19476 Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices 

Use of the Information: For NSF Form 

192, information will be used in order 

to verify eligibility and qualifications for 

the award. For NSF Form 250, 

information will be used to verify 

attendance at Advanced Study Institute 

and will be included in Division 

reports. 

Estimate of Burden: Form 192—1.5 

hours; Form 250—2 hours 

Respondents: Individuals. 

Estimated Number of Responses per 

Award: 150 responses, broken down as 

follows: For NSF Form 250, 75 

respondents; for NSF Form 192, 75 

respondents. 

Estimated Total Annual Burden on 

Respondents: 262.5 hours, broken down 

by 150 hours for NSF Form 250 (2 hours 

per 75 respondents); and 112.5 hours for 

NSF Form 192 (1.5 hours per 75 

respondents). 

Frequency of Responses: Annually. 

Comments: Comments are invited on 

(a) whether the proposed collection of 

information is necessary for the proper 

performance of the functions of the 

Agency, including whether the 

information shall have practical utility; 

(b) the accuracy of the Agency’s 

estimate of the burden of the proposed 

collection of information; (c) ways to 

enhance the quality, utility, and clarity 

of the information on respondents, 

including through the use of automated 

collection techniques or other forms of 

information technology; or (d) ways to 

minimize the burden of the collection of 

information on those who are to 

respond, including through the use of 

appropriate automated, electronic, 

mechanical, or other technological 

collection techniques or other forms of 

information technology. 

Dated: April 4, 2011. 

Suzanne H. Plimpton, 

Reports Clearance Officer, National Science 

Foundation. 

[FR Doc. 2011–8277 Filed 4–6–11; 8:45 am] 

BILLING CODE 7555–01–P 

NUCLEAR REGULATORY 

COMMISSION 

[Docket Nos. 50–277 and 50–278; NRC– 

2010–0303] 

Exelon Generation Company, LLC, 

Peach Bottom Atomic Power Station, 

Unit Nos. 2 and 3; Exemption 

1.0 Background 

Exelon Generation Company, LLC (the 

licensee, Exelon) is the holder of 

Renewed Facility Operating License 

Nos. DPR–44 and DPR–56, which 

authorizes operation of the Peach 

Bottom Atomic Power Station (PBAPS), 

Units 2 and 3. The license provides, 

among other things, that the facility is 

subject to all rules, regulations, and 

orders of the Nuclear Regulatory 

Commission (NRC, the Commission) 

now or hereafter in effect. 

The facility consists of two boilingwater reactors located partly in Peach 

Bottom Township, York County, partly 

in Drumore Township, Lancaster 

County, and partly in Fulton Township, 

Lancaster County, in southeastern 

Pennsylvania. 

2.0 Request/Action 

Title 10 of the Code of Federal 

Regulations (10 CFR), Part 50, Section 

50.48(b), requires that nuclear power 

plants that were licensed 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.’’ PBAPS, 

Units 2 and 3 were licensed to operate 

prior to January 1, 1979. As such, the 

licensee’s Fire Protection Program (FPP) 

must provide the established level of 

protection as intended by Section III.G 

of 10 CFR Part 50, Appendix R. 

By letter dated March 6, 2009, 

‘‘Request for Exemption from 10 CFR 50, 

Appendix R, Section III.G, ‘Fire 

Protection of Safe Shutdown 

Capability’ ’’ available at Agencywide 

Documents Access and Management 

System (ADAMS), Accession No. 

ML090680141, and supplemented by 

letter dated February 12, 2010, 

‘‘Response to Request for Additional 

Information Request for Exemption from 

10 CFR 50, Appendix R, Section III.G, 

‘Fire Protection of Safe Shutdown 

Capability’ ’’ (ADAMS Accession No. 

ML100470774), the licensee requested 

an exemption for PBAPS, Units 2 and 3, 

from certain technical requirements of 

10 CFR Part 50, Appendix R, Section 

III.G.2 (III.G.2) for the use of operator 

manual actions (OMAs) in lieu of 

meeting the circuit separation and 

protection requirements contained in 

III.G.2 for Fire Areas 2, 6N, 6S, 13N, 26, 

30, 36, 37, 43, 50, and 58 at the plant. 

3.0 Discussion 

Pursuant to 10 CFR 50.12, the 

Commission may, upon application by 

any interested person or upon its own 

initiative, grant exemptions from the 

requirements of 10 CFR Part 50 when: 

(1) The exemptions are authorized by 

law, will not present an undue risk to 

public health or safety, and are 

consistent with the common defense 

and security; and (2) when special 

circumstances are present. The licensee 

has stated that special circumstances are 

present in that the application of the 

regulation in this particular 

circumstance is not necessary to achieve 

the underlying purpose of the rule, 

which is consistent with the language 

included in 10 CFR 50.12(a)(2)(ii). 

In letters dated March 6, 2009, and 

February 12, 2010, the licensee 

discussed financial implications 

associated with plant modifications that 

may be necessary to comply with the 

regulation. 10 CFR 50.12(a)2(iii) states 

that if such costs have been shown to be 

significantly in excess of those 

contemplated at the time the regulation 

was adopted, or are significantly in 

excess of those incurred by others 

similarly situated, this may be 

considered a basis for considering an 

exemption request. However, financial 

implications were not considered in the 

regulatory review of the request since no 

substantiation was provided regarding 

such financial implications. Even 

though no financial substantiation was 

provided, the licensee did submit 

sufficient regulatory basis to support a 

technical review of the exemption 

request in that the application of the 

regulation in this particular 

circumstance is not necessary to achieve 

the underlying purpose of the rule. 

In accordance with 10 CFR 50.48(b), 

nuclear power plants licensed before 

January 1, 1979, are required to meet 

Section III.G, of 10 CFR Part 50, 

Appendix R. The underlying purpose of 

Section III.G of 10 CFR Part 50, 

Appendix R, is to ensure that the ability 

to achieve and maintain safe shutdown 

is preserved following a fire event. The 

regulation intends for licensees to 

accomplish this by extending the 

concept of defense-in-depth to: 

(1) Prevent fires from starting; 

(2) Rapidly detect, control, and 

extinguish promptly those fires that do 

occur; 

(3) Provide protection for structures, 

systems, and components important to 

safety, so that a fire that is not promptly 

extinguished by the fire suppression 

activities will not prevent the safe 

shutdown of the plant. 

The stated purpose of 10 CFR Part 50, 

Appendix R, Section III.G.2 (III.G.2) is to 

ensure that one of the redundant trains 

necessary to achieve and maintain hot 

shutdown conditions remains free of 

fire damage in the event of a fire. III.G.2 

requires one of the following means to 

ensure that a redundant train of safe 

shutdown cables and equipment is free 

of fire damage, where redundant trains 

are located in the same fire area outside 

of primary containment: 

a. Separation of cables and equipment 

by a fire barrier having a 3-hour rating; 

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b. Separation of cables and equipment 

by a horizontal distance of more than 20 

feet with no intervening combustibles or 

fire hazards and with fire detectors and 

an automatic fire suppression system 

installed in the fire area; or 

c. Enclosure of cables and equipment 

of one redundant train in a fire barrier 

having a 1-hour rating and with fire 

detectors and an automatic fire 

suppression system installed in the fire 

area. 

Exelon has requested an exemption 

from the requirements of III.G.2 for 

PBAPS, Units 2 and 3 to the extent that 

one of the redundant trains of systems 

necessary to achieve and maintain hot 

shutdown is not maintained free of fire 

damage in accordance with one of the 

required means, for a fire occurring in 

Fire Areas 2 (Radwaste Building), 6S 

(Unit 2 Reactor Building), 6N (Unit 2 

Reactor Building, North side), 13N (Unit 

3 Reactor Building), 26 (Unit 3 MotorGenerator (MG) Set Ventilation 

Equipment Room), 30 (Unit 3 B/D 

Battery Room), 36 (E42 Switchgear 

Room), 37 (E22 Switchgear Room), 43 

(E–4 Emergency Diesel Generator 

Room), 50 (Turbine Building), and 58 

(Unit 3 MG Set Room). 

In its submittals, the licensee 

described elements of the FPP that 

provide 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. 

Specifically, the licensee stated that the 

purpose of its 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. 

3.1 Fire Prevention 

In its March 6, 2009, and February 12, 

2010, letters, the licensee provided an 

analysis that described how fire 

prevention is addressed for each of the 

fire areas for which the OMAs may be 

required. Unless noted otherwise in 

Section 3.4 below, all of the fire areas 

included in this exemption have a 

combustible fuel load that is considered 

to be low with fuel sources consisting 

primarily of fire retardant cable 

insulation and limited floor-based 

combustibles. Unless noted otherwise, 

there are no high energy ignition 

sources located in the areas. The fire 

areas included in the exemption are not 

shop areas, so hot work activities are 

infrequent with administrative control 

programs (e.g., hot work permits, fire 

watch, and supervisory controls). The 

administrative control programs are 

described in the PBAPS FPP, which is 

incorporated into the Updated Final 

Safety Analysis Report. 

3.2 Detection, Control and 

Extinguishment 

PBAPS has been divided into fire 

areas, as described in the PBAPS FPP. 

Three-hour fire barriers are normally 

used to provide fire resistive separation 

between adjacent fire areas. In some 

cases, barriers with a fire resistance 

rating of less than 3 hours are credited, 

but exemptions have been approved or 

engineering evaluations performed in 

accordance with Generic Letter 86–10, 

‘‘Implementation of Fire Protection 

Requirements,’’ to demonstrate that the 

barriers are sufficient for the hazard. 

Walls separating rooms and zones 

within fire areas are typically 

constructed of concrete. In addition to 

these boundaries, the licensee provided 

a hazard analysis that described how 

detection, control, and extinguishment 

of fire are addressed for each of the fire 

areas for which the OMAs may be 

required. 

Unless noted otherwise below, fire 

areas are provided with ionization 

smoke detectors in various locations 

within a particular fire area. Although 

not installed in accordance with a 

recognized standard with regard to 

spacing, the detectors are located near 

equipment such that they are likely to 

adequately detect a fire. Upon detecting 

smoke, the detectors initiate an alarm in 

the Control Room enabling fire brigade 

response. The licensee stated that in 

most cases, no automatic fire 

suppression systems are provided in the 

areas included in this exemption but 

that fire suppression systems are 

installed in plant areas with significant 

fire hazards, such as lube oil. 

Suppression systems have also been 

installed in areas with 1-hour barrier 

walls and 1-hour rated electrical 

raceway encapsulation. 

The automatic suppression systems 

are not credited in reducing fire 

exposure to redundant equipment 

unless they are indicated as being fullarea or specifically described as being 

effective for redundant equipment. 

Equipment operators are trained fire 

brigade members and would likely 

identify and manually suppress or 

extinguish a fire using the portable fire 

extinguishers and manual hose stations 

located throughout the fire areas. 

3.3 Preservation of Safe Shutdown 

Capability 

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. The licensee 

stated that the postulated fire events 

that may require the use of the OMAs 

would include multiple failures of 

various components or equipment. In 

most cases, it is considered highly 

unlikely that the sequence of events 

required to necessitate the OMAs would 

fully evolve because of the fire 

prevention, fire protection, and physical 

separation features in place. However, 

in the event that the sequence does 

evolve, the OMAs are available to 

provide assurance that safe shutdown 

can be achieved. 

This analysis postulates that OMAs 

may be needed to assure safe shutdown 

capability in addition to the traditional 

fire protection features described above. 

For each of the fire areas included in 

this exemption, the licensee evaluated 

the OMAs against the criteria of 

NUREG–1852, ‘‘Demonstrating the 

Feasibility and Reliability of Operator 

Manual Actions in Response to Fire,’’ 

October 2007, in the March 6, 2009, 

submittal. A Fire Hazards Analysis was 

provided for each of the OMAs in the 

licensee’s February 12, 2010, 

supplement. 

3.3.1 Licensee’s Bases for Establishing 

Feasibility and Reliability 

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, staffing and 

demonstrations. 

In its March 6, 2009, submittal, and 

further supported by its February 12, 

2010, supplement, the licensee stated 

that environmental considerations such 

as radiological concerns, emergency 

lighting, temperature and humidity 

conditions and smoke and toxic gases 

were evaluated and found to not 

represent a negative impact on the 

operators’ abilities to complete the 

OMA. The licensee stated that the dose 

limits contained in 10 CFR Part 20 are 

never challenged at any point along the 

travel path of any of the OMAs included 

in this exemption. 

The licensee confirmed that each of 

the OMA locations addressed by this 

exemption is provided with emergency 

lighting that illuminates both the 

location where the manual action is 

performed and the access route to the 

manual action location. Where travel is 

required to buildings outside of the 

power block, portable lights are staged 

in the fire safe shutdown equipment 

locker which is inventoried and 

maintained by performance of a 

periodic routine test. The emergency 

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lights are periodically checked for 

operation and aim at the target location. 

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. This is further supported by the 

fact that the locations of the postulated 

fire events are in different fire areas than 

the locations for where the actions are 

performed. In most cases, the initiating 

fire area and manual action location fire 

area are in separate buildings and have 

separate ventilation systems. Other than 

smoke, CO2 is another toxic gas that 

could present a hazard. However, all of 

the CO2 fire suppression systems at 

PBAPS are manually actuated to prevent 

an inadvertent discharge of a system. 

The licensee stated that the 

equipment to be operated as part of the 

OMAs will be functional and 

maintained free of fire damage and will 

be accessible to the operators 

performing the action. Additionally, 

PBAPS maintains Transient Response 

Implementing Plan procedures and T– 

300 Fire Guides. T–300 Fire Guides 

provide the operators with specific 

instructions in the event of a fire in a 

specific fire area. The T–300 Fire Guides 

provide a list of the key protected 

instruments available for a fire in the 

fire area and list any ‘‘prompt’’ actions 

that are needed to restore an instrument 

for a fire in that area (i.e., those that 

need to be performed within 30 

minutes). The applicable T–300 Fire 

Guide lists the ‘‘prompt’’ actions at the 

front of the document. In addition, the 

licensee stated that where specific 

indications may be lost due to a 

postulated event, the applicable T–300 

Fire Guide for that fire area identifies 

which indications may be lost and how 

to recover the loss of that indication. 

Most required shutdown parameter 

indications are provided by multiple 

instruments; therefore, even with the 

loss of certain instruments or power 

supplies, redundant instruments are 

available to provide indications to assist 

operators. 

With regard to communications, the 

licensee stated that PBAPS has radios 

and phones available as part of the 

normal communications between the 

Control Room and the operators. 

Although the communication system is 

not specifically hardened for post-fire 

survivability, the radio and phone 

systems are robustly designed such that 

they will be available following most 

fire scenarios. In the event that the radio 

and phone systems are inoperable, faceto-face communication, and adequate 

time, is available to dispatch the safe 

shutdown operators from the Control 

Room to perform the tasks and return to 

the Control Room for reassignment 

when the task is complete. With the 

exception of Action H, none of the 

operator manual actions addressed by 

this exemption require immediate or 

concurrent coordination with the 

Control Room while performing the 

task. 

The licensee stated that if any keys, 

tools or equipment are required to 

perform the OMAs, the T–300 Fire 

Guides provide instructions on where to 

find them and how to use them. In 

addition, the licensee stated that 

operators are provided with standard 

personal protective equipment (PPE) 

(i.e., hardhat, safety glasses, hearing 

protection, gloves, etc.) and that 

additional PPE is not required for any of 

the OMAs, with the exception of actions 

that require that an electrical enclosure 

be opened to manipulate an insulated 

handle of a manual transfer switch. For 

these tasks, a PBAPS corporate safety 

procedure requires the use of additional 

electrical safety PPE when performing 

this task. 

The licensee stated that the T–300 

Fire Guides provide in-depth safe 

shutdown direction for fires in specific 

fire areas and that the procedures 

included in the guides include specific 

instructions on assessing plant 

indications and events as well as 

instructions on how to perform each of 

the OMAs. The procedures are then 

used to train the operators on the 

OMAs, which consist primarily of 

activities that are considered to be 

similar to those performed as part of 

typical work activity and are considered 

straightforward with minimal training 

demands. In addition, the licensee 

stated that licensed operators are trained 

biennially on the use of the T–300 Fire 

Guides using simulator scenarios that 

start with a fire in a specific fire area. 

With regard to staffing, the licensee 

stated that PBAPS maintains a 

minimum of three operators on each 

shift to perform safe shutdown duties in 

the event of a fire, which may be 

comprised of equipment operators, 

reactor operators or senior reactor 

operators. Additionally, the licensee 

stated that PBAPS performed several 

demonstrations using what is 

considered to be the most challenging 

initiating fire area, the Turbine Building 

(Fire Area 50), because it encompasses 

both Unit 2 and Unit 3, includes an 

action that is a prompt action in other 

fire areas, and includes a number of 

OMAs to perform within the first 60 

minutes. 

3.3.2 NRC Staff Evaluation of 

Feasibility 

The NRC staff has determined that the 

licensee’s analysis demonstrates that, 

for the expected scenarios, the OMAs 

can be diagnosed and executed within 

the amount of time necessary to 

complete them. The licensee’s analysis 

also demonstrates that various factors, 

as discussed above, have been 

considered to address uncertainties in 

estimating the time available. Therefore, 

the NRC staff finds that the OMAs 

included in this review are feasible 

because there is adequate time available 

for the operator to perform the required 

OMAs to achieve and maintain hot 

shutdown following a postulated fire 

event. The following table summarizes 

the ‘‘required’’ verses ‘‘allowable’’ times 

for each OMA. Where a diagnosis time 

has been identified, it is included as 

part of the required time for a particular 

action. Where an action has multiple 

times or contingencies associated with 

the ‘‘allowable’’ completion time, the 

lesser time is used. This approach is 

considered to represent a conservative 

approach to analyzing the timelines 

associated with each of the OMAs with 

regard to the feasibility and reliability of 

the actions included in this exemption. 

In some cases, the margin between the 

required time and allowable time is 

small. Specifically actions D, U, V, and 

X, have 20 percent or less margin. This 

limited margin is based on using the 

most limiting information from the 

licensee. For example, if the licensee 

postulated up to 30 minutes for 

diagnosis, the higher value of the 

required time range noted in the table 

below includes the time to complete the 

action plus the full 30 minutes. 

Finally, these numbers should not be 

considered without the understanding 

that the manual actions are a fall back 

in the unlikely event that the fire 

protection defense-in-depth features are 

insufficient. In most cases, there is no 

credible fire scenario that would 

necessitate the performance of these 

OMAs. The licensee provided a 

discussion of the times and 

circumstances associated with each of 

the actions in its March 6, 2009, and 

February 12, 2010, correspondence. 

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Fire area of fire origin OMA Required 

time (min) 

Allowable 

time (min) 

Fire Area 2 (Radwaste Building) ..................................................................... Action B .............................................. 15—45* 120 

Action C ............................................. 15 25 ** 

Action D ............................................. 18—48* 60 

Fire Area 6S (Unit 2 Reactor Building) ........................................................... Action G ............................................. 14—44* 60 

Fire Area 6N (Unit 2 Reactor Building, North Side) ....................................... Action H ............................................. 7 25 ** 

Fire Area 13N (Unit 3 Reactor Building) ......................................................... Action J .............................................. 12—42* 60 

Fire Area 26 (Unit 3 MG Set Ventilation Equipment Room) .......................... Action K .............................................. 12—42* 60 

Fire Area 30 (Unit 3 B/D Battery Room) ........................................................ Action M ............................................. 9—39* 60 

Fire Area 36 (E42 Switchgear Room) ............................................................ Action R ............................................. 12—42* 60 

Fire Area 37 (E22 Switchgear Room) ............................................................ Action S .............................................. 12—42* 60 

Fire Area 43 (E–4 Emergency Diesel Generator Room) ............................... Action T .............................................. 9—39* 60 

Fire Area 50 (Turbine Building) ...................................................................... Action U ............................................. 26—56* 60 

Action V .............................................. 26—56* 60 

Action X .............................................. 24—54* 60 

Action Y .............................................. 15—45* 120 

Fire Area 58 (Unit 3 MG Set Room) ............................................................... Action BB ........................................... 12—42* 60 

Action CC ........................................... 12 25** 

* The higher value of the required time range accounts for a generic 30-minute diagnosis time to assess the need for OMAs. 

** Prompt actions are those having allowable completion times of 30 minutes or less. 

3.3.3 NRC Staff Evaluation of 

Reliability 

The completion times noted in the 

table above provide reasonable 

assurance that the OMAs can reliably be 

performed under a wide range of 

conceivable conditions by different 

plant crews. This is because the 

completion time, in conjunction with 

the time margins associated with each 

action and other installed fire protection 

features, account for sources of 

uncertainty such as variations in fire 

and plant conditions, factors unable to 

be recreated in demonstrations and 

human-centered factors. Therefore, the 

NRC staff finds that the OMAs included 

in this review are reliable because there 

is adequate time available to account for 

uncertainties not only in estimates of 

the time available, but also in estimates 

of how long it takes to diagnose a fire 

and execute the OMAs (i.e., as based, at 

least in part, on a plant demonstration 

of the actions under non-fire 

conditions). 

For each of the fire areas included in 

this exemption, the postulated fire 

scenarios and pertinent details are 

summarized in Section 3.4 below. 

3.4 NRC Staff Fire Area Evaluations 

3.4.1 Fire Area 2 (Radwaste Building) 

Fire Prevention 

The licensee stated that the floorbased combustibles include health 

physics cleaning supplies, such as 

mops, vacuums and other Class A 

combustibles as well as several steel 

carts containing new resins in paper or 

plastic bags. The total weight of the 

plastic bags is estimated to be less than 

5 pounds and empty resin bags are 

immediately removed. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 2 

has fire suppression systems installed 

within the fire area but not within the 

rooms containing redundant cables. The 

licensee has further stated that the 

detection systems in the rooms 

containing redundant cables are not 

code compliant in terms of overall 

spacing in the fire area. However, a 

smoke detector is located within 5 feet 

of redundant cable ZA2B1021A. There 

is also a smoke detector located within 

15 feet of both cables ZD3A1806A and 

ZD3A1321A. The licensee also stated 

that the Radwaste Control Room is 

located directly adjacent to these three 

rooms and that it is normally occupied 

by an equipment operator. Because of 

this, it is likely that any fire would be 

quickly identified by an operator in the 

area. Additionally, the licensee stated 

that a fully trained onsite fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. Fire Area 

2 is provided with manual fire fighting 

equipment such as portable fire 

extinguishers and manual hose stations 

throughout the area. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 2 is 

a large fire area containing a number of 

rooms on several elevations and that 

spatial separation of redundant cables is 

provided as discussed below. 

OMAs Credited for a Fire in This Area 

Action B 

The licensee stated that the redundant 

cables located in Fire Area 2 (cables 

ZA2B1021A and ZD3B1321A or 

ZD3A1806A) are located a minimum of 

approximately 30 feet from each other 

and that no intervening combustibles 

are present between the two trains of 

cables. This physical separation with 

the available fire detection system will 

provide the site fire brigade an 

opportunity to extinguish the fire before 

redundant trains are damaged. The 

licensee also stated that the cables are 

located a minimum of approximately 9 

feet above the floor and that they are 

enclosed in rigid conduit, such that 

transient fire exposures and self-ignited 

cable fires are unlikely to affect the 

circuits. 

In the unlikely event that both trains 

of cable are lost due to a fire in Fire Area 

2, an OMA (Action B) is available to 

restore or maintain the necessary 

function to the effected equipment (SU– 

25 Breaker). Action B directs an 

operator to transfer SU–25 breaker 

auxiliary equipment from the normal 

power source to its alternate power 

source, by operating manual transfer 

switch 00S306, which is located in the 

Unit 2 Startup Building. The Unit 2 

Startup Building is located in the 

exterior yard area. 

Action C 

The potential need to perform this 

action is low since this action is only 

needed if two of three offsite power 

sources are unavailable, power to the 

2SU transformer tap changer is lost, and 

the tap changer is in the wrong position. 

The licensee stated that offsite power is 

provided to each of the 4kV Class 1E 

switchgear by two of three redundant 

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sources (2SU, 3SU, and 343SU) and that 

control cables for the sources have been 

physically separated by rerouting 

selected cables, such that one of the 

redundant sources remains free of fire 

damage for fires in most plant areas. In 

particular, the licensee stated that cables 

associated with the 2SU source have 

been relocated out of the Turbine 

Building (Fire Area 50), and portions of 

the Radwaste Building (Fire Areas 2 and 

58). 

The licensee stated that balance of 

plant (BOP) cables are routed through 

Fire Area 2, but that the routing of the 

cables was not part of the analysis. In 

the licensee’s February 12, 2010, 

supplement, the licensee described the 

circumstances that would determine the 

availability of the safe shutdown 

equipment located in this area; namely 

the 2SU power source, which includes 

a transformer tap changer that is 

powered by BOP power. Since the BOP 

cable routing was not part of the 

analysis, the loss of BOP power was 

assumed for a fire in these three fire 

areas. The licensee’s analysis also 

assumed that the transformer tap 

changer, which is powered by the BOP 

and responsible for maintaining power 

to the 4kV Bus, was not in the correct 

position. When the tap changer is not in 

the correct position, the voltage could 

vary resulting in actuation of the 4kV 

trip relays. 

In the unlikely event that all of the 

conditions discussed above exist and 

fire damage occurs to the redundant 

cables, Action C can be utilized, which 

directs operators to pull the fuse blocks 

for the degraded voltage trip relays to 

ensure that the 4kV busses remain 

available. Action C is a ‘‘prompt’’ action, 

with an allowable completion time of 30 

minutes or less, however, the licensee 

stated that its analysis assumed that the 

redundant cables were lost regardless of 

their location and that the tap changer 

was not in the correct position. The 

licensee stated that the loss of certain 

equipment in a fire area due to a fire 

will result in a Control Room alert. Off 

Normal procedure ON–114, ‘‘Actual Fire 

Reported in the Power Block, Diesel 

Generator Building, Emergency Pump, 

Inner Screen or Emergency Cooling 

Tower Structures,’’ is immediately 

entered upon confirmation of a fire 

condition. Procedure ON–114 directs 

immediate entry into the Fire Guide for 

the affected fire area. The licensee also 

stated that a note is provided in the 

applicable safe shutdown fire guide 

series (T–300 Fire Guides) providing 

guidance on how to determine whether 

the 2SU transformer tap changer has lost 

power using indications within the 

Control Room. Therefore, the Control 

Room will know immediately if this 

action is required and a generic 

diagnosis time is not necessary. 

The licensee’s T–300 Fire Guides also 

provide the following guidance to assist 

operators in evaluating a postulated 

event, ‘‘If 2SU is the only offsite power 

source available, and a loss of power to 

the 2SU Transformer Tap Change has 

occurred, then perform the manual 

action to remove the fuses.’’ 

Additionally, the 2SU transformer and 

associated auxiliaries are located in the 

yard area and would not be exposed by 

a fire in Fire Area 2. Lastly, the location 

of the OMA to remove the fuses in the 

4kV Switchgear Rooms is in a separate 

fire area, with ventilation systems that 

are separate from Fire Area 2. 

Action D 

The licensee stated that this action 

would only be required if the conduit 

containing cable, which is located above 

the suspended ceiling with the only 

exposing combustible being a tray with 

fire retardant cables, is damaged by fire. 

There is a lack of ignition sources and 

a relatively short length (approximately 

6 feet) of cable that passes through Fire 

Area 2. In addition, there is a smoke 

detector located within 5 feet of the 

conduit containing the cable, which 

would result in rapid plant notification 

of an exposure fire. 

In the unlikely event that a fire in Fire 

Area 2 damages cable ZA2B1014A, 

normal power to the 2AD003 battery 

charger could be lost, which is needed 

to maintain long term DC power through 

the station batteries. A loss of 

ZA2B1014A would necessitate a manual 

action to transfer battery charger 

2AD003 to an alternate power source 

within 60 minutes since the batteries 

can operate for 60 minutes prior to the 

initiation of recharging. The alternate 

power source is routed in separate fire 

areas, so a single fire cannot damage 

both the normal and alternate power 

feed. Action D is available to transfer 

the alternate power supply to the battery 

charger 2AD003. The action entails 

closing a breaker located in the E13 4kV 

Switchgear Room (Fire Area 33) and 

then operating a manual transfer switch 

located in the E32 4kV Switchgear 

Room (Fire Area 38), both of which are 

separate fire areas from Fire Area 2. 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials and ignition 

sources, it is unlikely that a fire would 

occur and go undetected by the smoke 

detection system noted above or 

unsuppressed by personnel, and damage 

the safe shutdown equipment. Even if 

such circumstances exist, Actions B, C, 

and D are available to provide 

additional assurance that safe shutdown 

capability is maintained. 

3.4.2 Fire Area 6S (Unit 2 Reactor 

Building) 

Fire Prevention 

The licensee stated that conduits are 

routed primarily through a transient 

combustible-free zone where a permit 

and review are required prior to the 

placement of combustibles in this area. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 6S 

has ionization smoke detectors installed 

in the overhead area but that these 

smoke detectors do not have code 

compliant spacing due to ceiling height 

and beam pockets. However, there are 

three smoke detectors located above the 

general routing of the redundant cable 

conduits, which would be expected to 

activate in the event of a fire occurring 

in close proximity to the redundant 

cables. Additionally, the licensee stated 

that a fully trained onsite fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Room 403 in 

Fire Area 6S has a ceiling height of 

approximately 29’ and an approximate 

floor area of 6,848 square feet, so it is 

unlikely that smoke and heat would 

accumulate at the height of the safe 

shutdown equipment and cause a 

failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action G 

The licensee stated that recent plant 

experience with faults and malfunctions 

in similar load centers has been that 

even when energetic failures have 

occurred, its damage has been contained 

within the breaker cubicle, with some 

heat and smoke damage to immediately 

adjacent cubicles. Therefore, it is 

considered unlikely that the cables 

routed above the load centers would be 

affected by a fault within the load 

centers since there is not a credible fire 

scenario that would be capable of 

damaging the cables within the 

conduits. 

A fire in Fire Area 6S has the 

potential to damage cables ZA2B1014A, 

ZA2A1505A, and ZA2B1021A. The 

licensee stated that there are three 480V 

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load centers in the room containing the 

redundant cables and that the cables are 

routed to one of the load centers. As a 

result, each cable is routed over a 480V 

load center and in two cases the conduit 

passes over two load centers prior to 

entering the third load center. The 

conduits are located above the two 

adjacent load centers, which consist of 

a 4kv to 480v sealed gas cooled stepdown transformer and a 480v 

switchgear. 

The loss of these cables could result 

in a loss of the normal power supply to 

the 2AD003 battery charger, which is 

needed to maintain long term DC power 

through the station batteries. A loss of 

ZA2B1014A, ZA2A1505A, and 

ZA2B1021A would necessitate a manual 

action to transfer battery charger 

2AD003 to an alternate power source 

within 60 minutes since the batteries 

can operate for 60 minutes prior to the 

initiation of recharging. The alternate 

power source is routed in separate fire 

areas, so a single fire cannot damage 

both the normal and alternate power 

feed. Action G is available to transfer 

the alternate power supply to the battery 

charger 2AD003. The action entails 

closing a breaker located in the E13 4kV 

Switchgear Room (Fire Area 33) and 

then operating a manual transfer switch 

located in the E32 4kV Switchgear 

Room (Fire Area 38), both of which are 

separate fire areas from Fire Area 6S. 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected by the smoke detection 

system noted above or unsuppressed by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action G is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.3 Fire Area 6N (Unit 2 Reactor 

Building, North side) 

Fire Prevention 

The licensee stated that the only floorbased combustibles in this area are trash 

cans and cables. Trash can lids are 

designed to provide self-extinguishing 

capability to the trash cans. Cables in 

the area are qualified to the Institute of 

Electrical and Electronics Engineers, 

Inc. Standard-383, ‘‘IEEE Standard For 

Qualifying Class 1E Electrical Cables 

And Field Splices for Nuclear Power 

Generating Stations’’ (IEEE 383), or 

equivalent. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 6N 

has a smoke detection system installed, 

but that the spacing is not in 

compliance with National Fire 

Protection Association Code 72, 

‘‘National Fire Alarm and Signaling 

Code’’ (NFPA 72), due to deep beam 

pockets at the ceiling of this area. 

However, there is a smoke detector 

within the vicinity (approximately 25 

feet) of each of the cases where cable 

ZA2Q1280B and a ‘‘B’’ residual heat 

removal (RHR) cable intersect, which 

would be expected to activate in the 

event of a fire in close proximity to the 

redundant equipment. There is also an 

automatic water curtain on the west side 

of the Unit 2 Reactor Building that 

separates Fire Area 6N from Fire Area 

6S, thus reducing any anticipated 

exposure from Fire Area 6S. 

Additionally, the licensee stated that a 

fully trained onsite fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 6N 

is the Unit 2 Reactor Building 135’ 

elevation, north side, which is in a 

separate building from the Cable 

Spreading Room, Fire Area 25, which is 

the location of the OMA. 

OMAs Credited for a Fire in This Area 

Action H 

The licensee stated that the cables 

associated with ‘‘B’’ RHR are located in 

trays and in conduit and that cables for 

both ‘‘A’’ and ‘‘B’’ RHR trains cross 

within 2 feet of each other. However, 

there are no high energy ignition 

sources where cable ZA2Q1280B and a 

‘‘B’’ RHR train cable cross and only a 

small amount of combustibles in the 

area overall. Therefore, it is unlikely 

that a single fire could damage both the 

‘‘A’’ train RHR cable and ‘‘B’’ RHR cables 

and necessitate the use of Action H. 

Action H, which requires coordination 

with the control room, directs an 

operator to insert a plug-in test switch 

into Panel 20C032, located in the Cable 

Spreading Room (Fire Area 25), to 

bypass the reactor low pressure 

permissive for opening MO–2–025A. 

In the unlikely event that a fire does 

damage the pressure permissive 

instrumentation circuit for opening 

MO–2–025A, operators will be aware of 

the condition, either by electronic 

indications in the Control Room, a 

smoke detection alarm annunciation in 

the Control Room, or physical 

observation by operators, and will 

initiate Action H, which is the only 

OMA required to achieve hot shutdown 

for a fire in Fire Area 6N. Therefore, the 

Control Room will know immediately if 

this action is required and a generic 

diagnosis time is not necessary. 

A fire in Fire Area 6N has the 

potential to damage cable ZA2Q1280B. 

This cable is associated with the 

pressure permissive circuit needed to 

open valve MO–2–10–025A. This valve 

needs to open to permit injection of Low 

Pressure Core Injection (‘‘A’’ train RHR) 

following depressurization. Fire Area 

6N also contains a number of cables 

associated with the ‘‘B’’ train of RHR. 

Any number of ‘‘B’’ RHR train cables 

could be damaged as a result of a fire 

in Fire Area 6N, so the licensee’s 

analysis assumed that the ‘‘B’’ RHR was 

considered to be unavailable for a fire in 

Fire Area 6N. 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials and ignition 

sources, it is unlikely that a fire would 

occur and go unsuppressed by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action H is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.4 Fire Area 13N (Unit 3 Reactor 

Building) 

Fire Prevention 

The licensee stated that limited 

amounts of Class A combustible 

materials, including step-off pads, are 

present in this area. The three cables 

addressed in this area are routed such 

that they terminate at either a 480V load 

center or a motor control center (MCC) 

cabinet or both. 

Detection, Control, and Extinguishment 

The licensee stated that both 

elevations containing redundant 

equipment within Fire Area 13N have 

smoke detection systems installed that 

produce an alarm in the Control Room, 

but that due to the room height and steel 

beams at the ceiling, the spacing of the 

smoke detectors on both elevations does 

not meet the spacing listed in NFPA 72. 

Although not entirely compliant with 

NFPA 72, this system is considered to 

provide adequate coverage to detect a 

fire and alert operators of a fire. 

Additionally, the licensee stated that a 

fully trained onsite fire brigade is 

provided, which is dispatched via plant 

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page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that the 135’ 

elevation of Fire Area 13N has a ceiling 

height of approximately 29’ and an 

approximate floor area of 4,033 square 

feet and the 165’ elevation has a ceiling 

height of approximately 29’ and an 

approximate floor area of 6,848 square 

feet, so it is unlikely that smoke and 

heat would accumulate at the height of 

the safe shutdown equipment and cause 

a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action J 

The licensee stated that while it is 

possible that any one of the three 

redundant cables located in Fire Area 

13N could potentially be damaged as a 

result of a fault or failure within its 

associated 480V load center or MCC, the 

impact of a fire on the ability to perform 

this action is low since Fire Area 13N 

is in a separate building with a separate 

ventilation system from the E43 4kV 

Switchgear Room and ample time is 

available to complete the action. 

However, the other installed fire 

protection features such as the smoke 

detection system, cable conduit, and fire 

brigade response would likely minimize 

the impact of a fire on the cables 

themselves. 

A fire in Fire Area 13N has the 

potential to damage cables ZD3B1313A, 

ZD3A1806A, and ZD3B3983A. The loss 

of any of these cables could result in a 

loss of the normal power supply to the 

3DD003 battery charger. A loss of 

ZD3B1313A, ZD3A1806A, or 

ZD3B3983A, would necessitate a 

manual action to transfer battery charger 

3DD003 to an alternate power source to 

within 60 minutes since the batteries 

can operate for 60 minutes prior to the 

initiation of recharging. Battery charger 

3DD003 can also be fed from an 

alternate power source, which is routed 

in separate fire areas, so a single fire 

cannot damage both the normal and 

alternate power feed. Action J is 

available to transfer the alternate power 

supply to the battery charger 3DD003. 

The action entails first closing a breaker 

and then operating a manual transfer 

switch. The breaker and manual transfer 

switch are located in the E43 4kV 

Switchgear Room (Fire Area 34). 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected by the smoke detection 

system noted above or unsuppressed by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action J is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.5 Fire Area 26 (Unit 3 MG Set 

Ventilation Equipment Room) 

Fire Prevention 

The licensee stated that the primary 

combustible material in Fire Area 26 is 

fire retardant cable insulation and that 

there are no in situ ignition sources in 

the vicinity of the cables. 

Detection, Control, and Extinguishment 

The licensee stated that in Fire Area 

26, there are two ionization smoke 

detectors located in the portion of the 

room containing the cables of concern, 

but that the overall detector placement 

for the fire area as a whole does not 

comply with the layout and spacing 

requirements of NFPA 72; however, the 

two smoke detectors are located in the 

immediate vicinity of the cables and 

would provide an alarm of a fire 

condition. Additionally, the licensee 

stated that a fully trained onsite fire 

brigade is provided, which is 

dispatched via plant page in the event 

of a fire. The fire brigade is composed 

of plant operators that are separate from 

operators assigned safe shutdown duties 

and are instructed to provide 

information about a fire event over the 

operations radio to assist in mitigating 

the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 26 

has a ceiling height of approximately 25’ 

and an approximate floor area of 2,100 

square feet, so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action K 

The licensee stated that it is unlikely 

that Action K will be necessary because 

there is reasonable assurance that both 

of the cables would not be damaged in 

the event of a fire in Fire Area 26 since 

there are no in situ ignition sources in 

Fire Area 26 in the vicinity of the 

cables, there are no combustible 

materials, other than fire retardant cable 

insulation exposing the two cables, and 

there are two smoke detectors provided 

in the area to notify operators of a fire. 

In the event that the action is necessary, 

the impact of a fire on the ability to 

perform this action is low since Fire 

Area 26N is in a separate building with 

a separate ventilation system from the 

E43 4kV Switchgear Room and ample 

time is available to complete the action. 

A fire in Fire Area 26 has the 

potential to damage cables ZD3B1313A, 

ZD3A1806A, and ZD3B3983A. The loss 

of any of these cables could result in a 

loss of the normal power supply to the 

3DD003 battery charger. A loss of 

ZD3B1313A, ZD3A1806A, or 

ZD3B3983A, would necessitate a 

manual action to transfer battery charger 

3DD003 to an alternate power source 

within 60 minutes since the batteries 

can operate for 60 minutes prior to the 

initiation of recharging. Battery charger 

3DD003 can also be fed from an 

alternate power source, which is routed 

in separate fire areas, so a single fire 

cannot damage both the normal and 

alternate power feed. Action K is 

available to transfer the alternate power 

supply to the battery charger 3DD003. 

The action entails first closing a breaker 

and then operating a manual transfer 

switch. The breaker and the manual 

transfer switch are located in the E43 

4kV Switchgear Room (Fire Area 34). 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected by the smoke detection 

system noted above or unsuppressed by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action K is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.6 Fire Area 30 (Unit 3 B/D Battery 

Room) 

Fire Prevention 

The licensee stated that the 

combustible loading in this area is 

considered to be low with the primary 

combustible material in this area being 

liquid filled plastic battery cases and 

that there are no cables in trays in this 

fire area. Additionally, the potential for 

hydrogen buildup due to the battery 

charging process is mitigated by the 

ventilation system in the room. The 

ventilation system is monitored, 

alarmed, and programmatically 

controlled. The licensee also stated that 

there are no significant ignition sources 

in this area. 

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Detection, Control, and Extinguishment 

The licensee stated that for Fire Area 

30 there are three smoke detectors 

located in the room and that the spacing 

of the detectors is compliant with NFPA 

72 with regard to ceiling height, beam 

configuration and air flow. 

Additionally, two of the three smoke 

detectors are located directly above the 

encapsulated conduits that contain 

redundant cables. Additionally, the 

licensee stated that a fully trained onsite 

fire brigade is provided, which is 

dispatched via plant page in the event 

of a fire. The fire brigade is composed 

of plant operators that are separate from 

operators assigned safe shutdown duties 

and are instructed to provide 

information about a fire event over the 

operations radio to assist in mitigating 

the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 30 

has a ceiling height of approximately 14′ 

and an approximate floor area of 525 

square feet, so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action M 

The licensee stated that it is unlikely 

that both of the redundant cables 

located in Fire Area 30 would be 

damaged in the event of a fire in Fire 

Area 30 since the conduits containing 

cables ZA3B1014A and ZA3A1505A are 

both encapsulated in abandoned 

Thermo-Lag, the primary combustible 

material in the room is liquid filled 

plastic battery cases, there are no cable 

trays or high voltage components 

located in the fire area, there are three 

smoke detectors located in close 

proximity to the cables, and the 

potential for hydrogen release from the 

battery charging process is mitigated by 

the ventilation system that is monitored 

for operation and addressed by the 

Technical Requirements Manual. 

A fire in Fire Area 30 has the 

potential to damage cables ZA3B1014A 

and ZA3A1505A, which the licensee 

stated are located approximately 16 

inches from one another at their closest 

location. The loss of either of these 

cables could result in a loss of the 

normal power supply to the 3AD003 

battery charger (located in Fire Area 32). 

A loss of ZA3B1014A or ZA3A1505A 

would necessitate a manual action to 

transfer battery charger 3AD003 to an 

alternate power source within 60 

minutes since batteries can operate for 

60 minutes prior to the initiation of 

recharging. Battery charger 3AD003 can 

also be fed from an alternate power 

source, which is routed in separate fire 

areas, so a single fire cannot damage 

both the normal and alternate power 

feed. Action M is available to transfer 

the alternate power supply to the battery 

charger 3AD003. The action entails 

operating a manual transfer switch 

located in the E33 4kV Switchgear 

Room (located in a different fire area). 

NRC Staff Evaluation 

Given the ventilation system located 

in the room, limited amount of 

combustible materials, lack of ignition 

sources, and the volume of the space, it 

is unlikely that a fire would occur and 

go undetected by the smoke detection 

system noted above or unsuppressed by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action M is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.7 Fire Area 36 (E42 Switchgear 

Room) 

Fire Prevention 

The licensee stated that the cables in 

this area are qualified to IEEE 383, or 

equivalent. The licensee also indicated 

that there are several sections of 

Thermo-Lag in the room. Thermo-Lag is 

a fire barrier material that is also 

considered a combustible. The licensee 

determined that this material does not 

create a credible fire exposure to the 

conduit and that the overall combustible 

material loading for the area is low. 

Additionally, Fire Area 36 contains 4kV 

switchgear which can create a high 

energy fault in the event of a failure and 

is considered an ignition source. 

However, the conduit containing the 

cables of concern is routed 4 feet 

horizontally from the front of the 

switchgear cabinet, not routed over the 

switchgear, and is not expected to be 

damaged in the event of a switchgear 

failure. Conduit containing four cables 

of concern is routed over two battery 

chargers, which convert 480 volt AC 

into 125 volt DC for the batteries. 

However, these chargers are not 

anticipated to provide a sustained fault 

current like a 4kV switchgear, but heat 

from a failure could expose the conduit 

and, therefore, represent an ignition 

source. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 36 

has an NFPA 72-compliant smoke 

detection system installed, comprised of 

six smoke detectors, and that the room 

is also provided with a pre-action 

sprinkler system designed in accordance 

with NFPA Standard 13, ‘‘Standard for 

the Installation of Sprinkler Systems’’ 

(NFPA 13). Additionally, the licensee 

stated that a fully trained onsite fire 

brigade is provided, which is 

dispatched via plant page in the event 

of a fire. The fire brigade is composed 

of plant operators that are separate from 

operators assigned safe shutdown duties 

and are instructed to provide 

information about a fire event over the 

operations radio to assist in mitigating 

the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 36 

has a ceiling height of approximately 14′ 

and an approximate floor area of 525 

square feet, so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action R 

The licensee stated that while it is 

possible that the redundant cables 

located in Fire Area 36 could potentially 

be damaged by heat resulting from a 

battery charger failure, it is unlikely that 

the cables within the conduits would be 

damaged since Fire Area 36 has full area 

smoke detection and pre-action 

sprinkler systems, the conduit is not 

routed directly above the 4kV 

switchgear, the combustible loading in 

the room is low consisting primarily of 

fire retardant cable insulation and 

Thermo-Lag, and there are no cable 

trays routed below the conduit. 

A fire in Fire Area 36 has the 

potential to damage cables ZA2A1501E, 

ZA2A1501F, ZA2A1508E, and 

ZA2A1508F, which the licensee stated 

are routed together in a single conduit, 

located approximately 9 feet above the 

floor, for their entire length in Fire Area 

36. The loss of these cables could result 

in the loss of power to the E12 bus from 

the E1 Emergency Diesel Generator. 

Since Fire Area 36 is the E42 4kV 

Switchgear Room, the switchgear in this 

room is primarily associated with the B 

and D electrical trains. Therefore, a fire 

in this room is assumed to result in the 

loss of the components associated with 

the B and D trains. In the event that 

these are lost due to a fire in Fire Area 

36, Action R is available, which directs 

an operator to enter the E12 Switchgear 

Room (located in Fire Area 39) and pull 

two fuse blocks, open two breakers by 

depressing the mechanical breaker trip 

button and taking a Main Control Room 

breaker control switch to ‘‘Close.’’ 

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NRC Staff Evaluation 

Given the limited amount of 

combustible materials and the volume 

of the space, it is unlikely that a fire 

would occur and go undetected by the 

smoke detection system noted above or 

unsuppressed by personnel, and damage 

the safe shutdown equipment. Even if 

such circumstances exist, Action R is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.8 Fire Area 37 (E22 Switchgear 

Room) 

Fire Prevention 

The licensee stated that the cables in 

this area are qualified to IEEE 383, or 

equivalent. Thermo-Lag is also present, 

but does not create a credible fire 

exposure to the conduit. The licensee 

determined that this material does not 

create a credible fire exposure to the 

conduit and that the overall combustible 

material loading for the area is low. Fire 

Area 37 also contains 4kV switchgear 

which can create a high energy fault in 

the event of a failure and is considered 

an ignition source. However, the 

conduit containing the cables of concern 

is routed 4 feet horizontally from the 

front of the switchgear cabinet, not 

routed over the switchgear, and is not 

expected to be damaged in the event of 

a switchgear failure. Additionally, a 

bank of 480V MCCs exposes conduit 

containing four cables of concern to an 

exposure hazard in the event that an 

MCC fails. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 37 

has an NFPA 72-compliant smoke 

detection system installed, comprised of 

three smoke detectors, and that the 

room is also provided with a pre-action 

sprinkler system designed in accordance 

with NFPA 13. Additionally, the 

licensee stated that a fully trained onsite 

fire brigade is provided, which is 

dispatched via plant page in the event 

of a fire. The fire brigade is composed 

of plant operators that are separate from 

operators assigned safe shutdown duties 

and are instructed to provide 

information about a fire event over the 

operations radio to assist in mitigating 

the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 37 

has a ceiling height of approximately 14’ 

and an approximate floor area of 525 

square feet, so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action S 

The licensee stated that while it is 

possible that the redundant cables 

located in Fire Area 37 could potentially 

be damaged by failure of the bank of 

480V MCCs located below the conduit, 

it is unlikely that the cables within the 

conduits would be damaged since Fire 

Area 37 has full area smoke detection 

and pre-action sprinkler systems, the 

conduit is not routed directly above the 

4kV switchgear, the combustible loading 

in the room is low consisting primarily 

of fire retardant cable insulation and 

Thermo-Lag, and there are no cable 

trays routed below the conduit. 

A fire in Fire Area 37 has the 

potential to damage cables ZA2A1501E, 

ZA2A1501F, ZA2A1508E, and 

ZA2A1508F, which the licensee stated 

are routed together in a single conduit, 

located approximately 9 feet above the 

floor, for their entire length in Fire Area 

37. The loss of these cables could result 

in the loss of power to the E12 bus from 

the E1 Emergency Diesel Generator. 

Since Fire Area 37 is the E22 4kV 

Switchgear Room, the switchgear in this 

room is primarily associated with the B 

and D electrical trains, so a fire in this 

room is assumed to result in the loss of 

the components associated with the B 

and D trains. In the event that these are 

lost due to a fire in Fire Area 36, Action 

R is available, which directs an operator 

to enter the E12 Switchgear Room 

(located in Fire Area 39) and pull two 

fuse blocks, open two breakers by 

depressing the mechanical breaker trip 

button and taking a Main Control Room 

breaker control switch to ‘‘Close.’’ 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials and the volume 

of the space, it is unlikely that a fire 

would occur and go undetected by the 

smoke detection system noted above or 

unsuppressed by personnel, and damage 

the safe shutdown equipment. Even if 

such circumstances exist, Action S is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.9 Fire Area 43 (E–4 Emergency 

Diesel Generator Room) 

Fire Prevention 

The licensee stated that other than the 

diesel fuel and lube oil in the EDG 

Rooms, the combustible material 

loading is considered to be low. The 

fuel oil day tank is located within the 

fire area, but in a separate room with 

heavy concrete walls and a 3-hour 

Underwriters Laboratory (UL)-listed fire 

door. Additionally, failure of an 

operating diesel generator represents a 

significant ignition source. There are 

also high voltage electrical components 

associated with the generator in the 

room. However, these ignition sources 

are only credible when the diesel is in 

operation. During routine diesel 

operations, an equipment operator is 

stationed in the room to monitor the 

diesel and would be available to 

immediately suppress any small fires 

that occurred, or to secure the diesel if 

a significant malfunction occurred. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 43 

has eight heat detectors installed that 

annunciate an alarm in the Control 

Room and that the room also has a 

manually-actuated carbon dioxide (CO2) 

fire suppression system installed. 

Additionally, the licensee stated that a 

fully trained on-site fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that the 

emergency diesel generator rooms are 

located in a separate building from the 

rest of the plant and that each of the 

emergency diesel generators are 

separated from one another with a threehour rated fire barrier. Additionally, the 

OMA for this area is performed in the 

E42 Switchgear room, Fire Area 36, 

which is located in the turbine building. 

OMAs Credited for a Fire in This Area 

Action T 

The licensee stated that while it is 

possible that the redundant cables in 

Fire Area 43 could potentially be 

damaged by a lube or fuel oil fire, it is 

unlikely that the cables within the 

conduits would be damaged since they 

are located in conduit that is embedded 

in the floor slab for much of the length 

they are in Fire Area 43, and there 

would have to be a sufficient amount of 

oil present on the floor which then 

spreads across the floor to expose the 

control panels. Even if these two 

circumstances occur, a manuallyactuated CO2 fire suppression system is 

available to extinguish any fires in the 

area. 

A fire in Fire Area 43 has the 

potential to damage cables ZD2A1807E 

or ZD2A1807H, which the licensee 

stated are located in conduits embedded 

in the concrete floor slab, control 

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panels, and a junction box. Failure of 

these cables via a hot short could cause 

the Unit 2 emergency diesel generator 

breaker to close into the E42 bus, either 

out of phase or not running, which 

would cause a protective trip of the E42 

bus. This could result in a loss of the 

normal power supply to the 2DD003 

battery charger. The battery charger is 

needed to maintain long term DC power 

through the station batteries. The 

batteries can operate for 60 minutes 

prior to the initiation of recharging. 

Battery charger 2DD003 can also be fed 

from an alternate power source, which 

is routed in separate fire areas, so a 

single fire cannot damage both the 

normal and alternate power feed. Action 

T is available to transfer the alternate 

power supply to the battery charger 

2DD003 (located in Fire Area 36). The 

action entails operating a manual 

transfer switch located in the E42 4kV 

Switchgear Room which is a separate 

fire area in a separate building. 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials and monitoring of 

credible ignition sources in this area, it 

is unlikely that a fire would occur and 

go undetected by the heat detection 

system or unsuppressed by the 

suppression system noted above or by 

personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Action T is 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.10 Fire Area 50 (Turbine Building) 

Fire Prevention 

The licensee stated that limited 

amounts of Thermo-Lag and various 

Class A combustible materials are 

present in the fire area. The licensee 

also stated that the room containing the 

cables of concern contains two rows of 

13kV switchgear cabinets, which would 

be capable of exposing the cables in the 

event of a 13 kV switchgear failure. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 50 

includes most of the Unit 2 and Unit 3 

Turbine Building and as such is a large 

fire area including several rooms located 

on multiple elevations. However, the 

cables of concern with regard to the 

associated OMA are only routed through 

Room 126. This room contains a full 

room smoke detection system with 

spacing in accordance with NFPA 72. In 

addition, a full room pre-action 

sprinkler system is provided in Room 

126 with sprinkler head placement in 

accordance with NFPA 13. There is also 

an automatic sprinkler system in the 

adjacent open areas of the Turbine 

Building. The remainder of the Turbine 

Building is separated from Room 126 by 

heavy concrete radiation barriers and a 

water curtain (which is part of the Room 

126 pre-action system) at the doorways. 

Additionally, the licensee stated that a 

fully trained onsite fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The primary basis for preserving safe 

shutdown capability is included in the 

discussion of prevention, detection, 

suppression, and control above or 

included in the OMAs discussed below. 

OMAs Credited for a Fire in This Area 

Action U 

The licensee stated that while it is 

possible that one of the redundant 

cables located in Fire Area 50 could 

potentially be damaged by failure of the 

13kV switchgear, it is unlikely that 

additional redundant cables would be 

damaged since the conduit containing 

cable ZD2A1807E runs above the 13kV 

switchgear, there is approximately 5 feet 

of separation between it and the next 

closest conduit which contains cable 

ZA2A1503E, and this conduit is not 

located above the 13kV switchgear. The 

area is also provided with a smoke 

detection system and a pre-action 

sprinkler system and the presence of 

abandoned, but intact, Thermo-Lag to 

protect the cables that are needed to 

ensure power to the ‘‘A’’ and ‘‘C’’ train 

switchgear to power credited shutdown 

components. 

There is a cable associated with each 

of the four 4kV busses routed through 

Fire Area 50. There is the potential for 

any of the four diesel generator output 

breakers to spuriously close, rendering 

the bus unavailable until the diesel 

generator breaker is opened and 

lockouts are reset. The four cables 

associated with the Unit 2 4kV busses 

are: Bus E12 breaker cable ZA2A1503E; 

bus E22 breaker cable ZB2A1606E; bus 

E32 breaker ZC2A1704E; and bus E42 

breaker cable ZD2A1807E. Loss of any 

one of these cables will only affect the 

associated 4kV bus and all four cables 

are routed in separate conduits. Cables 

ZA2A2503E and ZC2A1704E are routed 

in conduits that remain encapsulated in 

abandoned Thermo-Lag for their entire 

routing through Fire Area 50 while 

cables ZB2A1606E and ZD2A1807E are 

routed in conduit that is not 

encapsulated. The conduit containing 

cable ZB2A1606E is located within 5 

feet of the conduits containing cables 

ZA2B1503E and ZD2A1807E. 

Only cables ZA2A1503E and 

ZC2A1704E are necessary to power the 

busses credited for safe shutdown. 

However, Action U would restore power 

to all four busses. Only three of the four 

busses would require restoration within 

60 minutes and only one bus is assumed 

to require restoration, since only one 

bus is assumed to spuriously operate. 

Nevertheless, a 26-minute performance 

time is credited for restoration of all 

four Unit 2 busses. 

In the unlikely event that a fire does 

occur and goes undetected by the smoke 

detection system or unsuppressed by 

the suppression system and damages 

multiple redundant cables, Action U is 

available to restore power to the busses, 

which entails tripping the breaker and 

pulling a fuse block for each of the 

busses. The location of Action U is in 

the associated Switchgear Room for 

each associated bus. Additionally, the 

Switchgear Rooms are separate fire areas 

from the Turbine Building and from 

each other and have separate ventilation 

systems from the Turbine Building. 

Therefore, a fire in Fire Area 50 would 

not impact the location of the action. 

Action V 

Action V is the same as Action U 

above but for Unit 3. There is a cable 

associated with each of the four 4kV 

busses routed through Fire Area 50. 

There is the potential for any of the four 

diesel generator output breakers to 

spuriously close, rendering the bus 

unavailable until the diesel generator 

breaker is opened and lockouts are reset. 

The four cables associated with the Unit 

3 4kV busses are: bus E13 breaker cable 

ZA3A1503E; bus E23 breaker cable 

ZB3A1606E; bus E33 breaker cable 

ZC3A1704E; and bus E43 breaker cable 

ZD3A1807E. Loss of any one of these 

cables will only affect the associated 

4kV bus and all four cables are routed 

in separate conduits. Cables 

ZA3A1503E and ZC3A1704E are routed 

in conduits that remain encapsulated in 

abandoned Thermo-Lag for their entire 

routing through Fire Area 50 while 

cables ZB3A1606E and ZD3A1807E are 

routed in conduit that is not 

encapsulated. The conduit containing 

cable ZB3A1606E is located within 5 

feet of the conduits containing cables 

ZA3A1503E and ZC3A1704E. 

Only cables ZA3A1503E and 

ZC3A1704E are necessary to power the 

busses credited for safe shutdown. 

However, Action V would restore power 

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to all four busses. Only three of the four 

busses would require restoration within 

60 minutes and only one bus is assumed 

to require restoration, since only one 

bus is assumed to spuriously operate. 

Nevertheless, a 26-minute performance 

time is credited for restoration of all 

four Unit 3 busses. The licensee stated 

that while it is possible that one of the 

cables could potentially be damaged by 

failure of the 13kV switchgear since the 

conduit containing cable ZD2A1807E 

runs above the 13kV switchgear, there is 

approximately 5 feet of separation 

between it and the next closest conduit 

which contains cable ZA2A1503E, and 

this conduit is not located above the 

13kV switchgear. Therefore, it is 

unlikely that the cables required for safe 

shut down would be damaged by a fire 

resulting from failure of the 13kV 

switchgear since the area is also 

provided with a smoke detection system 

and a pre-action sprinkler system and 

the presence of abandoned, but intact, 

Thermo-Lag to protect the cables that 

are needed to ensure power to the ‘‘A’’ 

and ‘‘C’’ train switchgear to power 

credited shutdown components. 

In the unlikely event that a fire does 

occur and goes undetected by the smoke 

detection system or unsuppressed by 

the suppression system and damages 

multiple redundant cables, Action V is 

available to restore power to the busses, 

which entails tripping the breaker and 

pulling a fuse block for each of the 

busses. The location of Action U is in 

the associated Switchgear Room for 

each associated bus. Additionally, the 

Switchgear Rooms are separate fire areas 

from the Turbine Building and from 

each other and have separate ventilation 

systems from the Turbine Building. 

Therefore, a fire in Fire Area 50 would 

not impact the location of the action. 

Action X 

The potential need to perform this 

action is low since this action is only 

needed if two of three other offsite 

power sources are unavailable, power to 

the 2SU transformer tap changer is lost, 

and the tap changer is in the wrong 

position. The licensee stated that offsite 

power is provided to each of the 4kV 

Class 1E switchgear by two of three 

redundant sources (2SU, 3SU, and 

343SU) and that control cables for the 

sources have been physically separated 

by rerouting selected cables, such that 

one of the redundant sources remains 

free of fire damage for fires in most 

plant areas. In particular, the licensee 

stated that cables associated with the 

2SU source have been relocated out of 

the Turbine Building (Fire Area 50), and 

portions of the Radwaste Building (Fire 

Areas 2 and 58). 

The licensee stated that BOP cables 

are routed through Fire Area 50 but that 

the routing of the cables was not part of 

its analysis. In its February 12, 2010, 

supplement, the licensee described the 

circumstances that would determine the 

availability of the safe shutdown 

equipment located in this area; namely 

the 2SU power source, which includes 

a transformer tap changer that is 

powered by BOP power. Since the BOP 

cable routing was not part of the 

analysis, the loss of BOP power was 

assumed for a fire in these three fire 

areas. The licensee’s analysis also 

assumed that the transformer tap 

changer, which is powered by the BOP 

and responsible for maintaining power 

to the 4kV Bus 2SU, was not in the 

correct position. When the tap changer 

is not in the correct position, the voltage 

could vary resulting in 4kV trip relays 

actuating. 

In the unlikely event that all of the 

conditions discussed above exist and 

fire damage occurs to the redundant 

cables, Action X can be utilized, which 

directs operators to pull the fuse blocks 

for the degraded voltage trip relays to 

ensure that the 4kV busses remain 

available. 

The licensee’s T–300 Fire Guides 

provide the following guidance to assist 

operators in evaluating a postulated 

event, ‘‘If 2SU is the only offsite power 

source available, and a loss of power to 

the 2SU Transformer Tap Change has 

occurred, then perform the manual 

action to remove the fuses.’’ 

A note is also provided in the Fire 

Guide for this step providing guidance 

on how to determine if the 2SU 

transformer tap changer has lost power 

using indications within the Control 

Room. Therefore, the Control Room will 

know if this action is required. 

Additionally, the 2SU transformer and 

associated auxiliaries are located in the 

yard area and would not be exposed by 

a fire in Fire Area 50. Lastly, the 

location of the OMA to remove the fuses 

in the 4kV Switchgear Rooms is in a 

separate fire area, with separate 

ventilation systems, from Fire Area 50. 

Action Y 

The licensee stated that while it is 

possible that the redundant cables in 

Fire Area 50 could potentially be 

damaged by a fire resulting from a 13kV 

switchgear failure, it is unlikely that 

both of the cables within the conduits 

would be damaged since the conduit 

containing cable ZA2B1021B remains 

encapsulated in Thermo-Lag for the 

entire length above the 13kV switchgear, 

the cable ZA2B1021B is not located 

within the same conduit as cables 

ZD3B1321B and ZD3B1321D. In 

addition, the area is provided with a 

smoke detection system, as well as a 

pre-action sprinkler system. 

The licensee stated that the redundant 

cables located in Fire Area 50 (cables 

ZA2B1021B and ZD3B1321B or 

ZD3A1321D) are located approximately 

5 feet from each other and that no 

intervening combustibles are present 

between the two trains of cables. 

Additionally, the conduit containing 

cable ZA2B1021B remains encapsulated 

in abandoned Thermo-Lag for the entire 

routing through Fire Area 50. The 

licensee also stated that the conduits 

containing the cables associated with 

this OMA are routed directly above 

(approximately 5 feet) the 13kV 

switchgear cabinets in the room and that 

the conduits are assumed to be located 

within the anticipated heat plume in the 

event of a 13kV switchgear failure. 

In the unlikely event that a fire does 

occur and goes undetected by the smoke 

detection system or unsuppressed by 

the suppression system and both trains 

of cable are lost, an OMA (Action V) is 

available to restore or maintain the 

necessary function to the effected 

equipment (SU–25 Breaker). Action V 

directs an operator to transfer SU–25 

breaker auxiliary equipment from the 

normal power source to its alternate 

power source, by operating manual 

transfer switch 00S306, which is located 

in the Unit 2 Startup Building, which is 

located in the exterior yard area. 

NRC Staff Evaluation 

Given the limited amount of 

combustible materials and the volume 

of the space, it is unlikely that a fire 

would occur and go undetected by the 

smoke detection system noted above or 

unsuppressed by the suppression 

systems noted above or by personnel, 

and damage the safe shutdown 

equipment. Even if such circumstances 

exist, Actions U, V, X, and Y are 

available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.4.11 Fire Area 58 (Unit 3 MG Set 

Room) 

Fire Prevention 

The licensee stated that the 

combustible loading in Fire Area 58 is 

considered to be moderate and consists 

primarily of lube oil from the MG set. 

Other combustible materials in the area 

include fire retardant cable insulation 

and Thermo-Lag. Additionally, the MG 

set and the MCCs located in the room 

represent ignition sources. 

Detection, Control, and Extinguishment 

The licensee stated that Fire Area 58 

has a pre-action sprinkler system 

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installed that is designed to provide 

localized protection of the MG set with 

sprinkler heads located over the MG set 

itself and not at the ceiling. Although 

this is not considered to be an area-wide 

system and does not comply with NFPA 

13, this system was an original plant 

installation designed to provide 

localized protection of the MG set. The 

pre-action system is actuated 

automatically by any one of the six 

smoke detectors in the room, which are 

also located directly above the MG set 

and not at the ceiling. Since the 

detectors are not located at the ceiling 

level, the smoke detection system does 

not comply with NFPA 72, but still 

provides some smoke detection 

capability for the area as a whole and 

would be expected to alert operators of 

the credible fire scenarios for this area. 

Additionally, the licensee stated that a 

fully trained onsite fire brigade is 

provided, which is dispatched via plant 

page in the event of a fire. The fire 

brigade is composed of plant operators 

that are separate from operators 

assigned safe shutdown duties and are 

instructed to provide information about 

a fire event over the operations radio to 

assist in mitigating the event. 

Preservation of Safe Shutdown 

Capability 

The licensee stated that Fire Area 58 

has a ceiling height of approximately 29’ 

and an approximate floor area of 3,525 

square feet, so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

OMAs Credited for a Fire in This Area 

Action BB 

The licensee stated that while it is 

possible that the two redundant cables 

in Fire Area 58 associated with the 

normal power supply to the 3DD003 

battery charger could potentially be 

damaged by a lube oil or MG set fire, it 

is unlikely that the cables within the 

conduits would be damaged since the 

conduit containing cable ZD3B3983A is 

not located above the MG set. In 

addition, there is a smoke detection 

system provided in the area, as well as 

a pre-action sprinkler system located 

above the MG set. In the unlikely event 

that both cables are lost, the location of 

the action is in a different fire area from 

Fire Area 58. 

A fire in Fire Area 58 has the 

potential to damage cables ZD3A1806A 

and ZD3B3983A, which the licensee 

stated are located in conduits embedded 

in the concrete floor slab, control 

panels, and a junction box. The loss of 

either of these cables could result in a 

loss of the normal power supply to the 

3DD003 battery charger. The battery 

charger is needed to maintain long term 

DC power through the station batteries. 

The batteries can operate for 60 minutes 

prior to the initiation of recharging. 

Battery charger 3DD003 can also be fed 

an alternate power source, which is 

routed in separate fire areas, so a single 

fire cannot damage both the normal and 

alternate power feed. 

In the unlikely event that a fire does 

occur and goes undetected by the smoke 

detection system or unsuppressed by 

the suppression system and the cables 

are damaged, Action BB is available to 

transfer the alternate power supply to 

battery charger 3DD003. The action 

entails closing a breaker and then 

operating a manual transfer switch, both 

located in the E43 4kV Switchgear 

Room (Fire Area 34), which is a separate 

fire area from Fire Area 58. 

Action CC 

The potential need to perform this 

action is low since this action is only 

needed if two of three other offsite 

power sources are unavailable, power to 

the 2SU transformer tap changer lost, 

and the tap changer is in the wrong 

position. The licensee stated that offsite 

power is provided to each of the 4kV 

Class 1E switchgear by two of three 

redundant sources (2SU, 3SU, and 

343SU) and that control cables for the 

sources have been physically separated 

by rerouting selected cables, such that 

one of the redundant sources remains 

free of fire damage for fires in most 

plant areas. In particular, the licensee 

stated that cables associated with the 

2SU source have been relocated out of 

the Turbine Building (Fire Area 50), and 

portions of the Radwaste Building (Fire 

Areas 2 and 58). 

The licensee stated that BOP cables 

are routed through Fire Area 58 but that 

the routing of the cables was not part of 

its analysis. In its February 12, 2010, 

supplement, the licensee described the 

circumstances that would determine the 

availability of the safe shutdown 

equipment located in this area; namely 

the 2SU power source, which includes 

a transformer tap changer that is 

powered by BOP power. Since the BOP 

cable routing was not part of the 

analysis, the loss of BOP was assumed 

for a fire in these three fire areas. The 

licensee’s analysis also assumed that the 

transformer tap changer, which is 

powered by the BOP and responsible for 

maintaining power to the 4kV Bus 2SU, 

was not in the correct position. When 

the tap changer is not in the correct 

position, the voltage could vary 

resulting in the actuation of the 4kV trip 

relays. 

In the unlikely event that a fire does 

occur and goes undetected by the smoke 

detection system or unsuppressed by 

the suppression system and fire damage 

occurs to the redundant cables, Action 

CC can be utilized, which directs 

operators to pull the fuse blocks for the 

degraded voltage trip relays to ensure 

that the 4kV busses remain available. 

Action CC is a ‘‘prompt’’ action, 

however, the licensee stated that its 

analysis assumed that the redundant 

cables were lost regardless of their 

location and that the tap changer was 

not in the correct position. The licensee 

also stated that a note is provided in the 

applicable T–300 Fire Guide providing 

guidance on how to determine whether 

the 2SU transformer tap changer has lost 

power using indications within the 

Control Room. Therefore, the Control 

Room will know immediately if this 

action is required and a generic 

diagnosis time is not necessary. 

The licensee’s T–300 Fire Guides also 

provide the following guidance to assist 

operators in evaluating a postulated 

event, ‘‘If 2SU is the only offsite power 

source available and a loss of power to 

the 2SU Transformer Tap Changer has 

occurred, then perform the manual 

action to remove the fuses.’’ 

Additionally, the 2SU transformer 

and associated auxiliaries are located in 

the yard area and would not be exposed 

by a fire in Fire Area 58. Lastly, the 

location of the OMA to remove the fuses 

in the 4kV Switchgear Rooms is in a 

separate fire area, with separate 

ventilation systems, from Fire Area 58. 

NRC Staff Evaluation 

Given the moderate amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected by the smoke detection 

system noted above or unsuppressed by 

the suppression system noted above or 

by personnel, and damage the safe 

shutdown equipment. Even if such 

circumstances exist, Actions BB and CC 

are available to provide additional 

assurance that safe shutdown capability 

is maintained. 

3.5 Summary of Defense-in-Depth and 

Operator Manual Actions 

In summary, the NRC staff finds that 

the defense-in-depth concept for a fire 

in the fire areas discussed above 

provides a level of safety that results in 

the unlikely occurrence of fires, rapid 

detection, control and extinguishment 

of fires that do occur and the protection 

of structures, systems and components 

important to safety. As discussed above, 

the licensee has provided preventative 

and protective measures in addition to 

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feasible and reliable OMAs that together 

demonstrate the licensee’s ability to 

preserve or maintain safe shutdown 

capability in the event of a fire in the 

analyzed fire areas. 

Authorized by Law 

This exemption would allow PBAPS 

to rely on OMAs, in conjunction with 

the other installed fire protection 

features, to ensure that at least one 

means of achieving and maintaining hot 

shutdown remains available during and 

following a postulated fire event, as part 

of its FPP, in lieu of meeting the 

requirements specified in III.G.2 for a 

fire in the analyzed fire areas. As stated 

above, 10 CFR 50.12 allows the NRC to 

grant exemptions from the requirements 

of 10 CFR Part 50. The NRC staff has 

determined that granting of this 

exemption will not result in a violation 

of the Atomic Energy Act of 1954, as 

amended, or the Commission’s 

regulations. Therefore, the exemption is 

authorized by law. 

No Undue Risk to Public Health and 

Safety 

The underlying purpose of 10 CFR 

Part 50, Appendix R, Section III.G is to 

ensure that at least one means of 

achieving and maintaining hot 

shutdown remains available during and 

following a postulated fire event. Based 

on the above, no new accident 

precursors are created by the use of the 

specific OMAs, in conjunction with the 

other installed fire protection features, 

in response to a fire in the analyzed fire 

areas. Thus, 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. 

Consistent with Common Defense and 

Security 

The proposed exemption would allow 

PBAPS to credit the use of the specific 

OMAs, in conjunction with the other 

installed fire protection features, in 

response to a fire in the analyzed fire 

areas, discussed above, in lieu of 

meeting the requirements specified in 

III.G.2. This change, to the operation of 

the plant, has no relation to security 

issues. Therefore, the common defense 

and security is not diminished by this 

exemption. 

Special Circumstances 

Pursuant to 10 CFR 50.12(a)(2)(ii) 

special circumstances are present 

whenever application of the regulation 

in the particular circumstances is not 

necessary to achieve the underlying 

purpose of the rule. The underlying 

purpose of 10 CFR Part 50, Appendix R, 

Section III.G is to ensure that at least 

one means of achieving and maintaining 

hot shutdown remains available during 

and following a postulated fire event. 

Therefore, since the underlying purpose 

of Appendix R, Section III.G is 

achieved, the special circumstances for 

granting an exemption from 10 CFR Part 

50, Appendix R, Section III.G exist, as 

required by 10 CFR 50.12(a)(2)(ii). 

4.0 Conclusion 

Accordingly, the Commission has 

determined that, pursuant to 10 CFR 

50.12(a), the exemption is authorized by 

law, will not present an undue risk to 

the public health and safety, and is 

consistent with the common defense 

and security. Also, special 

circumstances are present. Therefore, 

the Commission hereby grants Exelon 

an exemption from the requirements of 

Section III.G.2 of Appendix R of 10 CFR 

Part 50, to utilize the OMAs discussed 

above at PBAPS. 

Pursuant to 10 CFR 51.32, the 

Commission has determined that the 

granting of this exemption will not have 

a significant effect on the quality of the 

human environment (75 FR 58445). 

This exemption is effective upon 

issuance. 

Dated at Rockville, Maryland, this 30th day 

of March 2011. 

For The Nuclear Regulatory Commission. 

Joseph G. Giitter, 

Director, Division of Operating Reactor 

Licensing, Office of Nuclear Reactor 

Regulation. 

[FR Doc. 2011–8317 Filed 4–6–11; 8:45 am] 

BILLING CODE 7590–01–P 

NUCLEAR REGULATORY 

COMMISSION 

[Docket No. 50–219; NRC–2010–0200] 

Exelon Generation Company, LLC, 

Oyster Creek Nuclear Generating 

Station; Exemption 

1.0 Background 

Exelon Generation Company, LLC 

(Exelon or the licensee) is the holder of 

Facility Operating License No. DPR–16 

that authorizes operation of the Oyster 

Creek Nuclear Generating Station 

(Oyster Creek). The license provides, 

among other things, that the facility is 

subject to all rules, regulations, and 

orders of the U.S. Nuclear Regulatory 

Commission (NRC or the Commission) 

now or hereafter in effect. 

The facility consists of a boiling-water 

reactor located in Ocean County, New 

Jersey. 

2.0 Request/Action 

Title 10 of the Code of Federal 

Regulations (10 CFR), Part 50, Section 

50.48 requires that nuclear power plants 

that were licensed before January 1, 

1979, must satisfy the requirements of 

10 CFR Part 50, Appendix R, Section 

III.G, ‘‘Fire protection of safe shutdown 

capability.’’ Oyster Creek was licensed 

to operate prior to January 1, 1979. As 

such, the licensee’s Fire Protection 

Program must provide the established 

level of protection as intended by 

Section III.G of 10 CFR Part 50, 

Appendix R. 

By letter dated March 4, 2009, 

‘‘Request for Exemption from 10 CFR 50, 

Appendix R, Section III.G, ‘Fire 

Protection of Safe Shutdown Capability 

(Phase 2)’ ’’ available at Agencywide 

Documents Access and Management 

System (ADAMS), Accession No. 

ML090640225, and supplemented by 

letter dated April 2, 2010, ‘‘Response to 

Request for Additional Information 

Request for Exemption from 10 CFR Part 

50, Appendix R, Section III.G, ‘Fire 

Protection of Safe Shutdown 

Capability’ ’’ (ADAMS Accession No. 

ML100920370), the licensee requested 

an exemption for Oyster Creek from 

certain technical requirements of 10 

CFR Part 50, Appendix R, Section III.G.2 

(III.G.2) for the use of operator manual 

actions (OMAs) in lieu of meeting the 

circuit separation and protection 

requirements contained in III.G.2 for the 

following 22 plant areas: CW–FA–14, 

OB–FA–9, OB–FZ–6A, OB–FZ–6B, OB– 

FZ–8A, OB–FZ–8B, OB–FZ–8C, OB– 

FZ–10A, RB–FZ–1D, RB–FZ–1E, RB– 

FZ–1F3, RB–FZ–1F5, RB–FZ–1G, TB– 

FA–3A, TB–FA–26, TB–FZ–11B, TB– 

FZ–11C, TB–FZ–11D, TB–FZ–11E, TB– 

FZ–11F, TB–FZ–11H, and Yard. The 22 

plant areas noted above are the subject 

of this exemption. 

3.0 Discussion 

Pursuant to 10 CFR 50.12, the 

Commission may, upon application by 

any interested person or upon its own 

initiative, grant exemptions from the 

requirements of 10 CFR Part 50 when: 

(1) The exemptions are authorized by 

law, will not present an undue risk to 

public health or safety, and are 

consistent with the common defense 

and security; and (2) when special 

circumstances are present. The licensee 

has stated that special circumstances are 

present in that the application of the 

regulation in this particular 

circumstance is not necessary to achieve 

the underlying purpose of the rule, 

which is consistent with the language 

included in 10 CFR 50.12(a)(2)(ii). 

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