[Federal Register Volume 77, Number 31 (Wednesday, February 15, 2012)]
[Notices]
[Pages 8904-8926]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2012-3122]


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

NUCLEAR REGULATORY COMMISSION

[NRC-2011-0278; Docket No.: 50-286]


Entergy Nuclear Indian Point 3, LLC.; Entergy Nuclear Operations, 
Inc., Indian Point Nuclear Generating Unit 3; Exemption

1.0 Background

    Entergy Nuclear Operations, Inc. (Entergy or the licensee) is the 
holder of Facility Operating License No. DPR-64, which authorizes 
operation of Indian Point Nuclear Generating Unit 3 (IP3). 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.
    IP3 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) 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 IP3 was licensed to operate before 
January 1, 1979, IP3 is required to meet Section III.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 
III.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 AFW-6, ETN-4{1{time} , 
ETN-4{3{time} , PAB-2{3{time} , PAB-2{5{time} , TBL-5, and YARD-7. The 
table below provides the dates and topics of the submittals related to 
this request.

----------------------------------------------------------------------------------------------------------------
            Subject                    Author              Date              Description        ADAMS  accession
----------------------------------------------------------------------------------------------------------------
Exemption Request from Appendix  Entergy..........  March 6, 2009....  Original Submittal....  ML090760993
 R.
Revised Exemption Request......  Entergy..........  October 1, 2009..  Revision to March       ML092810230
                                                                        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         ML101320263
                                                                        staff's January 20,
                                                                        2010, RAI.
RAI 2.................  NRC..............  August 11, 2010..  RAI on reactor coolant  ML102180331
                                                                        system makeup,
                                                                        separation distances,
                                                                        etc.
RAI Response 2........  Entergy..........  September 29,      Response to the         ML102930234
                                                     2010.              staff's August 11,
                                                                        2010, RAI.
RAI 3.................  NRC..............  December 16, 2010  RAI on reactor coolant  ML103500204
                                                                        system makeup.
RAI Response 3........  Entergy..........  January 19, 2011.  Responses to the        ML110310242
                                                                        staff's December 16,
                                                                        2010, RAI.
Letter to revise previously      Entergy..........  February 10, 2011  Letter updating tables  ML110540322
 submitted information.                                                 contained in previous
                                                                        submittals.
Letter to revise previously      Entergy..........  May 26, 2011.....  Letter updating tables  ML11158A196
 submitted information.                                                 contained in previous
                                                                        submittals.
----------------------------------------------------------------------------------------------------------------


[[Page 8905]]

    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 III.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 IP3; 
specifically, Fire Areas AFW-6, ETN-4{1{time} , ETN-4{3{time} , PAB-
2{3{time} , PAB-2{5{time} , TBL-5, and YARD-7.

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.
    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 AFW-6, ETN-4{1{time} , ETN-4{3{time} , PAB-2{3{time} , PAB-
2{5{time} , TBL-5, and YARD-7.
    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:

----------------------------------------------------------------------------------------------------------------
                                                                  Fire zone  crediting
       OMA  No.         Area of fire origin       Area name              the OMA         Operator manual actions
----------------------------------------------------------------------------------------------------------------
1....................  AFW-6...............  Auxiliary Feedwater  23..................  Locally start 33 AFW
                                              (AFW) Pump Room.                           Pump via operation of
                                                                                         the Bus 6A circuit
                                                                                         breaker.
2....................  ETN-4{1{time} ......  Entrance to          7A..................  Swap 32 Component
                                              Electrical Tunnels.                        Cooling Water (CCW)
                                                                                         pump to alternate power
                                                                                         supply or align city
                                                                                         water to charging
                                                                                         pumps.
3....................                                             7A..................  Operate 480V Bus 3A
                                                                                         breaker locally to
                                                                                         start 31 AFW pump.
4....................                                             7A..................  Locally operate the
                                                                                         bypass valve for Flow
                                                                                         Control Valve (FCV)-
                                                                                         1121 in support of use
                                                                                         of 31 AFW pump.
5....................                                             60A.................  Operate HCV-1118
                                                                                         manually to control 32
                                                                                         AFW pump.
6....................                                             7A, 60A.............  Align Appendix R Diesel
                                                                                         Generator (ARDG) to 480
                                                                                         V Buses 2A, 3A, 5A, and
                                                                                         312.
7....................                                             7A, 60A.............  Swap 31 or 32 charging
                                                                                         pump to alternate power
                                                                                         supply.
8....................                                             7A, 60A.............  Locally operate FCV-
                                                                                         405B, FCV-405D, or FCV-
                                                                                         406B to control AFW
                                                                                         flow to Steam
                                                                                         Generators (SGs).
9....................                                             60A.................  Locally open valve 227
                                                                                         to establish charging
                                                                                         [previously ``CVCS'']
                                                                                         makeup flowpath to
                                                                                         Reactor Coolant System
                                                                                         (RCS).
10...................                                             60A.................  Locally close Level
                                                                                         Control Valve (LCV)-
                                                                                         112C and open valve 288
                                                                                         to align charging pump
                                                                                         suction to the
                                                                                         Refueling Water Storage
                                                                                         Tank (RWST).
11...................                                             60A.................  Locally operate Pressure
                                                                                         Control Valve (PCV)-
                                                                                         1139 to ensure steam
                                                                                         supply to 32 AFW pump.
12...................                                             60A.................  Locally operate PCV-
                                                                                         1310A and PCV-1310B to
                                                                                         ensure steam supply to
                                                                                         32 AFW pump.
13...................                                             60A.................  Locally manually perform
                                                                                         Service Water (SW) pump
                                                                                         strainer backwash as
                                                                                         required.
14...................  ETN-4{3{time} ......  Electrical Tunnel..  73A.................  Operate HCV-1118
                                                                                         manually to control 32
                                                                                         AFW pump.
15...................                                             73A.................  Locally operate PCV-1139
                                                                                         to ensure steam supply
                                                                                         to 32 AFW pump.
16...................                                             73A.................  Locally operate 32 PCV-
                                                                                         1310A, PCV-1310B to
                                                                                         ensure steam supply to
                                                                                         32 AFW pump.
17...................                                             73A.................  Locally operate FCV-405C
                                                                                         and FCV-405D to control
                                                                                         AFW flow to SG.
18...................  PAB-2{3{time} ......  Primary Auxiliary    6...................  Locally close valve LCV-
                                              Building; Charging                         112C and open valve 228
                                              Pump Rooms.                                to align charging pump
                                                                                         suction path to RWST.

[[Page 8906]]

 
19...................  PAB-2{5{time} ......  Primary Auxiliary    17A, 19A, 58A.......  Locally close supply
                                              Building.                                  breaker for 32 Charging
                                                                                         Pump [previously
                                                                                         ``CVCS''] Pump.
20...................                                             17A, 19A, 58A.......  Locally control 32
                                                                                         charging [previously
                                                                                         ``CVCS''] pump using
                                                                                         scoop tube positioner.
21...................                                             59A.................  Open bypass valve 227 to
                                                                                         establish charging
                                                                                         flowpath to RCS around
                                                                                         potentially failed
                                                                                         closed HCV-142.
22...................                                             17A, 20A, 27A, 30A..  Locally close LCV-112C
                                                                                         and open bypass valve
                                                                                         288 to establish
                                                                                         flowpath from RWST to
                                                                                         charging pump suction.
23...................  TBL-5...............  Turbine Building     52A.................  Locally operate [bypass
                                              and the AFW Pump                           valve for] FCV-1121 AFW
                                              Building.                                  pump recirculation
                                                                                         valve during pump
                                                                                         startup.
24...................                                             52A, 54A............  Locally operate FCV-406A
                                                                                         and FCV-406B to control
                                                                                         AFW flow to SGs.
25...................                                             37A, 38A, 43A, 44A..  Locally/manually
                                                                                         backwash SW pump
                                                                                         strainer as required if
                                                                                         power to strainer
                                                                                         associated with
                                                                                         selected SW pump is
                                                                                         lost (use one of STR
                                                                                         PMP-31 through STR PMP-
                                                                                         36).
26...................  YARD-7..............  External Yard Areas  22..................  Locally start ARDG to
                                              Intake Structure.                          supply Motor Control
                                                                                         Center (MCC) 312A in
                                                                                         support of the use of
                                                                                         SW pump 38.
27...................                                             22, 222.............  Locally/manually
                                                                                         backwash SW Pump
                                                                                         strainer as required if
                                                                                         power to strainer
                                                                                         associated with
                                                                                         selected SW pump is
                                                                                         lost.
----------------------------------------------------------------------------------------------------------------

    In their submittals, the licensee described elements of their fire 
protection program that provide their justification that the concept of 
defense-in-depth that is in place in the above fire areas is consistent 
with that intended by the regulation. To accomplish this, the licensee 
utilizes various protective measures to accomplish the concept of 
defense-in-depth. Specifically, the licensee stated that the purpose of 
their request was to credit the use of OMAs, in conjunction with other 
defense-in-depth features, in lieu of the separation and protective 
measures required by III.G.2 for a fire in the fire areas stated above.
    In their 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 AFW-6, 
ETN-4{1{time} , ETN-4{3{time} , PAB-2{3{time} , and PAB-2{5{time}  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, the licensee 
stated that with the exception of Fire Areas TBL-5 and YARD-7, all of 
the fire areas identified in the licensee's request are subject to the 
Indian Point Energy Center Transient Combustible Control Program, as 
implemented via procedure EN-DC-161, ``Control of Combustibles,'' and 
are controlled as Level 2 combustible control areas. The licensee also 
stated that Fire Area TBL-5, consisting of the Turbine Building and 
certain adjacent fire zones, does not contain safety-related 
structures, systems or components (SSCs) and is not subject to the 
explicit transient combustible controls of EN-DC-161 but that procedure 
OAP-017, ``Plant Surveillance and Operator Rounds'' includes inspection 
guidelines for operator rounds, which include monitoring for general 
area cleanliness, and for any housekeeping problems that may present a 
fire or safety concern. Consequently, operator rounds performed each 
shift provide for the monitoring of Area TBL-5 and other plant areas 
for accumulations of combustibles that could present an unacceptable 
fire safety challenge. Similarly, procedure ENMA-132, ``Housekeeping'' 
includes guidance for monitoring general area cleanliness as well as 
monitoring for accumulations of combustibles. The licensee stated that 
the administrative controls are described in the IP3 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 IP3. 
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 the non-IEEE-383-qualified 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 at 
Indian Point Nuclear Generating Unit 2 (IP2) 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-ignited cable fires is 
minimized by appropriately sized electrical protection devices (e.g., 
fuses and circuit breakers).
    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

[[Page 8907]]

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 March 6, 1979, 
and a supplement dated May 2, 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 non-rated fire barrier assemblies are only 
used or credited in Fire Area AFW-6 (Fire Zone 23), Fire Area ETN-4 
(Fire Zones 7A and 60A), and Fire Area PAB-2 (Fire Zone 27A) and that 
in each case, the fire resistive capability of the barrier was 
evaluated and found to be acceptable given other features and 
circumstances present in those zones.
    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 is 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 the December 16, 2010 RAI-
01.1, the NRC staff requested the licensee to describe the spatial 
separation between redundant trains of equipment. However, the 
licensee's response only provided information regarding the separation 
between ignition sources and safe shutdown equipment and not 
information regarding the separation between redundant trains of 
equipment within the area. For example, in its response to RAI-01.1 
dated January 19, 2011, the licensee stated that ``With respect to Item 
3 above, Entergy has provided cable routing dimensional details for the 
circuits of concern in the submittal dated September 29, 2010. However, 
it should be noted that in most cases, the dimensional data provided 
does not relate to the separation between redundant trains, but rather 
the location and separation from ignition sources for a single train 
that presents the potential for use of the credited OMA if that train 
is impacted by fire damage.'' 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 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. The licensee 
stated that since Fire Area TBL-5 did not contain safety-related 
systems or components, it was not addressed by this procedure. The NRC 
staff notes that the licensee requested OMAs for Fire Area TBL-5 area 
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 TBL-5 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

[[Page 8908]]

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 AFW-6--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 AFW-6 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 IP3 
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 cable insulation, small quantities of lube oil, electrical 
panels, and incident materials and Class A combustibles. The licensee 
also stated that the ignition sources in the area consist of cable 
runs, junction boxes, motors, pumps, and an electrical cabinet.
3.1.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 23 has an automatic, ionization 
smoke detection system throughout the zone that is designed and 
installed in accordance with National Fire Protection Association 
(NFPA) standard NFPA 72E--1974 edition. The licensee also stated that 
Fire Zone 23 has an automatic, wet-pipe fire suppression system 
throughout the zone that is designed and installed in accordance with 
NFPA 13--1983 Edition.
3.1.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 23 has a ceiling height of 
approximately 13'-0'' and an approximate floor area of 1,254 square 
feet. This fire zone contains the three AFW pumps (31, 32, and 33) 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. 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 AFW-6 (Fire Zone 23)
3.1.4.1 OMA 1--Locally Start 33 AFW Pump via Operation of the 
Bus 6A Circuit Breaker
    The licensee stated that cables AK3-PT2 and JB1-PT2/2 for the 33 
AFW pump are located in Fire Zone 23 in rigid steel conduit located 6.3 
to 12 feet above the floor and terminating in the AFW pump control 
panel. In addition, the licensee stated that ignition sources in the 
zone located less than 20 feet horizontally from cables AK3-PT2 and 
JB1-PT2/2 consist of an electrical cabinet separated from the cable by 
approximately 12.4 feet horizontally and that there are no intervening 
combustibles.
    The licensee also stated that cable JB1-X32/2, also for the 33 AFW 
pump, is located in Fire Zone 23 in rigid steel conduit that runs 
vertically from a junction box on the north wall for approximately 5.5 
feet and then horizontally in a tray located approximately 10.8 ft 
above the floor, before exiting the zone through the ceiling. In 
addition, the licensee stated that ignition sources in the zone located 
less than 20 feet horizontally from cable JB1-X32/2 consist of an AFW 
pump motor and two electrical cabinets. According to the licensee, the 
AFW pump motor is separated from the cable by approximately 8.2 feet 
horizontally, one electrical cabinet is located approximately 5.7 feet 
directly below the cable, and the other electrical cabinet is separated 
from the cable by approximately 9.8 feet horizontally. The licensee 
also stated that there are no intervening combustibles.
    The licensee also stated that cables LL7-X32, LQ7-X32, and X32-Y2J, 
also for the 33 AFW pump, are located in Fire Zone 23 in rigid steel 
conduit that runs from flow transmitters FC-1136S and FC-1136A-S 
located approximately 4.4 feet above the floor along the north wall 
terminating at a junction box located approximately 5 feet above the 
floor. In addition, the licensee stated that ignition sources in the 
zone located less than 20 feet horizontally from cables LL7-X32, LQ7-
X32, and X32-Y2J consist of two AFW pump motors, which are separated 
from the cables by approximately 7 feet horizontally and that there are 
no intervening combustibles.
    In the event that a fire occurs and a failure of the CCR control 
switch response or pump indication prompts operator action to 
investigate the breaker status at the switchgear, the licensee stated 
that OMA 1 is available to restore this function by starting 
the 33 AFW pump via local operation of the circuit breaker on Bus 6A, 
which is located in a different fire area. If OMA 1 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 13 
minutes while the time available is 30 minutes, which provides 12.5 
minutes of margin.
3.1.5 Conclusion for Fire Area AFW-6 (Fire Zone 23)
    The NRC staff had previously issued an exemption from III.G.2 for 
Fire Zone 23 in 1987 (ML003779008). In that exemption, the NRC staff 
found that the low fire load, the fire detection system, the automatic 
fire suppression system, and the distance between AFW pumps would 
provide reasonable assurance that one train of shutdown equipment would 
be available following a fire in this fire zone, including the use of 
OMA 1. The NRC staff concludes that OMA 1 remains 
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 ETN-4{1{time} --Electrical Tunnels (Fire Zone 7A--Lower 
Electrical Tunnel, Elevation 33'-0'')

3.2.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and incidental 
materials, and that there are no transient combustibles. The licensee 
also stated that the ignition sources in the area consist of cable 
runs.
3.2.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 7A has an area-wide ionization 
smoke detection system installed as well as thermal detection in the 
cable trays and that the systems were designed and installed in 
accordance with NFPA 72E, 1974 Edition. The licensee also stated that 
Fire Zone 7A has a dry-pipe, preaction fire suppression sprinkler 
system installed in the cable trays that was designed and installed in 
accordance with NFPA 13, 1978 Edition and NFPA 15, 1977 Edition.
3.2.3 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 6,386 square 
feet. As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.

[[Page 8909]]

3.2.4 OMAs Credited for a Fire in Fire Area ETN-4{1{time}  (Fire Zone 
7A)
3.2.4.1 OMA 2--Swap 32 Component Cooling Water (CCW) Pump To 
Alternate Power Supply or Align City Water to Charging Pumps
    The licensee stated that cable AS9-W1D for the 32 CCW pump is 
routed through Fire Zone 7A. The licensee also stated that there are no 
ignition sources, other than cables, located less than 20 feet 
horizontally from the cables. The licensee further stated that the 
postulated fire scenario would involve a transient combustible fire 
that causes a failure of the power cables to redundant CCW pumps 31 and 
33.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all CCW pumps, the licensee stated that OMA 
2 is available to restore this function by swapping the 32 CCW 
pump to its alternate power supply or aligning city water to cool the 
charging pumps. If OMA 2 becomes necessary, the licensee 
stated that they have assumed failure at the onset of the fire and that 
the required time to perform the action is 34 minutes while the time 
available is >60 minutes, which provides 26 minutes of margin.
3.2.4.2 OMA 3--Operate 480V Bus 3A Breaker Locally To Start 31 
AFW Pump
    The licensee stated that cables A15-PT2, JB1 -PT2/1, JB1 -X32/1 for 
the 31 AFW pump are all routed through Fire Zone 7A. The licensee also 
stated that there are no ignition sources, other than cables, located 
less than 20 feet horizontally from the cables. The licensee further 
stated that the postulated fire scenario would involve a transient 
combustible fire that causes a failure of cables serving the 31 AFW 
pump.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for the 31 AFW pump, the licensee stated that OMA 
3 is available to restore this function by operating a 480V 
bus 3A breaker locally to start the 31 AFW pump. 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 7 minutes while the time available is 30 minutes, which 
provides 18.5 minutes of margin.
3.2.4.3 OMA 4--Locally Operate FCV-1121 Bypass Valve in 
Support of Use of 31 AFW Pump
    The licensee stated that cables A15-PT2, JB1 -PT2/1, JB1 -X32/1 for 
the 31 AFW pump, and cable JB1 -X32/1 for valve FCV-1121, which allows 
recirculation flow for the 31 AFW pump, are all routed through Fire 
Zone 7A. The licensee also stated that there are no ignition sources, 
other than cables, located less than 20 feet horizontally from the 
cables. The licensee further stated that the postulated fire scenario 
would involve a transient combustible fire that causes a failure of 
cables serving valve FCV-1121.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW pumps, the licensee stated that OMA 
4 is available to restore recirculation flow by locally 
operating the bypass valve for FCV-1121 to support the use of the 31 
AFW pump. If OMA 4 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 7 minutes while the time available is 30 
minutes, which provides 18.5 minutes of margin.
3.2.4.4 OMA 6--Align Appendix R Diesel Generator (ARDG) to 480 
V Buses 2A, 3A, 5A, and 312
    The licensee stated that in the event of a loss of offsite power, 
the use of the ARDG is credited for supplying power to the 480V buses 
in the event of a fire in Fire Area ETN-4{1{time} . In the event that a 
fire occurs and causes a loss of the CCR control or indication for the 
buses, the licensee stated that OMA 6 is available to align 
the ARDG to 480V buses 2A, 3A, 5A, and 312. If OMA 6 becomes 
necessary, the licensee stated that they have assumed a loss of offsite 
power at the outset of the event and that the required time to perform 
the action is 50 minutes while the time available is 75 minutes, which 
provides 25 minutes of margin. The NRC staff notes that this is 
equivalent to implementing an alternate safe shutdown system in 
accordance with III.G.3 and does not qualify for a III.G.2 exemption as 
requested by the licensee.
3.2.4.5 OMA 7--Swap 31 or 32 Charging Pump To Alternate Power 
Supply
    The licensee stated that cables AH9-K1 B, AH9-PL2, and JA4-PL2/2 
for the 32 charging pump are all routed through Fire Zone 7A. The 
licensee also stated that there are no ignition sources, other than 
cables, located less than 20 feet horizontally from the cables. The 
licensee further stated that the postulated fire scenario would involve 
a transient combustible fire that causes a failure of cables serving 
charging pumps 31 and 32.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all charging pumps, the licensee stated that 
OMA 7 is available to restore this function by swapping the 31 
or 32 charging pump to its alternate power supply. If OMA 7 
becomes necessary, the licensee stated that they have assumed a 30-
minute diagnosis period and that the required time to perform the 
action is 8 minutes while the time available is 75 minutes, which 
provides 37 minutes of margin.
3.2.4.6 OMA 8--Locally Operate FCV-405B, FCV-405D, or FCV-406B 
To Control AFW Flow to Steam Generators
    The licensee stated that cables JB1-SX1/1, JF5-KV4, JF5-LL8, K45-
YM3, and K47-YM3 for valve FCV-406B, which controls the flow from the 
32 AFW pump to the 34 steam generator (SG), are all routed through Fire 
Zone 7A. The licensee also stated that there are no ignition sources, 
other than cables, located less than 20 feet horizontally from the 
cables. The licensee further stated that the postulated fire scenario 
would involve a transient combustible fire that causes a failure of 
cables serving the AFW pumps and valves.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW flow control valves, the licensee 
stated that OMA 8 is available to restore this function by 
locally operating FCV-405B, FCV-405D, or FCV-406B to control AFW flow 
to the steam generators. If OMA 8 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 30 minutes, which provides 8.5 minutes of margin.
3.2.5 Conclusion for Fire Area ETN-4{1{time}  (Fire Zone 7A)
    The NRC staff had previously issued exemptions for Fire Zone 7A in 
1987 (ML003779008) and in 1984 (ML003779284). In those exemptions, the 
NRC staff found that the fire detection system, the automatic fire 
suppression system, and the distance between redundant trains would 
provide reasonable assurance that one train of shutdown equipment would 
be available following a fire in this fire zone. The NRC staff finds 
the defense-in-depth features in this fire zone and the available time 
margin would allow the use of OMAs 2, 3, 4, and 7. However, 
based on new information in the current submittal the NRC staff finds 
that OMA 6 is equivalent to implementing an alternate safe 
shutdown system in accordance with III.G.3 and does not qualify for a 
III.G.2 exemption as requested by the licensee.

[[Page 8910]]

Also, OMA 8 has insufficient available time margin to allow 
for reliable performance considering the potential variables as 
discussed in NUREG-1852. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on these OMAs cannot be granted for Fire 
Zone 7A.

3.3 Fire Area ETN-4{1{time} --Electrical Tunnels (Fire Zone 60A--Upper 
Electrical Tunnel, Elevation 43'-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 and incidental materials and that 
there are no transient combustibles. The licensee also stated that the 
ignition sources in the area consist of cables.
3.3.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 60A has an area-wide, automatic 
ionization smoke detection system installed that was designed and 
installed in accordance with NFPA 72E, 1974 Edition. The licensee also 
stated that Fire Zone 60A has a dry-pipe, preaction sprinkler fire 
suppression system installed in the cable trays that was designed and 
installed in accordance with NFPA 13, 1978 Edition and NFPA 15, 1977 
Edition.
3.3.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 60A has a ceiling height of 
approximately 10'-0'' and an approximate floor area of 3,200 square 
feet. The licensee stated that cables and JB1-S99, JB1-X02, JB1-X02/1, 
and JB1-SZ6 for valves PCV-1310A and PCV-1310B (steam supply to the 32 
AFW pump), DE1-XV2 for 38 SW strainer, JB1-TA5 for valve HCV-1118 
(governor valve for the 32 AFW pump), AQ3-K1C, AQ3-PL2, JA2-PL2/1 for 
31 charging pump, JB1-KV6 for valve FCV-405B (32 AFW pump to 32 SG), 
JB1-KV8 for valve FCV-405D (32 AFW pump to 34 SG), JB5-X1J for valve 
HCV-142 (charging pump discharge to RCS loops), DD4-JB5 for valve LCV-
112C (volume control tank to charging pump suction), JB1-PT2/3 for 
valve PCV-1139 (steam supply to the 32 AFW pump), JB1-SX1/1, JF5-KV4, 
K45-YM3, K47-YM3, and JF5-LL8 for valve FCV-406B (31 AFW pump to the 32 
SG) are all routed through Fire Zone 60A. The licensee also stated that 
there are no ignition sources, other than cables, located less than 20 
feet horizontally from the cables. The licensee further stated that no 
cables associated with the 31 AFW pump, its flow control valves (FCV-
406A to 31 SG, FCV-406B to 32 SG), or its power source (Bus 3A) are 
routed through this fire area but that the protected instrumentation 
credited in this fire area for monitoring steam generator (SG) level is 
the instrumentation for the 33 SG and 34 SG, which would make the 31 
AFW pump an unsuitable choice if all level instrumentation for 31 and 
32 SG has been rendered inoperable by fire damage. The licensee also 
stated that the anticipated fire is a slow developing cable fire 
located in the cable trays. The licensee also stated that Conduit 1VA/
JA (source range flux N31 instrumentation) is protected with fire 
barrier wrap from penetration H-20 in Fire Zone 73A through the upper 
electrical tunnel. As discussed in Section 3.0 above, the licensee did 
not identify any separation between credited and redundant trains of 
equipment.
3.3.4 OMAs Credited for a Fire in Fire Area ETN-4{1{time}  (Fire Zone 
60A)
3.3.4.1 OMA 5--Operate HCV-1118 Manually To Control 32 AFW 
Pump
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW pumps, the licensee stated that OMA 
5 is available to restore this function by manually operating 
HCV-1118 to control the 32 AFW pump. If OMA 5 becomes 
necessary, the licensee stated that they have assumed a 4.5-minute 
diagnosis period following the failure and that the required time to 
perform the action is 17 minutes while the time available is 30 
minutes, which provides 8.5 minutes of margin.
3.3.4.2 OMA 6--Align Appendix R Diesel Generator to 480 V 
Buses 2A, 3A, 5A, and 312
    The licensee stated that in the event of a loss of offsite power, 
the use of the ARDG is credited for supplying power to the 480V buses 
in the event of a fire in Fire Area ETN-4{1{time} . In the event that a 
fire occurs and causes a loss of the CCR control or indication for the 
buses, the licensee stated that OMA 6 is available to align 
the ARDG to 480V buses 2A, 3A, 5A, and 312. If OMA 6 becomes 
necessary, the licensee stated that they have assumed a loss of offsite 
power at the outset of the event and that the required time to perform 
the action is 50 minutes while the time available is 75 minutes, which 
provides 25 minutes of margin. The NRC staff notes that this is 
equivalent to implementing an alternate safe shutdown system in 
accordance with III.G.3 and does not qualify for a III.G.2 exemption as 
requested by the licensee.
3.3.4.3 OMA 7--Swap 31 or 32 Charging Pump To Alternate Power 
Supply
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all charging pumps, the licensee stated that 
OMA 7 is available to restore this function by swapping the 31 
or 32 charging pump to its alternate power supply. If OMA 7 
becomes necessary, the licensee stated that they have assumed a 30-
minute diagnosis period and that the required time to perform the 
action is 8 minutes while the time available is 75 minutes, which 
provides 37 minutes of margin.
3.3.4.4 OMA 8--Locally Operate FCV-405B, FCV-405D, or FCV-406B 
To Control AFW Flow to Steam Generators
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW flow control valves, the licensee 
stated that OMA 8 is available to restore this function by 
locally operating FCV-405B, FCV-405D, or FCV-406B to control AFW flow 
to the SGs. If OMA 8 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 30 minutes, which provides 8.5 minutes of margin.
3.3.4.5 OMA 9--Locally Open Valve 227 To Establish Charging 
Makeup Flowpath to RCS
    The licensee stated that OMA 9 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, or pressurizer level channels are nonfunctional or 
erratic in operation. The licensee also stated that the anticipated 
fire is a slow developing cable fire located in the cable trays.
    In the event that a fire occurs and causes the normal flowpath 
valve HCV-142 to close, the licensee stated that OMA 9 is 
available to restore this function by locally opening bypass valve 227 
to establish the charging makeup flowpath to the RCS. If OMA 9 
becomes necessary, the licensee stated that they have assumed a 60-
minute period before re-entering the fire area, a 30-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period and that the required time to perform the action is 9 minutes 
while the time available is 75

[[Page 8911]]

minutes, which provides 6 minutes of margin.
3.3.4.6 OMA 10--Locally Close Valve LCV-112C and Open Valve 
288 To Align Charging Pump Suction to RWST
    The licensee stated that preemptive steps in procedure 3-ONOP-FP-1, 
``Plant Fires,'' for a fire scenario will trigger action via 3-AOP-SSD-
1, ``Control Room Inaccessibility Safe Shutdown Control,'' to locally 
verify the charging pump suction path and perform the stated OMA prior 
to starting a charging pump. 3-AOP-CVCS-1, ``Chemical And Volume 
Control System Malfunctions,'' provides guidance to be followed in the 
event that a swap of the charging pump suction to the RWST cannot be 
confirmed (i.e., loss of CCR indication for valves LCV-112C [volume 
control tank to charging pump suction] or LCV-112B [refueling water 
storage tank to charging pump suction]), which will also trigger the 
OMA. The licensee also stated that the anticipated fire is a slow 
developing cable fire located in the cable trays.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 10 is available to restore this function by 
locally closing valve LCV-112C and opening valve 288 to align the 
charging pump suction to the RWST. If OMA 10 becomes 
necessary, the licensee stated that they have assumed a 60-minute 
period before re-entering the fire area, a 30-minute diagnosis period, 
which is assumed to transpire during the 60-minute waiting period and 
that the required time to perform the action is 11 minutes while the 
time available is 75 minutes, which provides 4 minutes of margin.
3.3.4.7 OMA 11--Locally Operate PCV-1139 To Ensure Steam 
Supply to 32 AFW Pump
    The licensee stated that OMA 11 is only required if 32 AFW 
pump is selected as the credited pump and other OMAs related to the 31 
AFW pump are unsuccessful. The licensee also stated that the 
anticipated fire is a slow developing cable fire located in the cable 
trays.
    In the event that a fire occurs and causes a loss of AFW flow 
indication, loss of AFW pump, or loss of PCV-1139 indication from the 
CCR, the licensee stated that OMA 11 is available to restore 
this function by locally operating PCV-1139 to ensure a steam supply to 
the 32 AFW pump. If OMA 11 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 30 minutes, which provides 8.5 minutes of margin.
3.3.4.8 OMA 12--Locally Operate PCV-1310A and PCV-1310B To 
Ensure Steam Supply to 32 AFW Pump
    The licensee stated that OMA 12 is only required if the 32 
AFW pump is selected as the credited pump. The licensee also stated 
that the anticipated fire is a slow developing cable fire located in 
the cable trays.
    In the event that a fire occurs and causes a loss of steam supply 
as diagnosed during local operation of the 32 AFW pump, the licensee 
stated that OMA 12 is available to restore this function by 
locally operating PCV-1310A and 1310B to ensure a steam supply to the 
32 AFW pump. If OMA 12 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 30 minutes, which provides 8.5 minutes of margin.
3.3.4.9 OMA 13--Locally Manually Perform SW Pump Strainer 
Backwash, as Required
    In an inspection report dated July 11, 2011 (ML111920339), NRC 
inspectors identified that this OMA was inappropriate because it was 
too complex and beyond the limited scope of an OMA to achieve and 
maintain post-fire hot shutdown. Therefore, the NRC staff finds that it 
is inappropriate to approve this OMA.
3.3.5 Conclusion for Fire Area ETN-4{1{time}  (Fire Zone 60A)
    The NRC staff had previously issued exemptions for Fire Zone 60A in 
1987 (ML003779008) and in 1984 (ML003779284). In those exemptions, the 
NRC staff found that the fire detection system, the automatic fire 
suppression system, and the distance between redundant trains would 
provide reasonable assurance that one train of shutdown equipment would 
be available following a fire in this fire zone. The NRC staff finds 
the defense-in-depth features in this fire zone and the available time 
margin would allow the use of OMA 7. However, based on new 
information in the current submittal the NRC staff finds that OMA 
6 is equivalent to implementing an alternate safe shutdown 
system in accordance with III.G.3 and does not qualify for a III.G.2 
exemption as requested by the licensee. Also, the previous exemption 
requests did not mention that OMA 13, SW pump strainer 
backwash, was needed for the safe shutdown of the plant. Based on the 
discussion in section 3.3.4.9, the NRC staff finds it inappropriate to 
approve OMA 13. Also, OMAs 5, 8, 9, 10, 11, and 12 
have insufficient available time margin to allow for reliable 
performance considering the potential variables as discussed in NUREG-
1852. Therefore, the NRC staff finds that an exemption from III.G.2 
based on these OMAs cannot be granted for Fire Zone 60A.

3.4 Fire Area ETN-4{3{time} --Electrical Tunnels (Fire Zone 73A--Upper 
Electrical Penetration Area, Elevation 46'-0'')

3.4.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles are cable insulation and incidental 
materials and that there are no transient combustibles. The licensee 
also stated that the ignition sources in the area consist of cables, 
junction boxes, electrical cabinets, and a transformer.
3.4.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 73A has an area-wide, automatic 
ionization smoke detection system installed that was designed and 
installed in accordance with NFPA 72E, 1974 Edition. The licensee also 
stated that Fire Zone 73A has a dry-pipe, preaction sprinkler fire 
suppression system installed in the cable trays that was designed and 
installed in accordance with NFPA 13, 1978 Edition and NFPA 15, 1977 
Edition.
3.4.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 73A has a ceiling height of 
approximately 17'-0Prime; and an approximate floor area of 1,350 square 
feet. As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.
3.4.4 OMAs Credited for a Fire in Fire Area ETN-4{3{time}  (Fire Zone 
73A)
3.4.4.1 OMA 14--Operate HCV-1118 Manually To Control 32 AFW 
Pump
    The licensee stated that cable JBI-TA5 for valve HCV-1118 is 
located in Fire Zone 73A in a cable tray located approximately 13 to 14 
feet above the floor. The licensee also stated that ignition sources 
located less than 20 feet horizontally from the cable consist of cables 
and eight electrical cabinets. According to the licensee, two of the 
electrical cabinets are separated from the cable by approximately 5.7 
to 6.7

[[Page 8912]]

feet vertically and the remaining electrical cabinets are separated 
from the cable by approximately 5.3 feet horizontally. The licensee 
further stated that no cables associated with the 31 AFW pump, its flow 
control valves (FCV-406A, FCV-406B), or its power source (Bus 3A) are 
routed through this fire area, but that the protected instrumentation 
credited in this fire area for monitoring SG level is the 
instrumentation for the 33 SG and the 34 SG, which would make the 31 
AFW pump an unsuitable choice if all level instrumentation for 31 and 
32 SG has been rendered inoperable by fire damage. The licensee also 
stated that the anticipated fire is a slow developing cable fire 
located in the cable trays.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW pumps, the licensee stated that OMA 
14 is available to restore this function by manually operating 
HCV-1118 to control the 32 AFW pump. 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 30 minutes, which provides 8.5 
minutes of margin.
3.4.4.2 OMA 15--Locally Operate PCV-1139 To Ensure Steam 
Supply to 32 AFW Pump
    The licensee stated that cable JB1-PT2/3 for valve PCV-1139 is 
located in Fire Zone 73A in a cable tray located approximately 13 to 14 
feet above the floor. The licensee also stated that ignition sources 
located less than 20 feet horizontally from the cable consist of cables 
and eight electrical cabinets. According to the licensee, two of the 
electrical cabinets are separated from the cable by approximately 5.7 
to 6.7 feet vertically and the remaining electrical cabinets are 
separated from the cable by approximately 5.3 feet horizontally. The 
licensee further stated that OMA 15 is only required if 32 AFW 
pump is selected as the credited pump and other OMAs related to the 31 
AFW pump are unsuccessful. The licensee also stated that the 
anticipated fire is a slow developing cable fire located in the cable 
trays.
    In the event that a fire occurs and causes a loss of AFW flow 
indication, loss of AFW pump, or loss of PCV-1139 indication from the 
CCR, the licensee stated that OMA 15 is available to restore 
this function by locally operating PCV-1139 to ensure steam supply to 
the 32 AFW pump. 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 17 minutes while the time 
available is 30 minutes, which provides 8.5 minutes of margin.
3.4.4.3 OMA 16--Locally Operates PCV-1310A and PCV-1310B To 
Ensure Steam Supply to 32 AFW Pump
    The licensee stated that cables JB1-X02 and JB1-S99 for valves PCV-
1310A and PCV-1310B are located in Fire Zone 73A. The licensee also 
stated that ignition sources located less than 20 feet horizontally 
from the cables consist of cables and eight electrical cabinets. 
According to the licensee, two of the electrical cabinets are separated 
from the cables by approximately 5.7 to 6.7 feet vertically and the 
remaining electrical cabinets are separated from the cables by 
approximately 5.3 feet horizontally.
    The licensee also stated that cables JB1-XO2/1 and JB1-SZ6 for 
valves PCV-1310A and PCV-1310B are located in Fire Zone 73A in a cable 
tray located approximately 13 feet above the floor. The licensee also 
stated that ignition sources located less than 20 feet horizontally 
from the cables consist of cables and eight electrical cabinets. 
According to the licensee, three of the electrical cabinets are 
separated from the cables by at least 4 feet vertically, two electrical 
cabinets are separated from the cables by approximately 2.3 feet 
horizontally and 2.3 feet vertically, and the remaining three 
electrical cabinets are separated from the cables by approximately 10.2 
feet horizontally. The licensee further stated that OMA 16 is 
only required if the 32 AFW pump is selected as the credited pump. The 
licensee also stated that the anticipated fire is a slow developing 
cable fire located in the cable trays.
    In the event that a fire occurs and causes a loss of steam supply 
as diagnosed during local operation of the 32 AFW pump, the licensee 
stated that OMA 16 is available to restore this function by 
locally operating PCV-1310A and 1310B to ensure steam supply to the 32 
AFW pump. If OMA 16 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 30 minutes, which provides 8.5 minutes of margin.
3.4.4.4 OMA 17--Locally Operate FCV-405B, FCV-405D, or FCV-
406B To Control AFW Flow to Steam Generators
    The licensee stated that cables JB1-KV8 and JB1-KV7 for valves FCV-
405C and FCV-405D are located in Fire Zone 73A in a cable tray located 
approximately 13 to 14 feet above the floor. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cables consist of cables and eight electrical cabinets. According to 
the licensee, two of the electrical cabinets are separated from the 
cables by approximately 5.7 to 6.7 feet vertically and the remaining 
electrical cabinets are separated from the cables by approximately 5.3 
feet horizontally. The licensee further stated that the postulated fire 
scenario would involve a fire that causes damage to the cables serving 
the AFW FCVs in the area.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for all AFW flow control valves, the licensee 
stated that OMA 17 is available to restore this function by 
locally operating FCV-405B, FCV-405D, or FCV-406B to control AFW flow 
to the steam generators. If OMA 17 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 30 minutes, which provides 8.5 minutes of margin.
3.4.5 Conclusion for Fire Area ETN-4{3{time}  (Fire Zone 73A)
    The NRC staff had previously issued exemptions for Fire Zone 73A in 
1987 (ML003779008) and in 1984 (ML003779284). In those exemptions, the 
NRC staff found that the fire detection system, the automatic fire 
suppression system, the distance between redundant trains, and the use 
of the alternate safe shutdown system would provide reasonable 
assurance that one train of shutdown equipment would be available 
following a fire in this fire zone. In the current exemption request 
the licensee did not credit the alternate safe shutdown system, but 
instead proposed certain OMAs. The NRC staff finds that OMAs 
14, 15, 16, and 17 have insufficient available time margin to 
allow for reliable performance considering the potential variables as 
discussed in NUREG-1852. Therefore, the NRC staff finds that an 
exemption from III.G.2 based on these OMAs cannot be granted for Fire 
Zone 73A.

3.5 Fire Area PAB-2{3{time} --Primary Auxiliary Building (Fire Zone 6--
32 Charging Pump Room, Elevation 55'-0'')

3.5.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles are cable insulation, lube oil, and 
incidental materials and that transient combustibles consist of lube 
oil, solvent, grease, cleaning materials, wood, anti-

[[Page 8913]]

contamination clothing (anti-C's), and plastic. The licensee also 
stated that the ignition sources in the area consist of cables, a 
junction box, an electrical cabinet, a motor, and a pump.
3.5.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 6 has an area-wide, automatic 
ionization smoke detection system installed that was designed and 
installed in accordance with NFPA 72E, 1974 Edition but that Fire Zone 
6 does not have an automatic fire suppression system installed.
3.5.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 6 has a ceiling height of 
approximately 16'-0'' and an approximate floor area of 288 square feet. 
As discussed in Section 3.0 above, the licensee did not identify any 
separation between credited and redundant trains of equipment.
3.5.4 OMAs Credited for a Fire in Fire Area PAB-2{3{time}  (Fire Zone 
6)
3.5.4.1 OMA 18--Locally Close LCV-112C and Open Valve 288 To 
Align Charging Pump Suction Path to RWST
    The licensee stated that cable DD4-VN3 for valve LCV-112C is 
located in Fire Zone 6 in conduit located approximately 14 feet above 
the floor and terminates at LCV-112B, which is located approximately 
7.5 feet above the floor. The licensee also stated that ignition 
sources located less than 20 feet horizontally from the cable consist 
of cables, the charging pump motor, and a transfer switch. According to 
the licensee, the motor is separated from the cable by approximately 
13.8 feet horizontally and the transfer switch is separated from the 
cable by approximately 16 feet horizontally.
    The licensee also stated that cable DD4-VN3 is an interlock cable 
that interfaces with RWST outlet valve LCV-112B and that fire-induced 
failures of this cable could cause the spurious closure of LCV-112C. In 
addition, the licensee stated that preemptive steps in 3-ONOP-FP-1 to 
secure the 31 and 32 charging pumps early in the fire scenario will 
trigger action via 3-AOP-SSD-1 to locally verify charging pump suction 
path and perform OMA 18 prior to starting a charging pump. 3-
AOP-CVCS-1 provides guidance to be followed in the event that the swap 
of charging pump suction to the RWST cannot be confirmed (i.e., loss of 
CCR indication for valves LCV-112C or LCV-112B), which will also 
trigger OMA 18.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 18 is available to restore this function by 
locally closing LCV-112C and opening valve 288 to align the charging 
pump suction path to RWST. If OMA 18 becomes necessary, the 
licensee stated that they have assumed a 60-minute period before re-
entering the fire area, an 11-minute diagnosis period, which is assumed 
to transpire during the 60-minute waiting period, and that the required 
time to perform the action is 11 minutes while the time available is 75 
minutes, which provides 4 minutes of margin.
3.5.5 Conclusion for Fire Area PAB-2{3{time}  (Fire Zone 6)
    Although there is 4 minutes of margin available for OMA 
18, Fire Zone 6 has moderate combustible loading, lacks 
automatic fire suppression, and the licensee did not provide details 
regarding any discernable separation between the credited and redundant 
equipment so it is not clear that at least one train of equipment would 
remain free of fire damage during or following a fire event. The NRC 
staff finds that OMA 18 has insufficient available time margin 
to allow for reliable performance considering the potential variables 
as discussed in NUREG-1852. 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 6 and finds 
that OMA 18 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 OMA 18 cannot be granted for Fire Zone 
6.

3.6 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
17A--Elevation 55'-0', PAB Corridor)

3.6.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, incidental materials, 
cellulose, resin, hydrogen, rubber, and plastic and that transient 
combustibles consist of solvent, lube oil, cleaning materials, grease, 
paper, wood, anti-C's, and plastic. The licensee also stated that the 
ignition sources in the area consist of cables, junction boxes, motor 
control centers (MCCs), transformers, a water heater, lighting power 
supply, an instrument panel, and electrical cabinets.
3.6.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 17A has ionization smoke 
detectors installed in the under-floor area at MCC Nos. 36A, 36B, and 
37 and ultraviolet detectors in the MCC area but that Fire Zone 17A 
does not have an automatic fire suppression system installed. The 
licensee also stated that the fire detection systems were designed and 
installed in accordance with NFPA 72E, 1974 Edition.
3.6.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 17A has a ceiling height of 
approximately 16'-0'' and an approximate floor area of 6,386 square 
feet. The licensee also stated that there are fire barriers, in the 
form of marinate boards, installed over the cable trays.
    The licensee stated that cable DD4-VN3 for valve LCV-112C is 
located in Fire Zone 17A in a tray located approximately 14 feet above 
the floor. The licensee also stated that ignition sources located less 
than 20 feet horizontally from the cable consist of cables, MCC panels, 
lighting power panels, electrical cabinets, and instrument panels. 
According to the licensee, the MCCs and lighting power panels are 
separated from the cable by approximately 7.4 feet horizontally, three 
electrical cabinets are located under the cable separated by 
approximately 3.5 feet vertically, and the rest of the electrical 
cabinets are separated from the cabinet by approximately 5.6 feet 
horizontally. The licensee also stated that cable DD4-VN3 is an 
interlock cable that interfaces with RWST outlet valve LCV-112B and 
that fire-induced failures of this cable could cause the spurious 
closure of LCV-112C.
    The licensee also stated that cables DD4-VN5/1 and DD4-VN5/2 for 
valve LCV-112C are located in Fire Zone 17A in a tray located 
approximately 14 feet above the floor. The licensee also stated that 
ignition sources located less than 20 feet horizontally from the cable 
consist of cables, MCC panels, lighting power panels, electrical 
cabinets, and instrument panels. According to the licensee, the MCCs 
and lighting power panels are separated from the cables by 
approximately 7.4 feet horizontally, three electrical cabinets are 
located under the cables separated by approximately 3.5 feet 
vertically, and the rest of the electrical cabinets are separated from 
the cables by approximately 5.6 to 10 feet horizontally.

[[Page 8914]]

    The licensee also stated that cables AH9-PL2 and JA4-PL2/2 for the 
32 charging pump are located in Fire Zone 17A in a tray located 
approximately 10 to 12 feet above the floor. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cable consist of cables, an instrument panel, 21 electrical cabinets, 
and one dry transformer. According to the licensee, the instrument 
panel and 12 of the electrical cabinets are located under the cables 
separated from the cables by approximately 4.2 feet vertically, the 
remaining 9 electrical cabinets are separated from the cables by 
approximately 4.2 feet horizontally, and the dry transformer is 
separated from the cables by approximately 15.8 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.
3.6.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
17A)
3.6.4.1 OMA 19--Locally Close Supply Breaker for 32 Charging 
Pump
    In the event that a fire occurs and causes a failure of the CCR 
control switch response, or indicating lights prompt operators to 
investigate breaker status at the switchgear, the licensee stated that 
OMA 19 is available to restore this function by locally 
closing the supply breaker for the 32 charging pump. The supply breaker 
is located in a different fire area. If OMA 19 becomes 
necessary, the licensee stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 7 
minutes while the time available is 75 minutes, which provides 38 
minutes of margin.
3.6.4.2 OMA 20--Locally Control 32 Charging Pump Using Scoop 
Tube Positioner
    In the event that a fire occurs and causes damage to the cables 
serving both the 31 and 32 charging pumps or causes a loss of CCR pump 
control or pump status indication, the licensee stated that OMA 
20 is available to restore this function by locally 
controlling the 32 charging pump using the scoop tube positioner. If 
OMA 20 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 9 minutes while the time available is 75 minutes, 
which provides 36 minutes of margin.
3.6.4.3 OMA 22--Locally Close LCV-112C and Open Bypass Valve 
288 To Establish Flowpath From RWST to Charging Pump Suction
    The licensee stated that preemptive steps in procedure 3-ONOP-FP-1 
to secure the 31 and 32 charging pumps early in the fire scenario will 
trigger action via 3-AOP-SSD-1 to locally verify charging pump suction 
path and perform OMA 22 prior to starting a charging pump. 3-
AOP-CVCS-1 provides guidance to be followed in the event that swap of 
charging pump suction to RWST cannot be confirmed (i.e., loss of CCR 
indication for valves LCV-112C or LCV-112B), which will also trigger 
OMA 22.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 22 is available to restore this function by 
locally closing LCV-112C and open bypass valve 288 to establish a 
flowpath from the RWST to the charging pump suction. If OMA 22 
becomes necessary, the licensee stated that they have assumed a 60-
minute period before re-entering the fire area, a 30-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period and that the required time to perform the action is 11 minutes 
while the time available is 75 minutes, which provides 4 minutes of 
margin.
3.6.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 17A)
    There are 38 minutes of margin and 36 minutes of margin available 
for OMAs 19 and 20, respectively, automatic fire 
detection systems installed, and these two particular OMAs have 
sufficient time margin available. The staff finds that there is 
adequate defense-in-depth to support the use of OMAs 19 and 
20 for Fire Zone 17A and that OMAs 19 and 20 
are acceptable for this fire zone.
    Although there is 4 minutes of margin available for OMA 
22, Fire Zone 17A lacks automatic fire suppression, and the 
licensee did not provide details regarding any discernable separation 
between the credited and redundant equipment so it is not clear that at 
least one train of equipment would remain free of fire damage during or 
following a fire event. The NRC staff finds that OMA 22 has 
insufficient available time margin to allow for reliable performance 
considering the potential variables as discussed in NUREG-1852. 
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 17A and finds that an exemption 
from III.G.2 based on OMA 22 cannot be granted for Fire Zone 
17A. The NRC previously granted an exemption for Fire Zone 17A dated 
January 7, 1987 (ML003779008), but that exemption also credited the use 
of the IP3 alternate safe shutdown system. The IP3 alternate safe 
shutdown system was not evaluated here as the licensee only requested 
consideration for the OMAs.

3.7 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
19A--Waste Evaporator Room, Elevation 55'-0'')

3.7.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and incidental 
materials and that transient combustibles consist of wood, anti-C's, 
and plastic. The licensee also stated that the ignition sources in the 
area consist of cables, a junction box, transformers, and electrical 
cabinets.
3.7.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 19A does not have a fire 
detection or automatic fire suppression system installed.
3.7.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 19A has a ceiling height of 
approximately 16'-0'' and an approximate floor area of 602 square feet. 
The licensee stated that cables AH9-PL2 and JA4-PL2/2 for the 32 
charging pump are located in Fire Zone 19A in conduit located 
approximately 10 to 12 feet above the floor. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cable consist of cables, an instrument panel, 21 electrical cabinets, 
and a dry transformer. According to the licensee, the instrument panel 
and 12 of the electrical cabinets are located under the cables 
separated from the cables by approximately 4.2 feet vertically, the 
remaining 9 electrical cabinets are separated from the cables by 
approximately 4.2 feet horizontally, and the dry transformer is 
separated from the cables by approximately 15.8 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.

[[Page 8915]]

3.7.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
19A)
3.7.4.1 OMA 19--Locally Close Supply Breaker for 32 Charging 
Pump
    In the event that a fire occurs and causes a failure of the CCR 
control switch response or indicating lights prompt operators to 
investigate breaker status at the switchgear, the licensee stated that 
OMA 19 is available to restore this function by locally 
closing the supply breaker for the 32 charging pump. The supply breaker 
is located in a different fire area. If OMA 19 becomes 
necessary, the licensee stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 7 
minutes while the time available is 75 minutes, which provides 38 
minutes of margin.
3.7.4.2 OMA 20--Locally Control 32 Charging Pump Using Scoop 
Tube Positioner
    In the event that a fire occurs and causes damage to the cables 
serving both the 31 and 32 charging pumps or causes a loss of CCR pump 
control or pump status indication, the licensee stated that OMA 
20 is available to restore this function by locally 
controlling the 32 charging pump using the scoop tube positioner. If 
OMA 20 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 9 minutes while the time available is 75 minutes, 
which provides 36 minutes of margin.
3.7.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 19A)
    Although there is 38 minutes of margin and 36 minutes of margin 
available for OMAs 19 and 20, respectively, Fire Zone 
19A lacks fire detection and automatic suppression systems and the 
licensee did not provide details regarding any discernable separation 
between the credited and redundant equipment and clear and direct 
procedures that instruct operators to proactively perform the OMAs, so 
it is not clear that at least one train of equipment would remain free 
of fire damage during or following a fire event. 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 19A and finds that an exemption from III.G.2 based on OMAs 
19 and 20 cannot be granted for Fire Zone 19A.

3.8 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
20A--Sample Room, Elevation 55'-0'')

3.8.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles are cable insulation and incidental 
materials and that transient combustibles consist of wood, solvent, 
cleaning materials, anti-C's, and plastic. The licensee also stated 
that the ignition sources in the area consist of cables and junction 
boxes.
3.8.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 20A does not have a fire 
detection or automatic suppression system installed.
3.8.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 20A has a ceiling height of 
approximately 14'-6'' and an approximate floor area of 210 square feet. 
As discussed in Section 3.0 above, the licensee did not identify any 
separation between credited and redundant trains of equipment.
3.8.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
20A)
3.8.4.1 OMA 22--Locally Close LCV-112C and Open Bypass Valve 
288 To Establish Flowpath From RWST to Charging Pump Suction
    The licensee did not describe which SSD cables are routed through 
Fire Zone 20A. The licensee stated that preemptive steps in procedure 
3-ONOP-FP-1 to secure the 31 and 32 charging pumps early in the fire 
scenario will trigger action via 3-AOP-SSD-1 to locally verify charging 
pump suction path and perform OMA 22 prior to starting a 
charging pump. 3-AOP-CVCS-1 provides guidance to be followed in the 
event that swap of charging pump suction to RWST cannot be confirmed 
(i.e., loss of CCR indication for valves LCV-112C or LCV-112B), which 
will also trigger OMA 22.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 22 is available to restore this function by 
locally closing LCV-112C and open bypass valve 288 to establish a 
flowpath from the RWST to the charging pump suction. If OMA 22 
becomes necessary, the licensee stated that they have assumed a 60-
minute period before re-entering the fire area, a 30-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period and that the required time to perform the action is 11 minutes 
while the time available is 75 minutes, which provides 4 minutes of 
margin.
3.8.5 Conclusion for Fire Area PAB-2 (Fire Zone 20A)
    Although there is 4 minutes of margin available for OMA 
22, Fire Zone 20A lacks automatic fire detection and 
suppression systems and the licensee did not provide details regarding 
any discernible separation between the credited and redundant equipment 
so it is not clear that at least one train of equipment would remain 
free of fire damage during or following a fire event. The NRC staff 
finds that OMA 22 has insufficient available time margin to 
allow for reliable performance considering the potential variables as 
discussed in NUREG-1852. 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 20A and 
finds that an exemption from III.G.2 based on OMA 22 cannot be 
granted for Fire Zone 20A.

3.9 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
27A--Elevation 73'-0'' PAB Corridor)

3.9.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, incidental materials, 
cellulose, plastic, and a flammable liquid locker and that transient 
combustibles consist of lube oil, grease, paper, wood, solvent, 
cleaning materials, anti-C's, and plastic. The licensee also stated 
that the ignition sources in the area consist of cables, a transformer, 
a water heater, and junction boxes.
3.9.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 27A does not have a fire 
detection or automatic suppression system installed.
3.9.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 27A has a ceiling height of 
approximately 15'-6'' and an approximate floor area of 5,532 square 
feet. The licensee stated that cables DD4-VN5/1 and DD4-VN5/2 for valve 
LCV-112C are located in Fire Zone 27A in a conduit or tray located 
approximately 12 feet above the floor. The licensee also stated that 
ignition sources located less than 20 feet horizontally from the cable 
consist of cables, electrical cabinets, and a dry transformer. 
According to the licensee, one of the electrical cabinets is located

[[Page 8916]]

under the cables separated from the cables by approximately 6.8 feet 
vertically, the remaining electrical cabinets are separated from the 
cables by approximately 11.9 feet horizontally, and the dry transformer 
is located under the cables separated from the cables by approximately 
3.5 feet vertically. As discussed in Section 3.0 above, the licensee 
did not identify any separation between credited and redundant trains 
of equipment.
3.9.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
27A)
3.9.4.1 OMA 22--Locally Close LCV-112C and Open Bypass Valve 
288 To Establish Flowpath From RWST to Charging Pump Suction
    The licensee stated that preemptive steps in procedure 3-ONOP-FP-1 
to secure the 31 and 32 charging pumps early in the fire scenario will 
trigger action via 3-AOP-SSD-1 to locally verify charging pump suction 
path and perform OMA 22 prior to starting a charging pump. 3-
AOP-CVCS-1 provides guidance to be followed in the event that swap of 
charging pump suction to RWST cannot be confirmed (i.e., loss of CCR 
indication for valves LCV-112C or LCV-112B), which will also trigger 
OMA 22.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 22 is available to restore this function by 
locally closing LCV-112C and open bypass valve 288 to establish a 
flowpath from the RWST to the charging pump suction. If OMA 22 
becomes necessary, the licensee stated that they have assumed a 60-
minute period before re-entering the fire area, a 30-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period and that the required time to perform the action is 11 minutes 
while the time available is 75 minutes, which provides 4 minutes of 
margin.
3.9.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 27A)
    Although there is 4 minutes of margin available for OMA 
22, Fire Zone 27A lacks fire detection and automatic 
suppression systems and the licensee did not provide details regarding 
any discernable separation between the credited and redundant equipment 
so it is not clear that at least one train of equipment would remain 
free of fire damage during or following a fire event. The NRC staff 
finds that OMA 22 has insufficient available time margin to 
allow for reliable performance considering the potential variables as 
discussed in NUREG-1852. 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 27A and 
finds that an exemption from III.G.2 based on OMA 22 cannot be 
granted for Fire Zone 27A.

3.10 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
30A--Valve Corridor, Elevation 73'-0'')

3.10.1 Fire Prevention
    The licensee stated that the fire loading in this area is moderate 
and that the fixed combustibles are cable insulation and incidental 
materials and that transient combustibles consist of lube oil, grease, 
wood, solvent, cleaning materials, anti-C's, and plastic. The licensee 
also stated that the ignition sources in the area consist of cables.
3.10.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 30A does not have a fire 
detection or automatic suppression system installed.
3.10.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 30A has a ceiling height of 
approximately 17'-0'' and an approximate floor area of 171 square feet. 
The licensee stated that cables DD4-VN5/1 and DD4-VN5/2 for valve LCV-
112C are located in Fire Zone 30A in a conduit or tray located 
approximately 2.5 to 12 feet above the floor. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cable consist of cables, electrical cabinets, and a dry transformer. 
According to the licensee, the electrical cabinets are separated from 
the cables by approximately 1.8 feet horizontally and the dry 
transformer is located under the cables separated from the cables by 
approximately 0.1 feet horizontally. As discussed in Section 3.0 above, 
the licensee did not identify any separation between credited and 
redundant trains of equipment.
3.10.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
30A)
3.10.4.1 OMA 22--Locally Close LCV-112C and Open Bypass Valve 
288 To Establish Flowpath From RWST to Charging Pump Suction
    The licensee stated that preemptive steps in procedure 3-ONOP-FP-1 
to secure the 31 and 32 charging pumps early in the fire scenario will 
trigger action via 3-AOP-SSD-1 to locally verify charging pump suction 
path and perform OMA 22 prior to starting a charging pump. 3-
AOP-CVCS-1 provides guidance to be followed in the event that swap of 
charging pump suction to RWST cannot be confirmed (i.e., loss of CCR 
indication for valves LCV-112C or LCV-112B), which will also trigger 
OMA 22.
    In the event that a fire occurs and causes a loss of the CCR 
control or indication for valves LCV-112C or LCV-112B, the licensee 
stated that OMA 22 is available to restore this function by 
locally closing LCV-112C and open bypass valve 288 to establish a 
flowpath from the RWST to the charging pump suction. If OMA 22 
becomes necessary, the licensee stated that they have assumed a 60-
minute period before re-entering the fire area, a 30-minute diagnosis 
period, which is assumed to transpire during the 60-minute waiting 
period and that the required time to perform the action is 11 minutes 
while the time available is 75 minutes, which provides 4 minutes of 
margin.
3.10.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 30A)
    Although there is 4 minutes of margin available for OMA 
22, Fire Zone 30A has moderate combustible fuel loading, lacks 
fire detection and automatic suppression systems and the licensee did 
not provide details regarding any discernable separation between the 
credited and redundant equipment so it is not clear that at least one 
train of equipment would remain free of fire damage during or following 
a fire event. The NRC staff finds that OMA 22 has insufficient 
available time margin to allow for reliable performance considering the 
potential variables as discussed in NUREG-1852. 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 30A and finds that an exemption from III.G.2 based on OMA 
22 cannot be granted for Fire Zone 30A.

3.11 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
58A--Piping Tunnel, Elevation 41'-0'')

3.11.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and incidental 
materials and that transient combustibles consist of lube oil, grease, 
wood, solvent, cleaning materials, anti-C's, and plastic. The licensee 
also stated that the ignition sources in the area consist of cables.

[[Page 8917]]

3.11.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 58A has an area-wide, ionization 
smoke detection system designed and installed in accordance with NFPA 
72E, 1974 Edition but does not have an automatic fire suppression 
system installed.
3.11.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 58A has a ceiling height of 
approximately 10'-0'' to 12'-0'' and an approximate floor area of 1,400 
square feet. The licensee stated that cable K1B-W1B for the 32 charging 
pump is located in Fire Zone 58A in a tray located approximately 9.5 
feet above the floor. The licensee also stated that other than cables, 
there are no ignition sources located less than 20 feet from the cable. 
As discussed in Section 3.0 above, the licensee did not identify any 
separation between credited and redundant trains of equipment.
3.11.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
58A)
3.11.4.1 OMA 19--Locally Close Supply Breaker for 32 Charging 
Pump
    In the event that a fire occurs and causes a failure of the CCR 
control switch response, or indicating lights prompt operators to 
investigate breaker status at the switchgear, the licensee stated that 
OMA 19 is available to restore this function by locally 
closing the supply breaker for the 32 charging pump. The supply breaker 
is located in a different fire area. If OMA 19 becomes 
necessary, the licensee stated that they have assumed a 30-minute 
diagnosis period and that the required time to perform the action is 7 
minutes while the time available is 75 minutes, which provides 38 
minutes of margin.
3.11.4.2 OMA 20--Locally Control 32 Charging Pump Using Scoop 
Tube Positioner
    In the event that a fire occurs and causes damage to the cables 
serving both the 31 and 32 charging pumps or causes a loss of CCR pump 
control or pump status indication, the licensee stated that OMA 
20 is available to restore this function by locally 
controlling the 32 charging pump using the scoop tube positioner. If 
OMA 20 becomes necessary, the licensee stated that they have 
assumed a 30-minute diagnosis period and that the required time to 
perform the action is 9 minutes while the time available is 75 minutes, 
which provides 36 minutes of margin.
3.11.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 58A)
    Since there is 38 minutes of margin and 36 minutes of margin 
available for OMAs 19 and 20, respectively, an 
automatic smoke detection system installed, and these two particular 
OMAs have sufficient margin available, the staff finds that there is 
adequate defense-in-depth to support the use of OMAs 19 and 
20 for Fire Zone 58A and that OMAs 19 and 20 
are acceptable 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 is granted for Fire Zone 58A.

3.12 Fire Area PAB-2{5{time} --Primary Auxiliary Building (Fire Zone 
59A--Pipe Penetration Area, Elevation 41'-0'' and 51'-0'' of the Fan 
House)

3.12.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and incidental 
materials and that transient combustibles consist of grease, wood, 
cleaning materials, anti-C's, and plastic. The licensee also stated 
that the ignition sources in the area consist of cables and a junction 
box.
3.12.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 59A has an area-wide, ionization 
smoke detection system designed and installed in accordance with NFPA 
72E, 1974 Edition but does not have an automatic fire suppression 
system installed.
3.12.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 59A has a ceiling height of 
approximately 8'-0'' to 26'-0'' and an approximate floor area of 3,782 
square feet. The licensee stated that cables JB5-X1J and VK4-X1J for 
valve HCV-142 are located in Fire Zone 59A in a tray located 
approximately 6 to 26 feet above the floor. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cable consist of cables, an electrical cabinet, and 8 motors attached 
to motor-operated valves. According to the licensee, the electrical 
cabinet is located under the cables separated from the cables by 
approximately 2.6 feet vertically and the motors are separated from the 
cables by approximately 2.1 feet horizontally and no vertical 
separation. As discussed in Section 3.0 above, the licensee did not 
identify any separation between credited and redundant trains of 
equipment.
3.12.4 OMAs Credited for a Fire in Fire Area PAB-2{5{time}  (Fire Zone 
59A)
3.12.4.1 OMA 21--Open Bypass Valve 227 To Establish Charging 
Flow Path to RCS Around Potentially Failed Close HCV-142
    In the event that a fire occurs and causes normal flowpath valve 
HCV-142 to close, the licensee stated that OMA 21 is available 
to restore this function by opening bypass valve 227 to establish a 
charging flowpath to the RCS around the potentially failed close HCV-
142. If OMA 21 becomes necessary, the licensee stated that 
they have assumed a 60-minute period before re-entering the fire area, 
a 30-minute diagnosis period, which is assumed to transpire during the 
60-minute waiting period and that the required time to perform the 
action is 9 minutes while the time available is 75 minutes, which 
provides 6 minutes of margin.
3.12.5 Conclusion for Fire Area PAB-2{5{time}  (Fire Zone 59A)
    Although there is 6 minutes of margin available for OMA 
21, this OMA requires the operator to re-enter the fire area 
after the fire has been extinguished. Fire Zone 59A contains credible 
fire scenarios, lacks automatic fire suppression, and the licensee did 
not provide details regarding any discernable separation between the 
credited and redundant equipment and clear and direct procedures that 
instruct operators to proactively perform the OMA so it is not clear 
that at least one train of equipment would remain free of fire damage 
during or following a fire event. The NRC staff finds that OMA 
21 has insufficient available time margin to allow for 
reliable performance considering the potential variables as discussed 
in NUREG-1852. 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 59A and finds that an exemption 
from III.G.2 based on this OMA cannot be granted for Fire Zone 59A.

3.13 Fire Area TBL-5--Turbine Building (Fire Zone 37A--Ground Floor 
South, Elevation 15'-0'')

3.13.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, MCC switchgear, 
cellulose, plastic, lube oil, and a flammable liquid cabinet and that 
there are no transient combustibles. The licensee also stated that the 
ignition sources in the area consist of cables, a junction box, a 
battery with charger, electrical cabinets, transformers, a dryer,

[[Page 8918]]

6.9 kV switchgear vertical panels (potential high energy arcing fault 
(HEAF) source), and MCC vertical panels.
3.13.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 37A has ionization smoke 
detectors installed over MCC 34 and over the 6.9 kV switchgear, thermal 
detection in the battery and charger room, a wet-pipe sprinkler system 
installed throughout the area except over switchgear, and a wet pipe 
sprinkler system installed throughout the battery and charger room. The 
licensee also stated that the detection systems were designed and 
installed in accordance with NFPA 72E, 1974 Edition and the fire 
suppression systems were designed and installed in accordance with NFPA 
13, 1983 Edition.
3.13.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 37A has a ceiling height of 
approximately 119'-0'' (See TABLE RAI-GEN-15 of the licensee's May 4, 
2010, letter, ML101320263) and an approximate floor area of 5,838 
square feet. The licensee stated that cable AQ7-WF6 for the 31 SW 
strainer is routed through Fire Zone 37A in a tray located 
approximately 11.3 feet above the floor. The licensee also stated that 
ignition sources located less than 20 feet horizontally from the cable 
consist of cables, an MCC, 6.9 kV switchgear, and an electrical 
cabinet. According to the licensee, the MCC and 6.9 kV switchgear are 
located under the cable separated by approximately 3 feet vertically 
and the electrical cabinet is separated from the cable by approximately 
8.1 feet horizontally. As discussed in Section 3.0 above, the licensee 
did not identify any separation between credited and redundant trains 
of equipment.
3.13.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 37A)
3.13.4.1 OMA 25--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers. The licensee also stated that the anticipated fire is a 
slow developing cable fire located in the cable trays.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.
3.13.5 Conclusion for Fire Area TBL-5 (Fire Zone 37A)
    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 37A and finds that OMA 25 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 37A.

3.14 Fire Area TBL-5--Turbine Building (Fire Zone 38A--Chemical 
Laboratory, Elevation 15'-0'')

3.14.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, an MCC, cellulose, 
plastic, hydrogen, chemicals, and a flammable liquid cabinet and that 
there are no transient combustibles. The licensee also stated that the 
ignition sources in the area consist of an electrical cabinet and an 
MCC.
3.14.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 38A has an ionization smoke 
detector installed over MCC 32 and a wet-pipe sprinkler suppression 
system installed in the chemical storage area. The licensee also stated 
that the detection system was designed and installed in accordance with 
NFPA 72E, 1974 Edition and the fire suppression system was designed and 
installed in accordance with NFPA 13, 1983 Edition.
3.14.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 38A has a ceiling height of 
approximately 8'-0'' and an approximate floor area of 4,500 square 
feet. The licensee stated that cables AQ7-WF6 and WF6-Z99 for the 31 SW 
strainer are routed through Fire Zone 38A in a tray or conduit that 
traverses the area vertically. The licensee also stated that ignition 
sources located less than 20 feet horizontally from the cables consist 
of cables and 2 electrical cabinets. According to the licensee, the 
electrical cabinets are separated from the cables by approximately 11.8 
feet horizontally. The licensee further stated that the need to 
periodically backwash a selected SW strainer is variable depending on 
ultimate heat sink conditions and other factors and that the diagnostic 
indicator to perform the OMA is based on operator rounds monitoring 
pressure across SW strainers. The licensee also stated that the 
anticipated fire is a slow developing cable fire located in the cable 
trays. As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.
3.14.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 38A)
3.14.4.1 OMA 25--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.
3.14.5 Conclusion for Fire Area TBL-5 (Fire Zone 38A)
    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 37A and finds that OMA 25 is unacceptable 
for the purpose of

[[Page 8919]]

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 38A.

3.15 Fire Area TBL-5--Turbine Building (Fire Zone 43A--South End, 
Elevation 36'-9'')

3.15.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are paper, MCC switchgear, rubber, wood, 
plastic, cable insulation, and incident materials and that transient 
combustibles consist of lube oil, solvent, grease, cleaning materials, 
and wood. The licensee also stated that the ignition sources in the 
area consist of cables, junction boxes, exciter switchgear, 
transformers, and electrical cabinets.
3.15.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 43A has an automatic wet-pipe 
sprinkler system installed throughout the zone but does not have an 
automatic fire detection system installed. The licensee also stated 
that the fire suppression system was designed and installed in 
accordance with NFPA 13, 1983 Edition.
3.15.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 43A has a ceiling height of 
approximately 97'-0'' (See TABLE RAI-GEN-17 of the licensee's May 4, 
2010 letter, ML101320263) and an approximate floor area of 7,725 square 
feet. The licensee stated that cable AQ7-WF6 for the 31 SW strainer is 
routed through Fire Zone 43A in a tray located approximately 7.4 feet 
above the floor. The licensee also stated that ignition sources located 
less than 20 feet horizontally from the cable consist of cables and 2 
electrical cabinets. According to the licensee, the electrical cabinets 
are separated from the cable by approximately 1 foot horizontally. The 
licensee also stated that the anticipated fire is a slow developing 
cable fire located in the cable trays. As discussed in Section 3.0 
above, the licensee did not identify any separation between credited 
and redundant trains of equipment.
3.15.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 43A)
3.15.4.1 OMA 25--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.
3.15.5 Conclusion for Fire Area TBL-5 (Fire Zone 43A)
    Although Fire Zone 43A has an automatic wet-pipe sprinkler system 
installed, OMA 25 is not acceptable, Fire Zone 43A lacks 
automatic fire detection, and the licensee did not provide details 
regarding any discernable separation between the credited and redundant 
equipment, and clear and direct procedures that instruct operators to 
proactively perform the OMAs, so it is not clear that at least one 
train of equipment would remain free of fire damage during or following 
a fire event. 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 finds that OMA 
25 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 43A.

3.16 Fire Area TBL-5--Turbine Building (Fire Zone 44A--South End of 
Heater Bay, Elevation 36'-9'')

3.16.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are a flammable liquid cabinet, cellulose, 
rubber, wood, plastic, cable insulation, and incident materials and 
that transient combustibles consist of lube oil, solvent, grease, 
cleaning materials, and wood. The licensee also stated that the 
ignition sources in the area consist of cables, junction boxes, a dry 
transformer, and electrical cabinets.
3.16.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 44A does not have a fire 
detection or automatic suppression system installed.
3.16.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 44A has a ceiling height of 
approximately 29'-0'' and an approximate floor area of 5,625 square 
feet. The licensee stated that cable AQ7-WF6 for the 31 SW strainer is 
routed through Fire Zone 44A in a tray located approximately 7.4 feet 
above the floor. The licensee also stated that ignition sources located 
less than 20 feet horizontally from the cable consist of cables, an 
MCC, 6.9 kV switchgear, and electrical cabinets. The licensee also 
stated that the anticipated fire is a slow developing cable fire 
located in the cable trays. As discussed in Section 3.0 above, the 
licensee did not identify any separation between credited and redundant 
trains of equipment.
3.16.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 44A)
3.16.4.1 OMA 25--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.

[[Page 8920]]

3.16.5 Conclusion for Fire Area TBL-5 (Fire Zone 44A)
    Since OMA 25 is unacceptable and Fire Zone 44A lacks fire 
detection and automatic suppression and the licensee did not provide 
details regarding any discernable separation between the credited and 
redundant equipment and clear and direct procedures that instruct 
operators to proactively perform the OMA, it is not clear that at least 
one train of equipment would remain free of fire damage during or 
following a fire event. 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 44A and 
finds that OMA 25 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 44A.

3.17 Fire Area TBL-5--Turbine Building (Fire Zone 52A--Chemical 
Addition Area, Elevation 32'-6'' of AFW Bldg)

3.17.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, cellulose barrels, 
and rubber hose and that transient combustibles consist of lube oil, 
solvent, grease, cleaning materials, and wood. The licensee also stated 
that the ignition sources in the area consist of motors, compressors, 
and a water heater.
3.17.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 52A does not have a fire 
detection or automatic suppression system installed.
3.17.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 52A has a ceiling height of 
approximately 8'-6'' and an approximate floor area of 1,254 square 
feet. The licensee stated that cable JB1-X32/1 for valve FCV-1121 
(recirculation flow for the 31 AFW pump) is located in Fire Zone 52A in 
rigid steel conduit. The licensee also stated that ignition sources 
located less than 20 feet horizontally from the cable consist of 
cables, 2 motors, and 2 electrical cabinets. According to the licensee, 
the motors are separated from the cable by approximately 13.2 feet 
horizontally and the two electrical cabinets are separated from the 
cable by approximately 6.3 feet horizontally.
    The licensee stated that cable K45-YM3 for valves FCV-406A and FCV-
406B (31 AFW pump discharge to 31 SG and 32 SG) is located in Fire Zone 
52A in rigid steel conduit. The licensee also stated that ignition 
sources located less than 20 feet horizontally from the cables consist 
of cables, 2 motors, and 2 electrical cabinets. According to the 
licensee, the motors are separated from the cables by approximately 
13.2 feet horizontally and the two electrical cabinets are separated 
from the cables by approximately 6.3 feet horizontally.
    As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.
3.17.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 52A)
3.17.4.1 OMA 23--Locally Operate Bypass Valve for FCV-1121 AFW 
Pump Recirculation Valve During Pump Startup
    If a fire were to occur and cause a loss of CCR control or 
indication of FCV-1121 or cause the valve to close and all AFW flow 
control valves FCV-406A through 406D fail closed, the licensee stated 
that OMA 23 is available to restore this function by locally 
operating the bypass valve for FCV-1121 during pump startup. If OMA 
23 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 8 minutes while the time available is 30 minutes, 
which provides 17.5 minutes of margin.
3.17.4.2 OMA 24--Locally Operate FCV-406A and 406B To Control 
AFW Flow to SGs
    If a fire were to occur and cause a loss of CCR control or 
indication of FCV-1121 or cause the valve to close and all AFW flow 
control valves FCV-406A through 406D fail closed, the licensee stated 
that OMA 24 is available to restore this function by locally 
operating valves FCV-406A and FCV-406B to control AFW flow to the SGs. 
If OMA 24 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 30 
minutes, which provides 8.5 minutes of margin.
3.17.5 Conclusion for Fire Area TBL-5 (Fire Zone 52A)
    Although there is 17.5 minutes of margin and 8.5 minutes of margin 
available for OMAs 23 and 24, respectively, Fire Zone 
52A lacks fire detection and automatic suppression, and the licensee 
did not provide details regarding any discernable separation between 
the credited and redundant equipment and clear and direct procedures 
that instruct operators to proactively perform the OMAs so it is not 
clear that at least one train of equipment would remain free of fire 
damage during or following a fire event. The NRC staff finds that OMA 
24 has insufficient available time margin to allow for 
reliable performance considering the potential variables as discussed 
in NUREG-1852. 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 52A and finds that an exemption 
from III.G.2 based on these OMAs cannot be granted for Fire Zone 52A.

3.18 Fire Area TBL-5--Turbine Building (Fire Zone 54A--Main Boiler 
Feedwater Regulator Area, Elevation 18'-6'' of AFW Bldg)

3.18.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, incidental material, 
and a flammable liquid cabinet and that transient combustibles consist 
of lube oil, solvent, grease, cleaning materials, and wood. The 
licensee also stated that the ignition sources in the area consist of 
cables, motors, junction boxes, and an electrical cabinet.
3.18.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 54A does not have a fire 
detection or automatic suppression system installed.
3.18.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 54A has a ceiling height of 
approximately 70' and an approximate floor area of 1,088 square feet. 
The licensee stated that cable K45-YM3 for valves FCV-406A and FCV-406B 
are located in Fire Zone 54A in rigid steel conduit. As discussed in 
Section 3.0 above, the licensee did not identify any separation between 
credited and redundant trains of equipment.
3.18.4 OMAs Credited for a Fire in Fire Area TBL-5 (Fire Zone 54A)
3.18.4.1 OMA 24--Locally Operate FCV-406A and 406B To Control 
AFW Flow to SGs
    If a fire were to occur and cause a loss of CCR control or 
indication of FCV-1121 or cause the valve to close and all AFW flow 
control valves FCV-406A through 406D fail closed, the licensee

[[Page 8921]]

stated that OMA 24 is available to restore this function by 
locally operating valves FCV-406A and FCV-406B to control AFW flow to 
the SGs. If OMA 24 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 30 
minutes, which provides 8.5 minutes of margin.
3.18.5 Conclusion for Fire Area TBL-5 (Fire Zone 54A)
    Although there is 8.5 minutes of margin available for OMA 
24, Fire Zone 54A lacks fire detection and automatic fire 
suppression, and the licensee did not provide details regarding any 
discernable separation between the credited and redundant equipment and 
clear and direct procedures that instruct operators to proactively 
perform the OMAs so it is not clear that at least one train of 
equipment would remain free of fire damage during or following a fire 
event. The NRC staff finds that OMA 24 has insufficient 
available time margin to allow for reliable performance considering the 
potential variables as discussed in NUREG-1852. 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 54A and finds that an exemption from III.G.2 based on this 
OMA cannot be granted for Fire Zone 54A.

3.19 Fire Area YARD-7--Exterior Yard (Fire Zone 22--Screenwell Area)

3.19.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation, MCC switchgear, 
plastic, and incidental materials and that transient combustibles 
consist of lube oil, solvent, grease, cleaning materials, and wood. The 
licensee also stated that the ignition sources in the area consist of 
cables, a junction box, a transformer, motors, pumps, and an electrical 
cabinet.
3.19.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 22 has an area-wide, 
photoelectric smoke detection system that was designed and installed in 
accordance with NFPA 72E, 1987 Edition but does not have an automatic 
fire suppression system installed.
3.19.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 22 has an approximate floor area 
of 784 square feet. Service water pumps 31, 32, 33, 34, 35, and 36, 
pump discharge strainers 31-36, and their power cables are located in 
the metal enclosure that comprises this fire zone. Backup service water 
pumps 37, 38, and 39 are located over 100 feet away on the plant 
discharge canal with negligible fixed combustibles between the two 
groups of pumps. Although it is unlikely due to the low fire loading, a 
fire in this fire zone could potentially disable service water pumps 
31-36, which would render the three emergency diesel generators 
inoperable due to lack of cooling water, along with other safe shutdown 
equipment that requires cooling water. The licensee stated that in the 
case of a loss of offsite power in conjunction with the fire in Fire 
Zone 22, they could perform an OMA to start the ARDG and energize 
backup service water pump 38 to provide cooling water as needed. As 
discussed in Section 3.0 above, the licensee did not identify any 
separation between credited and redundant trains of equipment.
3.19.4 OMAs Credited for a Fire in Fire Area YARD-7 (Fire Zone 22)
3.19.4.1 OMA 26--Locally Start ARDG To Supply MCC 312A in 
Support of the Use of SW Pump 38
    In the event that a fire occurs and causes a loss of CCR control or 
indication for all SW pumps, the licensee stated that OMA 26 
is available to restore this function by locally starting the ARDG 
(which is air-cooled) to supply MCC 312A in order to energize the 38 
service water pump. If OMA 26 becomes necessary, the licensee 
stated that they have assumed a less than 1-minute diagnosis period and 
that the required time to perform the action is 25 minutes while the 
time available is greater than 60 minutes, which provides 35 minutes of 
margin. The NRC staff notes that this is equivalent to implementing an 
alternate safe shutdown system in accordance with III.G.3 and does not 
qualify for a III.G.2 exemption.
3.19.4.2 OMA 27--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.
3.19.5 Conclusion for Fire Area YARD-7 (Fire Zone 22)
    Since OMA 26 is a III.G.3 solution which does not qualify 
for a III.G.2 exemption, and the NRC staff has determined that OMA 
27 is an inappropriate OMA, and Fire Zone 22 lacks automatic 
fire suppression and the licensee did not provide details regarding any 
discernable separation between the credited and redundant equipment, it 
is not clear that at least one train of equipment would remain free of 
fire damage during or following a fire event. 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 22 and finds that an exemption from III.G.2 based on these 
OMAs cannot be granted for Fire Zone 22. The NRC previously granted an 
exemption for Fire Zone 22 dated January 7, 1987 (ML003779008), but 
that exemption was primarily associated with the use of the IP3 
Alternate Safe Shutdown System. The IP3 Alternate Safe Shutdown System 
was not evaluated here as the licensee only requested consideration for 
the OMAs.

3.20 Fire Area YARD-7--Exterior Yard (Fire Zone 222--Backup Service 
Water Pit)

3.20.1 Fire Prevention
    The licensee stated that the fire loading in this area is low and 
that the fixed combustibles are cable insulation and that there are no 
transient combustibles. The licensee also stated that the ignition 
sources in the area consist of motors and pumps.
3.20.2 Detection, Control, and Extinguishment
    The licensee stated that Fire Zone 222 does not have a fire 
detection or automatic fire suppression system installed.

[[Page 8922]]

3.20.3 Preservation of Safe Shutdown Capability
    The licensee stated that Fire Zone 222 is an open outdoor area. The 
licensee stated that cables C2B-XD6 and C2B-XD6/1 for the 38 SW pump 
are routed through Fire Zone 222 in conduit located approximately 13 
feet above the floor. The licensee also stated that ignition sources 
located less than 20 feet horizontally from the cables consist of 
cables and a temporary yard power station. According to the licensee, 
the temporary yard power station is separated from the cables by 
approximately 18 feet horizontally.
    The licensee also stated that cables MY1-PY1 and PY1-XV2 for the 38 
SW strainer are routed through Fire Zone 222. The licensee also stated 
that ignition sources located less than 20 feet horizontally from the 
cables consist of cables and three motors. According to the licensee, 
the motors are separated from the cables by approximately 13.2 feet 
horizontally.
    As discussed in Section 3.0 above, the licensee did not identify 
any separation between credited and redundant trains of equipment.
3.20.4 OMAs Credited for a Fire in Fire Area YARD-7 (Fire Zone 222)
3.20.4.1 OMA 27--Locally Manually Backwash SW Pump Strainer, 
as Required, if Power to Strainer Associated With Selected SW Pump Is 
Lost
    The licensee stated that the need to periodically backwash a 
selected SW strainer is variable depending on ultimate heat sink 
conditions and other factors and that the diagnostic indicator to 
perform the OMA is based on operator rounds monitoring pressure across 
SW strainers.
    In the event that a fire occurs and causes an increase in SW pump 
strainer differential pressure or a loss of power to the strainer 
associated with the selected SW pump, the licensee stated that OMA 
25 is available to restore this function by locally manually 
performing a SW pump strainer backwash. In an inspection report dated 
July 11, 2011 (ML111920339), NRC inspectors identified that this OMA 
was inappropriate because it was too complex and beyond the limited 
scope of an OMA to achieve and maintain post-fire hot shutdown. 
Therefore, the NRC staff finds that it is inappropriate to approve this 
OMA.
3.20.5 Conclusion for Fire Area YARD-7 (Fire Zone 222)
    Since Fire Zone 222 lacks fire detection and automatic suppression 
and the licensee did not provide details regarding any discernable 
separation between the credited and redundant equipment, it is not 
clear that at least one train of equipment would remain free of fire 
damage during or following a fire event. The NRC staff has also found 
that the use of OMA 27 is inappropriate. 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 222 and finds that OMA 27 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 222.

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 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/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 indicates 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 3-ONOP-FP-001 and 3-AOP-SSD-1. The OMAs required for the 
III.G.2 fire areas are directed by Off-Normal Operating Procedure 3-
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 3-AOP-SSD-1 to

[[Page 8923]]

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 IP3 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 Emergency Operating Procedures (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 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 
Section III.G.2 areas are considered to be bounded by the sequences 
represented by alternate shutdown (Section III.G.3) Fire Area A. With 
regard to staffing, the licensee stated that timed field walkthroughs 
of Abnormal Operating Procedure 3-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 operator manual actions required in implementing 
alternate shutdown procedure 3-AOP-SSD-1 bounds the smaller set of 
manual actions credited for coping with III.G.2 fire area scenarios and 
that most OMAs required for the III.G.2 fire areas are directed by Off-
Normal Operating Procedure 3-ONOP-FP-001.
    Additionally, the licensee stated that post-fire OMAs have been 
validated through timed operator walkthroughs, using as the basis an 
enveloping scenario addressed by 3-AOP-SSD-1. When utilizing 3-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 3-ONOP-FP-001. 
The licensee states that the timed walkthroughs of 3-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 further states 
that in addition to the validation of key OMAs credited in alternate 
SSD procedure 3-AOP-SSD-1, the plant simulator was utilized to perform 
evaluations of bounding III.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.

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 a PFSSD scenario.
    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 areas 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.

--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                                   Required                   Available
                Fire area                        Fire zones \1\        OMA ID             OMA Summary             time  (min)   Available      margin
                                                                         \2\                                          \3\      time  (min)      (min)
--------------------------------------------------------------------------------------------------------------------------------------------------------
AFW-6...................................  23.........................       1  Locally start 33 AFW Pump via             17.5           30          12.5
                                                                                operation of the Bus 6A circuit
                                                                                breaker.
--------------------------------------------------------------------------------------------------------------------------------------------------------
ETN-4{1{time} ..........................  7A.........................       2  Swap 32 Component Cooling Water           34            >60          26
                                                                                (CCW) pump to alternate power
                                                                                supply or align city water to
                                                                                charging pumps.
                                          7A.........................       3  Operate 480V Bus 3A breaker               11.5           30          18.5
                                                                                locally to start 31 AFW pump.

[[Page 8924]]

 
                                          7A.........................       4  Locally operate Flow Control              12.5           30          17.5
                                                                                Valve (FCV)-1121 in support of
                                                                                use of 31 AFW pump.
                                          60A........................       5  Operate HCV-1118 manually to              21.5           30       \4\ 8.5
                                                                                control 32 AFW pump.
                                          7A, 60A....................       6  Align Appendix R Diesel                   50             75      \5\ 25
                                                                                Generator (ARDG) to 480V Buses
                                                                                2A, 3A, 5A, and 312.
                                          7A, 60A....................       7  Swap 31 or 32 charging pump to            38             75          37
                                                                                alternate power supply.
                                          7A, 60A....................       8  Locally operate FCV-405B, FCV-            21.5           30       \4\ 8.5
                                                                                405D, or FCV-406B to control
                                                                                AFW flow to Steam Generators
                                                                                (SGs).
                                          60A........................       9  Locally open valve 227 to                 69             75       \4\ 6
                                                                                establish charging [previously
                                                                                ``CVCS'] makeup flowpath to
                                                                                Reactor Coolant System (RCS).
                                          60a........................      10  Locally close valve LCV-112C and          71             75       \4\ 4
                                                                                open valve 288 to align
                                                                                charging pump suction to the
                                                                                Refueling Water Storage Tank
                                                                                (RWST).
                                          60A........................      11  Locally operate PCV-1139 to               21.5           30       \4\ 8.5
                                                                                ensure steam supply to 32 AFW
                                                                                pump.
                                          60A........................      12  Locally operate PCV-1310A and             21.5           30       \4\ 8.5
                                                                                PCV-1310B to ensure steam
                                                                                supply to 32 AFW pump.
                                          60A........................      13  Locally manually perform Service         >75            >60           *
                                                                                Water (SW) pump strainer
                                                                                backwash as required.
--------------------------------------------------------------------------------------------------------------------------------------------------------
ETN-4{3{time} ..........................  73A........................      14  Operate HCV-1118 manually to              21.5           30       \4\ 8.5
                                                                                control 32 AFW pump.
                                          ...........................      15  Locally operate PCV-1139 to               21.5           30       \4\ 8.5
                                                                                ensure steam supply to 32 AFW
                                                                                pump.
                                          ...........................      16  Locally operate 32 PCV-1310A,             21.5           30       \4\ 8.5
                                                                                PCV-1310B to ensure steam
                                                                                supply to 32 AFW pump.
                                          ...........................      17  Locally operate FCV-405C and FCV-         21.5           30       \4\ 8.5
                                                                                405D to control AFW flow to SG.
--------------------------------------------------------------------------------------------------------------------------------------------------------
PAB-2{3{time} ..........................  6..........................      18  Locally close valve LCV-112C and          71             75       \4\ 4
                                                                                open valve 228 to align
                                                                                charging pump suction path to
                                                                                RWST.
--------------------------------------------------------------------------------------------------------------------------------------------------------
PAB-2{5{time} ..........................  17A, 19A, 58A,.............      19  Locally close supply breaker for          37             75          38
                                                                                32 Charging Pump [previously
                                                                                ``CVCS''] Pump.
                                          17A, 19A, 58A..............      20  Locally control 32 charging               39             75          36
                                                                                [previously ``CVCS''] pumps
                                                                                using scoop tube positioner.
                                          59A........................      21  Open bypass valve 227 to                  69             75       \4\ 6
                                                                                establish charging flowpath to
                                                                                RCS around potentially failed
                                                                                closed HCV-142.
                                          17A, 20A, 27a, 30A.........      22  Locally Close LCV-112C and open           71             75       \4\ 4
                                                                                bypass valve 288 to establish
                                                                                flowpath from RWST to charging
                                                                                pump suction.
--------------------------------------------------------------------------------------------------------------------------------------------------------
TBL-5...................................  52A........................      23  Locally operate [bypass valve             12.5           30          17.5
                                                                                for] FCV-1121 AFW pump
                                                                                recirculation valve during pump
                                                                                startup.
                                          52A, 54A...................      24  Locally operate FCV-406A and FCV-         21.5           30       \4\ 8.5
                                                                                406B to control AFW flow to SGs.
                                          37A, 38A, 43A, 44A.........      25  Locally/manually backwash SW             >75            >60           *
                                                                                pump strainer as required if
                                                                                power to strainer associated
                                                                                with selected SW pump is lost
                                                                                (use one of STR PMP-31 through
                                                                                STR PMP-36).
--------------------------------------------------------------------------------------------------------------------------------------------------------
YARD-7..................................  22.........................      26  Locally start ARDG to supply              25            >60     \5\ >35
                                                                                Motor Control Center (MCC) 312A
                                                                                in support of the use of SW
                                                                                pump 38.

[[Page 8925]]

 
                                          22, 222....................      27  Locally/manually backwash SW             >75            >60           *
                                                                                Pump strainer as required if
                                                                                power to strainer associated
                                                                                with selected SW pump is lost.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Not acceptable.
\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\ OMAs found to be feasible but unreliable.
\5\ OMAs associated with III.G.3.

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). Other OMAs were determined to be feasible but not reliable 
since only nominal margin is available to complete them. Those OMAs 
found to be feasible but unreliable are those indicated by footnote 
4 to the table above.

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 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 for
           Fire zone                origin           this fire zone
------------------------------------------------------------------------
23............................  AFW-6          Previous exemption
                                                remains valid.
7A............................  ETN-4{1{time}  No.
 
60A...........................  ETN-4{1{time}  No.
 
73A...........................  ETN-4{3{time}  No.
 
6.............................  PAB-2{3{time}  No.
 
17A...........................  PAB-2{5{time}  No.
 
19A...........................  PAB-2{5{time}  No.
 
20A...........................  PAB-2{5{time}  No.
 
27A...........................  PAB-2{5{time}  No.
 
30A...........................  PAB-2{5{time}  No.
 
58A...........................  PAB-2{5{time}  Yes.
 
59A...........................  PAB-2{5{time}  No.
 
37A...........................  TBL-5          No.
38A...........................  TBL-5          No.
43A...........................  TBL-5          No.
44A...........................  TBL-5          No.
52A...........................  TBL-5          No.
54A...........................  TBL-5          No.
22............................  YARD-7         No.
222...........................  YARD-7         No.
------------------------------------------------------------------------

4.5 Authorized by Law

    This exemption would allow IP3 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 areas. As stated above, 10 CFR 50.12 allows 
the NRC to grant exemptions from the requirements of 10 CFR part 50. 
The NRC staff has determined that granting of this exemption will not 
result in a violation of the Atomic Energy Act of 1954, as amended, or 
the Commission's regulations. Therefore, the exemption is authorized by 
law.

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 
areas. Therefore, the probability of postulated accidents is not 
increased. Also based on the above, the consequences of postulated 
accidents are not increased. Therefore, there is no undue risk to 
public health and safety.

4.7 Consistent With Common Defense and Security

    This exemption would allow IP3 to credit the use of the specific 
OMAs, in conjunction with the other installed fire protection features, 
in response to a fire in the analyzed fire areas, discussed above, in 
lieu of meeting the requirements specified in III.G.2. This

[[Page 8926]]

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 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 IP3 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 
IP3.
    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. 2012-3122 Filed 2-14-12; 8:45 am]
BILLING CODE 7590-01-P