that the West Electrical Penetration Area is provided with an ionization smoke detection system, which alarms at the main fire alarm panel in the CR. The licensee further stated that a fire in the West Electrical Penetration Area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire E:\FR\FM\24JYN1.SGM 24JYN1 43388 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices sroberts on DSK5SPTVN1PROD with NOTICES resistive characteristics. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. 3.1.3 Preservation and Safe Shutdown Capability The licensee stated that the OMAs associated with a fire in the West Cable Vault are related to failure of the feed to the 480V load center bus 22F or the ‘‘B’’ EDGs control and power cables and that loss of bus 22F results in the loss of the ‘‘B’’ battery charger and the eventual depletion of the ‘‘B’’ battery which in turn results in the loss of level transmitter LT–5282. The licensee stated that the cables of concern in the Upper 4.16 kV Switchgear Room are for valves 2–CH– 429 and 2–CH–517, level transmitters LT–5282, LT–206 and LT–208 and breaker A305. The licensee also stated that the cabling of concern is part of the breaker control logic and coordination between buses 24C, 24D and 24E and that components 2–CH–429, 2–CH- 517, LT–5282, LT–206, and LT–208 are single train components. The licensee further stated that the worst case tray arrangement is the common tray for components 2–CH–429, 2–CH–517, LT– 206, LT–208 and LT–5282. The licensee further stated that there is a moderate likelihood that a fire can occur which will impact components 2–CH–429, 2– CH–517, LT–206, LT–208 or LT–5282. The licensee stated that cables of concern in the 480 V MCC B61 and B41A enclosures are the power, indication and control cables for valves 2–CS–13.1B and 2–CH–429. The licensee stated that valve 2–CH– 429 is located in the north and west side of the West Piping Penetration Room, near the containment building wall and that the power and indication cabling for this valve is routed via conduit into a cable tray located along the west wall of the room. The licensee also stated that there is likely no fire that can occur which will impact valve 2–CH–429 due to configuration, combustible loading and ignition sources, however, if there was an impact, the nature of the cables would fail the valve in the desired open position. The licensee stated that the cables of concern in the West Electrical Penetration Area service valves 2–CH– 429 and 2–CH–517, and level transmitters LT–206, LT–208 and LT– 5282. The licensee also stated that it is very unlikely that a fire can occur which will impact valves 2–CH–429 or 2–CH– 517 due to configuration, combustible VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 loading, and ignition sources and that analysis indicates there is a low likelihood that a fire will impact LT– 206, LT–208 and LT–5282. The licensee stated that a fire in the West Penetration Area, MCC B61, and the Facility Z2 Upper 4.16 kV Switchgear Room and Cable Vault will affect all Facility Z2 shutdown components, that Facility Z1 is used to achieve and maintain Hot Standby, and that an Abnormal Operating Procedure (AOP) is used to achieve plant shutdown to Hot Standby. The licensee also stated that for a fire in fire area R– 2, OMAs are required to provide for Decay Heat Removal and to restore Charging system flow to the RCS. minutes, since the OMA is conducted after AFW flow and before charging system flow is established, there is no minimum required completion time. 3.1.4 Area 3.1.4.2 3.1.4.1 Flow OMAs Credited for a Fire in This Auxiliary Feedwater (AFW) 3.1.4.1.1 OMA 12—Pull Control Power Fuses and Ensure Breaker A305 Is Open The licensee stated that in order to establish AFW flow, Bus 24C is credited to provide power from H7A (‘‘A’’ EDG) to P9A (‘‘A’’ Motor Drive Auxiliary Feedwater Pump (MDAFW)) and that calculations conclude that AFW flow must be established within 45 minutes. The licensee also stated that cable damage may result in a loss of remote breaker control capability for A305, which is the Bus 24C to Bus 24E crosstie breaker and that at A305 (Bus 24C), the OMA is to de-energize the breaker control circuit by pulling control power fuses and ensuring that the breaker is open which prevents spurious closure of A305. The licensee further stated that this step establishes AFW flow and provides for a 36 minute time margin on the 45 minute time requirement and that after AFW flow is established, the atmospheric dump valves (ADVs) are utilized to remove decay heat. The licensee further stated that prior to this, RCS decay heat removal is provided by utilizing the Main Steam Safety Valves (MSSVs) and that steaming through the MSSVs is also acceptable after AFW flow is established but utilizing the ADVs, with 2–MS–190A credited for the fire in fire area R–2, is required for initiating the transition to Cold Shutdown. 3.1.4.1.2 OMA 10—Operate Valve 2– MS–190A To Transition From MSSVs The licensee stated that valve 2–MS– 190A fails due to a postulated loss of IA and its cables are not impacted by fire. The licensee also stated that PEO–2, will remain with the ADV to modulate steam flow per direction from the CR. Although this OMA is completed in 10 PO 00000 Frm 00161 Fmt 4703 Sfmt 4703 3.1.4.1.3 OMA 20—Obtain Condensate Storage Tank Level at Local Level Indicating Switch LIS–5489A The licensee stated that the remaining decay heat removal function is to locally monitor CST level (LIS–5489) which is not a short-term requirement because there is sufficient inventory in the CST to provide over 10 hours of water flow to the AFW system. The licensee further stated that this activity will likely be repeated several times over the course of placing the plant in Cold Shutdown. Charging System Flow 3.1.4.2.1 OMAs 2 and 6—Open Valve 2–CH–429 To Establish Charging Pump Flow Path and Open Breaker to Fail Valve 2–CH–517 Closed The licensee stated that the Charging System has several OMAs to reestablish flow within the three hour required timeframe and that to initially restore charging, valve 2–CH–429 is opened or verified open (OMA 2), and valve 2– CH–517 (OMA 6) is closed. The licensee stated that valve 2–CH–429 is a MOV located in the fire area and will be locally manually operated postfire and that it has been evaluated with respect to the guidance contained in NRC IN 92–18. The licensee stated that valve 2– CH–517 is an AOV that fails closed and is located in containment. The licensee further stated that the OMA is to deenergize the power supply (DV20) and fail the valve closed and that once 2– CH–429 is manually opened, Charging can be reestablished. The licensee further stated that assuming 60 minutes before being allowed into the fire affected area, the Charging flow path can be established within 64 minutes and Charging flow within 66 minutes which provides 114 minutes of margin on the 180 minute required time. 3.1.4.2.2 OMAs 18 and 19—Obtain BAST Level at Local Level Indicator LI– 206A and Obtain BAST Level at Local Level Indicator LI–208A The licensee stated that due to fire cable damage, both LT–206 and LT–208 are not available from the CR and that both BAST levels require OMAs for local level indication at LI–206A (OMA 18) and LI–208A (OMA 19). The licensee also stated that both indicators are outside the R–2 fire area and that the action is considered part of the restoration for the Charging system and as such, this action is not required until the three hour timeframe. E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices 3.1.4.2.3 OMAs 1 and 8—Open Valve 2–CH–192 and Open Valve 2–CS–13.1B provides adequate assurance that safe shutdown capability is maintained. The licensee stated that after Charging is restored, there are OMAs to switch the Charging suction path from the BASTs to the RWST which requires opening valves 2–CH–192 (OMA1) and 2–CS–13.1B (OMA 8). The licensee also stated that the 2–CH–192 valve is an AOV which may have failed closed due to a loss of IA and that it has a safetyrelated air accumulator which provides sufficient air to stroke open the valve and maintains it open for three hours and that after the air accumulator is exhausted, the valve will fail closed and an OMA is required to establish/ maintain RWST flow to the Charging system. The licensee stated that valve 2–CS– 13.1B is a MOV which may spuriously close due to fire cable damage and that it has to be manually opened in the field prior to switching over to the RWST. The licensee also stated that based on requirements in the technical requirements manual (TRM), the BASTs can supply Charging for more than 72 minutes, at which time the Charging pump suction source is shifted to the RWST. 3.2 Fire Area R–4, Charging Pump Room, Degasifier Area 3.1.4.3 OMA Timing The OMA to establish AFW flow can be completed in 9 minutes which provides a 36 minute margin since the required completion time is 45 minutes. The OMA to monitor CST level can be completed in 12 minutes and is a long term action as the CST provides over 10 hours of inventory to AFW. The OMAs to establish Charging system flow from the BASTs can be completed in 66 minutes which provides a 114 minute margin since the required completion time is 180 minutes. The OMAs to establish Charging system flow from the RWST prior to BAST depletion can be completed in 40 minutes which provides a 32 minute margin since the required completion time is 72 minutes. sroberts on DSK5SPTVN1PROD with NOTICES 3.1.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection and automatic fire suppression (West Cable Vault), it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safety shutdown equipment and be completed with more than 30 minutes of margin, VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 3.2.1 Fire Prevention The licensee stated that the Charging Pump Room has low combustible loading that includes small amounts of lube oil and that potential ignition sources include electrical faults, pump motors, mechanical failure, and hot surfaces. The licensee stated that the Degasifier Area has low combustible loading that predominantly consists of cable insulation and that potential ignition sources include electrical faults. 3.2.2 Detection, Control, and Extinguishment The licensee stated that the Charging Pump Room is provided with an ionization smoke detection system which alarms at a local panel and at the main fire alarm panel in the CR. A fixed water curtain is provided at the entrance to the Degasifier Area (FHA Fire Zone A–6B), which provides protection for the Charging Pump area from a fire in the Reactor Building Closed Cooling Water System (RBCCW) Pump and Heat Exchanger Area (FHA Fire Zone A–1 B). The licensee also stated that actuation of this system results in an alarm (waterflow) at the main fire alarm panel in the CR. The licensee further stated that a fire in the Charging Pump cubicles that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a lube oil fire resulting from a Charging Pump failure and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee also stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation and that each charging pump contains just over 10 gallons of lube oil which could also serve as a pilot ignition source for cable insulation in the event of a pump/motor failure with the resultant ignition of the lube oil. The licensee further stated that based on the elevated ignition temperature of the lube oil and the low probability of a pump/motor assembly failure with subsequent ignition of the entire quantity of lube oil, it is unlikely that a lube oil fire from a Charging Pump failure would serve as an ignition source for IEEE 383 qualified cable PO 00000 Frm 00162 Fmt 4703 Sfmt 4703 43389 insulation. The licensee further stated that curbs are installed between each Charging Pump to protect each pump from a combustible liquid spill within a neighboring Charging Pump cubicle. The licensee further stated that a fire would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. The licensee stated that the Degasifier Area is provided with an ionization smoke detection system which alarms at a local panel and at the main fire alarm panel in the CR and that a fixed water curtain is provided at the entrance to this area and serves to provide protection for the Charging Pump Room (FHA Zone A–6A) from a fire in the RBCCW Pump and Heat Exchanger Area (FHA Zone A–1 B). The licensee also stated that actuation of this system results in an alarm (waterflow) to the main fire panel in the CR. The licensee further stated that a fire in the Degasifier Area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. 3.2.3 Preservation of Safe Shutdown Capability The licensee stated that the cables of concern in the Charging Pump Room are for control and indication of valve 2– CH–192 and that analysis indicates there is a low likelihood that a fire can occur which will impact the valve. The licensee stated that the cables of concern for the Degasifier Area pass through the hallway leading into the area and are for control and indication of valve 2–CH–192 and that analysis indicates there is a very low likelihood that a fire can occur which will impact valve 2–CH–192. The licensee stated that a fire in the Charging Pump cubicles will affect the Charging Pumps and several suction valves and that the compliance strategy relies on re-routing of Facility Z2 control and power cables for P18B and E:\FR\FM\24JYN1.SGM 24JYN1 43390 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices Facility Z2 power cable for P18C from the pump cubicles to outside of fire area R–4. The licensee also stated that an exemption provides technical justification of survivability of at least one Charging Pump following a fire in this area, even though the requirements of III.G.2 are not met. The licensee further stated that survivability is justified based on existing physical spatial separation, partial height missile walls, curbing between pumps, and low intervening combustibles and that plant shutdown can be accomplished using an AOP. The licensee further stated that OMAs are required to provide for decay heat removal and to restore Charging system flow to the RCS. 3.2.4 Area sroberts on DSK5SPTVN1PROD with NOTICES 3.2.4.1 Flow OMAs Credited for a Fire in This AFW and Charging System 3.2.4.1.1 OMAs 1 and 11 Open Valve 2–CH–192 and Control Valve 2–MS– 190B at Panel C10 or Local Manual Operation The licensee stated that establishing AFW flow to the credited steam generator (SG) is required to be accomplished within 45 minutes and that the required flow path utilizes the turbine driven auxiliary feedwater (TDAFW) pump. The licensee also stated that prior to AFW initiation, the plant is placed in the Hot Standby condition by steaming through the MSSVs and that after AFW is established from the CR, operation of the ADV (2–MS–190B) (OMA 11) is the required method of removing decay heat to maintain Hot Standby and transition to Cold Shutdown. The licensee further stated that there is no cable damage from fire to the required ADV (2–MS– 190B), however, the fire may cause a loss of IA which is required to operate the ADVs to support decay heat removal. The licensee stated that upon a loss of air, the ADV will fail closed and that this design prevents excessive RCS cooldown prior to AFW start and, therefore, in the event of a loss of IA, Operators will establish local manual control of 2–MS–190B after AFW flow is established. The licensee further stated that PEO–2 will remain with the ADV to modulate steam flow per direction from the CR and that after restoration of the Charging system, the BASTs are credited for maintaining RCS inventory and that the BASTs have a minimum level specified in the TRM which ensures 72 minutes of flow. The licensee further stated that once the BASTs are depleted, Operators switch over to the RWST. The licensee further stated that due to fire damage, the 2– VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 CH–192 valve may spuriously close and that in order to establish the RWST as the suction path for the Charging system, an OMA is required to open valve 2–CH–192 (OMA 1) prior to BAST depletion. The licensee further stated that OMA 1 is performed in the fire affected area and is performed after the fire is extinguished and after the Station Emergency Response Organization (SERO) is fully staffed. OMA 1 establishes the RWST as the suction supply for the charging system and is not conducted until after AFW is established which takes 17 minutes. The BASTs have a minimum TRM specified inventory to ensure 72 minutes of flow and OMA 1 can be completed in 32 minutes which results in 40 minutes of margin. 3.2.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.2.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection and water curtain, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.3 Fire Area R–5, ‘‘A’’ Safeguards Room (Containment Spray and High Pressure Safety Injection/Low Pressure Safety Injection Pump Room) 3.3.1 Fire Prevention The licensee stated that the area has low combustible loading that includes cable insulation and small amounts of lube oil and that potential ignition sources include electrical faults, pump motors, mechanical failure, and hot surfaces. 3.3.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with an ionization smoke PO 00000 Frm 00163 Fmt 4703 Sfmt 4703 detection system which alarms at a local panel and at the main fire alarm panel in the CR. The licensee also stated that a fire in this area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a lube oil fire resulting from a pump and/or motor failure. Combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this fire area, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation and that while lube oil could also serve as a pilot ignition source for cable insulation, the small quantities of lube oil would result in a low intensity fire and based on the elevated ignition temperature of the lube oil and the low probability of a pump and/or motor assembly failure with subsequent ignition of the entire quantity of lube oil, it is unlikely that a lube oil fire from a pump and/or motor failure would serve as an ignition source for IEEE 383 qualified cable insulation. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. 3.3.3 Preservation of Safe Shutdown Capability The licensee stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a lube oil fire resulting from a pump and/or motor failure and that some Shutdown Cooling system components would be affected and that plant shutdown to Hot Standby can be accomplished using existing AOPs. 3.3.4 Area OMAs Credited for a Fire in This 3.3.4.1 Flow AFW and Charging System 3.3.4.1.1 OMAs 1 and 10—Open Valve 2–CH–192 and Operate Valve 2–MS– 190A The licensee stated that for a fire in fire area R–5, two OMAs are identified to provide for decay heat removal and restore charging system flow to the RCS, with the first OMA (OMA 10) being to open and modulate 2–MS–190A (ADV) and the second OMA (OMA 1) being to open valve 2–CH–192. The licensee also stated that both OMAs are needed to compensate for a postulated loss of IA E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices and that neither valve will experience cable damage due to a fire in fire area R–5. The licensee further stated that the ADVs are utilized after AFW flow is established and that AFW is required to be established within 45 minutes and prior to this, RCS decay heat removal is provided by utilizing the MSSVs. The licensee further stated that steaming through the MSSVs is also acceptable after AFW flow is established, but utilizing the ADVs, with 2–MS–190A credited for a fire in fire area R–5, is required for maintaining the plant in Hot Standby and initiating the transition to Cold Shutdown. The licensee further stated that PEO–2 will remain with the ADV to modulate steam flow per direction from the CR and that PEO–1 will complete the second OMA by opening 2–CH–192 to establish the RWST as the source of water to the RCS. The licensee further stated that 2–CH– 192 is an AOV which may have failed closed due to a loss of IA and that the valve has a safety-related air accumulator which supplies sufficient air to stroke open the valve and maintain it open for three hours and that after the air accumulator is exhausted, the valve will fail closed. The licensee further stated that the required OMA establishes/maintains RWST flow to the Charging system and the BASTs have a minimum level specified in the TRM which ensures Charging flow for more than 72 minutes, at which time Charging pump suction is shifted to the RWST. The licensee further stated that calculations indicate that the Charging system must be restored within three hours, therefore, the accumulator capacity and the minimum TRM BAST level requirement require the OMA to locally open 2–CH– 192 be accomplished within three hours (prior to the air accumulator being exhausted). sroberts on DSK5SPTVN1PROD with NOTICES 3.3.4.2 OMA Timing AFW flow is established within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.3.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.4 Fire Area R–6, ‘‘B’’ Safeguards Room (Low Pressure Safety Injection Pump Room) 3.4.1 The licensee stated that the area has low combustible loading that includes cable insulation and small amounts of lube oil and that potential ignition sources include electrical faults, pump motors, mechanical failure, and hot surfaces. 3.4.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with an ionization smoke detection system which alarms at a local panel and at the main fire alarm panel in the CR. The licensee also stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a lube oil fire resulting from a pump and/or motor failure and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this fire area, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation and that while lube oil could also serve as a pilot ignition source for cable insulation, the small quantities of lube oil would result in a low intensity fire and based on the elevated ignition temperature of the lube oil and the low probability of a pump and/or motor assembly failure with subsequent ignition of the entire quantity of lube oil, it is unlikely that a lube oil fire from a pump and/or motor failure would serve as an ignition source for IEEE 383 qualified cable insulation. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. PO 00000 Frm 00164 Fmt 4703 Sfmt 4703 3.4.3 Preservation of Safe Shutdown Capability The licensee stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a lube oil fire resulting from a pump and/or motor failure, that some Shutdown Cooling System components would be affected, that Hot Standby equipment will not be affected, and that plant shutdown to Hot Standby can be accomplished using an AOP. 3.4.4 Area Fire Prevention 43391 OMAs Credited for a Fire in This 3.4.4.1 Flow AFW and Charging System 3.4.4.1.1 OMAs 1 and 10—Open Valve 2–CH–192 and Operate Valve 2–MS– 190A The licensee stated that for a fire in fire area R–6, two OMAs are identified, the first OMA (OMA 10) which is to open 2–MS–190A (ADV) and the second OMA (OMA 1) which is to open 2–CH– 192. The licensee also stated that both OMAs are needed to compensate for a postulated loss of IA and that neither valve will experience cable damage due to a fire in fire area R–6. The licensee further stated that the ADVs are utilized after AFW flow is established, that AFW is not fire impacted, is required to be established within 45 minutes, and that prior to this, RCS decay heat removal is provided by steaming through the MSSVs which is also acceptable after AFW flow is established. Utilizing the ADVs, with 2–MS–190A credited for a fire in fire area R–6, is required for maintaining the plant in Hot Standby and initiating the transition to Cold Shutdown. The licensee further stated that PEO–2 will remain with the ADV to modulate steam flow per direction from the CR and that PEO–1 will complete the second OMA by opening 2–CH–192 to establish the RWST as the source of water to the RCS and that 2– CH–192 is an air operated valve which may have failed closed due to a loss of IA. The licensee further stated that the valve has a safety-related air accumulator which supplies sufficient air to stroke open the valve and maintain it open for three hours and that after the air accumulator is exhausted, the valve will fail closed. The licensee further stated that the required OMA establishes/maintains RWST flow to the charging system and that the BASTs have a minimum level specified in the TRM which ensures charging flow for more than 72 minutes, at which time charging pump suction is shifted to the RWST and that E:\FR\FM\24JYN1.SGM 24JYN1 43392 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices calculations indicate that the Charging system must be restored within three hours, and therefore, the accumulator and the minimum TRM BAST level requirement require the OMA to locally open 2–CH–192 be accomplished within three hours (prior to the accumulator being exhausted). 3.4.4.2 OMA Timing AFW flow is established within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.4.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.5 Fire Area R–7, ‘‘A’’ Diesel Generator Room sroberts on DSK5SPTVN1PROD with NOTICES 3.5.1 Fire Prevention The licensee stated that the area has high combustible loading that includes diesel fuel and small amounts of lube oil and that potential ignition sources include motors, mechanical failure, and hot surfaces. 3.5.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with automatic pre-action sprinkler protection to provide automatic suppression in/around the diesel generator as well as to provide cooling to the structural steel overhead and that the deluge valve for this system is opened by the installed heat detection system. The licensee also stated that the detection system alarms at the main fire alarm panel in the CR while the preaction sprinkler system alarms at a local panel and at the main fire alarm panel in the CR. The licensee stated that a fire in the area that could potentially impact any cables of concern would likely involve VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 diesel fuel oil and/or lube oil resulting from a mechanical failure of the diesel generator or cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee also stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire involving Class A combustibles occurring which could act as a pilot ignition source for the cable insulation and that while a fuel oil or lube oil fire could serve as a pilot ignition source to the cabling, it is expected that a fire involving Class B combustibles (flammable/combustible liquids) would be rapidly detected by the installed heat detection system and be suppressed by the installed suppression system and/or manual firefighting. The licensee further stated that the heat detection system would also aid in providing prompt Fire Brigade response were a fire to occur in this area. 3.5.3 Preservation of Safe Shutdown Capability The licensee stated that the components of concern for the area are valves 2–CH–192, 2–CH–508, and 2– CH–509 and that the loss of the EDG results in the loss of the Facility Z1 emergency power supply which results in the loss of power to the battery charger supplying the battery for valve 2–CH–192. The licensee also stated that the loss of the Facility Z1 emergency power causes the loss of power to valves 2–CH–508 and 2–CH–509 and that a fire could also cause the failure of IA which would impact valves 2–CH–192 and 2– MS–190B. The licensee stated that a fire in the area will affect all Facility Z1 shutdown components, that Facility Z2 is used to achieve and maintain Hot Standby, and that plant shutdown to Hot Standby can be accomplished using an AOP. 3.5.4 Area 3.5.4.1 Flow OMAs Credited for a Fire in This AFW and Charging System 3.5.4.1.1 OMA 11—Control Valve 2– MS–190B at Panel C10 or Local Manual Operation The licensee stated that for a fire in the area, OMAs are required to provide decay heat removal and restore Charging system flow to the RCS, that AFW flow must be established to the credited SG within 45 minutes, and that the required AFW flow path utilizes the TDAFW pump which is not fire impacted. The PO 00000 Frm 00165 Fmt 4703 Sfmt 4703 licensee also stated that once AFW flow is established from the CR, operation of an ADV (2–MS–190B) (OMA 11) is the method of removing decay heat to maintain the plant in Hot Standby and for initiating the transition to Cold Shutdown and that prior to AFW initiation, the plant is placed in the Hot Standby condition by steaming through the MSSVs. The licensee further stated that there is no cable damage from a fire in the area to the required ADV (2–MS– 190B), however, the fire may cause a loss of IA which is required to operate the ADVs to support decay heat removal. The licensee further stated that upon a loss of IA, the ADV will fail closed and this ‘‘fail to closed’’ design prevents excessive RCS cooldown prior to AFW start, and therefore, in the event of a loss of IA, Operators will establish local manual control of 2–MS–190B after AFW is established and that PEO– 1 will remain with the ADV to modulate steam flow per direction from the CR. 3.5.4.1.2 OMAs 4, 5, and 1—Open Valve 2–CH–508, Open Valve 2–CH– 509, and Open Valve 2–CH–192 The licensee stated that for a fire in the area the Charging system has OMAs identified and that the BASTs gravity feed valves, 2–CH–508 (OMA 4) and 2– CH–509 (OMA 5), may fail as is (closed) due to a loss of power supply. The licensee also stated that an OMA is in place to locally open the valves as part of restoring the Charging system and that once these valves are opened, the CR can establish charging flow within 2–3 minutes. The licensee further stated that establishing pump suction from the BASTs and restoring charging is required within three hours of reactor shutdown/loss of charging and charging is re-established within 24 minutes (21 minutes to open BASTs valves and 3 minutes to establish charging flow in the CR) which provides a 156 minute margin. The licensee further stated that after the BASTs have reached the 10 percent level, Operators switch the charging suction flow path to the RWST and the 2–CH–192 (OMA 1) valve is required to be open to accomplish the switch over. The licensee further stated that evaluations conclude that the BASTs will last a minimum of 72 minutes after charging is re-established. The licensee stated that valve 2–CH–192 fails closed in the event of a loss of its power supply and/or IA, but valve 2– CH–192 will remain operable using its backup air source until it and/or the Facility Z1 battery is depleted and that the backup air source is capable of opening the valve and maintaining it open for three hours. The licensee further stated that battery depletion will E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices not occur prior to exhausting the backup air source and that the OMA is not required prior to this time. 3.5.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to establish Charging system flow from the BASTs can be completed in 24 minutes which provides a 156 minute margin since the required completion time is 180 minutes. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.5.5 Conclusion Although a fuel oil or lube oil fire could serve as a pilot ignition source to cabling, it is expected that such a fire would be detected by the installed heat detection and controlled by the suppression system with additional suppression provided by manual firefighting, therefore, it is unlikely that a fire would occur and go undetected or unsuppressed and damage safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.6 Fire Area R–8, ‘‘B’’ Diesel Generator Room sroberts on DSK5SPTVN1PROD with NOTICES 3.6.1 Fire Prevention The licensee stated that the area has high combustible loading that includes diesel fuel oil, small amounts of lube oil, and negligible amounts of cable insulation and that potential ignition sources include electrical faults, motors, mechanical failure and hot surfaces. 3.6.2 Detection, Control, and Extinguishment The licensee stated that this area is provided with automatic pre-action sprinkler protection to provide automatic suppression in/around the diesel generator as well as to provide cooling to the structural steel overhead and that the deluge valve for this system is opened by the installed heat detection system. The licensee also stated that the detection system alarms at the main fire alarm panel in the CR while the preaction sprinkler system alarms at a local VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 panel and at the main fire alarm panel in the CR. The licensee stated that a fire in the area that could potentially impact any cables of concern would likely involve diesel fuel oil and/or lube oil resulting from a mechanical failure of the diesel generator or cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee also stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire involving Class A combustibles occurring which could act as a pilot ignition source for the cable insulation and that while a fuel oil or lube oil fire could serve as a pilot ignition source to the cabling, it is expected that a fire involving Class B flammable/ combustible liquids would be rapidly detected by the installed heat detection system and be suppressed by the installed suppression system and/or manual firefighting. The licensee further stated that the heat detection system would also aid in providing prompt Fire Brigade response were a fire to occur in this area. 3.6.3 Preservation of Safe Shutdown Capability The licensee stated that the OMAs associated with a fire in the area are related to failure of the ‘‘B’’ EDG resulting in the loss of power to breakers 24D, 22F and MCC B61, and the battery charger resulting in the depletion of the ‘‘B’’ battery and that a fire in this area could also cause the failure of IA. The licensee stated that a fire in the area will affect all Facility Z2 shutdown components, that Facility Z1 is used to achieve and maintain Hot Standby, and that plant shutdown to Hot Standby can be accomplished by using an AOP. 3.6.4 Area 3.6.4.1 Flow OMAs Credited for a Fire in This AFW and Charging System 3.6.4.1.1 OMAs 10 and 1—Operate Valve 2–MS–190A and Open Valve 2– CH–192 The licensee stated that for a fire in the area, two OMAs are identified, the first OMA (OMA 10) is to open 2–MS– 190A (ADV) and the second OMA (OMA 1) is to open 2–CH–192. The licensee also stated that both OMAs are required to compensate for a postulated loss of IA and that neither valve will experience cable damage due to a fire in the area. The licensee further stated that the ADVs are utilized after AFW flow is PO 00000 Frm 00166 Fmt 4703 Sfmt 4703 43393 established, that AFW is not fire impacted, is required to be established within 45 minutes and that prior to this, RCS decay heat removal is provided by steaming through the MSSVs which is also acceptable after AFW flow is established. The licensee further stated that utilizing the ADVs, with 2–MS– 190A credited for the fire in the area, is required for maintaining the plant in Hot Standby and initiating the transition to Cold Shutdown, that PEO–1 will remain with the ADV to modulate steam flow per direction from the CR and that PEO–2 will complete the second OMA by opening 2–CH–192 to establish the RWST as the source of water to the RCS. The licensee further stated that 2–CH– 192 is an AOV which may have failed closed due to a loss of IA, that the valve has a safety-related air accumulator which supplies sufficient air to stroke open the valve and maintain it open for three hours and that after the air accumulator is exhausted, the valve will fail closed. The licensee further stated that the required OMA establishes/ maintains RWST flow to the Charging system and the BASTs have a minimum level specified in the TRM which ensures Charging flow for more than 72 minutes, at which time Charging Pump suction is shifted to the RWST. The licensee further stated that calculations indicate that the Charging system is to be restored within three hours, therefore, the accumulator and the minimum TRM BAST level requirement require the OMA to locally open 2–CH– 192 within three hours (prior to the accumulator being exhausted). 3.6.4.1.2 OMA 20—Obtain CST Level at Local Level Indicating Switch LIS– 5489A In their letter dated February 29, 2012 the licensee added OMA 20 to the exemption request for fire area R–8. The licensee stated that a fire in the area could cause a loss of the ‘‘B’’ EDG resulting in the depletion of the ‘‘B’’ battery after 480 minutes causing a loss of level transmitter LT–5282 (CST Level) which will necessitate obtaining level readings locally at the tank using level indicator LIS–5489 (OMA 20). The licensee also stated that the route to the CST is illuminated by emergency lighting units (ELUs), that checking the level of the CST supports AFW system operation and checking the level is not a short-term requirement as there is sufficient inventory in the CST to provide over 10 hours of water flow to the AFW system. The licensee further stated that if necessary, after the CST is depleted, Operators can switch over to the fire water system and maintain flow to the AFW system. E:\FR\FM\24JYN1.SGM 24JYN1 43394 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices 3.6.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to check CST level can be completed in 6 minutes and is a long term action as the CST provides over 10 hours of inventory to AFW. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.6.5 Conclusion Although a fuel oil or lube oil fire could serve as a pilot ignition source to cabling, it is expected that such a fire would be detected and suppressed by the installed heat detection and suppression system with additional suppression provided by manual firefighting, therefore, it is unlikely that a fire would occur and go undetected or unsuppressed and damage safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.7 Fire Area R–9, ‘‘A’’ East DC Equipment Room sroberts on DSK5SPTVN1PROD with NOTICES 3.7.1 Fire Prevention The licensee stated that the area has low combustible loading that predominantly consists of cable insulation and that potential ignition sources include electrical faults. 3.7.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with a cross-zoned ionization and photoelectric smoke detection system that activates a total flooding Halon 1301 fire suppression system and that the Halon 1301 suppression system has manual release stations at each doorway and an abort switch located at the doorway to the east CR/cable vault stairway. The licensee also stated that this system alarms locally at the Halon control panel and at the main fire alarm panel in the CR. The licensee further stated that duct smoke detection is provided between this area, the ‘‘B’’ (West) DC Equipment Room (FHA Zone A–21), and the auxiliary building cable vault (FHA Zone A–24) and that this VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 system alarms at a local panel and at the main fire alarm panel in the CR. The licensee further stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or failure of a bus or electrical panel located in the room and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring, outside of a bus/electrical panel failure, which could act as a pilot ignition source for the cable insulation and that a bus/electrical panel failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables. The licensee further stated that in the unlikely event of a fire in this area, it would be rapidly detected by the cross-zoned ionization and photoelectric smoke detection system and subsequently extinguished by the total flooding Halon 1301 suppression system and that the smoke detection system would also aid in providing prompt Fire Brigade response. 3.7.3 Preservation of Safe Shutdown Capability The licensee stated that the OMAs associated with a fire in the area are related to loss of power to the ‘‘A’’ DC buses (such as DV10) and that cables for valves 2–CH–192, 2–CH–508, and 2– CH–509 do not pass through this room. The licensee stated that a fire in the area will affect all Facility Z1 shutdown components, that Facility Z2 is used to achieve and maintain Hot Standby, and that plant shutdown to Hot Standby can be accomplished using an AOP. 3.7.4 OMAs Credited for a Fire in This Area In their letter dated February 29, 2012 the licensee deleted OMAs 1 and 11 from the exemption request for fire area R–9 since loss of IA is no longer postulated. 3.7.4.1 Flow AFW and Charging System 3.7.4.1.1 OMAs 4 and 5.—Open Valve 2–CH–508 and Open Valve 2–CH–509 The licensee stated that for a fire in fire area R–9, the Charging system has OMAs identified and that the BASTs gravity feed valves, 2–CH–508 (OMA 4) and 2–CH–509 (OMA 5), may fail as is (closed) due to a loss of power supply. The licensee also stated that an OMA is PO 00000 Frm 00167 Fmt 4703 Sfmt 4703 in place to locally open the valves as part of restoring the Charging system and that once these valves are opened, the CR can establish charging flow within 2–3 minutes. The licensee further stated that establishing charging pump suction from the BASTs and restoring charging is required within three hours of reactor shutdown/loss of charging and that Charging is reestablished within 24 minutes (21 minutes to open the BASTs valves and 3 minutes to establish charging flow in the CR) which provides a 156 minute margin. 3.7.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period. The OMA to establish Charging system flow from the BASTs can be completed in 24 minutes which provides a 156 minute margin since the required completion time is 180 minutes. 3.7.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection and suppression, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.8 Fire Area R–10, ‘‘B’’ West DC Equipment Room 3.8.1 Fire Prevention The licensee stated that the area has low combustible loading that predominantly consists of cable insulation and that potential ignition sources include electrical faults. 3.8.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with a cross-zoned ionization and photoelectric smoke detection system that activates a total flooding Halon 1301 fire suppression system and that the Halon 1301 suppression system has manual release stations at each doorway and an abort switch located at the doorway to the ‘‘A’’ (East) DC equipment room (FHA Zone A–20). The licensee also stated that this system alarms locally on the halon control panel and at the main fire alarm panel E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices in the CR. The licensee further stated that duct smoke detection is provided between this fire area, the ‘‘A’’ (East) DC Equipment Room (FHA Zone A–20), and the AB cable vault (FHA Zone A– 24) and that this system alarms at a local panel and at the main fire alarm panel in the CR. The licensee further stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or failure of a bus or electrical panel located in the room and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring, outside of a bus/electrical panel failure, which could act as a pilot ignition source for the cable insulation and that a bus/electrical panel failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables. The licensee further stated that in the unlikely event of a fire in this area, it would be rapidly detected by the cross-zoned ionization and photoelectric smoke detection smoke detection system and subsequently extinguished by the total flooding Halon 1301 suppression system installed in this area. The smoke detection system would also aid in providing prompt Fire Brigade response. 3.8.3 Preservation of Safe Shutdown Capability sroberts on DSK5SPTVN1PROD with NOTICES The licensee stated that the OMAs associated with a fire in the area are related to loss of power to the ‘‘B’’ AC vital power panels (such as VA20) and that cables for level transmitters LT– 206, LT–208 and LT–5282 do not pass through this room. The licensee stated that a fire in the area will affect all Facility Z2 shutdown components, that Facility Z1 is used to achieve and maintain Hot Standby, and that plant shutdown to Hot Standby can be accomplished using an AOP. 3.8.4 Area OMAs Credited for a Fire in This In their letter dated February 29, 2012 the licensee deleted OMA 1 and 10 from the exemption request for fire area R–10 since loss of IA is no longer postulated. VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 3.8.4.1 Flow AFW and Charging System 3.8.4.1.1 OMA 20—Obtain CST Level at Local Level Indicating Switch LIS– 5489A The licensee stated that a fire in area may cause cable damage to level transmitter LT–5282 (CST Level) which will necessitate obtaining level readings locally at the tank using level indicator LIS–5489 (OMA 20). The licensee also stated that the route to the CST is illuminated by ELUs, that checking the level of the CST supports AFW system operation and checking the level is not a short-term requirement as there is sufficient inventory in the CST to provide over 10 hours of water flow to the AFW system. The licensee further stated that if necessary, after the CST is depleted, Operators can switch over to the fire water system and maintain flow to the AFW system. 3.8.4.1.2 OMAs 18 and 19—Obtain BAST Level at Local Level Indicator LI– 206A and Obtain BAST Level at Local Level Indicator LI–208A The licensee stated that for a fire in the area, the Charging system has OMAs identified and that fire damage to cables may render level transmitters LT–206 and LT–208 (BAST Level) inoperable from the CR which would necessitate BAST level indication being obtained locally via level indicators LI–206A (OMA 18) and LI–206B (OMA 19). The licensee also stated that the TRM requires a minimum level be maintained in the BASTs and that maintaining this level provides a minimum of 72 minutes of charging flow to the RCS after charging is re-established and that calculations indicate that charging must be restored within three hours of a reactor trip. 3.8.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period. The OMA to check CST level can be completed in 6 minutes and is a long term action as the CST provides over 10 hours of inventory to AFW. The OMAs to check BAST level can be completed in 12 minutes which provides a 168 minute margin since the required completion time is 180 minutes. 3.8.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection and suppression, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. PO 00000 Frm 00168 Fmt 4703 Sfmt 4703 43395 The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.9 Fire Area R–12, Steam Driven Auxiliary Feedwater Pump Pit 3.9.1 Fire Prevention The licensee stated that the area has low combustible loading that includes lube oil only, that there is no cable insulation or Class A combustibles located in the area, and that potential ignition sources include electrical faults or the over-heating of a pump bearing. 3.9.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with an ionization smoke detection system which alarms at a local panel and at the main fire alarm panel in the CR. The licensee stated that a fire in the TDAFW Pump Pit that could potentially impact any cables of concern would likely involve a lube oil fire resulting from an auxiliary feedwater pump failure and that lube oil found within the steam driven AFW pump is the only contributing factor to the combustible loading of this area. The licensee also stated that the lube oil is completely enclosed within the pump housing, which would help in preventing ignition of the oil from an external ignition source and that there are no external ignition sources for the lube oil in this room. The licensee further stated that restrictive access to this pump room limits the amount of transient combustibles and ignition sources in this room and in the event of a fire in this room, the low combustible loading would result in a low intensity fire which would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. 3.9.3 Preservation of Safe Shutdown Capability The licensee stated that a fire in the area will affect only the TDAFW pump and its steam supply components, that no other Hot Standby equipment will be affected and the MDAFW pumps may be used to feed the SGs. The licensee also stated that plant shutdown to Hot Standby can be accomplished using existing shutdown procedures. E:\FR\FM\24JYN1.SGM 24JYN1 43396 3.9.4 Area 3.9.4.1 Flow Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices OMAs Credited for a Fire in This AFW and Charging System 3.9.4.1.1 OMA 10—Operate Valve 2– MS–190A and Open Valve 2–CH–192 The licensee stated that for a fire in the area, two OMAs are identified, the first is to open 2–MS–190A (ADV) (OMA 10) and the second is to open 2– CH–192 (OMA 1). The licensee also stated that both OMAs are required to compensate for a postulated loss of IA, that neither valve will experience cable damage due to a fire in the area, and that the ADVs are utilized after AFW flow is established. The licensee further stated that AFW flow is required to be established within 45 minutes and that prior to this, RCS decay heat removal is provided by steaming through the MSSVs which is also acceptable after AFW flow is established. The licensee further stated that utilizing the ADVs, with 2–MS–190A credited for the fire in the area, is required for maintaining the plant in Hot Standby and the transition to Cold Shutdown, and that PEO–1 will remain with the ADV to modulate steam flow per direction from the CR. The licensee further stated that PEO–2 will complete the second OMA by opening 2–CH–192 to establish the RWST as the source of water to the RCS. The licensee stated that 2–CH–192 is an AOV which may have failed closed due to a loss of IA and that the valve has a safety-related air accumulator which supplies sufficient air to stroke open the valve and maintain it open for three hours. After the air accumulator is exhausted, the valve will fail closed. The licensee further stated that the required OMA establishes/maintains RWST flow to the Charging system and that the BASTs have a minimum level specified in the TRM which ensures Charging flow for more than 72 minutes, at which time Charging Pump suction is shifted to the RWST. The licensee further stated that calculations indicate that the Charging system must be restored within 3 hours, therefore, the accumulator capacity and the minimum TRM BAST level requirements require that this OMA be accomplished within three hours (prior to the accumulator being exhausted). sroberts on DSK5SPTVN1PROD with NOTICES 3.9.4.2 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.9.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.10 Fire Area R–13, West 480 V Load Center Room 3.10.1 Fire Prevention The licensee stated that the area has low combustible loading that predominantly consists of cable insulation and that potential ignition sources include electrical faults. 3.10.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with ionization smoke detection that alarms at the main fire alarm panel in the CR. The licensee also stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault or a bus failure and that combustibles in the area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring, outside of a bus failure, which could act as a pilot ignition source for the cable insulation. A bus failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables. The licensee further stated that in the unlikely event of a fire, it would be rapidly detected by the ionization smoke detection system installed in the area and that the smoke detection system will aid in providing prompt Fire Brigade response. 3.10.3 Preservation of Safe Shutdown Capability The licensee stated that the components of concern for the area are for valves 2–CH–192, 2–CH–508, 2–CH– PO 00000 Frm 00169 Fmt 4703 Sfmt 4703 509, 2–FW–43B and 2–MS–190B, breaker A406, H21 (TDAFW speed control circuit), level transmitter LT– 5282, P18C (‘‘C’’ charging pump), SV– 4188 (TDAFW steam supply valve) and breaker DV2021. The licensee stated that a fire in the area will affect Facility Z1 safe shutdown equipment, that the ‘‘A’’ EDG will be unavailable due to a loss of the Facility Z1 power supply for the diesel room ventilation fan F38A, that Facility Z2 is used to achieve and maintain Hot Standby, and that plant shutdown to Hot Standby can be accomplished using an AOP. 3.10.4 OMAs Credited for a Fire in This Area In their letter dated February 29, 2012, the licensee deleted OMAs 1, 9, and 11, from the exemption request for fire area R–13 since loss of IA is no longer postulated. 3.10.4.1 AFW Flow 3.10.4.1.1 OMAs 22 and 17—Operate Supply Valve SV–4188 From Panel C10 and Operate Turbine Driven AFW Pump Speed Control Circuit H–21 From Panel C10 The licensee stated that for a fire in the area, OMAs are required to provide decay heat removal and restore Charging system flow to the RCS and that establishing AFW flow to the credited SG is required within 45 minutes. The licensee stated that for a fire in the area, the required AFW flow path utilizes the TDAFW pump and that due to fire induced cable damage, AFW turbine steam supply valve (SV–4188) (OMA 22), and TDAFW turbine speed control (H21) (OMA 17) may not be available from the CR. The licensee further stated that the cable damage can be isolated and the TDAFW pump can be operated from the Fire Shutdown Panel (C–10) located in fire area R–2 and that an OMA is necessary to isolate the damaged cables and operate the TDAFW turbine speed control to maintain level in the SG. The licensee stated that in the case of 2–FW–43B, cable damage could result in spurious operation and that isolation of the affected cables and control of the valve can be accomplished at the C–10 panel, and that control of SG water level can be maintained using the speed control function of the TDAFW pump. The licensee further stated that the timeframe to establish control of TDAFW at the C–10 panel is 45 minutes and that after Reactor Operator 1 (RO– 1) has established control of TDAFW pump speed at the C–10 panel (8 minutes), it will take an additional 2 E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices minutes to establish AFW flow which results in a total time to establish AFW flow of 10 minutes, leaving a 35 minute margin. 3.10.4.1.2 OMA 20—Obtain CST Level at Local Level Indicating Switch LIS– 5489A The licensee stated that valves 2–MS– 190B and 2–FW–43B can be operated from the C–10 panel and that the OMA for local or C–10 operation of 2–MS– 190B is not required until after AFW flow is established and that PEO–1 will remain with the ADV to modulate steam flow per direction from the CR. The licensee further stated that the final decay heat removal function is to monitor CST level from either the C–10 panel (LT–5282) or locally at the CST (LIS–5489) (OMA 20) and that checking the level is not a short-term requirement because there is sufficient inventory in the CST to provide over 10 hours of water flow to the AFW system. The licensee further stated that a spurious start of the TDAFW coupled with 2– FW–43B failing open should not result in a SG overfill and that the nominal water level in the SG is maintained between 60–75% as indicated on the Narrow Range (NR) level instruments (i.e. the normal operating band). The licensee further stated that from the top of the normal operating band, more than 8000 gallons of water can be added before reaching 100 percent on the NR level instruments and allotting 8 minutes to establish operations from the C–10 panel and assuming all the flow from the TDAFW is filling one SG, approximately 4800 gallons can be added before regaining level control. The licensee further stated that there is also an additional 14,000 gallons of margin available before the SG would overfill (i.e. from 100 percent NR to the Main Steam nozzle). 3.10.4.2 Charging System Flow sroberts on DSK5SPTVN1PROD with NOTICES 3.10.4.2.1 OMAs 4, 5, 16, 21, and 24— Open Valve 2–CH–508, Open Valve 2– CH–509, Pull Control Power Fuses for Breaker A406 and Ensure Breaker Is Open, Operate Pump P18C From Panel C10, and Locally Close Breaker DV2021 The licensee stated that for a fire in the area, the Charging system has OMAs identified. The BASTs gravity feed valves, 2–CH–508 and 2–CH–509, may fail as is, (closed) due to cable damage and that OMAs are (OMA 4 and 5) in place to locally open these valves as part of restoring the Charging system. The licensee further stated that cable damage due to fire may also cause a spurious start of the P18C Charging Pump and that cable damage may be VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 mitigated by isolating and operating P18C (OMA 21) at the C–10 panel. The licensee further stated that RO–1 is at C–10 and must manipulate the controls for P18C and that establishing pump suction from the BASTs and operating P18C is required within 3 hours of reactor shutdown/loss of Charging. The licensee further stated that completing the OMAs to re-establish Charging would take 23 minutes leaving a margin of 157 minutes, which includes the parallel actions of PEO–2 establishing control of Bus 24D (by pulling control power fuses to circuit breaker A406 (OMA 16), ensuring A406 is open and closing breaker DV2021 (OMA 24) and PEO–3 (by manually aligning valves 2– CH–508 and 2–CH–509). The licensee further stated that after the BASTs have reached the 10 percent level, Operators switch Charging Pump suction over to the RWST and valve 2–CH–192 may fail closed due to a loss of power supply, but it can be controlled from the CR. 3.10.4.4 OMA Timing The OMAs to establish AFW flow can be completed in 10 minutes which provides a 35 minute margin since the required completion time is 45 minutes. The OMA to check CST level can be completed in 3 minutes and is a long term action as the CST provides over 10 hours of inventory to AFW. The OMAs to establish Charging system flow from the BASTs can be completed in 23 minutes which provides a margin of 157 minutes since the required completion time is 180 minutes. 3.10.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.11 Fire Area R–14, Lower 6.9 and 4.16 kV Switchgear Room, East Cable Vault 3.11.1 Fire Prevention The licensee stated that the areas have low combustible loading that predominantly consists of cable insulation and Thermo-Lag fire resistant PO 00000 Frm 00170 Fmt 4703 Sfmt 4703 43397 wrap, and that potential ignition sources include electrical faults. 3.11.2 Detection, Control, and Extinguishment The licensee stated that the Lower 6.9 and 4.16 kV Switchgear Room contains ionization smoke detectors located directly over each switchgear cabinet that alarm at the main fire alarm panel in the CR. The licensee also stated that a fire in the Lower 6.9 and 4.16 kV Switchgear Room that could potentially impact cables of concern would likely involve cable insulation resulting from an electrical fault in one of the cable trays routed over Bus 24E or failure of Bus 24E itself. Combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire occurring, outside of a switchgear failure, which could act as a pilot ignition source for the cable insulation and that a switchgear failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained combustion of IEEE 383 qualified cables. The licensee further stated that in the unlikely event of a fire, it would be rapidly detected by the ionization smoke detection system installed in the area and that the smoke detection system, which consists of an ionization smoke detector located directly over each switchgear cabinet in the area, will aid in providing prompt Fire Brigade response. The licensee stated that the East Cable Vault is provided with an automatic wet-pipe sprinkler system designed to protect structural steel and an ionization smoke detection system that alarms at the main fire alarm panel in the CR. The licensee also stated that the vertical cable chase that leads down the AB cable vault is protected by an automatic deluge spray system which is actuated by a cross-zoned smoke detection system that alarms at a local panel and at the main fire alarm panel in the CR. The licensee further stated that a fire in the area that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that since there is a minimal amount of Class A combustibles in this area, there is little chance of a fire E:\FR\FM\24JYN1.SGM 24JYN1 43398 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices occurring which could act as a pilot ignition source for the cable insulation. The licensee further stated that ThermoLag, while considered combustible, is one-hour fire rated in this area and that based on its fire resistive qualities and lack of ignition sources, a fire involving Thermo-Lag wrap is not credible. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. In the unlikely event the fire advanced beyond its incipient stage (unlikely based on type of cable insulation and Fire Brigade suppression activities), it would actuate the installed automatic wet-pipe suppression system provided in this area which will, at a minimum, provide reasonable assurance that a cable tray fire in this area will be controlled and confined to the immediate area of origin. sroberts on DSK5SPTVN1PROD with NOTICES 3.11.3 Preservation of Safe Shutdown Capability The licensee stated that a fire in the Facility Z1 Lower 4.16 kV Switchgear Room and Cable Vault will affect all Facility Z1 shutdown components, that Facility Z2 is used to achieve and maintain Hot Standby, that plant shutdown to Hot Standby can be accomplished using an AOP and that OMAs are required to provide decay heat removal and restore Charging system flow to the RCS. The licensee stated that the cables of concern in the East Cable Vault are the control and indication cabling for valve 2–FW–43B. The licensee also stated that cables for valves 2–CH–192, 2–CH–508 and 2–CH–509 are not located in this room, however, valves 2–CH–508 and 2–CH–509 are impacted due to the potential loss of the feed cables for bus 22E or the ‘‘A’’ EDG’s control and power cables which results in the loss of power to the valves. 3.11.4 OMAs Credited for a Fire in This Area In their letter dated February 29, 2012, the licensee deleted OMAs 1, 9 and 11 from the exemption request for fire area R–14 since loss of IA is no longer postulated. The licensee stated that during verification and validation of the AOPs, it was identified that for a fire in fire area R–14 an additional operator might be necessary to place the plant into hot standby. The staffing requirements for MPS2 were changed to add one licensed or non-licensed operator over the minimum technical specification (TS) requirement to be on duty each shift during Modes 1, 2, 3, or 4, with this VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 operator being designated as the Appendix R operator and is not part of the credited five man Fire Brigade crew. 3.11.4.1 Charging System Flow 3.11.4.1.1 OMAs 4 and 5—Open Valve 2–CH–508 and Open Valve 2–CH–509 The licensee stated that the Charging system has OMAs identified in that the BASTs gravity feed valves, 2–CH–508 and 2–CH–509, may fail as is (closed) due to a loss of power supply and that OMAs are in place (OMA 4 for 2–CH– 508 and OMA 5 for 2–CH–509) to locally open these valves as part of restoring the Charging system. The licensee further stated that establishing Charging Pump suction from the BASTs is required within 3 hours of reactor shutdown/loss of Charging and that RO– 1 and PEO–3 will perform their OMAs in parallel (see Section 3.11.4.1.2) to restore Charging. OMAs 4 and 5 are completed in 21 minutes. 3.11.4.1.2 OMAs 13, 14, 15, 23, and 24—Pull Control Power Fuses for Breaker A408 and Ensure Breaker Is Open, Pull Control Power Fuses for Breaker A410 and Ensure Breaker Is Open, Pull Control Power Fuses for Breaker A411 and Ensure Breaker Is Open, Pull Control Power Fuses for Breaker A401 and Ensure Breaker Is Closed, and Locally Close Breaker DV2021 The licensee stated that as part of the restoration of Charging flow to the RCS, Bus 24D must be isolated from cross-ties to Bus 24B, Bus 24E and the RSST and that this is due to fire-induced cable damage which may result in spurious operation/loss of control from the CR of breakers A401, A410, A408 and A411. The OMAs associated with these breakers are to pull the control power fuses and ensure that breakers A410 (OMA 14), A408 (OMA 13) and A411 (OMA 15) are open and that breaker A401 (OMA 23) is closed. The licensee also stated that once RO–1 completes the OMAs, PEO–1 will then reset and close breaker DV2021 (OMA 24). OMAs 13, 14, 15, 23 and 24 are completed in 24 minutes, then it will take an additional 3 minutes for the CR to establish Charging flow for a total of 27 minutes which results in a 153 minute margin since the required completion time is 180 minutes. 3.11.4.2 OMA Timing The OMAs to establish Charging system flow from the BASTs can be completed in 27 minutes which provides for a margin of 153 minutes since the required completion time is 180 minutes. PO 00000 Frm 00171 Fmt 4703 Sfmt 4703 3.11.5 Conclusion Given the limited amount of combustible materials and ignition sources and installed detection (Lower 6.9 and 4.16 kV Switchgear Room) and installed detection and suppression (East Cable Vault), it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel and damage the safe shutdown equipment. The low likelihood of damage to safe shutdown equipment due to a fire in this area, combined with the ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment and to be completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.12 Fire Area R–15, Containment Building 3.12.1 Fire Prevention The licensee stated that the area has low combustible loading including cable insulation and small amounts of lube oil and that potential ignition sources include electrical faults, motors, mechanical failure, and hot surfaces. 3.12.2 Detection, Control, and Extinguishment The licensee stated that the area is provided with smoke detection at each of the East and West Electrical Penetration Areas on the 14′–6″ elevation and that the system alarms at a local panel and at the main fire alarm panel in the CR. The licensee also stated that heat detection is provided for each of the Reactor Coolant Pumps (RCPs) and that during refueling outages, the fire protection header within Containment is charged, with hose stations available on all elevations with the exception of the 3′–6″ elevation. The licensee further stated that during normal plant operation, fire protection piping within the Containment is not charged. The licensee further stated that a fire in the Containment that could potentially impact any cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that during plant operation, there are negligible amounts of Class A combustibles in this area, and therefore, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation. If a cable fire does occur, it would be rapidly detected by the smoke detection E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices sroberts on DSK5SPTVN1PROD with NOTICES system installed at the east and west electrical penetration areas on the 14′– 6″ elevation of the Containment, alerting the CR to a fire condition in Containment. The licensee further stated that a lube oil fire serving as a pilot ignition source to cable in the Containment is not a realistic scenario, that lube oil in this fire area is predominantly associated with the four RCPs and that while a failure of one of these RCP motors and a subsequent lube oil fire could be postulated, each of the RCP motors (located on the 14′–6″ Elevation of Containment) is partially enclosed in reinforced concrete compartments and the floor beneath the RCPs drains to the lowest elevation of Containment (22′–6″ Elevation). The licensee further stated that cabling in the Containment is routed outside of these concrete compartments along the outer annulus of the Containment and would be shielded from an RCP motor fire. The licensee further stated that based on the large volume of the Containment, the heat and hot gasses generated by an RCP motor lube oil fire would rise to the upper elevations of the Containment away from the cable tray concentrations located at the East and West Electrical Penetration Areas on the 14′–6″ elevation of the Containment. If an RCP motor lube oil fire does occur, it would be detected in its incipient stage by the installed heat detection system that protects the RCP motors, alerting the CR to a fire condition in Containment. 3.12.3 Preservation of Safe Shutdown Capability The licensee stated that the cables of concern for the Containment are the power and indication cables for valves 2–CH–517 and 2–CH–519. The licensee stated that a fire in the Containment will affect a significant amount of instrumentation needed to monitor plant parameters and that a review of all instrument cables inside the Containment indicates that compliance with separation criteria was achieved with the exception of the Pressurizer cubicle. The separation issues inside Containment have been evaluated as follows: 1. Separation criteria were evaluated for the Pressurizer cubicle to address instruments LT–11OX, LT–1 10Y, PT– 102A, and PT–102B (instruments located on Racks C140 and C211 in the NE quadrant of containment) and instruments PT–103 and PT–103–1. 2. Separation criteria were evaluated for the remainder of the instruments required for safe shutdown (RCS temperature, SG level and pressure, core exit thermocouples, nuclear instruments VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 (NIs), containment temperature) and the sensing lines for the pressurizer level and pressurizer pressure instruments. The licensee stated that plant shutdown to Hot Standby can be accomplished using an AOP and that for a fire in the area, OMAs are required to provide decay heat removal and restore Charging system flow to the RCS. 3.12.4 OMAs Credited for a Fire in This Area 3.12.4.1 AFW Flow 3.12.4.1.1 OMAs 10 and 11—Operate Valve 2–MS–190A and Control Valve 2– MS–190B at Panel C10 or Local Manual Operation The licensee stated that for decay heat removal, after AFW flow is established from the CR in the required 45 minute time period, Operators will transfer from steaming through the MSSVs to steaming through the ADVs and that for a fire in the area, both ADVs (2–MS– 190A and 2–MS–190B) are required. The licensee also stated that operators must first determine which SG instruments are available and that if SG1 instrumentation is available, then 2–MS–190A (OMA 10) ADV will be utilized for the decay heat steam path, and if SG2 instrumentation is available, then the 2–MS–190B (OMA 11) ADV will be utilized for the decay heat steam path. The licensee further stated that neither ADV is fire affected, however, the fire may cause a loss of IA which is required to operate the ADVs to support decay heat removal. The licensee further stated that upon a loss of IA, the ADV will fail closed and that this ‘‘fail to closed’’ design prevents excessive RCS cooldown prior to AFW start. In the event of a loss of IA, operators will establish local manual control of 2–MS– 190A or 2–MS–190B after AFW flow is established. The licensee further stated that PEO–1 will remain with the ADV to modulate steam flow per direction from the CR. OMAs 10 and 11 can begin 17 minutes after AFW is established by the CR. 3.12.4.2 Charging System Flow 3.12.4.2.1 OMAs 6 and 7—Open Breaker to Fail Valve 2–CH–517 Closed and Open Breaker to Fail Valve 2–CH– 519 Open The licensee stated that the Charging system OMAs are for possible spurious operation of valves 2–CH–517, 2–CH– 518, and 2–CH–519, due to fire-induced cable damage and that these valves are located in Containment. The licensee also stated that PEO–3 opens breakers to place the valves in their required positions and for valve 2–CH–517 (OMA 6), breaker DV2012 is opened which PO 00000 Frm 00172 Fmt 4703 Sfmt 4703 43399 will fail the valve in the closed position and that this breaker manipulation will also fail 2–CH–519 (OMA 7) in its required open position. The licensee further stated that valve 2–CH–518 is not required for a fire in the area, but will be failed open (desired position) when other power circuits are isolated and that once PEO–3 completes the OMA in 7 minutes, it takes approximately 3 additional minutes for the CR to re-establish Charging flow which provides a 170 minute margin. 3.12.4.2.2 OMA 1—Open Valve 2–CH– 192 The licensee stated that although not fire affected, valve 2–CH–192 will failed closed after the isolation of power to Containment which will necessitate an OMA (OMA 1) to establish the RWST as the source of water to the RCS once the BASTs are depleted. The licensee also stated that a minimum switch-over time of 72 minutes, after charging has been restored, has been established based on the TRM BAST level requirements and that calculations conclude that the Charging system must be restored within 3 hours, therefore, the initial alignment of 2–CH–517 and 2–CH–519 will take place within 3 hours. The licensee further stated that establishing the RWST as a flow path to the RCS is not required until 1.2 hours after Charging is re-established. 3.12.4.3 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMAs to establish Charging system flow from the BAST can be completed in 10 minutes which provides a margin of 170 minutes since the required completion time is 180 minutes. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.12.5 Conclusion Given the limited amount of combustible materials, ignition sources, installed partial detection, and separation from the RCPs, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel and damage the safe shutdown equipment. There is a low likelihood of damage to safe shutdown equipment due to a fire in this area. The ability of the OMAs to manipulate the plant in the event of a fire that damages safe shutdown equipment, to be E:\FR\FM\24JYN1.SGM 24JYN1 43400 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices completed with more than 30 minutes of margin, provides adequate assurance that safe shutdown capability is maintained. 3.13 Fire Area R–17, East Electrical Penetration Area, East Main Steam Safety Valve/Blowdown Tank Room, East Piping Penetration Area 3.13.1 Fire Prevention The licensee stated that the East Electrical Penetration Area has moderate combustible loading that includes cable insulation and small amounts of plastics and that potential ignition sources include electrical faults. The licensee stated that the East Main Steam Safety Valve/Blowdown Tank Room has low combustible loading that consists entirely of cable insulation and that potential ignition sources include electrical faults. The licensee stated that the East Piping Penetration Area has low combustible loading that includes Class A combustibles (e.g., rubber) and that potential ignition sources include transient ignition sources (e.g. hotwork). sroberts on DSK5SPTVN1PROD with NOTICES 3.13.2 Detection, Control, and Extinguishment The licensee stated that the East Electrical Penetration Area is provided with an ionization smoke detection system which alarms at the main fire alarm panel in the CR. The licensee also stated that a fire in the area that could potentially impact a cable of concern would likely involve cable insulation resulting from an electrical fault. The licensee stated that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee further stated that the cable trays in this area are predominantly located towards the southern and eastern end of the room, while the Class A combustibles are located predominantly towards the northern end of the room. Based on the location of the Class A combustibles in relation to the cable trays in this area, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation. Based on the length of the east wall (55 feet), the distance between the cable trays and the Class A combustibles is approximately 45 feet. The licensee further stated that a failure of motor control center (MCC) B–31B could also serve as an ignition source and that an MCC failure normally results in a high intensity fire that lasts for a short duration, which makes it unlikely that it will cause sustained VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 combustion of IEEE 383 qualified cables. In order to impact the subject cable trays, an MCC failure would have to ignite a cable tray located immediately above the MCC. The fire would also have to propagate via the cable tray until it reached any cables of concern. The licensee further stated that based on the discussion above, the postulated fire scenario is highly unlikely. The characteristics of an MCC failure and the fire retardant properties of IEEE 383 cabling also make it implausible that failure of hydrogen analyzers C86 or C87 would result in the ignition of a cable tray located several feet above the analyzers. The heavy construction of the hydrogen analyzer cabinets would further preclude this event. The licensee further stated that in the event of a fire in this area, it would be rapidly detected in its incipient stage by the installed smoke detection system, which will aid in providing rapid response by the Fire Brigade. The licensee stated that a fire in the East Main Steam Safety Valve/ Blowdown Tank Room that could potentially impact the cables of concern would likely involve cable insulation resulting from an electrical fault and that combustibles in this area consist predominantly of IEEE 383 qualified cable insulation or cable that has been tested and found to have similar fire resistive characteristics. The licensee also stated that since the amount of Class A combustibles in this fire area is negligible, there is little chance of a fire occurring which could act as a pilot ignition source for the cable insulation and in the unlikely event of a fire in this fire area, the high ceiling and the large volume of this room would preclude a large rise in temperature in the areas where the subject cable trays or conduits are routed, reducing the likelihood that they would be damaged by the fire. The licensee stated that the East Piping Penetration Area is not provided with a smoke detection system, however, due to the openings in the ceiling of this area, the ionization smoke detection system located at the ceiling of the east electrical penetration area (FHA Zone A–10B) would provide supplemental coverage to detect a fire in this area. The licensee stated that a fire in the East Piping Penetration Area that could potentially impact any cables of concern would likely involve Class A combustibles from a transient ignition source. Based on the controls placed on transient combustibles and transient ignition sources, it is unlikely a fire would occur in this area. The licensee also stated that all hot work evolutions PO 00000 Frm 00173 Fmt 4703 Sfmt 4703 in the plant are procedurally required to have a fire watch in place. Hot work fire watches are individuals stationed in plant areas for the purpose of fire safety for workers and welders, detecting and suppressing smoke, fire, flames, or sparks as a result of hot work such as welding, cutting, or grinding. If a fire starts as a result of hot work, it would be detected in its incipient stages. The licensee further stated that since the amount of Class A combustibles in this area is small, a fire in this room is unlikely to occur. If a fire did occur, it would be of low intensity and would not likely be of sufficient magnitude to impact cable routed in conduit. The licensee further stated that the high ceiling of this room and the fact that this area opens up to the east electrical penetration area above (FHA Zone A– 10B) would preclude a large rise in temperature in the areas where the subject conduits are routed, lessening the likelihood that they would be damaged by the fire. 3.13.3 Preservation of Safe Shutdown Capability The licensee stated that OMAs associated with a fire in the East Electrical Penetration Area are related to failure of the ‘‘A’’ EDGs power or control cables resulting in the loss of power to buses 24C, 22E, B51 and the battery charger, which results in the depletion of the ‘‘A’’ battery and that a fire in this area could also cause the failure of IA. The licensee stated that the OMAs associated with a fire in the East Main Steam Safety Valve/Blowdown Tank Room are related to failure of IA and that cables for valves 2–CH–192 and 2– MS–190B do not enter this room. The licensee stated that in the event of a fire in the East Penetration Area which could affect Facility Z1 shutdown components, Facility Z2 is used to achieve and maintain Hot Standby and that plant shutdown to Hot Standby can be accomplished using an AOP. The licensee also stated that for a fire in the area, OMAs are required to provide decay heat removal and restore charging system flow to the RCS. 3.13.4 OMAs Credited for a Fire in This Area 3.13.4.1 AFW Flow 3.13.4.1.1 OMA 11—Control Valve 2– MS–190B at Panel C10 or Local Manual Operation The licensee stated that establishing AFW flow to the credited SG is required within 45 minutes and that for a fire in the area, the required AFW flow path utilizes the TDAFW pump. The licensee E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices also stated that once AFW flow is established from the CR, operation of the ADV (2–MS–190B) (OMA 11) is the required method for maintaining the plant in Hot Standby and transitioning to Cold Shutdown and that prior to AFW initiation, the plant is placed in the Hot Standby condition by steaming through the MSSVs. The licensee further stated that a fire in the area would not damage any cables associated with ADV (2–MS–1 90B), however, the fire might cause a loss of IA which is required to operate the ADVs and support decay heat removal. The licensee further stated that upon a loss of IA, the ADV will fail closed and that this ‘‘failed to close’’ design prevents excessive RCS cooldown prior to AFW start. Therefore, in the event of a loss of IA, Operators will establish local manual control of 2–MS–190B after AFW flow is established. The licensee further stated that PEO–1 will remain with the ADV to modulate steam flow per direction from the CR. 3.13.4.2 Charging System Flow sroberts on DSK5SPTVN1PROD with NOTICES 3.13.4.2.1 OMAs 4, 5 and 1—Open Valve 2–CH–508, Open Valve 2–CH– 509, and Open Valve 2–CH–192 The licensee stated that for a fire in the area, the Charging system has OMAs identified as the BASTs gravity feed valves, 2–CH–508 and 2–CH–509, might fail as is (closed) due to a loss of power supply. The licensee also stated that OMAs (OMA 4 and 5) are in place to locally open these valves as part of restoring the Charging system and that once these valves are opened, the CR can establish Charging flow within 2–3 minutes. The licensee further stated that establishing Charging Pump suction from the BASTs is required within 3 hours of reactor shutdown/loss of charging, and Charging is therefore reestablished within 24 minutes (21 minutes to open BASTs valves and 3 minutes to establish charging flow from the CR) which provides a 156 minute margin. The licensee further stated that after the BASTs have reached the 10 percent level, Operators switch the charging pump suction over to the RWST and that valve 2–CH–192 will fail closed when DV1013 is opened to mitigate spurious operation of 2–CH– 518 and that an OMA is required to open 2–CH–192 (OMA 1) once the BASTs supply to charging is exhausted. The licensee further stated that evaluations conclude that the BASTs will last a minimum of 72 minutes after Charging is re-established and that the OMA is not required to be performed prior to this time. VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 3.13.4.3 OMA Timing AFW flow is established from the CR within the required 45 minute time period and should IA be lost, the OMA to continue decay heat removal can be conducted beginning 17 minutes after AFW flow is established. The OMAs to establish Charging system flow from the BAST can be completed in 24 minutes which provides a margin of 156 minutes since the required completion time is 180 minutes. The OMA to establish Charging system flow from the RWST prior to BAST depletion can be completed in 32 minutes which provides a 40 minute margin since the required completion time is 72 minutes. 3.13.5 Conclusion Given the limited amount of combustible materials and ignition sources, administrative controls, available margin (40 minutes), and installed detection in the East Electrical Penetration Area, it is unlikely that a fire would occur and go undetected or unsuppressed by the personnel, and damage the safe shutdown equipment. The East Piping Penetration Room has limited combustible materials and ignition sources and lacks credible fire scenarios, but is not provided with detection. However, due to the openings in the ceiling, the detection located in the East Electrical Penetration Area provides some coverage to the East Piping Penetration Room. A fire in this room, although unlikely, would be expected to be of low intensity and not likely to impact cable routed in conduit. In addition, the high ceiling and ceiling openings to the East Electrical Penetration Area would preclude a large rise in temperature reducing the likelihood that cables would be damaged by the fire. The limited amount of combustible materials and ignition sources, administrative controls, and lack of credible fire scenarios, combined with the ability of the OMAs with available margin (40 minutes) to manipulate the plant, in the unlikely event of a fire that damages safe shutdown equipment, provides adequate assurance that safe shutdown capability can be maintained. The East Main Steam Safety Valve/ Blowdown Tank Room has limited combustible materials and ignition sources and lacks credible fire scenarios, but is not provided with detection. However, since the amount of Class A combustibles is small, there is little likelihood of a fire occurring which could act as a pilot ignition source for the cable insulation. In addition, the high ceiling and the large volume would preclude a large rise in PO 00000 Frm 00174 Fmt 4703 Sfmt 4703 43401 temperature where the cable trays or conduits are routed, reducing the likelihood of cable damage. The limited amount of combustible materials and ignition sources, administrative controls, and lack of credible fire scenarios, combined with the ability of the OMAs with available margin (40 minutes) to manipulate the plant in the unlikely event of a fire that damages safe shutdown equipment, provides adequate assurance that safe shutdown capability can be maintained. 3.14 Feasibility and Reliability of the Operator Manual Actions In their February 29, 2012 letter, the licensee stated that the means to safely shutdown MPS2 in the event of a fire that does occur and is not rapidly extinguished, as expected, has been documented in the Appendix R Compliance report. The entire Appendix R Compliance report was not reviewed by the NRC as part of this exemption, the relevant information was submitted on the docket in the letters identified above. The sections below outline the licensees basis for the OMA’s feasibility and reliability. 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 MPS2 analysis of these criteria for justifying the OMAs specified in this exemption. 3.14.1 Bases for Establishing Feasibility and Reliability The licensee stated that in establishing the assumed times for operators to perform various tasks, a significant margin (i.e., a factor of two) was used with respect to the required time to establish the system function for all fire area scenarios identified in the exemption request (with the exception of RWST flow to charging). For example, the Time Critical Action (TCA) to establish AFW flow is validated to be able to be completed within 22.5 minutes, which provides a factor of two margin of the 45 minute timeframe used in the fire scenario analysis. The licensee stated that confirmation times for valve/breaker manipulations was included in the action time for the OMAs. The licensee also stated that for valves that are operated in the field, if they are being manually opened or closed, there is local indication plus the mechanical stops to confirm valve operation. For valves that are throttled, the field operator is in communication with the CR personnel who monitor E:\FR\FM\24JYN1.SGM 24JYN1 43402 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices sroberts on DSK5SPTVN1PROD with NOTICES control board indication to confirm the proper response. The licensee further stated that all breakers have local mechanical indication for position verification, that all sequenced steps are coordinated from the CR, and that the OMA times listed include this coordination. 3.14.2 Environmental Factors The licensee stated that a review of ventilation systems for the fire areas addressed by the exemption request concluded that no credible paths exist that could allow the spread of products of combustion from the area of fire origin to an area that either serves as a travel path for OMAs or is an action location for an OMA. There is an exception for OMA 1 in fire area R–4 which was discussed in section 3.2.4.1.1 (and below). The licensee also stated that the installed ventilation systems are not used to perform smoke removal activity for the fire areas discussed in the exemption request and that smoke evacuation for these areas would be accomplished by the site Fire Brigade utilizing portable mechanical ventilation. The licensee stated that the performance of all the OMAs for each of the fire areas have specific safe pathways for access and egress and that in all cases, ELUs have been provided to ensure adequate lighting. The licensee also stated that during a fire event, implementation of CR actions ensure the radiation levels along these pathways, and at the location of the OMAs, are within the normal and expected levels. The licensee stated that area temperatures may be slightly elevated due to a loss of normal ventilation, however, in no case would the temperatures prevent access along the defined routes or prevent the performance of an OMA. The licensee also stated that only OMA 1 could occur in the fire affected area in that a fire in fire area R–4, charging pump cubicle, could impact valve 2–CH–192 requiring the OMA to manually open this valve. The licensee further stated that this action would be delayed until after the fire is extinguished and the area is ventilated and that opening valve 2– CH–192 would not be required until the BASTs are emptied. The licensee further stated that the most limiting time estimate is 72 minutes of Charging system operation injecting the contents of the BASTs based on the tanks being at the TRM minimum level at the start of the event and that during the event, Charging may be lost or secured, and RCS inventory can meet the Appendix R performance goal for 180 minutes. VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 The licensee further stated that analysis indicates that valve 2–CH–192 may not need to be opened until 252 minutes into the event. The licensee stated that fire barrier deviations that could allow the spread of products of combustion of a fire to an adjacent area that either serves as a travel path for OMAs or is an action location for an OMA have been found to not adversely impact OMA travel paths or action areas. surveillances for the equipment utilized in each OMA. 3.14.3 Equipment Functionality and Accessibility The licensee stated that as part of the OMA validation process, lighting, component labeling, accessibility of equipment, tools, keys, flashlights, and other devices or supplies needed are verified to ensure successful completion of the OMA. The licensee stated that for each OMA, the current MPS2 Appendix R Compliance Report indicates that operator access is assured by an alternate path or access is not required until after the fire has been suppressed. Where applicable, the licensee stated that OMAs have sufficient ELUs to provide for access to the particular component and to perform the task. 3.14.8 Procedures and Training The licensee stated that entry into AOP 2559, ‘‘FIRE’’ is at the first indication of a fire from a panel alarm or report from the field. If the fire is in an Appendix R area, the shift is directed to determine if a fire should be considered Appendix R by: 1. Identifying actual or imminent damage to safe shutdown components, switchgear, MCCs, cable trays or conduit runs; 2. Observation of spurious operation of plant components needed for safe shutdown; 3. Observation of loss of indication, control, or function of safe shutdown plant systems or components; 4. Observation of conflicting instrument indication for safe shutdown systems or components; or 5. Observation of parameters associated with safe shutdown systems or components not being within expected limits for the existing plant configuration. The licensee stated that AOP 2559, ‘‘FIRE’’ has various attachments that have Appendix R egress/access routes which provide a safe pathway to reach the required equipment necessary to complete the OMAs and that they have confirmed that the pathways will be free of hazards to the operators due to the subject fire. The licensee also stated that there is an Appendix R AOP corresponding to each Appendix R fire area, which are entered when an Appendix R fire is declared. Operations personnel train to those AOPs which identify the steps to perform each OMA. The licensee further stated that time critical OMAs are also identified within operating procedures which require that Operations personnel train to perform these time critical activities. The OMAs presented in this exemption request are encompassed in the time critical procedure. The licensee further stated that the times allotted to perform these tasks are easily achieved by experienced and inexperienced operators during training sessions, evaluated requalification training, and supervised walk downs and that for each case, there is sufficient 3.14.4 Available Indications Indicators and indication cables have been evaluated by the licensee as part of the exemption request process. Where impacts to indication have been identified the licensee provided an alternate method to obtain the needed indication(s). 3.14.5 Communications The licensee stated that Operators are provided with dedicated radio communication equipment and that the Appendix R communication system utilizes a portion of the MPS 800 MHz trunked radio system which consists of 800 MHz portable radio units, a CR base station transmitter, antennas, a main communication console located inside the CR and redundant repeaters. The licensee also stated that the CR base station transmitter is provided to ensure two-way voice communications with the CR without affecting plant safety systems that may have sensitive electronic equipment located in the area and the resulting design configuration ensures communications capability for all Appendix R fire scenarios. 3.14.6 Portable Equipment The licensee stated that all equipment required to complete a required action is included in a preventative maintenance program and is also listed in the TRM which identifies PO 00000 Frm 00175 Fmt 4703 Sfmt 4703 3.14.7 Personnel Protection Equipment The licensee stated that there are no OMAs required in fire areas identified in the exemption request that necessitate the use of self-contained breathing apparatus. No fire areas necessitate reentry to the area of fire origin other than described in Section 3.2.4.1.1. E:\FR\FM\24JYN1.SGM 24JYN1 43403 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices margin to account for the uncertainties associated with stress, environmental factors, and unexpected delays. 3.14.9 Staffing The licensee stated that the Operations shift staffing requirements include one additional licensed or nonlicensed operator over the minimum TS requirement to be on duty each shift during Modes 1, 2, 3, or 4, and that this operator is designated as the Appendix R operator and is specified in the TRM. The licensee also stated that the number of individuals available to respond to the OMAs is one RO, two PEOs, and one additional licensed or non-licensed individual (Appendix R Operator). The licensee stated that the exemption request allocated tasks to PEO–1, PEO– 2, PEO–3 and RO–1 and that one of the three PEOs would be the TRM required Appendix R Operator. With the exception of the panel C10 activities, the assignments are interchangeable between the four operators, since these individuals are specified by the TS and TRM, they are not members of the Fire Brigade and have no other collateral duties. The licensee stated that MPS2 has a SERO and appropriate emergency response facilities. In the event of a declaration of an ALERT (events which are in progress or have occurred involving an actual or potential substantial degradation of the level of safety of the plant, with releases expected to be limited to small fractions of the Environmental Protection Agency, Protective Action Guideline exposure levels), ALERT event activates the SERO organization, which is immediately staffed by on-site personnel and is fully established with on-call personnel within 60 minutes of the ALERT being declared. The licensee also stated that after this time, off-shift Operations staff (e.g., personnel in training, performing administrative functions, etc.) may be called in as requested by the SM. The licensee further stated that many of the OMAs are not required prior to the establishment of SERO and that the additional staff available through SERO will improve the reliability of these OMAs. The licensee stated that operators are required and assumed to be within the Protected Area and that the time lines account for the initial response by the field Operator. The licensee also stated that upon the announcement of a fire, the field Operators are directed to report to the CR and await further directions. Upon a report of a fire, the CR Operators enter AOP 2559, ‘‘FIRE.’’ The licensee further stated that the flow path to get into an Appendix R fire scenario is, that upon indication of a fire, the Fire Brigade is dispatched, and based on their report or indications in the CR, an Appendix R fire may be declared. In the development of the time lines, the Operators are allowed 5 minutes to respond and report to the CR. 3.14.10 Demonstrations In their letter dated February 29, 2012 the licensee provided its validation process for the OMAs included in the exemption request. The validation process included the following: 1. Validation Objectives; 2. Validation Frequency; 3. Validation Methods; 4. Validation Attributes; and 5. Validation Performance. The licensee stated that all OMAs are encompassed in procedure COP 200.18, ‘‘Time Critical Action Validation and Verification’’ and that an enhancement to the tracking and training on TCAs has been developed and is currently being implemented. The licensee stated that all of the OMAs identified are contained in the AOPs to respond to an Appendix R Fire in the AOP Series 2579’s fire procedures for Appendix R and that during initial validation of these procedures, the OMAs were performed and all of the time performance objectives were met as a result of the validation. 3.14.11 Feasibility Summary The licensee’s analysis demonstrates that, for the expected scenarios, the OMAs can be diagnosed and executed within the amount of time available to complete them. The licensee’s analysis also demonstrates that various factors, including the factor of two time margin, the use of the minimum BAST inventory, and the use of the CST inventory, have been considered to address uncertainties in estimating the time available. Therefore, the OMAs included in this review are feasible because there is adequate time available for the Operator to perform the required OMAs to achieve and maintain hot shutdown following a postulated fire event. The following table summarizes the ‘‘required’’ versus ‘‘available’’ times for OMAs with time requirements. Where a diagnosis time has been identified, it is included as part of the required time for a particular action. Where an action has multiple times or contingencies associated with the ‘‘allowable’’ completion time, the lesser time is used. This approach is considered to represent a conservative approach to analyzing the timelines associated with each of the OMAs with regard to the feasibility and reliability of the actions included in this exemption. All OMAs have at least 30 minutes of margin, and all but one have a factor of two time margin available. Margin is based on using the most limiting information from the licensee, for example, if the licensee postulated a range of time for diagnosis, the required time below includes the largest number in the range. Finally, these numbers should not be considered without the understanding that the manual actions are a fall back in the unlikely event that the fire protection defense-in-depth features are insufficient. In most cases there is no credible fire scenario that would necessitate the performance of these OMAs. The licensee provided a discussion of the activity completion times and associate margins related to the OMAs in their June 30, 2011, and February 29, 2012 letters which are summarized in Table 3. TABLE 3 Available time (min) Margin (min) sroberts on DSK5SPTVN1PROD with NOTICES Activity Fire Area R–2 (West Penetration Area, MCC B61, and the Facility Z2 Upper 4.16kV Switchgear Room and Cable Vault). Establish AFW Flow ................... 12 45 9 36 Establish Charging Suction from BAST. Establish Charging Suction from RWST. 2, 6, 10, 18, 19, 20 1, 8 180 66 114 72 40 32 VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 PO 00000 Frm 00176 Fmt 4703 OMAs Time to conduct OMAs (min) Fire Area of Fire Origin Sfmt 4703 E:\FR\FM\24JYN1.SGM 24JYN1 43404 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices TABLE 3—Continued Fire Area of Fire Origin Activity Fire Area R–4 (Charging Pump Cubicles) ............. Establish Charging Suction from RWST. Establish Charging Suction from RWST. Establish Charging Suction from RWST. Establish Charging Suction from BAST. Establish Charging Suction from RWST. Establish Charging Suction from RWST. Establish Charging Suction from BAST. Obtain Local BAST Level Indication. Establish Charging Suction from RWST. Establish AFW Flow ................... Fire Area R–5 (‘‘A’’ Safeguards Room, HPSI/ LPSI). Fire Area R–6 (‘‘B’’ Safeguards Room, LPSI) ....... Fire Area R–7 (Diesel Generator Room A) ........... Fire Area R–8 (Diesel Generator Room B) ........... Fire Area R–9 (Facility Z1 DC Switchgear Room and Battery Room). Fire Area R–10 (Facility Z2 DC Equipment Room and Battery Room). Fire Area R–12 (TDAFW Pump Pit) ...................... Fire Area R–13 (West (Facility Z1) 480 VAC Switchgear Room). Fire Area R–14 (Facility Z1 Lower 4.16kV Switchgear Room and Cable Vault). Fire Area R–15 (Containment Building) ................. Fire Area R–17 (East Penetration Area) ................ The completion times noted in the table above provide reasonable assurance that the OMAs can reliably be performed under a wide range of conceivable conditions by different plant crews because it, in conjunction with the time margins associated with each action and other installed fire protection features, account for sources of uncertainty such as variations in fire and plant conditions, factors unable to be recreated in demonstrations and human-centered factors. sroberts on DSK5SPTVN1PROD with NOTICES 3.14.12 Reliability A reliable action is a feasible action that is analyzed and demonstrated as being dependably repeatable within an available time. The above criteria, 3.14.1 through 3.14.10 provide the staff’s basis that the actions are feasible. Section 3.14.11, provides a discussion of the available time margin. The licensee provided a basis that the actions were reliable, based on the available time margin; the administrative controls such as procedures, staffing levels, and availability of equipment; and by accounting for uncertainty in fires and plant conditions. Therefore, the OMAs included in this review are reliable VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 Establish Charging BASTs. Establish Charging BASTs. Establish Charging BASTs. Establish Charging RWST. Establish Charging BASTs. Establish Charging RWST. 32 40 1 72 32 40 1 72 32 40 4, 5, 11 180 24 156 1 72 32 40 1 72 32 40 4, 5 180 24 156 18, 19 180 12 168 1 72 32 40 17, 22 45 10 35 180 23 157 180 27 153 Suction from 4, 5, 16, 20, 21, 24 4, 5, 13, 14, 15, 23, 24 6, 7 180 10 170 Suction from 1 72 32 40 Suction from 4, 5 180 24 156 Suction from 1 72 32 40 Suction from Suction from In summary, the defense-in-depth concept for a fire in the fire areas discussed above provides a level of safety that results in the unlikely occurrence of fires, rapid detection, control and extinguishment of fires that do occur and the protection of structures, systems and components important to safety. As discussed above, Fmt 4703 Margin (min) 72 3.15 Summary of Defense-in-Depth and Operator Manual Actions Frm 00177 Time to conduct OMAs (min) 1 because there is adequate time available to account for uncertainties not only in estimates of the time available, but also in estimates of how long it takes to diagnose a fire and execute the OMAs (e.g., as based, at least in part, on a plant demonstration of the actions under nonfire conditions). OMA 1 for fire area R– 4 is performed in a fire affected area and is performed after the fire is extinguished and after the SERO is fully staffed. This OMA establishes the RWST as the suction supply for the charging system and is not conducted until after AFW is established and since the BASTs have a minimum TRM specified inventory to ensure 72 minutes of flow, OMA 1 can be completed with 40 minutes of margin. PO 00000 Available time (min) OMAs Sfmt 4703 the licensee has provided preventative and protective measures in addition to feasible and reliable OMAs that together demonstrate the licensee’s ability to preserve or maintain safe shutdown capability in the event of a fire in the analyzed fire areas. 3.16 Authorized by Law This exemption would allow MPS2 to rely on OMAs, in conjunction with the other installed fire protection features, to ensure that at least one means of achieving and maintaining hot shutdown remains available during and following a postulated fire event, as part of its fire protection program, in lieu of meeting the requirements specified in III.G.2 for a fire in the analyzed fire areas. As stated above, 10 CFR 50.12 allows the NRC to grant exemptions from the requirements of 10 CFR Part 50. The NRC staff has determined that granting of this exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission’s regulations. Therefore, the exemption is authorized by law. E:\FR\FM\24JYN1.SGM 24JYN1 Federal Register / Vol. 77, No. 142 / Tuesday, July 24, 2012 / Notices 3.17 No Undue Risk to Public Health and Safety The underlying purpose of 10 CFR Part 50, Appendix R, Section III.G is to ensure that at least one means of achieving and maintaining hot shutdown remains available during and following a postulated fire event. Based on the above, no new accident precursors are created by the use of the specific OMAs, in conjunction with the other installed fire protection features, in response to a fire in the analyzed fire areas. 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. 3.18 Consistent with Common Defense and Security This exemption would allow MPS2 to credit the use of the specific OMAs, in conjunction with the other installed fire protection features, in response to a fire in the analyzed fire areas, discussed above, in lieu of meeting the requirements specified in III.G.2. This change, to the operation of the plant, has no relation to security issues. Therefore, the common defense and security is not diminished by this exemption. 3.19 sroberts on DSK5SPTVN1PROD with NOTICES Conclusion Based on the all of the features of the defense-in-depth concept discussed above, the NRC staff concludes that the use of the requested OMAs, 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 is consistent with the underlying purpose of the rule. As such, the level of safety present at MPS2 is commensurate with VerDate Mar<15>2010 21:06 Jul 23, 2012 Jkt 226001 Dated at Rockville, Maryland, this 12th day of July 2012. For the Nuclear Regulatory Commission. Michele G. Evans, Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation. [FR Doc. 2012–17735 Filed 7–23–12; 8:45 am] BILLING CODE 7590–01–P NUCLEAR REGULATORY COMMISSION Special Circumstances One of the special circumstances described in 10 CFR 50.12(a)(2)(ii) is that the application of the regulation is not necessary to achieve the underlying purpose of the rule. The underlying purpose of 10 CFR Part 50, Appendix R, Section III.G is to ensure that at least one means of achieving and maintaining hot shutdown remains available during and following a postulated fire event. While the licensee does not comply with the explicit requirements of III.G.2 specifically, they do meet the underlying purpose of 10 CFR Part 50, Appendix R, and Section III.G as a whole. Therefore, special circumstances exist that warrant the issuance of this exemption as required by 10 CFR 50.12(a)(2)(ii). 4.0 the established safety standards for nuclear power plants. 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 Dominion an exemption from the requirements of Section III.G.2 of Appendix R of 10 CFR Part 50, to utilize the OMAs discussed above at MPS2. 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 (77 FR 39746). This exemption is effective upon issuance. [NRC–2010–0138] Final Standard Review Plan, Branch Technical Position 7–19 on Guidance for Evaluation of Diversity and Defense-in-Depth in Digital ComputerBased Instrumentation and Control Systems Nuclear Regulatory Commission. ACTION: Notice of availability. AGENCY: The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff is issuing Final Revision 6 to NUREG–0800, ‘‘Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,’’ Branch Technical Position (BTP) 7–19 on ‘‘Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based Instrumentation and Control Systems.’’ This BTP is to be cited as the acceptance criteria for Diversity and Defense-in-Depth in Digital Computer-Based Instrumentation and Control Systems in the Standard Review Plan (SRP), Chapter 7, for those standard reactor designs that have not been certified prior to the date of this BTP. The purpose of this SRP update is SUMMARY: PO 00000 Frm 00178 Fmt 4703 Sfmt 4703 43405 to provide staff guidance for assessing combined license (COL) applicant compliance with the requirements. DATES: The effective date of this SRP update is August 23, 2012. ADDRESSES: Please refer to Docket ID NRC–2010–0138 when contacting the NRC about the availability of information regarding this document. You may access information related to this document, which the NRC possesses and are publicly available by any of the following methods: • Federal Rulemaking Web site: Go to https://www.regulations.gov and search for Docket ID NRC–2010–0138. Address questions about NRC dockets to Carol Gallagher; telephone: 301–492–3668; email: Carol.Gallagher@nrc.gov. • NRC’s Agencywide Documents Access and Management System (ADAMS): You may access publiclyavailable documents online in the NRC Library at https://www.nrc.gov/readingrm/adams.html. To begin the search, select ‘‘ADAMS Public Documents’’ and then select ‘‘Begin Web-based ADAMS Search.’’ For problems with ADAMS, please contact the NRC’s Public Document Room (PDR) reference staff at 1–800–397–4209, 301–415–4737, or by email to pdr.resource@nrc.gov. The ADAMS accession number for each document referenced in this notice (if that document is available in ADAMS) is provided the first time that a document is referenced. The Final Revision 6 to NUREG–0800, ‘‘Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,’’ Branch Technical Position (BTP) 7–19 on ‘‘Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based Instrumentation and Control Systems’’ (Package) (ADAMS Accession No. ML110550767), Final Revision 6 to NUREG–0800, ‘‘Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants,’’ Branch Technical Position (BTP) 7–19 on ‘‘Guidance for Evaluation of Diversity and Defense-inDepth in Digital Computer-Based Instrumentation and Control Systems,’’ (ADAMS Accession No. ML110550791), and Comment Response Document for BTP 7–19, (ADAMS Accession No. ML120830075). • NRC’s PDR: You may examine and purchase copies of public documents at the NRC’s PDR, Room O1–F21, One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852. • The NRC posts its issued staff guidance on the NRC’s external Web page (https://www.nrc.gov/reading-rm/ doc-collections/nuregs/staff/sr0800/). E:\FR\FM\24JYN1.SGM 24JYN1

Agencies

NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 77, Number 142 (Tuesday, July 24, 2012)]
[Notices]
[Pages 43382-43405]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-17735]


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NUCLEAR REGULATORY COMMISSION

[Docket No. 50-336; NRC-2012-0158]


Millstone Power Station, Unit 2; Exemption

1.0 Background

    Dominion Nuclear Connecticut, Inc., (the licensee, Dominion) is the 
holder of Renewed Facility Operating License No. DPR-65, which 
authorizes operation of the Millstone Power Station, Unit 2 (MPS2). 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.
    MPS2 shares the site with Millstone Power Station Unit 1, a 
permanently defueled boiling water reactor nuclear unit, and Millstone 
Power Station Unit 3, a pressurized water reactor. The facility is 
located in Waterford, Connecticut, approximately 3.2 miles west 
southwest of New London, CT. This exemption applies to MPS2 only. The 
other units, Units 1 and 3, are not part of this exemption.

2.0 Request/Action

    Title 10 of the Code of Federal Regulations (10 CFR) 50.48, 
requires that nuclear power plants that were licensed 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.'' MPS2 was licensed to operate prior to January 1, 1979. As 
such, the licensee's Fire Protection Program (FPP) must provide the 
established level of protection as intended by Section III.G of 10 CFR 
Part 50, Appendix R.
    By letter dated June 30, 2011, ``Request for Exemption from 10 CFR 
Part 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown 
Capability'' available at Agencywide Documents Access and Management 
System (ADAMS), Accession No. ML11188A213, and supplemented by letter 
dated February 29, 2012, ``Response to Request for Additional 
Information Request for Exemption from 10 CFR Part 50, Appendix R, 
Section III.G, Fire Protection of Safe Shutdown Capability'' (ADAMS 
Accession No. ML12069A016), the licensee requested an exemption for 
MPS2, from certain technical requirements of 10 CFR Part 50, Appendix 
R, Section III.G.2 (III.G.2) for the use of operator manual actions 
(OMAs) in lieu of meeting the circuit

[[Page 43383]]

separation and protection requirements contained in III.G.2 for fire 
areas:

R-2/Fire Hazards Analysis (FHA) Zone A-8C, Zone A-8D, Zone A-13, Zone 
T-8, Zone T-10;
R-4/FHA Zone A-6A, Zone A-6B;
R-5/FHA Zone A-8A;
R-6/FHA Zone A-3;
R-7/FHA Zone A-15;
R-8/FHA Zone A-16;
R-9/FHA Zone A-20;
R-10/FHA Zone A-21;
R-12/FHA Zone T-4;
R-13/FHA Zone T-6;
R-14/FHA Zone T-7, Zone T-9;
R-15/FHA Zone C-1;
R-17/FHA Zone A-10A, Zone A-10B, and Zone A-10C.

3.0 Discussion

    Pursuant to 10 CFR 50.12, the Commission may, upon application by 
any interested person or upon its own initiative, grant exemptions from 
the requirements of 10 CFR Part 50 when: (1) The exemptions are 
authorized by law, will not present an undue risk to public health or 
safety, and are consistent with the common defense and security; and 
(2) when special circumstances are present. The licensee has stated 
that special circumstances are present in that the application of the 
regulation in this particular circumstance is not necessary to achieve 
the underlying purpose of the rule, which is consistent with the 
language included in 10 CFR 50.12(a)(2)(ii). The licensee further 
states that the OMAs included in the exemption request provide 
assurance that one train of systems necessary to achieve and maintain 
hot shutdown will remain available in the event of a fire.
    In accordance with 10 CFR 50.48(b), nuclear power plants licensed 
before January 1, 1979, are required to meet Section III.G, of 10 CFR 
Part 50, Appendix R. The underlying purpose of Section III.G of 10 CFR 
Part 50, Appendix R, is to ensure that the ability to achieve and 
maintain safe shutdown is preserved following a fire event. The 
regulation intends for licensees to accomplish this by extending the 
concept of defense-in-depth to:
    a. Prevent fires from starting;
    b. Rapidly detect, control, and extinguish promptly those fires 
that do occur;
    c. Provide protection for structures, systems, and components 
important to safety so that a fire that is not promptly extinguished by 
the fire suppression activities will not prevent the safe shutdown of 
the plant.
    The stated purpose of III.G.2 is to ensure that in the event of a 
fire, one of the redundant trains necessary to achieve and maintain hot 
shutdown conditions remains free of fire damage. III.G.2 requires one 
of the following means to ensure that a redundant train of safe 
shutdown cables and equipment is free of fire damage, where redundant 
trains are located in the same fire area outside of primary 
containment:
    a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
    b. Separation of cables and equipment by a horizontal distance of 
more than 20 feet with no intervening combustibles or fire hazards and 
with fire detectors and an automatic fire suppression system installed 
in the fire area; or
    c. Enclosure of cables and equipment of one redundant train in a 
fire barrier having a 1-hour rating and with fire detectors and an 
automatic fire suppression system installed in the fire area.
    The licensee stated that the OMAs addressed in the exemption 
request are those contained in the MPS2 Appendix R Compliance Report. 
The licensee stated that the MPS2 Appendix R Compliance Report was 
submitted to the NRC for review on May 29, 1987 (ADAMS Legacy Library 
Accession No. 8706120088, available at NRC Public Document Room) and 
found acceptable by an NRC safety evaluation report (SER) dated July 
17, 1990 (ADAMS Accession No. ML012880391), but that the SER did not 
specifically address the OMAs.
    Each OMA included in this review consists of a sequence of tasks 
that need to be performed in various fire areas. The OMAs are initiated 
upon confirmation of a fire in a particular fire area. Table 1 lists 
the OMAs included in this review (OMAs are listed in the order they are 
conducted for a fire originating in a particular area). Some OMAs are 
listed more than once, if they are needed for fires that originate in 
different areas.

                                                     Table 1
----------------------------------------------------------------------------------------------------------------
       Area of fire origin                Area name                       Actions                      OMA
----------------------------------------------------------------------------------------------------------------
Fire Area R-2...................  West Penetration Area,    Pull Control Power Fuses and        OMA 12
                                   Motor Control Center      Ensure Breaker A305 is Open.
                                   B61, and the Facility
                                   Z2 Upper 4.16kV
                                   Switchgear Room and
                                   Cable Vault.
                                                            Operate Valve 2-MS-190A to          OMA 10
                                                             Transition from Main Steam Safety
                                                             Valves.
                                                            Check Local Condensate Storage      OMA 20
                                                             Tank Level Indication at LIS-5489.
                                                            Open Breaker to Fail Valve 2-CH-    OMA 6
                                                             517 Closed.
                                                            Check Local Level Indication at LI- OMA 18
                                                             206A.
                                                            Check Local Boric Acid Storage      OMA 19
                                                             Tank Level Indication at LI-208A.
                                                            Open Valve 2-CH-429 to Establish    OMA 2
                                                             Charging Flow Path.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
                                                            Open Valve 2-CS-13.1B to Establish  OMA 8
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-4...................  Charging Pump Cubicles..  Control at Panel C-10 Until Loss    OMA 11
                                                             of Air, Operate Valve 2-MS-190B
                                                             to Transition from Main Steam
                                                             Safety Valves.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-5...................  ``A'' Safeguards Room     Operate Valve 2-MS-190A to          OMA 10
                                   (High Pressure Safety     Transition from MSSVs.
                                   Injection/Low Pressure
                                   Safety Injection).

[[Page 43384]]

 
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-6...................  ``B'' Safeguards Room     Operate Valve 2-MS-190A to          OMA 10
                                   (Low Pressure Safety      Transition from Main Steam Safety
                                   Injection).               Valves.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-7...................  Diesel Generator Room A.  Control at Panel C-10 Until Loss    OMA 11
                                                             of Air, Operate Valve 2-MS-190B
                                                             to Transition from Main Steam
                                                             Safety Valves.
                                                            Open Valve 2-CH-508 to Obtain       OMA 4
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Open Valve 2-CH-509 to Obtain       OMA 5
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-8...................  Diesel Generator Room B.  Operate Valve 2-MS-190A to          OMA 10
                                                             Transition from Main Steam Safety
                                                             Valves.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
                                                            Check Local Condensate Storage      OMA 20
                                                             Tank Level Indication at LIS-5489.
----------------------------------------------------------------------------------------------------------------
Fire Area R-9...................  Facility Z1 Direct        Open Valve 2-CH-508 to Obtain       OMA 4
                                   Current Switchgear Room   Charging Pump Suction from Boric
                                   and Battery Room.         Acid Storage Tank.
                                                            Open Valve 2-CH-509 to Obtain       OMA 5
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-10..................  Facility Z2 Direct        Check Local Condensate Storage      OMA 20
                                   Current Equipment Room    Tank Level Indication at LIS-5489.
                                   and Battery Room.
                                                            Check Local Boric Acid Storage      OMA 18
                                                             Tank Level Indication at LI-206A.
                                                            Check Local Boric Acid Storage      OMA 19
                                                             Tank Level Indication at LI-208A.
----------------------------------------------------------------------------------------------------------------
Fire Area R-12..................  Turbine Driven Auxiliary  Operate Valve 2-MS-190A to          OMA 10
                                   Feedwater Pump Pump Pit.  Transition from Main Steam Safety
                                                             Valves.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-13..................  West (Facility Z1) 480    Operate Valve SV-4188 from Panel C- OMA 22
                                   VAC Switchgear Room.      10.
                                                            Operate Speed Control Circuit H-21  OMA 17
                                                             from Panel C-10 to Control
                                                             Turbine Driven Auxiliary
                                                             Feedwater Pump Speed.
                                                            Check Local Condensate Storage      OMA 20
                                                             Tank Level Indication at LIS-5489.
                                                            Pull Control Power Fuses and        OMA 16
                                                             Ensure Breaker A406 is Open.
                                                            Close Breaker DV2021 at Panel DV20  OMA 24
                                                            Open Valve 2-CH-508 to Obtain       OMA 4
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Open Valve 2-CH-509 to Obtain       OMA 5
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Operate Pump P18C from Panel C-10.  OMA 21
----------------------------------------------------------------------------------------------------------------
Fire Area R-14..................  Facility Z1 Lower 4.16kV  Open Valve 2-CH-508 to Obtain       OMA 4
                                   Switchgear Room and       Charging Pump Suction from Boric
                                   Cable Vault.              Acid Storage Tank.
                                                            Open Valve 2-CH-509 to Obtain       OMA 5
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Pull Control Power Fuses and        OMA 14
                                                             Ensure Breaker A410 is Open to
                                                             Isolate Required Bus.
                                                            Pull Control Power Fuses and        OMA 13
                                                             Ensure Breaker A408 is Open to
                                                             Isolate Required Bus.
                                                            Pull Control Power Fuses and        OMA 23
                                                             Ensure Breaker A401 is Closed to
                                                             Power Bus from the Emergency
                                                             Diesel Generator.
                                                            Pull Control Power Fuses and        OMA 15
                                                             Ensure Breaker A411 is Open to
                                                             Isolate Required Bus.
                                                            Close Breaker DV2021 at Panel DV20  OMA 24
----------------------------------------------------------------------------------------------------------------
Fire Area R-15..................  Containment Building....  Operate Valve 2-MS-190A to          OMA 10
                                                             Transition from Main Steam Safety
                                                             Valves.

[[Page 43385]]

 
                                                            Control at Panel C-10 Until Loss    OMA 11
                                                             of Air, Operate Valve 2-MS-190B
                                                             to Transition from Main Steam
                                                             Safety Valves.
                                                            Open Breaker to Fail Valve 2-CH-    OMA 6
                                                             517 Closed.
                                                            Open Breaker to Fail Valve 2-CH-    OMA 7
                                                             519 Open to Establish Charging
                                                             Flow Path.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------
Fire Area R-17..................  East Penetration Area...  Control at Panel C-10 Until Loss    OMA 11
                                                             of Air, Operate Valve 2-MS-190B
                                                             to Transition from Main Steam
                                                             Safety Valves.
                                                            Open Valve 2-CH-508 to Obtain       OMA 4
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Open Valve 2-CH-509 to Obtain       OMA 5
                                                             Charging Pump Suction from Boric
                                                             Acid Storage Tank.
                                                            Open Valve 2-CH-192 to Establish    OMA 1
                                                             Charging Pump Suction from
                                                             Refueling Water Storage Tank.
----------------------------------------------------------------------------------------------------------------

    The designation Z1 and Z2 are used throughout this exemption. The 
licensee stated that the 4.16 kV subsystems are divided into two 
specific ``Facilities'' and that Facility Z1 or Z1 Power begins with 
load center 24C which powers one train of Engineered Safety Features 
(ESFs) and is provided with an emergency power supply by the ``A'' 
Emergency Diesel Generator (EDG) while Facility Z2 begins with load 
center 24D and powers a redundant second train of ESF and is provided 
with an emergency power supply by the ``B'' EDG. The licensee also 
stated that vital power and control cables fall mainly into two 
redundancy classifications; Channel Z1 and Channel Z2 and that in a few 
cases there is also a Channel Z5, which is a system that can be 
transferred from one source to another. The licensee further stated 
that, Facility Z1 would be synonymous with ``A'' train while Facility 
Z2 would be synonymous with ``B'' train.
    The licensee stated that their exemption request is provided in 
accordance with the information contained in Regulatory Issue Summary 
(RIS) 2006-10, ``Regulatory Expectations with Appendix R Paragraph 
III.G.2 Operator Manual Actions,'' which states that an approved 10 CFR 
50.12 exemption is required for all OMAs, even those accepted in a 
previously issued NRC SER.
    Dominion has requested an exemption from the requirements of 
III.G.2 for MPS2 to the extent that one of the redundant trains of 
systems necessary to achieve and maintain hot shutdown is not 
maintained free of fire damage in accordance with one of the required 
means, for a fire occurring in the following fire areas:

R-2 West Penetration Area, Motor Control Center (MCC) B61, and the 
Facility Z2 Upper 4.16kV Switchgear Room and Cable Vault;
R-4 Charging Pump Cubicles;
R-5 ``A'' Safeguards Room;
R-6 ``B'' Safeguards Room;
R-7 Diesel Generator Room ``A'';
R-8 Diesel Generator Room ``B'';
R-9 Facility Z1 DC Switchgear Room and Battery Room;
R-10 Facility Z2 DC Switchgear Room and Battery Room;
R-12 Turbine Driven Auxiliary Feedwater Pump Pit;
R-13 West 480 VAC Switchgear Room;
R-14 Facility Z1 Lower 4.16kV Switchgear Room and Cable Vault;
R-15 Containment Building;
R-17 East Penetration Area.

    The licensee stated that the OMAs are credited for the III.G.2 
deficiencies, such as having only a single safe shutdown train, lack of 
separation between redundant trains, lack of detection and automatic 
suppression in the fire area or a combination of those deficiencies. 
The NRC staff notes that having only a single safe shutdown train is 
not uncommon to this plant design. Single train systems at MPS2 include 
Instrument Air (IA), ``A'' and ``B'' Boric Acid Storage Tank (BAST) 
Control Room (CR) level indication, Condensate Storage Tank (CST) CR 
level indication, suction-side flow to the Charging Pumps from the 
Refueling Water Storage Tank (RWST), auxiliary spray to the 
Pressurizer, and Charging Pump discharge to the Reactor Coolant System 
(RCS).
    The licensee also stated that they have evaluated/modified all 
motor operated valves (MOVs) relied upon by OMAs consistent with NRC 
Information Notice (IN) 92-18 (February 28, 1992) which detailed the 
potential for fires to damage MOVs that are required for safe shutdown 
so that they can no longer be remotely or manually operated and that as 
a result of this evaluation and modifications, the possibility that the 
desired result was not obtained is minimized. The licensee further 
stated that all the equipment operated to perform these OMAs are not 
fire affected and therefore are reasonably expected to operate as 
designed with one exception being in fire area R-4 concerning the 
performance of OMA 1 (see section 3.2.4.1.1) The licensee further 
stated that valve 2-CH-192 could be fire affected, however, it is an 
(air operated valve (AOV) that fails closed on loss of IA or power and 
is normally closed and that a fire event in this area will not cause 
this valve to be driven beyond its stops and that the valve will not be 
overtourqued. The licensee further stated that operating valve 2-CH-192 
is not required until the BASTs are nearly depleted; a minimum of 72 
minutes after charging is reestablished (which is not required until 
180 minutes) and that a fire directly impacting valve 2-CH-429 would 
result in the valve failing in the desired open position.
    In their submittals, the licensee described elements of their FPP 
that provide their justification that the concept of defense-in-depth 
that is in place in the above fire areas is consistent with that 
intended by the regulation. To accomplish this, the licensee utilizes 
various protective measures to accomplish the concept of defense-in-
depth. Specifically, the licensee stated that the purpose of their 
request was to credit the use of OMAs, in conjunction with other 
defense-in-depth features, in lieu of the separation and protective 
measures required by III.G.2. Their approach is discussed below.
    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.

[[Page 43386]]

Unless noted otherwise below, all of the fire areas included in this 
exemption have a combustible fuel load that is considered to be low, 
with fuel sources consisting primarily of fire retardant cable 
insulation and limited floor based combustibles. The licensee also 
stated that two of the fire areas (R-7/FHA Zone A-15 and R-8/FHA Zone 
A-16) have high combustible loading consisting of fuel oil and lube oil 
and that automatic pre-action fire suppression systems are provided in 
these areas. The licensee further stated that two other fire areas (R-
17/FHA Zone A-10A and R-12/FHA Zone T-4) contain negligible combustible 
loading, with combustibles in these areas consisting of Class A 
combustibles and lube oil. There are no high energy ignition sources 
located in the areas except as noted in fire areas R-2 and R-14. The 
fire areas included in the exemption request are not shop areas so hot 
work activities are infrequent with administrative control (e.g., hot 
work permits, fire watch, and supervisory controls) programs in place 
if hot work activities do occur. The administrative controls are 
described in the Millstone FPP, which is incorporated into the Updated 
Final Safety Analysis Report.
    The licensee stated that the storage of combustibles is 
administratively controlled by the site's FPP procedures to limit the 
effects of transient fire exposures on the plant and in addition, hot 
work (i.e., welding, cutting, grinding) is also administratively 
controlled by site FPP procedure CM-AA-FPA-100.
    The licensee indicated that their FPP uses the concept of defense-
in-depth, both procedurally and physically, to meet the following 
objectives: 1. Prevent fires from starting; 2. Rapidly detect, control, 
and extinguish promptly, those fires that do occur; and, 3. Provide 
protection for structures, systems, and components important to safety 
so that a fire that is not promptly extinguished by the fire 
suppression activities will not prevent the safe shutdown of the plant. 
The licensee also stated that the integration of the program, 
personnel, and procedures, which are then collectively applied to the 
facility, reinforce the defense in-depth aspect of the FPP and that 
strict enforcement of ignition source and transient combustible control 
activities (through permitting), and monthly fire prevention 
inspections by the site Fire Marshal ensure that this work is actively 
monitored to prevent fires.
    The MPS Fire Brigade consists of a minimum of a Shift Leader and 
four Fire Brigade personnel. The affected unit (MPS2 or MPS3) supplies 
an advisor, who is a qualified Plant Equipment Operator (PEO). The 
advisor provides direction and support concerning plant operations and 
priorities. Members of the Fire Brigade are trained in accordance with 
MPS, Station Procedure TQ-1, Personnel Qualification and Training. Fire 
Brigade personnel are responsible for responding to all fires, fire 
alarms, and fire drills and to ensure availability, a minimum of a 
Shift Leader and four Fire Brigade personnel remain in the Owner 
Controlled Area and do not engage in any activity which would require a 
relief in order to respond to a fire. The licensee further stated that 
the responding Fire Brigade lead may request the Shift Manager (SM) 
augment the on-shift five member Fire Brigade with outside resources 
from the Town of Waterford Fire Department which has a letter of 
agreement with MPS, to respond to the site (when requested) in the 
event of a fire emergency or rescue and will attempt to control the 
situation with available resources.
    MPS2 has been divided into fire areas, as described in the MPS FPP. 
Three-hour fire barriers are normally used to provide fire resistive 
separation between adjacent fire areas. In some cases, barriers with a 
fire resistance rating of less than three hours are credited but 
exemptions have been approved or engineering evaluations performed in 
accordance with Generic Letter 86-10 to demonstrate that the barriers 
are sufficient for the hazard. Walls separating rooms within fire areas 
are typically constructed of heavy concrete. The licensee stated that 
in general, fire rated assemblies separating Appendix R fire areas meet 
Underwriters Laboratories/Factory Mutual (UL/FM) design criteria and 
the requirements of American Society of Testing Materials (ASTM) E-119, 
``Fire Test of Building Construction and Materials'' for 3-hour rated 
fire assemblies. The licensee also stated that openings created in fire 
rated assemblies are sealed utilizing penetration seal details that 
have been tested in accordance with ASTM E-119 and are qualified for a 
3-hour fire rating, in addition, fireproof coating of structural steel 
conforms to UL-Listed recognized details and is qualified for a 3-hour 
fire rating. The licensee further stated that fire dampers are UL-
Listed and have been installed in accordance with the requirements of 
National Fire Protection Association (NFPA) 90A, ``Standard for the 
Installation of Air Conditioning and Ventilation Systems,'' and that 
the code of record for fire dampers is either the version in effect at 
the time of original plant construction (late 1960s) or the 1985 
edition. The licensee further stated that fire doors are UL-Listed and 
have been installed in accordance with NFPA 80, ``Standard for Fire 
Doors and Windows'' in effect at the time of plant construction (late 
1960s).
    The licensee provided a discussion of the impacts of any Generic 
Letter (GL) 86-10 evaluations and/or exemptions on the fire areas 
included in this exemption request. For all the areas with GL 86-10 
evaluations and/or other exemptions, the licensee stated that none of 
the issues addressed by the evaluations would adversely impact, through 
the spread of fire or products of combustion, plant areas where OMAs 
are performed or the respective travel paths necessary to reach these 
areas. The licensee also stated that there are no adverse impacts on 
the ability to perform OMAs and that the conclusions of the GL 86-10 
evaluations and the exemption requests would remain valid with the OMAs 
in place. In addition to these boundaries, the licensee provided a 
hazard analysis that described how detection, control, and 
extinguishment of fires are addressed for each of the fire areas for 
which the OMAs may be needed.
    Unless noted otherwise below, fire areas are provided with 
ionization smoke detectors. The licensee stated that the smoke and heat 
detection systems were designed and installed using the guidance of the 
requirements set forth in several NFPA standards including the 1967, 
1979, and 1986 Editions of NFPA 72D, ``Standard for the Installation, 
Maintenance and Use of Proprietary Protective Signaling Systems for 
Watchman, Fire Alarm and Supervisory Service,'' and the 1978 and 1984 
Editions of NFPA 72E, ``Standard on Automatic Fire Detectors.'' Upon 
detecting smoke or fire, the detectors initiate an alarm in the CR 
enabling Fire Brigade response. The licensee stated that in most cases, 
no automatic fire suppression systems are provided in the areas 
included in this exemption request except for plant areas with 
significant quantities of combustibles, such as lube oil. Automatic 
fire suppression systems have also been installed in areas with one-
hour barrier walls and one-hour rated electrical raceway encapsulation.
    The licensee stated that fire suppression systems were designed in 
general compliance with, and to meet the intent of the requirements of 
several NFPA standards depending on the type of system including the 
1985 Edition of NFPA 13, ``Standard for the Installation of Sprinkler 
Systems,'' the 1985 Edition of NFPA 15, ``Standard for Water Spray

[[Page 43387]]

Fixed Systems For Fire Protection,'' and the 1987 Edition of NFPA 12A, 
``Standard on Halon 1301 Fire Extinguishing Systems.''
    The licensee stated that in general, fire extinguishers and hose 
stations have been installed in accordance with the requirements of the 
1968 Edition of NPFA 10, ``Standard for the Installation of Portable 
Fire Extinguishers'' and the 1978 Edition of NFPA 14, ``Standard for 
the Installation of Standpipe and Hose Systems,'' respectively. The 
licensee stated that Equipment Operators are trained Fire Brigade 
members and would likely identify and manually suppress or extinguish a 
fire using the portable fire extinguishers and manual hose stations 
located either in or adjacent to, or both, these fire areas.
    Each of the fire areas included in this exemption is analyzed below 
with regard to how the concept of defense-in-depth is achieved for each 
area and the role of the OMAs in the overall level of safety provided 
for each area.

3.1 Fire Area R-2, West Cable Vault, Upper 6.9 and 4.16kV Switchgear 
Rooms, 480V MCC B61 and B41A Enclosure, West Piping Penetration Area, 
West Electrical Penetration Area

3.1.1 Fire Prevention
    The licensee stated that the West Cable Vault, the Upper 6.9 and 
4.16 kV Switchgear Room, the 480V MCC B61 and B41A Enclosure, and the 
West Piping Penetration Area have low combustible loading that 
predominantly consists of cable insulation and that potential ignition 
sources for these areas includes electrical faults.
    The licensee stated that the West Electrical Penetration Area has 
low to moderate combustible loading that includes small amounts of 
plastics and cellulosic materials and that potential ignition sources 
include electrical faults.
3.1.2 Detection, Control and Extinguishment
    The licensee stated that the West Cable Vault is provided with an 
automatic wet-pipe sprinkler system designed to protect structural 
steel in this area from the adverse affects of a fire, and also 
protected by an ionization smoke detection system that alarms at the 
main fire alarm panel in the CR. In addition, the licensee stated that 
the vertical cable chase that leads down the Auxiliary Building (AB) 
cable vault is protected by an automatic deluge spray system which is 
actuated by a cross-zoned smoke detection system that alarms at a local 
panel and at the main fire alarm panel in the CR. The licensee also 
stated that a fire in the West Cable Vault that could potentially 
impact a cable of concern would likely involve cable insulation and 
result from an electrical fault and that combustibles in this area 
consist predominantly of Institute of Electrical and Electronics 
Engineers (IEEE) 383 qualified cable insulation or cable that has been 
tested and found to have similar fire resistive characteristics (not 
self-igniting or capable of propagating flame after pilot ignition 
source is removed). The licensee also stated that were a cable fire to 
occur in this area, it would be rapidly detected in its incipient stage 
by the installed smoke detection system, which will aid in providing 
rapid response by the Fire Brigade and that in the unlikely event the 
fire advanced beyond its incipient stage, it would actuate the 
installed automatic wet-pipe suppression system which consists of 
sprinklers located in each beam pocket and provides reasonable 
assurance that a cable tray fire in this area will be controlled and 
confined to the immediate area of origin, and will limit fire exposure/
damage.
    The licensee stated that the Upper 6.9 and 4.16kV Switchgear Room 
has ionization smoke detection located directly over each switchgear 
cabinet that alarms at the main fire alarm panel in the CR. The 
licensee further stated that a fire in the Upper 6.9 and 4.16 kV 
Switchgear Room that could potentially impact any cables of concern 
would likely involve cable insulation resulting from an electrical 
fault or failure of Bus 25B, which is located several feet away from 
the subject cable tray and that combustibles in this area consist 
predominantly of IEEE 383 qualified cable insulation or cable that has 
been tested and found to have similar fire resistive characteristics. 
The licensee further stated that in the unlikely event of a fire, it 
would be rapidly detected by the ionization smoke detection system 
installed in the area and that the smoke detection system, which 
consists of an ionization smoke detector located directly over each 
switchgear cabinet in the area, will aid in providing prompt Fire 
Brigade response.
    The licensee stated that the 480V MCC B61 and B41A enclosures are 
provided with ionization smoke detection that alarms at a local panel 
and at the main fire alarm panel in the CR. The licensee also stated 
that the steel enclosure of the MCC room is protected by a wet pipe 
water spray system in lieu of a three hour fire barrier. The licensee 
further stated that a fire in the 480 V MCC B61 and B41A enclosures 
that could potentially impact any cables of concern would likely 
involve cable insulation resulting from an electrical fault or failure 
of one of the MCC's located in the room and that combustibles in this 
area consist predominantly of IEEE 383 qualified cable insulation or 
cable that has been tested and found to have similar fire resistive 
characteristics. The licensee further stated that a failure of MCC B-
41B could also serve as an ignition source and that an MCC failure 
normally results in a high intensity fire that lasts for a short 
duration, which makes it unlikely that it will cause sustained 
combustion of IEEE 383 qualified cables despite the fact that the 
subject cable trays are located approximately 6-8' above the MCC. The 
smoke detection system, which consists of an ionization smoke detector 
located directly over MCC B61, will aid in providing prompt Fire 
Brigade response.
    The licensee stated that the West Piping Penetration Area is 
provided with an ionization smoke detection system, which alarms at a 
local panel and at the main fire alarm panel in the CR. The licensee 
further stated that a fire in the West Piping Penetration area that 
could potentially impact any cables of concern would likely involve 
cable insulation resulting from an electrical fault and that 
combustibles in this area consist predominantly of IEEE 383 qualified 
cable insulation or cable that has been tested and found to have 
similar fire resistive characteristics. The licensee further stated 
that since there is a minimal amount of Class A combustibles in this 
area, there is little chance of a fire occurring, outside of a 
switchgear failure, which could act as a pilot ignition source for the 
cable insulation and that a switchgear failure normally results in a 
high intensity fire that lasts for a short duration, which makes it 
unlikely that it will cause sustained combustion of IEEE 383 qualified 
cables. The licensee further stated that in the event of a fire in this 
area, it would be rapidly detected in its incipient stage by the 
installed smoke detection system, which will aid in providing rapid 
response by the Fire Brigade.
    The licensee stated that the West Electrical Penetration Area is 
provided with an ionization smoke detection system, which alarms at the 
main fire alarm panel in the CR. The licensee further stated that a 
fire in the West Electrical Penetration Area that could potentially 
impact any cables of concern would likely involve cable insulation 
resulting from an electrical fault and that combustibles in this area 
consist predominantly of IEEE 383 qualified cable insulation or cable 
that has been tested and found to have similar fire

[[Page 43388]]

resistive characteristics. The licensee further stated that in the 
event of a fire in this area, it would be rapidly detected in its 
incipient stage by the installed smoke detection system, which will aid 
in providing rapid response by the Fire Brigade.
3.1.3 Preservation and Safe Shutdown Capability
    The licensee stated that the OMAs associated with a fire in the 
West Cable Vault are related to failure of the feed to the 480V load 
center bus 22F or the ``B'' EDGs control and power cables and that loss 
of bus 22F results in the loss of the ``B'' battery charger and the 
eventual depletion of the ``B'' battery which in turn results in the 
loss of level transmitter LT-5282.
    The licensee stated that the cables of concern in the Upper 4.16 kV 
Switchgear Room are for valves 2-CH-429 and 2-CH-517, level 
transmitters LT-5282, LT-206 and LT-208 and breaker A305. The licensee 
also stated that the cabling of concern is part of the breaker control 
logic and coordination between buses 24C, 24D and 24E and that 
components 2-CH-429, 2-CH- 517, LT-5282, LT-206, and LT-208 are single 
train components. The licensee further stated that the worst case tray 
arrangement is the common tray for components 2-CH-429, 2-CH-517, LT-
206, LT-208 and LT-5282. The licensee further stated that there is a 
moderate likelihood that a fire can occur which will impact components 
2-CH-429, 2-CH-517, LT-206, LT-208 or LT-5282.
    The licensee stated that cables of concern in the 480 V MCC B61 and 
B41A enclosures are the power, indication and control cables for valves 
2-CS-13.1B and 2-CH-429.
    The licensee stated that valve 2-CH-429 is located in the north and 
west side of the West Piping Penetration Room, near the containment 
building wall and that the power and indication cabling for this valve 
is routed via conduit into a cable tray located along the west wall of 
the room. The licensee also stated that there is likely no fire that 
can occur which will impact valve 2-CH-429 due to configuration, 
combustible loading and ignition sources, however, if there was an 
impact, the nature of the cables would fail the valve in the desired 
open position.
    The licensee stated that the cables of concern in the West 
Electrical Penetration Area service valves 2-CH-429 and 2-CH-517, and 
level transmitters LT-206, LT-208 and LT-5282. The licensee also stated 
that it is very unlikely that a fire can occur which will impact valves 
2-CH-429 or 2-CH-517 due to configuration, combustible loading, and 
ignition sources and that analysis indicates there is a low likelihood 
that a fire will impact LT-206, LT-208 and LT-5282.
    The licensee stated that a fire in the West Penetration Area, MCC 
B61, and the Facility Z2 Upper 4.16 kV Switchgear Room and Cable Vault 
will affect all Facility Z2 shutdown components, that Facility Z1 is 
used to achieve and maintain Hot Standby, and that an Abnormal 
Operating Procedure (AOP) is used to achieve plant shutdown to Hot 
Standby. The licensee also stated that for a fire in fire area R-2, 
OMAs are required to provide for Decay Heat Removal and to restore 
Charging system flow to the RCS.
3.1.4 OMAs Credited for a Fire in This Area
3.1.4.1 Auxiliary Feedwater (AFW) Flow
3.1.4.1.1 OMA 12--Pull Control Power Fuses and Ensure Breaker A305 Is 
Open
    The licensee stated that in order to establish AFW flow, Bus 24C is 
credited to provide power from H7A (``A'' EDG) to P9A (``A'' Motor 
Drive Auxiliary Feedwater Pump (MDAFW)) and that calculations conclude 
that AFW flow must be established within 45 minutes. The licensee also 
stated that cable damage may result in a loss of remote breaker control 
capability for A305, which is the Bus 24C to Bus 24E cross-tie breaker 
and that at A305 (Bus 24C), the OMA is to de-energize the breaker 
control circuit by pulling control power fuses and ensuring that the 
breaker is open which prevents spurious closure of A305. The licensee 
further stated that this step establishes AFW flow and provides for a 
36 minute time margin on the 45 minute time requirement and that after 
AFW flow is established, the atmospheric dump valves (ADVs) are 
utilized to remove decay heat. The licensee further stated that prior 
to this, RCS decay heat removal is provided by utilizing the Main Steam 
Safety Valves (MSSVs) and that steaming through the MSSVs is also 
acceptable after AFW flow is established but utilizing the ADVs, with 
2-MS-190A credited for the fire in fire area R-2, is required for 
initiating the transition to Cold Shutdown.
3.1.4.1.2 OMA 10--Operate Valve 2-MS-190A To Transition From MSSVs
    The licensee stated that valve 2-MS-190A fails due to a postulated 
loss of IA and its cables are not impacted by fire. The licensee also 
stated that PEO-2, will remain with the ADV to modulate steam flow per 
direction from the CR. Although this OMA is completed in 10 minutes, 
since the OMA is conducted after AFW flow and before charging system 
flow is established, there is no minimum required completion time.
3.1.4.1.3 OMA 20--Obtain Condensate Storage Tank Level at Local Level 
Indicating Switch LIS-5489A
    The licensee stated that the remaining decay heat removal function 
is to locally monitor CST level (LIS-5489) which is not a short-term 
requirement because there is sufficient inventory in the CST to provide 
over 10 hours of water flow to the AFW system. The licensee further 
stated that this activity will likely be repeated several times over 
the course of placing the plant in Cold Shutdown.
3.1.4.2 Charging System Flow
3.1.4.2.1 OMAs 2 and 6--Open Valve 2-CH-429 To Establish Charging Pump 
Flow Path and Open Breaker to Fail Valve 2-CH-517 Closed
    The licensee stated that the Charging System has several OMAs to 
reestablish flow within the three hour required timeframe and that to 
initially restore charging, valve 2-CH-429 is opened or verified open 
(OMA 2), and valve 2-CH-517 (OMA 6) is closed. The licensee stated that 
valve 2-CH-429 is a MOV located in the fire area and will be locally 
manually operated postfire and that it has been evaluated with respect 
to the guidance contained in NRC IN 92-18. The licensee stated that 
valve 2-CH-517 is an AOV that fails closed and is located in 
containment. The licensee further stated that the OMA is to de-energize 
the power supply (DV20) and fail the valve closed and that once 2-CH-
429 is manually opened, Charging can be reestablished. The licensee 
further stated that assuming 60 minutes before being allowed into the 
fire affected area, the Charging flow path can be established within 64 
minutes and Charging flow within 66 minutes which provides 114 minutes 
of margin on the 180 minute required time.
3.1.4.2.2 OMAs 18 and 19--Obtain BAST Level at Local Level Indicator 
LI-206A and Obtain BAST Level at Local Level Indicator LI-208A
    The licensee stated that due to fire cable damage, both LT-206 and 
LT-208 are not available from the CR and that both BAST levels require 
OMAs for local level indication at LI-206A (OMA 18) and LI-208A (OMA 
19). The licensee also stated that both indicators are outside the R-2 
fire area and that the action is considered part of the restoration for 
the Charging system and as such, this action is not required until the 
three hour timeframe.

[[Page 43389]]

3.1.4.2.3 OMAs 1 and 8--Open Valve 2-CH-192 and Open Valve 2-CS-13.1B
    The licensee stated that after Charging is restored, there are OMAs 
to switch the Charging suction path from the BASTs to the RWST which 
requires opening valves 2-CH-192 (OMA1) and 2-CS-13.1B (OMA 8). The 
licensee also stated that the 2-CH-192 valve is an AOV which may have 
failed closed due to a loss of IA and that it has a safety-related air 
accumulator which provides sufficient air to stroke open the valve and 
maintains it open for three hours and that after the air accumulator is 
exhausted, the valve will fail closed and an OMA is required to 
establish/maintain RWST flow to the Charging system.
    The licensee stated that valve 2-CS-13.1B is a MOV which may 
spuriously close due to fire cable damage and that it has to be 
manually opened in the field prior to switching over to the RWST. The 
licensee also stated that based on requirements in the technical 
requirements manual (TRM), the BASTs can supply Charging for more than 
72 minutes, at which time the Charging pump suction source is shifted 
to the RWST.
3.1.4.3 OMA Timing
    The OMA to establish AFW flow can be completed in 9 minutes which 
provides a 36 minute margin since the required completion time is 45 
minutes. The OMA to monitor CST level can be completed in 12 minutes 
and is a long term action as the CST provides over 10 hours of 
inventory to AFW. The OMAs to establish Charging system flow from the 
BASTs can be completed in 66 minutes which provides a 114 minute margin 
since the required completion time is 180 minutes. The OMAs to 
establish Charging system flow from the RWST prior to BAST depletion 
can be completed in 40 minutes which provides a 32 minute margin since 
the required completion time is 72 minutes.
3.1.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection and automatic fire suppression (West 
Cable Vault), it is unlikely that a fire would occur and go undetected 
or unsuppressed by the personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this area, combined with the ability of the OMAs to 
manipulate the plant in the event of a fire that damages safety 
shutdown equipment and be completed with more than 30 minutes of 
margin, provides adequate assurance that safe shutdown capability is 
maintained.

3.2 Fire Area R-4, Charging Pump Room, Degasifier Area

3.2.1 Fire Prevention
    The licensee stated that the Charging Pump Room has low combustible 
loading that includes small amounts of lube oil and that potential 
ignition sources include electrical faults, pump motors, mechanical 
failure, and hot surfaces.
    The licensee stated that the Degasifier Area has low combustible 
loading that predominantly consists of cable insulation and that 
potential ignition sources include electrical faults.
3.2.2 Detection, Control, and Extinguishment
    The licensee stated that the Charging Pump Room is provided with an 
ionization smoke detection system which alarms at a local panel and at 
the main fire alarm panel in the CR. A fixed water curtain is provided 
at the entrance to the Degasifier Area (FHA Fire Zone A-6B), which 
provides protection for the Charging Pump area from a fire in the 
Reactor Building Closed Cooling Water System (RBCCW) Pump and Heat 
Exchanger Area (FHA Fire Zone A-1 B). The licensee also stated that 
actuation of this system results in an alarm (waterflow) at the main 
fire alarm panel in the CR. The licensee further stated that a fire in 
the Charging Pump cubicles that could potentially impact any cables of 
concern would likely involve cable insulation resulting from an 
electrical fault or a lube oil fire resulting from a Charging Pump 
failure and that combustibles in this area consist predominantly of 
IEEE 383 qualified cable insulation or cable that has been tested and 
found to have similar fire resistive characteristics. The licensee also 
stated that since there is a minimal amount of Class A combustibles in 
this area, there is little chance of a fire occurring which could act 
as a pilot ignition source for the cable insulation and that each 
charging pump contains just over 10 gallons of lube oil which could 
also serve as a pilot ignition source for cable insulation in the event 
of a pump/motor failure with the resultant ignition of the lube oil. 
The licensee further stated that based on the elevated ignition 
temperature of the lube oil and the low probability of a pump/motor 
assembly failure with subsequent ignition of the entire quantity of 
lube oil, it is unlikely that a lube oil fire from a Charging Pump 
failure would serve as an ignition source for IEEE 383 qualified cable 
insulation. The licensee further stated that curbs are installed 
between each Charging Pump to protect each pump from a combustible 
liquid spill within a neighboring Charging Pump cubicle. The licensee 
further stated that a fire would be rapidly detected in its incipient 
stage by the installed smoke detection system, which will aid in 
providing rapid response by the Fire Brigade.
    The licensee stated that the Degasifier Area is provided with an 
ionization smoke detection system which alarms at a local panel and at 
the main fire alarm panel in the CR and that a fixed water curtain is 
provided at the entrance to this area and serves to provide protection 
for the Charging Pump Room (FHA Zone A-6A) from a fire in the RBCCW 
Pump and Heat Exchanger Area (FHA Zone A-1 B). The licensee also stated 
that actuation of this system results in an alarm (waterflow) to the 
main fire panel in the CR. The licensee further stated that a fire in 
the Degasifier Area that could potentially impact any cables of concern 
would likely involve cable insulation resulting from an electrical 
fault and that combustibles in this area consist predominantly of IEEE 
383 qualified cable insulation or cable that has been tested and found 
to have similar fire resistive characteristics. The licensee further 
stated that since there is a minimal amount of Class A combustibles in 
this area, there is little chance of a fire occurring which could act 
as a pilot ignition source for the cable insulation. The licensee 
further stated that in the event of a fire in this area, it would be 
rapidly detected in its incipient stage by the installed smoke 
detection system, which will aid in providing rapid response by the 
Fire Brigade.
3.2.3 Preservation of Safe Shutdown Capability
    The licensee stated that the cables of concern in the Charging Pump 
Room are for control and indication of valve 2-CH-192 and that analysis 
indicates there is a low likelihood that a fire can occur which will 
impact the valve. The licensee stated that the cables of concern for 
the Degasifier Area pass through the hallway leading into the area and 
are for control and indication of valve 2-CH-192 and that analysis 
indicates there is a very low likelihood that a fire can occur which 
will impact valve 2-CH-192.
    The licensee stated that a fire in the Charging Pump cubicles will 
affect the Charging Pumps and several suction valves and that the 
compliance strategy relies on re-routing of Facility Z2 control and 
power cables for P18B and

[[Page 43390]]

Facility Z2 power cable for P18C from the pump cubicles to outside of 
fire area R-4. The licensee also stated that an exemption provides 
technical justification of survivability of at least one Charging Pump 
following a fire in this area, even though the requirements of III.G.2 
are not met. The licensee further stated that survivability is 
justified based on existing physical spatial separation, partial height 
missile walls, curbing between pumps, and low intervening combustibles 
and that plant shutdown can be accomplished using an AOP. The licensee 
further stated that OMAs are required to provide for decay heat removal 
and to restore Charging system flow to the RCS.
3.2.4 OMAs Credited for a Fire in This Area
3.2.4.1 AFW and Charging System Flow
3.2.4.1.1 OMAs 1 and 11 Open Valve 2-CH-192 and Control Valve 2-MS-190B 
at Panel C10 or Local Manual Operation
    The licensee stated that establishing AFW flow to the credited 
steam generator (SG) is required to be accomplished within 45 minutes 
and that the required flow path utilizes the turbine driven auxiliary 
feedwater (TDAFW) pump. The licensee also stated that prior to AFW 
initiation, the plant is placed in the Hot Standby condition by 
steaming through the MSSVs and that after AFW is established from the 
CR, operation of the ADV (2-MS-190B) (OMA 11) is the required method of 
removing decay heat to maintain Hot Standby and transition to Cold 
Shutdown. The licensee further stated that there is no cable damage 
from fire to the required ADV (2-MS-190B), however, the fire may cause 
a loss of IA which is required to operate the ADVs to support decay 
heat removal. The licensee stated that upon a loss of air, the ADV will 
fail closed and that this design prevents excessive RCS cooldown prior 
to AFW start and, therefore, in the event of a loss of IA, Operators 
will establish local manual control of 2-MS-190B after AFW flow is 
established. The licensee further stated that PEO-2 will remain with 
the ADV to modulate steam flow per direction from the CR and that after 
restoration of the Charging system, the BASTs are credited for 
maintaining RCS inventory and that the BASTs have a minimum level 
specified in the TRM which ensures 72 minutes of flow. The licensee 
further stated that once the BASTs are depleted, Operators switch over 
to the RWST. The licensee further stated that due to fire damage, the 
2-CH-192 valve may spuriously close and that in order to establish the 
RWST as the suction path for the Charging system, an OMA is required to 
open valve 2-CH-192 (OMA 1) prior to BAST depletion. The licensee 
further stated that OMA 1 is performed in the fire affected area and is 
performed after the fire is extinguished and after the Station 
Emergency Response Organization (SERO) is fully staffed. OMA 1 
establishes the RWST as the suction supply for the charging system and 
is not conducted until after AFW is established which takes 17 minutes. 
The BASTs have a minimum TRM specified inventory to ensure 72 minutes 
of flow and OMA 1 can be completed in 32 minutes which results in 40 
minutes of margin.
3.2.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMA to establish Charging system flow from the RWST 
prior to BAST depletion can be completed in 32 minutes which provides a 
40 minute margin since the required completion time is 72 minutes.
3.2.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection and water curtain, it is unlikely that 
a fire would occur and go undetected or unsuppressed by the personnel, 
and damage the safe shutdown equipment. The low likelihood of damage to 
safe shutdown equipment due to a fire in this area, combined with the 
ability of the OMAs to manipulate the plant in the event of a fire that 
damages safe shutdown equipment and be completed with more than 30 
minutes of margin, provides adequate assurance that safe shutdown 
capability is maintained.

3.3 Fire Area R-5, ``A'' Safeguards Room (Containment Spray and High 
Pressure Safety Injection/Low Pressure Safety Injection Pump Room)

3.3.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
includes cable insulation and small amounts of lube oil and that 
potential ignition sources include electrical faults, pump motors, 
mechanical failure, and hot surfaces.
3.3.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with an ionization 
smoke detection system which alarms at a local panel and at the main 
fire alarm panel in the CR. The licensee also stated that a fire in 
this area that could potentially impact any cables of concern would 
likely involve cable insulation resulting from an electrical fault or a 
lube oil fire resulting from a pump and/or motor failure. Combustibles 
in this area consist predominantly of IEEE 383 qualified cable 
insulation or cable that has been tested and found to have similar fire 
resistive characteristics. The licensee further stated that since there 
is a minimal amount of Class A combustibles in this fire area, there is 
little chance of a fire occurring which could act as a pilot ignition 
source for the cable insulation and that while lube oil could also 
serve as a pilot ignition source for cable insulation, the small 
quantities of lube oil would result in a low intensity fire and based 
on the elevated ignition temperature of the lube oil and the low 
probability of a pump and/or motor assembly failure with subsequent 
ignition of the entire quantity of lube oil, it is unlikely that a lube 
oil fire from a pump and/or motor failure would serve as an ignition 
source for IEEE 383 qualified cable insulation. The licensee further 
stated that in the event of a fire in this area, it would be rapidly 
detected in its incipient stage by the installed smoke detection 
system, which will aid in providing rapid response by the Fire Brigade.
3.3.3 Preservation of Safe Shutdown Capability
    The licensee stated that a fire in the area that could potentially 
impact any cables of concern would likely involve cable insulation 
resulting from an electrical fault or a lube oil fire resulting from a 
pump and/or motor failure and that some Shutdown Cooling system 
components would be affected and that plant shutdown to Hot Standby can 
be accomplished using existing AOPs.
3.3.4 OMAs Credited for a Fire in This Area
3.3.4.1 AFW and Charging System Flow
3.3.4.1.1 OMAs 1 and 10--Open Valve 2-CH-192 and Operate Valve 2-MS-
190A
    The licensee stated that for a fire in fire area R-5, two OMAs are 
identified to provide for decay heat removal and restore charging 
system flow to the RCS, with the first OMA (OMA 10) being to open and 
modulate 2-MS-190A (ADV) and the second OMA (OMA 1) being to open valve 
2-CH-192. The licensee also stated that both OMAs are needed to 
compensate for a postulated loss of IA

[[Page 43391]]

and that neither valve will experience cable damage due to a fire in 
fire area R-5. The licensee further stated that the ADVs are utilized 
after AFW flow is established and that AFW is required to be 
established within 45 minutes and prior to this, RCS decay heat removal 
is provided by utilizing the MSSVs. The licensee further stated that 
steaming through the MSSVs is also acceptable after AFW flow is 
established, but utilizing the ADVs, with 2-MS-190A credited for a fire 
in fire area R-5, is required for maintaining the plant in Hot Standby 
and initiating the transition to Cold Shutdown. The licensee further 
stated that PEO-2 will remain with the ADV to modulate steam flow per 
direction from the CR and that PEO-1 will complete the second OMA by 
opening 2-CH-192 to establish the RWST as the source of water to the 
RCS. The licensee further stated that 2-CH-192 is an AOV which may have 
failed closed due to a loss of IA and that the valve has a safety-
related air accumulator which supplies sufficient air to stroke open 
the valve and maintain it open for three hours and that after the air 
accumulator is exhausted, the valve will fail closed. The licensee 
further stated that the required OMA establishes/maintains RWST flow to 
the Charging system and the BASTs have a minimum level specified in the 
TRM which ensures Charging flow for more than 72 minutes, at which time 
Charging pump suction is shifted to the RWST. The licensee further 
stated that calculations indicate that the Charging system must be 
restored within three hours, therefore, the accumulator capacity and 
the minimum TRM BAST level requirement require the OMA to locally open 
2-CH-192 be accomplished within three hours (prior to the air 
accumulator being exhausted).
3.3.4.2 OMA Timing
    AFW flow is established within the required 45 minute time period 
and should IA be lost, the OMA to continue decay heat removal can be 
conducted beginning 17 minutes after AFW flow is established. The OMA 
to establish Charging system flow from the RWST prior to BAST depletion 
can be completed in 32 minutes which provides a 40 minute margin since 
the required completion time is 72 minutes.
3.3.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection, it is unlikely that a fire would occur 
and go undetected or unsuppressed by the personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of the 
OMAs to manipulate the plant in the event of a fire that damages safe 
shutdown equipment and be completed with more than 30 minutes of 
margin, provides adequate assurance that safe shutdown capability is 
maintained.

3.4 Fire Area R-6, ``B'' Safeguards Room (Low Pressure Safety Injection 
Pump Room)

3.4.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
includes cable insulation and small amounts of lube oil and that 
potential ignition sources include electrical faults, pump motors, 
mechanical failure, and hot surfaces.
3.4.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with an ionization 
smoke detection system which alarms at a local panel and at the main 
fire alarm panel in the CR. The licensee also stated that a fire in the 
area that could potentially impact any cables of concern would likely 
involve cable insulation resulting from an electrical fault or a lube 
oil fire resulting from a pump and/or motor failure and that 
combustibles in this area consist predominantly of IEEE 383 qualified 
cable insulation or cable that has been tested and found to have 
similar fire resistive characteristics. The licensee further stated 
that since there is a minimal amount of Class A combustibles in this 
fire area, there is little chance of a fire occurring which could act 
as a pilot ignition source for the cable insulation and that while lube 
oil could also serve as a pilot ignition source for cable insulation, 
the small quantities of lube oil would result in a low intensity fire 
and based on the elevated ignition temperature of the lube oil and the 
low probability of a pump and/or motor assembly failure with subsequent 
ignition of the entire quantity of lube oil, it is unlikely that a lube 
oil fire from a pump and/or motor failure would serve as an ignition 
source for IEEE 383 qualified cable insulation. The licensee further 
stated that in the event of a fire in this area, it would be rapidly 
detected in its incipient stage by the installed smoke detection 
system, which will aid in providing rapid response by the Fire Brigade.
3.4.3 Preservation of Safe Shutdown Capability
    The licensee stated that a fire in the area that could potentially 
impact any cables of concern would likely involve cable insulation 
resulting from an electrical fault or a lube oil fire resulting from a 
pump and/or motor failure, that some Shutdown Cooling System components 
would be affected, that Hot Standby equipment will not be affected, and 
that plant shutdown to Hot Standby can be accomplished using an AOP.
3.4.4 OMAs Credited for a Fire in This Area
3.4.4.1 AFW and Charging System Flow
3.4.4.1.1 OMAs 1 and 10--Open Valve 2-CH-192 and Operate Valve 2-MS-
190A
    The licensee stated that for a fire in fire area R-6, two OMAs are 
identified, the first OMA (OMA 10) which is to open 2-MS-190A (ADV) and 
the second OMA (OMA 1) which is to open 2-CH-192. The licensee also 
stated that both OMAs are needed to compensate for a postulated loss of 
IA and that neither valve will experience cable damage due to a fire in 
fire area R-6. The licensee further stated that the ADVs are utilized 
after AFW flow is established, that AFW is not fire impacted, is 
required to be established within 45 minutes, and that prior to this, 
RCS decay heat removal is provided by steaming through the MSSVs which 
is also acceptable after AFW flow is established. Utilizing the ADVs, 
with 2-MS-190A credited for a fire in fire area R-6, is required for 
maintaining the plant in Hot Standby and initiating the transition to 
Cold Shutdown. The licensee further stated that PEO-2 will remain with 
the ADV to modulate steam flow per direction from the CR and that PEO-1 
will complete the second OMA by opening 2-CH-192 to establish the RWST 
as the source of water to the RCS and that 2-CH-192 is an air operated 
valve which may have failed closed due to a loss of IA. The licensee 
further stated that the valve has a safety-related air accumulator 
which supplies sufficient air to stroke open the valve and maintain it 
open for three hours and that after the air accumulator is exhausted, 
the valve will fail closed. The licensee further stated that the 
required OMA establishes/maintains RWST flow to the charging system and 
that the BASTs have a minimum level specified in the TRM which ensures 
charging flow for more than 72 minutes, at which time charging pump 
suction is shifted to the RWST and that

[[Page 43392]]

calculations indicate that the Charging system must be restored within 
three hours, and therefore, the accumulator and the minimum TRM BAST 
level requirement require the OMA to locally open 2-CH-192 be 
accomplished within three hours (prior to the accumulator being 
exhausted).
3.4.4.2 OMA Timing
    AFW flow is established within the required 45 minute time period 
and should IA be lost, the OMA to continue decay heat removal can be 
conducted beginning 17 minutes after AFW flow is established. The OMA 
to establish Charging system flow from the RWST prior to BAST depletion 
can be completed in 32 minutes which provides a 40 minute margin since 
the required completion time is 72 minutes.
3.4.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection, it is unlikely that a fire would occur 
and go undetected or unsuppressed by the personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of the 
OMAs to manipulate the plant in the event of a fire that damages safe 
shutdown equipment and to be completed with more than 30 minutes of 
margin, provides adequate assurance that safe shutdown capability is 
maintained.

3.5 Fire Area R-7, ``A'' Diesel Generator Room

3.5.1 Fire Prevention
    The licensee stated that the area has high combustible loading that 
includes diesel fuel and small amounts of lube oil and that potential 
ignition sources include motors, mechanical failure, and hot surfaces.
3.5.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with automatic pre-
action sprinkler protection to provide automatic suppression in/around 
the diesel generator as well as to provide cooling to the structural 
steel overhead and that the deluge valve for this system is opened by 
the installed heat detection system. The licensee also stated that the 
detection system alarms at the main fire alarm panel in the CR while 
the pre-action sprinkler system alarms at a local panel and at the main 
fire alarm panel in the CR.
    The licensee stated that a fire in the area that could potentially 
impact any cables of concern would likely involve diesel fuel oil and/
or lube oil resulting from a mechanical failure of the diesel generator 
or cable insulation resulting from an electrical fault and that 
combustibles in this area consist predominantly of IEEE 383 qualified 
cable insulation or cable that has been tested and found to have 
similar fire resistive characteristics. The licensee also stated that 
since there is a minimal amount of Class A combustibles in this area, 
there is little chance of a fire involving Class A combustibles 
occurring which could act as a pilot ignition source for the cable 
insulation and that while a fuel oil or lube oil fire could serve as a 
pilot ignition source to the cabling, it is expected that a fire 
involving Class B combustibles (flammable/combustible liquids) would be 
rapidly detected by the installed heat detection system and be 
suppressed by the installed suppression system and/or manual 
firefighting. The licensee further stated that the heat detection 
system would also aid in providing prompt Fire Brigade response were a 
fire to occur in this area.
3.5.3 Preservation of Safe Shutdown Capability
    The licensee stated that the components of concern for the area are 
valves 2-CH-192, 2-CH-508, and 2-CH-509 and that the loss of the EDG 
results in the loss of the Facility Z1 emergency power supply which 
results in the loss of power to the battery charger supplying the 
battery for valve 2-CH-192. The licensee also stated that the loss of 
the Facility Z1 emergency power causes the loss of power to valves 2-
CH-508 and 2-CH-509 and that a fire could also cause the failure of IA 
which would impact valves 2-CH-192 and 2-MS-190B.
    The licensee stated that a fire in the area will affect all 
Facility Z1 shutdown components, that Facility Z2 is used to achieve 
and maintain Hot Standby, and that plant shutdown to Hot Standby can be 
accomplished using an AOP.
3.5.4 OMAs Credited for a Fire in This Area
3.5.4.1 AFW and Charging System Flow
3.5.4.1.1 OMA 11--Control Valve 2-MS-190B at Panel C10 or Local Manual 
Operation
    The licensee stated that for a fire in the area, OMAs are required 
to provide decay heat removal and restore Charging system flow to the 
RCS, that AFW flow must be established to the credited SG within 45 
minutes, and that the required AFW flow path utilizes the TDAFW pump 
which is not fire impacted. The licensee also stated that once AFW flow 
is established from the CR, operation of an ADV (2-MS-190B) (OMA 11) is 
the method of removing decay heat to maintain the plant in Hot Standby 
and for initiating the transition to Cold Shutdown and that prior to 
AFW initiation, the plant is placed in the Hot Standby condition by 
steaming through the MSSVs. The licensee further stated that there is 
no cable damage from a fire in the area to the required ADV (2-MS-
190B), however, the fire may cause a loss of IA which is required to 
operate the ADVs to support decay heat removal. The licensee further 
stated that upon a loss of IA, the ADV will fail closed and this ``fail 
to closed'' design prevents excessive RCS cooldown prior to AFW start, 
and therefore, in the event of a loss of IA, Operators will establish 
local manual control of 2-MS-190B after AFW is established and that 
PEO-1 will remain with the ADV to modulate steam flow per direction 
from the CR.
3.5.4.1.2 OMAs 4, 5, and 1--Open Valve 2-CH-508, Open Valve 2-CH-509, 
and Open Valve 2-CH-192
    The licensee stated that for a fire in the area the Charging system 
has OMAs identified and that the BASTs gravity feed valves, 2-CH-508 
(OMA 4) and 2-CH-509 (OMA 5), may fail as is (closed) due to a loss of 
power supply. The licensee also stated that an OMA is in place to 
locally open the valves as part of restoring the Charging system and 
that once these valves are opened, the CR can establish charging flow 
within 2-3 minutes. The licensee further stated that establishing pump 
suction from the BASTs and restoring charging is required within three 
hours of reactor shutdown/loss of charging and charging is re-
established within 24 minutes (21 minutes to open BASTs valves and 3 
minutes to establish charging flow in the CR) which provides a 156 
minute margin. The licensee further stated that after the BASTs have 
reached the 10 percent level, Operators switch the charging suction 
flow path to the RWST and the 2-CH-192 (OMA 1) valve is required to be 
open to accomplish the switch over. The licensee further stated that 
evaluations conclude that the BASTs will last a minimum of 72 minutes 
after charging is re-established. The licensee stated that valve 2-CH-
192 fails closed in the event of a loss of its power supply and/or IA, 
but valve 2-CH-192 will remain operable using its backup air source 
until it and/or the Facility Z1 battery is depleted and that the backup 
air source is capable of opening the valve and maintaining it open for 
three hours. The licensee further stated that battery depletion will

[[Page 43393]]

not occur prior to exhausting the backup air source and that the OMA is 
not required prior to this time.
3.5.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMA to establish Charging system flow from the BASTs 
can be completed in 24 minutes which provides a 156 minute margin since 
the required completion time is 180 minutes. The OMA to establish 
Charging system flow from the RWST prior to BAST depletion can be 
completed in 32 minutes which provides a 40 minute margin since the 
required completion time is 72 minutes.
3.5.5 Conclusion
    Although a fuel oil or lube oil fire could serve as a pilot 
ignition source to cabling, it is expected that such a fire would be 
detected by the installed heat detection and controlled by the 
suppression system with additional suppression provided by manual 
firefighting, therefore, it is unlikely that a fire would occur and go 
undetected or unsuppressed and damage safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area, combined with the ability of the OMAs to manipulate the plant in 
the event of a fire that damages safe shutdown equipment and to be 
completed with more than 30 minutes of margin, provides adequate 
assurance that safe shutdown capability is maintained.

3.6 Fire Area R-8, ``B'' Diesel Generator Room

3.6.1 Fire Prevention
    The licensee stated that the area has high combustible loading that 
includes diesel fuel oil, small amounts of lube oil, and negligible 
amounts of cable insulation and that potential ignition sources include 
electrical faults, motors, mechanical failure and hot surfaces.
3.6.2 Detection, Control, and Extinguishment
    The licensee stated that this area is provided with automatic pre-
action sprinkler protection to provide automatic suppression in/around 
the diesel generator as well as to provide cooling to the structural 
steel overhead and that the deluge valve for this system is opened by 
the installed heat detection system. The licensee also stated that the 
detection system alarms at the main fire alarm panel in the CR while 
the pre-action sprinkler system alarms at a local panel and at the main 
fire alarm panel in the CR. The licensee stated that a fire in the area 
that could potentially impact any cables of concern would likely 
involve diesel fuel oil and/or lube oil resulting from a mechanical 
failure of the diesel generator or cable insulation resulting from an 
electrical fault and that combustibles in this area consist 
predominantly of IEEE 383 qualified cable insulation or cable that has 
been tested and found to have similar fire resistive characteristics. 
The licensee also stated that since there is a minimal amount of Class 
A combustibles in this area, there is little chance of a fire involving 
Class A combustibles occurring which could act as a pilot ignition 
source for the cable insulation and that while a fuel oil or lube oil 
fire could serve as a pilot ignition source to the cabling, it is 
expected that a fire involving Class B flammable/combustible liquids 
would be rapidly detected by the installed heat detection system and be 
suppressed by the installed suppression system and/or manual 
firefighting. The licensee further stated that the heat detection 
system would also aid in providing prompt Fire Brigade response were a 
fire to occur in this area.
3.6.3 Preservation of Safe Shutdown Capability
    The licensee stated that the OMAs associated with a fire in the 
area are related to failure of the ``B'' EDG resulting in the loss of 
power to breakers 24D, 22F and MCC B61, and the battery charger 
resulting in the depletion of the ``B'' battery and that a fire in this 
area could also cause the failure of IA.
    The licensee stated that a fire in the area will affect all 
Facility Z2 shutdown components, that Facility Z1 is used to achieve 
and maintain Hot Standby, and that plant shutdown to Hot Standby can be 
accomplished by using an AOP.
3.6.4 OMAs Credited for a Fire in This Area
3.6.4.1 AFW and Charging System Flow
3.6.4.1.1 OMAs 10 and 1--Operate Valve 2-MS-190A and Open Valve 2-CH-
192
    The licensee stated that for a fire in the area, two OMAs are 
identified, the first OMA (OMA 10) is to open 2-MS-190A (ADV) and the 
second OMA (OMA 1) is to open 2-CH-192. The licensee also stated that 
both OMAs are required to compensate for a postulated loss of IA and 
that neither valve will experience cable damage due to a fire in the 
area. The licensee further stated that the ADVs are utilized after AFW 
flow is established, that AFW is not fire impacted, is required to be 
established within 45 minutes and that prior to this, RCS decay heat 
removal is provided by steaming through the MSSVs which is also 
acceptable after AFW flow is established. The licensee further stated 
that utilizing the ADVs, with 2-MS-190A credited for the fire in the 
area, is required for maintaining the plant in Hot Standby and 
initiating the transition to Cold Shutdown, that PEO-1 will remain with 
the ADV to modulate steam flow per direction from the CR and that PEO-2 
will complete the second OMA by opening 2-CH-192 to establish the RWST 
as the source of water to the RCS. The licensee further stated that 2-
CH-192 is an AOV which may have failed closed due to a loss of IA, that 
the valve has a safety-related air accumulator which supplies 
sufficient air to stroke open the valve and maintain it open for three 
hours and that after the air accumulator is exhausted, the valve will 
fail closed. The licensee further stated that the required OMA 
establishes/maintains RWST flow to the Charging system and the BASTs 
have a minimum level specified in the TRM which ensures Charging flow 
for more than 72 minutes, at which time Charging Pump suction is 
shifted to the RWST. The licensee further stated that calculations 
indicate that the Charging system is to be restored within three hours, 
therefore, the accumulator and the minimum TRM BAST level requirement 
require the OMA to locally open 2-CH-192 within three hours (prior to 
the accumulator being exhausted).
3.6.4.1.2 OMA 20--Obtain CST Level at Local Level Indicating Switch 
LIS-5489A
    In their letter dated February 29, 2012 the licensee added OMA 20 
to the exemption request for fire area R-8. The licensee stated that a 
fire in the area could cause a loss of the ``B'' EDG resulting in the 
depletion of the ``B'' battery after 480 minutes causing a loss of 
level transmitter LT-5282 (CST Level) which will necessitate obtaining 
level readings locally at the tank using level indicator LIS-5489 (OMA 
20). The licensee also stated that the route to the CST is illuminated 
by emergency lighting units (ELUs), that checking the level of the CST 
supports AFW system operation and checking the level is not a short-
term requirement as there is sufficient inventory in the CST to provide 
over 10 hours of water flow to the AFW system. The licensee further 
stated that if necessary, after the CST is depleted, Operators can 
switch over to the fire water system and maintain flow to the AFW 
system.

[[Page 43394]]

3.6.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMA to check CST level can be completed in 6 minutes 
and is a long term action as the CST provides over 10 hours of 
inventory to AFW. The OMA to establish Charging system flow from the 
RWST prior to BAST depletion can be completed in 32 minutes which 
provides a 40 minute margin since the required completion time is 72 
minutes.
3.6.5 Conclusion
    Although a fuel oil or lube oil fire could serve as a pilot 
ignition source to cabling, it is expected that such a fire would be 
detected and suppressed by the installed heat detection and suppression 
system with additional suppression provided by manual firefighting, 
therefore, it is unlikely that a fire would occur and go undetected or 
unsuppressed and damage safe shutdown equipment. The low likelihood of 
damage to safe shutdown equipment due to a fire in this area, combined 
with the ability of the OMAs to manipulate the plant in the event of a 
fire that damages safe shutdown equipment and to be completed with more 
than 30 minutes of margin, provides adequate assurance that safe 
shutdown capability is maintained.

3.7 Fire Area R-9, ``A'' East DC Equipment Room

3.7.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
predominantly consists of cable insulation and that potential ignition 
sources include electrical faults.
3.7.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with a cross-zoned 
ionization and photoelectric smoke detection system that activates a 
total flooding Halon 1301 fire suppression system and that the Halon 
1301 suppression system has manual release stations at each doorway and 
an abort switch located at the doorway to the east CR/cable vault 
stairway. The licensee also stated that this system alarms locally at 
the Halon control panel and at the main fire alarm panel in the CR. The 
licensee further stated that duct smoke detection is provided between 
this area, the ``B'' (West) DC Equipment Room (FHA Zone A-21), and the 
auxiliary building cable vault (FHA Zone A-24) and that this system 
alarms at a local panel and at the main fire alarm panel in the CR. The 
licensee further stated that a fire in the area that could potentially 
impact any cables of concern would likely involve cable insulation 
resulting from an electrical fault or failure of a bus or electrical 
panel located in the room and that combustibles in this area consist 
predominantly of IEEE 383 qualified cable insulation or cable that has 
been tested and found to have similar fire resistive characteristics. 
The licensee further stated that since there is a minimal amount of 
Class A combustibles in this area, there is little chance of a fire 
occurring, outside of a bus/electrical panel failure, which could act 
as a pilot ignition source for the cable insulation and that a bus/
electrical panel failure normally results in a high intensity fire that 
lasts for a short duration, which makes it unlikely that it will cause 
sustained combustion of IEEE 383 qualified cables. The licensee further 
stated that in the unlikely event of a fire in this area, it would be 
rapidly detected by the cross-zoned ionization and photoelectric smoke 
detection system and subsequently extinguished by the total flooding 
Halon 1301 suppression system and that the smoke detection system would 
also aid in providing prompt Fire Brigade response.
3.7.3 Preservation of Safe Shutdown Capability
    The licensee stated that the OMAs associated with a fire in the 
area are related to loss of power to the ``A'' DC buses (such as DV10) 
and that cables for valves 2-CH-192, 2-CH-508, and 2-CH-509 do not pass 
through this room.
    The licensee stated that a fire in the area will affect all 
Facility Z1 shutdown components, that Facility Z2 is used to achieve 
and maintain Hot Standby, and that plant shutdown to Hot Standby can be 
accomplished using an AOP.
3.7.4 OMAs Credited for a Fire in This Area
    In their letter dated February 29, 2012 the licensee deleted OMAs 1 
and 11 from the exemption request for fire area R-9 since loss of IA is 
no longer postulated.
3.7.4.1 AFW and Charging System Flow
3.7.4.1.1 OMAs 4 and 5.--Open Valve 2-CH-508 and Open Valve 2-CH-509
    The licensee stated that for a fire in fire area R-9, the Charging 
system has OMAs identified and that the BASTs gravity feed valves, 2-
CH-508 (OMA 4) and 2-CH-509 (OMA 5), may fail as is (closed) due to a 
loss of power supply. The licensee also stated that an OMA is in place 
to locally open the valves as part of restoring the Charging system and 
that once these valves are opened, the CR can establish charging flow 
within 2-3 minutes. The licensee further stated that establishing 
charging pump suction from the BASTs and restoring charging is required 
within three hours of reactor shutdown/loss of charging and that 
Charging is re-established within 24 minutes (21 minutes to open the 
BASTs valves and 3 minutes to establish charging flow in the CR) which 
provides a 156 minute margin.
3.7.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period. The OMA to establish Charging system flow from the BASTs 
can be completed in 24 minutes which provides a 156 minute margin since 
the required completion time is 180 minutes.
3.7.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection and suppression, it is unlikely that a 
fire would occur and go undetected or unsuppressed by the personnel, 
and damage the safe shutdown equipment. The low likelihood of damage to 
safe shutdown equipment due to a fire in this area, combined with the 
ability of the OMAs to manipulate the plant in the event of a fire that 
damages safe shutdown equipment and to be completed with more than 30 
minutes of margin, provides adequate assurance that safe shutdown 
capability is maintained.

3.8 Fire Area R-10, ``B'' West DC Equipment Room

3.8.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
predominantly consists of cable insulation and that potential ignition 
sources include electrical faults.
3.8.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with a cross-zoned 
ionization and photoelectric smoke detection system that activates a 
total flooding Halon 1301 fire suppression system and that the Halon 
1301 suppression system has manual release stations at each doorway and 
an abort switch located at the doorway to the ``A'' (East) DC equipment 
room (FHA Zone A-20). The licensee also stated that this system alarms 
locally on the halon control panel and at the main fire alarm panel

[[Page 43395]]

in the CR. The licensee further stated that duct smoke detection is 
provided between this fire area, the ``A'' (East) DC Equipment Room 
(FHA Zone A-20), and the AB cable vault (FHA Zone A-24) and that this 
system alarms at a local panel and at the main fire alarm panel in the 
CR. The licensee further stated that a fire in the area that could 
potentially impact any cables of concern would likely involve cable 
insulation resulting from an electrical fault or failure of a bus or 
electrical panel located in the room and that combustibles in this area 
consist predominantly of IEEE 383 qualified cable insulation or cable 
that has been tested and found to have similar fire resistive 
characteristics. The licensee further stated that since there is a 
minimal amount of Class A combustibles in this area, there is little 
chance of a fire occurring, outside of a bus/electrical panel failure, 
which could act as a pilot ignition source for the cable insulation and 
that a bus/electrical panel failure normally results in a high 
intensity fire that lasts for a short duration, which makes it unlikely 
that it will cause sustained combustion of IEEE 383 qualified cables. 
The licensee further stated that in the unlikely event of a fire in 
this area, it would be rapidly detected by the cross-zoned ionization 
and photoelectric smoke detection smoke detection system and 
subsequently extinguished by the total flooding Halon 1301 suppression 
system installed in this area. The smoke detection system would also 
aid in providing prompt Fire Brigade response.
3.8.3 Preservation of Safe Shutdown Capability
    The licensee stated that the OMAs associated with a fire in the 
area are related to loss of power to the ``B'' AC vital power panels 
(such as VA20) and that cables for level transmitters LT-206, LT-208 
and LT-5282 do not pass through this room.
    The licensee stated that a fire in the area will affect all 
Facility Z2 shutdown components, that Facility Z1 is used to achieve 
and maintain Hot Standby, and that plant shutdown to Hot Standby can be 
accomplished using an AOP.
3.8.4 OMAs Credited for a Fire in This Area
    In their letter dated February 29, 2012 the licensee deleted OMA 1 
and 10 from the exemption request for fire area R-10 since loss of IA 
is no longer postulated.
3.8.4.1 AFW and Charging System Flow
3.8.4.1.1 OMA 20--Obtain CST Level at Local Level Indicating Switch 
LIS-5489A
    The licensee stated that a fire in area may cause cable damage to 
level transmitter LT-5282 (CST Level) which will necessitate obtaining 
level readings locally at the tank using level indicator LIS-5489 (OMA 
20). The licensee also stated that the route to the CST is illuminated 
by ELUs, that checking the level of the CST supports AFW system 
operation and checking the level is not a short-term requirement as 
there is sufficient inventory in the CST to provide over 10 hours of 
water flow to the AFW system. The licensee further stated that if 
necessary, after the CST is depleted, Operators can switch over to the 
fire water system and maintain flow to the AFW system.
3.8.4.1.2 OMAs 18 and 19--Obtain BAST Level at Local Level Indicator 
LI-206A and Obtain BAST Level at Local Level Indicator LI-208A
    The licensee stated that for a fire in the area, the Charging 
system has OMAs identified and that fire damage to cables may render 
level transmitters LT-206 and LT-208 (BAST Level) inoperable from the 
CR which would necessitate BAST level indication being obtained locally 
via level indicators LI-206A (OMA 18) and LI-206B (OMA 19). The 
licensee also stated that the TRM requires a minimum level be 
maintained in the BASTs and that maintaining this level provides a 
minimum of 72 minutes of charging flow to the RCS after charging is re-
established and that calculations indicate that charging must be 
restored within three hours of a reactor trip.
3.8.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period. The OMA to check CST level can be completed in 6 minutes 
and is a long term action as the CST provides over 10 hours of 
inventory to AFW. The OMAs to check BAST level can be completed in 12 
minutes which provides a 168 minute margin since the required 
completion time is 180 minutes.
3.8.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection and suppression, it is unlikely that a 
fire would occur and go undetected or unsuppressed by the personnel, 
and damage the safe shutdown equipment. The low likelihood of damage to 
safe shutdown equipment due to a fire in this area, combined with the 
ability of the OMAs to manipulate the plant in the event of a fire that 
damages safe shutdown equipment and to be completed with more than 30 
minutes of margin, provides adequate assurance that safe shutdown 
capability is maintained.

3.9 Fire Area R-12, Steam Driven Auxiliary Feedwater Pump Pit

3.9.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
includes lube oil only, that there is no cable insulation or Class A 
combustibles located in the area, and that potential ignition sources 
include electrical faults or the over-heating of a pump bearing.
3.9.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with an ionization 
smoke detection system which alarms at a local panel and at the main 
fire alarm panel in the CR. The licensee stated that a fire in the 
TDAFW Pump Pit that could potentially impact any cables of concern 
would likely involve a lube oil fire resulting from an auxiliary 
feedwater pump failure and that lube oil found within the steam driven 
AFW pump is the only contributing factor to the combustible loading of 
this area. The licensee also stated that the lube oil is completely 
enclosed within the pump housing, which would help in preventing 
ignition of the oil from an external ignition source and that there are 
no external ignition sources for the lube oil in this room. The 
licensee further stated that restrictive access to this pump room 
limits the amount of transient combustibles and ignition sources in 
this room and in the event of a fire in this room, the low combustible 
loading would result in a low intensity fire which would be rapidly 
detected in its incipient stage by the installed smoke detection 
system, which will aid in providing rapid response by the Fire Brigade.
3.9.3 Preservation of Safe Shutdown Capability
    The licensee stated that a fire in the area will affect only the 
TDAFW pump and its steam supply components, that no other Hot Standby 
equipment will be affected and the MDAFW pumps may be used to feed the 
SGs. The licensee also stated that plant shutdown to Hot Standby can be 
accomplished using existing shutdown procedures.

[[Page 43396]]

3.9.4 OMAs Credited for a Fire in This Area
3.9.4.1 AFW and Charging System Flow
3.9.4.1.1 OMA 10--Operate Valve 2-MS-190A and Open Valve 2-CH-192
    The licensee stated that for a fire in the area, two OMAs are 
identified, the first is to open 2-MS-190A (ADV) (OMA 10) and the 
second is to open 2-CH-192 (OMA 1). The licensee also stated that both 
OMAs are required to compensate for a postulated loss of IA, that 
neither valve will experience cable damage due to a fire in the area, 
and that the ADVs are utilized after AFW flow is established. The 
licensee further stated that AFW flow is required to be established 
within 45 minutes and that prior to this, RCS decay heat removal is 
provided by steaming through the MSSVs which is also acceptable after 
AFW flow is established. The licensee further stated that utilizing the 
ADVs, with 2-MS-190A credited for the fire in the area, is required for 
maintaining the plant in Hot Standby and the transition to Cold 
Shutdown, and that PEO-1 will remain with the ADV to modulate steam 
flow per direction from the CR. The licensee further stated that PEO-2 
will complete the second OMA by opening 2-CH-192 to establish the RWST 
as the source of water to the RCS. The licensee stated that 2-CH-192 is 
an AOV which may have failed closed due to a loss of IA and that the 
valve has a safety-related air accumulator which supplies sufficient 
air to stroke open the valve and maintain it open for three hours. 
After the air accumulator is exhausted, the valve will fail closed. The 
licensee further stated that the required OMA establishes/maintains 
RWST flow to the Charging system and that the BASTs have a minimum 
level specified in the TRM which ensures Charging flow for more than 72 
minutes, at which time Charging Pump suction is shifted to the RWST. 
The licensee further stated that calculations indicate that the 
Charging system must be restored within 3 hours, therefore, the 
accumulator capacity and the minimum TRM BAST level requirements 
require that this OMA be accomplished within three hours (prior to the 
accumulator being exhausted).
3.9.4.2 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMA to establish Charging system flow from the RWST 
prior to BAST depletion can be completed in 32 minutes which provides a 
40 minute margin since the required completion time is 72 minutes.
3.9.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection, it is unlikely that a fire would occur 
and go undetected or unsuppressed by the personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of the 
OMAs to manipulate the plant in the event of a fire that damages safe 
shutdown equipment and to be completed with more than 30 minutes of 
margin, provides adequate assurance that safe shutdown capability is 
maintained.

3.10 Fire Area R-13, West 480 V Load Center Room

3.10.1 Fire Prevention
    The licensee stated that the area has low combustible loading that 
predominantly consists of cable insulation and that potential ignition 
sources include electrical faults.
3.10.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with ionization smoke 
detection that alarms at the main fire alarm panel in the CR. The 
licensee also stated that a fire in the area that could potentially 
impact any cables of concern would likely involve cable insulation 
resulting from an electrical fault or a bus failure and that 
combustibles in the area consist predominantly of IEEE 383 qualified 
cable insulation or cable that has been tested and found to have 
similar fire resistive characteristics. The licensee further stated 
that since there is a minimal amount of Class A combustibles in this 
area, there is little chance of a fire occurring, outside of a bus 
failure, which could act as a pilot ignition source for the cable 
insulation. A bus failure normally results in a high intensity fire 
that lasts for a short duration, which makes it unlikely that it will 
cause sustained combustion of IEEE 383 qualified cables. The licensee 
further stated that in the unlikely event of a fire, it would be 
rapidly detected by the ionization smoke detection system installed in 
the area and that the smoke detection system will aid in providing 
prompt Fire Brigade response.
3.10.3 Preservation of Safe Shutdown Capability
    The licensee stated that the components of concern for the area are 
for valves 2-CH-192, 2-CH-508, 2-CH-509, 2-FW-43B and 2-MS-190B, 
breaker A406, H21 (TDAFW speed control circuit), level transmitter LT-
5282, P18C (``C'' charging pump), SV-4188 (TDAFW steam supply valve) 
and breaker DV2021.
    The licensee stated that a fire in the area will affect Facility Z1 
safe shutdown equipment, that the ``A'' EDG will be unavailable due to 
a loss of the Facility Z1 power supply for the diesel room ventilation 
fan F38A, that Facility Z2 is used to achieve and maintain Hot Standby, 
and that plant shutdown to Hot Standby can be accomplished using an 
AOP.
3.10.4 OMAs Credited for a Fire in This Area
    In their letter dated February 29, 2012, the licensee deleted OMAs 
1, 9, and 11, from the exemption request for fire area R-13 since loss 
of IA is no longer postulated.
3.10.4.1 AFW Flow
3.10.4.1.1 OMAs 22 and 17--Operate Supply Valve SV-4188 From Panel C10 
and Operate Turbine Driven AFW Pump Speed Control Circuit H-21 From 
Panel C10
    The licensee stated that for a fire in the area, OMAs are required 
to provide decay heat removal and restore Charging system flow to the 
RCS and that establishing AFW flow to the credited SG is required 
within 45 minutes. The licensee stated that for a fire in the area, the 
required AFW flow path utilizes the TDAFW pump and that due to fire 
induced cable damage, AFW turbine steam supply valve (SV-4188) (OMA 
22), and TDAFW turbine speed control (H21) (OMA 17) may not be 
available from the CR. The licensee further stated that the cable 
damage can be isolated and the TDAFW pump can be operated from the Fire 
Shutdown Panel (C-10) located in fire area R-2 and that an OMA is 
necessary to isolate the damaged cables and operate the TDAFW turbine 
speed control to maintain level in the SG. The licensee stated that in 
the case of 2-FW-43B, cable damage could result in spurious operation 
and that isolation of the affected cables and control of the valve can 
be accomplished at the C-10 panel, and that control of SG water level 
can be maintained using the speed control function of the TDAFW pump. 
The licensee further stated that the timeframe to establish control of 
TDAFW at the C-10 panel is 45 minutes and that after Reactor Operator 1 
(RO-1) has established control of TDAFW pump speed at the C-10 panel (8 
minutes), it will take an additional 2

[[Page 43397]]

minutes to establish AFW flow which results in a total time to 
establish AFW flow of 10 minutes, leaving a 35 minute margin.
3.10.4.1.2 OMA 20--Obtain CST Level at Local Level Indicating Switch 
LIS-5489A
    The licensee stated that valves 2-MS-190B and 2-FW-43B can be 
operated from the C-10 panel and that the OMA for local or C-10 
operation of 2-MS-190B is not required until after AFW flow is 
established and that PEO-1 will remain with the ADV to modulate steam 
flow per direction from the CR. The licensee further stated that the 
final decay heat removal function is to monitor CST level from either 
the C-10 panel (LT-5282) or locally at the CST (LIS-5489) (OMA 20) and 
that checking the level is not a short-term requirement because there 
is sufficient inventory in the CST to provide over 10 hours of water 
flow to the AFW system. The licensee further stated that a spurious 
start of the TDAFW coupled with 2-FW-43B failing open should not result 
in a SG overfill and that the nominal water level in the SG is 
maintained between 60-75% as indicated on the Narrow Range (NR) level 
instruments (i.e. the normal operating band). The licensee further 
stated that from the top of the normal operating band, more than 8000 
gallons of water can be added before reaching 100 percent on the NR 
level instruments and allotting 8 minutes to establish operations from 
the C-10 panel and assuming all the flow from the TDAFW is filling one 
SG, approximately 4800 gallons can be added before regaining level 
control. The licensee further stated that there is also an additional 
14,000 gallons of margin available before the SG would overfill (i.e. 
from 100 percent NR to the Main Steam nozzle).
3.10.4.2 Charging System Flow
3.10.4.2.1 OMAs 4, 5, 16, 21, and 24--Open Valve 2-CH-508, Open Valve 
2-CH-509, Pull Control Power Fuses for Breaker A406 and Ensure Breaker 
Is Open, Operate Pump P18C From Panel C10, and Locally Close Breaker 
DV2021
    The licensee stated that for a fire in the area, the Charging 
system has OMAs identified. The BASTs gravity feed valves, 2-CH-508 and 
2-CH-509, may fail as is, (closed) due to cable damage and that OMAs 
are (OMA 4 and 5) in place to locally open these valves as part of 
restoring the Charging system. The licensee further stated that cable 
damage due to fire may also cause a spurious start of the P18C Charging 
Pump and that cable damage may be mitigated by isolating and operating 
P18C (OMA 21) at the C-10 panel. The licensee further stated that RO-1 
is at C-10 and must manipulate the controls for P18C and that 
establishing pump suction from the BASTs and operating P18C is required 
within 3 hours of reactor shutdown/loss of Charging. The licensee 
further stated that completing the OMAs to re-establish Charging would 
take 23 minutes leaving a margin of 157 minutes, which includes the 
parallel actions of PEO-2 establishing control of Bus 24D (by pulling 
control power fuses to circuit breaker A406 (OMA 16), ensuring A406 is 
open and closing breaker DV2021 (OMA 24) and PEO-3 (by manually 
aligning valves 2-CH-508 and 2-CH-509). The licensee further stated 
that after the BASTs have reached the 10 percent level, Operators 
switch Charging Pump suction over to the RWST and valve 2-CH-192 may 
fail closed due to a loss of power supply, but it can be controlled 
from the CR.
3.10.4.4 OMA Timing
    The OMAs to establish AFW flow can be completed in 10 minutes which 
provides a 35 minute margin since the required completion time is 45 
minutes. The OMA to check CST level can be completed in 3 minutes and 
is a long term action as the CST provides over 10 hours of inventory to 
AFW. The OMAs to establish Charging system flow from the BASTs can be 
completed in 23 minutes which provides a margin of 157 minutes since 
the required completion time is 180 minutes.
3.10.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection, it is unlikely that a fire would occur 
and go undetected or unsuppressed by the personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of the 
OMAs to manipulate the plant in the event of a fire that damages safe 
shutdown equipment and to be completed with more than 30 minutes of 
margin, provides adequate assurance that safe shutdown capability is 
maintained.

3.11 Fire Area R-14, Lower 6.9 and 4.16 kV Switchgear Room, East Cable 
Vault

3.11.1 Fire Prevention
    The licensee stated that the areas have low combustible loading 
that predominantly consists of cable insulation and Thermo-Lag fire 
resistant wrap, and that potential ignition sources include electrical 
faults.
3.11.2 Detection, Control, and Extinguishment
    The licensee stated that the Lower 6.9 and 4.16 kV Switchgear Room 
contains ionization smoke detectors located directly over each 
switchgear cabinet that alarm at the main fire alarm panel in the CR. 
The licensee also stated that a fire in the Lower 6.9 and 4.16 kV 
Switchgear Room that could potentially impact cables of concern would 
likely involve cable insulation resulting from an electrical fault in 
one of the cable trays routed over Bus 24E or failure of Bus 24E 
itself. Combustibles in this area consist predominantly of IEEE 383 
qualified cable insulation or cable that has been tested and found to 
have similar fire resistive characteristics. The licensee further 
stated that since there is a minimal amount of Class A combustibles in 
this area, there is little chance of a fire occurring, outside of a 
switchgear failure, which could act as a pilot ignition source for the 
cable insulation and that a switchgear failure normally results in a 
high intensity fire that lasts for a short duration, which makes it 
unlikely that it will cause sustained combustion of IEEE 383 qualified 
cables. The licensee further stated that in the unlikely event of a 
fire, it would be rapidly detected by the ionization smoke detection 
system installed in the area and that the smoke detection system, which 
consists of an ionization smoke detector located directly over each 
switchgear cabinet in the area, will aid in providing prompt Fire 
Brigade response.
    The licensee stated that the East Cable Vault is provided with an 
automatic wet-pipe sprinkler system designed to protect structural 
steel and an ionization smoke detection system that alarms at the main 
fire alarm panel in the CR. The licensee also stated that the vertical 
cable chase that leads down the AB cable vault is protected by an 
automatic deluge spray system which is actuated by a cross-zoned smoke 
detection system that alarms at a local panel and at the main fire 
alarm panel in the CR. The licensee further stated that a fire in the 
area that could potentially impact any cables of concern would likely 
involve cable insulation resulting from an electrical fault and that 
combustibles in this area consist predominantly of IEEE 383 qualified 
cable insulation or cable that has been tested and found to have 
similar fire resistive characteristics. The licensee further stated 
that since there is a minimal amount of Class A combustibles in this 
area, there is little chance of a fire

[[Page 43398]]

occurring which could act as a pilot ignition source for the cable 
insulation. The licensee further stated that Thermo-Lag, while 
considered combustible, is one-hour fire rated in this area and that 
based on its fire resistive qualities and lack of ignition sources, a 
fire involving Thermo-Lag wrap is not credible. The licensee further 
stated that in the event of a fire in this area, it would be rapidly 
detected in its incipient stage by the installed smoke detection 
system, which will aid in providing rapid response by the Fire Brigade. 
In the unlikely event the fire advanced beyond its incipient stage 
(unlikely based on type of cable insulation and Fire Brigade 
suppression activities), it would actuate the installed automatic wet-
pipe suppression system provided in this area which will, at a minimum, 
provide reasonable assurance that a cable tray fire in this area will 
be controlled and confined to the immediate area of origin.
3.11.3 Preservation of Safe Shutdown Capability
    The licensee stated that a fire in the Facility Z1 Lower 4.16 kV 
Switchgear Room and Cable Vault will affect all Facility Z1 shutdown 
components, that Facility Z2 is used to achieve and maintain Hot 
Standby, that plant shutdown to Hot Standby can be accomplished using 
an AOP and that OMAs are required to provide decay heat removal and 
restore Charging system flow to the RCS.
    The licensee stated that the cables of concern in the East Cable 
Vault are the control and indication cabling for valve 2-FW-43B. The 
licensee also stated that cables for valves 2-CH-192, 2-CH-508 and 2-
CH-509 are not located in this room, however, valves 2-CH-508 and 2-CH-
509 are impacted due to the potential loss of the feed cables for bus 
22E or the ``A'' EDG's control and power cables which results in the 
loss of power to the valves.
3.11.4 OMAs Credited for a Fire in This Area
    In their letter dated February 29, 2012, the licensee deleted OMAs 
1, 9 and 11 from the exemption request for fire area R-14 since loss of 
IA is no longer postulated.
    The licensee stated that during verification and validation of the 
AOPs, it was identified that for a fire in fire area R-14 an additional 
operator might be necessary to place the plant into hot standby. The 
staffing requirements for MPS2 were changed to add one licensed or non-
licensed operator over the minimum technical specification (TS) 
requirement to be on duty each shift during Modes 1, 2, 3, or 4, with 
this operator being designated as the Appendix R operator and is not 
part of the credited five man Fire Brigade crew.
3.11.4.1 Charging System Flow
3.11.4.1.1 OMAs 4 and 5--Open Valve 2-CH-508 and Open Valve 2-CH-509
    The licensee stated that the Charging system has OMAs identified in 
that the BASTs gravity feed valves, 2-CH-508 and 2-CH-509, may fail as 
is (closed) due to a loss of power supply and that OMAs are in place 
(OMA 4 for 2-CH-508 and OMA 5 for 2-CH-509) to locally open these 
valves as part of restoring the Charging system. The licensee further 
stated that establishing Charging Pump suction from the BASTs is 
required within 3 hours of reactor shutdown/loss of Charging and that 
RO-1 and PEO-3 will perform their OMAs in parallel (see Section 
3.11.4.1.2) to restore Charging. OMAs 4 and 5 are completed in 21 
minutes.
3.11.4.1.2 OMAs 13, 14, 15, 23, and 24--Pull Control Power Fuses for 
Breaker A408 and Ensure Breaker Is Open, Pull Control Power Fuses for 
Breaker A410 and Ensure Breaker Is Open, Pull Control Power Fuses for 
Breaker A411 and Ensure Breaker Is Open, Pull Control Power Fuses for 
Breaker A401 and Ensure Breaker Is Closed, and Locally Close Breaker 
DV2021
    The licensee stated that as part of the restoration of Charging 
flow to the RCS, Bus 24D must be isolated from cross-ties to Bus 24B, 
Bus 24E and the RSST and that this is due to fire-induced cable damage 
which may result in spurious operation/loss of control from the CR of 
breakers A401, A410, A408 and A411. The OMAs associated with these 
breakers are to pull the control power fuses and ensure that breakers 
A410 (OMA 14), A408 (OMA 13) and A411 (OMA 15) are open and that 
breaker A401 (OMA 23) is closed. The licensee also stated that once RO-
1 completes the OMAs, PEO-1 will then reset and close breaker DV2021 
(OMA 24). OMAs 13, 14, 15, 23 and 24 are completed in 24 minutes, then 
it will take an additional 3 minutes for the CR to establish Charging 
flow for a total of 27 minutes which results in a 153 minute margin 
since the required completion time is 180 minutes.
3.11.4.2 OMA Timing
    The OMAs to establish Charging system flow from the BASTs can be 
completed in 27 minutes which provides for a margin of 153 minutes 
since the required completion time is 180 minutes.
3.11.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources and installed detection (Lower 6.9 and 4.16 kV Switchgear Room) 
and installed detection and suppression (East Cable Vault), it is 
unlikely that a fire would occur and go undetected or unsuppressed by 
the personnel and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area, combined with the ability of the OMAs to manipulate the plant in 
the event of a fire that damages safe shutdown equipment and to be 
completed with more than 30 minutes of margin, provides adequate 
assurance that safe shutdown capability is maintained.

3.12 Fire Area R-15, Containment Building

3.12.1 Fire Prevention
    The licensee stated that the area has low combustible loading 
including cable insulation and small amounts of lube oil and that 
potential ignition sources include electrical faults, motors, 
mechanical failure, and hot surfaces.
3.12.2 Detection, Control, and Extinguishment
    The licensee stated that the area is provided with smoke detection 
at each of the East and West Electrical Penetration Areas on the 14'-
6'' elevation and that the system alarms at a local panel and at the 
main fire alarm panel in the CR. The licensee also stated that heat 
detection is provided for each of the Reactor Coolant Pumps (RCPs) and 
that during refueling outages, the fire protection header within 
Containment is charged, with hose stations available on all elevations 
with the exception of the 3'-6'' elevation. The licensee further stated 
that during normal plant operation, fire protection piping within the 
Containment is not charged. The licensee further stated that a fire in 
the Containment that could potentially impact any cables of concern 
would likely involve cable insulation resulting from an electrical 
fault and that combustibles in this area consist predominantly of IEEE 
383 qualified cable insulation or cable that has been tested and found 
to have similar fire resistive characteristics. The licensee further 
stated that during plant operation, there are negligible amounts of 
Class A combustibles in this area, and therefore, there is little 
chance of a fire occurring which could act as a pilot ignition source 
for the cable insulation. If a cable fire does occur, it would be 
rapidly detected by the smoke detection

[[Page 43399]]

system installed at the east and west electrical penetration areas on 
the 14'-6'' elevation of the Containment, alerting the CR to a fire 
condition in Containment. The licensee further stated that a lube oil 
fire serving as a pilot ignition source to cable in the Containment is 
not a realistic scenario, that lube oil in this fire area is 
predominantly associated with the four RCPs and that while a failure of 
one of these RCP motors and a subsequent lube oil fire could be 
postulated, each of the RCP motors (located on the 14'-6'' Elevation of 
Containment) is partially enclosed in reinforced concrete compartments 
and the floor beneath the RCPs drains to the lowest elevation of 
Containment (22'-6'' Elevation). The licensee further stated that 
cabling in the Containment is routed outside of these concrete 
compartments along the outer annulus of the Containment and would be 
shielded from an RCP motor fire. The licensee further stated that based 
on the large volume of the Containment, the heat and hot gasses 
generated by an RCP motor lube oil fire would rise to the upper 
elevations of the Containment away from the cable tray concentrations 
located at the East and West Electrical Penetration Areas on the 14'-
6'' elevation of the Containment. If an RCP motor lube oil fire does 
occur, it would be detected in its incipient stage by the installed 
heat detection system that protects the RCP motors, alerting the CR to 
a fire condition in Containment.
3.12.3 Preservation of Safe Shutdown Capability
    The licensee stated that the cables of concern for the Containment 
are the power and indication cables for valves 2-CH-517 and 2-CH-519.
    The licensee stated that a fire in the Containment will affect a 
significant amount of instrumentation needed to monitor plant 
parameters and that a review of all instrument cables inside the 
Containment indicates that compliance with separation criteria was 
achieved with the exception of the Pressurizer cubicle. The separation 
issues inside Containment have been evaluated as follows:
    1. Separation criteria were evaluated for the Pressurizer cubicle 
to address instruments LT-11OX, LT-1 10Y, PT-102A, and PT-102B 
(instruments located on Racks C140 and C211 in the NE quadrant of 
containment) and instruments PT-103 and PT-103-1.
    2. Separation criteria were evaluated for the remainder of the 
instruments required for safe shutdown (RCS temperature, SG level and 
pressure, core exit thermocouples, nuclear instruments (NIs), 
containment temperature) and the sensing lines for the pressurizer 
level and pressurizer pressure instruments.
    The licensee stated that plant shutdown to Hot Standby can be 
accomplished using an AOP and that for a fire in the area, OMAs are 
required to provide decay heat removal and restore Charging system flow 
to the RCS.
3.12.4 OMAs Credited for a Fire in This Area
3.12.4.1 AFW Flow
3.12.4.1.1 OMAs 10 and 11--Operate Valve 2-MS-190A and Control Valve 2-
MS-190B at Panel C10 or Local Manual Operation
    The licensee stated that for decay heat removal, after AFW flow is 
established from the CR in the required 45 minute time period, 
Operators will transfer from steaming through the MSSVs to steaming 
through the ADVs and that for a fire in the area, both ADVs (2-MS-190A 
and 2-MS-190B) are required. The licensee also stated that operators 
must first determine which SG instruments are available and that if SG1 
instrumentation is available, then 2-MS-190A (OMA 10) ADV will be 
utilized for the decay heat steam path, and if SG2 instrumentation is 
available, then the 2-MS-190B (OMA 11) ADV will be utilized for the 
decay heat steam path. The licensee further stated that neither ADV is 
fire affected, however, the fire may cause a loss of IA which is 
required to operate the ADVs to support decay heat removal. The 
licensee further stated that upon a loss of IA, the ADV will fail 
closed and that this ``fail to closed'' design prevents excessive RCS 
cooldown prior to AFW start. In the event of a loss of IA, operators 
will establish local manual control of 2-MS-190A or 2-MS-190B after AFW 
flow is established. The licensee further stated that PEO-1 will remain 
with the ADV to modulate steam flow per direction from the CR. OMAs 10 
and 11 can begin 17 minutes after AFW is established by the CR.
3.12.4.2 Charging System Flow
3.12.4.2.1 OMAs 6 and 7--Open Breaker to Fail Valve 2-CH-517 Closed and 
Open Breaker to Fail Valve 2-CH-519 Open
    The licensee stated that the Charging system OMAs are for possible 
spurious operation of valves 2-CH-517, 2-CH-518, and 2-CH-519, due to 
fire-induced cable damage and that these valves are located in 
Containment. The licensee also stated that PEO-3 opens breakers to 
place the valves in their required positions and for valve 2-CH-517 
(OMA 6), breaker DV2012 is opened which will fail the valve in the 
closed position and that this breaker manipulation will also fail 2-CH-
519 (OMA 7) in its required open position. The licensee further stated 
that valve 2-CH-518 is not required for a fire in the area, but will be 
failed open (desired position) when other power circuits are isolated 
and that once PEO-3 completes the OMA in 7 minutes, it takes 
approximately 3 additional minutes for the CR to re-establish Charging 
flow which provides a 170 minute margin.
3.12.4.2.2 OMA 1--Open Valve 2-CH-192
    The licensee stated that although not fire affected, valve 2-CH-192 
will failed closed after the isolation of power to Containment which 
will necessitate an OMA (OMA 1) to establish the RWST as the source of 
water to the RCS once the BASTs are depleted. The licensee also stated 
that a minimum switch-over time of 72 minutes, after charging has been 
restored, has been established based on the TRM BAST level requirements 
and that calculations conclude that the Charging system must be 
restored within 3 hours, therefore, the initial alignment of 2-CH-517 
and 2-CH-519 will take place within 3 hours. The licensee further 
stated that establishing the RWST as a flow path to the RCS is not 
required until 1.2 hours after Charging is re-established.
3.12.4.3 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMAs to establish Charging system flow from the BAST 
can be completed in 10 minutes which provides a margin of 170 minutes 
since the required completion time is 180 minutes. The OMA to establish 
Charging system flow from the RWST prior to BAST depletion can be 
completed in 32 minutes which provides a 40 minute margin since the 
required completion time is 72 minutes.
3.12.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, installed partial detection, and separation from the RCPs, it 
is unlikely that a fire would occur and go undetected or unsuppressed 
by the personnel and damage the safe shutdown equipment. There is a low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area. The ability of the OMAs to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, to be

[[Page 43400]]

completed with more than 30 minutes of margin, provides adequate 
assurance that safe shutdown capability is maintained.

3.13 Fire Area R-17, East Electrical Penetration Area, East Main Steam 
Safety Valve/Blowdown Tank Room, East Piping Penetration Area

3.13.1 Fire Prevention
    The licensee stated that the East Electrical Penetration Area has 
moderate combustible loading that includes cable insulation and small 
amounts of plastics and that potential ignition sources include 
electrical faults.
    The licensee stated that the East Main Steam Safety Valve/Blowdown 
Tank Room has low combustible loading that consists entirely of cable 
insulation and that potential ignition sources include electrical 
faults.
    The licensee stated that the East Piping Penetration Area has low 
combustible loading that includes Class A combustibles (e.g., rubber) 
and that potential ignition sources include transient ignition sources 
(e.g. hotwork).
3.13.2 Detection, Control, and Extinguishment
    The licensee stated that the East Electrical Penetration Area is 
provided with an ionization smoke detection system which alarms at the 
main fire alarm panel in the CR. The licensee also stated that a fire 
in the area that could potentially impact a cable of concern would 
likely involve cable insulation resulting from an electrical fault. The 
licensee stated that combustibles in this area consist predominantly of 
IEEE 383 qualified cable insulation or cable that has been tested and 
found to have similar fire resistive characteristics. The licensee 
further stated that the cable trays in this area are predominantly 
located towards the southern and eastern end of the room, while the 
Class A combustibles are located predominantly towards the northern end 
of the room. Based on the location of the Class A combustibles in 
relation to the cable trays in this area, there is little chance of a 
fire occurring which could act as a pilot ignition source for the cable 
insulation. Based on the length of the east wall (55 feet), the 
distance between the cable trays and the Class A combustibles is 
approximately 45 feet. The licensee further stated that a failure of 
motor control center (MCC) B-31B could also serve as an ignition source 
and that an MCC failure normally results in a high intensity fire that 
lasts for a short duration, which makes it unlikely that it will cause 
sustained combustion of IEEE 383 qualified cables. In order to impact 
the subject cable trays, an MCC failure would have to ignite a cable 
tray located immediately above the MCC. The fire would also have to 
propagate via the cable tray until it reached any cables of concern. 
The licensee further stated that based on the discussion above, the 
postulated fire scenario is highly unlikely. The characteristics of an 
MCC failure and the fire retardant properties of IEEE 383 cabling also 
make it implausible that failure of hydrogen analyzers C86 or C87 would 
result in the ignition of a cable tray located several feet above the 
analyzers. The heavy construction of the hydrogen analyzer cabinets 
would further preclude this event. The licensee further stated that in 
the event of a fire in this area, it would be rapidly detected in its 
incipient stage by the installed smoke detection system, which will aid 
in providing rapid response by the Fire Brigade.
    The licensee stated that a fire in the East Main Steam Safety 
Valve/Blowdown Tank Room that could potentially impact the cables of 
concern would likely involve cable insulation resulting from an 
electrical fault and that combustibles in this area consist 
predominantly of IEEE 383 qualified cable insulation or cable that has 
been tested and found to have similar fire resistive characteristics. 
The licensee also stated that since the amount of Class A combustibles 
in this fire area is negligible, there is little chance of a fire 
occurring which could act as a pilot ignition source for the cable 
insulation and in the unlikely event of a fire in this fire area, the 
high ceiling and the large volume of this room would preclude a large 
rise in temperature in the areas where the subject cable trays or 
conduits are routed, reducing the likelihood that they would be damaged 
by the fire.
    The licensee stated that the East Piping Penetration Area is not 
provided with a smoke detection system, however, due to the openings in 
the ceiling of this area, the ionization smoke detection system located 
at the ceiling of the east electrical penetration area (FHA Zone A-10B) 
would provide supplemental coverage to detect a fire in this area. The 
licensee stated that a fire in the East Piping Penetration Area that 
could potentially impact any cables of concern would likely involve 
Class A combustibles from a transient ignition source. Based on the 
controls placed on transient combustibles and transient ignition 
sources, it is unlikely a fire would occur in this area. The licensee 
also stated that all hot work evolutions in the plant are procedurally 
required to have a fire watch in place. Hot work fire watches are 
individuals stationed in plant areas for the purpose of fire safety for 
workers and welders, detecting and suppressing smoke, fire, flames, or 
sparks as a result of hot work such as welding, cutting, or grinding. 
If a fire starts as a result of hot work, it would be detected in its 
incipient stages. The licensee further stated that since the amount of 
Class A combustibles in this area is small, a fire in this room is 
unlikely to occur. If a fire did occur, it would be of low intensity 
and would not likely be of sufficient magnitude to impact cable routed 
in conduit. The licensee further stated that the high ceiling of this 
room and the fact that this area opens up to the east electrical 
penetration area above (FHA Zone A-10B) would preclude a large rise in 
temperature in the areas where the subject conduits are routed, 
lessening the likelihood that they would be damaged by the fire.
3.13.3 Preservation of Safe Shutdown Capability
    The licensee stated that OMAs associated with a fire in the East 
Electrical Penetration Area are related to failure of the ``A'' EDGs 
power or control cables resulting in the loss of power to buses 24C, 
22E, B51 and the battery charger, which results in the depletion of the 
``A'' battery and that a fire in this area could also cause the failure 
of IA.
    The licensee stated that the OMAs associated with a fire in the 
East Main Steam Safety Valve/Blowdown Tank Room are related to failure 
of IA and that cables for valves 2-CH-192 and 2-MS-190B do not enter 
this room.
    The licensee stated that in the event of a fire in the East 
Penetration Area which could affect Facility Z1 shutdown components, 
Facility Z2 is used to achieve and maintain Hot Standby and that plant 
shutdown to Hot Standby can be accomplished using an AOP. The licensee 
also stated that for a fire in the area, OMAs are required to provide 
decay heat removal and restore charging system flow to the RCS.
3.13.4 OMAs Credited for a Fire in This Area
3.13.4.1 AFW Flow
3.13.4.1.1 OMA 11--Control Valve 2-MS-190B at Panel C10 or Local Manual 
Operation
    The licensee stated that establishing AFW flow to the credited SG 
is required within 45 minutes and that for a fire in the area, the 
required AFW flow path utilizes the TDAFW pump. The licensee

[[Page 43401]]

also stated that once AFW flow is established from the CR, operation of 
the ADV (2-MS-190B) (OMA 11) is the required method for maintaining the 
plant in Hot Standby and transitioning to Cold Shutdown and that prior 
to AFW initiation, the plant is placed in the Hot Standby condition by 
steaming through the MSSVs. The licensee further stated that a fire in 
the area would not damage any cables associated with ADV (2-MS-1 90B), 
however, the fire might cause a loss of IA which is required to operate 
the ADVs and support decay heat removal. The licensee further stated 
that upon a loss of IA, the ADV will fail closed and that this ``failed 
to close'' design prevents excessive RCS cooldown prior to AFW start. 
Therefore, in the event of a loss of IA, Operators will establish local 
manual control of 2-MS-190B after AFW flow is established. The licensee 
further stated that PEO-1 will remain with the ADV to modulate steam 
flow per direction from the CR.
3.13.4.2 Charging System Flow
3.13.4.2.1 OMAs 4, 5 and 1--Open Valve 2-CH-508, Open Valve 2-CH-509, 
and Open Valve 2-CH-192
    The licensee stated that for a fire in the area, the Charging 
system has OMAs identified as the BASTs gravity feed valves, 2-CH-508 
and 2-CH-509, might fail as is (closed) due to a loss of power supply. 
The licensee also stated that OMAs (OMA 4 and 5) are in place to 
locally open these valves as part of restoring the Charging system and 
that once these valves are opened, the CR can establish Charging flow 
within 2-3 minutes. The licensee further stated that establishing 
Charging Pump suction from the BASTs is required within 3 hours of 
reactor shutdown/loss of charging, and Charging is therefore re-
established within 24 minutes (21 minutes to open BASTs valves and 3 
minutes to establish charging flow from the CR) which provides a 156 
minute margin. The licensee further stated that after the BASTs have 
reached the 10 percent level, Operators switch the charging pump 
suction over to the RWST and that valve 2-CH-192 will fail closed when 
DV1013 is opened to mitigate spurious operation of 2-CH-518 and that an 
OMA is required to open 2-CH-192 (OMA 1) once the BASTs supply to 
charging is exhausted. The licensee further stated that evaluations 
conclude that the BASTs will last a minimum of 72 minutes after 
Charging is re-established and that the OMA is not required to be 
performed prior to this time.
3.13.4.3 OMA Timing
    AFW flow is established from the CR within the required 45 minute 
time period and should IA be lost, the OMA to continue decay heat 
removal can be conducted beginning 17 minutes after AFW flow is 
established. The OMAs to establish Charging system flow from the BAST 
can be completed in 24 minutes which provides a margin of 156 minutes 
since the required completion time is 180 minutes. The OMA to establish 
Charging system flow from the RWST prior to BAST depletion can be 
completed in 32 minutes which provides a 40 minute margin since the 
required completion time is 72 minutes.
3.13.5 Conclusion
    Given the limited amount of combustible materials and ignition 
sources, administrative controls, available margin (40 minutes), and 
installed detection in the East Electrical Penetration Area, it is 
unlikely that a fire would occur and go undetected or unsuppressed by 
the personnel, and damage the safe shutdown equipment.
    The East Piping Penetration Room has limited combustible materials 
and ignition sources and lacks credible fire scenarios, but is not 
provided with detection. However, due to the openings in the ceiling, 
the detection located in the East Electrical Penetration Area provides 
some coverage to the East Piping Penetration Room. A fire in this room, 
although unlikely, would be expected to be of low intensity and not 
likely to impact cable routed in conduit. In addition, the high ceiling 
and ceiling openings to the East Electrical Penetration Area would 
preclude a large rise in temperature reducing the likelihood that 
cables would be damaged by the fire. The limited amount of combustible 
materials and ignition sources, administrative controls, and lack of 
credible fire scenarios, combined with the ability of the OMAs with 
available margin (40 minutes) to manipulate the plant, in the unlikely 
event of a fire that damages safe shutdown equipment, provides adequate 
assurance that safe shutdown capability can be maintained.
    The East Main Steam Safety Valve/Blowdown Tank Room has limited 
combustible materials and ignition sources and lacks credible fire 
scenarios, but is not provided with detection. However, since the 
amount of Class A combustibles is small, there is little likelihood of 
a fire occurring which could act as a pilot ignition source for the 
cable insulation. In addition, the high ceiling and the large volume 
would preclude a large rise in temperature where the cable trays or 
conduits are routed, reducing the likelihood of cable damage. The 
limited amount of combustible materials and ignition sources, 
administrative controls, and lack of credible fire scenarios, combined 
with the ability of the OMAs with available margin (40 minutes) to 
manipulate the plant in the unlikely event of a fire that damages safe 
shutdown equipment, provides adequate assurance that safe shutdown 
capability can be maintained.

3.14 Feasibility and Reliability of the Operator Manual Actions

    In their February 29, 2012 letter, the licensee stated that the 
means to safely shutdown MPS2 in the event of a fire that does occur 
and is not rapidly extinguished, as expected, has been documented in 
the Appendix R Compliance report. The entire Appendix R Compliance 
report was not reviewed by the NRC as part of this exemption, the 
relevant information was submitted on the docket in the letters 
identified above. The sections below outline the licensees basis for 
the OMA's feasibility and reliability.
    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 MPS2 analysis of these criteria for justifying the OMAs 
specified in this exemption.
3.14.1 Bases for Establishing Feasibility and Reliability
    The licensee stated that in establishing the assumed times for 
operators to perform various tasks, a significant margin (i.e., a 
factor of two) was used with respect to the required time to establish 
the system function for all fire area scenarios identified in the 
exemption request (with the exception of RWST flow to charging). For 
example, the Time Critical Action (TCA) to establish AFW flow is 
validated to be able to be completed within 22.5 minutes, which 
provides a factor of two margin of the 45 minute timeframe used in the 
fire scenario analysis.
    The licensee stated that confirmation times for valve/breaker 
manipulations was included in the action time for the OMAs. The 
licensee also stated that for valves that are operated in the field, if 
they are being manually opened or closed, there is local indication 
plus the mechanical stops to confirm valve operation. For valves that 
are throttled, the field operator is in communication with the CR 
personnel who monitor

[[Page 43402]]

control board indication to confirm the proper response. The licensee 
further stated that all breakers have local mechanical indication for 
position verification, that all sequenced steps are coordinated from 
the CR, and that the OMA times listed include this coordination.
3.14.2 Environmental Factors
    The licensee stated that a review of ventilation systems for the 
fire areas addressed by the exemption request concluded that no 
credible paths exist that could allow the spread of products of 
combustion from the area of fire origin to an area that either serves 
as a travel path for OMAs or is an action location for an OMA. There is 
an exception for OMA 1 in fire area R-4 which was discussed in section 
3.2.4.1.1 (and below). The licensee also stated that the installed 
ventilation systems are not used to perform smoke removal activity for 
the fire areas discussed in the exemption request and that smoke 
evacuation for these areas would be accomplished by the site Fire 
Brigade utilizing portable mechanical ventilation.
    The licensee stated that the performance of all the OMAs for each 
of the fire areas have specific safe pathways for access and egress and 
that in all cases, ELUs have been provided to ensure adequate lighting. 
The licensee also stated that during a fire event, implementation of CR 
actions ensure the radiation levels along these pathways, and at the 
location of the OMAs, are within the normal and expected levels.
    The licensee stated that area temperatures may be slightly elevated 
due to a loss of normal ventilation, however, in no case would the 
temperatures prevent access along the defined routes or prevent the 
performance of an OMA. The licensee also stated that only OMA 1 could 
occur in the fire affected area in that a fire in fire area R-4, 
charging pump cubicle, could impact valve 2-CH-192 requiring the OMA to 
manually open this valve. The licensee further stated that this action 
would be delayed until after the fire is extinguished and the area is 
ventilated and that opening valve 2-CH-192 would not be required until 
the BASTs are emptied. The licensee further stated that the most 
limiting time estimate is 72 minutes of Charging system operation 
injecting the contents of the BASTs based on the tanks being at the TRM 
minimum level at the start of the event and that during the event, 
Charging may be lost or secured, and RCS inventory can meet the 
Appendix R performance goal for 180 minutes. The licensee further 
stated that analysis indicates that valve 2-CH-192 may not need to be 
opened until 252 minutes into the event.
    The licensee stated that fire barrier deviations that could allow 
the spread of products of combustion of a fire to an adjacent area that 
either serves as a travel path for OMAs or is an action location for an 
OMA have been found to not adversely impact OMA travel paths or action 
areas.
3.14.3 Equipment Functionality and Accessibility
    The licensee stated that as part of the OMA validation process, 
lighting, component labeling, accessibility of equipment, tools, keys, 
flashlights, and other devices or supplies needed are verified to 
ensure successful completion of the OMA.
    The licensee stated that for each OMA, the current MPS2 Appendix R 
Compliance Report indicates that operator access is assured by an 
alternate path or access is not required until after the fire has been 
suppressed. Where applicable, the licensee stated that OMAs have 
sufficient ELUs to provide for access to the particular component and 
to perform the task.
3.14.4 Available Indications
    Indicators and indication cables have been evaluated by the 
licensee as part of the exemption request process. Where impacts to 
indication have been identified the licensee provided an alternate 
method to obtain the needed indication(s).
3.14.5 Communications
    The licensee stated that Operators are provided with dedicated 
radio communication equipment and that the Appendix R communication 
system utilizes a portion of the MPS 800 MHz trunked radio system which 
consists of 800 MHz portable radio units, a CR base station 
transmitter, antennas, a main communication console located inside the 
CR and redundant repeaters. The licensee also stated that the CR base 
station transmitter is provided to ensure two-way voice communications 
with the CR without affecting plant safety systems that may have 
sensitive electronic equipment located in the area and the resulting 
design configuration ensures communications capability for all Appendix 
R fire scenarios.
3.14.6 Portable Equipment
    The licensee stated that all equipment required to complete a 
required action is included in a preventative maintenance program and 
is also listed in the TRM which identifies surveillances for the 
equipment utilized in each OMA.
3.14.7 Personnel Protection Equipment
    The licensee stated that there are no OMAs required in fire areas 
identified in the exemption request that necessitate the use of self-
contained breathing apparatus. No fire areas necessitate reentry to the 
area of fire origin other than described in Section 3.2.4.1.1.
3.14.8 Procedures and Training
    The licensee stated that entry into AOP 2559, ``FIRE'' is at the 
first indication of a fire from a panel alarm or report from the field. 
If the fire is in an Appendix R area, the shift is directed to 
determine if a fire should be considered Appendix R by:
    1. Identifying actual or imminent damage to safe shutdown 
components, switchgear, MCCs, cable trays or conduit runs;
    2. Observation of spurious operation of plant components needed for 
safe shutdown;
    3. Observation of loss of indication, control, or function of safe 
shutdown plant systems or components;
    4. Observation of conflicting instrument indication for safe 
shutdown systems or components; or
    5. Observation of parameters associated with safe shutdown systems 
or components not being within expected limits for the existing plant 
configuration.
    The licensee stated that AOP 2559, ``FIRE'' has various attachments 
that have Appendix R egress/access routes which provide a safe pathway 
to reach the required equipment necessary to complete the OMAs and that 
they have confirmed that the pathways will be free of hazards to the 
operators due to the subject fire.
    The licensee also stated that there is an Appendix R AOP 
corresponding to each Appendix R fire area, which are entered when an 
Appendix R fire is declared. Operations personnel train to those AOPs 
which identify the steps to perform each OMA. The licensee further 
stated that time critical OMAs are also identified within operating 
procedures which require that Operations personnel train to perform 
these time critical activities. The OMAs presented in this exemption 
request are encompassed in the time critical procedure.
    The licensee further stated that the times allotted to perform 
these tasks are easily achieved by experienced and inexperienced 
operators during training sessions, evaluated requalification training, 
and supervised walk downs and that for each case, there is sufficient

[[Page 43403]]

margin to account for the uncertainties associated with stress, 
environmental factors, and unexpected delays.
3.14.9 Staffing
    The licensee stated that the Operations shift staffing requirements 
include one additional licensed or non-licensed operator over the 
minimum TS requirement to be on duty each shift during Modes 1, 2, 3, 
or 4, and that this operator is designated as the Appendix R operator 
and is specified in the TRM. The licensee also stated that the number 
of individuals available to respond to the OMAs is one RO, two PEOs, 
and one additional licensed or non-licensed individual (Appendix R 
Operator). The licensee stated that the exemption request allocated 
tasks to PEO-1, PEO-2, PEO-3 and RO-1 and that one of the three PEOs 
would be the TRM required Appendix R Operator. With the exception of 
the panel C10 activities, the assignments are interchangeable between 
the four operators, since these individuals are specified by the TS and 
TRM, they are not members of the Fire Brigade and have no other 
collateral duties.
    The licensee stated that MPS2 has a SERO and appropriate emergency 
response facilities. In the event of a declaration of an ALERT (events 
which are in progress or have occurred involving an actual or potential 
substantial degradation of the level of safety of the plant, with 
releases expected to be limited to small fractions of the Environmental 
Protection Agency, Protective Action Guideline exposure levels), ALERT 
event activates the SERO organization, which is immediately staffed by 
on-site personnel and is fully established with on-call personnel 
within 60 minutes of the ALERT being declared. The licensee also stated 
that after this time, off-shift Operations staff (e.g., personnel in 
training, performing administrative functions, etc.) may be called in 
as requested by the SM. The licensee further stated that many of the 
OMAs are not required prior to the establishment of SERO and that the 
additional staff available through SERO will improve the reliability of 
these OMAs.
    The licensee stated that operators are required and assumed to be 
within the Protected Area and that the time lines account for the 
initial response by the field Operator. The licensee also stated that 
upon the announcement of a fire, the field Operators are directed to 
report to the CR and await further directions. Upon a report of a fire, 
the CR Operators enter AOP 2559, ``FIRE.'' The licensee further stated 
that the flow path to get into an Appendix R fire scenario is, that 
upon indication of a fire, the Fire Brigade is dispatched, and based on 
their report or indications in the CR, an Appendix R fire may be 
declared. In the development of the time lines, the Operators are 
allowed 5 minutes to respond and report to the CR.
3.14.10 Demonstrations
    In their letter dated February 29, 2012 the licensee provided its 
validation process for the OMAs included in the exemption request. The 
validation process included the following: 1. Validation Objectives; 2. 
Validation Frequency; 3. Validation Methods; 4. Validation Attributes; 
and 5. Validation Performance.
    The licensee stated that all OMAs are encompassed in procedure COP 
200.18, ``Time Critical Action Validation and Verification'' and that 
an enhancement to the tracking and training on TCAs has been developed 
and is currently being implemented.
    The licensee stated that all of the OMAs identified are contained 
in the AOPs to respond to an Appendix R Fire in the AOP Series 2579's 
fire procedures for Appendix R and that during initial validation of 
these procedures, the OMAs were performed and all of the time 
performance objectives were met as a result of the validation.
3.14.11 Feasibility Summary
    The licensee's analysis demonstrates that, for the expected 
scenarios, the OMAs can be diagnosed and executed within the amount of 
time available to complete them. The licensee's analysis also 
demonstrates that various factors, including the factor of two time 
margin, the use of the minimum BAST inventory, and the use of the CST 
inventory, have been considered to address uncertainties in estimating 
the time available. Therefore, the OMAs included in this review are 
feasible because there is adequate time available for the Operator to 
perform the required OMAs to achieve and maintain hot shutdown 
following a postulated fire event. The following table summarizes the 
``required'' versus ``available'' times for OMAs with time 
requirements. Where a diagnosis time has been identified, it is 
included as part of the required time for a particular action. Where an 
action has multiple times or contingencies associated with the 
``allowable'' completion time, the lesser time is used. This approach 
is considered to represent a conservative approach to analyzing the 
timelines associated with each of the OMAs with regard to the 
feasibility and reliability of the actions included in this exemption. 
All OMAs have at least 30 minutes of margin, and all but one have a 
factor of two time margin available. Margin is based on using the most 
limiting information from the licensee, for example, if the licensee 
postulated a range of time for diagnosis, the required time below 
includes the largest number in the range.
    Finally, these numbers should not be considered without the 
understanding that the manual actions are a fall back in the unlikely 
event that the fire protection defense-in-depth features are 
insufficient. In most cases there is no credible fire scenario that 
would necessitate the performance of these OMAs. The licensee provided 
a discussion of the activity completion times and associate margins 
related to the OMAs in their June 30, 2011, and February 29, 2012 
letters which are summarized in Table 3.

                                                     Table 3
----------------------------------------------------------------------------------------------------------------
                                                                                          Time to
      Fire Area of Fire Origin               Activity             OMAs      Available     conduct       Margin
                                                                            time (min)   OMAs (min)     (min)
----------------------------------------------------------------------------------------------------------------
Fire Area R-2 (West Penetration       Establish AFW Flow....           12           45            9           36
 Area, MCC B61, and the Facility Z2
 Upper 4.16kV Switchgear Room and
 Cable Vault).
                                      Establish Charging        2, 6, 10,          180           66          114
                                       Suction from BAST.      18, 19, 20
                                      Establish Charging             1, 8           72           40           32
                                       Suction from RWST.

[[Page 43404]]

 
Fire Area R-4 (Charging Pump          Establish Charging                1           72           32           40
 Cubicles).                            Suction from RWST.
Fire Area R-5 (``A'' Safeguards       Establish Charging                1           72           32           40
 Room, HPSI/LPSI).                     Suction from RWST.
Fire Area R-6 (``B'' Safeguards       Establish Charging                1           72           32           40
 Room, LPSI).                          Suction from RWST.
Fire Area R-7 (Diesel Generator Room  Establish Charging         4, 5, 11          180           24          156
 A).                                   Suction from BAST.
                                      Establish Charging                1           72           32           40
                                       Suction from RWST.
Fire Area R-8 (Diesel Generator Room  Establish Charging                1           72           32           40
 B).                                   Suction from RWST.
Fire Area R-9 (Facility Z1 DC         Establish Charging             4, 5          180           24          156
 Switchgear Room and Battery Room).    Suction from BAST.
Fire Area R-10 (Facility Z2 DC        Obtain Local BAST            18, 19          180           12          168
 Equipment Room and Battery Room).     Level Indication.
Fire Area R-12 (TDAFW Pump Pit).....  Establish Charging                1           72           32           40
                                       Suction from RWST.
Fire Area R-13 (West (Facility Z1)    Establish AFW Flow....       17, 22           45           10           35
 480 VAC Switchgear Room).
                                      Establish Charging        4, 5, 16,          180           23          157
                                       Suction from BASTs.     20, 21, 24
Fire Area R-14 (Facility Z1 Lower     Establish Charging        4, 5, 13,          180           27          153
 4.16kV Switchgear Room and Cable      Suction from BASTs.    14, 15, 23,
 Vault).                                                               24
Fire Area R-15 (Containment           Establish Charging             6, 7          180           10          170
 Building).                            Suction from BASTs.
                                      Establish Charging                1           72           32           40
                                       Suction from RWST.
Fire Area R-17 (East Penetration      Establish Charging             4, 5          180           24          156
 Area).                                Suction from BASTs.
                                      Establish Charging                1           72           32           40
                                       Suction from RWST.
----------------------------------------------------------------------------------------------------------------

    The completion times noted in the table above provide reasonable 
assurance that the OMAs can reliably be performed under a wide range of 
conceivable conditions by different plant crews because it, in 
conjunction with the time margins associated with each action and other 
installed fire protection features, account for sources of uncertainty 
such as variations in fire and plant conditions, factors unable to be 
recreated in demonstrations and human-centered factors.
3.14.12 Reliability
    A reliable action is a feasible action that is analyzed and 
demonstrated as being dependably repeatable within an available time. 
The above criteria, 3.14.1 through 3.14.10 provide the staff's basis 
that the actions are feasible. Section 3.14.11, provides a discussion 
of the available time margin. The licensee provided a basis that the 
actions were reliable, based on the available time margin; the 
administrative controls such as procedures, staffing levels, and 
availability of equipment; and by accounting for uncertainty in fires 
and plant conditions. Therefore, the OMAs included in this review are 
reliable because there is adequate time available to account for 
uncertainties not only in estimates of the time available, but also in 
estimates of how long it takes to diagnose a fire and execute the OMAs 
(e.g., as based, at least in part, on a plant demonstration of the 
actions under non-fire conditions). OMA 1 for fire area R-4 is 
performed in a fire affected area and is performed after the fire is 
extinguished and after the SERO is fully staffed. This OMA establishes 
the RWST as the suction supply for the charging system and is not 
conducted until after AFW is established and since the BASTs have a 
minimum TRM specified inventory to ensure 72 minutes of flow, OMA 1 can 
be completed with 40 minutes of margin.

3.15 Summary of Defense-in-Depth and Operator Manual Actions

    In summary, the defense-in-depth concept for a fire in the fire 
areas discussed above provides a level of safety that results in the 
unlikely occurrence of fires, rapid detection, control and 
extinguishment of fires that do occur and the protection of structures, 
systems and components important to safety. As discussed above, the 
licensee has provided preventative and protective measures in addition 
to feasible and reliable OMAs that together demonstrate the licensee's 
ability to preserve or maintain safe shutdown capability in the event 
of a fire in the analyzed fire areas.

3.16 Authorized by Law

    This exemption would allow MPS2 to rely on OMAs, in conjunction 
with the other installed fire protection features, to ensure that at 
least one means of achieving and maintaining hot shutdown remains 
available during and following a postulated fire event, as part of its 
fire protection program, in lieu of meeting the requirements specified 
in III.G.2 for a fire in the analyzed fire areas. As stated above, 10 
CFR 50.12 allows the NRC to grant exemptions from the requirements of 
10 CFR Part 50. The NRC staff has determined that granting of this 
exemption will not result in a violation of the Atomic Energy Act of 
1954, as amended, or the Commission's regulations. Therefore, the 
exemption is authorized by law.

[[Page 43405]]

3.17 No Undue Risk to Public Health and Safety

    The underlying purpose of 10 CFR Part 50, Appendix R, Section III.G 
is to ensure that at least one means of achieving and maintaining hot 
shutdown remains available during and following a postulated fire 
event. Based on the above, no new accident precursors are created by 
the use of the specific OMAs, in conjunction with the other installed 
fire protection features, in response to a fire in the analyzed fire 
areas. 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.

3.18 Consistent with Common Defense and Security

    This exemption would allow MPS2 to credit the use of the specific 
OMAs, in conjunction with the other installed fire protection features, 
in response to a fire in the analyzed fire areas, discussed above, in 
lieu of meeting the requirements specified in III.G.2. This change, to 
the operation of the plant, has no relation to security issues. 
Therefore, the common defense and security is not diminished by this 
exemption.

3.19 Special Circumstances

    One of the special circumstances described in 10 CFR 
50.12(a)(2)(ii) is that the application of the regulation is not 
necessary to achieve the underlying purpose of the rule. The underlying 
purpose of 10 CFR Part 50, Appendix R, Section III.G is to ensure that 
at least one means of achieving and maintaining hot shutdown remains 
available during and following a postulated fire event. While the 
licensee does not comply with the explicit requirements of III.G.2 
specifically, they do meet the underlying purpose of 10 CFR Part 50, 
Appendix R, and Section III.G as a whole. Therefore, special 
circumstances exist that warrant the issuance of this exemption as 
required by 10 CFR 50.12(a)(2)(ii).

4.0 Conclusion

    Based on the all of the features of the defense-in-depth concept 
discussed above, the NRC staff concludes that the use of the requested 
OMAs, 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 is consistent with the underlying purpose 
of the rule. As such, the level of safety present at MPS2 is 
commensurate with the established safety standards for nuclear power 
plants.
    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 Dominion an exemption from the requirements of Section III.G.2 
of Appendix R of 10 CFR Part 50, to utilize the OMAs discussed above at 
MPS2.
    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 (77 FR 39746).
    This exemption is effective upon issuance.

    Dated at Rockville, Maryland, this 12th day of July 2012.

    For the Nuclear Regulatory Commission.
Michele G. Evans,
Director, Division of Operating Reactor Licensing, Office of Nuclear 
Reactor Regulation.
[FR Doc. 2012-17735 Filed 7-23-12; 8:45 am]
BILLING CODE 7590-01-P

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