[Federal Register Volume 77, Number 28 (Friday, February 10, 2012)]
[Notices]
[Pages 7184-7211]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2012-3124]


=======================================================================
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NUCLEAR REGULATORY COMMISSION

[Docket No. 50-247]


Entergy Nuclear Indian Point 2, LLC; Entergy Nuclear Operations, 
Inc.; Indian Point Nuclear Generating Unit No. 2; Exemption

1.0 Background

    Entergy Nuclear Operations, Inc. (Entergy or the licensee) is the 
holder of Facility Operating License No. DPR-026, which authorizes 
operation of Indian Point Nuclear Generating Unit No. 2 (IP2). The 
license provides, among other things, that the facility is subject to 
all rules, regulations, and orders of the U.S. Nuclear Regulatory 
Commission (NRC or the Commission) now or hereafter in effect.
    IP2 is a pressurized-water reactor located approximately 24 miles 
north of the New York City boundary line on the east bank of the Hudson 
River in Westchester County, New York.

2.0 Request/Action

    Title 10 of the Code of Federal Regulations (10 CFR) part 50, 
Section 50.48(b), requires that nuclear power plants that were licensed 
to operate before January 1, 1979, satisfy the requirements of 10 CFR 
part 50, Appendix R, ``Fire Protection Program for Nuclear Power 
Facilities Operating Prior to January 1, 1979,'' Section III.G, ``Fire 
protection of safe shutdown capability.'' The circuit separation and 
protection requirements being addressed in this request for exemption 
are specified in Section III.G.2. Since IP2 was licensed to operate 
before January 1, 1979, IP2 is required to meet Section lll.G.2 of 
Appendix R to 10 CFR part 50.
    The underlying purpose of Section III.G of Appendix R to 10 CFR 
part 50 is to establish reasonable assurance that safe shutdown (SSD) 
of the reactor can be achieved and maintained in the event of a 
postulated fire in any plant area. Circuits which could cause 
maloperation or prevent operation of redundant trains of equipment 
required to achieve and maintain hot shutdown conditions as a result of 
fire in a single fire area must be protected in accordance with 
lll.G.2. If conformance with the technical requirements of III.G.2 
cannot be assured in a specific fire area, an alternative or dedicated 
shutdown capability must be provided in accordance with Section 
III.G.3, or an exemption obtained in accordance with 10 CFR 50.12, 
``Specific exemptions.''
    By letter dated March 6, 2009, Entergy requested an exemption from 
the requirements of 10 CFR part 50, Appendix R, in accordance with 10 
CFR 50.12. Specifically, Entergy requested an exemption to allow the 
use of Operator Manual Actions (OMAs) in lieu of meeting certain 
technical requirements of III.G.2 in Fire Areas C, F, H, J, K, P, and 
YD of IP2. The table below provides the dates and topics of the 
submittals related to this request.

----------------------------------------------------------------------------------------------------------------
            Subject                  Author             Date             Description          ADAMS  Accession
----------------------------------------------------------------------------------------------------------------
Exemption Request from          Entergy.........  March 6, 2009...  Original Submittal...  ML090770151.
 Appendix R.
Revised Exemption Request.....  Entergy.........  October 1, 2009.  Revision to March      ML092810231
                                                                     2009 submittal,
                                                                     incorporated changes
                                                                     to Attachment 2,
                                                                     Technical Basis in
                                                                     Support of Exemption
                                                                     Request.
Request for Additional          NRC.............  January 20, 2010  Request for            ML100150128
 Information (RAI) 1.                                       information on the
                                                                     overall defense-in-
                                                                     depth for each fire
                                                                     zone..
RAI Response 1.......  Entergy.........  May 4, 2010.....  Response to the        ML101320230
                                                                     staff's January 20,
                                                                     2010, RAI..
RAI 2................  NRC.............  August 11, 2010.  RAI on reactor         ML102180331
                                                                     coolant system
                                                                     makeup, separation
                                                                     distances, etc.
RAI Response 2.......  Entergy.........  September 29,     Response to the        ML102930237
                                                   2010.             staff's August 11,
                                                                     2010, RAI.
RAI 3................  NRC.............  December 16,      RAI on reactor         ML103500204
                                                   2010.             coolant system
                                                                     makeup.
RAI Response 3.......  Entergy.........  January 19, 2011  Responses to the       ML110310013
                                                                     staff's December 16,
                                                                     2010, RAI.
Letter to revise previously     Entergy.........  February 10,      Letter updating        ML110540321
 submitted information.                            2011.             tables contained in
                                                                     previous submittals.

[[Page 7185]]

 
Letter to revise previously     Entergy.........  May 26, 2011....  Letter updating        ML11158A197
 submitted information.                                              tables contained in
                                                                     previous submittals.
----------------------------------------------------------------------------------------------------------------

    III.G.2 establishes various protection options for providing 
reasonable assurance that at least one train of systems, equipment, and 
cabling required to achieve and maintain hot shutdown conditions 
remains free of fire damage. In lieu of providing one of the means 
specified in the regulation, Entergy requests an exemption from lll.G.2 
to allow the use of OMAs to achieve and maintain hot shutdown 
conditions in the event of fire in seven fire areas at IP2, Fire Areas 
C, F, H, J, K, P, and YD. The licensee further subdivides these fire 
areas into one or more fire zones for analysis purposes.

3.0 Discussion

    Pursuant to 10 CFR 50.12, the Commission may, upon application by 
any interested person or upon its own initiative, grant exemptions from 
the requirements of 10 CFR part 50 when: (1) the exemptions are 
authorized by law, will not present an undue risk to public health or 
safety, and are consistent with the common defense and security; and 
(2) when special circumstances are present. The licensee stated that 
special circumstances exist because the application of the regulation 
in this particular circumstance is not necessary to achieve the 
underlying purpose of the rule.
    In accordance with 10 CFR 50.48(b), nuclear power plants licensed 
to operate before January 1, 1979, are required to meet Section III.G, 
of 10 CFR part 50, Appendix R. The underlying purpose of Section III.G 
of 10 CFR part 50, Appendix R, is to ensure that the ability to achieve 
and maintain SSD is preserved following a fire event. The regulation 
intends for licensees to accomplish this by extending the concept of 
defense-in-depth to:
     Prevent fires from starting.
     Rapidly detect, control, and extinguish promptly those 
fires that do occur.
     Provide protection for structures, systems, and components 
important to safety so that a fire that is not promptly extinguished by 
the fire suppression activities will not prevent the SSD of the plant.
    Section III.G.2 requires one of the following means to ensure that 
a redundant train of SSD cables and equipment is free of fire damage, 
where redundant trains are located in the same fire area outside of 
primary containment:
    a. Separation of cables and equipment by a fire barrier having a 3-
hour rating;
    b. Separation of cables and equipment by a horizontal distance of 
more than 20 feet with no intervening combustibles or fire hazards and 
with fire detectors and an automatic fire suppression system installed 
in the fire area; or
    c. Enclosure of cables and equipment of one redundant train in a 
fire barrier having a 1-hour rating and with fire detectors and an 
automatic fire suppression system installed in the fire area.
    In its March 6, 2009, and October 1, 2009, submittals, Entergy 
requested an exemption from certain technical requirements of III.G.2 
to the extent that one of the redundant trains of systems necessary to 
achieve and maintain hot shutdown is not maintained free of fire damage 
in accordance with one of the required means prescribed in III.G.2 in 
Fire Areas C, F, H, J, K, P, and YD. The licensee also listed an 
operator action to implement emergency operating procedure (EOP) 2-FR-
H.1, ``Response To Loss Of Secondary Heat Sink.'' The NRC does not 
consider implementing 2-FR-H.1 an OMA, as actions to establish reactor 
coolant system decay heat removal can be performed from the control 
room and there are redundant trains of equipment located outside of the 
fire area of fire origin.
    Each OMA included in this review consists of a sequence of tasks 
that occur in various fire areas. The OMAs are initiated upon 
confirmation of a fire in a particular fire area, which the licensee 
has further subdivided into fire zones. Listed in the order of the fire 
area of fire origin, the OMAs included in this review are as follows:

------------------------------------------------------------------------
                      Area of fire                       Operator manual
   OMA          origin           Area name          actions
------------------------------------------------------------------------
1................  C................  Auxiliary Boiler  Implement EOP FR-
                                       Feed Pump Room,   H.l as directed
                                       Elevation 18'-    by EOPs and
                                       6'' of the        status trees if
                                       Auxiliary Feed    necessary to
                                       Pump Building.    establish
                                                         alternate
                                                         secondary heat
                                                         sink. Action
                                                         performed from
                                                         the control
                                                         room, so the
                                                         NRC does not
                                                         consider this
                                                         an OMA.
                                                       -----------------
2................  .................  ................  Operate turbine-
                                                         driven 22
                                                         auxiliary
                                                         feedwater (AFW)
                                                         pump upon
                                                         reentry to the
                                                         room following
                                                         the initial
                                                         hour of the
                                                         fire scenario.
                                                       -----------------
3................  .................  ................  Open or check
                                                         open 22 AFW
                                                         pump steam
                                                         supply
                                                         isolation
                                                         valves PCV-
                                                         1310A and PCV-
                                                         1310B.
                                                       -----------------
4................  .................  ................  Operate 22 AFW
                                                         pump flow
                                                         control valves
                                                         FCV-405A
                                                         (discharge to
                                                         21 steam
                                                         generator
                                                         (SG)), FCV-405B
                                                         (discharge to
                                                         22 SG), FCV-
                                                         405C (discharge
                                                         to 23 SG), and/
                                                         or FCV-405 to
                                                         align AFW flow
                                                         to selected
                                                         steam
                                                         generators.
------------------------------------------------------------------------
5................  F................  Primary           Open HCV-142
                                       Auxiliary         bypass valve
                                       Building and      227 to align
                                       Fan House.        charging pump
                                                         makeup path to
                                                         the Reactor
                                                         Coolant System
                                                         (RCS).
                                                       -----------------

[[Page 7186]]

 
6................  .................  ................  Align charging
                                                         pump suction
                                                         source to the
                                                         Refueling Water
                                                         Storage Tank
                                                         (RWST).
                                                       -----------------
7................  .................  ................  Transfer
                                                         instrument
                                                         buses 23 and
                                                         23A to
                                                         alternate
                                                         power.
------------------------------------------------------------------------
8................  H................  Vapor (Reactor)   Fail open valves
                                       Containment       204A (charging
                                       Building.         flow to Loop 2
                                                         hot leg) and
                                                         204B (charging
                                                         flow to Loop 1
                                                         cold leg) to
                                                         align charging
                                                         pump makeup
                                                         path to the
                                                         RCS.
                                                       -----------------
9................  .................  ................  Activate or
                                                         enable
                                                         Alternate Safe
                                                         Shutdown System
                                                         pneumatic
                                                         instruments
                                                         (steam
                                                         generator
                                                         level,
                                                         pressurizer
                                                         pressure and
                                                         level) at Fan
                                                         House local
                                                         control panel.
                                                       -----------------
10...............  .................  ................  Enable Alternate
                                                         Safe Shutdown
                                                         System source-
                                                         range channel
                                                         and Loop 21 and
                                                         22 hot leg (Th)
                                                         and cold leg
                                                         (Tc)
                                                         temperature
                                                         channels.
------------------------------------------------------------------------
11...............  J................  Unit 1 Control    Trip breakers 52/
                                       Room, Turbine     5A and 52-SAC
                                       Building,         on Bus 5A and
                                       Superheater       52/6A and 52/
                                       Building,         TAO at Bus 6A
                                       Nuclear Service   and remove
                                       Building,         control power
                                       Chemical          fuses.
                                       Systems
                                       Building,
                                       Administration
                                       Building,
                                       Screenwell
                                       House, and Unit
                                       2 Turbine
                                       Building.
                                                       -----------------
12...............  .................  ................  Transfer
                                                         Instrument
                                                         Buses 23 and
                                                         23A to
                                                         emergency power
                                                         source.
                                                       -----------------
13...............  .................  ................  Align charging
                                                         pump suction to
                                                         RWST.
------------------------------------------------------------------------
14...............  K................  Auxiliary Feed    Operate transfer
                                       Pump Building     switch EDC5 and
                                       (not including    close supply
                                       the AFW Pump      breaker at
                                       Room).            substation
                                                         12FD3 to
                                                         transfer 21 AFW
                                                         Pump to
                                                         Alternate Safe
                                                         Shutdown System
                                                         power source.
                                                       -----------------
15...............  .................  ................  Open 21 AFW pump
                                                         recirculation
                                                         bypass valve
                                                         BFD-77.
------------------------------------------------------------------------
16...............  P................  Component         Transfer 23 CCW
                                       Cooling Water     pump to
                                       (CCW) Pump Room.  Alternate Safe
                                                         Shutdown System
                                                         power feed
                                                         followed by
                                                         breaker closure
                                                         at 12FD3.
                                                       -----------------
17...............  .................  ................  Start Appendix R
                                                         Diesel
                                                         Generator
                                                         (ARDG) if
                                                         normal power
                                                         and offsite
                                                         power are lost.
------------------------------------------------------------------------
18...............  YD...............  Outdoor (Yard)    Open HCV-142
                                       Area.             bypass valve
                                                         227 to align
                                                         charging pump
                                                         makeup path to
                                                         RCS.
------------------------------------------------------------------------

    In their submittals, the licensee described elements of their fire 
protection program that provide their justification that the concept of 
defense-in-depth that is in place in the above fire areas is consistent 
with that intended by the regulation. The licensee utilizes various 
protective measures to accomplish the concept of defense-in-depth. 
Specifically, the licensee stated that the purpose of their request was 
to credit the use of OMAs, in conjunction with other defense-in-depth 
features, in lieu of the separation and protective measures required by 
III.G.2 for a fire in the fire areas identified above.
    In their March 6, 2009, and October 1, 2009, submittals, the 
licensee provided an analysis that described how fire prevention is 
addressed for each of the fire areas for which the OMAs may be required 
because the separation requirements for equipment and electrical 
circuits required by III.G.2 are not met. Specifically, the licensee 
stated that noncombustible materials have been used to the maximum 
extent practicable and that the introduction of combustible materials 
into areas with safety-related equipment, including Fire Areas C, F, H, 
K, and P, is strictly controlled by administrative procedures. The 
administrative procedures govern the handling, storage, and limitations 
for use of ordinary combustible materials, combustible and flammable 
gases and liquids, and other combustible supplies. In addition, 
periodic fire prevention inspections are performed to assess compliance 
with Indian Point's programs for Control of Combustibles and Control of 
Ignition Sources. The licensee stated that the administrative controls 
are described in the IP2 Fire Protection Program (FPP), which is 
incorporated by reference into the Updated Final Safety Analysis 
Report.
    The licensee stated that both thermoplastic and thermoset low-
voltage power, control, and instrument cables are installed at IP2. 
Since the thermoplastic insulated cables were manufactured and 
installed prior to the issuance of IEEE-383, a standard for nuclear 
plant cables, they were not qualified to that standard. In its May 4, 
2010 letter, the licensee stated that these cables are constructed with 
an asbestos glass braid outer jacket which provides protection from 
flame spread. In addition, the licensee stated that the results of 
various tests, as well as an actual fire event during plant 
construction, have demonstrated the ability of this type of 
thermoplastic insulated cables to minimize the growth and spread of 
cable fires. The licensee also stated that the likelihood of self-

[[Page 7187]]

ignited cable fires is minimized by appropriately sized electrical 
protection devices (e.g., fuses and circuit breakers). The licensee 
stated that all cables installed after plant construction are thermoset 
cables which meet the IEEE-383 standard. The IEEE-383 standard includes 
fire-retardation characteristics.
    All of the fire areas in the plant are comprised of one or more 
fire zones consisting of separate compartments or fire zone 
delineations based on spatial separation. In addition, the licensee 
stated that the localization of hazards and combustibles within each 
fire zone, combined with the spatial or physical barrier separation 
between zones, provides reasonable assurance that a fire that occurs 
within a particular zone will be confined to that zone. As such, the 
licensee provided a characterization of the defense-in-depth that is 
present in each of the fire zones containing multiple trains of SSD 
equipment. The licensee further stated that for each of the fire zones 
where OMAs are performed, the adequacy of non-rated fire barriers was 
evaluated to ensure that they can withstand the hazards associated with 
the area. Therefore, this review evaluates the defense-in-depth 
provided in each of the zones of concern.
    In its submittals, the licensee provided a summary of plant-
specific fire protection features provided for each fire zone 
identified in its request including an account of combustible loading 
(both fixed and transient), ignition sources, detection, suppression, 
administrative controls, and identified any additional fire protection 
features that may be unique to the fire zone, such as electrical 
raceway fire barriers. In its responses, the licensee stated that 
combustibles and sources of ignition are tightly controlled by 
administrative controls programs and that the areas included in this 
exemption are not shop areas so hot work activities (such as welding) 
are infrequent and appropriate administrative controls (e.g., hot work 
permits, fire watch, and supervisory controls) are in place if hot work 
activities do occur. The licensee also stated that the original 
installation of the suppression and detection systems was accepted by 
the NRC staff in safety evaluation reports (SERs) dated January 31, 
1979, and a supplement dated October 31, 1980, and that there are no 
code compliance items that present an adverse impact to the 
implementation of the requested OMAs. Within the fire zones of concern 
to its request, the licensee stated that fire-rated assemblies are only 
used and credited for intra-zone separation of redundant SSD equipment 
trains in part of Fire Area F (Fire Zone 7A) and part of Fire Area P 
(Fire Zone 1). The fire-rated assemblies consist of a Hemyc Electrical 
Raceway Fire Barrier System (ERFBS) and have been evaluated to ensure 
they are adequate for the hazards of the areas of installation.
    Entergy stated that for each of the fire areas addressed in this 
evaluation, Post-Fire Safe Shutdown (PFSSD) is principally accomplished 
by remaining in the Central Control Room (CCR) and conducting a normal 
(non-alternative) shutdown. In all cases, the identified OMAs mitigate 
conditions where certain technical requirements of III.G.2 are not 
satisfied.
    Entergy further stated that the OMAs required for achieving and 
maintaining hot shutdown conditions are feasible, reliable, and are not 
impacted by environmental conditions (radiation, lighting, temperature, 
humidity, smoke, toxic gas, noise, fire suppression discharge, etc.) 
associated with fires in III.G.2 areas. The feasibility and reliability 
of the requested OMAs are addressed in Section 4.0 of this evaluation.

NRC Staff Observations

    In its May 4, 2010, response to RAI-07.1, the licensee stated that 
no credit was taken for immediate and proactive OMA response by plant 
operators upon the receipt of a fire detection alarm in any of the 
identified fire zones. Instead, the licensee stated that OMAs are 
initiated upon the detection of operating abnormalities or failures 
caused by a postulated fire event. In this same response, the licensee 
stated that they conducted exercises using the plant simulator to 
evaluate the feasibility of the OMAs where a fire condition or a 
spontaneous reactor trip caused by a fire was announced at the outset 
of the simulation followed by the failure of discrete components that 
are subject to impairment due to fire damage to cables or components 
resulting from a fire in the area of concern. For fires originating in 
fire zones lacking fire detection and/or automatic fire suppression 
systems, the NRC staff considers it improbable that the operators would 
properly indentify that the indications were the result of a fire 
instead of some other fault. In addition, the operators would be 
delayed in positively identifying the location of the fire based on 
these indirect and ambiguous indicators. Therefore, for some scenarios 
involving fire zones that lack fire detection systems, operators are 
unlikely to identify and respond to a fire event in a manner that 
prompts them to perform certain OMAs prior to a significant degradation 
of the plant's condition. This becomes especially relevant for OMAs 
that are required to be completed within a relatively short period of 
time, e.g., within about 30 minutes, or have limited margins available 
to complete the required actions.
    For OMAs that are required to be completed within a short period of 
time, the NRC staff evaluates if operators can reliably perform the 
OMA. In order to be able to perform OMAs reliably, it is important that 
operators are able to promptly implement any required action based on 
clear indications. Indirect indicators and diagnostic analysis would 
result in delayed action to initiate the appropriate OMAs and would 
impair their reliable completion. For example, loss of control or 
indication for a pump or other affected component could result from the 
power supply circuit breaker opening due to an electrical fault other 
than a fire, and the operator might delay taking actions for a fire 
while investigating other potential and more-likely causes. The NRC 
staff documented a position on procedures and training for such actions 
in Section 4.2.9 of NUREG-1852, ``Demonstrating the Feasibility and 
Reliability of Operator Manual Actions in Response to Fire,'' which 
notes that the procedures for reactive actions should clearly describe 
the indications which prompt initiation of the actions. Therefore, 
where OMAs need to be performed within a short period of time, fire 
zones crediting those OMAs are expected to have more robust defense-in-
depth and clear, direct procedures than fire zones that have a 
significant margin in their OMA performance times.
    In the August 11, 2010 RAI-02.1 and RAI-06.1, and the December 16, 
2010 RAI-01.1, the NRC staff requested that the licensee describe the 
spatial separation between redundant trains of equipment. However, the 
licensee's responses only provided information regarding the separation 
between ignition sources and safe shutdown equipment and no information 
regarding separation between redundant trains of equipment within the 
fire area. For example, in its September 29, 2010 response to RAI-06.1 
the licensee stated that ``The cables serving valves 204A and 204B are 
routed within Containment (Fire Area H) in raceways which are not 
separated by 20 feet at all locations, nor are other separation 
measures as prescribed by III.G.2 (f) provided.'' During a 
clarification call with the licensee, the licensee did not provide any 
dimensional data on train separation. Without dimensional data on train 
separation, the staff has conservatively assumed that there is no

[[Page 7188]]

discernable separation between redundant trains of equipment.
    In addition, the licensee noted that the introduction of 
combustible materials into most areas included in its request was 
limited via administrative procedures such as EN-DC-161, ``Control of 
Combustibles.'' The licensee stated that Fire Area J did not contain 
safety-related systems or components and was not addressed by this 
procedure. The NRC staff notes that the licensee requested OMAs for 
Fire Area J and that alternate shutdown equipment and several cables 
associated with normal safe-shutdown equipment are located in this 
area. The licensee stated that operator rounds are performed each shift 
in Fire Area J that would monitor the presence of combustibles that 
could present an unacceptable fire safety challenge. In addition, the 
licensee stated that procedures OAP-017, ``Plant Surveillance and 
Operator Rounds'' and EN-MA-132, ``Housekeeping,'' include guidance for 
monitoring general area cleanliness including monitoring for 
accumulations of combustibles. The NRC staff notes that the combustible 
material controls procedures for this fire area are not as robust as 
for safety-related areas, and therefore results in a reduction in the 
defense-in-depth for the impacted fire zones.

Specific Area or Zone Discussion

    Each of the fire areas or zones included in this exemption is 
analyzed below with regard to how the concept of defense-in-depth is 
achieved for each area or zone and the role of the OMAs in the overall 
level of safety provided for each area or zone.
3.1 Fire Area C--Auxiliary Boiler Feed Pump Room, Elevation 18'-6'' of 
the Auxiliary Feed Pump Building (Fire Zone 23--Auxiliary Boiler Feed 
Pump (ABFP) Room, Elevation 18'-6'')
3.1.1 Fire Prevention
    Fire Area C consists of a single room (the ABFP Room or the 
Auxiliary Feedwater (AFW) Pump Room) and is designated as Fire Zone 23. 
Note that the pumps which supply water to the steam generators 
following a reactor trip are generically known as AFW pumps, but at IP2 
they are also called Auxiliary Boiler Feed Pumps. The licensee stated 
that the fire loading in this area is low and that fixed combustibles 
consist of fire retardant cable insulation. The licensee stated that 
small quantities of lube oil and Class A combustibles are present but 
those do not pose a credible challenge to components of concern located 
in the zone. The licensee also stated that the ignition sources in the 
area consist of cable runs, junction boxes, motors, pumps, and 
electrical panels.
3.1.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 23 does not have a fire 
suppression system installed but does have an area-wide, ionization 
smoke detection system installed, which would provide early 
notification of a fire and assist in a prompt fire brigade response. 
The licensee also stated that the detection system was designed and 
installed in accordance with National Fire Protection Association 
(NFPA) standard NFPA 72D, 1975 Edition.
3.1.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 23 has a ceiling height of 
approximately 14'-0'' and an approximate floor area of 1,210 square 
feet. This fire zone contains the three AFW pumps (21, 22, and 23) and 
their discharge valves used to supply water to the steam generators for 
reactor coolant system decay heat removal when the normal feedwater 
system is not available, such as following a reactor trip. The licensee 
stated that a radiant energy shield is installed between 21 AFW pump 
and 23 AFW pump and that the power cables for 23 AFW pump are wrapped 
in Hemyc fire barrier material rated for 30 minutes. The licensee 
stated that damage to the control or instrument cables in the overhead 
trays could present an immediate impact on redundant AFW trains. As 
discussed in section 3.0 above, the licensee did not identify any 
separation between credited and redundant trains of equipment.
3.1.4 OMAs Credited for a Fire in Fire Area C (Fire Zone 23)
3.1.4.1 OMA 1--Implement 2-FR-H.1 If Necessary to Establish 
Alternate Secondary Heat Sink
    The licensee stated that for a worst case fire scenario, OMAs to 
restore AFW functionality would be implemented after a period of 1 hour 
following fire initiation. This time is provided to extinguish the fire 
and clear the smoke from the fire area. In the unlikely event that 
control and indication for all three AFW pumps is lost during the 
initial hour of a fire event, the licensee stated that Emergency 
Operating Procedure EOP 2-FR-H.1, ``Response to Loss of Secondary Heat 
Sink,'' can be implemented to provide the reactor coolant heat removal 
function using the normal feedwater system or feed-and-bleed cooling 
with safety injection pumps. Since actions to remove reactor coolant 
system decay heat can be performed from the CCR (no OMAs are required 
in the field), this action is included for completeness only. Since no 
exemption is being requested, this OMA is not part of this exemption. 
In a letter dated September 14, 1988, the licensee had described the 
use of EOP 2-FR-H.1 to the NRC, and by letter dated January 12, 1989, 
the NRC staff concluded that the licensee's clarifications to the fire 
protection program conformed with NRC fire protection guidelines and 
requirements and were acceptable, so the use of EOP 2-FR-H.1 is 
considered to already be part of the licensee's licensing basis.
3.1.4.2 OMA 2--Operate 22 AFW Pump (Turbine-Driven)
    The licensee stated that all three AFW pumps are within this area 
and associated cables are routed in this area. According to the 
licensee, the cables of concern are typically routed in rigid steel 
conduits and located between 8.9 feet and 10.8 feet above the floor. 
The OMAs for this area are only needed if all three AFW pumps are 
affected by the fire. The licensee stated that the diagnostic indicator 
for this scenario would be a loss of control or indication for 22 AFW 
pump from the CCR or indication of decreasing level in all steam 
generators as viewed at recorders LR-417, 427, 437, and 447. In the 
event that this does occur, OMAs 2, 3, and 4 
are available to operate 22 AFW Pump. OMA 2 will open PCV-1139 
to admit steam, operate HCV-1118 at the pump to control speed, and 
operate PCV-1213 as necessary to regulate pump bearing cooling water. 
Since these actions are required to be performed in the zone where the 
fire occurs, a 60-minute waiting period prior to operator reentry into 
the area is described in the submittal. The licensee stated that they 
allotted 60 minutes before performing OMA 2 to allow the fire 
brigade to perform its fire fighting operations and for the area to be 
made tenable prior to entering to perform certain OMAs. In Table RAI-
08.1-1 of its February 10, 2011 submittal, the licensee indicated that 
the OMA initiator (postulated fire-induced failure) is located in Fire 
Zone 23 as is the OMA performance location. The licensee also provided 
a comment in the same table establishing the 60-minute duration of the 
waiting period.
    If OMA 2 becomes necessary, the licensee stated that they 
have assumed a 60-minute period before re-entering the fire area, a 
4.5-minute diagnosis period, which is assumed to transpire during the 
60-minute waiting period,

[[Page 7189]]

and that the required time to perform the action is 22 minutes, which 
results in a total required time of 82 minutes. The licensee is 
crediting the use of EOP 2-FR-H.1 until OMAs 2, 3, 
and 4 can be accomplished. Since there is defense-in-depth 
including full area fire detection and limited combustibles, and EOP 2-
FR-H.1 can be used to perform the reactor coolant system heat removal 
function while OMA 2 is being implemented, the NRC staff finds 
this OMA acceptable.
3.1.4.3 OMA 3--Open or Check Open 22 AFW Pump Steam Supply 
Isolation Valves
    This OMA is one of the three OMAs needed to operate the 22 AFW 
pump, as described in the previous section. OMA 3 would open 
the 22 AFW pump steam supply pressure control valves PCV-1310A and PCV-
1310B in Fire Area K.
    If OMA 3 becomes necessary, the licensee stated that they 
have assumed a 4.5-minute diagnosis period, and that the required time 
to perform the action is 15 minutes, which results in a total required 
time of 19.5 minutes. The licensee is crediting the use of EOP 2-FR-H.1 
until OMAs 2, 3, and 4 can be accomplished. 
Since there is defense-in-depth including full area fire detection and 
limited combustibles, and EOP 2-FR-H.1 can be used to perform the 
reactor coolant system heat removal function while OMA 3 is 
being implemented, the NRC staff finds this OMA acceptable.
3.1.4.4 OMA 4--Operate 22 AFW Pump Flow Control Valves To 
Align AFW Flow to Selected Steam Generators
    This OMA is one of the three OMAs needed to operate the 22 AFW 
pump, as described in the previous sections. OMA 4 would 
operate FCV-405A (discharge to 21 SG) and FCV-405B (discharge to 22 SG) 
in the AFW Pump Room, upon reentry to the room following the initial 
60-minute waiting period.
    If OMA 4 becomes necessary, the licensee stated that they 
have assumed a 60-minute period before re-entering the fire area, a 
4.5-minute diagnosis period, which is assumed to transpire during the 
60-minute waiting period, and that the required time to perform the 
action is 22 minutes, which results in a total required time of 82 
minutes. The licensee is crediting the use of EOP 2-FR-H.1 until OMAs 
2, 3, and 4 can be accomplished. Since there 
is defense-in-depth including full area fire detection and limited 
combustibles, and EOP 2-FR-H.1 can be used to perform the reactor 
coolant system heat removal function while OMA 4 is being 
implemented, the NRC staff finds this OMA acceptable.
3.1.5 Conclusion for Fire Area C (Fire Zone 23)
    The NRC staff had previously issued an exemption from III.G.2 for 
Fire Zone 23 in 1984 (ML003776266). In that exemption, the NRC staff 
found that the low fire load and features such as fire wrap on the 23 
AFW pump cables justified an exemption. By letter dated January 12, 
1989, the NRC staff concluded that the licensee's clarifications to the 
fire protection program, which in part described the use of EOP 2-FR-
H.1, conform with NRC fire protection guidelines and requirements and 
were acceptable. The NRC staff notes that the fire detection in this 
fire zone will clearly alert the operators to take actions for a fire. 
Therefore, the NRC staff concludes that with the defense-in-depth 
including full area fire detection and limited combustibles, OMAs 
2, 3, and 4, along with EOP 2-FR-H.1, are 
acceptable for maintaining the reactor coolant system heat removal 
function and that the III.G.2 exemption for Fire Zone 23 remains valid.
3.2 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
5A--Sampling Room, Elevation 80'-0'')
3.2.1 Fire Prevention
    The licensee stated that the fire loading in this fire zone is 
moderate and that the fixed combustibles are primarily cable 
insulation. The licensee also stated that the ignition sources in the 
fire zone consists of cable runs, junction boxes, and electrical 
panels.
3.2.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 5A does not have fire detection 
or fire suppression systems installed.
3.2.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 5A has a ceiling height of 
approximately 14'-0'' and an approximate floor area of 150 square feet. 
This fire zone contains cables which could affect the position of 
valves LCV-112B and LCV-112C. These valves provide water to the suction 
of the charging pumps. As discussed in Section 3.0 above, the licensee 
could not demonstrate any separation between credited and redundant 
trains of equipment.
3.2.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 5A)
3.2.4.1 OMA 6--Align Charging Pump Suction to Refueling Water 
Storage Tank (RWST)
    The licensee stated that a postulated fire in Fire Area F could 
present the potential for immediate damage to the one charging pump 
(there are three charging pumps) that is normally in service during 
power operations by affecting the source of water to the suction of the 
pump. The licensee stated that the 21 Charging Pump is credited for 
accomplishing the RCS makeup function in the event of fire in Fire Area 
F. In the event that the 21 Charging Pump is in operation during a fire 
in Fire Area F, and fire damage causes valve LCV-112C to spuriously 
close, the 21 Charging Pump could be damaged due to a loss of suction. 
For a fire in Fire Area F, the licensee stated that alignment of the 
charging suction flowpath to the RWST is established by OMAs to close 
valve LCV-112C and open normally closed manual valve 288, which 
provides a bypass path around valve LCV-112B. To open valve 288, the 
licensee stated that operators must reenter Fire Area F following a 
fire.
    If a fire were to occur in Fire Zone 5A and cause LCV-112C to 
spuriously close, the licensee stated that OMA 6 is available 
to restore or maintain the necessary function (RCS makeup) to the 
affected equipment (Charging Pumps) and align charging pump suction to 
the RWST by closing the volume control tank (VCT) outlet valve LCV-112C 
and opening RWST manual bypass valve 288. If OMA 6 becomes 
necessary, the licensee stated that they have assumed a 60-minute 
waiting period before re-entering the fire area, a 14-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period, and that the required time to perform the action is 18 minutes, 
which results in a total required time of 78 minutes, while the time 
available to restore makeup flow to the RCS is 75 minutes. Therefore, 
there is insufficient margin available to perform the OMA for all fire 
zones in Fire Area F.
3.2.5 Conclusion for Fire Area F (Fire Zone 5A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 5A lacks an automatic fire detection or automatic suppression 
system, and any discernable separation between the credited and 
redundant equipment in the area, it is possible that a fire would not 
be detected and extinguished in a reasonable amount of time to ensure 
that at least one train of equipment

[[Page 7190]]

remains free of fire damage or allow reentry to the area to perform 
OMAs. Additionally, OMA 6 cannot be completed in a timely 
manner for any fire in Fire Area F. Thus, OMA 6 does not 
provide assurance that safe shutdown capability will be maintained 
following the postulated fire events. Therefore, the NRC staff finds 
that the defense-in-depth is insufficient to demonstrate reasonable 
assurance that safe shutdown can be achieved for a fire in Fire Zone 5A 
and that an exemption from III.G.2 based on OMA 6 cannot be 
granted for Fire Zone 5A.
3.3 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 6-
22 Charging Pump Room, Elevation 80'-0'')
3.3.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, lube oil, and 
plastic. Transient combustibles consist of trash, paint, lube oil, and 
radiation boundaries. The licensee also stated that the ignition source 
in the area is the 22 charging pump motor.
3.3.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 6 has an automatic fire 
detection system installed but does not have an automatic fire 
suppression system installed. The licensee also stated that the 
detection system was designed and installed in accordance with NFPA 
72D, 1975 Edition.
3.3.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 6 has a ceiling height of 
approximately 15'-6'' and an approximate floor area of 282 square feet. 
As discussed in Section 3.0 above, the licensee could not demonstrate 
any separation between credited and redundant trains of equipment. The 
licensee stated that cable YZ1-JB5 associated with valve LCV-112C and 
cables PL2-M41 and PL2-M42 associated with instrument buses 23 and 23A 
are located in this area and that they are located 12 feet, 6.8 feet, 
and 15.6 feet, respectively, from the primary ignition source in the 
zone, the 22 charging pump motor.
3.3.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 6)
3.3.4.1 OMA 6--Align charging pump suction to RWST
    OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above. 
As stated in Section 3.2.4.1, there is insufficient margin to perform 
OMA 6 for any fire zone in Fire Area F.
3.3.4.2 OMA 7--Transfer Instrument Buses 23 and 23A to 
Alternate Power
    The licensee stated that if indication of instrument buses 23 and 
23A is lost in the CCR, OMA 7 may be necessary to transfer 
both buses to their alternate power supply. If OMA 7 becomes 
necessary, the licensee stated that they have assumed a 5.5-minute 
diagnosis period and that the required time to perform the action is 2 
minutes, while the time available is 30 minutes, which results in 22.5 
minutes of margin.
3.3.5 Conclusion for Fire Area F (Fire Zone 6)
    Since the licensee described postulated fire scenarios and Fire 
Zone 6 lacks an automatic fire suppression system and any discernable 
separation between the credited and redundant equipment in the area, it 
is possible that a fire would not be extinguished in a reasonable 
amount of time to ensure that at least one train of equipment remains 
free of fire damage or allow reentry to the area to perform OMAs. The 
NRC staff finds that the defense-in-depth is insufficient to 
demonstrate reasonable assurance that safe shutdown can be achieved for 
a fire in Fire Zone 6. OMA 6 was found to be unacceptable for 
this fire zone. OMA 7 has insufficient time available 
considering the lack of fire suppression and therefore is unacceptable 
for this fire zone. Therefore, the staff finds that an exemption from 
III.G.2 based on these OMAs cannot be granted for Fire Zone 6.
3.4 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
7A--Corridor, Elevation 80'-0'')
3.4.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and electrical 
cabinets, and that transient combustibles consist of trash, flammable 
liquids, plastic, cellulose, and radiation boundaries. The licensee 
also stated that the ignition sources in the area consist of cable 
insulation, junction boxes, and electrical panels.
3.4.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 7A has an automatic fire 
detection system installed but does not have an automatic fire 
suppression system installed. The licensee also stated that the 
detection system was designed and installed in accordance with NFPA 
72D, 1975 Edition.
3.4.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 7A has a ceiling height of 
approximately 16'-0'' and an approximate floor area of 6,000 square 
feet. The licensee also stated that the power cable from transfer 
switch EDF-9 to 23 component cooling water CCW pump motor is wrapped 
with Hemyc fire barrier material rated for 30 minutes. As discussed in 
Section 3.0 above, the licensee could not demonstrate any separation 
between credited and redundant trains of equipment. The licensee stated 
that cable YZ1-JB5 associated with valve LCV-112C and cables PL2-M41 
and PL2-M42 associated with instrument buses 23 and 23A are located in 
this area.
3.4.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 7A)
3.4.4.1 OMA 6--Align Charging Pump Suction to RWST
    OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above. 
As stated in Section 3.2.4.1, there is insufficient margin to perform 
OMA 6 for any fire zone in Fire Area F.
3.4.4.2 OMA 7--Transfer Instrument Buses 23 and 23A to 
Alternate Power
    The licensee stated that if indication of instrument buses 23 and 
23A is lost in the CCR, OMA 7 may be necessary to transfer 
both buses to their alternate power supply. If OMA 7 becomes 
necessary, the licensee stated that they have assumed a 5.5-minute 
diagnosis period and that the required time to perform the action is 2 
minutes, while the time available is 30 minutes, which results in 22.5 
minutes of margin.
3.4.5 Conclusion for Fire Area F (Fire Zone 7A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 7A lacks an automatic fire suppression system and any discernable 
separation between the credited and redundant equipment in the area, it 
is possible that a fire would not be extinguished in a reasonable 
amount of time to ensure that at least one train of equipment remains 
free of fire damage or allow reentry to the area to perform OMAs. The 
NRC staff finds that the defense-in-depth is insufficient demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 7A. OMA 6 was found to be unacceptable for this fire 
zone. OMA 7 has insufficient time available considering the 
lack of fire suppression and therefore is unacceptable for this fire 
zone. Therefore, the staff finds that

[[Page 7191]]

an exemption from III.G.2 based on these OMAs cannot be granted for 
Fire Zone 7A.
3.5 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
22A--Valve Corridor, Elevation 98'-0'')
3.5.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that there are no fixed or transient combustibles in this zone, except 
for small amounts of cable insulation. The licensee also stated that 
the ignition sources in the area consist of electrical cabinets.
3.5.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 22A does not have an automatic 
fire detection or automatic suppression system installed.
3.5.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 22A has a ceiling height of 
approximately 14'-0'' and an approximate floor area of 115 square feet. 
The licensee stated that if cables for LCV-112C are affected, it may be 
necessary to align an alternate water supply to the charging pump 
suction. The licensee stated that cables associated with valves LCV-
112C and LCV-112B are located in Fire Zone 22A.
3.5.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 22A)
3.5.4.1 OMA 6--Align charging pump suction to RWST
    OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above. 
As stated in Section 3.2.4.1, there is insufficient margin to perform 
OMA 6 for any fire zone in Fire Area F.
3.5.5 Conclusion for Fire Area F (Fire Zone 22A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 22A lacks any automatic fire detection or automatic suppression 
system, it is possible that a fire would not be extinguished in a 
reasonable amount of time to ensure that at least one train of 
equipment remains free of fire damage or allow reentry to the area to 
perform OMAs. Additionally, there is insufficient margin available for 
the OMA credited in this area to provide assurance that safe shutdown 
capability will be maintained following the postulated fire events. 
Therefore, the staff finds that the defense-in-depth is insufficient to 
demonstrate reasonable assurance that safe shutdown can be achieved for 
a fire in Fire Zone 22A and that an exemption from III.G.2 based on OMA 
6 cannot be granted for Fire Zone 22A.
3.6 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
27A--Corridor, Elevation 98'-0'')
3.6.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles in this zone consist of cable 
insulation, vinyl covers, control cabinets and panels, plastic, and 
office supplies and that transient combustibles consist of trash, 
rubber, paint, and radiation boundaries. The licensee also stated that 
the ignition sources in the area consist of cable, junction boxes, dry 
transformers, motor control center (MCC) vertical panels, and 
electrical panels.
3.6.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 27A has an automatic fire 
detection system installed but does not have an automatic fire 
suppression system installed. The licensee also stated that the 
detection system was designed and installed in accordance with NFPA 
72D, 1975 Edition.
3.6.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 27A has a ceiling height of 
approximately 15'-0'' and an approximate floor area of 5,450 square 
feet. The licensee stated that cables associated with valves LCV-112C, 
LCV-112B, HCV-142 and 227 are also located in this fire zone. As 
discussed in Section 3.0 above, the licensee could not demonstrate any 
separation between credited and redundant trains of equipment.
3.6.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 27A)
3.6.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
    The licensee stated that in order to ensure a reliable charging 
makeup path to the reactor coolant system (RCS), air-operated valve 
HCV-142 must remain open or bypass valve 227, which is normally motor-
operated and normally closed, must be opened. The licensee stated that 
air-operated valve HCV-142 is assumed to fail closed as designed in 
response to a loss of instrument air. The licensee stated that if HCV-
142 were to close in response to a loss of instrument air, and cables 
for valve 227 are damaged in a manner that causes normally closed 
motor-operated valve 227 to remain closed and unable to be opened 
remotely from the CCR, OMA 5 would be used to locally open 
bypass valve 227 in Fire Area A to restore or maintain a reliable 
charging pump flow path to the RCS.
    If OMA 5 becomes necessary, the licensee stated that they 
have assumed a 60-minute waiting period before re-entering the fire 
area, a 14-minute diagnosis period, which is assumed to transpire 
during the 60-minute waiting period, and that the required time to 
perform the action is 14 minutes, which provides a total required time 
of 74 minutes while the time available is 75 minutes, which provides 1 
minute of margin. Although there is fire detection in this zone, the 
NRC staff finds that 1 minute of margin is insufficient to ensure the 
OMA can be accomplished reliably. Therefore, the NRC staff finds that 
OMA 5 is unacceptable for a fire which initiates in Fire Zone 
27A or for any fire zone in Fire Area F.
3.6.4.2 OMA 6--Align Charging Pump Suction to RWST
    OMA 6 was evaluated in Sections 3.2.4.1 and 3.2.5 above. 
As stated in Section 3.2.4.1, there is insufficient margin to perform 
OMA 6 for any fire zone in Fire Area F.
3.6.5 Conclusion for Fire Area F (Fire Zone 27A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 27A lacks an automatic fire suppression system and any discernable 
separation between the credited and redundant equipment in the area, it 
is possible that a fire would not be extinguished in a reasonable 
amount of time to ensure that at least one train of equipment remains 
free of fire damage or allow reentry to the area to perform OMAs. Also, 
the NRC staff finds that OMAs 5 and 6 are 
unacceptable for a fire which initiates in Fire Zone 27A or for any 
fire zone in Fire Area F. Therefore, the staff finds that the defense-
in-depth is insufficient to demonstrate reasonable assurance that safe 
shutdown can be achieved for a fire in Fire Zone 27A and that an 
exemption from III.G.2 based on OMA 5 and 6 cannot be 
granted for Fire Zone 27A.
3.7 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
33A--MCC 26AA and MCC 26BB Room, Elevation 98'-0'')
3.7.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles in this zone consist of cable 
insulation and electrical panels and that transient combustibles 
consist of trash, paint, and radiation

[[Page 7192]]

boundaries. The licensee also stated that the ignition sources in the 
area consist of cables, junction boxes, dry transformers, MCC vertical 
panels, and electrical cabinets.
3.7.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 33A does not have an automatic 
fire detection or automatic suppression system installed.
3.7.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 33A has an approximate floor 
area of 1,122 square feet and is open to Fire Zone 27A above. The 
licensee stated that cables associated with charging pump makeup valves 
HCV-142 and 227 are located in this fire zone. As discussed in Section 
3.0 above, the licensee could not demonstrate any separation between 
credited and redundant trains of equipment.
3.7.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 33A)
3.7.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
    OMA 5 was evaluated in Section 3.6.4.1 above. As stated in 
Section 3.6.4.1, 1 minute of margin for OMA 5 is too low to 
credit OMA 5 as being a reliable method of restoring the 
charging pump flow path to the RCS for any fire zone in Fire Area F.
3.7.5 Conclusion for Fire Area F (Fire Zone 33A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 33A lacks an automatic fire detection system or automatic 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be extinguished in a reasonable amount of time to ensure that at 
least one train of equipment remains free of fire damage or allow 
reentry to the area to perform OMAs. There is insufficient margin 
available for OMA 5 for any fire in Fire Area F to provide 
assurance that safe shutdown capability will be maintained following 
the postulated fire events. Therefore, the staff finds that the 
defense-in-depth is insufficient to demonstrate reasonable assurance 
that safe shutdown can be achieved for a fire in Fire Zone 33A and that 
an exemption from III.G.2 based on OMA 5 cannot be granted for 
Fire Zone 33A.
3.8 Fire Area F--Primary Auxiliary Building and Fan House (Fire Zone 
59A--Fan House Elevation 72'-0'', 80'-0'', and 92'-0)
3.8.1 Fire Prevention
    The licensee stated that the fire loading in this area is high and 
that the fixed combustibles in this zone consist of charcoal and cable 
insulation and that transient combustibles consist of trash, paint, and 
radiation boundaries. The licensee also stated that the ignition 
sources in the area consist of electrical cabinets.
3.8.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 59A has a partial automatic fire 
suppression system installed at the charcoal filter housings and a 
partial automatic fire detection system installed that consists of 
Thermistor wire for the charcoal filters and an ionization detector 
outside the charcoal filter enclosure on the 72'-0'' elevation. The 
licensee also stated that the detection system was designed and 
installed in accordance with NFPA 72D, 1967 Edition and the fire 
suppression system was designed and installed in accordance with NFPA 
13, 1972 Edition and NFPA 15, 1969 Edition. The partial fire detection 
system may not be effective at detecting fires in other areas of this 
fire zone, as it is located on the lower level of the fire zone.
3.8.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 59A has an approximate floor 
area of 1,400 square feet and an approximate ceiling height of 29'-0''. 
Fire Zone 59A contains cable ECD3-EXF6/2, which is associated with 
motor-operated valve 227.
3.8.4 OMAs Credited for a Fire in Fire Area F (Fire Zone 59A)
3.8.4.1 OMA 5--Align Charging Pump Makeup Path to RCS
    OMA 5 was evaluated in Section 3.6.4.1 above. As stated in 
Section 3.6.4.1, 1 minute of margin for OMA 5 is too low to 
credit OMA 5 as being a reliable method of restoring the 
charging pump flow path to the RCS for any fire zone in Fire Area F.
3.8.5 Conclusion for Fire Area F (Fire Zone 59A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 59A has a high combustible loading and lacks an automatic fire 
detection system or automatic suppression system throughout the zone, 
except where installed at the charcoal filters, it is possible that a 
fire would not be detected and extinguished in a reasonable amount of 
time to ensure that at least one train of equipment remains free of 
fire damage or allow reentry to the area to perform OMAs. There is 
insufficient margin available for OMA 5 for any fire in Fire 
Area F to provide assurance that safe shutdown capability will be 
maintained following the postulated fire events. Therefore, the staff 
finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 59A and that an exemption from III.G.2 based on OMA 
5 cannot be granted for Fire Zone 59A.
3.9 Fire Area H--Containment Building (Fire Zone 70A--23 and 24 Reactor 
Coolant Pump Area, Elevation 46-0'')
3.9.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation 
and reactor coolant pump (RCP) lube oil and that transient combustibles 
are administratively controlled. The licensee also stated that the 
ignition sources in the area consist of cables, junction boxes, and RCP 
motors.
3.9.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 70A has a partial automatic fire 
detection system installed that consists of ionization detectors 
located over RCPs 23 and 24 but does not have an automatic fire 
suppression system. The licensee also stated that the detection system 
was designed and installed in accordance with NFPA 72D, 1975 Edition.
3.9.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 70A has an approximate floor 
area of 3,320 square feet and an approximate ceiling height of 25'-8''. 
The licensee also stated that there is an oil collection system 
provided for RCPs 23 and 24. The licensee stated that cable Y15-H50 for 
valve 204B and cable Y17-H55 for valve 204A are located in this zone. 
Valve 204A is an air-operated valve which allows charging pump flow to 
an RCS hot leg. Valve 204B is an air-operated valve which allows 
charging pump flow to an RCS cold leg. The licensee stated that cables 
and components associated with redundant trains of normal 
instrumentation required to support normal safe

[[Page 7193]]

shutdown operations are located in this zone. The normal safe shutdown 
instrumentation potentially affected by fire includes:
     SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
     Pressurizer level: LT-459, LT-460, LT-461, LT-462
     Source-range neutron monitoring: N-31, N-32
     RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
3.9.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 70A)
3.9.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    It is possible that a fire in this zone could result in a loss of a 
reliable charging makeup path to the RCS due to air-operated charging 
system valves 204A and 204B spuriously closing. The licensee stated 
that normal reactor coolant makeup to the RCS may be established via 
hot leg injection through valve 204A or cold leg injection through 
valve 204B and that in order to accomplish this, normal reactor coolant 
makeup air-operated charging system valves 204A and 204B would need to 
be failed open by de-energizing 125VDC control power in the CCR or by 
closing the air supply isolation valve IA-501, which is outside the 
containment building, to isolate instrument air.
    Procedure 2-ONOP-FP-001 includes preemptive actions to establish 
the charging makeup path by failing open charging injection valves 204A 
and 204B. This is accomplished by removing DC control power to the 
valves by pulling the control power fuses in the CCR or tripping 
breakers 5 and 15 on 125 VDC DP 21 and 22, respectively. Procedure 2-
AOP-SSD-1 includes actions to close the air supply isolation valve IA-
501, and the loss of air pressure will cause valves 204A and 204B to 
fail open.
    If a fire were to occur and causes valves 204A and 204B to remain 
closed, the licensee stated that OMA 8 is available to align 
the charging pump makeup path to the RCS. If OMA 8 becomes 
necessary, the licensee stated that they have assumed a 14-minute 
diagnosis period and that the required time to perform the action is 14 
minutes, which results in a total required time of 28 minutes while the 
time available is 75 minutes, which provides 47 minutes of margin.
3.9.4.2 OMAs 9 and 10--Activate or Enable Alternate 
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe 
Shutdown System Source-Range Channel and Loop 21 and 22 hot and cold 
leg Temperature Channels
    In the event that a fire in Fire Area H disables redundant trains 
of normal safe shutdown instrumentation identified in Section 3.9.3, 
the licensee may make use of OMAs performed in a different fire area to 
place in service Alternate Safe-Shutdown System instruments which have 
been separated from the normal shutdown instruments in accordance with 
III.G.2(f). The licensee also stated that in locations where normal and 
alternate shutdown instrument cables are separated by less than 20 
feet, the cables of the alternate shutdown instruments are protected by 
a radiant energy shield as required to meet III.G.2(f). The Alternate 
Safe Shutdown System instrument channels include:
     RCP Loop 21 and 22 hot and cold leg temperature (TE-5139, 
TE-5140, TE-5141, TE-5142),
     SG 21 and 22 level (LT-5001, LT-5002),
     Pressurizer level (LT-3101), pressurizer pressure (PT-
3105), and
     Source range neutron monitoring (NE-5143)
    The licensee stated that cables associated with Loop 21 and 22 hot 
and cold leg temperature channels TE-5139, 5140, 5141, 5142, and 
source-range channel NE-5143 are routed into containment through 
penetration H20, and are protected with a radiant energy shield 
throughout the containment annulus area, where they are in proximity to 
cable trays or conduits containing the corresponding normal RCS loop 
temperature channels. The licensee also stated that there are no cables 
associated with the balance of the alternate SSD instruments (LT-5001, 
LT-5002, PT-3105, and LT- 3101), since these channels utilize 
pneumatically-operated transducers. The licensee stated that the 
Alternate Safe Shutdown System pneumatic instrumentation can be 
expected to remain operable despite fire-induced failure of the 
redundant electrically-operated instrumentation, since the Alternate 
Safe Shutdown System instruments do not utilize any electrical 
components or cables.
    In addition, the licensee stated that all four RCPs are equipped 
with RCP lube oil collection systems which capture any leakage from 
credible leak sites and transport it to collection tanks located 
outside the bioshield wall in Fire Zone 77A.
    In the event that redundant trains of normal shutdown 
instrumentation are damaged by a fire, OMAs 9 and 10 
are available to activate the following Alternate Safe Shutdown System 
instruments:
     Pneumatic instruments
    [cir] SG level (LT-5001, LT-5002),
    [cir] Pressurizer pressure (PT-3105), and
    [cir] Pressurizer level (LT-3101)
     Source-range channel (NE-5143), and
     Loop 21 and 22 hot leg (Th) and cold leg (Tc) temperature 
channels (TE-5139, TE-5140, TE-5141, TE-5142)
    Procedure 2-AOP-SSD-1 includes actions to place these Alternate 
Safe Shutdown System instruments in service. If OMAs 9 and 
10 become necessary, the licensee stated that they have 
assumed less than 1 minute for diagnosis, with the normal instruments 
assumed to be failed at the start of the event, and that the required 
time to perform the action is 13 minutes for the pneumatic instruments. 
The shortest timeline is to monitor level in the SGs, which could 
approach boil-dry conditions within 34 minutes. This results in 21 
minutes of margin for the pneumatic instruments. The five electronic 
instruments are then energized by the same operator who made the 
pneumatic instruments operable, so it takes 24 minutes to put the 
electronic instruments in service. However, the electronic instrument 
readings are not needed until later in the scenario. This results in a 
total required time of 13 minutes while the time available is 34 
minutes, which provides 21 minutes of margin.
3.9.5 Conclusion for Fire Area H (Fire Zone 70A)
    Given the low combustible fuel loading, the oil collection system 
for the RCPs, automatic smoke detection system, large volume of the 
space, and preemptive nature of the OMAs, it is unlikely that a fire 
would occur and go undetected and not be extinguished in a reasonable 
amount of time to ensure that at least one train of equipment necessary 
for safe shutdown remains free of fire damage. In the unlikely event 
that a fire does occur and causes damage that necessitates OMAs 
8, 9, and 10, the actions are clear and 
proceduralized with 47 minutes of margin for OMA 8 and 21 
minutes of margin for OMAs 9 and 10, available to 
provide assurance that safe shutdown capability will be maintained 
following the postulated fire events. Therefore, the NRC staff finds 
that there is adequate defense-in-depth provided for Fire Zone 70A and 
that OMAs 8, 9, and 10 are acceptable for 
the purpose of providing the level of

[[Page 7194]]

protection intended by the regulation, and that an exemption from 
III.G.2 based on these OMAs is granted for Fire Zone 70A.
3.10 Fire Area H--Containment Building (Fire Zone 71A--21 and 22 
Reactor Coolant Pump Area, Elevation 46'-0'')
3.10.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation, 
RCP lube oil, and other miscellaneous combustibles and that transient 
combustibles are administratively controlled. The licensee also stated 
that the ignition sources in the area consist of cables, junction 
boxes, RCP motors, and pumps.
3.10.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 71A has a partial automatic fire 
detection system installed that consists of ionization detectors 
located over RCPs 21 and 22 but does not have an automatic fire 
suppression system. The licensee also stated that the detection system 
was designed and installed in accordance with NFPA 72D, 1975 Edition.
3.10.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 71A has an approximate floor 
area of 3,320 square feet and an approximate ceiling height of 25'8''. 
The licensee also stated that there is an oil collection system 
provided for RCPs 21 and 22. The licensee stated that cable Y15-H50 for 
valve 204B and cable Y17-H55 for valve 204A are located in this zone. 
Valve 204A is an air-operated valve which allows charging pump flow to 
an RCS hot leg. Valve 204B is an air-operated valve which allows 
charging pump flow to an RCS cold leg. As discussed in Section 3.0 
above, the licensee did not demonstrate any separation between credited 
and redundant trains of equipment.
3.10.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 71A)
3.10.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As discussed in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75 minutes, 
which provides 47 minutes of margin.
3.10.5 Conclusion for Fire Area H (Fire Zone 71A)
    Given the low combustible fuel loading, the oil collection system 
for the RCPs, automatic smoke detection system, large volume of the 
space, and preemptive nature of OMA 8, it is unlikely that a 
fire would occur and go undetected and not be extinguished in a 
reasonable amount of time to ensure that at least one train of 
equipment necessary for safe shutdown remains free of fire damage. In 
the unlikely event that a fire does occur and causes damage that 
necessitates OMA 8, the actions are clear and proceduralized 
with 47 minutes of margin available to provide assurance that safe 
shutdown capability will be maintained following the postulated fire 
events. Therefore, the NRC staff finds that there is adequate defense-
in-depth provided for Fire Zone 71A and that OMA 8 is 
acceptable for the purpose of providing the level of protection 
intended by the regulation, and that an exemption from III.G.2 based on 
OMA 8 is granted for Fire Zone 71A.
3.11 Fire Area H--Containment Building (Fire Zone 72A--Outer Annulus, 
Elevation 46'0'')
3.11.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation 
and that transient combustibles are administratively controlled. The 
licensee also stated that the ignition sources in the area consist of 
cables.
3.11.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 72A does not have an automatic 
fire detection or automatic suppression system installed.
3.11.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 72A has an approximate floor 
area of 1,100 square feet and an approximate ceiling height of 22'0''. 
The licensee stated that cables for valve 204B and valve 204A are 
located in this zone. Valve 204A is an air-operated valve which allows 
charging pump flow to an RCS hot leg. Valve 204B is an air-operated 
valve which allows charging pump flow to an RCS cold leg. As discussed 
in Section 3.0 above, the licensee did not demonstrate any separation 
between credited and redundant trains of equipment.
3.11.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 72A)
3.11.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75 minutes, 
which provides 47 minutes of margin.
3.11.5 Conclusion for Fire Area H (Fire Zone 72A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 72A lacks an automatic fire detection system or automatic 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is credible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 47 minutes of margin 
available for OMA 8, Fire Zone 72A still lacks adequate 
defense-in-depth. Therefore, the staff finds that Fire Zone 72A's 
defense-in-depth is insufficient to demonstrate reasonable assurance 
that safe shutdown can be achieved. As such, OMA 8 is 
unacceptable for the purpose of providing the level of protection 
intended by the regulation and an exemption from III.G.2 based on OMA 
8 cannot be granted for Fire Zone 72A.
3.12 Fire Area H--Containment Building (Fire Zone 75A--Outer Annulus, 
Elevation 46'-0'')
3.12.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles in this zone consist of cable 
insulation and that transient combustibles are administratively 
controlled. The licensee also stated that the ignition sources in the 
area consist of cables and junction boxes.
3.12.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 75A does not have an automatic 
fire

[[Page 7195]]

detection or automatic suppression system installed.
3.12.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 75A has an approximate floor 
area of 1,100 square feet and an approximate ceiling height of 22'-0''. 
The licensee also stated that the Alternate Safe Shutdown System 
instrumentation cabling is protected with a radiant energy shield. The 
licensee stated that cables and components associated with redundant 
trains of normal instrumentation required to support normal safe 
shutdown operations are located in this zone. The normal safe shutdown 
instrumentation potentially affected by fire in Fire Area H includes:
     SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
     Pressurizer level: LT-459, LT-460, LT-461, LT-462
     Source-range neutron monitoring: N-31, N-32
     RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
    The licensee stated that cable Y15-H50 for valve 204B and cable 
Y17-H55 for valve 204A are located in this zone. As discussed in 
Section 3.0 above, the licensee did not demonstrate any separation 
between credited and redundant trains of equipment.
3.12.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 75A)
3.12.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75 minutes, 
which provides 47 minutes of margin.
3.12.4.2 OMAs 9 and 10--Activate or Enable Alternate 
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe 
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold 
Leg Temperature Channels
    As discussed in Section 3.9.4.2 above, in the event that a fire in 
Fire Area H disables redundant trains of normal safe shutdown 
instrumentation identified in Section 3.9.3, the licensee may make use 
of OMAs performed in a different fire area to place in service 
Alternate Safe Shutdown System instruments which have been separated 
from the normal shutdown instruments in accordance with III.G.2(f). The 
licensee also stated that in locations where normal and alternate 
shutdown instrument cables are separated by less than 20 feet, the 
cables of the alternate shutdown instruments are protected by a radiant 
energy shield as required to meet III.G.2(f).
    If OMAs 9 and 10 become necessary, the licensee 
stated that they have assumed less than 1 minute for diagnosis, with 
the normal instruments assumed to be failed at the start of the event, 
and that the required time to perform the action is 13 minutes for the 
pneumatic instruments. The shortest timeline is to monitor level in the 
SGs, which could approach boil-dry conditions within 34 minutes. This 
results in 21 minutes of margin for the pneumatic instruments. The five 
electronic instruments are then energized by the same operator who made 
the pneumatic instruments operable, so it takes 24 minutes to put the 
electronic instruments in service. However, the electronic instrument 
readings are not needed until later in the scenario. This results in a 
total required time of 13 minutes while the time available is 34 
minutes, which provides 21 minutes of margin.
3.12.5 Conclusion for Fire Area H (Fire Zone 75A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 75A has a moderate combustible fuel loading, lacks an automatic 
fire detection system or automatic suppression system, and any 
discernable separation between the credited and redundant equipment in 
the area, it is credible that a fire would not be detected and 
extinguished in a reasonable amount of time to ensure that at least one 
train of equipment remains free of fire damage following a fire event. 
Although there is 47 minutes of margin available for OMA 8 and 
21 minutes of margin available for OMAs 9 and 10, 
Fire Zone 75A still lacks adequate defense-in-depth. Therefore, the 
staff finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 75A and that OMAs 8, 9, and 10 are 
unacceptable for the purpose of providing the level of protection 
intended by the regulation and that an exemption from III.G.2 based on 
these OMAs cannot be granted for Fire Zone 75A.
3.13 Fire Area H--Containment Building (Fire Zone 77A--Outer Annulus)
3.13.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation 
and that transient combustibles are administratively controlled. The 
licensee also stated that the ignition sources in the area consist of 
cables and junction boxes.
3.13.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 77A does not have an automatic 
fire detection or automatic suppression system installed.
3.13.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 77A has an approximate floor 
area of 950 square feet and an approximate ceiling height of 22'-0''. 
The licensee stated that cables and components associated with 
redundant trains of normal instrumentation required to support normal 
safe shutdown operations are located in this zone. The normal safe 
shutdown instrumentation potentially affected by fire in Fire Area H 
includes:
     SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
     Pressurizer level: LT-459, LT-460, LT-461, LT-462
     Source-range neutron monitoring: N-31, N-32
     RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443
    The licensee stated that cable Y15-H50 for valve 204B and cable 
Y17-H55 for valve 204A are located in this zone. As discussed in 
Section 3.0 above, the licensee did not demonstrate any separation 
between credited and redundant trains of equipment.
3.13.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 77A)
3.13.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75

[[Page 7196]]

minutes, which provides 47 minutes of margin.
3.13.4.2 OMAs 9 and 10--Activate or Enable Alternate 
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe 
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold 
Leg Temperature Channels
    As discussed in Section 3.9.4.2 above, in the event that a fire in 
Fire Area H disables redundant trains of normal safe shutdown 
instrumentation identified in Section 3.9.3, the licensee may make use 
of OMAs performed in a different fire area to place in service 
Alternate Safe-Shutdown System instruments which have been separated 
from the normal shutdown instruments in accordance with III.G.2(f). The 
licensee also stated that in locations where normal and alternate 
shutdown instrument cables are separated by less than 20 feet, the 
cables of the alternate shutdown instruments are protected by a radiant 
energy shield as required to meet III.G.2(f).
    If OMAs 9 and 10 become necessary, the licensee 
stated that they have assumed less than 1 minute for diagnosis, with 
the normal instruments assumed to be failed at the start of the event, 
and that the required time to perform the action is 13 minutes for the 
pneumatic instruments. The shortest timeline is to monitor level in the 
SGs, which could approach boil-dry conditions within 34 minutes. This 
results in 21 minutes of margin for the pneumatic instruments. The five 
electronic instruments are then energized by the same operator who made 
the pneumatic instruments operable, so it takes 24 minutes to put the 
electronic instruments in service. However, the electronic instrument 
readings are not needed until later in the scenario. This results in a 
total required time of 13 minutes while the time available is 34 
minutes, which provides 21 minutes of margin.
3.13.5 Conclusion for Fire Area H (Fire Zone 77A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 77A lacks an automatic fire detection or automatic suppression 
system, and any discernable separation between the credited and 
redundant equipment in the area, it is credible that a fire would not 
be detected and extinguished in a reasonable amount of time to ensure 
that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 47 minutes of margin 
available for OMA 8 and 21 minutes of margin available for 
OMAs 9 and 10, Fire Zone 77A still lacks adequate 
defense-in-depth. Therefore, the staff finds that the defense-in-depth 
is insufficient to demonstrate reasonable assurance that safe shutdown 
can be achieved for a fire in Fire Zone 77A and that OMAs 8, 
9, and 10 are unacceptable for the purpose of 
providing the level of protection intended by the regulation and that 
an exemption from III.G.2 based on these OMAs cannot be granted for 
Fire Zone 77A.
3.14 Fire Area H--Containment Building (Fire Zone 84A-22 Containment 
Fan Cooler Unit Area, Elevation 68'-0'')
3.14.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation 
and that transient combustibles are administratively controlled. The 
licensee also stated that the ignition sources in the area consist of 
cables.
3.14.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 84A does not have an automatic 
fire detection or automatic suppression system installed.
3.14.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 84A has an approximate floor 
area of 910 square feet and an approximate ceiling height of 27'-0''. 
The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55 
for valve 204A are located in this zone. As discussed in Section 3.0 
above, the licensee could not demonstrate any separation between 
credited and redundant trains of equipment.
3.14.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 84A)
3.14.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75 minutes, 
which provides 47 minutes of margin.
3.14.5 Conclusion for Fire Area H (Fire Zone 84A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 84A lacks an automatic fire detection or automatic suppression 
system, and any discernable separation between the credited and 
redundant equipment in the area, it is credible that a fire would not 
be detected and extinguished in a reasonable amount of time to ensure 
that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 47 minutes of margin 
available for OMA 8, Fire Zone 84A still lacks adequate 
defense-in-depth. Therefore, the staff finds that the defense-in-depth 
is insufficient to demonstrate reasonable assurance that safe shutdown 
can be achieved for a fire in Fire Zone 84A and that OMA 8 is 
unacceptable for the purpose of providing the level of protection 
intended by the regulation and that an exemption from III.G.2 based on 
this OMA cannot be granted for Fire Zone 84A.
3.15 Fire Area H--Containment Building (Fire Zone 85A--Incore Detector 
Drive Area, Elevation 68'-0'')
3.15.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of cable insulation 
and that transient combustibles are administratively controlled.
3.15.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 85A does not have an automatic 
fire detection or automatic suppression system installed.
3.15.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 85A has an approximate floor 
area of 560 square feet and an approximate ceiling height of 27'-0''. 
The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55 
for valve 204A are located in this zone. As discussed in Section 3.0 
above, the licensee could not demonstrate any separation between 
credited and redundant trains of equipment.
3.15.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 85A)
3.15.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available

[[Page 7197]]

to align the charging pump makeup path to the RCS. If OMA 8 
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the 
action is 14 minutes, which results in a total required time of 28 
minutes while the time available is 75 minutes, which provides 47 
minutes of margin.
3.15.5 Conclusion for Fire Area H (Fire Zone 85A)
    Since the licensee stated that a fire in this zone could result in 
a loss of a reliable charging makeup path to the RCS and Fire Zone 85A 
lacks an automatic fire detection or suppression system, and any 
discernable separation between the credited and redundant equipment in 
the area, it is credible that a fire would not be detected and 
extinguished in a reasonable amount of time to ensure that at least one 
train of equipment remains free of fire damage following a fire event. 
Although there is 47 minutes of margin available for OMA 8, 
Fire Zone 85A still lacks adequate defense-in-depth. Therefore, the 
staff finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 85A and that OMA 8 is unacceptable for the purpose 
of providing the level of protection intended by the regulation and 
that an exemption from III.G.2 based on this OMA cannot be granted for 
Fire Zone 85A.
3.16 Fire Area H--Containment Building (Fire Zone 87A--Outer Annulus, 
Elevation 46'-0'')
3.16.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles in this zone consist of MCCs and instrument 
racks and that transient combustibles are administratively controlled. 
The licensee also stated that the ignition sources in the area consist 
of MCCs.
3.16.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 87A does not have an automatic 
fire detection or automatic suppression system installed.
3.16.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 87A has an approximate floor 
area of 434 square feet and an approximate ceiling height of 22'-0'', 
which is partially open to the containment dome at the 95'-0'' 
elevation. The licensee stated that cables and components associated 
with redundant trains of normal instrumentation required to support 
normal safe shutdown operations are located in this zone. The normal 
safe shutdown instrumentation potentially affected by fire in Fire Area 
H includes:
     SG wide range level: LT-417D, LT-427D, LT-437D, LT-447D
     Pressurizer level: LT-459, LT-460, LT-461, LT-462
     Source-range neutron monitoring: N-31, N-32
     RCS loop hot and cold leg temperatures: TE-411 A/1, TE-
413, TE-422A/1, TE-423, TE-431A/1, TE-433, TE-440A/1, TE-443

The licensee stated that cable Y15-H50 for valve 204B and cable Y17-H55 
for valve 204A are located in this zone. As discussed in Section 3.0 
above, the licensee did not demonstrate any separation between credited 
and redundant trains of equipment.
3.16.4 OMAs Credited for a Fire in Fire Area H (Fire Zone 87A)
3.16.4.1 OMA 8--Align Charging Pump Makeup Path to RCS
    As stated in Section 3.9.4.1 above, if a fire were to occur and 
causes valves 204A and 204B to remain closed, the licensee stated that 
OMA 8 is available to align the charging pump makeup path to 
the RCS. If OMA 8 becomes necessary, the licensee stated that 
they have assumed a 14-minute diagnosis period and that the required 
time to perform the action is 14 minutes, which results in a total 
required time of 28 minutes while the time available is 75 minutes, 
which provides 47 minutes of margin.
3.16.4.2 OMAs 9 and 10--Activate or Enable Alternate 
Safe Shutdown System Pneumatic Instruments and Enable Alternate Safe 
Shutdown System Source-Range Channel and Loop 21 and 22 Hot and Cold 
Leg Temperature Channels
    As discussed in Section 3.9.4.2 above, in the event that a fire in 
Fire Area H disables redundant trains of normal safe shutdown 
instrumentation identified in Section 3.9.3, the licensee may make use 
of OMAs performed in a different fire area to place in service 
Alternate Safe Shutdown System instruments which have been separated 
from the normal shutdown instruments in accordance with III.G.2(f). The 
licensee also stated that in locations where normal and alternate 
shutdown instrument cables are separated by less than 20 feet, the 
cables of the alternate shutdown instruments are protected by a radiant 
energy shield as required to meet III.G.2(f).
    If OMAs 9 and 10 become necessary, the licensee 
stated that they have assumed less than 1 minute for diagnosis, with 
the normal instruments assumed to be failed at the start of the event, 
and that the required time to perform the action is 13 minutes for the 
pneumatic instruments. The shortest timeline is to monitor level in the 
SGs, which could approach boil-dry conditions within 34 minutes. This 
results in 21 minutes of margin for the pneumatic instruments. The five 
electronic instruments are then energized by the same operator who made 
the pneumatic instruments operable, so it takes 24 minutes to put the 
electronic instruments in service. However, the electronic instrument 
readings are not needed until later in the scenario. This results in a 
total required time of 13 minutes while the time available is 34 
minutes, which provides 21 minutes of margin.
3.16.5 Conclusion for Fire Area H (Fire Zone 87A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 87A lacks an automatic fire detection or suppression system, and 
any discernable separation between the credited and redundant equipment 
in the area, it is credible that a fire would not be detected and 
extinguished in a reasonable amount of time to ensure that at least one 
train of equipment remains free of fire damage following a fire event. 
Although there is 47 minutes of margin available for OMA 8 and 
21 minutes of margin available for OMAs 9 and 10, 
Fire Zone 87A still lacks adequate defense-in-depth. Therefore, the 
staff finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 87A and that OMAs 8, 9, and 10 are 
unacceptable for the purpose of providing the level of protection 
intended by the regulation and that an exemption from III.G.2 based on 
these OMAs cannot be granted for Fire Zone 87A.
3.17 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 17--Turbine Oil Reservoir Area, Elevation 15'-0'' Unit 2 
Turbine Building)
3.17.1 Fire Prevention
    The licensee stated that the fire loading in this area is high and 
that the

[[Page 7198]]

fixed combustibles in this zone consist of lube oil, fuel oil, and 
welding leads and that transient combustibles consist of trash, 
cardboard, lube oil, fiberglass, rubber, wood, and plastic. The 
licensee also stated that the ignition sources in the area consist of 
electrical cabinets. The licensee further stated that since Fire Area J 
does not contain safety-related structures, systems or components, it 
is not subject to the explicit transient combustible controls of 
procedure EN-DC-161. However, operator rounds performed each shift 
provide for the monitoring of combustibles that could challenge fire 
safety. In addition, the licensee stated that procedures OAP-017, 
``Plant Surveillance and Operator Rounds'' and EN-MA-132, 
``Housekeeping'' include guidance for monitoring general area 
cleanliness as well as monitoring for accumulations of combustibles.
3.17.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 17 has an automatic thermal fire 
detection system installed throughout the zone and an automatic aqueous 
foaming foam spray system installed at the turbine lube oil reservoir. 
The licensee also stated that the detection system was designed and 
installed in accordance with NFPA 72D, 1967 Edition and the fire 
suppression system was designed and installed in accordance with NFPA 
16, 1968 Edition.
3.17.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 17 has an approximate floor area 
of 968 square feet and an approximate ceiling height of 37'-0''. The 
licensee stated that cable JC2-YA9, which is associated with Buses 5A 
and 6A, is routed through Fire Zones 17, 47A, and 50A and that ignition 
sources in the zone located less than 20 feet horizontally from cable 
JC2-YA9 consists of electrical cabinets, motors, and MCCs. According to 
the licensee, the electrical cabinets are separated from the cable by 
approximately 3.8 feet horizontally and 1.9 feet vertically or greater 
and six motors are located above the cable routing separated from the 
cable by approximately 2.1 feet horizontally or greater. The licensee 
also stated that the turbine lube oil reservoir is located in Fire Zone 
17. As discussed in Section 3.0 above, the licensee could not 
demonstrate any separation between credited and redundant trains of 
equipment.
3.17.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 17)
3.17.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and 
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
    The licensee stated that offsite power is the preferred lineup for 
supplying the 480V loads on Buses 2A, 3A, 5A, and 6A. In the event that 
offsite power is not available due to fire, the licensee stated that 
the Emergency Diesel Generators (EDGs) are credited to supply 480V 
loads on Buses 2A, 3A, 5A, and 6A. The licensee also stated that a fire 
in Fire Zone 17 which damages certain cables associated with 480V Buses 
5A and/or 6A could prevent loading of Buses 5 and 6 from the EDGs, and 
thereby, result in a loss of 480V power from the affected bus(es). 
Since a fire in Fire Zone 17 may impact the availability of offsite 
power, the licensee stated that they assume offsite power is 
unavailable at the start of the fire event.
    In the event that a fire occurs and damages the cables identified 
above, the licensee stated that OMA 11 is available to restore 
or maintain power by tripping breakers 52/5A and 52-SAC on Bus 5A and 
Breakers 52/6A and 52/TAO at Bus 6A in the 480V Switchgear Room (Fire 
Area A) and removing their control power fuses. The licensee stated 
that loss of power to the affected buses is detected by loss of 
indication in the CCR. Loss of power to Bus 5A or Bus 6A causes 
operators to immediately enter procedure 2-AOP-480V-1. The procedure 
directs operators to locally inspect the switchgear, at which time any 
remaining untripped breakers (i.e., 52/5A, 52-SAC, 52/6A, 52/TAO) would 
be noted and locally tripped as necessary. If OMA 11 becomes 
necessary, the licensee stated that they have assumed that a loss of 
offsite power occurs at the beginning of the fire event and that the 
required time to perform the action is 10 minutes while the time 
available is 60 minutes, which provides 50 minutes of margin. The NRC 
staff finds that OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.17.5 Conclusion for a Fire in Fire Area J (Fire Zone 17)
    Given the fire detection system, automatic fire suppression system, 
and large volume of the space, it is unlikely that a fire would occur 
and go undetected and not be extinguished in a reasonable amount of 
time to ensure that at least one train of equipment necessary for safe 
shutdown remains free of fire damage. In the unlikely event that a fire 
does occur and causes damage that necessitates OMA 11, the 
action is clear and proceduralized with 50 minutes of margin available 
to provide assurance that safe shutdown capability will be maintained 
following the postulated fire events. Therefore, the NRC staff finds 
that there is adequate defense-in-depth provided for Fire Zone 17 and 
that OMA 11 is acceptable for the purpose of providing the 
level of protection intended by the regulation, and that an exemption 
from III.G.2 based on OMA 11 is granted for Fire Zone 17.
3.18 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 19--Station Air Compressor Area, Elevation 15'-0'' Unit 2 
Turbine Building)
3.18.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the primary fixed combustible in this zone is lube oil, which is 
contained in the turbine lube oil piping system, and that transient 
combustibles consist of trash, cleaning rags, lube oil, and paint. The 
licensee also stated that the ignition sources in the area consist of a 
motor, a compressor, and an electrical cabinet. The licensee further 
stated that since Fire Area J does not contain safety-related 
structures, systems or components, it is not subject to the explicit 
transient combustible controls of procedure EN-DC-161. However, 
operator rounds performed each shift provide for the monitoring of 
combustibles that could challenge fire safety. In addition, the 
licensee stated that procedures OAP-017, ``Plant Surveillance and 
Operator Rounds'' and EN-MA-132, ``Housekeeping'' include guidance for 
monitoring general area cleanliness as well as monitoring for 
accumulations of combustibles.
3.18.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 19 does not have a fire 
detection or automatic fire suppression system installed.
3.18.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 19 has an approximate floor area 
of 798 square feet and an approximate ceiling height of 21'-0''. The 
licensee stated that a fire in Fire Area J which damages certain cables 
associated with 480V Buses 5A and/or 6A could prevent loading of Buses 
5A and 6A from the EDGs, and thereby, result in a loss of

[[Page 7199]]

480VAC power from the affected bus(es). According to the licensee, 
cables associated with Buses 5A and 6A are located in this fire zone. 
The licensee stated that cable AG5-XA5, which is associated with Bus 
5A, is located in Fire Zone 19. The licensee also stated that the 
ignition sources in the zone located less than 20 feet horizontally 
from cable AG5-XA5 consist of seven electrical cabinets, a 150kVA dry 
transformer, three motors, and an MCC. According to the licensee, three 
electrical cabinets are located under the cable separated by 
approximately 3 feet vertically or greater, the remaining four 
electrical cabinets are separated from the cable by approximately 2 
feet horizontally or greater, the 150 kVA dry transformer is separated 
from the cable by approximately 1.6 feet horizontally and 6.7 feet 
vertically, the motors are separated from the cable by approximately 
4.6 feet horizontally or greater, and the MCC is separated from the 
cable by approximately 7.5 feet horizontally.
    The licensee stated that cables PC9-XA5/1 and PC9-XA5/2, which are 
associated with Bus 5A, are routed between two junction boxes in Fire 
Zone 19 for approximately 2 feet. The licensee also stated that the 
ignition sources in the zones located less than 20 feet horizontally 
from the cable consist of three motors, which are all separated from 
the cables by approximately 4.6 feet horizontally or greater. The 
licensee also stated that cable XA5-WU9, associated with Bus 5A, is 
routed in Fire Zone 19 from east to west terminating at the Station Air 
Compressor. The licensee stated that the ignition sources in the zone 
located less than 20 feet horizontally from the cable consist of two 
motors, which are separated from the cable by approximately 4.6 feet 
horizontally or greater. As discussed in Section 3.0 above, the 
licensee could not demonstrate any separation between credited and 
redundant trains of equipment.
3.18.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 19)
3.18.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on bus 5A and 
52/6A and 52/TAO at bus 6A and Remove Control Power Fuses.
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.18.5 Conclusion for Fire Area J (Fire Zone 19)
    Since the licensee described postulated fire scenarios and Fire 
Zone 19 lacks an automatic fire detection or automatic fire suppression 
system, and any discernable separation between the credited and 
redundant equipment in the area, it is possible that a fire would not 
be detected and extinguished in a reasonable amount of time to ensure 
that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11, Fire Zone 19 still lacks adequate 
defense-in-depth. Therefore, the staff finds that the defense-in-depth 
is insufficient to demonstrate reasonable assurance that safe shutdown 
can be achieved for a fire in Fire Zone 19 and that OMA 11 is 
unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on this OMA cannot be granted for Fire 
Zone 19.
3.19 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 25--23 Battery Room, Elevation 33'-0'' of the Unit 1 
Superheater Building)
3.19.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the primary fixed combustibles in this zone are batteries and 
cable insulation and that transient combustibles are administratively 
controlled. The licensee also stated that the ignition sources in the 
area consist of batteries and electrical cabinets. The licensee further 
stated that since Fire Area J does not contain safety-related 
structures, systems or components, it is not subject to the explicit 
transient combustible controls of procedure EN-DC-161. However, 
operator rounds performed each shift provide for the monitoring of 
combustibles that could present an unacceptable fire safety challenge. 
In addition, the licensee stated that procedures OAP-017, ``Plant 
Surveillance and Operator Rounds'' and EN-MA-132, ``Housekeeping'' 
include guidance for monitoring general area cleanliness as well as 
monitoring for accumulations of combustibles.
3.19.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 25 does not have a fire 
detection or automatic fire suppression system installed.
3.19.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 25 has an approximate floor area 
of 92 square feet and an approximate ceiling height of 10'-0''. The 
licensee stated that cables EDB8-EPB3, EGA9-EDB8/4, and EGA9-EDB8/5 are 
routed through Fire Zone 25 in rigid steel conduit and that since 
cables EGA9-EDB8/4 and EGA9-EDB8/5 originate inside the battery room at 
the batteries, there is no separation between the cables and the 
batteries. The licensee also stated that ignition sources in the zone 
located less than 20 feet horizontally from cable EDB8-EPB3 consist of 
an MCC, a 45kVA dry transformer, and two electrical cabinets. According 
to the licensee, the MCC is separated from the cable by approximately 
18.5 feet horizontally, the transformer is separated from the cable by 
approximately 13.6 feet horizontally, one electrical cabinet is 
separated from the cable by approximately 12.8 feet horizontally, and 
the second electrical cabinet is separated from the cable by 
approximately 5.5 feet horizontally. As discussed in Section 3.0 above, 
the licensee could not demonstrate any separation between credited and 
redundant trains of equipment.
3.19.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 25)
3.19.4.1 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 25. If this were to occur, the 
licensee stated that OMA 12 is available to swap Instrument 
Buses 23 and 23A to their backup power source (MCC-29A). If OMA 
12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.19.5 Conclusion for Fire Area J (Fire Zone 25)
    Since the licensee described postulated fire scenarios and Fire 
Zone 25 lacks an automatic fire detection or automatic fire suppression 
system, and any discernable separation between the credited and 
redundant equipment in the area, it is possible that a fire would not 
be detected and extinguished in a reasonable amount of time to ensure

[[Page 7200]]

that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 22.5 minutes of margin 
available for OMA 12, Fire Zone 25 still lacks adequate 
defense-in-depth. Therefore, the NRC staff finds that the defense-in-
depth is insufficient to demonstrate reasonable assurance that safe 
shutdown can be achieved for a fire in Fire Zone 25 and that OMA 
12 is unacceptable for the purpose of providing the level of 
protection intended by the regulation. Therefore, the NRC staff finds 
that an exemption from III.G.2 based on OMA 12 cannot be 
granted for Fire Zone 25.
3.20 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 39A--Mezzanine Floor, Elevation 36'-9'' Unit 2 Turbine 
Building)
3.20.1 Fire Prevention
    The licensee stated that the fire loading in this zone is moderate 
and that the fixed combustibles in this zone consist of cable 
insulation, plastic, and cellulose and that transient combustibles in 
this zone consist of trash, wood, and lube oil. The licensee also 
stated that the ignition sources in this zone consist of cables, 
junction boxes, electrical cabinets, and motors. The licensee further 
stated that since Fire Area J does not contain safety-related 
structures, systems or components, it is not subject to the explicit 
transient combustible controls of procedure EN-DC-161. However, 
operator rounds performed each shift provide for the monitoring of 
combustibles that could present an unacceptable fire safety challenge. 
In addition, the licensee stated that procedures OAP-017 (Plant 
Surveillance and Operator Rounds) and EN-MA-132 (Housekeeping) include 
guidance for monitoring general area cleanliness as well as monitoring 
for accumulations of combustibles.
3.20.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 39A does not have a fire 
detection or automatic fire suppression system installed.
3.20.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 39A has an approximate floor 
area of 7,592 square feet and an approximate ceiling height of 16'-0''. 
The licensee stated that cable AG5-XA5, which is associated with 
instrument buses 23 and 23A and buses 5A and 6A, is located in Fire 
Zone 39A. The licensee also stated that the ignition sources in the 
zone located less than 20 feet horizontally from cable AG5-XA5 consist 
of seven electrical cabinets, a 150 kVA dry transformer, three motors, 
and an MCC. According to the licensee, three electrical cabinets are 
located under the cable separated by approximately 3 feet vertically or 
greater, the remaining four electrical cabinets are separated from the 
cable by approximately 2 feet horizontally or greater, the 150 kVA dry 
transformer is separated from the cable by approximately 1.6 feet 
horizontally and 6.7 feet vertically, the motors are separated from the 
cable by approximately 4.6 feet horizontally or greater, and the MCC is 
separated from the cable by approximately 7.5 feet horizontally. As 
discussed in Section 3.0 above, the licensee could not demonstrate any 
separation between credited and redundant trains of equipment.
3.20.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 39A)
3.20.4.1 OMA 11--Trip breakers 52/5A and 52-SAC on bus 5A and 
52/6A and 52/TAO at bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.20.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 39A. If this were to occur, the 
licensee stated that OMA 12 is available to swap Instrument 
Buses 23 and 23A to their backup power source (MCC-29A). If OMA 
12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.20.5 Conclusion for Fire Area J (Fire Zone 39A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 39A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11 and 22.5 minutes of margin available for 
OMA 12, Fire Zone 39A still lacks adequate defense-in-depth. 
Therefore, the NRC staff finds that the defense-in-depth is 
insufficient to demonstrate reasonable assurance that safe shutdown can 
be achieved for a fire in Fire Zone 39A and that OMAs 11 and 
12 are unacceptable for the purpose of providing the level of 
protection intended by the regulation. Therefore, the NRC staff finds 
that an exemption from III.G.2 based on these OMAs cannot be granted 
for Fire Zone 39A.
3.21 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 43A--Ground Floor, Elevation 15-0'' Unit 2 Turbine Building)
3.21.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cable insulation, 
lube oil, plastic, wood, electrical panels, and cabinets and that the 
transient combustibles in this zone consist of trash, cardboard drums, 
cleaning rags, lube oil, plastic, fiberglass ladders, and paint. The 
licensee also stated that the ignition sources in this zone consist of 
cables, junction boxes, MCC, motors, pumps, electrical cabinets, high 
voltage arcing faults, and an air dryer. The licensee further stated 
that since Fire Area J does not contain safety-related structures, 
systems or components, it is not subject to the explicit transient 
combustible controls of procedure EN-DC-161. However, operator rounds 
performed each shift provide for the monitoring of combustibles that 
could present an unacceptable fire safety challenge. In addition, the 
licensee stated that procedures OAP-017 (Plant Surveillance and 
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for 
monitoring general area cleanliness as well as monitoring for 
accumulations of combustibles.
3.21.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 43A does not have a fire 
detection or automatic fire suppression system installed.
3.21.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 43A has an approximate floor 
area of

[[Page 7201]]

6,600 square feet and an approximate ceiling height of 21'-0''. The 
licensee stated that cable JC2-YA9, which is associated with Buses 5A 
and 6A, is routed through Fire Zone 43A in a tray located approximately 
15 feet above the floor and that ignition sources in the zone located 
less than 20 feet horizontally from the cable consist of two MCCs, an 
air dryer skid, 6.9 kV switchgear, and an electrical cabinet. According 
to the licensee, the MCCs are located under the cable routing separated 
from the cable by approximately 7.7 feet vertically, the air dryer skid 
is separated from the cable by approximately 6.1 feet horizontally, the 
electrical cabinet is separated from the cable by approximately 2 feet 
horizontally and 9.2 feet vertically, and the 6.9 kV switchgear is 
separated from the cable by approximately 0.7 feet horizontally and 7.7 
feet vertically.
    The licensee also stated that cable AC4-BA6 is routed through Fire 
Zone 43A in a tray located approximately 12 feet above the floor and 
that ignition sources in the zone located less than 20 feet 
horizontally from the cable consist of 6.9 kV switchgear and an 
electrical cabinet. According to the licensee, the 6.9 kV switchgear is 
separated from the cable by zero feet horizontally and approximately 
3.7 feet vertically and the electrical cabinet is separated from the 
cable by approximately 6 feet horizontally.
    The licensee also stated that cable AA3-BA5 is associated with 
instrument buses 23 and 23A and is routed through Fire Zone 43A in tray 
located approximately 14 feet above the floor and that ignition sources 
in the zone located less than 20 feet horizontally from the cable 
consist of 6.9 kV switchgear and an electrical cabinet. According to 
the licensee, the 6.9 kV switchgear is separated from the cable by 
approximately 0 feet horizontally and 5 feet vertically and the 
electrical cabinet is separated from the cable by approximately 3 feet 
horizontally and 7 feet vertically.
    The licensee also stated that cable AD1-BA8 is associated with 
instrument buses 23 and 23A and is routed through Fire Zone 43A in tray 
located approximately 14 feet above the floor and that ignition sources 
in the zone located less than 20 feet horizontally from the cable 
consist of 6.9 kV switchgear and an electrical cabinet. According to 
the licensee, the 6.9 kV switchgear is separated from the cable by 
approximately 0 feet horizontally and 5.6 feet vertically and the 
electrical cabinet is separated from the cable by approximately 6 feet 
horizontally.
    The licensee stated that cable ECE19-MN3/01, which is associated 
with valve LCV-112B, is routed through Fire Zone 43A in a cable tray 
located approximately 13 feet above the floor and that ignition sources 
in the zone located less than 20 feet horizontally from the cable 
consist of an MCC, an air dryer skid, 6.9 kV switchgear, a portable 
Duraline power station, and an electrical cabinet. According to the 
licensee, the MCC is separated from the cable by approximately 3.2 feet 
horizontally and 0 feet vertically, the air dryer skid is separated 
from the cable by approximately 7.7 feet horizontally and 2.6 feet 
vertically, the electrical cabinet is separated from the cable by 
approximately 2 feet horizontally and 7.3 feet vertically, the 6.9 kV 
switchgear is separated from the cable by approximately 0.7 feet 
horizontally and 5.8 feet vertically, and the Duraline power station is 
separated from the cable by approximately 19.5 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not demonstrate 
any separation between credited and redundant trains of equipment.
3.21.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 43A)
3.21.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and 
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.21.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that Instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 43A. If a fire were to occur and 
causes a loss of offsite power and damages the cables identified above, 
the licensee stated that OMA 12 is available to swap 
Instrument Buses 23 and 23A to their backup power source (MCC-29A). If 
OMA 12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.21.4.3 OMA 13--Align Charging Pump Suction to RWST
    The licensee stated that fire-induced cable damage may render 
alternate charging pump suction supply valve LCV-112B (normally closed 
RWST outlet valve) inoperable. In the event that cable failures have 
rendered LCV-112B inoperable, local valve manipulations are required to 
support alignment of the charging pump suction to the alternate source, 
the RWST.
    If a fire were to occur and renders the alternate charging pump 
suction supply valve LCV-112B inoperable, the licensee stated that OMA 
13 is available to locally close valve LCV-112C and open 
manual valve 288 to provide a bypass around RWST outlet valve LCV-112B 
and provide water to the charging pump suction. If OMA 13 
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the 
action is 18 minutes while the time available is 75 minutes, which 
provides 43 minutes of margin.
3.21.5 Conclusion for Fire Area J (Fire Zone 43A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 43A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11, 22.5 minutes of margin available for OMA 
12, and 43 minutes of margin available for OMA 13, 
Fire Zone 43A lacks adequate defense-in-depth. Therefore, the NRC staff 
finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 43A and that OMAs 11, 12, and 13 
are unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on these OMAs cannot be granted for Fire 
Zone 43A.
3.22 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 45A--Ground Floor, Elevation 15-0'' and 3'-3'' of the Unit 2 
Turbine Building)
3.22.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cable insulation, 
lube oil, vinyl insulation, and hydrogen and that the transient 
combustibles in this zone

[[Page 7202]]

consist of trash, cardboard drums, lube oil, fiberglass ladders, paint, 
and radiation boundaries. The licensee also stated that the ignition 
sources in this zone consist of cables, junction boxes, MCC, motors, 
pumps, and electrical cabinets. The licensee further stated that since 
Fire Area J does not contain safety-related structures, systems or 
components, it is not subject to the explicit transient combustible 
controls of procedure EN-DC-161. However, operator rounds performed 
each shift provide for the monitoring of combustibles that could 
present an unacceptable fire safety challenge. In addition, the 
licensee stated that procedures OAP-017 (Plant Surveillance and 
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for 
monitoring general area cleanliness as well as monitoring for 
accumulations of combustibles.
3.22.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 45A does not have a fire 
detection or automatic fire suppression system installed.
3.22.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 45A has an approximate floor 
area of 5,380 square feet and an approximate ceiling height of 12'-4''. 
The licensee stated that cable AG5-XA5, which affects buses 5A and 6A, 
is located in Fire Zone 45A and that ignition sources in the zone 
located less than 20 feet horizontally from cable AG5-XA5 consist of 
seven electrical cabinets, a 150KVA dry transformer, three motors, and 
an MCC. According to the licensee, three electrical cabinets are 
located under the cable separated by approximately 3 feet vertically or 
greater, four electrical cabinets are separated from the cable by 
approximately 2 feet horizontally or greater, the 150KVA dry 
transformer is separated from the cable by approximately 1.6 feet 
horizontally and 6.7 feet vertically. The motors are separated from the 
cable by approximately 4.6 feet horizontally or greater, and the MCC is 
separated from the cable by approximately 7.5 feet horizontally. As 
discussed in Section 3.0 above, the licensee could not demonstrate any 
separation between credited and redundant trains of equipment.
3.22.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 45A)
3.22.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and 
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.22.5 Conclusion for Fire Area J (Fire Zone 45A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 45A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11, Fire Zone 45A still lacks adequate 
defense-in-depth. The NRC staff finds that the defense-in-depth is 
insufficient to demonstrate reasonable assurance that safe shutdown can 
be achieved for a fire in Fire Zone 45A and that OMA 11 is 
unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on OMA 11 cannot be granted for 
Fire Zone 45A.
3.23 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 46A--Ground Floor, Elevation 12'-0'' and 3'-3'' Unit 2 
Turbine Building)
3.23.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cable insulation 
and lube oil and that the transient combustibles in this zone consist 
of trash, cleaning rags, lube oil, and paint. The licensee also stated 
that the ignition sources in this zone consist of cables, junction 
boxes, motors, pumps, and electrical cabinets. The licensee further 
stated that since Fire Area J does not contain safety-related 
structures, systems or components, it is not subject to the explicit 
transient combustible controls of procedure EN-DC-161. However, 
operator rounds performed each shift provide for the monitoring of 
combustibles that could present an unacceptable fire safety challenge. 
In addition, the licensee stated that procedures OAP-017, ``Plant 
Surveillance and Operator Rounds,'' and EN-MA-132, ``Housekeeping,'' 
include guidance for monitoring general area cleanliness as well as 
monitoring for accumulations of combustibles.
3.23.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 46A does not have a fire 
detection or automatic fire suppression system installed.
3.23.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 46A has an approximate floor 
area of 12,350 square feet and an approximate ceiling height of 12'-
4''. The licensee stated that cable JC2-YA9, which is associated with 
Buses 5A and 6A, is routed through Fire Zone 46A in a tray located 
approximately 15 feet above the floor and that ignition sources in the 
zone located less than 20 feet horizontally from the cable consist of 
two MCCs, an air dryer skid, 6.9kV switchgear, and an electrical 
cabinet. According to the licensee, the MCCs are located under the 
cable routing separated from the cable by approximately 7.7 feet 
vertically, the air dryer skid is separated from the cable by 
approximately 6.1 feet horizontally, the electrical cabinet is 
separated from the cable by approximately 2 feet horizontally and 9.2 
feet vertically, and the 6.9kV switchgear is separated from the cable 
by approximately 0.7 feet horizontally and 7.7 feet vertically.
    The licensee also stated that cable JB1-L91, which is associated 
with instrument buses 23 and 23A, is routed through the Fire Zone 46A.
    The licensee also stated that cable ECE19-MN3/01, which is 
associated with valve LCV-112B, is routed through Fire Zone 46A in a 
cable tray located approximately 13 feet above the floor and that 
ignition sources in the zone located less than 20 feet horizontally 
from the cable consist of an MCC, an air dryer skid, 6.9kV switchgear, 
a portable Duraline power station, and an electrical cabinet. According 
to the licensee, the MCC is separated from the cable by approximately 
3.2 feet horizontally and 0 feet vertically, the air dryer skid is 
separated from the cable by approximately 7.7 feet horizontally and 2.6 
feet vertically, the electrical cabinet is separated from the cable by 
approximately 2 feet horizontally and 7.3 feet vertically, the 6.9kV 
switchgear is separated from the cable by approximately 0.7 feet 
horizontally and 5.8 feet vertically, and the Duraline power station is 
separated from the

[[Page 7203]]

cable by approximately 19.5 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not demonstrate 
any separation between credited and redundant trains of equipment.
3.23.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 46A)
3.23.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and 
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.23.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 46A. If this were to occur, the 
licensee stated that OMA 12 is available to swap instrument 
buses 23 and 23A to their backup power source (MCC-29A). If OMA 
12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.23.4.3 OMA 13--Align Charging Pump Suction to RWST
    The licensee stated that fire-induced cable damage may render 
alternate charging pump suction supply valve LCV-112B (normally closed 
RWST outlet valve) inoperable. In the event that cable failures have 
rendered LCV-112B inoperable, this valve is required to be opened to 
support alignment of charging pump suction to the alternate source, the 
RWST.
    If a fire were to occur and it renders alternate charging pump 
suction supply valve LCV-112B inoperable, the licensee stated that OMA 
13 is available to locally close valve LCV-112C and open 
manual valve 288 to provide a bypass around RWST outlet valve LCV-112B 
and provide water to the charging pump suction. If OMA 13 
becomes necessary, the licensee stated that they have assumed a 14-
minute diagnosis period and that the required time to perform the 
action is 18 minutes while the time available is 75 minutes, which 
provides 43 minutes of margin.
3.23.5 Conclusion for Fire Area J (Fire Zone 46A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 46A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11, 22.5 minutes of margin available for OMA 
12, and 43 minutes of margin available for OMA 13, 
Fire Zone 46A still lacks adequate defense-in-depth. The NRC staff 
finds that the defense-in-depth is insufficient to demonstrate 
reasonable assurance that safe shutdown can be achieved for a fire in 
Fire Zone 46A and that OMAs 11, 12, and 13 
are unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on these OMAs cannot be granted for Fire 
Zone 46A.
3.24 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 47A--Ground Floor, Elevation 15'-0'' Unit 2 Turbine 
Building)
3.24.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cable insulation 
and that the transient combustibles in this zone consist of trash, lube 
oil, rubber hose, and paint. The licensee also stated that the ignition 
sources in this zone consist of cables, junction boxes, MCC vertical 
panels, and electrical cabinets. The licensee further stated that since 
Fire Area J does not contain safety-related structures, systems or 
components, it is not subject to the explicit transient combustible 
controls of procedure EN-DC-161. However, operator rounds performed 
each shift provide for the monitoring of combustibles that could 
present an unacceptable fire safety challenge. In addition, the 
licensee stated that procedures OAP-017 (Plant Surveillance and 
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for 
monitoring general area cleanliness as well as monitoring for 
accumulations of combustibles.
3.24.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 47A does not have a fire 
detection or automatic fire suppression system installed.
3.24.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 47A has an approximate floor 
area of 5,175 square feet and an approximate ceiling height of 37'-0''. 
The licensee stated that cable JC2-YA9, which is associated with Buses 
5A and 6A, is located in Fire Zone 47A in a cable tray located 
approximately 8 feet above the floor and that ignition sources in the 
zone located less than 20 feet horizontally from cable JC2-YA9 consist 
of electrical cabinets, motors, and MCCs. According to the licensee, 
the electrical cabinets are separated from the cable by approximately 
3.8 feet horizontally and 1.9 feet vertically and the MCCs are located 
under the cable separated from the cable by approximately 0.2 feet 
vertically. As discussed in Section 3.0 above, the licensee did not 
demonstrate any separation between credited and redundant trains of 
equipment.
3.24.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 47A)
3.24.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on Bus 5A and 
52/6A and 52/TAO at Bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.24.5 Conclusion for Fire Area J (Fire Zone 47A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 47A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 50 minutes of margin 
available for OMA 11, Fire Zone 47A still lacks adequate 
defense-in-depth. The NRC staff finds that the defense-in-depth is 
insufficient to demonstrate reasonable assurance that safe shutdown can 
be achieved for a fire in Fire Zone 47A and that OMA 11 is 
unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on OMA 11 cannot be granted for 
Fire Zone 47A.

[[Page 7204]]

3.25 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 50A--Mezzanine Floor, Elevation 36'-9'' Unit 2 Turbine 
Building)
3.25.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cables, plastic, 
cellulose, and office materials and that the transient combustibles in 
this zone consist of trash, vinyl covers, lube oil, and paint. The 
licensee also stated that the ignition sources in this zone consist of 
cables, junction boxes, dry transformers, motors, pumps, and electrical 
cabinets. The licensee further stated that since Fire Area J does not 
contain safety-related structures, systems or components, it is not 
subject to the explicit transient combustible controls of procedure EN-
DC-161. However, operator rounds performed each shift provide for the 
monitoring of combustibles that could present an unacceptable fire 
safety challenge. In addition, the licensee stated that procedures OAP-
017 (Plant Surveillance and Operator Rounds) and EN-MA-132 
(Housekeeping) include guidance for monitoring general area cleanliness 
as well as monitoring for accumulations of combustibles.
3.25.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 50A does not have a fire 
detection or automatic fire suppression system installed.
3.25.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 50A has an approximate floor 
area of 1,550 square feet and an approximate ceiling height of 16'-0''. 
The licensee stated that cable JC2-YA9, which is associated with Buses 
5A and 6A, is located in Fire Zone 50A in a cable tray located 
approximately 8 feet above the floor and that ignition sources in the 
zone located less than 20 feet horizontally from cable JC2-YA9 consist 
of electrical cabinets, motors, and MCCs. According to the licensee, 
the electrical cabinets are separated from the cable by approximately 
3.8 feet horizontally and 1.9 feet vertically and a motor is located 
under the cable separated by approximately 5.2 feet vertically. The 
licensee also stated that cable AG5-XA5, which is associated with 
instrument buses 23 and 23A, is routed through the Fire Zone 50A and 
that ignition sources in the zone located less than 20 feet 
horizontally from the cable consist of electrical cabinets, a dry 
transformer, motors, and an MCC. According to the licensee, three of 
the electrical cabinets are located under the cable separated from the 
cable by approximately 3 feet vertically or greater, another four 
electrical cabinets are separated from the cable by approximately 2 
feet horizontally or greater, the dry transformer is separated from the 
cable by approximately 1.6 feet horizontally and 6.7 feet vertically, 
the motors are separated from the cable by approximately 4.6 feet 
horizontally or greater, and the MCC is separated from the cable by 
approximately 7.5 feet horizontally. As discussed in Section 3.0 above, 
the licensee did not demonstrate any separation between credited and 
redundant trains of equipment.
3.25.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 50A)
3.25.4.1 OMA 11--Trip Breakers 52/5A and 52-SAC on bus 5A and 
52/6A and 52/TAO at bus 6A and Remove Control Power Fuses
    OMA 11 was evaluated in Section 3.17.4.1 above. As stated 
in Section 3.17.4.1, OMA 11 has acceptable margin for all fire 
zones in Fire Area J.
3.25.4.2 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 50A. If this were to occur, the 
licensee stated that OMA 12 is available to swap Instrument 
Buses 23 and 23A to their backup power source (MCC-29A). If OMA 
12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.25.5 Conclusion for Fire Area J (Fire Zone 50A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 50A lacks an automatic fire detection or automatic fire 
suppression system and a robust combustible controls program, and any 
discernable separation between the credited and redundant equipment in 
the area, it is possible that a fire would not be detected and 
extinguished in a reasonable amount of time to ensure that at least one 
train of equipment remains free of fire damage following a fire event. 
Although there are 50 minutes of margin available for OMA 11 
and 22.5 minutes of margin available for OMA 12, Fire Zone 50A 
still lacks adequate defense-in-depth. The NRC staff finds that the 
defense-in-depth is insufficient to demonstrate reasonable assurance 
that safe shutdown can be achieved for a fire in Fire Zone 50A and that 
OMAs 11 and 12 are unacceptable for the purpose of 
providing the level of protection intended by the regulation. 
Therefore, the NRC staff finds that an exemption from III.G.2 based on 
these OMAs cannot be granted for Fire Zone 50A.
3.26 Fire Area J--Unit 1 Control Room, Turbine Building, Superheater 
Building, Nuclear Service Building, Chemical Systems Building, 
Administration Building, Screenwell House, and Unit 2 Turbine Building 
(Fire Zone 270--General Area of the 33' Elev. of the Unit 1 Superheater 
Bldg.)
3.26.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that the fixed combustibles in this zone consist of cables and that the 
transient combustibles in this zone consist of trash, cardboard drums, 
a flammable liquid cabinet, plastic, wood, and paint. The licensee also 
stated that the ignition sources in this zone consist of cables, 
junction boxes, dry transformers, motors, a battery charger, an MCC 
vertical panel, and electrical cabinets. The licensee further stated 
that since Fire Area J does not contain safety-related structures, 
systems or components, it is not subject to the explicit transient 
combustible controls of procedure EN-DC-161. However, operator rounds 
performed each shift provide for the monitoring of combustibles that 
could present an unacceptable fire safety challenge. In addition, the 
licensee stated that procedures OAP-017 (Plant Surveillance and 
Operator Rounds) and EN-MA-132 (Housekeeping) include guidance for 
monitoring general area cleanliness as well as monitoring for 
accumulations of combustibles.
3.26.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 270 does not have a fire 
detection or automatic fire suppression system installed.
3.26.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 270 has an approximate floor 
area of 13,000 square feet and an approximate ceiling height of 19'-
0''. The licensee also stated

[[Page 7205]]

that cables EDB8-EPB3, associated with instrument buses 23 and 23A, are 
routed through the Fire Zone 270 in rigid steel conduit and that 
ignition sources in the zone located less than 20 feet horizontally 
from the cables consist of electrical cabinets, a dry transformer, 
batteries, and an MCC. According to the licensee, one of the electrical 
cabinets is separated from the cables by approximately 12.8 feet 
horizontally, another electrical cabinet is separated from the cables 
by approximately 5.5 feet horizontally, the dry transformer is 
separated from the cables by approximately 13.6 feet horizontally, the 
MCC is separated from the cables by approximately 18.5 feet 
horizontally, and there is no separation between the cables and the 
batteries since the cables originate at the batteries.
    As discussed in Section 3.0 above, the licensee did not demonstrate 
any separation between credited and redundant trains of equipment.
3.26.4 OMAs Credited for a Fire in Fire Area J (Fire Zone 270)
3.26.4.1 OMA 12--Transfer Instrument Buses 23 and 23A to 
Emergency Power Source
    The licensee stated that Instrument buses 23 and 23A could 
experience a loss of their normal power source (125 VDC power panel 23) 
as a result of fire in Fire Zone 270. If this were to occur, the 
licensee stated that OMA 12 is available to swap Instrument 
Buses 23 and 23A to their backup power source (MCC-29A). If OMA 
12 becomes necessary, the licensee stated that they have 
assumed a 5.5-minute diagnosis period and that the required time to 
perform the action is 2 minutes while the time available is 30 minutes, 
which provides 22.5 minutes of margin.
3.26.5 Conclusion for Fire Area J (Fire Zone 270)
    Since the licensee described postulated fire scenarios and Fire 
Zone 270 lacks a fire detection or automatic fire suppression system 
and a robust combustible controls program, and any discernable 
separation between the credited and redundant equipment in the area, it 
is possible that a fire would not be detected and extinguished in a 
reasonable amount of time to ensure that at least one train of 
equipment remains free of fire damage following a fire event. Although 
there are 22.5 minutes of margin available for OMA 12, Fire 
Zone 270 still lacks adequate defense-in-depth. The NRC staff finds 
that the defense-in-depth is insufficient to demonstrate reasonable 
assurance that safe shutdown can be achieved for a fire in Fire Zone 
270 and that OMA 12 is unacceptable for the purpose of 
providing the level of protection intended by the regulation. 
Therefore, the NRC staff finds that an exemption from III.G.2 based on 
OMA 12 cannot be granted for Fire Zone 270.
3.27 Fire Area K--Auxiliary Feed Pump Building (not Including the AFW 
Pump Room) (Fire Zone 60A--Chemical Addition Area, Elev. 33'-0'')
3.27.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there are no fixed combustibles in this zone and that the 
transient combustibles in this zone consist of trash, fiber drums, and 
paint. The licensee also stated that the ignition sources in this zone 
consist of motors, blowers, and electrical cabinets.
3.27.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 60A does not have a fire 
detection or automatic fire suppression system installed.
3.27.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 60A has an approximate floor 
area of 1,210 square feet and an approximate ceiling height of 8'-6''. 
The licensee stated that cables LL8-JF5 for FCV-406A, LL9-JF9 for FCV-
406C, JB1-YN9 for FCV-1121, and JB1-PT1/2 and PT1-A16 associated with 
21 AFW pump are routed through Fire Zone 60A in rigid steel conduit 
that runs vertically from floor to ceiling and that ignition sources in 
the zone located less than 20 feet horizontally from the cables consist 
of one electrical cabinet and four motors. According to the licensee, 
the electrical cabinet is separated from the cables by approximately 7 
feet horizontally and the motors are separated from the cables by 
approximately 5.5 feet horizontally or greater.
    The licensee also stated that cables PU9-JF9 for FCV-406D, PU9-JH1 
for FCV-406B, PU9-JG2 for FCV-406A, and PU9-JF2 for FCV-406C are routed 
through Fire Zone 60A in a combination of rigid steel conduits and a 
cable tray that runs from floor to ceiling and that ignition sources in 
the zone located less than 20 feet horizontally from the cables consist 
of two electrical cabinet and four motors. According to the licensee, 
the electrical cabinet is separated from the cables by approximately 7 
feet horizontally or greater and the motors are separated from the 
cables by approximately 1.6 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not demonstrate 
any separation between credited and redundant trains of equipment.
3.27.4 OMAs Credited for a Fire in Fire Area K (Fire Zone 60A)
3.27.4.1 OMA 14--Transfer 21 AFW Pump to Alternate Safe 
Shutdown System Power Source
    If a fire were to occur and it causes damage to the cables 
associated with the 21 AFW pump normal power supply, the licensee 
stated that OMA 14 is available to operate transfer switch 
EDC5 and close the supply breaker at substation 12FD3 to transfer 21 
AFW pump to the Alternate Safe Shutdown System power supply. If OMA 
14 becomes necessary, the licensee stated that they have 
assumed a 4.5-minute diagnosis period and that the required time to 
perform the action is 17 minutes while the time available is 34 
minutes, which provides 12.5 minutes of margin.
3.27.4.2 OMA 15--Open 21 AFW Pump Recirculation Bypass Valve 
(BFD-77)
    If a fire were to occur and it causes damage to the cables 
associated with the 21 AFW pump recirculation valve, FCV-1121, the 
licensee stated that OMA 15 is available to open the 21 AFW 
pump recirculation bypass valve BFD-77. If OMA 15 becomes 
necessary, the licensee stated that they have assumed a 4.5-minute 
diagnosis period and that the required time to perform the action is 5 
minutes while the time available is 34 minutes, which provides 24.5 
minutes of margin.
3.27.5 Conclusion for Fire Area K (Fire Zone 60A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 60A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 12.5 minutes of margin 
available for OMA 14 and 24.5 minutes of margin available for 
OMA 15, Fire Zone 60A still lacks adequate defense-in-depth.
    The NRC staff finds that the defense-in-depth is insufficient to 
demonstrate reasonable assurance that safe shutdown can be achieved for 
a fire in Fire Zone 60A and that OMAs 14 and 15 are 
unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore,

[[Page 7206]]

the NRC staff finds that an exemption from III.G.2 based on these OMAs 
cannot be granted for Fire Zone 60A.
3.28 Fire Area K--Auxiliary Feed Pump Building (not Including the AFW 
Pump Room) (Fire Zone 65A--Main Steam and Feedwater Valve Area 43'-0'', 
65'-0'', and 74'-0'')
3.28.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that fixed combustibles in this zone consist of wood and that the 
transient combustibles in this zone consist of trash and paint. The 
licensee also stated that the ignition sources in this zone consist of 
a transformer and electrical cabinets.
3.28.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 65A does not have a fire 
detection or automatic fire suppression system installed.
3.28.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 65A has an approximate floor 
area of 1,210 square feet and an approximate ceiling height of 43'-0''. 
The licensee stated that cables PU9-JF9 for FCV-406D, PU9-JH1 for FCV-
406B, PU9-JG2 for FCV-406A, PU9-JF2 for FCV-406C, LL8-JF5 for FCV-406A, 
LL9-JF9 for FCV-406C, JB1-YN9 for FCV-1121, and JB1-PT1/2 and PT1-A16 
associated with 21 AFW pump are routed through Fire Zone 65A in rigid 
steel conduit that runs vertically from the floor to a height of 
approximately 6.5 feet to 8.5 feet above the floor before exiting the 
zone and that ignition sources in the zone located less than 20 feet 
horizontally from the cables consist of two switches. According to the 
licensee, the switches are separated from the cables by approximately 
2.5 feet horizontally. As discussed in Section 3.0 above, the licensee 
did not demonstrate any separation between credited and redundant 
trains of equipment.
3.28.4 OMAs Credited for a Fire in Fire Area K (Fire Zone 65A)
3.28.4.1 OMA 14--Transfer 21 AFW Pump to Alternate Safe 
Shutdown System Power Source
    If a fire were to occur and it causes damage to the cables 
associated with the 21 AFW pump normal power supply, the licensee 
stated that OMA 14 is available to operate transfer switch 
EDC5 and close supply breaker at substation 12FD3 to transfer 21 AFW 
pump to the Alternate Safe Shutdown System power supply. If OMA 
14 becomes necessary, the licensee stated that they have 
assumed a 4.5-minute diagnosis period and that the required time to 
perform the action is 17 minutes while the time available is 34 
minutes, which provides 12.5 minutes of margin.
3.28.4.2 OMA 15--Open 21 AFW Pump Recirculation Bypass Valve 
(BFD-77)
    If a fire were to occur and it causes damage to the cables 
associated with the 21 AFW pump recirculation valve, FCV-1121, the 
licensee stated that OMA 15 is available to open the 21 AFW 
pump recirculation bypass valve BFD-77. If OMA 15 becomes 
necessary, the licensee stated that they have assumed a 4.5-minute 
diagnosis period and that the required time to perform the action is 5 
minutes while the time available is 34 minutes, which provides 24.5 
minutes of margin.
3.28.5 Conclusion for Fire Area K (Fire Zone 65A)
    Since the licensee described postulated fire scenarios and Fire 
Zone 65A lacks an automatic fire detection or automatic fire 
suppression system, and any discernable separation between the credited 
and redundant equipment in the area, it is possible that a fire would 
not be detected and extinguished in a reasonable amount of time to 
ensure that at least one train of equipment remains free of fire damage 
following a fire event. Although there is 12.5 minutes of margin 
available for OMA 14 and 24.5 minutes of margin available for 
OMA 15, Fire Zone 65A still lacks adequate defense-in-depth. 
The NRC staff finds that the defense-in-depth is insufficient to 
demonstrate reasonable assurance that safe shutdown can be achieved for 
a fire in Fire Zone 65A and that OMAs 14 and 15 are 
unacceptable for the purpose of providing the level of protection 
intended by the regulation. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on these OMAs cannot be granted for Fire 
Zone 65A.
3.29 Fire Area P--Component Cooling Pump Room, Elevation 68'-0''--PAB 
(Fire Zone 1--Component Cooling Pump Room, Elevation 68'-0''--PAB)
3.29.1 Fire Prevention
    The licensee stated that the fire loading in this zone is low and 
that there are no fixed combustibles in this zone and that the 
transient combustibles in this zone consist of trash, radiation 
boundaries, and paint. The licensee also stated that the ignition 
sources in this zone consist of electric motors and pumps.
3.29.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 1 has an area-wide, fire 
detection system installed but does not have an automatic fire 
suppression system installed. The licensee also stated that the fire 
detection system is designed and installed in accordance with NFPA 72D, 
1975 Edition.
3.29.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 1 has an approximate floor area 
of 710 square feet and an approximate ceiling height of 12'-0''. The 
licensee stated that power supply cables for 21, 22, and 23 component 
cooling water (CCW) pumps are located in this zone in rigid steel 
conduit for each motor and that the conduit for 23 CCW Pump is wrapped 
with an ERFBS rated for 30 minutes. The licensee also stated that the 
pumps are located approximately 10 feet from each other and that a 
radiant energy shield is installed between the 22 CCW pump and the 23 
CCW pump. In addition, the licensee stated that the ignition sources in 
the zone consist of the three CCW pumps and two electrical cabinets. 
According to the licensee, the conduits for 21 and 22 CCW pumps are 
routed vertically from the motors to approximately 8.8 feet above the 
floor and are separated by approximately 0.5 feet horizontally, the 
cable for 23 CCW pump rises vertically from the motor to approximately 
9.5 feet above the floor, and that the conduit for the 22 CCW Pump 
crosses over the 21 CCW Pump. Also according to the licensee, the 
electrical cabinets are separated from the 21 and 22 CCW pump power 
cables by approximately 19.5 feet horizontally or greater, one of the 
electrical cabinets is located directly under the 23 CCW pump power 
cable separated by approximately 5.2 feet vertically, and the other 
electrical cabinet is separated from the 23 CCW pump power conduit by 
approximately 3.8 feet horizontally and 4.1 feet vertically. As 
discussed in Section 3.0 above, the licensee did not demonstrate any 
separation between credited and redundant trains of equipment.
3.29.4 OMAs Credited for a Fire in Fire Area P (Fire Zone 1)
3.29.4.1 OMA 16--Transfer 23 CCW Pump to Alternate Safe 
Shutdown System Power Feed if Normal Power or Control Is Lost
    The licensee stated that the CCW pump room contains all three CCW 
pumps and that power to the CCW pumps is normally supplied from the

[[Page 7207]]

480V switchgear. The licensee also stated that the Alternate Safe 
Shutdown System provides the capability to use individual components as 
required to meet specific plant shutdown goals and that to ensure the 
availability of at least one CCW pump for SSD in the event that the 
normal power supply is disabled as a result of a fire, Alternate Safe 
Shutdown System power can be supplied to CCW pump 23 through manual 
transfer switch EDF9 which is hardwired to Alternate Safe Shutdown 
System bus 12FD3 at the Alternate Safe Shutdown System load center, 
where starting and stopping 23 CCW pump can be accomplished.
    In the unlikely event that a fire occurs and causes a loss of all 
three trains of normal power, the licensee stated that OMA 16 
is available to align the 23 CCW pump to an alternate power supply, 
thereby recovering one of the redundant CCW trains. If OMA 16 
becomes necessary, the licensee stated that they have assumed a 24-
minute diagnosis period and that the required time to perform the 
action is 7 minutes while the time available is greater than 60 
minutes, which provides 29 minutes of margin.
3.29.4.2 OMA 17--Start Appendix R Diesel Generator (ARDG) if 
Normal Power and Offsite Power Are Lost
    The licensee confirmed that Fire Area P presents no impact to 
cables or components associated with the onsite power supplied by the 
safety-related EDGs 21, 22, and 23. In the event that it is desired or 
necessary to utilize the ARDG, the licensee stated that it would only 
be in response to CCR operators observing the loss of indication for 
power availability to all 480V safety-related buses. The licensee also 
stated that there are no credible fire scenarios that would necessitate 
this OMA.
    In the unlikely event that a fire occurs and causes a loss of both 
normal and offsite power supply, the licensee stated that OMA 
17 is available to start the ARDG. If OMA 17 becomes 
necessary, the licensee stated that they have assumed that offsite 
power is unavailable at the outset of the event and that the required 
time to perform the action is 17 minutes while the time available is 60 
minutes, which provides 43 minutes of margin.
3.29.5 Conclusion for Fire Area P (Fire Zone 1)
    Given the low combustible fuel loading, ERFBS and radiant energy 
shield noted above, and the automatic fire detection system, it is 
unlikely that a fire would occur and go undetected and not be 
extinguished in a reasonable amount of time to ensure that at least one 
train of equipment necessary for safe shutdown remains free of fire 
damage. For OMA 17, the NRC staff finds that a fire in Fire 
Zone 1 should not affect power availability on the 480V safety-related 
buses, and therefore OMA 17 would not be required. In the 
unlikely event that a fire does occur and causes damage that 
necessitates the use of OMA 16, there is 29 minutes of margin 
available to provide assurance that safe shutdown capability will be 
maintained following the postulated fire events. The NRC staff had 
previously issued an exemption from III.G for Fire Zone 1 in 1984 
(ML003776266). In that exemption, the NRC staff found that the low fire 
load, the fire detection system, and features such as fire wrap on the 
23 CCW pump cables from transfer switch EDF-9 and the non-combustible 
fire barriers in the room justified an exemption. The NRC staff finds 
that there is adequate defense-in-depth provided for Fire Zone 1 and 
that OMA 16 is acceptable for the purpose of providing the 
level of protection intended by the regulation. Therefore, the NRC 
staff finds that the previous III.G.2 exemption for Fire Zone 1 remains 
valid.
3.30 Fire Area YD--Exterior Yard (Fire Zone 900--Yard)
3.30.1 Fire Prevention
    The licensee stated that this zone is an outdoor area with minimal 
fixed combustibles and that any ignition sources would be transient in 
nature. The licensee also stated that although this zone contains 
minimal fixed combustibles, postulated fire scenarios would involve 
transient materials and ignition sources.
3.30.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 900 does not have a fire 
detection or automatic fire suppression system installed.
3.30.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 900 is an outside area with no 
walls or ceiling and open to the exterior so it is unlikely that smoke 
or heat would accumulate in the zone to cause damage to equipment not 
exposed directly to a fire. The licensee stated that Fire Zone 900 
contains cable ECD3-EXF6/2, which is associated with motor-operated 
valve 227, and is routed outside through rigid steel conduit from 
approximately 12 feet above the floor at elevation of 98' which is also 
the roof of 80' elevation to approximately elevation 104' where it 
enters the fan house. As discussed in Section 3.0 above, the licensee 
did not demonstrate any separation between credited and redundant 
trains of equipment.
3.30.4 OMAs Credited for a Fire in Fire Area YD (Fire Zone 900)
3.30.4.1 OMA 18--Align Charging Pump Makeup Path to RCS
    The licensee stated that in order to ensure a reliable charging 
makeup path to the RCS, air-operated valve HCV-142 must remain open or 
motor-operated bypass valve 227, which is normally closed, must be 
opened and that air-operated valve HCV-142 is assumed to fail closed as 
designed in response to a loss of instrument air. The licensee stated 
that OMA 18 is only required if normal flowpath valve HCV-142 
fails closed and that spurious isolation of the charging makeup path to 
the RCS is identified in the CCR by operators confirming that a 
charging pump is in operation, but pressurizer level is decreasing. 
Since no CCR pressurizer level indicating channels have cables routed 
through Fire Area YD, the CCR indication of pressurizer level can be 
expected to remain unaffected and operable in the event of a fire in 
Fire Zone 900.
    In the unlikely event that a fire occurs and causes damage to cable 
ECD3-EXF6/2 and causes HCV-142 to close in response to a loss of 
instrument air, the licensee stated that OMA 18 is available 
to align charging makeup path to RCS by manually opening bypass valve 
227 to mitigate a spuriously closed HCV-142 and restore or maintain a 
reliable charging makeup path to the RCS. If OMA 18 becomes 
necessary, the licensee stated that they have assumed a 14-minute 
diagnosis period and that the required time to perform the action is 14 
minutes while the time available is greater than 75 minutes, which 
provides 47 minutes of margin.
3.30.5 Conclusion for Fire Area YD (Fire Zone 900)
    Given the low combustible fuel loading and outdoor nature of the 
zone, it is unlikely that a fire would occur and damage cable ECD3-
EXF6/2. In the unlikely event that a fire does occur and causes damage 
that necessitates the use of OMA 18, there is 47 minutes of 
margin available to provide assurance that safe shutdown capability 
will be maintained following the postulated fire events. The NRC staff 
finds that there is adequate defense-in-depth provided for Fire Zone 
900 and that OMA 18 is acceptable for the purpose of providing 
the level of protection intended by the

[[Page 7208]]

regulation. Therefore, the NRC staff finds that an exemption from 
III.G.2 based on OMA 18 is granted for Fire Zone 900.

4.0 Feasibility and Reliability of the Operator Manual Actions

    Based on Section 3.0 above, several areas where OMAs are credited 
were found acceptable. The OMAs credited in those areas were then 
evaluated for feasibility and reliability. This analysis postulates 
that OMAs may be necessary to assure SSD capability in addition to the 
traditional fire protection features described above. NUREG-1852, 
``Demonstrating the Feasibility and Reliability of Operator Manual 
Actions in Response to Fire,'' provides criteria and associated 
technical bases for evaluating the feasibility and reliability of post-
fire OMAs in nuclear power plants. The following provides the 
licensee's justification for the OMAs specified in this exemption.

4.1 Bases for Establishing Feasibility

    The licensee's analysis addresses factors such as environmental 
concerns, equipment functionality and accessibility, available 
indications, communications, portable equipment, personnel protection 
equipment, procedures and training, and staffing and demonstrations. In 
its submittals, the licensee stated that environmental factors such as 
radiation, lighting, temperature, humidity, smoke, toxic gas, noise, 
and fire suppression discharge were evaluated and found to not 
represent a negative impact on the operators' abilities to complete the 
OMAs. The licensee stated that normal radiation conditions within the 
areas of concern will not be adversely affected by the fire and 
subsequent spurious equipment operation. The licensee also confirmed 
that each of the OMA locations addressed by this exemption are provided 
with emergency lighting that illuminates both the potential ingress and 
egress paths and the component requiring OMA manipulation.
    The licensee also confirmed that temperature and humidity 
conditions will not challenge the operators performing the OMAs. 
Additionally, the licensee indicated that heat and smoke or gas 
generation from a fire will not impact the operator performing the 
OMAs. For those specific cases in which it is necessary to reenter the 
fire area no less than 1 hour after the postulated fire event, the 
licensee stated that sufficient time is available to initiate smoke/
heat venting through fixed ventilation systems and augmented by 
portable smoke ejectors, consistent with the Pre-Fire Plans, to ensure 
operator habitability to implement the necessary OMAs. In addition, the 
licensee stated that pre-staged self-contained breathing apparatus 
(SCBA), sufficient to equip the full operating crew, are available for 
deployment in response to post-fire environmental conditions.
    The licensee stated that equipment credited for implementation of 
OMAs was reviewed to ensure it is accessible, available, and not 
damaged by the affects of the fire. Where ladders are required for 
access to components to perform OMAs, appropriate ladders are staged in 
accordance with plant procedures and the presence of these ladders is 
verified periodically in accordance with plant surveillance procedures. 
Any tools that are required in support of post-fire hot shutdown OMAs 
are pre-staged at the locations where they would be used. These consist 
of common tools such as wrenches, banding cutters, and pliers. Where 
special tools or equipment are required, the licensee stated that they 
are designated for post-fire cold shutdown repairs, and the necessary 
tools and supplies are pre-staged in designated locations. The staging 
of necessary tools is confirmed via periodic surveillance.
    In addition, the licensee indicated that procedures are in place, 
in the form of fire response procedures, to ensure that clear and 
accessible instructions on how to perform the manual actions are 
available to the operators. The licensee stated that all of the 
requested OMAs are directed by plant procedures, and the operators are 
trained in the use of the procedures. Specifically, the licensee stated 
that post-fire operator manual actions are clearly defined in 
procedures 2-ONOP-FP-001 and 2-AOP-SSD-1. Most OMAs required for the 
lll.G.2 fire areas are directed by Off-Normal Operating Procedure 2-
ONOP-FP-001. Where CCR controls and indications are not assured to be 
reliably operable, the licensee stated that sufficiently detailed 
guidance is provided in procedure 2-AOP-SSD-1 to direct the operators 
to an alternate component or operating method that is assured to be 
available and viable for the specific fire scenario under 
consideration. Initial and periodic requalification operator training 
is provided on these procedures, consistent with standard licensed and 
non-licensed operator training programs.
    The licensee stated that key diagnostic instrumentation is expected 
to remain available in the CCR to alert operators to implement the 
contingency OMAs as credited in the IP2 Appendix R SSD Analysis. Key 
indicators that trigger the need for local operator intervention for 
the credited set of OMAs include not only the RCS and secondary system 
instrumentation, but also the failure of components to respond or 
reliably indicate status in the CCR. The licensee further stated that 
based on field notes compiled from simulator exercises in which 
bounding fire area scenarios were modeled, the available CCR 
instruments and indicators, combined with operator response in 
accordance with EOPs, AOPs, fire SSD procedures, and other supporting 
procedures, are sufficient to ensure timely diagnosis of conditions 
requiring the dispatch of operator(s) to perform the credited OMAs 
outside the CCR. With the exception of those OMAs found to lack 
adequate time margin, the NRC staff determined that diagnosis and 
initiation times, in conjunction with the available margin, were 
acceptable.
    With regard to communications, the licensee stated that reliance is 
placed on radios for communication between plant operators during a 
post-fire shutdown event. Radio repeaters are located outside the 
protected area and are not subject to disruption caused by fire events 
within the protected area. The repeaters are also equipped with 
uninterruptible power supplies to ensure continued operation in the 
event of the loss of normal power to the buildings in which they are 
located. Field verifications of radio system functionality have 
validated that communications between the designated control and 
monitoring locations are feasible and reliable.
    The licensee stated that the manual action sequences in all of the 
lll.G.2 areas are considered to be bounded by the sequences represented 
by alternate shutdown (lll.G.3) Fire Area A. With regard to staffing, 
the licensee stated that timed field walkthroughs of Abnormal Operating 
Procedure 2-AOP-SSD-1 have been performed to validate that the number 
of operators available on the watch staff (7) can safely accomplish all 
required actions within the required time period to meet Appendix R SSD 
performance goals. The licensee stated that the broad set of OMAs 
required in implementing alternate shutdown procedure 2-AOP-SSD-1 
bounds the smaller set of manual actions credited for coping with 
lll.G.2 fire area scenarios and that most OMAs required for the lll.G.2 
fire areas are directed by Off-Normal Operating Procedure 2-ONOP-FP-
001.
    Additionally, the licensee stated that post-fire OMAs have been 
validated through timed operator walkthroughs, using as the basis an 
enveloping

[[Page 7209]]

scenario addressed by 2-AOP-SSD-1. When utilizing 2-AOP-SSD-1, the most 
challenging set of local manual operator actions (number of actions and 
time sensitivity of actions) is presented to the operations shift crew, 
and this set of actions is considered to adequately bound the limited 
set of manual actions that are credited in 2-ONOP-FP-001. The licensee 
also stated that the timed walkthroughs of 2-AOP-SSD-1 have 
consistently demonstrated that the key SSD tasks (e.g., restoration of 
RCS makeup; restoration of AFW to SGs; mitigation of key potential 
spurious actuation concerns) can be accomplished in a timely manner to 
meet the Appendix R SSD performance goals.
    The licensee stated that none of the OMA operating locations are 
difficult to access, and the required operations are straightforward 
manual actions that do not require any special tools, processes, or 
unique personal capabilities. Specifically, the OMAs entail:
     Manual operation of valves (manual valves, as well as 
operation of air-operated valves and motor-operated valves via hand 
wheels or installed jacking devices).
     Local manual trip or closure of circuit breakers.
     Manual control of the turbine-driven AFW pump.
    The licensee further stated that none of the requested OMAs involve 
complex instruction sets, the installation or removal of jumpers, or 
any actions requiring uniquely specialized knowledge or fine motor 
skills. The OMA task assignments are within the capability of any 
licensed operator or nuclear plant operator, as applicable to his or 
her responsibility set. As such, the challenge presented for completion 
of these basic tasks within the prescribed time limits is within the 
capability of the standard IP2 operating crew. The licensee further 
stated that in addition to the validation of key OMAs credited in 
alternate SSD procedure 2-AOP-SSD-1, the plant simulator was utilized 
to perform evaluations of bounding lll.G.2 fire scenarios, and based on 
the field notes compiled from these exercises, there is reasonable 
assurance that conditions requiring the implementation of the 
identified OMAs can be identified and mitigated in a sufficiently 
timely manner to ensure Appendix R performance goals are met. However, 
certain OMAs were found to lack adequate margin due to the prompt 
nature of the action or because the NRC staff concluded there was a 
lack of time available to perform an OMA where reentry to a fire area 
is required. These cases are indicated below.

4.2 Feasibility

    The licensee's analysis demonstrates that, with exceptions, the 
OMAs can be diagnosed and executed within the amount of time available 
to complete them. The licensee's analysis also demonstrates that 
various factors, as discussed above, have been considered to address 
uncertainties in estimating the time available. The licensee stated 
that the credited OMAs have been demonstrated to be feasible through 
timed evolutions performed using a combination of simulator drills and 
dispatch of operators to simulate performance of the OMAs within the 
physical plant. In most cases, the OMAs are completed, with margin 
remaining, within the time constraints established by the supporting 
SSD thermal-hydraulic analyses. The licensee stated that the time 
values have been shown to be consistently achievable, and the 
operations resource demand required to support any one of the fire area 
scenarios is a fraction of the 7-operator complement available to 
support an SSD scenario. However, OMA 6 requires operators to 
reenter a fire area following a fire event to perform an OMA and the 
licensee failed to account for the 60-minute waiting period in their 
required time. Because of this, this OMA was determined to be 
infeasible and has been noted as such in the table below. The available 
margin is indicated as a negative number where an OMA credited in a 
particular area was found to be infeasible and therefore unreliable as 
well. Other OMAs were determined to be feasible but not reliable since 
only nominal margin is available to complete them.
    The following table summarizes the ``required time'' versus 
``available time'' for each OMA. The indicated ``required time'' is the 
time needed to complete all actions that may be required as a result of 
fire in each of the identified fire zones and includes diagnosis time, 
implementation time, and uncertainty time. The indicated ``available 
time'' is the time by which the action must be completed in order to 
meet the assumptions in plant analyses. The NRC staff finds that the 
required time to perform the actions is reasonable as the licensee has 
verified these times in simulator scenarios and by simulating 
performance in the plant. Where reentry to a fire area is required to 
perform an OMA, a 60-minute waiting period is also included in the 
required time and the diagnosis period for these instances was assumed 
to occur concurrent with the waiting period. Finally, the times noted 
below should be considered with the understanding that the manual 
actions are a fall back in the unlikely event that the fire protection 
defense-in-depth features are insufficient.

--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                      OMA ID                               Required time  Available time     Available
               Fire area                       Fire zones \1\          \2\            OMA summary            (min) \3\         (min)       margin  (min)
--------------------------------------------------------------------------------------------------------------------------------------------------------
C......................................  23........................    \4\ 1  Implement EOP 2-FR-H.l....              NA              NA              NA
                                                                    ------------------------------------------------------------------------------------
                                                                           2  Operate turbine-driven                  82             >60          \5\ >0
                                                                               22AFW pump.
                                                                    ------------------------------------------------------------------------------------
                                                                           3  Open 22 AFW pump steam                19.5             >60           >40.5
                                                                               supply isolation valves
                                                                               PCV-1310A and PCV-1310B..
                                                                    ------------------------------------------------------------------------------------
                                                                           4  Operate TDAFW flow valves               82             >60          \5\ >0
                                                                               FCV-405A,B,C and/or D to
                                                                               align TDAFW to selected
                                                                               SGs.
--------------------------------------------------------------------------------------------------------------------------------------------------------
F......................................  27A, 33A, 59A.............        5  Align Charging flow to RCS              74              75           \6\ 1
                                        ----------------------------------------------------------------------------------------------------------------
                                         5A, 6, 7A, 22A, 27A.......        6  Align Charging Suction To               78              75          \6\ -3
                                                                               RWST.
                                        ----------------------------------------------------------------------------------------------------------------
                                         6, 7A.....................        7  Transfer Inst. Buses 23/               7.5              30            22.5
                                                                               23A to alternate power.
--------------------------------------------------------------------------------------------------------------------------------------------------------

[[Page 7210]]

 
H......................................  70A, 71 A, 72A, 75A, 77A,         8  Align charging pump makeup              28              75              47
                                          84A, 85A, 87A.                       path to RCS.
                                        ----------------------------------------------------------------------------------------------------------------
                                         70A, 75A, 77A, 87A........        9  Enable Alternate Safe                   13              34              21
                                                                               Shutdown System Pneumatic
                                                                               Instruments.
                                                                    ------------------------------------------------------------------------------------
                                                                          10  Enable Alternate Safe                   23              34              11
                                                                               Shutdown System source
                                                                               range channel.
--------------------------------------------------------------------------------------------------------------------------------------------------------
J......................................  17,19 39A, 43A, 45A, 46A,        11  Trip breakers 52/5A and 52-             10              60              50
                                          47A, 50A.                            SAC on Bus 5A and 52/6A
                                                                               and 52/TAO on Bus 6A and
                                                                               remove control power
                                                                               fuses.
                                        ----------------------------------------------------------------------------------------------------------------
                                         25, 39A, 43A, 46A, 50A,          12  Transfer Inst. Buses 23/               7.5              30            22.5
                                          270.                                 23A to alternate power.
                                        ----------------------------------------------------------------------------------------------------------------
                                         43A, 46A..................       13  Align charging pump                     32              75              43
                                                                               suction source to RWST.
--------------------------------------------------------------------------------------------------------------------------------------------------------
K......................................  60A 65A...................       14  Transfer 21 AFW to                    21.5              34            12.5
                                                                               Alternate Safe Shutdown
                                                                               System power source.
                                                                    ------------------------------------------------------------------------------------
                                                                          15  Open 21 AFW recirc. bypass             9.5              34            24.5
                                                                               valve BFD-77.
--------------------------------------------------------------------------------------------------------------------------------------------------------
P......................................  1.........................       16  Transfer 23 CCW pump to                 31             >60              29
                                                                               Alternate Safe Shutdown
                                                                               System power.
                                                                    ------------------------------------------------------------------------------------
                                                                          17  Start ARDG if normal power              17              60              43
                                                                               and offsite power are
                                                                               lost.
--------------------------------------------------------------------------------------------------------------------------------------------------------
YD.....................................  900.......................       18  Align charging pump makeup              28              75              47
                                                                               path to RCS.
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ Fire Areas are areas of fire origin; Indicated Fire Zones contain the cables or equipment whose damage due to fire may require implementation of the
  OMAs.
\2\ Operator Action ID designators (1, 2, 3 etc.) were assigned by the NRR reviewer.
\3\ Total of simulator-based diagnosis was added to the field-based time to travel to the OMA location, complete the OMA, confirm the action, and notify
  the CCR of completion as well as the 60-minute waiting period as discussed above.
\4\ Action A--Implementation of EOP 2-FR-H.l is not a requested OMA since these are proceduralized control room actions- identified here for
  completeness only.
\5\ Operators use procedure EOP 2-FR-H.1 to extend the available time.
\6\ OMAs determined to be infeasible or unreliable.

4.3 Reliability

    As stated in NUREG-1852, for a feasible action to be performed 
reliably, it should be shown that there is adequate time available to 
account for uncertainties not only in estimates of the time available, 
but also in estimates of how long it takes to diagnose and execute the 
OMAs (e.g., as based, at least in part, on a plant demonstration of the 
action under non-fire conditions). To confirm reliability, for each 
fire area having the potential to initiate the need for an OMA, the 
licensee considered uncertainties associated with estimating how long 
it takes to diagnose and execute operator manual actions.
    Where the licensee demonstrated that adequate margin was available, 
the required completion times noted in the table above provide 
reasonable assurance that the OMAs can reliably be performed under a 
wide range of conceivable conditions by different plant crews because 
the completion times, in conjunction with the available time margins 
associated with each action and other installed fire protection 
features, account for sources of uncertainty such as variations in fire 
and plant conditions, factors unable to be recreated in demonstrations 
and human-centered factors. As noted in the table above, several of the 
OMAs included in this review were found to be reliable because there is 
adequate time available to account for uncertainties not only in 
estimates of the time available, but also in estimates of how long it 
takes to diagnose a fire and execute the OMAs (e.g., as based, at least 
in part, on a plant demonstration of the actions under non-fire 
conditions). However, OMA 6 was found to be infeasible and 
therefore unreliable as well. Other OMAs were determined to be feasible 
but not reliable since only nominal margin is available to complete 
them. The OMA found to be infeasible and unreliable is indicated by a 
negative available margin value in the table above and those OMAs found 
to be feasible but unreliable are those indicated by footnote 
6 to the table above but with a positive available margin 
value.

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

    In summary, the defense-in-depth concept for a fire in the fire 
areas included in the table below provides a level of safety that 
results in the unlikely occurrence of fires; rapid detection, control, 
and extinguishment of fires that do occur; and the protection of 
structures, systems, and components important to safety. For these 
particular fire zones and the OMAs credited in them and found 
acceptable in Sections 3.0 and 4.0 above, the licensee has provided 
preventative and protective measures in addition to feasible and 
reliable OMAs that together demonstrate the licensee's ability to 
preserve or maintain SSD capability in the event of a fire in the 
analyzed fire areas. The

[[Page 7211]]

remaining zones included in the licensee's request were found to 
provide an inadequate level of defense-in-depth or safety margin and as 
such the requested OMAs for these zones are not approved for permanent 
use. The table below summarizes which fire zones are granted exemptions 
from III.G.2.

------------------------------------------------------------------------
                                     Area of fire     Exemption approved
            Fire zone                   origin        for this fire zone
------------------------------------------------------------------------
23..............................  C.................  Previous exemption
                                                       remains valid
5A..............................  F.................  No
6...............................  F.................  No
7A..............................  F.................  No
22A.............................  F.................  No
27A.............................  F.................  No
33A.............................  F.................  No
59A.............................  F.................  No
70A.............................  H.................  Yes
71A.............................  H.................  Yes
72A.............................  H.................  No
75A.............................  H.................  No
77A.............................  H.................  No
84A.............................  H.................  No
85A.............................  H.................  No
87A.............................  H.................  No
17..............................  J.................  Yes
19..............................  J.................  No
25..............................  J.................  No
39A.............................  J.................  No
43A.............................  J.................  No
45A.............................  J.................  No
46A.............................  J.................  No
47A.............................  J.................  No
50A.............................  J.................  No
270.............................  J.................  No
60A.............................  K.................  No
65A.............................  K.................  No
1...............................  P.................  Previous exemption
                                                       remains valid
900.............................  YD................  Yes
------------------------------------------------------------------------

4.5 Authorized by Law

    This exemption would allow IP2 to rely on specific OMAs, as 
discussed in Sections 3.0 and 4.0 above, in conjunction with the other 
installed fire protection features, to ensure that at least one means 
of achieving and maintaining safe shutdown remains available during and 
following a postulated fire event, as part of its fire protection 
program, in lieu of meeting the requirements specified in III.G.2 for a 
fire in the analyzed fire zones. As stated above, 10 CFR 50.12 allows 
the NRC to grant exemptions from the requirements of 10 CFR part 50. 
The NRC staff has determined that granting of this exemption, as 
limited by the staff's analysis will not result in a violation of the 
Atomic Energy Act of 1954, as amended, or the Commission's regulations. 
Therefore, the exemption is authorized by law.

4.6 No Undue Risk to Public Health and Safety

    The underlying purpose of 10 CFR part 50, Appendix R, Section III.G 
is to ensure that at least one means of achieving and maintaining safe 
shutdown remains available during and following a postulated fire 
event. Based on the above, no new accident precursors are created by 
the use of the specific OMAs, in conjunction with the other installed 
fire protection features, in response to a fire in the analyzed fire 
zones. Therefore, the probability of postulated accidents is not 
increased. Also based on the above, the consequences of postulated 
accidents are not increased. Therefore, there is no undue risk to 
public health and safety.

4.7 Consistent With Common Defense and Security

    This exemption would allow IP2 to credit the use of the specific 
OMAs, in conjunction with the other installed fire protection features, 
in response to a fire in the analyzed fire zones, discussed above, in 
lieu of meeting the requirements specified in III.G.2. This change to 
the operation of the plant has no relation to security issues. 
Therefore, the common defense and security is not diminished by this 
exemption.

4.8 Special Circumstances

    One of the special circumstances described in 10 CFR 
50.12(a)(2)(ii) is that the application of the regulation is not 
necessary to achieve the underlying purpose of the rule. The underlying 
purpose of 10 CFR part 50, Appendix R, Section III.G is to ensure that 
at least one means of achieving and maintaining safe shutdown remains 
available during and following a postulated fire event. While the 
licensee does not comply with the explicit requirements of Section 
III.G.2, the approved OMAs, in conjunction with the other installed 
fire protection features, provide a method to ensure that a train of 
equipment necessary to achieve and maintain safe shutdown of the plant 
will be available in the event of a fire in these fire zones. The NRC 
staff concludes that the application of the regulation is not necessary 
to achieve the underlying purpose of the rule for the plant 
configurations approved in this exemption. Therefore special 
circumstances exist, as required by 10 CFR 50.12(a)(2)(ii), that 
warrant the issuance of this exemption.

5.0 Conclusion

    Based on all of the features of the defense-in-depth concept 
discussed for the fire zones listed in Section 4.4 of this exemption, 
the NRC staff concludes that the use of specific OMAs found acceptable 
in Sections 3.0 and 4.0 of this evaluation, in these particular 
instances and in conjunction with the other installed fire protection 
features, in lieu of strict compliance with the requirements of 
III.G.2, will allow IP2 to meet the underlying purpose of the rule for 
those fire zones. The use of other specific OMAs in certain fire zones 
were found to be not acceptable, as discussed in Sections 3.0 and 4.0 
of this evaluation, and as such, are not approved by this exemption.
    Accordingly, the Commission has determined that, pursuant to 10 CFR 
50.12(a), the exemption is authorized by law, will not present an undue 
risk to the public health and safety, is consistent with the common 
defense and security and that special circumstances are present to 
warrant issuance of the exemption. Therefore, the Commission hereby 
grants Entergy an exemption from the requirements of Section III.G.2 of 
Appendix R of 10 CFR part 50, to utilize the OMAs approved above at 
IP2.
    Pursuant to 10 CFR 51.32, the Commission has determined that the 
granting of this exemption will not have a significant effect on the 
quality of the human environment (76 FR 74832).
    This exemption is effective upon issuance.

    Dated at Rockville, Maryland this first day of February, 2012.
    For the Nuclear Regulatory Commission.
Michele G. Evans,
Director, Division of Operating Reactor Licensing, Office of Nuclear 
Reactor Regulation.
[FR Doc. 2012-3124 Filed 2-9-12; 8:45 am]
BILLING CODE 7590-01-P