[Federal Register Volume 77, Number 249 (Friday, December 28, 2012)]
[Notices]
[Pages 76542-76569]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-31202]


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NUCLEAR REGULATORY COMMISSION

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


Millstone Power Station, Unit 2; Exemption

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of Issuance; Correction.

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SUMMARY: This document corrects an exemption to 10 CFR Part 50, 
Appendix R appearing in the Federal Register on July 24, 2012 (77 FR 
43382), which inadvertently omitted: (1) Operator Manual Action (OMA) 1 
from Fire Area R-9, (2) OMA 9, OMA 11 and OMA 1 from Fire Area R-13, 
and (3) OMA 9 and OMA 1 from Fire Area R-14. Due to the complexity of 
the corrections, the exemption is being reissued in its entirety.

FOR FURTHER INFORMATION CONTACT: James Kim, NRR/DORL/PM, Office of 
Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, 
Washington, DC 20555-0001; telephone 301-415-4125, email: 
James.Kim@nrc.gov.

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) Part 50, 
Section 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 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

[[Page 76543]]

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.

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[GRAPHIC] [TIFF OMITTED] TN28DE12.030

    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, ``Potential for Loss of Remote Shutdown 
Capability During a Control Room Fire,'' (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 overtorqued. 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

[[Page 76548]]

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. 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, ``Implementation of Fire 
Protection Requirements,'' 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

[[Page 76549]]

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 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 if there 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. 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 inches 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

[[Page 76550]]

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 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 post-fire 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

[[Page 76551]]

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.
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

[[Page 76552]]

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 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

[[Page 76553]]

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 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 3 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 3 hours, 
therefore, the accumulator capacity and the minimum TRM BAST level 
requirement require the OMA to locally open 2-CH-1 92 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. 
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

[[Page 76554]]

charging flow for more than 72 minutes, at which time charging pump 
suction is shifted to the RWST and that 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 3 
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

[[Page 76555]]

opening the valve and maintaining it open for 3 hours. The licensee 
further stated that battery depletion will 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

[[Page 76556]]

depleted, Operators can switch over to the fire water system and 
maintain flow to the AFW system.
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 OMA 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 1, 4 and 5,--Open Valve 2-CH-192, 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 3 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. The licensee further stated that prior to 
BAST depletion, Operators switch over to the RWST. The licensee further 
stated that cables for 2-CH-192 do not pass through the fire area but 
the valve may fail closed if DV10 lost power and that an OMA would be 
required to open valve 2-CH-192 (OMA 1). OMA 1 establishes the RWST as 
the suction supply for the charging system. The BASTs have a minimum 
TRM specified inventory to ensure 72 minutes of flow after charging is 
reestablished and OMA 1 can be completed in 32 minutes which results in 
40 minutes of 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. 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.
3.7.5 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.

[[Page 76557]]

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 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

[[Page 76558]]

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.
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
3.10.4.1 AFW Flow
3.10.4.1.1 OMAs 9, 22 and 17--Operate Feed Regulating Valve 2-FW-43B 
from the C10 panel, 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

[[Page 76559]]

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 (OMA 9), 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 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 OMAs 11 and 20--Operate Valve 2-MS-190B From Panel C10, 
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 (OMA 11) is not required until after AFW flow is 
established. 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 1, 4, 5, 16, 21, and 24--Open Valve 2-CH-192, 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, but it can be controlled from the CR for approximately 8 
hours until after the depletion of the ``A'' battery, due to a loss of 
power supply to the battery charger. The licensee further stated that 
cables for 2-CH-192 do not pass through the fire area but the valve 
fails closed when battery ``A'' is depleted, and that an OMA would be 
required to maintain open valve 2-CH-192 (OMA 1). OMA 1 establishes the 
RWST as the suction supply for the charging system.
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 Lower 6.9 and 4.16 kV Switchgear Room 
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.
    The licensee stated that the East Cable Vault area have moderate 
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 4.16kV 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

[[Page 76560]]

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 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 4.16kV 
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 OMA 
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 and AFW 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 1, 13, 14, 15, 23, and 24--Open Valve 2-CH-192, 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. The licensee further 
stated that after the BASTs have reached the 10 percent level, 
Operators switch Charging Pump suction over to the RWST. Cables for 
valve 2-CH-192 do not pass through the fire area but the valve fails 
closed when battery ``A'' is depleted, approximately 8 hours, due to a 
loss of power supply to the battery charger. OMA would be required to 
maintain open valve 2-CH-192 (OMA 1). OMA 1 maintains the RWST as the 
suction supply for the charging system.
3.11.4.1.3 OMA 9-Operate Feed Regulating Valve 2-FW-43B from the C10 
panel
    The licensee stated that for a fire in the area, OMA 9 is required 
to provide decay heat removal by establishing AFW flow to the credited 
SG is required within 45 minutes. The licensee stated that for a fire 
in the area valve 2-FW-43B cable damage could result in the valve not 
being operational from the CR and that isolation of the affected cables 
and control of the valve can be accomplished at the C-10 panel (OMA 9). 
The licensee further stated that the timeframe to establish control of 
AFW at the C-10 panel is 45 minutes and that after Reactor Operator 1 
(RO-1) has established control of 2-FW-43B at the C-10 panel (4 
minutes), it will take an

[[Page 76561]]

additional 2 minutes to establish AFW flow which results in a total 
time to establish AFW flow of 6 minutes, leaving a 39 minute margin.
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. The OMA to establish 
AFW flow can be completed in 6 minutes which provides a 39 minute 
margin since the required completion time is 45 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 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

[[Page 76562]]

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 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.

[[Page 76563]]

    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 and 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 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

[[Page 76564]]

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 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

[[Page 76565]]

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 
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 license provided it's 
validation process for the OMA's 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

[[Page 76566]]

OMAs to achieve and maintain hot shutdown following a postulated fire 
event. The following table summarizes the ``required'' verses 
``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.

[[Page 76567]]

[GRAPHIC] [TIFF OMITTED] TN28DE12.031


[[Page 76568]]


[GRAPHIC] [TIFF OMITTED] TN28DE12.032

    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

[[Page 76569]]

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.

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 18th day of December 2012.
    For The Nuclear Regulatory Commission.

Michele G. Evans,
Director, Division of Operating Reactor Licensing, Office of Nuclear 
Reactor Regulation.
[FR Doc. 2012-31202 Filed 12-27-12; 8:45 am]
BILLING CODE 7590-01-P