[Federal Register Volume 76, Number 68 (Friday, April 8, 2011)]
[Notices]
[Pages 19795-19817]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-8405]


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

NUCLEAR REGULATORY COMMISSION

[Docket No. 50-219; NRC-2010-0320]


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

1.0 Background

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

2.0 Request/Action

    Title 10 of the Code of Federal Regulations (10 CFR), part 50, 
Section 50.48 requires that nuclear power plants that were licensed 
before January 1, 1979, must satisfy the requirements of 10 CFR part 
50, Appendix R, Section III.G, ``Fire protection of safe shutdown 
capability.'' Oyster Creek was licensed to operate prior to January 1, 
1979. As such, the licensee's Fire Protection Program (FPP) must 
provide the established level of protection as intended by Section 
III.G of 10 CFR part 50, Appendix R.
    By letter dated March 3, 2009, ``Request for Exemption from 10 CFR 
50, Appendix R, Section III.G, `Fire Protection of Safe Shutdown 
Capability (Phase 1)' '' available at Agencywide Documents Access and 
Management System (ADAMS), Accession No. ML090630132, and supplemented 
by letter dated April 2, 2010, ``Response to Request for Additional 
Information Request for Exemption from 10 CFR 50, Appendix R, Section 
III.G, `Fire Protection of Safe Shutdown Capability' '' (ML100920370), 
the licensee requested an exemption for Oyster Creek from certain 
technical requirements of 10 CFR part 50, Appendix R, Section III.G.2 
(III.G.2) for the use of operator manual actions (OMAs) in lieu of 
meeting the circuit separation and protection requirements contained in 
III.G.2 for the following 21 plant Fire Areas: CW-FA-14, OB-FA-9, OB-
FZ-6A, OB-FZ-6B, OB-FZ-8A, OB-FZ-8B, OB-FZ-8C, OB-FZ-10A, RB-FZ-1D, RB-
FZ-1E, RB-FZ-1F3, RB-FZ-1F5, RB-FZ-1G, TB-FA-3A, TB-FA-26, TB-FZ-11B, 
TB-FZ-11C, TB-FZ-11D, TB-FZ-11E, TB-FZ-11F, and TB-FZ-11H. These 21 
plant areas are the subject of this exemption.

3.0 Discussion

    Pursuant to 10 CFR 50.12, the Commission may, upon application by 
any interested person or upon its own initiative, grant exemptions from 
the requirements of 10 CFR part 50 when: (1) The exemptions are 
authorized by law, will not present an undue risk to public health or 
safety, and are consistent with the common defense and security; and 
(2) when special circumstances are present. The licensee has stated 
that special circumstances are present in that the application of the 
regulation in this particular circumstance is not necessary to achieve 
the underlying purpose of the rule, which is consistent with the 
language included in 10 CFR 50.12(a)(2)(ii).
    In their March 3, 2009, and April 2, 2010, letters, the licensee 
discussed financial implications associated with plant modifications 
that may be necessary to comply with the regulation. 10 CFR 
50.12(a)2(iii) states that if such costs have been shown to be 
significantly in excess of those contemplated at the time the 
regulation was adopted, or are significantly in excess of those 
incurred by others similarly situated, this may be considered a basis 
for considering an exemption request. However, financial implications 
were not considered in the regulatory review of their request since no 
substantiation was provided regarding such financial implications. Even 
though no financial substantiation was provided, the licensee did 
submit sufficient regulatory basis to support a technical review of 
their exemption request in that the application of the regulation in 
this particular circumstance is not necessary to achieve the underlying 
purpose of the rule.
    In accordance with 10 CFR 50.48(b), nuclear power plants licensed 
before January 1, 1979, are required to meet Section III.G of 10 CFR 
part 50, Appendix R. The underlying purpose of Section III.G of 10 CFR 
part 50, Appendix R, is to ensure that the ability to achieve and 
maintain safe shutdown is preserved following a fire event. The 
regulation intends for licensees to accomplish this by extending the 
concept of defense-in-depth to:
    (1) Prevent fires from starting;
    (2) Rapidly detect, control, and extinguish promptly those fires 
that do occur;
    (3) Provide protection for structures, systems, and components 
important to safety so that a fire that is not promptly extinguished by 
the fire suppression activities will not prevent the safe shutdown of 
the plant.
    The stated purpose of 10 CFR part 50, Appendix R, Section III.G.2 
(III.G.2) is to ensure that one of the redundant trains necessary to 
achieve and maintain hot shutdown conditions remains free of fire 
damage in the event of a fire. III.G.2 requires one of the following 
means to ensure that a redundant train of safe shutdown cables and 
equipment is free of fire damage, where redundant trains are located in 
the same fire area outside of primary containment:
    a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
    b. Separation of cables and equipment by a horizontal distance of 
more than 20 feet with no intervening combustibles or fire hazards and 
with fire detectors and

[[Page 19796]]

an automatic fire suppression system installed in the fire area; or
    c. Enclosure of cables and equipment of one redundant train in a 
fire barrier having a 1-hour rating and with fire detectors and an 
automatic fire suppression system installed in the fire area.
    Exelon has requested an exemption from the requirements of III.G.2 
for Oyster Creek to the extent that redundant trains of systems 
necessary to achieve and maintain hot shutdown are not maintained free 
of fire damage in accordance with one of the required means prescribed 
in III.G.2.
    Each OMA included in this review consists of a sequence of tasks 
that occur in various fire areas. The OMAs are initiated upon 
confirmation of a fire in a particular fire area. Table 1 lists, in the 
order of the fire area of fire origin, the OMAs included in this 
review.

                                 Table 1
------------------------------------------------------------------------
   Area of fire origin         Area name           Actions       OMA No.
------------------------------------------------------------------------
1 CW-FA-14...............  Circulatory Water  Manually open            7
                            Intake.            valve (V) V-9-
                                               2099 and V-11-49
                                               and close V-11-
                                               63 and V-11-41.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
2 OB-FA-9................  Office Building    Locally read             2
                            (Bldg.) Elev.      Condensate
                            23'-6'', 35'-      Storage Tank
                            0'', 46'-6''.      level at level
                                               indicator (LI)
                                               LI-424-993 due
                                               to damage to
                                               control circuits.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
3 OB-FZ-6A...............  Office Bldg.       Locally read             2
                            ``A'' 480V         condensate
                            Switchgear         storage tank
                            (SWGR) Room        (CST) level at
                            Elev. 23'-6''.     LI-424-993 due
                                               to damage to
                                               control circuits.
                                              Use Remote               9
                                               Shutdown Panel
                                               (RSP) to control
                                               equipment: RSP,
                                               Control Rod
                                               Drive (CRD)
                                               Hydraulic Pump
                                               NC08B and 480V
                                               USS 1B2 Incoming
                                               breaker (Operate
                                               USS 1B2/CRD
                                               Transfer Switch
                                               (Partial
                                               initiation) to
                                               ``Alternate''
                                               and operate
                                               Control Switches
                                               for USS-1B2 Main
                                               Breaker and B
                                               CRD Pump).
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
4 OB-FZ-6B...............  Office Bldg.       Manually open V-9-       7
                            ``B'' 480V SWGR    2099 and V-11-49
                            Room Elev. 23'-    and close V-11-
                            6''.               63 and V-11-41.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI)
                                               FI-225-2 and
                                               close V-15-52.
------------------------------------------------------------------------
5 OB-FZ-8A...............  Office Bldg.       Manually open V-9-       7
                            Reactor            2099 and V-11-49
                            Recirculation      and close V-11-
                            Motor Generator    63 and V-11-41.
                            (MG) Set Room
                            Elev. 23'-6''.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
6 OB-FZ-8B...............  Office Bldg.       Manually open V-9-       7
                            Mechanical         2099 and V-11-49
                            Equipment Room     and close V-11-
                            Elev. 35'-0''.     63 and V-11-41.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
7 OB-FZ-8C...............  Office Bldg. A/B   Locally read             2
                            Battery Room,      Condensate
                            Tunnel and         Storage Tank
                            Electrical Tray    level at LI-424-
                            Room Elev. 35'-    993 due to
                            0''.               damage to
                                               control circuits.
                                              Manually open V-9-       7
                                               2099 and V-11-49
                                               and close V-11-
                                               63 and V-11-41.
                                              Use Local                8
                                               Shutdown Panels
                                               to control
                                               equipment as
                                               follows: LSP-
                                               1A2, CRD
                                               Hydraulic PP
                                               NC08A and 480V
                                               USS 1A2 Incoming
                                               breaker (Operate
                                               transfer switch
                                               ``Alternate''
                                               and operate
                                               Control Switch
                                               for USS-1A2 Main
                                               Breaker 1A2M and
                                               A CRD Pump).
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
                                              Trip all five           16
                                               Reactor
                                               Recirculation
                                               Pumps (NG01-A,
                                               NG01-B, NG01-C,
                                               NG01D and
                                               NG01E). Also,
                                               lockout the
                                               4160V breakers
                                               using local
                                               switch.
------------------------------------------------------------------------
8 OB-FZ-10A..............  Office Bldg.       Manually open V-        12
                            Monitor and        15-237, throttle
                            Change Room Area   V-15-30 using
                            and Operations     local flow
                            Support Area       indicator (FI-
                            Elev. 35'-0'' &    225-2) and close
                            46'-6''.           V-15-52.
------------------------------------------------------------------------
9 RB-FZ-1D...............  Reactor Bldg.      Manually open V-        12
                            Elev. 51'-3''.     15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52;.
------------------------------------------------------------------------
10 RB-FZ-1E..............  Reactor Building   Read CRD local          11
                            Elev. 23'-6''.     flow gauge FI-
                                               225-998.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------

[[Page 19797]]

 
11 RB-FZ-1F3.............  Reactor Bldg.      Open Core Spray         13
                            Northwest Corner   System II manual
                            Elev.-19'-6''.     valves V-20-1
                                               and V-20-2 and
                                               close V-20-4.
------------------------------------------------------------------------
12 RB-FZ-1F5.............  Reactor Bldg.      Manually open V-        12
                            Torus Room Elev.   15-237, throttle
                            -19'-6''.          V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
13 RB-FZ-1G..............  Reactor Bldg.      Read CRD local          11
                            Shutdown Cooling   flow gauge FI-
                            Room Elev. 38'-    225-998.
                            0'' & 51'-3''.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
14 TB-FA-3A..............  Turbine Bldg.      Manually open V-        12
                            4160V Emergency    15-237, throttle
                            SWGR Vault 1C      V-15-30 using
                            Elev. 23'-6''.     local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
15 TB-FA-26..............  Turbine Bldg.      Manually trip            1
                            125V DC Battery    4160V 1D
                            Room C Elev. 23'-  Breakers and
                            6''.               control USS 1B2
                                               and 1B3 480V
                                               Breakers locally
                                               at LSP-1D.
                                              Manually control         3
                                               1B3M Breaker
                                               from LSP-1B3.
                                              Manually re-close        6
                                               motor control
                                               center (MCC)
                                               1B32 Feeder
                                               Breaker at USS
                                               1B3.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
16 TB-FZ-11B.............  Turbine Bldg.      Manually trip            1
                            Lube Oil           4160V 1D
                            Storage,           Breakers and
                            Purification and   control USS 1B2
                            Pumping Area       and 1B3 480V
                            Elev. 0'-0'',      Breakers locally
                            27'-0'', and 36'-  at LSP-1D.
                            0''.
                                              Locally read             2
                                               Condensate
                                               Storage Tank
                                               level at LI-424-
                                               993.
                                              Manually control         3
                                               1B3M Breaker
                                               from LSP-1B3.
                                              Local Shutdown           4
                                               Panels used to
                                               control
                                               equipment as
                                               follows: LSP-
                                               1B32 Condensate
                                               Transfer Pump 1-
                                               2 (Operate
                                               transfer switch
                                               to ``Alternate''
                                               and operate
                                               Control Switch
                                               for Condensate
                                               Transfer Pump 1-
                                               2).
                                              Manually re-close        6
                                               MCC 1B32 Feeder
                                               Breaker at USS
                                               1B3.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
                                              Trip all five           16
                                               Reactor
                                               Recirculation
                                               Pumps (NG01-A,
                                               NG01-B, NG01-C,
                                               NG01D and
                                               NG01E). Also,
                                               lockout the
                                               4160V breakers
                                               using local
                                               switch.
------------------------------------------------------------------------
17 TB-FZ-11C.............  Turbine Bldg.      Manually trip            1
                            SWGR Room 1A and   4160V 1D
                            1B Elev. 23'-6''.  Breakers and
                                               control USS 1B2
                                               and 1B3 480V
                                               Breakers locally
                                               at LSP-1D.
                                              Manually control         3
                                               1B3M Breaker
                                               from LSP-1B3.
                                              Manually re-close        6
                                               MCC 1B32 Feeder
                                               Breaker at USS
                                               1B3.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
18 TB-FZ-11D.............  Turbine Bldg.      Manually trip            1
                            Basement Floor     4160V 1D
                            South End Elev.    Breakers and
                            3'-6''.            control USS 1B2
                                               and 1B3 480V
                                               Breakers locally
                                               at LSP-1D.
                                              Manually control         3
                                               1B3M Breaker
                                               from LSP-1B3.
                                              Local Shutdown           5
                                               Panels are used
                                               to control
                                               equipment as
                                               follows: LSP-
                                               DG2, EDG2 and
                                               its Switchgear
                                               (Operate
                                               transfer
                                               Switches (3
                                               total) to
                                               ``Alternate''
                                               and operate
                                               Control Switch
                                               on Diesel Panel
                                               to start diesel).
                                              Manually re-close        6
                                               MCC 1B32 Feeder
                                               Breaker at USS
                                               1B3.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
19 TB-FZ-11E.............  Turbine Bldg.      Manually trip            1
                            Condenser Bay      4160V 1D
                            Area Elev. 0'-     Breakers and
                            0''.               control USS 1B2
                                               and 1B3 480V
                                               Breakers locally
                                               at LSP-1D.
                                              Locally read             2
                                               Condensate
                                               Storage Tank
                                               level at LI-424-
                                               993.
                                              Manually control         3
                                               1B3M Breaker
                                               from LSP-1B3.
                                              Local Shutdown           4
                                               Panels used to
                                               control
                                               equipment as
                                               follows: LSP-
                                               1B32 Condensate
                                               Transfer Pump 1-
                                               2 (Operate
                                               transfer switch
                                               to ``Alternate''
                                               and operate
                                               Control Switch
                                               for Condensate
                                               Transfer Pump 1-
                                               2).

[[Page 19798]]

 
                                              Local Shutdown           5
                                               Panels are used
                                               to control
                                               equipment as
                                               follows: LSP-
                                               DG2, EDG2 and
                                               its Switchgear
                                               (Operate
                                               transfer
                                               Switches (3
                                               total) to
                                               ``Alternate''
                                               and operate
                                               Control Switch
                                               on Diesel Panel
                                               to start diesel).
                                              Manually re-close        6
                                               MCC 1B32 Feeder
                                               Breaker at USS
                                               1B3.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
                                              Trip all five           16
                                               Reactor
                                               Recirculation
                                               Pumps (NG01-A,
                                               NG01-B, NG01-C,
                                               NG01D and NG01E)
                                               Also, lockout
                                               the 4160V
                                               breakers using
                                               the 69 Switch.
------------------------------------------------------------------------
20 TB-FZ-11F.............  Turbine Bldg.      Manually open V-9-       7
                            Feedwater Pump     2099 and V-11-49
                            Room Elev. 0'-     and close V-11-
                            0'' & 3'-6''.      63 and V-11-41.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------
21 TB-FZ-11H.............  Turbine Bldg.      Manually open V-9-       7
                            Demineralizer      2099 and V-11-49
                            Tank and Steam     and close V-11-
                            Jet Air Ejector    63 and V-11-41.
                            Area Elev. 3'-
                            6'' & 23'-6''.
                                              Manually open V-        12
                                               15-237, throttle
                                               V-15-30 using
                                               local flow
                                               indicator (FI-
                                               225-2) and close
                                               V-15-52.
------------------------------------------------------------------------

    In their submittals, the licensee described elements of their fire 
protection program that provide their justification that the concept of 
defense-in-depth that is in place in the above fire areas is consistent 
with that intended by the regulation. To accomplish this, the licensee 
utilizes various protective measures to accomplish the concept of 
defense-in-depth. Specifically, the licensee stated that the purpose of 
their request was to credit the use of OMAs, in conjunction with other 
defense-in-depth features, in lieu of the separation and protective 
measures required by III.G.2 for a fire in the fire areas stated above.
    In their April 2, 2010, letter the licensee provided an analysis 
that described how fire prevention is addressed for each of the fire 
areas for which the OMAs may be required. The licensee developed a Fire 
Hazards Analysis (FHA) for each fire area or zone identified in its 
exemption request. For each fire area or zone, the FHA describes the 
physical location and arrangement of equipment, combustible loading, 
ignition sources, fire protection features, and proximity of redundant 
safe shutdown equipment to in situ hazards and identifies deviations 
from fire protection codes and previously approved exemptions. In 
addition, for each fire area or zone the licensee's response includes a 
tabulation of potential ignition sources as well as the equipment that 
may exhibit high energy arcing faults. For each fire area or zone, the 
FHA states that the fire protection configuration achieves a level of 
protection commensurate with that intended by III.G.2.
    The 21 areas or zones identified in the request have 
administratively limited combustible fuel loading with fuel sources 
consisting primarily of cable insulation and limited floor based 
combustibles except areas OB-FZ-6A, OB-FZ-6B, and TB-FZ-11B, which 
contain quantities of transformer liquid or lubricating oil. 
Combustible fuel loading in most areas is classified as low by the 
licensee while Fire Areas OB-FZ-6A, OB-FZ-6B, and TB-FA-26 have been 
classified as having moderate combustible fuel loading and TB-FZ-11B 
has been classified as having a high combustible fuel loading. In 
addition, the licensee has stated that they maintain a robust 
administrative program (e.g., hot work permits, fire watches for hot 
work, and supervisory controls) to limit and control transient 
combustible materials and ignition sources in the areas. The fire areas 
included in the exemption are not shop areas so hot work activities are 
infrequent and the administrative control programs are in place if hot 
work activities do occur.
    The licensee also stated that 98% of the Oyster Creek cables are 
jacketed with Vulkene, which passes the horizontal flame test of the 
Underwriter's Laboratory (UL), therefore reducing the likelihood of the 
cables themselves contributing to a fire hazard. Furthermore, the areas 
or zones are of noncombustible construction with typical utilities 
installed, lighting, ventilation, etc. and 3-hour fire resistance-rated 
barriers normally used to provide fire resistive separation between 
adjacent fire areas. In some cases, barriers with a fire resistance 
rating of less than 3 hours are credited but exemptions have been 
approved or the licensee has stated they have performed engineering 
evaluations in accordance with Generic Letter 86-10, ``Implementation 
of Fire Protection Requirements,'' to demonstrate that the barriers are 
sufficient for the hazard. Walls separating rooms and zones within fire 
areas are typically constructed of heavy concrete. This 
compartmentalization of the areas reduces the likelihood for fire 
events in a particular area to spread to or impact other adjacent 
areas.
    Many fire areas included in this exemption have automatic detection 
systems installed, although the licensee indicated that not all systems 
are installed in accordance with a recognized standard with regard to 
spacing in all areas. In such cases, the licensee has stated that the 
detectors are located near equipment such that they are likely to 
detect a fire. Upon detecting smoke, the detectors initiate an alarm in 
the constantly staffed control room. In addition to the automatic 
suppression systems noted below, equipment operators are trained fire 
brigade members and may identify and manually suppress or extinguish a 
fire using the portable fire extinguishers and manual hose stations 
located throughout the fire areas if a fire is identified in its early 
stages of growth.
    The licensee stated that the postulated fire events that may 
require the use of the OMAs would include multiple

[[Page 19799]]

failures of various components or equipment. In most cases, it is 
considered unlikely that the sequence of events required to necessitate 
the OMAs would fully evolve because of the fire prevention, fire 
protection, and physical separation features in place. However, in the 
event that the sequence does evolve, the OMAs are available to provide 
assurance that safe shutdown can be achieved. For each of the fire 
areas included in this exemption, the postulated fire scenarios and 
pertinent details are summarized in the table below.
    Each of the fire areas or zones included in this exemption is 
analyzed below with regard to how the concept of defense-in-depth is 
achieved for each area or zone and the role of the OMAs in the overall 
level of safety provided for each area or zone.

3.1 Fire Area CW-FA-14--Circulatory Water Intake

3.1.1 Fire Prevention
    The licensee stated that combustible loading is not tracked in this 
area since it is an outside area. The licensee also stated that the 
primary combustible materials in the area are transformer liquid and 
electrical motors; although the amount is not quantified since the area 
is open to the atmosphere with no walls or ceiling to contain the heat 
or smoke that may be produced during a fire event. Additionally, the 
main combustible in this area that could result in the need for the 
OMAs is Dow Corning 561 Silicon transformer liquid, which the licensee 
states has characteristics that minimize the likelihood of a fire 
involving the insulating liquid itself.
3.1.2 Detection, Control, and Extinguishment
    CW-FA-14 is not equipped with automatic fire detection or 
suppression systems but since it is an outdoor area with no walls or 
ceiling, it is not expected that such systems would enhance this 
element of defense-in-depth in this area since the area is open to the 
atmosphere with no walls or ceiling to contain the heat or smoke that 
may be produced during a fire event. However, the licensee stated that 
a security tower monitors this area continuously; therefore, any fire 
of significance would be detected and responded to appropriately by the 
station fire brigade. Manual suppression is also provided by a fire 
hydrant and fire hose house located approximately 75 feet from the 
principal fire hazards.
3.1.3 Preservation of Safe Shutdown Capability
    Since Fire Area CW-FA-14 is an outdoor space with no walls or 
ceiling, smoke and heat would not accumulate within the fire area to 
cause damage to components remote to the initiating fire or obstruct 
operator actions.
3.1.4 OMAs Credited for a Fire in This Area
3.1.4.1 OMA 7--Align the Fire Water System to the Isolation 
Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. Unit Substation 
Transformer (USS) 1B3 is located in the outside area on the west side 
of the power block on a raised concrete foundation that sits 
approximately 5 feet above grade. USS 1B3 is considered as a potential 
ignition source as well as its associated adjacent transformer, USS 
1A3, which is located approximately 15 feet west of USS 1B3. Both of 
these unit substations are located approximately 20 feet from any plant 
operating equipment (e.g., circulating water pump motor, etc.). 
Additionally, the need to perform this OMA would likely be apparent in 
the control room based on the loads that are lost (e.g., control room 
ventilation, service water pump, etc.) and a fire at USS 1B3 would be 
visible from the security tower monitoring the area.
    In the unlikely event that a fire does occur and causes the loss of 
USS 1B3 or its associated cables, OMA 7 is available to 
manually open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to 
align the fire water system for make-up water to Isolation Condenser 
``B'' since there is no power (``B'' Train) available to the Condensate 
Transfer System. The licensee also stated that they have assumed a 10-
minute diagnosis period and that the required time to perform the 
action is 13 minutes while the time available is 45 minutes, which 
provides a 22-minute margin.
3.1.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that they conservatively assume that 
instrument air is lost for all Appendix R fires based on the fact that 
instrument air lines run throughout many areas of the plant. The 
licensee's analysis assumes that the air line could potentially fail in 
approximately 45 minutes when exposed to the postulated fire.
    The licensee also stated that the normal CRD flow control valve is 
a single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
    The licensee stated that OMA 12 essentially duplicates the 
Emergency Operating Procedure (EOP) actions for reactor pressure vessel 
(RPV) level control. Therefore, if a fire did occur and was not 
immediately discovered, any delay in the entry into the appropriate 
Fire Support Procedure (FSP) or delay in suppression of the fire would 
not significantly affect the performance of this OMA, since the EOPs 
would direct the same action to be performed if required.
3.1.5 Conclusion
    Given the combustion resistant properties of the most probable 
combustible materials, limited ignition sources, and open nature of the 
area, it is unlikely that a fire would occur, go undetected or 
unsuppressed by station personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this area, combined with the ability of OMAs 7 
and 12 to manipulate the plant in the event of a fire that 
damages safe shutdown equipment, provides adequate assurance that safe 
shutdown capability is maintained.

3.2 Fire Area OB-FA-9--Office Bldg. Elev. 23[foot]-6, 
35[foot]-0, 46[foot]-6

3.2.1 Fire Prevention
    The licensee has classified the fire loading in this fire area as 
low. The licensee also stated that OB-FA-9 has an administrative fire 
loading limit of less than 1.5 hours as determined by the time-
temperature curve contained in American Society of Testing and

[[Page 19800]]

Materials standard E119, ``Standard Test Methods for Fire Tests of 
Building Construction and Materials'' (ASTM E119), and that the major 
combustibles in the multiplexer (MUX) corridor, which is within OC-FA-
9, are cable insulation and a wood ceiling on top of the MUX enclosure, 
which is within the MUX corridor.
3.2.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FA-9 has a partial area coverage wet 
pipe sprinkler system installed. The licensee further stated that the 
area is not provided with an area-wide detection system but that there 
is an installed detection system in the main hallways and inside of the 
MUX corridor and that it is a high traffic area so a fire would likely 
be detected by personnel. The wet pipe sprinkler system, when actuated, 
will alarm in the control room to notify operators of a potential fire 
event. Extinguishment of a fire in the majority of this area will be 
accomplished by the plant fire brigade.
3.2.3 Preservation of Safe Shutdown Capability
    The licensee stated that the MUX corridor within OB-FA-9 has a 
ceiling height of approximately 10'-6'' and an approximate floor area 
of 513 square feet in the MUX corridor where the safe shutdown 
equipment is located so it is unlikely that smoke and heat would 
accumulate at the height of the safe shutdown equipment and cause a 
failure due to fire damage.
3.2.4 OMAs Credited for a Fire in This Area
3.2.4.1 OMA 2--Read Condensate Storage Tank (CST) Local Level 
Indicator LI-424-993
    In order for OMA 2 to be necessary, the primary CST level 
indicator (5F-27) would have to fail as a result of the fire. Should 
this occur, indication can only be obtained by reading the local 
indicator (LI-424-993) located at the CST. The licensee stated that the 
safe shutdown success path structure, system, or component (SSC) cable 
for the level indicator is routed in a cable tray located approximately 
12 feet above the floor in this area (MUX corridor). The cable enters 
the room in the northwest corner and is routed in a cable tray for 
approximately 15 feet. It then air drops vertically down into the MUX 
enclosure. The credited cable is routed in a cable tray with other 
cables and is routed through the wooden ceiling, which also has some 
rubber piping insulation on top of the ceiling, thus putting the cable 
in close proximity to in situ combustibles. However, there are no 
ignition sources in this area. Therefore, due to the lack of ignition 
sources, it is not expected that a fire would occur in this area and it 
is unlikely that the OMA would be required.
    In the unlikely event that a fire does occur and causes the loss of 
the primary CST level indicator, OMA 2 is available to locally 
read CST level at the local level indicator, LI-424-993. The licensee 
also stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 7 minutes while the 
time available is 73 minutes, which provides a 36-minute margin.
3.2.4.2 OMA 12--Establish Control Rod Drive (CRD) Flow to 
Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.2.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and sufficient volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the sprinkler system 
noted above, or personnel, and damage the safe shutdown equipment. The 
low likelihood of damage to safe shutdown equipment due to a fire in 
this area, combined with the ability of OMAs 2 and 12 
to manipulate the plant in the event of a fire that damages safe 
shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

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

3.3.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
moderate. The licensee also stated that this area has an administrative 
fire loading limit of less than 3 hours as determined by the ASTM E119 
time-temperature curve. The main combustibles in this area are cable 
insulation (approximately 81% of loading) and Dow Corning 561 Silicon 
transformer liquid (approximately 15% of loading). Additionally, the 
transformer liquid has characteristics that minimize the likelihood of 
a fire involving the insulating liquid itself.
3.3.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-6A has an automatic smoke detection 
system, a total flooding automatic Halon 1301 System, and manual fire 
fighting capabilities (portable extinguishers and hose stations).
3.3.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FA-6A has a ceiling height of 
approximately 10'-8'' and an approximate floor area of 1157 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.3.4 OMAs Credited for a Fire in This Zone
3.3.4.1 OMA 2--Read Condensate Storage Tank Local Level 
Indicator LI-424-993
    In order for OMA 2 to be necessary, the primary CST level 
indicator (5F-27) would have to fail as a result of the fire. Should 
this occur, indication can only be obtained by reading the local 
indicator (LI-424-993) located at the CST. The licensee stated that the 
safe shutdown success path cable for the level indicator is routed in a 
conduit that leaves a 120 VAC distribution panel and travels 
approximately 5 feet vertically to a cable tray that is approximately 9 
feet above the floor. The cable is routed with other cables in the 
cable tray for approximately 15 feet at which point the cable tray 
travels up through the ceiling. The liquid filled transformer is 
located approximately 10 feet north of the cable. However, there is a 
partial non-rated concrete block wall between the transformer and cable 
tray that would provide some protection of direct flame impingement or 
radiant heat transfer on the cable tray. The ignition sources in this 
fire zone consist

[[Page 19801]]

of enclosed metal electrical cabinets (120 VAC and 125 VDC circuits) 
and the liquid filled transformer (4160 VAC to 480 VAC).
    In the unlikely event that a fire does occur and damages the 
primary CST level indicator, OMA 2 is available to locally 
read CST level at local indicator LI-424-993. The licensee also stated 
that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 7 minutes while the time 
available is 73 minutes, which provides a 36-minute margin.
3.3.4.2 OMA 9--Manually Control 480V Breakers From Remote 
Shutdown Panel
    In order for OMA 9 to be necessary, damage to the credited 
and redundant cables would have to occur due to a fire. The licensee 
stated that the credited and redundant cables are located in the same 
cable tray with additional cables and that the tray is located 
approximately 7 feet above the floor. Other than the cables themselves, 
the primary combustible in this area is a liquid filled transformer, 
which is located approximately 7 feet from the cable tray. The licensee 
also stated that the ignition sources in this fire zone consist of 
electrical cabinets (120 VAC and 125 VDC circuits) and the liquid 
filled transformer (4160 VAC to 480 VAC). The electrical cabinets are 
enclosed metal cabinets, which are located approximately 2 feet from 
the credited and redundant cables in some locations.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 9 is available to manually 
control the 480V USS 1B2 breakers for CRD Pump NC08B and 1B2M from the 
Remote Shutdown Panel. The licensee also stated that they have assumed 
a 30-minute diagnosis period and that the required time to perform the 
action is 13 minutes while the time available is 180 minutes, which 
provides a 137-minute margin.
3.3.4.3 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.3.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the volume of the space, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the smoke detection or Halon 
system noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMAs 2, 
9, and 12 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provide adequate assurance 
that safe shutdown capability is maintained.

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

3.4.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
moderate. The licensee also stated that this area has an administrative 
fire loading limit of less than 2 hours as determined by the ASTM E119 
time-temperature curve. The main combustibles in this area are cable 
insulation (approximately 28% of loading), Thermo-Lag (approximately 
29% of loading) and Dow Corning 561 Silicon transformer liquid 
(approximately 31% of loading). Also, the transformer liquid has 
characteristics that minimize the likelihood of a fire involving the 
insulating liquid itself.
3.4.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-6B has an automatic smoke detection 
system, a total flooding Halon 1301 System, and manual fire fighting 
capabilities (portable extinguishers and hose stations).
3.4.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FA-6B has a ceiling height of 
approximately 10'-8'' and an approximate floor area of 679 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.4.4 OMAs Credited for a Fire in This Zone
3.4.4.1 OMA 7--Align the Fire Water System to the Isolation 
Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. Motor control 
center (MCC) 1B21 is located approximately 5 feet from USS 1B2. The 
licensee indicated that a credited power cable for the static charger 
enters the fire zone through the ceiling of the corridor and then 
enters the main portion of the room through the north wall 
approximately 9 feet above the floor. It then runs east and down into 
MCC 1B21. The cable is located approximately 2 feet above the potential 
ignition source, USS 1B2, and runs directly into ignition source MCC 
1B21. The credited power cable for MCC 1B21 is routed from USS 1B2 to 
MCC 1B21 in a cable tray. This cable tray runs approximately 10 feet 
above the floor and approximately 2 feet above the potential ignition 
sources, USS 1B2 and MCC 1B21, but it also enters into both as 
indicated above. However, both of these ignition sources are contained 
in enclosed metal cabinets and are not high voltage. The cable tray is 
also located approximately 10 feet from the ignition source of the USS 
1B2 transformer, which is located near the west end of the room.
    The licensee also indicated that the ``A'' train of power is 
credited and available for this fire zone and that the redundant cable 
is associated with the ``C'' battery charger, which is fire wrapped 
with a 1-hour barrier in this fire zone. It is unlikely that a fire 
would develop and cause damage to multiple redundant pieces of 
equipment given the spatial relationship between the credited equipment 
and ignition sources, the presence of the automatic Halon system, and 
the protected ``C'' battery charger cable.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to align the 
fire water system for make-up water to Isolation Condenser ``B'' since 
there is no power (``B'' Train) available to the Condensate Transfer 
System. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 13 
minutes while the time

[[Page 19802]]

available is 45 minutes, which provides a 22-minute margin.
3.4.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
    In the unlikely event that a fire does occur and damages multiple 
redundant trains, OMAs 7 and 12 are available to 
align the fire water system to the isolation condenser and establish 
CRD flow. The locations of these OMAs are in separate fire areas from 
Fire Area OB-FZ-6B so a fire in Fire Area OB-FZ-6B would not impact the 
locations of the actions.
3.4.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the volume of the space, it is unlikely that a fire would 
occur and go undetected or unsuppressed by the smoke detection or Halon 
system noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMAs 7 
and 12 to manipulate the plant in the event of a fire that 
damages safe shutdown equipment, provides adequate assurance that safe 
shutdown capability is maintained.

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

3.5.1 Fire Prevention
    Fire Zones OB-FZ-8A and 8B are evaluated together for the 
combustible loading and fire safe shutdown (FSSD) analysis due to the 
lack of rated fire barriers between the zones. The licensee has 
classified the fire loading in these fire zones as low. The licensee 
also stated that these fire zones have an administrative fire loading 
limit of less than 45 minutes as determined by the ASTM E119 time-
temperature curve. There are minimal combustibles in Fire Zone OB-FZ-
8B. The major combustibles in Fire Zone OB-FZ-8A are lubricating oil 
(approximately 83% of loading) and cable insulation (approximately 13% 
of loading).
3.5.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-8A has a partial wet-pipe sprinkler 
system with a flow alarm that notifies the control room and that the 
area does not have a smoke detection system, however, a duct smoke 
detector is located in the exhaust duct of fan EF-1-20. Since operation 
of the sprinkler system will alarm in the control room, prompt 
notification of and response by, the fire brigade for any required 
manual fire fighting activities is expected.
3.5.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-8A has a ceiling height of 
approximately 10'-10'' and an approximate floor area of 2128 square 
feet and OB-FZ-8B has a ceiling height of approximately 11'-0'' and an 
approximate floor area of 479 square feet so it is unlikely that smoke 
and heat would accumulate at the height of the safe shutdown equipment 
and cause a failure due to fire damage.
3.5.4 OMAs Credited for a Fire in these Zones
3.5.4.1 OMA 7--Align the Fire Water System to the Isolation 
Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. The licensee 
indicated that the cable for the 125 VDC control power is in conduit 
that enters this zone through the ceiling in the northwest corner and 
then travels south along the ceiling near the west wall approximately 9 
feet above the floor and approximately 7 feet from the primary ignition 
sources in the area, the motor-generator (MG) Sets, and then leaves 
through the floor, where it runs within 2 feet of the ``E'' MG-Set. The 
licensee also indicated that the ``A'' train of power is credited and 
available for this fire zone and that the redundant cable is associated 
with the ``C'' battery and this cable is not located in this fire zone.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to align the 
fire water system for make-up water to Isolation Condenser ``B'' since 
there is no power (``B'' Train) available to the Condensate Transfer 
System. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 13 
minutes while the time available is 45 minutes, which provides a 22-
minute margin.
3.5.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.5.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this zone, combined with the ability of OMAs 
7 and 12 to manipulate the plant in the event of a 
fire that damages safe

[[Page 19803]]

shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

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

3.6.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this fire zone has an administrative 
fire loading limit of less than 1.5 hours as determined by the ASTM 
E119 time-temperature curve. The major combustibles in Fire Zone OB-FZ-
8C are electrolyte-filled plastic battery cases and racks 
(approximately 56% of loading) and cable insulation (approximately 39% 
of loading).
3.6.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-8C has a fixed, total-flooding, 
Halon 1301 extinguishing system, area-wide smoke detection that is 
installed at the ceiling level and cross-zoned to sound a local alarm, 
and an alarm in the control room upon actuation of one detector. 
Actuation of a second detector will sound a local alarm, discharge the 
Halon system, trip supply and exhaust fans, and close dampers.
3.6.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-8C has a ceiling height of 
approximately 11'-0'' and an approximate floor area of 1292 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.6.4 OMAs Credited for a Fire in This Zone
3.6.4.1 OMA 2--Read Condensate Storage Tank Local Level 
Indicator LI-424-993
    In order for OMA 2 to be necessary, damage to the primary 
CST level indicator (5F-27) cable would have to occur due to a fire. 
Should this occur, indication can only be obtained by reading the local 
indicator (LI-424-993) located at the CST. Although there is no 
redundant train of equipment for the credited source of obtaining CST 
level Indication, the licensee stated that the tray containing the 
credited train is located in the Electric Tray Room portion of the 
zone, which is separated from the main battery room by a cable tunnel 
that is approximately 25 feet long. The licensee also stated that the 
credited cable runs in a cable tray with other cables, thus putting it 
in close proximity to in-situ hazards, however, due to the size and use 
of the room, there are no other credible hazards including transient 
combustibles.
    In the unlikely event that a fire does occur and causes the loss of 
the primary CST level indicator, OMA 2 is available to locally 
read CST level at the local level indicator, LI-424-993. The licensee 
also stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 7 minutes while the 
time available is 73 minutes, which provides a 36-minute margin.
3.6.4.2 OMA 7--Align Fire Water to Isolation Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. The licensee 
indicated that the credited cable is located in the A/B Battery Room 
portion (main portion) of this fire zone and that the credited cable 
runs in a conduit that begins at 125V DC Distribution Panel B. The 
cable is routed in a conduit that runs approximately 1 foot above a 
series of vertical cable trays, approximately 8 feet above the ``B'' MG 
Set, and approximately 3 feet over the top of the 125V DC ``B'' 
Distribution Center. However, the ``B'' MG Set is not normally 
energized since the static charger is utilized normally for charging 
the ``B'' Battery. The licensee also indicated that the battery banks 
are another potential ignition source in the room but that they are 
located greater than 15 feet from the particular conduit in question 
but that the failure of the battery itself may also require the OMA. 
The ``A'' train of power is credited and available for this fire zone. 
The redundant cable, ``C'' battery, ``C'' Distribution center, etc. are 
not located in this fire zone.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to align the 
fire water system for make-up water to Isolation Condenser ``B'' since 
there is no power (``B'' Train) available to the Condensate Transfer 
System. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 13 
minutes while the time available is 45 minutes, which provides a 22-
minute margin.
3.6.4.3 OMA 8--Manually Control USS 1A2 ``A'' CRD Pump & 1A2M 
From LSP-1A2
    In order for OMA 8 to be necessary, damage to the credited 
control cables, 1A2M & A CRD Pump, and the redundant control cables, 
1B2M and B CRD Pump, would have to occur due to a fire. The licensee 
stated that the credited and redundant cables are run in the same cable 
tray with additional cables in the Electric Tray Room portion of this 
fire area and are separated from the main battery room by a cable 
tunnel that is approximately 25-feet long. With the exception of the 
cables themselves, there are no other combustibles or ignition sources 
and the storage of transient combustibles in this portion of the fire 
zone is remote since it is a small room with only one door for access 
or egress.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 8 is available to manually 
control the 480V USS 1A2 breakers for ``A'' CRD Pump and 1A2M from LSP-
1A2. The licensee also stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 8 
minutes while the time available is 60 minutes, which provides a 22-
minute margin.
3.6.4.4 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.6.4.5 OMA 16--Manually Trip Rx Recirculation Pumps at 4160V 
Switchgear
    In order for OMA 16 to be necessary, damage to the 
credited cables for tripping the recirculation pumps or the loss of the 
125 VDC ``B'' Battery and ``B'' Distribution Center would have to occur 
due to a fire. The licensee stated that the

[[Page 19804]]

cable tray configuration in the A/B Battery Room is a series of 
vertical trays closely stacked together and that the trays containing 
the required equipment are located approximately 4 feet from the ``B'' 
MG Set. However, the ``B'' MG Set is not normally energized since the 
static charger is utilized normally for charging the ``B'' Battery. The 
licensee also stated that other than the cables themselves, there are 
no other combustibles or ignition sources in the area and that the 
placement of transient combustibles is remote since access is limited 
and the rooms are small in size.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 16 is available to manually 
trip Reactor Recirculation Pumps (``A,'' ``C,'' and ``E'') 4160V 
Switchgear 1A and 1B. The licensee also stated that they have assumed a 
10-minute diagnosis period and that the required time to perform the 
action is 13 minutes while the time available is 30 minutes, which 
provides a 7-minute margin.
3.6.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
Halon systems noted above, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMAs 2, 
7, 8, 12, and 16 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

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

3.7.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles in this area are cable 
insulation (approximately 27% of loading), rubber flooring 
(approximately 31% of loading), miscellaneous plastics (approximately 
15% of loading) and protective clothing supplies (approximately 20% of 
loading). However, since the protective clothing supplies have been 
placed in metal cans with self-closing lids they are no longer 
considered a contribution to the combustibles in this area.
3.7.2 Detection, Control, and Extinguishment
    The licensee stated that OB-FZ-10A has an area-wide smoke detection 
system and a wet-pipe automatic sprinkler system installed throughout 
the area. In addition, a hose station located nearby, outside the 
control room, provides manual suppression capability.
3.7.3 Preservation of Safe Shutdown Capability
    The licensee stated that OB-FZ-10A has a ceiling height of 
approximately 13'-0'' and an approximate floor area of 2019 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.7.4 OMAs Credited for a Fire in This Zone
3.7.4.1 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 18 minutes, while the 
time available is 204 minutes, which provides a 156-minute margin.
3.7.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this zone, combined with the ability of OMA 
12 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 has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The main combustible in this area is attributed 
to cable insulation (approximately 84% of loading).
3.8.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1D has an area-wide smoke detection 
system and an automatic fixed deluge water spray system installed over 
cable trays and open hatches. The deluge suppression system protecting 
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 trays and smoke 
detectors are located in each beam pocket at the ceiling.
3.8.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1D has a ceiling height of 
approximately 21'-0' and an approximate floor area of 9,100 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.8.4 OMAs Credited for a Fire in This Zone
3.8.4.1 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while

[[Page 19805]]

monitoring flow at FI-225-2, and close V-15-52 to establish CRD flow to 
the reactor. Furthermore, OMA 12 would only be necessary if 
the Isolation Condenser/CRD systems are utilized for hot shutdown. If 
OMA 12 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 15 minutes, while the time available is 204 
minutes, which provides a 159-minute margin.
3.8.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
localized water deluge systems noted above, or personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this zone, combined with the 
ability of OMA 12 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

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

3.9.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The main combustible in this area is attributed 
to cable insulation (approximately 84% of loading).
3.9.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1E has an area-wide smoke detection 
system and an automatic fixed deluge water spray system installed over 
cable trays and open hatches. The deluge suppression system protecting 
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 trays and smoke 
detectors are located in each beam pocket at the ceiling.
3.9.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1E has a ceiling height of 
approximately 26'-9'' and an approximate floor area of 12,140 square 
feet so it is unlikely that smoke and heat would accumulate at the 
height of the safe shutdown equipment and cause a failure due to fire 
damage.
3.9.4 OMAs Credited for a Fire in This Zone
3.9.4.1 OMA 11--Locally Read CRD Flow Gauge FI-225-998
    In order for OMA 11 to be necessary, the normal local 
gauge for CRD flow, FI-225-2, would have to be damaged by fire. The 
licensee stated that there are no in-situ combustibles present in the 
immediate area surrounding the gauge and that the placement of 
transient combustibles is remote since the gauge is surrounded by 
piping and tubing. The licensee also stated that the nearest ignition 
source is MCC 1A21B, which is located approximately 8 feet from the 
flow gauge. However, the solid steel rear of the MCC faces the flow 
gauge making it highly unlikely that this potential ignition source 
would adversely impact the flow gauge.
    OMA 11 would require re-entry into Fire Zone RB-FZ-1E to 
manually control CRD System valves V-15-237, V-15-30, and V-15-52 
located in this fire zone while monitoring flow at FI-225-998 to 
establish CRD flow to the reactor due to the loss of instrument air to 
the CRD flow control valve. Fusing of the unprotected CRD valves by 
heat from a fire resulting in the valves becoming inoperable is not 
considered credible because of the low fire loading, the provision of 
automatic fire detection and suppression capability and the heat sink 
capability of the water filled piping connected to the valve. Operation 
of one of the valves that is in close proximity to these valves was 
previously approved in the exemption discussed above.
    In the unlikely event that a fire occurs and this flow gauge 
becomes unreadable, OMA 11 is available to locally read flow 
gauge FI-225-998, which is the redundant instrument that provides the 
same data and is mounted on an instrument rack located in Fire Zone RB-
FZ-1D. The licensee also stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 
100 minutes, including a 90-minute allowance before re-entry, while the 
time available is 204 minutes, which provides a 74-minute margin.
3.9.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to reenter RB-FZ-1E and 
manually open V-15-237, throttle V-15-30 while monitoring flow at FI-
225-2, and close V-15-52 to establish CRD flow to the reactor. 
Furthermore, OMA 12 would only be necessary if the Isolation 
Condenser/CRD systems are utilized for hot shutdown. If OMA 12 
becomes necessary, the licensee stated that they have assumed a 30-
minute diagnosis period and that the required time to perform the 
action is 100 minutes, including a 90-minute allowance before re-entry, 
while the time available is 204 minutes, which provides a 74-minute 
margin.
3.9.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
localized water deluge systems noted above, or personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this zone, combined with the 
ability of OMAs 11 and 12 to manipulate the plant in 
the event of a fire that damages safe shutdown equipment, provides 
adequate assurance that safe shutdown capability is maintained.

3.10 RB-FZ-1F3 Reactor Bldg. Northwest Corner Elev. -19[foot]-
6

3.10.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles in this area are cable 
insulation (approximately 58% of loading), ladders (approximately 16% 
of loading) and lubricating oil in pumps (approximately 16% of 
loading).
3.10.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1F3 has smoke detectors which alarm 
locally and in the control room installed over hazards rather than 
mounted at the ceiling. Fire extinguishers are also

[[Page 19806]]

provided for manual fire fighting backup. Hose lines are available from 
outside hydrants and hose houses.
3.10.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1F3 has a ceiling height of 
approximately 41'-6'' and an approximate floor area of 560 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.10.4 OMAs Credited for a Fire in This Zone
3.10.4.1 OMA 13--Manually Align Core Spray to CST To Provide 
Reactor Coolant Makeup
    In order for OMA 13 to be necessary, both CRD pumps 
located in this area would have to become damaged due to a fire. The 
licensee stated that the pumps are separated by a horizontal distance 
of approximately 6 feet and that the associated cables and conduits are 
in close proximity to each other. The licensee also stated that the 
primary ignition sources in the area, aside from the pumps themselves, 
are located approximately 18 feet from the CRD pumps.
    In the unlikely event that a fire occurs and causes damage to both 
pumps, OMA 13 is available to re-enter this fire zone and 
manually open Core Spray valves V-20-1 and V-20-2 and close V-20-4 (V-
20-2 and V-20-4 are located in Fire Zone RB-FZ-1F2) to provide Reactor 
Coolant Makeup from the CST for Fire Zone RB-FZ-1F3. The licensee also 
stated that they have assumed a 30-minute diagnosis period and that the 
required time to perform the action is 35 minutes while the time 
available is 204 minutes, which provides a 139-minute margin.
3.10.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space it is unlikely that a fire would 
occur and go undetected or unsuppressed by the smoke detection system 
or personnel and damage the safe shutdown equipment. The low likelihood 
of damage to safe shutdown equipment due to a fire in this zone, 
combined with the ability of OMA 13 to manipulate the plant in 
the event of a fire that damages safe shutdown equipment, provides 
adequate assurance that safe shutdown capability is maintained.

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

3.11.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles in this area are cable 
insulation (approximately 19% of loading) and gratings (approximately 
76% of loading). The grating, which is the largest plastic material in 
this area, has a low flame spread rating (less than 25).
3.11.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1F5 does not have a detection or 
suppression systems. The NRC staff finds that the, because of the low 
amount of combustible material in the area and low flame spread rating 
of the majority of this material, a fire in this zone is not expected 
to be of significant size or duration.
3.11.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1F5 is a voluminous area with an 
approximate floor area of 11450 square feet and a ceiling height of 
approximately 41[foot]-6, therefore, it is unlikely that 
smoke and heat from a fire in the area would accumulate at the location 
of the instrument air line and cause a loss of instrument air.
3.11.4 OMAs Credited for a Fire in This Zone
3.11.4.1 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.11.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and the large volume of the area, it is unlikely that a fire 
would occur and go undetected or unsuppressed by personnel, and damage 
the safe shutdown equipment. The low likelihood of damage to safe 
shutdown equipment due to a fire in this zone, combined with the 
ability of OMA 12 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

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

3.12.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The main combustibles in this area are cable 
insulation (approximately 12% of loading), plastic (approximately 57% 
of loading) and Class A combustibles (approximately 14% of loading). 
The grating, which is the majority of the plastic material in this 
area, has a low flame spread rating (less than 25).
3.12.2 Detection, Control, and Extinguishment
    The licensee stated that RB-FZ-1G is provided with a smoke 
detection system that alarms locally and in the control room to provide 
prompt notification of a potential fire event.
3.12.3 Preservation of Safe Shutdown Capability
    The licensee stated that RB-FZ-1G has a ceiling height of 
approximately 21', measured from the 51'-3'' elevation, and an 
approximate floor area of 1609 square feet so it is unlikely that smoke 
and heat would accumulate at the height of the safe shutdown equipment 
and cause a failure due to fire damage.
3.12.4 OMAs Credited for a Fire in This Zone
3.12.4.1 OMA 11--Locally Read CRD Flow Gauge FI-225-998
    In order for OMA 11 to be necessary, the normal local 
gauge for CRD flow, FI-

[[Page 19807]]

225-2, located in Fire Zone RB-FZ-1E or its associated cables, would 
have to be damaged by fire. The licensee stated that there are no in-
situ combustibles present in the immediate area surrounding the gauge 
and that the placement or storage of transient combustibles is remote 
since the gauge is surrounded by piping and tubing. The licensee also 
stated that the nearest ignition source is MCC 1A21B, which is located 
approximately 8 feet from the flow gauge. However, the solid steel rear 
of the MCC faces the flow gauge making it highly unlikely that this 
potential ignition source would adversely impact the flow gauge.
    In the unlikely event that a fire occurs and this flow gauge 
becomes unreadable, OMA 11 is available to locally read flow 
gauge FI-225-998, which is the redundant instrument that provides the 
same data and is mounted on an instrument rack located in Fire Zone RB-
FZ-1D. The licensee also stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 
100 minutes, including a 90-minute allowance before re-entry, while the 
time available is 204 minutes, which provides a 74-minute margin.
3.12.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 100 minutes, including 
a 90-minute allowance before re-entry, while the time available is 204 
minutes, which provides a 74-minute margin.
3.12.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection 
system or personnel and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
zone, combined with the ability of OMAs 11 and 12 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

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

3.13.1 Fire Prevention
    The licensee has classified the fire loading in this fire area as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. There are minimal amounts of cable insulation 
(approximately 5% of loading) miscellaneous plastic (approximately 73% 
of loading) and class A combustibles such as paper for procedures 
(approximately 20% of loading) in this area.
3.13.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FA-3A is provided with an area-wide 
smoke detection system and a total-flooding, manually actuated 
CO2 system.
3.13.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FA-3A has a ceiling height of 
approximately 21' and an approximate floor area of 336 square feet so 
it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.13.4 OMAs Credited for a Fire in This Area
3.13.4.1 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.13.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
CO2 systems, or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this area, combined with the ability of OMA 12 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

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

3.14.1 Fire Prevention
    The licensee has classified the fire loading in this fire area as 
moderate. The licensee also stated that this area has an administrative 
fire loading limit of less than 90 minutes as determined by the ASTM 
E119 time-temperature curve. The major combustibles in this area are 
plastic, which is contributed by the battery cases (approximately 92% 
of loading) and cable insulation (approximately 6% of loading).
3.14.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FA-26 has an area-wide automatic pre-
action sprinkler system and an area-wide smoke detection system 
installed. Additionally, the licensee identified that the battery cases 
are filled with water which would provide some resistance to combustion 
of the cases.
3.14.3 Preservation of Safe Shutdown Capability
    The licensee stated that there are no specific cables in this fire 
area associated with the OMAs identified for Fire Area TB-FA-26 and 
that the only

[[Page 19808]]

FSSD component and cable located in this fire area is associated with 
the ``C'' battery. Additionally, per the Oyster Creek Updated Final 
Safety Analysis Report, Section 8.3.2.4, the ``B'' 125V DC distribution 
system is redundant to the ``C'' system and the two systems are 
physically independent.
3.14.4 OMAs Credited for a Fire in This Area
    The licensee stated that this fire area is wholly contained within 
Fire Zone TB-FZ-11C (A and B 4160V Room) and that all cables to TB-FA-
26 must traverse TB-FZ-11C. Therefore, TB-FA-26 and TB-FZ-11C were 
analyzed together for safe shutdown purposes and the OMAs are 
duplicated for these two plant areas. Refer to Section 3.16 below for 
NRC staff's evaluation of the feasibility of OMAs 1, 
3, 6, and 12, which are common to both 
areas.
3.14.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and lack of multiple safe shutdown trains in this area, it is 
unlikely that a fire would occur and go undetected or unsuppressed by 
the smoke detection or sprinkler systems, or personnel, and damage the 
safe shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this area, combined with the ability of OMAs 
1, 3, 6, and 12 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

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

3.15.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
high. The licensee also stated that this fire zone has administrative 
controls such that additional combustible materials are not introduced 
into this zone and defense-in-depth features to control a potential oil 
fire in this zone. The major combustibles in this area are lubricating 
oil (approximately 99% of loading) and cable insulation (approximately 
0.3% of loading). The amount of oil contained in the lube oil storage 
tanks in this fire zone results in a combustible loading of 
approximately 14 hours.
3.15.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11B has automatic suppression 
systems installed over principal combustibles and a rate of rise/fixed 
temperature fire detection system installed at the lube oil tank. A 
closed head automatic sprinkler system protects cable trays and open 
head water spray deluge system protects oil handling equipment and the 
oil storage tank. Thermal detectors are located in close proximity to 
the lube oil tank so that a lube oil fire would be quickly detected, 
which in turn would activate the deluge system for extinguishment. 
Additionally, the licensee stated that there are fire extinguishers 
provided throughout the zone and that aqueous film-forming foam (AFFF) 
is staged in the Fire Brigade van for use if necessary.
3.15.3 Preservation of Safe Shutdown Capability
    The licensee stated that the ceiling heights in the area are 
approximately 9'-0'' in the basement hallway, approximately 19'-0'' in 
the basement stairs, approximately 26'-0'' on the first floor of the 
area, and approximately 42'-0'' on the second floor of the area. 
Additionally, the licensee stated that the floor area, measured at the 
0'-0'' elevation is approximately 3,175 square feet.
3.15.4 OMAs Credited for a Fire in This Zone
3.15.4.1 OMA 1--Manually Trip 4160V 1D Breakers and Control 
USS 1B2 & 1B3 Breakers Locally at LSP-1D
    In order for OMA 1 to be necessary, damage to the credited 
and redundant cables would have to occur due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 14 feet above the floor. 
The licensee also stated that the cables pass over the top of potential 
ignition sources MCC 1A12 and MCC 1B12 and that the cables are located 
approximately 6 feet above these ignition sources. Additionally, the 
lube oil tanks are located below the cables, although not directly 
below, with a distance of approximately 26 feet separating the cables 
and the tanks. The cables are also located approximately 20 feet from 
ignition sources MCC 1A12A and 1B12A.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 1 is available to manually 
trip the 4160V 1D breakers and control USS 1B2 and the 1B3 480V 
breakers locally at LSP-1D. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 19 minutes while the time available is 45 
minutes, which provides a 16-minute margin.
3.15.4.2 OMA 2--Read Condensate Storage Tank Local Level 
Indicator LI-424-993
    In order for OMA 2 to be necessary, damage to the primary 
CST level indicator (5F-27) cable would have to occur due to a fire. 
The licensee stated that this cable is located approximately 20 feet 
above the floor and that the nearest primary ignition source in the 
area, the lube oil tank, is located approximately 7 feet below the 
cable. With the exception of the cables themselves, there are no other 
ignition sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
primary CST level indicator, OMA 2 is available to locally 
read CST level at the local indicator, LI-424-993, located at the CST. 
The licensee also stated that they have assumed a 30-minute diagnosis 
period and that the required time to perform the action is 7 minutes 
while the time available is 73 minutes, which provides a 36-minute 
margin.
3.15.4.3 OMA 3--Manually Control 1B3M Breaker at LSP-1B3
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 14 feet above the floor. 
The licensee also stated that the cables pass over the top of potential 
ignition sources MCC 1A12 and MCC 1B12 and that the cables are located 
approximately 6 feet above these ignition sources. Additionally, the 
lube oil tanks are located below the cables, although not directly 
below, with a distance of approximately 26 feet separating the cables 
and the tanks. The cables are also located approximately 20 feet from 
ignition sources MCC 1A12A and 1B12A.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 1B3M breaker locally from LSP-1B3. The licensee also stated 
that they have assumed a 10-minute diagnosis period and that the 
required time to perform the action is 10 minutes while the time 
available is 45 minutes, which provides a 25-minute margin.
3.15.4.4 OMA 4--Manually Control Condensate Transfer Pump 1-2 
from LSP-1B32
    In order for OMA 4 to be necessary, damage to the credited 
and redundant cables for the Condensate Transfer

[[Page 19809]]

Pump 1-2 would have to be damaged due to a fire. The licensee stated 
that these cables are located in the same tray with additional cables 
and are generally located approximately 20 feet above the floor and 
approximately 7 feet above the lube oil tank.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 4 is available to manually 
control Condensate Transfer Pump 1-2 locally from LSP-1B32. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 10 minutes 
while the time available is 45 minutes, which provides a 25-minute 
margin.
3.15.4.5 OMA 6--Manually Reclose Feeder Breaker MCC 1B32 at 
USS 1B3
    In order for OMA 6 to be necessary, power to USS 1B3 or 
the 1B 4160V switchgear would have to be lost due to a fire. The 
licensee stated that these cables are located in the same tray with 
additional cables and are generally located approximately 14 feet above 
the floor. The licensee also stated that the cables pass over the top 
of potential ignition sources MCC 1A12 and MCC 1B12 and that the cables 
are located approximately 6 feet above these ignition sources. 
Additionally, the lube oil tanks are located below the cables, although 
not directly below, with a distance of approximately 26 feet separating 
the cables and the tanks. The cables are also located approximately 20 
feet from ignition sources MCC 1A12A and 1B12A.
    In the unlikely event that a fire does occur and causes a loss of 
power to USS 1B3 or a loss of the 1B 4160V switchgear, OMA 6 
is available to manually re-close Feeder Breaker MCC 1B32 at USS 1B3 
due to an under voltage trip. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 6 minutes while the time available is 45 minutes, 
which provides a 29-minute margin.
3.15.4.6 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.15.4.7 OMA 16--Manually Trip Rx Recirculation Pumps at 4160V 
Switchgear
    In order for OMA 16 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 14 feet above the floor. 
The licensee also stated that the cables pass over the top of potential 
ignition sources MCC 1A12 and MCC 1B12 and that the cables are located 
approximately 6 feet above these ignition sources. Additionally, the 
lube oil tanks are located below the cables, although not directly 
below, with a distance of approximately 26 feet separating the cables 
and the tanks. The cables are also located approximately 20 feet from 
ignition sources MCC 1A12A and 1B12A.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 16 is available to manually 
trip Reactor Recirculation Pumps (``A,'' ``B,'' ``C,'' ``D'' and ``E'') 
4160V Switchgear 1A and 1B. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 13 minutes while the time available is 30 
minutes, which provides a 7-minute margin.
3.15.5 Conclusion
    Although the fire loading for this zone is high, the limited 
ignition sources, large volume of the space, and the detection and 
suppression system make it unlikely that a fire would occur and go 
undetected or unsuppressed and damage the safe shutdown equipment. 
Additionally, the availability of fire extinguishers and AFFF, which is 
effective against oil based fires, provides an augmented ability to 
suppress a fire prior to damaging safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
zone, combined with the ability of OMAs 1, 2, 
3, 4, 6, 12, and 16 to 
manipulate the plant in the event of a fire that damages safe shutdown 
equipment, provides adequate assurance that safe shutdown capability is 
maintained.

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

3.16.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The main combustible loading is attributed to 
cable insulation (approximately 73% of loading) and plastic 
(approximately 17% of loading).
3.16.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11C has an area-wide smoke detection 
system and an area-wide automatic fixed pre-action sprinkler system 
installed (except in the small caged area located to the east of Fire 
Area TB-FA-3A).
3.16.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11C has a ceiling height of 
approximately 21'-8'' and an approximate floor area of 2666 square feet 
so it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.16.4 OMAs Credited for a Fire in This Zone
3.16.4.1 OMA 1--Manually Trip 4160V 1D Breakers and Control 
USS 1B2 & 1B3 Breakers Locally at LSP-1D
    In order for OMA 1 to be necessary, the credited cables 
for USS 1B2 and 1B3 4160V breakers and the redundant cables for USS 1A2 
and 1A3 breakers would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 17 feet above the floor. The 
licensee also stated that the tray passes over the top of potential 
ignition source ``B'' 4160V switchgear and that the cables are located 
approximately 9 feet above this ignition source and 3 feet above the 
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 1 is available to manually 
trip the 4160V 1D breakers and control USS 1B2 and the 1B3 480V 
breakers locally at LSP-1D. The licensee

[[Page 19810]]

also stated that they have assumed a 10-minute diagnosis period and 
that the required time to perform the action is 24 minutes while the 
time available is 45 minutes, which provides an 11-minute margin.
3.16.4.3 OMA 3--Manually Control 1B3M Breaker at LSP-1B3
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 17 feet above the floor. The 
licensee also stated that the tray passes over the top of potential 
ignition source ``B'' 4160V switchgear and that the cables are located 
approximately 9 feet above this ignition source and 3 feet above the 
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 1B3M breaker locally from LSP-1B3. The licensee also stated 
that they have assumed a 10-minute diagnosis period and that the 
required time to perform the action is 10 minutes while the time 
available is 45 minutes, which provides a 25-minute margin.
3.16.4.5 OMA 6--Manually Reclose Feeder Breaker MCC 1B32 at 
USS 1B3
    In order for OMA 6 to be necessary, power to USS 1B3 or 
the 1B 4160V switchgear would have to be lost due to a fire. The 
licensee stated that these cables are located in the same tray with 
additional cables and are generally located at least 17 feet above the 
floor. The licensee also stated that the tray passes over the top of 
potential ignition source ``B'' 4160V switchgear and that the cables 
are located approximately 9 feet above this ignition source and 3 feet 
above the iso-phase bus duct at their closest point.
    In the unlikely event that a fire does occur and causes a loss of 
power to USS 1B3 or a loss of the 1B 4160V switchgear, OMA 6 
is available to manually re-close Feeder Breaker MCC 1B32 at USS 1B3 
due to an under voltage trip. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 6 minutes while the time available is 45 minutes, 
which provides a 29-minute margin.
3.16.4.6 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that the normal CRD flow control valve is a 
single component without a redundant counterpart. Because of this, a 
manual bypass is provided to maintain flow around the CRD flow control 
valves that fail closed upon loss of instrument air or control cable 
damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.16.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the smoke detection or 
sprinkler systems noted above, or personnel, and damage the safe 
shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this zone, combined with the ability of OMAs 
1, 3, 6, and 12 to manipulate the 
plant in the event of a fire that damages safe shutdown equipment, 
provides adequate assurance that safe shutdown capability is 
maintained.

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

3.17.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles in this area are cable 
insulation (approximately 29% of loading), Dow Corning 561 Silicon 
transformer liquid (approximately 15% of loading) and lubricating oil 
(approximately 40% of loading).
3.17.2 Detection, Control, and Extinguishment
    The licensee stated that an automatic wet-pipe sprinkler system and 
an automatic water spray system located at the hydrogen seal oil unit 
are installed in the area.
3.17.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11D has a ceiling height of 
approximately 19' and an approximate floor area of 9668 square feet so 
it is unlikely that smoke and heat would accumulate at the height of 
the safe shutdown equipment and cause a failure due to fire damage.
3.17.4 OMAs Credited for a Fire in This Zone
3.17.4.1 OMA 1--Manually Trip 4160V 1D Breakers and Control 
USS 1B2 & 1B3 Breakers Locally at LSP-1D
    In order for OMA 1 to be necessary, the credited cables 
for USS 1B2 and 1B3 4160V breakers and the redundant cables for USS 1A2 
and 1A3 breakers would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 15 feet above the floor. The 
primary combustible fuel load in the area is the cables themselves and 
storage of transient combustibles is limited due to a sump and 
abandoned acid/caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 1 is available to manually 
trip the 4160V 1D breakers and control USS 1B2 and the 1B3 480V 
breakers locally at LSP-1D. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 24 minutes while the time available is 45 
minutes, which provides an 11-minute margin.

[[Page 19811]]

3.17.4.2 OMA 3--Manually Control 1B3M Breaker at LSP-1B3
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located at least 15 feet above the floor. The 
primary combustible fuel load in the area is the cables themselves and 
storage of transient combustibles is limited due to a sump and 
abandoned acid/caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 1B3M breaker locally from LSP-1B3. The licensee also stated 
that they have assumed a 10-minute diagnosis period and that the 
required time to perform the action is 10 minutes while the time 
available is 45 minutes, which provides a 25-minute margin.
3.17.4.3 OMA 5--Manually Control Diesel Generator 2 
from LSP-DG2
    In order for OMA 5 to be necessary, damage to the credited 
and redundant cables for Diesel Generator 1 and 2 
would have to occur due to a fire. The licensee stated that the 
credited and redundant cables are located in the same cable trays, in 
some areas, with additional cables and that the cable trays are 
approximately 17 feet above the floor. The primary combustible fuel 
load in the area is the cables themselves and storage of transient 
combustibles is limited due to a sump and abandoned acid/caustic tanks 
located in the area.
    The licensee also stated that the primary ignition sources in the 
area are the Turbine Building Closed Cooling Water Pumps and USS 1A1 
and its associated transformer. The licensee stated that the Turbine 
Building Closed Cooling Water Pumps contain less than 5 gallons of oil, 
are enclosed in metal casings, and are located approximately 13 feet 
from the cable tray containing the credited and redundant cables. 
Additionally, USS 1A1 and its associated transformer are located 
approximately 8 feet directly below some of the credited cables for 
Diesel Generator 2, however, the redundant cables are 
approximately 25 feet from this portion of the credited cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 5 is available to manually 
control Emergency Diesel Generator 2 from LSP-DG2. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 14 minutes 
while the time available is 45 minutes, which provides a 21-minute 
margin.
3.17.4.4 OMA 6--Manually Reclose Feeder Breaker MCC 1B32 at 
USS 1B3
    In order for OMA 6 to be necessary, power to USS 1B3 or 
the 1B 4160V switchgear would have to be lost due to a fire. The 
licensee stated that these cables are located in the same tray with 
additional cables and are generally located at least 15 feet above the 
floor. The primary combustible fuel load in the area is the cables 
themselves and storage of transient combustibles is limited due to a 
sump and abandoned acid/caustic tanks located in the area.
    The licensee also stated that the primary ignition sources in the 
area near the cable trays are the Turbine Building Closed Cooling Water 
Pumps and USS 1A1 and its associated transformer (4160V to 480V 
transformer). However, the Turbine Building Closed Cooling Water Pumps 
contain less than 5 gallons of oil and are enclosed in metal casings 
and the cable tray containing the cables is approximately 13 feet from 
the top of the pumps/motors. The top of USS 1A1 and its associated 
transformer are located approximately 30 feet diagonally from the 
credited cables and approximately 15 feet diagonally from the redundant 
cables. Additionally, there is a concrete ceiling beam, with a water 
curtain sprinkler system attached, which would provide some shielding 
for the cables from potential products of combustion generated by this 
ignition source. Sprinkler heads are also located in a ceiling pocket 
between the concrete ceiling beam and the USS 1A1 and transformer.
    In the unlikely event that a fire does occur and causes a loss of 
power to USS 1B3 or loss of the 1B 4160V switchgear, OMA 6 is 
available to manually re-close Feeder Breaker MCC1B32 at USS 1B3 due to 
an under voltage trip. The licensee also stated that they have assumed 
a 10-minute diagnosis period and that the required time to perform the 
action is 6 minutes while the time available is 45 minutes, which 
provides a 29-minute margin.
3.17.4.5 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that although the USSs powering the air 
compressors are located 35 feet apart from each other, the power cables 
are located in the same cable trays for at least 45 feet and that the 
normal CRD flow control valve is a single component without a redundant 
counterpart. Because of this, a manual bypass is provided to maintain 
flow around the CRD flow control valves that fail closed upon loss of 
instrument air or control cable damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.17.5 Conclusion
    Given the limited amount of combustible materials, ignition sources 
and the volume of the space, it is unlikely that a fire would occur and 
go undetected or unsuppressed by the suppression systems noted above, 
or personnel, and damage the safe shutdown equipment. The low 
likelihood of damage to safe shutdown equipment due to a fire in this 
zone, combined with the ability of OMAs 1, 3, 
5, 6, and 12 to manipulate the plant in the 
event of a fire that damages safe shutdown equipment, provides adequate 
assurance that safe shutdown capability is maintained.

[[Page 19812]]

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

3.18.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this Fire Zone is procedurally 
controlled as a transient combustible free area while the plant is 
operating. This area is a high radiation area during plant operation 
and is not normally accessed. The zone has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles in this area are cable 
insulation (approximately 40% of loading) and plastic (approximately 
59% of loading). Plastic grating, which is the largest plastic material 
in this zone, is dispersed throughout this fire zone (not concentrated) 
and has a low flame spread (less than 25).
3.18.2 Detection, Control, and Extinguishment
    The licensee stated that a closed head automatic sprinkler and 
spray systems protect the south end basement area and the hydrogen seal 
oil unit. An exemption was granted from the requirements of Appendix R 
Section III.G.2 in Safety Evaluations (SEs) dated March 24, 1986, and 
June 25, 1990, for not having fixed fire detection in this area. The 
primary basis for this exemption is the presence of the automatic wet 
pipe sprinkler system, low fire loading and the 1-hour barrier 
protection for safe shutdown circuits. Also, the flow alarm will notify 
the control room of any sprinkler system activation. Since the 
Condenser Bay is procedurally controlled as a transient combustible 
free area in procedure OP-AA-201-009 while the plant is operating. 
Extinguishment of a fire will be accomplished by the automatic fixed 
suppression system and the plant fire brigade. A closed head automatic 
sprinkler system was recently expanded to provide fire suppression over 
the cables in cable trays in the northeast side of the condenser bay.
3.18.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11E has a ceiling height of at least 
40' and an approximate floor area of 26427 square feet so it is 
unlikely that smoke and heat would accumulate at the height of the safe 
shutdown equipment and cause a failure due to fire damage.
3.18.4 OMAs Credited for a Fire in This Zone
3.18.4.1 OMA 1--Manually Trip 4160V 1D Breakers and Control 
USS 1B2 & 1B3 Breakers Locally at LSP-1D
    In order for OMA 1 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 40 feet above the floor. 
With the exception of the cables themselves, there are no other 
ignition sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 1 is available to manually 
trip the 4160V 1D breakers and control USS 1B2 and the 1B3 480V 
breakers locally at LSP-1D. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 19 minutes while the time available is 45 
minutes, which provides a 16-minute margin.
3.18.4.2 OMA 2--Read Condensate Storage Tank Local Level 
Indicator LI-424-993
    In order for OMA 2 to be necessary, damage to the primary 
CST level indicator (5F-27) cable would have to occur due to a fire. 
The licensee stated that this cable is located approximately 16 feet 
above the floor. With the exception of the cables themselves, there are 
no other ignition sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
primary CST level indicator, OMA 2 is available to locally 
read CST level at the local indicator, LI-424-993, located at the CST. 
The licensee also stated that they have assumed a 30-minute diagnosis 
period and that the required time to perform the action is 7 minutes 
while the time available is 73 minutes, which provides a 36-minute 
margin.
3.18.4.3 OMA 3--Manually Control 1B3M Breaker at LSP-1B3
    In order for OMA 3 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that these cables are located in the same tray with additional 
cables and are generally located approximately 40 feet above the floor. 
With the exception of the cables themselves, there are no other 
ignition sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 3 is available to manually 
control the 1B3M breaker locally from LSP-1B3. The licensee also stated 
that they have assumed a 10-minute diagnosis period and that the 
required time to perform the action is 10 minutes while the time 
available is 45 minutes, which provides a 25-minute margin.
3.18.4.4 OMA 4--Manually Control Condensate Transfer Pump 1-2 
From LSP-1B32
    In order for OMA 4 to be necessary, damage to the credited 
and redundant cables for the Condensate Transfer Pump 1-2 would have to 
be damaged due to a fire. The licensee stated that these cables are 
located in the same tray with additional cables and are generally 
located approximately 18 feet above the floor. With the exception of 
the cables themselves, there are no other ignition sources or 
combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 4 is available to manually 
control Condensate Transfer Pump 1-2 locally from LSP-1B32. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 10 minutes 
while the time available is 45 minutes, which provides a 25-minute 
margin.
3.18.4.5 OMA 5--Manually Control Diesel Generator 2 
from LSP-DG2
    In order for OMA 5 to be necessary, damage to the credited 
and redundant cables would have to occur due to a fire. The licensee 
stated that the credited and redundant cables are located in separate 
cable trays separated by a horizontal distance of at least 90 feet. The 
licensee also stated that there are no ignition sources near the 
redundant cables and that the primary ignition sources that could 
affect the credited cables are the moisture separator drain pumps and 
area sump pumps, which are located on the floor approximately 20 feet 
horizontally and 17 feet vertically from the credited cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 5 is available to manually 
control Emergency Diesel Generator 2 from LSP-DG2. The 
licensee also stated that they have assumed a 10-minute diagnosis 
period and that the required time to perform the action is 14 minutes 
while the time available is 45 minutes, which provides a 21-minute 
margin.

[[Page 19813]]

3.18.4.6 OMA 6--Manually Reclose Feeder Breaker MCC 1B32 at 
USS 1B3
    In order for OMA 6 to be necessary, power to USS 1B3 or 
the 1B 4160V switchgear would have to be lost due to a fire. The 
licensee stated that the cables that could cause the loss of USS 1B3 
are located in the same tray with additional cables and are generally 
located approximately 40 feet above the floor. With the exception of 
the cables themselves, there are no other ignition sources or 
combustibles located near the cables.
    In the unlikely event that a fire does occur and causes a loss of 
power to USS 1B3 or loss of the 1B 4160V switchgear, OMA 6 is 
available to manually re-close Feeder Breaker MCC 1B32 at USS 1B3 due 
to an under voltage trip. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 6 minutes while the time available is 45 minutes, 
which provides a 29-minute margin.
3.18.4.7 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that although the USSs powering the air 
compressors are located 35 feet apart from each other, the power cables 
are located in the same cable trays for at least 45 feet and that the 
normal CRD flow control valve is a single component without a redundant 
counterpart. Because of this, a manual bypass is provided to maintain 
flow around the CRD flow control valves that fail closed upon loss of 
instrument air or control cable damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.18.4.8 OMA 16--Manually Trip Rx Recirculation Pumps at 4160V 
Switchgear
    In order for OMA 16 to be necessary, the credited and 
redundant cables would have to be damaged due to a fire. The licensee 
stated that the credited cables for tripping the recirculation pumps 
are located in the same tray, or adjacent tray, with additional cables 
and are generally located approximately 40 feet above the floor. With 
the exception of the cables themselves, there are no other ignition 
sources or combustibles located near the cables.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 16 is available to manually 
trip Reactor Recirculation Pumps (``A,'' ``B,'' ``C,'' ``D'' and ``E'') 
4160V Switchgear 1A and 1B. The licensee also stated that they have 
assumed a 10-minute diagnosis period and that the required time to 
perform the action is 13 minutes while the time available is 30 
minutes, which provides a 7-minute margin.
3.18.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the suppression system 
noted above or personnel, and damage the safe shutdown equipment. The 
low likelihood of damage to safe shutdown equipment due to a fire in 
this zone, combined with the ability of OMAs 1, 2, 
3, 4, 5, 6, 12, and 
16 to manipulate the plant in the event of a fire that damages 
safe shutdown equipment, provides adequate assurance that safe shutdown 
capability is maintained.

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

3.19.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustible load consists of cable 
insulation (approximately 15% of loading), lubricating oil 
(approximately 39% of loading), rubber (approximately 21% of loading) 
and plastics (approximately 17% of loading). The licensee states that 
the majority of the combustible loading attributed to rubber and 
plastic was due to the storage of hoses which are now no longer in the 
area.
3.19.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11F has an area-wide thermal fire 
detection system. Extinguishment of the fire will be accomplished by 
the plant fire brigade.
3.19.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11F has a ceiling height of 
approximately 16' in approximately 70% of the area and approximately 
19'-6'' in the remainder of the area. With an approximate floor area of 
5,650 square feet, it is unlikely that smoke and heat would accumulate 
at the height of the safe shutdown equipment and cause a failure due to 
fire damage.
3.19.4 OMAs Credited for a Fire in This Area
3.19.4.1 OMA 7--Align Fire Water to Isolation Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. The loss of the 
``B'' Train of power is attributed to the fact that the 125 VDC control 
power could be lost to the 1D 4160V Switchgear or the 1D 4160V main 
breaker could trip due to cables that traverse through this fire zone. 
The licensee stated that the cables for the 125 VDC control power and 
the control circuit for the 1D main breaker are contained in separate 
conduits but are routed within approximately 6 inches of each other in 
a portion of this zone and that the conduits are located approximately 
5 to 18 feet above the floor. Additionally, the licensee stated that 
the 125 VDC control cable leaves the zone through the east wall into 
Fire Zone RB-FZ-1F2 while the 1D main breaker control cable continues 
along the east wall near the floor through the remaining portion of 
this zone and rises up to approximately 6 feet from the floor where it 
exits the zone.
    The licensee also stated that the primary ignition sources in the 
area are the feedwater pumps and motors, which are located 
approximately 10 feet from the conduits. Transient combustibles are 
controlled by administrative procedures and although the accumulation 
of transient combustibles along the east wall of the area could 
potentially impact the cables, the majority of the conduits are routed 
such that it would be unlikely that a fire in this area would adversely 
impact the cables in the conduit. The ``A'' train of power is credited 
and available for this fire zone. The redundant cable, ``C'' battery, 
``C'' Distribution center, etc. are not located in this fire zone.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available

[[Page 19814]]

to manually open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to 
align the fire water system for make-up water to Isolation Condenser 
``B'' since there is no power (``B'' Train) available to the Condensate 
Transfer System. The licensee also stated that they have assumed a 10-
minute diagnosis period and that the required time to perform the 
action is 13 minutes while the time available is 45 minutes, which 
provides a 22-minute margin.
3.19.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that although the USSs powering the air 
compressors are located 35 feet apart from each other, the power cables 
are located in the same cable trays for at least 45 feet and that the 
normal CRD flow control valve is a single component without a redundant 
counterpart. Because of this, a manual bypass is provided to maintain 
flow around the CRD flow control valves that fail closed upon loss of 
instrument air or control cable damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.19.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is unlikely that a fire 
would occur and go undetected or unsuppressed by the thermal detection 
system noted above or personnel, and damage the safe shutdown 
equipment. The low likelihood of damage to safe shutdown equipment due 
to a fire in this zone, combined with the ability of OMAs 7 
and 12 to manipulate the plant in the event of a fire that 
damages safe shutdown equipment, provides adequate assurance that safe 
shutdown capability is maintained.

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

3.20.1 Fire Prevention
    The licensee has classified the fire loading in this fire zone as 
low. The licensee also stated that this area has an administrative fire 
loading limit of less than 30 minutes as determined by the ASTM E119 
time-temperature curve. The major combustibles are cable insulation 
(approximately 23% of loading), ladders and other miscellaneous 
plastics (approximately 55% of loading) and miscellaneous ordinary 
combustibles.
3.20.2 Detection, Control, and Extinguishment
    The licensee stated that TB-FZ-11H has a partial area thermal fire 
detector system. The system alarms locally and in the control room. 
Manual extinguishment of fire will be accomplished by the plant fire 
brigade.
3.20.3 Preservation of Safe Shutdown Capability
    The licensee stated that TB-FZ-11H has a ceiling height of 
approximately 7'-0'', measured at the 3'-6'' elevation, and 
approximately 19'-0'', measured at the 23'-6'' elevation with an 
approximate floor area of 3,944 square feet and 4,366 square feet, 
respectively, so it is unlikely that smoke and heat would accumulate at 
the height of the safe shutdown equipment and cause a failure due to 
fire damage.
3.20.4 OMAs Credited for a Fire in This Area
3.20.4.1 OMA 7--Align Fire Water to Isolation Condenser
    In order for OMA 7 to be necessary, the loss of the ``B'' 
Train of power would have to occur due to fire damage. The loss of the 
``B'' Train of power is attributed to the fact that the 125 VDC control 
power could be lost to the 1D 4160V Switchgear or the 1D 4160V main 
breaker could trip due to cables that traverse through this fire zone. 
The licensee stated that the cables for the 125 VDC control power and 
the control circuit for the 1D main breaker are contained in separate 
conduits but are routed within approximately 6 inches of each other in 
a portion of this zone and that the conduits are located approximately 
5 to 6 feet above the floor. Additionally, the licensee stated that the 
total length of the conduits in this area is approximately 20 feet.
    The licensee also stated that there are no ignition sources in the 
area and that combustible loading is limited since the area is a 
stairway area. Transient combustibles are controlled by administrative 
procedures and although the accumulation of transient combustibles 
below the conduits could potentially impact the cables, it is unlikely 
because the area is a stairway and part of the floor is blocked by a 
large ventilation duct. The ``A'' train of power is credited and 
available for this fire zone. The redundant cable, ``C'' battery, ``C'' 
Distribution center, etc. are not located in this fire zone.
    In the unlikely event that a fire does occur and damages the 
credited and redundant cables, OMA 7 is available to manually 
open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 to align the 
fire water system for make-up water to Isolation Condenser ``B'' since 
there is no power (``B'' Train) available to the Condensate Transfer 
System. The licensee also stated that they have assumed a 10-minute 
diagnosis period and that the required time to perform the action is 13 
minutes while the time available is 45 minutes, which provides a 22-
minute margin.
3.20.4.2 OMA 12--Establish CRD Flow to Reactor
    In order for OMA 12 to be necessary, a loss of instrument 
air to the CRD flow control valve would have to occur due to fire 
damage. The licensee stated that although the USSs powering the air 
compressors are located 35 feet apart from each other, the power cables 
are located in the same cable trays for at least 45 feet and that the 
normal CRD flow control valve is a single component without a redundant 
counterpart. Because of this, a manual bypass is provided to maintain 
flow around the CRD flow control valves that fail closed upon loss of 
instrument air or control cable damage.
    In the unlikely event that a fire does occur and causes the normal 
flow control valve to be unavailable due to a loss of instrument air or 
cable damage, OMA 12 is available to manually open V-15-237, 
throttle V-15-30 while monitoring flow at FI-225-2, and close V-15-52 
to establish CRD flow to the reactor. Furthermore, OMA 12 
would only be necessary if the Isolation Condenser/CRD systems are 
utilized for hot shutdown. If OMA 12 becomes necessary, the 
licensee stated that they have assumed a 30-minute diagnosis period and 
that the required time to perform the action is 15 minutes, while the 
time available is 204 minutes, which provides a 159-minute margin.
3.20.5 Conclusion
    Given the limited amount of combustible materials, ignition 
sources, and large volume of the space, it is

[[Page 19815]]

unlikely that a fire would occur and go undetected or unsuppressed by 
the thermal detection system noted above or personnel, and damage the 
safe shutdown equipment. The low likelihood of damage to safe shutdown 
equipment due to a fire in this zone, combined with the ability of OMAs 
7 and 12 to manipulate the plant in the event of a 
fire that damages safe shutdown equipment, provides adequate assurance 
that safe shutdown capability is maintained.

3.21 Feasibility of the Operator Manual Actions

    This analysis postulates that OMAs may, in some scenarios, be 
needed to assure safe shutdown capability in addition to the 
traditional fire protection features described above. NUREG-1852, 
``Demonstrating the Feasibility and Reliability of Operator Manual 
Actions in Response to Fire,'' provides criteria and associated 
technical bases for evaluating the feasibility and reliability of post-
fire OMAs in nuclear power plants. However, Exelon states that the OMAs 
identified in its Phase 1 request were previously found acceptable in 
fire protection SEs dated March 24, 1986 and June 25, 1990, and, 
therefore, do not need to meet the reliability criteria specified in 
NUREG-1852, ``Demonstrating the Feasibility and Reliability of Operator 
Manual Actions in Response to Fire,'' dated October 2007. The NRC staff 
finds that the SEs referenced by the licensee, in addition to the 
feasibility review contained in this SE, provide the necessary 
information to determine the feasibility and reliability of the OMAs.
3.21.1 Bases for Establishing Feasibility
    Using NUREG-1852, the NRC staff has evaluated the feasibility 
review provided by the licensee in the April 2, 2010, Response to 
Request for Additional Information. For an OMA to be considered 
feasible, the required actions must be proceduralized, any equipment 
that is needed to implement the OMA is available, the environments in 
which the OMA is to be performed must permit the action, and the time 
taken to diagnose the need for the OMA and implement it (time required) 
must be less than the time in which the OMA must be completed (time 
available).
3.21.2 Feasibility
    The feasibility review provided by the licensee documents that 
procedures are in place, in the form of fire response procedures, to 
ensure that clear and accessible instructions on how to perform the 
manual actions are available to the operators. All of the requested 
OMAs are directed by plant procedures, and the operators are trained in 
the use of the procedures. Specifically, the licensee stated that 
abnormal operating procedure ABN-29, ``Plant Fires,'' is entered 
whenever a fire or indication of a fire occurs on the main fire alarm 
panel in the control room or at any local fire alarm panel. In addition 
to dispatching a 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, 
CO2) or a fire is confirmed. In addition, the licensee 
stated that ABN-29 directs immediate entry into the FSP for the 
affected fire area as soon as the existence of a fire is confirmed. The 
licensee states that the following indications or symptoms are 
considered examples of a confirmed fire:
     Fire detection alarm and equipment malfunction indication 
or alarms within the same area;
     Fire pump start and either sprinkler flow alarm or deluge 
flow alarm;
     Gaseous suppression system actuation;
     Report from the field of an actual smoke condition or 
actual fire condition; or
     Fire detection alarm with follow up confirmation by field 
operator.
    Entering the FSP means that the operator will review the FSP, 
identify equipment that could be affected, identify equipment that will 
be available, monitor plant equipment from the control room and 
communicate with the fire brigade leader. Based on the symptoms 
received in the control room and the feedback from the fire brigade 
leader, the operator will decide using the procedure what mitigating 
actions are necessary. In the event that a plant shutdown has occurred 
before the FSP is entered, the operator will still enter the FSP based 
on the fire and initiate the OMAs as appropriate. OMAs that are 
considered ``prompt'' (i.e., those that must be done within 45 minutes 
or less) are identified in both ABN-29 and in the applicable FSPs as an 
item requiring immediate attention. The operators are trained to 
perform prompt actions first and prioritize them based upon existing 
plant conditions. The FSPs are based on the worst-case loss 
considerations by assuming all fire damage occurs instantaneously and 
thus all operator manual actions will be required. The use of the EOPs 
in conjunction with the applicable FSPs will permit the use of any 
mitigating system available first, and if a desired system is not 
available, the FSP provides a contingency action to restore the system 
or provide another means to perform the function. Operator training, 
including simulator demonstrations and plant walk downs, has been 
performed to ensure consistency in operator and team response for each 
OMA.
    The licensee evaluated several potential environmental concerns, 
such as radiation levels, temperature/humidity conditions and the 
ventilation configuration and fire effects that the operators may 
encounter during certain emergency scenarios. The licensee's 
feasibility review concluded that the operators performing the manual 
actions would not be exposed to adverse or untenable conditions during 
any particular operator manual action procedure or during the time to 
perform the procedure. The licensee states that OMAs required for 
achieving and maintaining hot shutdown conditions are not impacted by 
environmental conditions associated with fires in the fire area 
identified in the request. Each of the safe shutdown calculations that 
provide the technical basis for the FSPs contains a timeline for 
operator actions for the specific fire area. In addition, the licensee 
stated that the equipment needed to implement OMAs remains available 
and the fire areas remain accessible during or following the event.
    In one instance, OMA 12, the licensee identified that an operator 
may need to re-enter Fire Zone RB-FZ-1E (i.e., perform part of an OMA 
in the affected fire zone) to manually manipulate three 2-inch CRD 
System valves V-15-237, V-15-30, and V-15-52 that are physically 
located within 4 feet of each other within the spray area of the 
automatic localized fixed water spray deluge system installed in this 
fire zone. An exemption was granted in SE dated June 25, 1990, for not 
providing either additional separation from in-situ combustibles or 
protection for CRD System valve V-15-30. This exemption was granted on 
the basis that: (1) There are 204 minutes following a scram before this 
action would need to be completed and this action and only requires 15 
minutes to complete; (2) any fires in that area are unlikely to render 
the valve inoperable; (3) the valves are within the spray area of an 
automatic fixed water spray deluge system. Since valves V-15-237, V-15-
52, and V-15-30 are physically within 4 feet of each other the NRC 
staff considers the technical basis of the exemption to be equally 
valid for these two additional valves.
    The licensee's analysis demonstrates that, for the expected 
scenarios, the OMAs can be diagnosed and executed

[[Page 19816]]

within the amount of time available to complete them. The licensee's 
analysis also demonstrates that various factors, as discussed above, 
have been considered to address uncertainties in estimating the time 
available. Therefore, the OMAs included in this review are feasible 
because there is adequate time available for the operator to perform 
the required OMAs to achieve and maintain hot shutdown following a 
postulated fire event. Table 2 summarizes the ``required'' versus 
``available'' times for each OMA. The licensee has included any 
diagnosis time as part of the required time for performing a particular 
action. Where an action has multiple times or contingencies associated 
with the ``available'' completion time, the lesser time is used. This 
approach is considered to represent a conservative approach to 
analyzing the timelines associated with each of the OMAs with regard to 
the feasibility and reliability of the actions included in this 
exemption. The licensee provided a discussion of the times and 
circumstances associated with each of the actions in their March 3, 
2009, and April 2, 2010, correspondence.

                                                     Table 2
----------------------------------------------------------------------------------------------------------------
                                                                             Required    Available      Margin
       OMA         Fire area/zone of fire origin        OMA location       time  (min)  time  (min)     (min)
----------------------------------------------------------------------------------------------------------------
1................  TB-FA-26, TB-FZ-11B, TB-FZ-    TB-FA-3B...............           29           45           16
                    11E.
                  -------------------------------                         --------------------------------------
                   TB-FZ-11C, TB-FZ-11D.........                                    34           45           11
2................  OB-FA-9, OB-FZ-6A, OB-FZ-8C,   Yard...................           37           73           36
                    TB-FZ-11B, TB-FZ-11E.
3................  TB-FA-26, TB-FZ-11B, TB-FZ-    CW-FA-14...............           20           45           25
                    11C, TB-FZ-11D, TB-FZ-11E.
4................  TB-FZ-11B, TB-FZ-11E.........  MT-FA-12...............           20           45           25
5................  TB-FZ-11D, TB-FZ-11E.........  DG-FA-17...............           24           45           21
6................  TB-FA-26, TB-FZ-11B, TB-FZ-    CW-FA-14...............           16           45           29
                    11C, TB-FZ-11D, TB-FZ-11E.
7................  OB-FZ-6B, OB-FZ-8A, OB-FZ-8B,  RB-FZ-1E...............           23           45           22
                    OB-FZ-8C, TB-FZ-11F, TB-FZ-
                    11H, CW-FA-14.
8................  OB-FZ-8C.....................  OB-FZ-6A...............           38           60           22
9................  OB-FZ-6A.....................  OB-FZ-6B...............           43          180          137
11...............  RB-FZ-1E, RB-FZ-1G...........  RB-FZ-1D...............          130          204           74
12...............  RB-FZ-1D, RB-FZ-1F5, TB-FA-    RB-FZ-1E...............           45          204          159
                    3A, OB-FZ-6A, OB-FZ-6B, OB-
                    FZ-8A, OB-FZ-8B, OB-FZ-8C,
                    OB-FA-9, TB-FA-26, TB-FZ-
                    11B, TB-FZ-11C, TB-FZ-11D,
                    TB-FZ-11E, TB-FZ-11F, TB-FZ-
                    11H, CW-FA-14.
                  -------------------------------                         --------------------------------------
                   OB-FZ-10A....................                                    48          204          156
                  -------------------------------                         --------------------------------------
                   RB-FZ-1E, RB-FZ-1G...........                                   130          204           74
13...............  RB-FZ-1F3....................  RB-FZ-1F2..............           65          204          139
16...............  TB-FZ-11B, TB-FZ-11E, OB-FZ-   TB-FZ-11C..............           23           30            7
                    8C.
----------------------------------------------------------------------------------------------------------------

    The NRC staff reviewed the required OMA completion time limits 
versus the time before the action becomes critical to safely shutting 
down the unit as presented in the feasibility analyses. The NRC staff 
recognizes that, in some cases, the time required neared the time 
available for an OMA. The NRC staff, however, also recognizes that 
there are conservatisms built in to these time estimates such as adding 
in the entire time assumed to diagnose the need for an OMA where in 
reality, the actual time take would likely be less.
    The NRC staff notes that, in one case, an OMA must be completed 
within 30 minutes (i.e., it is considered a prompt action). This action 
is identified as OMA 16 and requires an operator to manually 
trip the Reactor Recirculation Pumps ``A,'' ``B,'' ``C,'' ``D'' and 
``E'' at the 4160V Switchgear 1A and 1B. The action may be required as 
a result of fire in OB-FZ-8C, TB-FZ-11B, or TB-FZ-11E. The symptom for 
this action is the inability to trip the Recirculation Pumps from the 
control room and this is detected using the associated pump breaker 
indicating lights, alarms and flow indications. The Fire Support 
Procedures direct the operator to trip the pumps using the pump control 
switches or the Recirculation Pump Trip circuitry (two trip coils for 
pumps). If both of these methods fail on one or more pumps, the 
guidance is given to trip the pumps from the 4160V Switchgear 1A and 1B 
located outside the control room in Fire Area TB-FZ-11C. Only one 
operator would be required and it would take approximately 13 minutes 
for access to the area and to perform the action of tripping the 
breakers. Given the low complexity of this action, the NRC staff finds 
that there is a sufficient amount of time available to complete the 
proposed OMAs.

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

    In summary, the defense-in-depth concept for a fire in the fire 
areas discussed above provides a level of safety that limits the 
occurrence of fires and results in rapid detection, control and 
extinguishment of fires that do occur and the protection of structures, 
systems, and components important to safety. It should be understood 
that the OMAs are a fall back in the unlikely event that the fire 
protection defense-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.

[[Page 19817]]

3.23 Authorized by Law

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

3.24 No Undue Risk to Public Health and Safety

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

3.25 Consistent With Common Defense and Security

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

3.26 Special Circumstances

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

4.0 Conclusion

    Accordingly, the Commission has determined that, pursuant to 10 CFR 
50.12(a), the exemption is authorized by law, will not present an undue 
risk to the public health and safety, is consistent with the common 
defense and security and that special circumstances are present to 
warrant issuance of the exemption. Therefore, the Commission hereby 
grants Exelon an exemption from the requirements of Section III.G.2 of 
Appendix R of 10 CFR part 50, to utilize the OMAs discussed above at 
Oyster Creek.
    Pursuant to 10 CFR 51.32, the Commission has determined that the 
granting of this exemption will not have a significant effect on the 
quality of the human environment (74 FR 36274).
    This exemption is effective upon issuance.

    Dated at Rockville, Maryland, this 30th day of March 2011.
    For the Nuclear Regulatory Commission.
Joseph G. Giitter,
Director, Division of Operating Reactor Licensing, Office of Nuclear 
Reactor Regulation.
[FR Doc. 2011-8405 Filed 4-7-11; 8:45 am]
BILLING CODE 7590-01-P