[Federal Register Volume 76, Number 67 (Thursday, April 7, 2011)]
[Notices]
[Pages 19488-19510]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-8318]


-----------------------------------------------------------------------

NUCLEAR REGULATORY COMMISSION

[Docket No. 50-219; NRC-2010-0200]


Exelon Generation Company, LLC, Oyster Creek Nuclear Generating 
Station; Exemption

1.0 Background

    Exelon Generation Company, LLC (Exelon or the licensee) is the 
holder of Facility Operating License No. DPR-16 that authorizes 
operation of the Oyster Creek Nuclear Generating Station (Oyster 
Creek). The license provides, among other things, that the facility is 
subject to all rules, regulations, and orders of the U.S. Nuclear 
Regulatory Commission (NRC or the Commission) now or hereafter in 
effect.
    The facility consists of a boiling-water reactor located in Ocean 
County, New Jersey.

2.0 Request/Action

    Title 10 of the Code of Federal Regulations (10 CFR), Part 50, 
Section 50.48 requires that nuclear power plants that were licensed 
before January 1, 1979, must satisfy the requirements of 10 CFR Part 
50, Appendix R, Section III.G, ``Fire protection of safe shutdown 
capability.'' Oyster Creek was licensed to operate prior to January 1, 
1979. As such, the licensee's Fire Protection Program must provide the 
established level of protection as intended by Section III.G of 10 CFR 
Part 50, Appendix R.
    By letter dated March 4, 2009, ``Request for Exemption from 10 CFR 
50, Appendix R, Section III.G, `Fire Protection of Safe Shutdown 
Capability (Phase 2)' '' available at Agencywide Documents Access and 
Management System (ADAMS), Accession No. ML090640225, and supplemented 
by letter dated April 2, 2010, ``Response to Request for Additional 
Information Request for Exemption from 10 CFR Part 50, Appendix R, 
Section III.G, `Fire Protection of Safe Shutdown Capability' '' (ADAMS 
Accession No. ML100920370), the licensee requested an exemption for 
Oyster Creek from certain technical requirements of 10 CFR Part 50, 
Appendix R, Section III.G.2 (III.G.2) for the use of operator manual 
actions (OMAs) in lieu of meeting the circuit separation and protection 
requirements contained in III.G.2 for the following 22 plant areas: CW-
FA-14, OB-FA-9, OB-FZ-6A, OB-FZ-6B, OB-FZ-8A, OB-FZ-8B, OB-FZ-8C, OB-
FZ-10A, RB-FZ-1D, RB-FZ-1E, RB-FZ-1F3, RB-FZ-1F5, RB-FZ-1G, TB-FA-3A, 
TB-FA-26, TB-FZ-11B, TB-FZ-11C, TB-FZ-11D, TB-FZ-11E, TB-FZ-11F, TB-FZ-
11H, and Yard. The 22 plant areas noted above are the subject of this 
exemption.

3.0 Discussion

    Pursuant to 10 CFR 50.12, the Commission may, upon application by 
any interested person or upon its own initiative, grant exemptions from 
the requirements of 10 CFR Part 50 when: (1) The exemptions are 
authorized by law, will not present an undue risk to public health or 
safety, and are consistent with the common defense and security; and 
(2) when special circumstances are present. The licensee has stated 
that special circumstances are present in that the application of the 
regulation in this particular circumstance is not necessary to achieve 
the underlying purpose of the rule, which is consistent with the 
language included in 10 CFR 50.12(a)(2)(ii).

[[Page 19489]]

    In their March 4, 2009, and April 2, 2010, letters, the licensee 
discussed financial implications associated with plant modifications 
that may be necessary to comply with the regulation.
    Section 50.12(a)2(iii) of 10 CFR states that if such costs have 
been shown to be significantly in excess of those contemplated at the 
time the regulation was adopted, or are significantly in excess of 
those incurred by others similarly situated, this may be considered a 
basis for considering an exemption request. However, financial 
implications were not considered in the regulatory review of their 
request since no substantiation was provided regarding such financial 
implications. Even though no financial substantiation was provided, the 
licensee did submit sufficient regulatory basis to support a technical 
review of their exemption request in that the application of the 
regulation in this particular circumstance is not necessary to achieve 
the underlying purpose of the rule.
    In accordance with 10 CFR 50.48(b), nuclear power plants licensed 
before January 1, 1979, are required to meet Section III.G of 10 CFR 
Part 50, Appendix R. The underlying purpose of Section III.G of 10 CFR 
Part 50, Appendix R, is to ensure that the ability to achieve and 
maintain safe shutdown is preserved following a fire event. The 
regulation intends for licensees to accomplish this by extending the 
concept of defense-in-depth to:
    (1) Prevent fires from starting;
    (2) Rapidly detect, control, and extinguish promptly those fires 
that do occur;
    (3) Provide protection for structures, systems, and components 
important to safety so that a fire that is not promptly extinguished by 
the fire suppression activities will not prevent the safe shutdown of 
the plant.
    The stated purpose of 10 CFR Part 50, Appendix R, Section III.G.2 
(III.G.2) is to ensure that one of the redundant trains necessary to 
achieve and maintain hot shutdown conditions remains free of fire 
damage in the event of a fire. Section III.G.2 requires one of the 
following means to ensure that a redundant train of safe shutdown 
cables and equipment is free of fire damage, where redundant trains are 
located in the same fire area outside of primary containment:
    a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
    b. Separation of cables and equipment by a horizontal distance of 
more than 20 feet with no intervening combustibles or fire hazards and 
with fire detectors and an automatic fire suppression system installed 
in the fire area; or
    c. Enclosure of cables and equipment of one redundant train in a 
fire barrier having a 1-hour rating and with fire detectors and an 
automatic fire suppression system installed in the fire area.
    Exelon has requested an exemption from the requirements of III.G.2 
for Oyster Creek to the extent that redundant trains of systems 
necessary to achieve and maintain hot shutdown are not maintained free 
of fire damage in accordance with one of the required means prescribed 
in III.G.2.
    Each OMA included in this review consists of a sequence of tasks 
that occur in various fire areas. The OMAs are initiated upon 
confirmation of a fire in a particular fire area. Table 1 lists, in the 
order of the fire area of fire origin, the OMAs included in this 
review.

                                                     TABLE 1
----------------------------------------------------------------------------------------------------------------
                                                                                                          OMA
                         Area of fire origin             Area name                   Actions           
----------------------------------------------------------------------------------------------------------------
1...................  CW-FA-14.................  Circulatory Water Intake.  Provide makeup control           17
                                                                             air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
2...................  OB-FA-9..................  Office Building (Bldg.)    Provide makeup control           17
                                                  Elev. 23'-6'', 35'-0'',    air to the accumulator
                                                  46'-6''.                   for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
3...................  OB-FZ-6A.................  Office Bldg. ``A'' 480V    Provide makeup control           17
                                                  Switchgear (SWGR) Room     air to the accumulator
                                                  Elev. 23'-6''.             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
4...................  OB-FZ-6B.................  Office Bldg. ``B'' 480V    Provide makeup control           18
                                                  SWGR Room Elev. 23'-6''.   air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
5...................  OB-FZ-8A.................  Office Bldg. Reactor       Provide makeup control           17
                                                  Recirculation Motor        air to the accumulator
                                                  Generator (MG) Set Room    for V-11-34 for the
                                                  Elev. 23'-6''.             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
6...................  OB-FZ-8B.................  Office Bldg. Mechanical    Provide makeup control           17
                                                  Equipment Room Elev. 35'-  air to the accumulator
                                                  0''.                       for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
7...................  OB-FZ-8C.................  Office Bldg. A/B Battery   Provide makeup control           17
                                                  Room, Tunnel and           air to the accumulator
                                                  Electrical Tray Room       for V-11-34 for the
                                                  Elev. 35'-0''.             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
8...................  OB-FZ-10A................  Office Bldg. Monitor and   Provide makeup control           18
                                                  Change Room Area and       air to the accumulator
                                                  Operations Support Area    for V-11-36 for the
                                                  Elev. 35'-0'' & 46'-6''.   Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
9...................  RB-FZ-1D.................  Reactor Bldg. Elev. 51'-   Provide makeup control           17
                                                  3''.                       air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
10..................  RB-FZ-1E.................  Reactor Building Elev.     Provide makeup control           17
                                                  23'-6''.                   air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
11..................  RB-FZ-1F3................  Reactor Bldg. Northwest    Provide makeup control           17
                                                  Corner Elev.-19'-6''.      air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
12..................  RB-FZ-1F5................  Reactor Bldg. Torus Room   Provide makeup control           17
                                                  Elev. -19'-6''.            air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.

[[Page 19490]]

 
13..................  RB-FZ-1G.................  Reactor Bldg. Shutdown     Provide makeup control           17
                                                  Cooling Room Elev. 38'-    air to the accumulator
                                                  0'' & 51'-3''.             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
14..................  TB-FA-3A.................  Turbine Bldg. 4160V        Provide makeup control           17
                                                  Emergency SWGR Vault 1C    air to the accumulator
                                                  Elev. 23'-6''.             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
15..................  TB-FA-26.................  Turbine Bldg. 125V DC      Trip Field Breakers for           1
                                                  Battery Room C Elev. 23'-  Recirculation Pumps MG
                                                  6''.                       Set so that the Fuel
                                                                             Zone Level Indicators
                                                                             can be used.
                                                                            Provide Fire Water to             2
                                                                             Isolation Condenser
                                                                             shell by operating
                                                                             valves V-9-2099, V-11-
                                                                             49, V-11-63 and V-11-41
                                                                             due to loss of power
                                                                             (contingency action).
                                                                            Manually control 480V USS         3
                                                                             1B2 Breakers for control
                                                                             rod drive (CRD) Pump
                                                                             NC08B and 1B2M from
                                                                             Remote Shutdown Panel
                                                                             due to control circuit
                                                                             damage.
                                                                            Manually open V-11-36 to          7
                                                                             provide makeup to
                                                                             Isolation Condenser due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Check Isolation Condenser         8
                                                                             Shell level locally due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Provide makeup control           18
                                                                             air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
16..................  TB-FZ-11B................  Turbine Bldg. Lube Oil     Manually control 480V             3
                                                  Storage, Purification      Unit Substation (USS)
                                                  and Pumping Area Elev.     1B2 Breakers for CRD
                                                  0'[dash]0'', 27'-0'',      Pump NC08B and 1B2M from
                                                  and 36'-0''.               Remote Shutdown Panel
                                                                             due to control circuit
                                                                             damage.
                                                                            Provide makeup control           18
                                                                             air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
17..................  TB-FZ-11C................  Turbine Bldg. SWGR Room    Trip Field Breakers for           1
                                                  1A and 1B Elev. 23'-6''.   Recirculation Pumps MG
                                                                             Set so that the Fuel
                                                                             Zone Level Indicators
                                                                             can be used.
                                                                            Provide Fire Water to             2
                                                                             Isolation Condenser
                                                                             shell by operating
                                                                             valves V-9-2099, V-11-
                                                                             49, V-11-63 and V-11-41
                                                                             due to loss of power
                                                                             (contingency action).
                                                                            Manually control 480V USS         3
                                                                             1B2 Breakers for CRD
                                                                             Pump NC08B and 1B2M from
                                                                             Remote Shutdown Panel
                                                                             due to control circuit
                                                                             damage.
                                                                            Manually open V-11-36 to          7
                                                                             provide makeup to
                                                                             Isolation Condenser due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Check Isolation Condenser         8
                                                                             Shell level locally due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Provide makeup control           18
                                                                             air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
18..................  TB-FZ-11D................  Turbine Bldg. Basement     Trip Field Breakers for           1
                                                  Floor South End Elev. 3'-  Recirculation Pumps MG
                                                  6''.                       Set so that the Fuel
                                                                             Zone Level Indicators
                                                                             can be used.
                                                                            Provide Fire Water to             2
                                                                             Isolation Condenser
                                                                             shell by operating
                                                                             valves V-9-2099, V-11-
                                                                             49, V-11-63 and V-11-41
                                                                             due to loss of power
                                                                             (contingency action).
                                                                            Manually control 480V USS         3
                                                                             1B2 Breakers for CRD
                                                                             Pump NC08B and 1B2M from
                                                                             Remote Shutdown Panel
                                                                             due to control circuit
                                                                             damage.
                                                                            Manually open V-11-36 to          7
                                                                             provide makeup to
                                                                             Isolation Condenser due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Check Isolation Condenser         8
                                                                             Shell level locally due
                                                                             to loss of power
                                                                             (contingency action).
                                                                            Provide makeup control           18
                                                                             air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
19..................  TB-FZ-11E................  Turbine Bldg. Condenser    Manually control 480V USS         3
                                                  Bay Area Elev. 0'-0''.     1B2 Breakers for CRD
                                                                             Pump NC08B and 1B2M from
                                                                             Remote Shutdown Panel
                                                                             due to control circuit
                                                                             damage.
                                                                            Provide makeup control           18
                                                                             air to the accumulator
                                                                             for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
20..................  TB-FZ-11F................  Turbine Bldg. Feedwater    Provide makeup control           18
                                                  Pump Room Elev. 0'-0'' &   air to the accumulator
                                                  3'-6''.                    for V-11-36 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
21..................  TB-FZ-11H................  Turbine Bldg.              Provide makeup control           18
                                                  Demineralizer Tank and     air to the accumulator
                                                  Steam Jet Air Ejector      for V-11-36 for the
                                                  Area Elev. 3'-6'' & 23'-   Isolation Condenser
                                                  6''.                       makeup line due to the
                                                                             loss of instrument air.

[[Page 19491]]

 
22..................  Yard.....................  Office Bldg. Roof,         Manually open V-15-237,           9
                                                  Turbine Bldg. Roof, and    throttle V-15-30 while
                                                  All Remaining Outside      monitoring flow at FI-
                                                  Areas.                     225-2 and close V-15-52
                                                                             to establish CRD flow to
                                                                             Reactor due to the loss
                                                                             of instrument air to the
                                                                             CRD Flow Control Valve.
                                                                            Provide makeup control           17
                                                                             air to the accumulator
                                                                             for V-11-34 for the
                                                                             Isolation Condenser
                                                                             makeup line due to the
                                                                             loss of instrument air.
----------------------------------------------------------------------------------------------------------------

    In their submittals the licensee described elements of their fire 
protection program that provide their justification that the concept of 
defense-in-depth that is in place in the above fire areas is consistent 
with that intended by the regulation. To accomplish this, the licensee 
utilizes various protective measures to accomplish the concept of 
defense-in-depth. Specifically, the licensee stated that the purpose of 
their request was to credit the use of OMAs, in conjunction with other 
defense-in-depth features, in lieu of the separation and protective 
measures required by III.G.2 for a fire in the fire areas stated above.
    In their April 2, 2010, letter the licensee provided an analysis 
that described how fire prevention is addressed for each of the fire 
areas for which the OMAs may be required. The licensee developed a Fire 
Hazards Analysis (FHA) for each fire area or zone identified in its 
exemption request. For each fire area or zone, the FHA describes the 
physical location and arrangement of equipment, combustible loading, 
ignition sources, fire protection features, and proximity of redundant 
safe shutdown equipment to in situ hazards and identifies deviations 
from fire protection codes and previously approved exemptions. In 
addition, for each fire area or zone, the licensee's response includes 
a tabulation of potential ignition sources as well as the equipment 
that may exhibit high energy arcing faults. For each fire area or zone, 
the FHA states that the fire protection configuration achieves a level 
of protection commensurate with that intended by III.G.2.
    The 22 areas or zones identified in the request have 
administratively limited combustible fuel loading with fuel sources 
consisting primarily of cable insulation and limited floor based 
combustibles except areas OB-FZ-6A, OB-FZ-6B, and TB-FZ-11B, which 
contain quantities of transformer liquid or lubricating oil. 
Combustible fuel loading in most areas is classified as low by the 
licensee while Fire Areas OB-FZ-6A and OB-FZ-6B have been classified as 
having a moderate combustible fuel loading and TB-FZ-11B has been 
classified as having a high combustible fuel loading. In addition, the 
licensee has stated that they maintain a robust administrative program 
(e.g., hot work permits, fire watches for hot work, and supervisory 
controls) to limit and control transient combustible materials and 
ignition sources in the areas. The fire areas included in the exemption 
are not shop areas so hot work activities are infrequent and the 
administrative control programs are in place if hot work activities do 
occur.
    The licensee also stated that 98% of the Oyster Creek cables are 
jacketed with Vulkene, which passes the horizontal flame test of the 
Underwriter's Laboratory, therefore reducing the likelihood of the 
cables themselves contributing to a fire hazard. Furthermore, the areas 
or zones are of noncombustible construction with typical utilities 
installed lighting, ventilation, etc., and 3-hour fire resistance-rated 
barriers normally used to provide fire resistive separation between 
adjacent fire areas. In some cases, barriers with a fire resistance 
rating of less than 3 hours are credited, but exemptions have been 
approved or the licensee has stated they have performed engineering 
evaluations in accordance with Generic Letter 86-10 to demonstrate that 
the barriers are sufficient for the hazard. Walls separating rooms and 
zones within fire areas are typically constructed of heavy concrete. 
This compartmentalization of the areas reduces the likelihood for fire 
events in a particular area to spread to or impact other adjacent 
areas.
    Many fire areas included in this exemption have automatic detection 
systems installed, although the licensee indicated that not all systems 
are installed in accordance with a recognized standard with regard to 
spacing in all areas. In such cases, the licensee has stated that the 
detectors are located near equipment such that they are likely to 
detect a fire. Upon detecting smoke, the detectors initiate an alarm in 
the constantly staffed control room. In addition to the automatic 
suppression systems noted below, equipment operators are trained fire 
brigade members and may identify and manually suppress or extinguish a 
fire using the portable fire extinguishers and manual hose stations 
located throughout the fire areas if a fire is identified in its early 
stages of growth.
    The licensee stated that the postulated fire events that may 
require the use of the OMAs would include multiple failures of various 
components or equipment. In most cases, it is considered unlikely that 
the sequence of events required to necessitate the OMAs would fully 
evolve because of the fire prevention, fire protection, and physical 
separation features in place. However, in the event that the sequence 
does evolve, the OMAs are available to provide assurance that safe 
shutdown can be achieved. For each of the fire areas included in this 
exemption, the postulated fire scenarios and pertinent details are 
summarized in Table 2 below.
    Each of the fire areas or zones included in this exemption is 
analyzed below with regard to how the concept of defense-in-depth is 
achieved for each area or zone and the role of the OMAs in the overall 
level of safety provided for each area or zone.

3.1 CW-FA-14 Circulatory Water Intake

3.1.1 Fire Prevention
    The licensee stated that combustible loading is not tracked in this 
area since it is an outside area. The licensee also stated that the 
primary combustible materials in the area are transformer liquid and 
electrical motors; although the amount is not quantified since the area 
is open to the atmosphere with no walls or ceiling to contain the heat 
or smoke that may be produced during a fire event. Additionally, the 
main combustible in this area that could result in the need for the 
OMAs is Dow Corning 561 Silicon transformer liquid, which the licensee 
states has characteristics that minimize the likelihood of a fire 
involving the insulating liquid itself.

[[Page 19492]]

3.1.2 Detection, Control, and Extinguishment
    CW-FA-14 is not equipped with automatic fire detection or 
suppression systems but since it is an outdoor area with no walls or 
ceiling, it is not expected that such systems would enhance this 
element of defense-in-depth in this area since the area is open to the 
atmosphere with no walls or ceiling to contain the heat or smoke that 
may be produced during a fire event. However, the licensee stated that 
a security tower monitors this area continuously. Therefore, any fire 
of significance would likely be detected and responded to appropriately 
by the station fire brigade. Manual suppression is also provided by a 
fire hydrant and fire hose house located approximately 75 feet from the 
principal fire hazards.
3.1.3 Preservation of Safe Shutdown Capability
    Since Fire Area CW-FA-14 is an outdoor space with no walls or 
ceiling, smoke and heat would not accumulate within the fire area to 
cause damage to components remote to the initiating fire or obstruct 
operator actions.
3.1.4 OMAs Credited for a Fire in This Area
3.1.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the main steam isolation valves (MSIVs) will close, 
as well as multiple air-operated valves changing state. Additionally, 
reactor pressure vessel (RPV) level indication is also available for 
all fire areas or zones. All of these indications would help the 
operator diagnose the loss of instrument air and initiate mitigating 
procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.1.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and open nature of the area, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this area, combined with the 
ability of OMA 17 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

3.2 OB-FA-9 Office Bldg. Elev. 23'-6'', 35'-0'', 46'-6'',

3.2.1 Fire Prevention
    The licensee has classified the fire loading in this fire area as 
low. The licensee also stated that the major combustibles in the 
multiplexer (MUX) corridor, which is within OC-FA-9, are cable 
insulation and a wood ceiling on top of the MUX enclosure, which is 
within the MUX corridor.
3.2.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FA-9 has a partial area coverage wet 
pipe sprinkler system installed. The licensee further stated that the 
area is not provided with a detection system but that there is an 
installed detection system in the main hallways and inside of the MUX 
corridor and that it is a high traffic area so a fire would likely be 
detected by personnel. The wet pipe sprinkler system, when actuated, 
will alarm in the control room to notify operators of a potential fire 
event. Extinguishment of a fire in the majority of this area will be 
accomplished by the plant fire brigade.
3.2.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FA-9 has a ceiling height of 
approximately 10'-6'', and an approximate floor area of 513 square feet 
in the MUX corridor where the safe shutdown equipment is located so it 
is unlikely that smoke and heat would accumulate at the height of the 
safe shutdown equipment and cause a failure due to fire damage.
3.2.4 OMAs Credited for a Fire in this Area
3.2.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a

[[Page 19493]]

panel in the control room for instrument air pressure. If all of these 
instruments are not available, then ABN-35 further indicates that the 
control rods will start to drift into the core and the MSIVs will 
close, as well as multiple air-operated valves changing state. 
Additionally, RPV level indication will not be compromised by a fire in 
any zone or area. All of these indications would help the operator 
diagnose the loss of instrument air and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.2.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and volume of the space, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the sprinkler system noted 
above, or personnel, and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area, combined with the ability of OMA 17 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

3.3 OB-FZ-6A Office Bldg. ``A'' 480V Switchgear (SWGR) Room Elev. 23'-
6'',

3.3.1 Fire Prevention
    The licensee stated that the fire loading in this zone is moderate 
and that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the main combustibles in this area are cable 
insulation (approximately 81% of loading) and Dow Corning 561 Silicon 
transformer liquid (approximately 15% of loading). The transformer 
liquid has characteristics that minimize the likelihood of a fire 
involving the insulating liquid itself.
3.3.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-6A has an automatic smoke detection 
system, a total flooding automatic Halon 1301 System, and manual fire 
fighting capabilities (portable extinguishers and hose stations).
3.3.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FA-6A has a ceiling height of 
approximately 10'-8'', and an approximate floor area of 1157 square 
feet so it is unlikely that smoke and heat would accumulate at the 
height of the safe shutdown equipment and cause a failure due to fire 
damage.
3.3.4 OMAs Credited for a Fire in this Zone
3.3.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.3.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the volume of the space, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the smoke detection or Halon 
system noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMA 17 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.4 OB-FZ-6B Office Building ``B'' 480V SWGR Room Elev. 23'-6'',

3.4.1 Fire Prevention
    The licensee stated that the fire loading in this zone is moderate 
and that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the main combustibles in this area are cable 
insulation (approximately 28% of loading), Thermo-Lag (approximately 
29% of loading) and Dow Corning 561 Silicon transformer liquid 
(approximately 31% of loading). The transformer liquid has 
characteristics that minimize the likelihood of a fire involving the 
insulating liquid itself.
3.4.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-6B has an automatic smoke detection 
system, a total flooding Halon 1301 System, and manual fire fighting 
capabilities (portable extinguishers and hose stations).
3.4.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FA-6B has a ceiling height of 
approximately 10'-8'' and an approximate floor area of 679 square feet 
so it is unlikely that

[[Page 19494]]

smoke and heat would accumulate at the height of the safe shutdown 
equipment and cause a failure due to fire damage.
3.4.4 OMAs Credited for a Fire in This Zone
3.4.4.1 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.4.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the volume of the space, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the smoke detection or Halon 
system noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this area, combined with the ability of OMA 18 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.5 OB-FZ-8A Office Bldg. Reactor Recirculation MG Set Room & OB-FZ-8B 
Mechanical Equipment Room Elev. 23'-6'' & 35'-0''

3.5.1 Fire Prevention
    Fire Zones OB-FZ-8A and 8B are evaluated together for the 
combustible loading and fire safe shutdown analysis. The licensee 
stated that the fire loading in this zone is low and that there is an 
administrative controls program in place to limit additional 
combustible materials and sources of ignition. The licensee also stated 
that there are minimal combustibles in Fire Zone OB-FZ-8B. The major 
combustibles in Fire Zone OB-FZ-8A are lubricating oil (approximately 
83% of loading) and cable insulation (approximately 13% of loading).
3.5.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-8A has a partial wet-pipe sprinkler 
system with a flow alarm that notifies the control room and that the 
area does not have a smoke detection system however, a duct smoke 
detector is located in the exhaust duct of fan EF-1-20. Since operation 
of the sprinkler system will alarm in the control room, prompt 
notification of and response by, the fire brigade for any required 
manual fire fighting activities is expected.
3.5.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-8A has a ceiling height of 
approximately 10'-10'' and an approximate floor area of 2128 square 
feet and OB-FZ-8B has a ceiling height of approximately 11'-0'' and an 
approximate floor area of 479 square feet so it is unlikely that smoke 
and heat would accumulate at the height of the safe shutdown equipment 
and cause a failure due to fire damage.
3.5.4 OMAs Credited for a Fire in This Area
3.5.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17

[[Page 19495]]

becomes necessary, the licensee stated that they have assumed a 30-
minute diagnosis period and that the required time to perform the 
action is 26 minutes, while the time available is 300 minutes, which 
provides a 244-minute margin.
3.5.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment in this zone, combined with the ability of OMA 17 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.6 OB-FZ-8C Office Bldg. A/B Battery Room, Tunnel and Electrical Tray 
Room Elev. 35'-0''

3.6.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in Fire Zone OB-FZ-8C are 
electrolyte-filled plastic battery cases and racks (approximately 56% 
of loading) and cable insulation (approximately 39% of loading).
3.6.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-8C has a fixed, total-flooding, 
Halon 1301 extinguishing system, area-wide smoke detection that is 
installed at the ceiling level and cross-zoned to sound a local alarm, 
and an alarm in the control room upon actuation of one detector. 
Actuation of a second detector will sound a local alarm, discharge the 
Halon system, trip supply and exhaust fans, and close dampers.
3.6.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-8C has a ceiling height of 
approximately 11'-0'' and an approximate floor area of 1292 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.6.4 OMAs Credited for a Fire in This Zone
3.6.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.6.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
Halon systems noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMA 17 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.7 OB-FZ-10A Office Bldg. Monitor and Change Room and Operations 
Support Area Elev. 35'-0'' & 46'-6''

3.7.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are cable 
insulation (approximate 27% of loading), rubber flooring (approximately 
31% of loading), miscellaneous plastics (approximately 17% of loading) 
and protective clothing supplies (approximately 20% of loading). 
However, since the protective clothing have been placed in metal cans 
with self-closing lids they are no longer considered a contribution to 
the combustibles in this area.
3.7.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-10A has an area-wide smoke detection 
system and a wet-pipe automatic sprinkler system installed throughout 
the area. In addition, a hose station located nearby, outside the 
control room, provides manual suppression capability.
3.7.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-10A has a ceiling height of 
approximately 13'-0'' and an approximate floor area of 2019 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.

[[Page 19496]]

3.7.4 OMAs Credited for a Fire in This Area
3.7.4.1 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 29 minutes, while the time available is 300 
minutes, which provides a 241-minute margin.
3.7.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this zone, combined with the ability of OMA 
18 to manipulate the plant in the event of a fire that damages 
safe shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

3.8 RB-FZ-1D Reactor Bldg. Elev. 51'-3''

3.8.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the main combustible in this area is attributed to 
cable insulation (approximately 84% of loading).
3.8.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1D has an area-wide smoke detection 
system and an automatic fixed deluge water spray system installed over 
cable trays and open hatches. The deluge suppression system protecting 
safety related cable trays is automatically activated by a cross-zoned 
detection system consisting of linear heat detection wire located on 
top of the cables in each original safety related cable tray and smoke 
detectors are located in each beam pocket at the ceiling.
3.8.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1D has a ceiling height of 
approximately 21'-0'' and an approximate floor area of 9,100 square 
feet so it is unlikely that smoke and heat would accumulate at the 
height of the safe shutdown equipment and cause a failure due to fire 
damage.
3.8.4 OMAs Credited for a Fire in This Area
3.8.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.

[[Page 19497]]

3.8.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
localized water deluge systems noted above, or personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this area, combined with the 
ability of OMA 17 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

3.9 RB-FZ-1E Reactor Bldg. Elev. 51'-3''

3.9.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the main combustible in this area is attributed to 
cable insulation (approximately 84% of loading).
3.9.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1E has an area-wide smoke detection 
system and an automatic fixed deluge water spray system installed over 
cable trays and open hatches. The deluge suppression system protecting 
safety related cable trays is automatically activated by a cross-zoned 
detection system consisting of linear heat detection wire located on 
top of the cables in each original safety related cable tray and smoke 
detectors are located in each beam pocket at the ceiling.
3.9.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1E has a ceiling height of 
approximately 26'-9'' and an approximate floor area of 12,140 square 
feet so it is unlikely that smoke and heat would accumulate at the 
height of the safe shutdown equipment and cause a failure due to fire 
damage.
3.9.4 OMAs Credited for a Fire in This Zone
3.9.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.9.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
localized water deluge systems noted above, or personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this zone, combined with the 
ability of OMA 17 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

3.10 RB-FZ-1F3 Reactor Bldg. Northwest Corner Elev. -19'-6''

3.10.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are cable 
insulation (approximately 58% of loading), ladders (approximately 16% 
of loading) and lubricating oil in pumps (approximately 16% of 
loading).
3.10.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1F3 has smoke detectors which alarm 
locally and in the control room installed over hazards rather than 
mounted at the ceiling. Fire extinguishers are also provided for manual 
fire fighting backup. Hose lines are available from outside hydrants 
and hose houses.
3.10.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1F3 has a ceiling height of 
approximately 41'-6'' and an approximate floor area of 560 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.10.4 OMAs Credited for a Fire in This Zone
3.10.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to

[[Page 19498]]

the accumulator of Condensate Transfer System valve V-11-34 and that 
these air-operated valves are used to control makeup to the isolation 
condensers. Each valve is provided with an air accumulator that 
provides a minimum of six full cycles. As a result, this OMA is only 
necessary to ensure long-term operation of these valves and makeup to 
the isolation condensers. Further, this OMA would only be necessary if 
the plant had to remain in hot shutdown for an extended time. This 
scenario is unlikely for this particular area since the plant would 
likely reach cold shutdown before the action is required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.10.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection 
system or personnel and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area, combined with the ability of OMA 17 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

3.11 RB-FZ-1F5 Reactor Bldg. Torus Room Elev. -19'-6''

3.11.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are cable 
insulation (approximately 19% of loading) and gratings (approximately 
76% of loading). The grating, which is the largest plastic material in 
this area, has a low flame spread rating (less than 25).
3.11.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1F5 does not have detection or 
suppression systems. However, due to the limited combustible loading 
and the nature of the combustibles, a fire in this zone is not expected 
to be of significant size or duration.
3.11.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1F5 is a voluminous area with an 
approximate floor area of 11,450 square feet and a ceiling height of 
approximately 41'-6'' therefore, it is unlikely that smoke and heat 
from a fire in the area would accumulate at the location of the 
instrument air line and cause a loss of instrument air.
3.11.4 OMAs Credited for a Fire in This Zone
3.11.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.11.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the area, it is unlikely that a fire 
would occur and go undetected or unsuppressed by personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this area, combined with the 
ability of OMA 17 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

3.12 RB-FZ-1G Reactor Bldg. Shutdown Cooling Room Elev. 38'-0'' & 51'-
3''

3.12.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional

[[Page 19499]]

combustible materials and sources of ignition. The licensee also stated 
that the main combustibles in this area are cable insulation 
(approximately 12% of loading), plastic (approximately 57% of loading) 
and Class A combustibles (approximately 14% of loading). The grating, 
which is the majority of the plastic material in this area, has a low 
flame spread rating (less than 25).
3.12.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1G is provided with a smoke 
detection system that alarms locally and in the control room to provide 
prompt notification of a potential fire event.
3.12.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1G has a ceiling height of 
approximately 21', measured from the 51'-3'' elevation, and an 
approximate floor area of 1,609 square feet so it is unlikely that 
smoke and heat would accumulate at the height of the safe shutdown 
equipment and cause a failure due to fire damage.
3.12.4 OMAs Credited for a Fire in This Area
3.12.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.12.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection 
system or personnel and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
area, combined with the ability of OMA 17 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

3.13 TB-FA-3A Turbine Bldg. 4160V Emergency Switchgear Vault 1C Elev. 
23'-6''

3.13.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that there are minimal amounts of cable insulation 
(approximately 5% of loading) miscellaneous plastic (approximately 73% 
of loading) and class A combustibles such as paper for procedures 
(approximately 20% of loading) in this area.
3.13.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FA-3A is provided with an area-wide 
smoke detection system and a total-flooding, manually actuated CO2 
system.
3.13.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FA-3A has a ceiling height of 
approximately 21' and an approximate floor area of 336 square feet so 
it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.13.4 OMAs Credited for a Fire in This Area
3.13.4.1 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally,

[[Page 19500]]

RPV level indication will not be compromised by a fire in any zone or 
area. All of these indications would help the operator diagnose the 
loss of instrument air and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.13.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
CO2 systems, or personnel, and damage the safe shutdown equipment. The 
low likelihood of damage to safe shutdown equipment due to a fire in 
this area, combined with the ability of OMA 17 to manipulate 
the plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

3.14 TB-FA-26 Turbine Bldg. 125V DC Battery Room C Elev. 23'-6''

3.14.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are plastic, which 
is contributed by the battery cases (approximately 92% of loading) and 
cable insulation (approximately 6% of loading).
3.14.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FA-26 has an area-wide automatic pre-
action sprinkler system and an area-wide smoke detection system 
installed.
3.14.3 Preservation of Safe Shutdown Capability
    The licensee stated that there are no specific cables in this fire 
area associated with the OMAs identified for Fire Area TB-FA-26 and 
that the only fire safe shutdown component and cable located in this 
fire area is associated with the ``C'' battery.
3.14.4 OMAs Credited for a Fire in This Area
    The licensee stated that this fire area is wholly contained within 
Fire Zone TB-FZ-11C (A and B 4160V Room) and that all cables to TB-FA-
26 must traverse TB-FZ-11C. Therefore, TB-FA-26 and TB-FZ-11C were 
analyzed together for safe shutdown purposes and the OMAs are 
duplicated for these two plant areas. Refer to Section 3.16 below for 
the discussion of OMAs 1, 2, 3, 7, 
8, and 18.
3.14.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and lack of multiple safe shutdown trains in this area, it is 
unlikely that a fire would occur and go undetected or unsuppressed by 
the smoke detection or sprinkler systems, or personnel, and damage the 
safe shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of OMAs 
1, 2, 3, 7, 8, and 
18 to manipulate the plant in the event of a fire that damages 
safe shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

3.15 TB-FZ-11B Turbine Bldg. Lube Oil Storage, Purification and Pumping 
Area Elev. 0'-0'', 27'-0'', and 36'-0''

3.15.1 Fire Prevention
    The licensee stated that the fire loading in this zone is high and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are lubricating 
oil (approximately 99% of loading) and cable insulation (approximately 
0.3% of loading).
3.15.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11B has automatic suppression 
systems installed over principal combustibles and a rate of rise/fixed 
temperature fire detection system installed at the lube oil tank. A 
closed head automatic sprinkler system protects cable trays and open 
head water spray deluge system protects oil handling equipment and the 
oil storage tank. Thermal detectors are located in close proximity to 
the lube oil tank so that a lube oil fire would be quickly detected, 
which in turn would activate the deluge system for extinguishment. 
Additionally, the licensee stated that there are fire extinguishers 
provided throughout the zone and that aqueous film-forming foam (AFFF) 
is staged in the Fire Brigade van for use if necessary.
3.15.3 Preservation of Safe Shutdown Capability
    The licensee stated that the ceiling heights in the area are 
approximately 9'-0'' in the basement hallway, approximately 19'-0'' in 
the basement stairs, approximately 26'-0'' on the first floor of the 
area, and approximately 42'-0'' on the second floor of the area. 
Additionally, the licensee stated that the floor area, measured at the 
0'-0'' elevation is approximately 3175 square feet.
3.15.4 OMAs Credited for a Fire in This Zone
3.15.4.1 OMA 3--Manually Control 480V USS 1B2 Breakers for CRD 
Pump at Remote Shutdown Panel
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 14 feet above the floor. 
The licensee also stated that the cables pass over the top of potential 
ignition sources MCC 1A12 and MCC 1B12 and that the cables are located 
approximately 6 feet above these ignition sources. Additionally, the 
lube oil tanks are located below the cables, although not directly 
below, with a distance of approximately 26 feet separating the cables 
and the tanks. The cables are also located approximately 20 feet from 
ignition sources MCC 1A12A and 1B12A.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 480V USS 1B2 Breakers for CRD Pump NC08B and 1B2M from the 
Remote Shutdown Panel due to control circuit damage. The licensee also 
stated that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 8 minutes while the time 
available is 180 minutes, which provides a 142-minute margin.
3.15.4.2 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout

[[Page 19501]]

many areas of the plant. The licensee's analysis assumes that the air 
line could potentially fail in approximately 45 minutes when exposed to 
the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.15.5 Conclusion
    Although the fire loading is high, the limited ignition sources, 
large volume of the space, and the detection and suppression system 
make it unlikely that a fire would occur and go undetected or 
unsuppressed and damage the safe shutdown equipment. Additionally, the 
availability of fire extinguishers and AFFF, which is effective against 
oil based fires, provides an augmented ability to suppress a fire prior 
to damaging safe shutdown equipment. The low likelihood of damage to 
safe shutdown equipment due to a fire in this zone, combined with the 
ability of OMAs 3 and 18 to manipulate the plant in 
the event of a fire that damages safe shutdown equipment, provides 
adequate assurance that safe shutdown capability is maintained.

3.16 TB-FZ-11C Turbine Bldg. 4160V SWGR Room 1A and 1B Elev. 23'-6''

3.16.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the main combustible loading is attributed to cable 
insulation (approximately 73% of loading) and plastic (approximately 
17% of loading).
3.16.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11C has an area-wide smoke detection 
system and an area-wide automatic fixed pre-action sprinkler system 
(except in the small caged area located to the east of Fire Area TB-FA-
3A) installed.
3.16.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11C has a ceiling height of 
approximately 21'-8'' and an approximate floor area of 2666 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.16.4 OMAs Credited for a Fire in This Area
3.16.4.1 OMA 1--Trip Field Breakers for Recirculation Pumps MG 
Set
    In order for OMA 1 to be necessary, damage to the 1A and 
1B 4160V Switchgear Cabinets and the ``C'' Battery distribution panel, 
or the associated control wiring, would have to occur due to a fire and 
prevent tripping of the 4160V motor-generator set breakers. The 
licensee stated that these cables are located in the same tray with 
additional cables and are generally located at least 17 feet above the 
floor. The licensee also stated that the tray passes over the top of 
potential ignition source ``B'' 4160V switchgear and that the cables 
are located approximately 9 feet above this ignition source and 3 feet 
above the iso-phase bus duct at their closest point.
    In the unlikely event that a fire does occur and damages the 
credited and redundant equipment, OMA 1 is available to trip 
the field breakers for the recirculation pumps motor-generator set so 
that the Fuel Zone Level Indicators can be used. The licensee also 
stated that they have assumed a 10-minute diagnosis period and that the 
required time to perform the action is 8 minutes while the time 
available is 30 minutes, which provides a 12-minute margin.
3.16.4.2 OMA 2--Align Fire Water to Isolation Condenser
    In order for OMA 2 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. The licensee also stated that these 
cables are located in the same tray with additional cables and are 
generally located at least 17 feet above the floor and that the tray 
passes over the top of potential ignition source ``B'' 4160V switchgear 
and that the cables are located approximately 9 feet above this 
ignition source and 3 feet above the iso-phase bus duct at their 
closest point.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 2 is available to provide 
fire water to the isolation condenser shell by operating valves V-9-
2099, V-11-49, V-11-63, and V-11-41 due to loss of power. The licensee 
also stated that they have assumed a 10-minute diagnosis period and 
that the required time to perform the action is 13 minutes while the 
time available is 45 minutes, which provides a 22-minute margin.
3.16.4.3 OMA 3--Manually Control 480V USS 1B2 Breakers for CRD 
Pump at Remote Shutdown Panel
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 17 feet above the floor. The 
licensee also stated that the tray passes over the top of potential 
ignition source ``B'' 4160V switchgear and that the cables are located 
approximately 9 feet above this

[[Page 19502]]

ignition source and 3 feet above the iso-phase bus duct at their 
closest point.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 480V USS 1B2 Breakers for CRD Pump NC08B and 1B2M from the 
Remote Shutdown Panel due to control circuit damage. The licensee also 
stated that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 8 minutes while the time 
available is 180 minutes, which provides a 142-minute margin.
3.16.4.4 OMA 7--Provide Makeup to Isolation Condenser via V-
11-36
    In order for OMA 7 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. The licensee also stated that these 
cables are located in the same tray with additional cables and are 
generally located at least 17 feet above the floor and that the tray 
passes over the top of potential ignition source ``B'' 4160V switchgear 
and that the cables are located approximately 9 feet above this 
ignition source and 3 feet above the iso-phase bus duct at their 
closest point.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-11-36 to provide makeup to Isolation Condenser due to loss of 
power. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 16 
minutes while the time available is 45 minutes, which provides a 19-
minute margin.
3.16.4.5 OMA 8--Locally Check Isolation Condenser Shell Level
    In order for OMA 8 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. The licensee also stated that these 
cables are located in the same tray with additional cables and are 
generally located at least 17 feet above the floor and that the tray 
passes over the top of potential ignition source ``B'' 4160V switchgear 
and that the cables are located approximately 9 feet above this 
ignition source and 3 feet above the iso-phase bus duct at their 
closest point.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 8 is available to check the 
isolation condenser shell level locally due to loss of power. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 16 minutes 
while the time available is 45 minutes, which provides a 19-minute 
margin.
3.16.4.6 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the main MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.16.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of OMAs 
1, 2, 3, 7, 8, and 
18 to manipulate the plant in the event of a fire that damages 
safe shutdown equipment, provide adequate assurance that safe shutdown 
capability is maintained.

3.17 TB-FZ-11D Turbine Bldg. Basement Floor South End Elev. 3'-6''

3.17.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are cable 
insulation (approximately 29% of loading), Dow Corning 561 Silicon 
transformer liquid (approximately 15% of loading) and lubricating oil 
(approximately 40% of loading).
3.17.2 Detection, Control, and Extinguishment
    The licensee stated that an automatic wet-pipe sprinkler system and 
an automatic water spray system located at the hydrogen seal oil unit 
are installed in the area.
3.17.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11D has a ceiling height of 
approximately 19' and an approximate floor area of 9668 square feet so 
it is unlikely that smoke and heat would accumulate at the

[[Page 19503]]

height of the safe shutdown equipment and cause a failure due to fire 
damage.
3.17.4 OMAs Credited for a Fire in This Zone
3.17.4.1 OMA 1--Trip Field Breakers for Recirculation Pumps MG 
Set
    In order for OMA 1 to be necessary, damage to the 1A and 
1B 4160V Switchgear Cabinets and the ``C'' Battery distribution panel, 
or the associated control wiring, would have to occur due to a fire and 
prevent tripping of the 4160V MG set breakers. The licensee stated that 
these cables are located in the same tray with additional cables and 
are generally located at least 15 feet above the floor. The primary 
combustible fuel load in the area is the cables themselves and storage 
of transient combustibles is limited due to a sump and abandoned acid/
caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant equipment, OMA 1 is available to trip 
the field breakers for the recirculation pumps MG Set so that the fuel 
zone level indicators can be used. The licensee also stated that they 
have assumed a 10-minute diagnosis period and that the required time to 
perform the action is 8 minutes while the time available is 30 minutes, 
which provides a 12-minute margin.
3.17.4.2 OMA 2--Align Fire Water to Isolation Condenser
    In order for OMA 2 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. In addition, the licensee stated that 
these cables are located in the same tray with additional cables and 
are generally located at least 15 feet above the floor. The primary 
combustible fuel load in the area is the cables themselves and storage 
of transient combustibles is limited due to a sump and abandoned acid/
caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 2 is available to provide 
fire water to the isolation condenser shell by operating valves V-9-
2099, V-11-49, V-11-63, and V-11-41 due to loss of power. The licensee 
also stated that they have assumed a 10-minute diagnosis period and 
that the required time to perform the action is 13 minutes while the 
time available is 45 minutes, which provides a 22-minute margin.
3.17.4.3 OMA 3--Manually Control 480V USS 1B2 Breakers for CRD 
Pump at Remote Shutdown Panel
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 15 feet above the floor. The 
primary combustible fuel load in the area is the cables themselves and 
storage of transient combustibles is limited due to a sump and 
abandoned acid/caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 480V USS 1B2 Breakers for CRD Pump NC08B and 1B2M from the 
Remote Shutdown Panel due to control circuit damage. The licensee also 
stated that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 8 minutes while the time 
available is 180 minutes, which provides a 142-minute margin.
3.17.4.4 OMA 7--Provide Makeup to Isolation Condenser via V-
11-36
    In order for OMA 7 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. In addition, the licensee stated that 
these cables are located in the same tray with additional cables and 
are generally located at least 15 feet above the floor. The primary 
combustible fuel load in the area is the cables themselves and storage 
of transient combustibles is limited due to a sump and abandoned acid/
caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building

[[Page 19504]]

Closed Cooling Water Pumps and USS 1A1 and its associated transformer 
(4160V to 480V transformer). However, the Turbine Building Closed 
Cooling Water Pumps contain less than 5 gallons of oil and are enclosed 
in metal casings and the cable tray containing the cables is 
approximately 13 feet from the top of the pumps/motors. The top of USS 
1A1 and its associated transformer are located approximately 30 feet 
diagonally from the credited cables and approximately 15 feet 
diagonally from the redundant cables. Additionally, there is a concrete 
ceiling beam, with a water curtain sprinkler system attached, which 
would provide some shielding for the cables from potential products of 
combustion generated by this ignition source. Sprinkler heads are also 
located in a ceiling pocket between the concrete ceiling beam and the 
USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-11-36 to provide makeup to Isolation Condenser due to loss of 
power. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 16 
minutes while the time available is 45 minutes, which provides a 19-
minute margin.
3.17.4.5 OMA 8--Locally Check Isolation Condenser Shell Level
    In order for OMA 8 to be necessary, loss of the ``B'' 
train of power would have to occur due to a fire causing a loss of both 
condensate transfer pumps. The licensee stated that this OMA is 
dependent on the LSP-1D OMA, which was included in the licensee's Phase 
1 request, and would not be required unless the OMA at the LSP-1D is 
required and access is not immediately available. As such, this OMA is 
considered a contingency action. In addition, the licensee stated that 
these cables are located in the same tray with additional cables and 
are generally located at least 15 feet above the floor. The primary 
combustible fuel load in the area is the cables themselves and storage 
of transient combustibles is limited due to a sump and abandoned acid/
caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 8 is available to check the 
isolation condenser shell level locally due to loss of power. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 16 minutes 
while the time available is 45 minutes, which provides a 19-minute 
margin.
3.17.4.6 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.17.5 Conclusion
    Given the limited amount of combustible materials, ignition sources 
and the volume of the space, it is unlikely that a fire would occur and 
go undetected or unsuppressed by the suppression systems noted above, 
or personnel, and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
zone, combined with the ability of OMAs 1, 2, 
3, 7, 8, and 18 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

3.18 TB-FZ-11E Turbine Bldg. Condenser Bay Area Elev. 0'-''0

3.18.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles in this area are cable 
insulation (approximately 40% of loading) and plastic (approximately 
59% of loading). The grating, which is the largest plastic material in 
this area, is dispersed throughout this fire zone (not concentrated) 
and has a low flame spread (less than 25). The licensee also stated 
that this Fire Zone is procedurally controlled as a transient 
combustible free area while the plant is operating and that this area 
is a high

[[Page 19505]]

radiation area during plant operation and is not normally accessed.
3.18.2 Detection, Control, and Extinguishment
    The licensee stated that a closed head automatic sprinkler and 
spray systems protect the south end basement area and the hydrogen seal 
oil unit. An exemption was granted from the requirements of Appendix R 
Section III.G.2 in safety evaluations dated March 24, 1986, and June 
25, 1990, for not having fixed fire detection in this area. The primary 
basis for this exemption was the presence of the automatic wet pipe 
sprinkler system and low fire loading. The Condenser Bay is 
procedurally controlled as a transient combustible free area in while 
the plant is operating. If a fire did occur, the flow alarm would 
notify the control room of any sprinkler system activation. 
Extinguishment of a fire can be accomplished by the automatic fixed 
suppression system and the plant fire brigade. A closed head automatic 
sprinkler system was recently expanded to provide fire suppression over 
the cables in cable trays in the northeast side of the condenser bay.
3.18.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11E has a ceiling height of at least 
40' and an approximate floor area of 26,427 square feet so it is 
unlikely that smoke and heat would accumulate at the height of the safe 
shutdown equipment and cause a failure due to fire damage.
3.18.4 OMAs Credited for a Fire in This Zone
3.18.4.1 OMA 3--Manually Control 480V USS 1B2 Breakers for CRD 
Pump at Remote Shutdown Panel
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 40 feet above the floor. 
With the exception of the cables themselves, there are no other 
ignition sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 480V USS 1B2 Breakers for CRD Pump NC08B and 1B2M from the 
Remote Shutdown Panel due to control circuit damage. The licensee also 
stated that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 8 minutes while the time 
available is 180 minutes, which provides a 142-minute margin.
3.18.4.2 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.18.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the suppression system 
noted above or personnel, and damage the safe shutdown equipment. The 
low likelihood of damage to safe shutdown equipment due to a fire in 
this zone, combined with the ability of OMAs 3 and 18 
to manipulate the plant in the event of a fire that damages safe 
shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

3.19 TB-FZ-11F Turbine Bldg. Feedwater Pump Room Elev. 0'-0'' & 3'-6''

3.19.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustible load consists of cable 
insulation (approximately 15% of loading), lubricating oil 
(approximately 39% of loading), rubber (approximately 21% of loading) 
and plastics (approximately 17% of loading). The licensee states that 
the majority of the combustible loading attributed to rubber and 
plastic was due to the storage of hoses that are now no longer in the 
area.
3.19.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11F has an area-wide thermal fire 
detection system. Extinguishment of the fire will be accomplished by 
the plant fire brigade.
3.19.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11F has a ceiling height of 
approximately 16' in approximately 70% of the area and approximately 
19'-6'' in the remainder of the area. With an approximate floor area of 
5650 square feet, it is unlikely that smoke and heat would accumulate 
at the height of the safe shutdown equipment and cause a failure due to 
fire damage.

[[Page 19506]]

3.19.4 OMAs Credited for a Fire in This Zone
3.19.4.1 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.19.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the thermal detection 
system noted above or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMA 18 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.20 TB-FZ-11H Turbine Bldg. Demineralizer Tank and Steam Jet Air 
Ejector Area Elev. 3'-6'' & 23'-6''

3.20.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there is an administrative controls program in place to limit 
additional combustible materials and sources of ignition. The licensee 
also stated that the major combustibles are cable insulation 
(approximately 23% of loading), ladders and other miscellaneous 
plastics (approximately 55% of loading) and miscellaneous ordinary 
combustibles.
3.20.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11H has a partial area thermal fire 
detector system. The system alarms locally and in the control room. 
Manual extinguishment of fire will be accomplished by the plant fire 
brigade.
3.20.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11H has a ceiling height of 
approximately 7'-0'', measured at the 3'-6'' elevation, and 
approximately 19'-0'', measured at the 23'-6'' elevation with an 
approximate floor area of 3,944 square feet and 4,366 square feet, 
respectively, so it is unlikely that smoke and heat would accumulate at 
the height of the safe shutdown equipment and cause a failure due to 
fire damage.
3.20.4 OMAs Credited for a Fire in This Area
3.20.4.1 OMA 18--Provide Makeup Air to Isolation Condenser 
Valve V-11-36 Accumulator
    In order for OMA 18 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-36 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 18 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-36 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 18 is available 
to provide makeup control air to the accumulator for V-11-36 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 18 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26

[[Page 19507]]

minutes, while the time available is 300 minutes, which provides a 244-
minute margin.
3.20.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the thermal detection 
system noted above or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMA 18 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

3.21 Yard

3.21.1 Fire Prevention
    The licensee stated that no specific quantification of fire loading 
was considered necessary for the Yard area since it is an outdoor area 
with no ceiling or physical boundaries to contain heat and smoke from a 
fire event.
3.21.2 Detection, Control, and Extinguishment
    The licensee stated that there is no fire detection or fixed fire 
suppression systems installed in this area but that manual suppression 
is provided by a hose station from the office building and by fire 
hydrants located throughout the Yard area.
3.21.3 Preservation of Safe Shutdown Capability
    Since the Yard area is an outdoor space with no walls or ceiling, 
smoke and heat would not accumulate within the fire area to cause 
damage to components remote to the initiating fire or obstruct operator 
actions.
3.21.4 OMAs Credited for a Fire in This Area
3.21.4.1 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.21.4.2 OMA 17--Provide Makeup Air to Isolation Condenser 
Valve V-11-34 Accumulator
    In order for OMA 17 to be necessary, a loss of instrument 
air to the isolation condenser valve V-11-34 would have to occur due to 
fire damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that OMA 17 connects a high 
pressure air cylinder to the accumulator of Condensate Transfer System 
valve V-11-34 and that these air-operated valves are used to control 
makeup to the isolation condensers. Each valve is provided with an air 
accumulator that provides a minimum of six full cycles. As a result, 
this OMA is only necessary to ensure long-term operation of these 
valves and makeup to the isolation condensers. Further, this OMA would 
only be necessary if the plant had to remain in hot shutdown for an 
extended time. This scenario is unlikely for this particular area since 
the plant would likely reach cold shutdown before the action is 
required.
    In addition, the licensee stated that they maintain a fire support 
procedure (ABN-35, ``Loss of Instrument Air'') that provides guidance 
to perform this OMA if instrument air is lost and indicates that there 
are four annunciator alarm windows that monitor instrument air 
pressure, plus a pressure gauge on a panel in the control room for 
instrument air pressure. If all of these instruments are not available, 
then ABN-35 further indicates that the control rods will start to drift 
into the core and the MSIVs will close, as well as multiple air-
operated valves changing state. Additionally, RPV level indication will 
not be compromised by a fire in any zone or area. All of these 
indications would help the operator diagnose the loss of instrument air 
and initiate mitigating procedures.
    In the unlikely event that a fire does occur and causes a loss of 
instrument air to the air-operated valves, OMA 17 is available 
to provide makeup control air to the accumulator for V-11-34 for the 
isolation condenser makeup line due to the loss of instrument air. If 
OMA 17 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 26 minutes, while the time available is 300 
minutes, which provides a 244-minute margin.
3.21.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the thermal detection 
system noted above or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this area, combined with the ability of OMAs 12 
and 17 to manipulate the plant in the event of a fire that 
damages safe shutdown equipment, provides adequate assurance that safe 
shutdown capability is maintained.

3.22 Feasibility and Reliability of the Operator Manual Actions

    This analysis postulates that OMAs may be needed to assure safe 
shutdown capability in addition to the traditional fire protection 
features described above. NUREG-1852, ``Demonstrating the Feasibility 
and Reliability of Operator Manual Actions in Response to Fire,'' 
provides criteria and associated technical bases for evaluating the 
feasibility and reliability of post-fire OMAs in nuclear power plants. 
The following provides the Oyster Creek analysis of these criteria for 
justifying the OMAs specified in this exemption.
3.22.1 Bases for Establishing Feasibility and Reliability
    Using NUREG-1852, the NRC staff has evaluated the feasibility and 
reliability review provided by the licensee in the April 2, 2010, 
Response to Request for Additional Information. For an OMA to be 
considered feasible, the required actions must be proceduralized, any 
equipment that is needed to implement the OMA is available, the 
environments in which the OMA is to be performed must permit the 
action, and the time taken to diagnose the need for the OMA and 
implement it (time required) must be

[[Page 19508]]

less than the time in which the OMA must be completed (time available).
3.22.2 Feasibility
    The feasibility review provided by the licensee documents that 
procedures are in place, in the form of fire response procedures, to 
ensure that clear and accessible instructions on how to perform the 
manual actions are available to the operators. All of the requested 
OMAs are directed by plant procedures, and the operators are trained in 
the use of the procedures. Specifically, the licensee stated that 
procedure ABN-29, Plant Fires, is entered whenever a fire or indication 
of a fire occurs on the main fire alarm panel in the control room or at 
any local fire alarm panel. In addition to dispatching a radio-equipped 
operator to the alarming location, ABN-29 also directs that the fire 
brigade be dispatched whenever a fire suppression system has actuated 
(sprinkler, deluge, Halon, or CO2) or a fire is confirmed. 
In addition, the licensee stated that ABN-29 directs immediate entry 
into the Fire Support Procedure (FSP) for the affected fire area as 
soon as the existence of a fire is confirmed. The licensee states that 
the following indications or symptoms are considered examples of a 
confirmed fire:
     Fire detection alarm and equipment malfunction indication 
or alarms within the same area;
     Fire pump start and either sprinkler flow alarm or deluge 
flow alarm;
     Gaseous suppression system actuation;
     Report from the field of an actual smoke condition or 
actual fire condition; or
     Fire detection alarm with follow up confirmation by field 
operator.
    Entering the FSP means that the operator will review the FSP, 
identify equipment that could be affected, identify equipment that will 
be available, monitor plant equipment from the control room and 
communicate with the fire brigade leader. Based on the symptoms 
received in the control room and the feedback from the fire brigade 
leader, the operator will decide using the procedure what mitigating 
actions are necessary. In the event that a plant shutdown has occurred 
before the FSP is entered, the operator will still enter the FSP based 
on the fire and initiate the OMAs as appropriate. OMAs that are 
considered ``prompt'' (i.e., those that must be done within 45 minutes 
or less) are identified in both ABN-29 and in the applicable FSPs as an 
item requiring immediate attention. The operators are trained to 
perform prompt actions first and prioritize them based upon existing 
plant conditions. The FSPs are based on the worst-case loss 
considerations by assuming all fire damage occurs instantaneously and 
thus all operator manual actions will be required. The use of the 
Emergency Operating Procedures in conjunction with the applicable FSPs 
will permit the use of any mitigating system available first, and if a 
desired system is not available, the FSP provides a contingency action 
to restore the system or provide another means to perform the function. 
Operator training, including simulator demonstrations and plant walk 
downs, has been performed to ensure consistency in operator and team 
response for each OMA.
    The licensee evaluated several potential environmental concerns, 
such as radiation levels, temperature/humidity conditions and the 
ventilation configuration and fire effects that the operators may 
encounter during certain emergency scenarios. The licensee's 
feasibility review concluded that the operators performing the manual 
actions would not be exposed to adverse or untenable conditions during 
any particular operator manual action procedure or during the time to 
perform the procedure. The licensee stated that OMAs required for 
achieving and maintaining hot shutdown conditions are not impacted by 
environmental conditions associated with fires in the fire area 
identified in the request. Each of the safe shutdown calculations that 
provide the technical basis for the FSPs contains a timeline for 
operator actions for the specific fire area. In addition, the licensee 
stated that the equipment needed to implement OMAs remains available 
and the fire areas remain accessible during or following the event.
    The licensee's analysis demonstrates that, for the expected 
scenarios, the OMAs can be diagnosed and executed within the amount of 
time available to complete them. The licensee's analysis also 
demonstrates that various factors, as discussed above, have been 
considered to address uncertainties in estimating the time available. 
Therefore, the OMAs included in this review are feasible because there 
is adequate time available for the operator to perform the required 
OMAs to achieve and maintain hot shutdown following a postulated fire 
event. Table 2 summarizes the ``required'' verses ``available'' times 
for each OMA. The licensee has included any diagnosis time as part of 
the required time for performing a particular action. Where an action 
has multiple times or contingencies associated with the ``available'' 
completion time, the lesser time is used. This is approach is 
considered to represent a conservative approach to analyzing the 
timelines associated with each of the OMAs with regard to the 
feasibility and reliability of the actions included in this exemption. 
The licensee provided a discussion of the times and circumstances 
associated with each of the actions in their March 3, 2009, and April 
2, 2010, correspondence.

                                                     Table 2
----------------------------------------------------------------------------------------------------------------
                                                                  OMA        Required    Available      Margin
             OMA               Fire area/zone of fire origin    location    time (min)   time (min)     (min)
----------------------------------------------------------------------------------------------------------------
1...........................  TB-FA-26, TB-FZ-11C, and TB-FZ-    OB-FZ-8A           18           30           12
                               11D.
2...........................  TB-FA-26, TB-FZ-11C, and TB-FZ-    RB-FZ-1E           23           45           22
                               11D.
3...........................  TB-FA-26, TB-FZ-11B, TB-FZ-        OB-FZ-6B           38          180          142
                               11C, TB-FZ-11D, and TB-FZ-11E.
7...........................  TB-FA-26, TB-FZ-11C, and TB-FZ-    RB-FZ-1B           26           45           19
                               11D.
8...........................  TB-FA-26, TB-FZ-11C, and TB-FZ-    DG-FA-17           26           45           19
                               11D.
9...........................  Yard..........................     RB-FZ-1E           45          204          159
17..........................  CW-FA-14, OB-FZ-6A, OB-FZ-8A,      RB-FZ-1B           56          300          244
                               OB-FZ-8B, OB-FZ-8C, OB-FA-9,
                               RB-FZ-1D, RB-FZ-1E, RB-FZ-
                               1F3, RB-FZ-1F5, RB-FZ-1G, TB-
                               FA-3A, and Yard.
18..........................  OB-FZ-6B, TB-FA-26, TB-FZ-11B,     RB-FZ-1B           56          300          244
                               TB-FZ-11C, TB-FZ-11D, TB-FZ-
                               11E, TB-FZ-11F, and TB-FZ-11H.
                              OB-FZ-10A.....................  ...........           38           60           22
----------------------------------------------------------------------------------------------------------------


[[Page 19509]]

    The NRC staff reviewed the required operator manual action 
completion time limits versus the time before the action becomes 
critical to safely shutting down the unit as presented in the 
feasibility analyses. The NRC staff recognizes that, in some cases the 
time required neared the time available for an OMA. The NRC staff, 
however, also recognizes that there are conservatisms built in to these 
time estimates such as adding in the entire time assumed to diagnose 
the need for an OMA where in reality, the actual time take would likely 
be less.
    The NRC staff notes that, in one case, an OMA must be completed 
within 30 minutes (i.e., it is considered a prompt action). This action 
is identified as OMA 1 and requires an operator to trip the 
field breakers for the recirculation pumps MG set so that the Fuel Zone 
Level Indicators can be used. The action may be required as a result of 
fire in TB-FA-26, TB-FZ-11C, or TB-FZ-11D. The symptom for this action 
is the inability to trip the Recirculation Pumps from the control room 
and this is detected using the associated pump breaker indicating 
lights, alarms and flow indications. The Fire Support Procedures direct 
the operator to trip the pumps using the pump control switches or the 
Recirculation Pump Trip circuitry (two trip coils for pumps). If both 
of these methods fail on one or more pumps, the guidance is given to 
trip the pumps from the 4160V Switchgear 1A and 1B located outside the 
control room in Fire Area TB-FZ-11C. Only one operator would be 
required and it would take approximately 13 minutes for access to the 
area and to perform the action of tripping the breakers. Given the low 
complexity of this action, the NRC staff finds that there is a 
sufficient amount of time available to complete the proposed operator 
manual actions.

3.23 Reliability

    The completion times noted in the table above provide reasonable 
assurance that the OMAs can reliably be performed under a wide range of 
conceivable conditions by different plant crews. This is because the 
time margins associated with each action and other installed fire 
protection features, account for sources of uncertainty such as 
variations in fire and plant conditions, factors unable to be recreated 
in demonstrations and human-centered factors. Therefore, the OMAs 
included in this review are reliable because there is adequate time 
available to account for uncertainties not only in estimates of the 
time available, but also in estimates of how long it takes to diagnose 
a fire and execute the OMAs. This is based, in part, on a plant 
demonstration of the actions under non-fire conditions.

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

    In summary, the defense-in-depth concept for a fire in the fire 
areas discussed above provides a level of safety that limits the 
occurrence of fires and results in rapid detection, control and 
extinguishment of fires that do occur and the protection of structures, 
systems and components important to safety. It should be understood 
that the OMAs are a fall back in the unlikely event that the fire 
protection defense-in-depth features are insufficient. In most cases, 
there is no credible fire scenario that would necessitate the 
performance of these OMAs. As discussed above, the licensee has 
provided preventative and protective measures in addition to feasible 
and reliable OMAs that together demonstrate the licensee's ability to 
preserve or maintain safe shutdown capability in the event of a fire in 
the analyzed fire areas.

3.25 Authorized by Law

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

3.26 No Undue Risk to Public Health and Safety

    The underlying purpose of 10 CFR Part 50, Appendix R, Section III.G 
is to ensure that at least one means of achieving and maintaining hot 
shutdown remains available during and following a postulated fire 
event. Based on the above evaluation, the NRC staff finds that the 
plant features, as described in the March 3, 2009, submittal, as 
supplemented by letter dated April 2, 2010, should limit the occurrence 
and impacts of any fire that may occur. This, combined with the ability 
of the OMAs to place and maintain the plant in a safe condition in the 
event of a fire that does damage safe shutdown equipment, provides 
adequate protection of public health and safety. Therefore, there is no 
undue risk to public health and safety.

3.27 Consistent With Common Defense and Security

    This exemption would allow Oyster Creek to credit the use of the 
specific OMAs, in conjunction with the other installed fire protection 
features, in response to a fire in the analyzed fire areas, discussed 
above, in lieu of meeting the requirements specified in III.G.2. This 
change, to the operation of the plant, has no relation to security 
issues nor does it diminish the level of safety from what was intended 
by the requirements of III.G.2. Therefore, the common defense and 
security is not diminished by this exemption.

3.28 Special Circumstances

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

4.0 Conclusion

    Accordingly, the Commission has determined that, pursuant to 10 CFR 
50.12(a), the exemption is authorized by law, will not present an undue 
risk to the public health and safety, is consistent with the common 
defense and security and that special circumstances are present to 
warrant issuance of the exemption. Therefore, the Commission hereby 
grants Exelon an exemption from the requirements of Section III.G.2 of 
Appendix R of 10 CFR Part 50, to utilize the OMAs discussed above at 
Oyster Creek.
    Pursuant to 10 CFR 51.32, the Commission has determined that the 
granting of this exemption will not have a significant effect on the 
quality of the human environment (75 FR 33656).
    This exemption is effective upon issuance.

    Dated at Rockville, Maryland, this 30th day of March 2011.

[[Page 19510]]

    For the Nuclear Regulatory Commission.
Robert A. Nelson,
Acting Director, Division of Operating Reactor Licensing, Office of 
Nuclear Reactor Regulation.
[FR Doc. 2011-8318 Filed 4-6-11; 8:45 am]
BILLING CODE 7590-01-P