19488 Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices 

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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In their March 4, 2009, and April 2, 

2010, letters, the licensee discussed 

financial implications associated with 

plant modifications that may be 

necessary to comply with the regulation. 

Section 50.12(a)2(iii) of 10 CFR states 

that if such costs have been shown to be 

significantly in excess of those 

contemplated at the time the regulation 

was adopted, or are significantly in 

excess of those incurred by others 

similarly situated, this may be 

considered a basis for considering an 

exemption request. However, financial 

implications were not considered in the 

regulatory review of their request since 

no substantiation was provided 

regarding such financial implications. 

Even though no financial substantiation 

was provided, the licensee did submit 

sufficient regulatory basis to support a 

technical review of their exemption 

request in that the application of the 

regulation in this particular 

circumstance is not necessary to achieve 

the underlying purpose of the rule. 

In accordance with 10 CFR 50.48(b), 

nuclear power plants licensed before 

January 1, 1979, are required to meet 

Section III.G of 10 CFR Part 50, 

Appendix R. The underlying purpose of 

Section III.G of 10 CFR Part 50, 

Appendix R, is to ensure that the ability 

to achieve and maintain safe shutdown 

is preserved following a fire event. The 

regulation intends for licensees to 

accomplish this by extending the 

concept of defense-in-depth to: 

(1) Prevent fires from starting; 

(2) Rapidly detect, control, and 

extinguish promptly those fires that do 

occur; 

(3) Provide protection for structures, 

systems, and components important to 

safety so that a fire that is not promptly 

extinguished by the fire suppression 

activities will not prevent the safe 

shutdown of the plant. 

The stated purpose of 10 CFR Part 50, 

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

ensure that one of the redundant trains 

necessary to achieve and maintain hot 

shutdown conditions remains free of 

fire damage in the event of a fire. 

Section III.G.2 requires one of the 

following means to ensure that a 

redundant train of safe shutdown cables 

and equipment is free of fire damage, 

where redundant trains are located in 

the same fire area outside of primary 

containment: 

a. Separation of cables and equipment 

by a fire barrier having a 3-hour rating; 

b. Separation of cables and equipment 

by a horizontal distance of more than 20 

feet with no intervening combustibles or 

fire hazards and with fire detectors and 

an automatic fire suppression system 

installed in the fire area; or 

c. Enclosure of cables and equipment 

of one redundant train in a fire barrier 

having a 1-hour rating and with fire 

detectors and an automatic fire 

suppression system installed in the fire 

area. 

Exelon has requested an exemption 

from the requirements of III.G.2 for 

Oyster Creek to the extent that 

redundant trains of systems necessary to 

achieve and maintain hot shutdown are 

not maintained free of fire damage in 

accordance with one of the required 

means prescribed in III.G.2. 

Each OMA included in this review 

consists of a sequence of tasks that 

occur in various fire areas. The OMAs 

are initiated upon confirmation of a fire 

in a particular fire area. Table 1 lists, in 

the order of the fire area of fire origin, 

the OMAs included in this review. 

TABLE 1 

Area of fire origin Area name Actions OMA # 

1 .......... CW–FA–14 ............ Circulatory Water Intake ................. Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

2 .......... OB–FA–9 ............... Office Building (Bldg.) Elev. 23′-6′′, 

35′-0′′, 46′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

3 .......... OB–FZ–6A ............. Office Bldg. ‘‘A’’ 480V Switchgear 

(SWGR) Room Elev. 23′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

4 .......... OB–FZ–6B ............. Office Bldg. ‘‘B’’ 480V SWGR Room 

Elev. 23′-6′′.

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

5 .......... OB–FZ–8A ............. Office Bldg. Reactor Recirculation 

Motor Generator (MG) Set Room 

Elev. 23′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

6 .......... OB–FZ–8B ............. Office Bldg. Mechanical Equipment 

Room Elev. 35′-0′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

7 .......... OB–FZ–8C ............ Office Bldg. A/B Battery Room, 

Tunnel and Electrical Tray Room 

Elev. 35′-0′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

8 .......... OB–FZ–10A ........... Office Bldg. Monitor and Change 

Room Area and Operations Support Area Elev. 35′-0′′ & 46′-6′′.

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

9 .......... RB–FZ–1D ............. Reactor Bldg. Elev. 51′-3′′ .............. Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

10 ........ RB–FZ–1E ............. Reactor Building Elev. 23′-6′′ .......... Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

11 ........ RB–FZ–1F3 ........... Reactor Bldg. Northwest Corner 

Elev.-19′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

12 ........ RB–FZ–1F5 ........... Reactor Bldg. Torus Room Elev. 

-19′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

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TABLE 1—Continued 

Area of fire origin Area name Actions OMA # 

13 ........ RB–FZ–1G ............ Reactor Bldg. Shutdown Cooling 

Room Elev. 38′-0′′ & 51′-3′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

14 ........ TB–FA–3A ............. Turbine Bldg. 4160V Emergency 

SWGR Vault 1C Elev. 23′-6′′.

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

15 ........ TB–FA–26 ............. Turbine Bldg. 125V DC Battery 

Room C Elev. 23′-6′′.

Trip Field Breakers for Recirculation Pumps MG Set so that the 

Fuel Zone Level Indicators can be used.

1 

Provide Fire Water to Isolation Condenser shell by operating 

valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to 

loss of power (contingency action).

2 

Manually control 480V USS 1B2 Breakers for control rod drive 

(CRD) Pump NC08B and 1B2M from Remote Shutdown 

Panel due to control circuit damage.

3 

Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).7 

Check Isolation Condenser Shell level locally due to loss of 

power (contingency action).

8 

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

16 ........ TB–FZ–11B ........... Turbine Bldg. Lube Oil Storage, Purification and Pumping Area Elev. 

0′-0′′, 27′-0′′, and 36′-0′′.

Manually control 480V Unit Substation (USS) 1B2 Breakers for 

CRD Pump NC08B and 1B2M from Remote Shutdown Panel 

due to control circuit damage.

3 

......... Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

17 ........ TB–FZ–11C ........... Turbine Bldg. SWGR Room 1A and 

1B Elev. 23′-6′′.

Trip Field Breakers for Recirculation Pumps MG Set so that the 

Fuel Zone Level Indicators can be used.

1 

Provide Fire Water to Isolation Condenser shell by operating 

valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to 

loss of power (contingency action).

2 

Manually control 480V USS 1B2 Breakers for CRD Pump 

NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.

3 

Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).7 

Check Isolation Condenser Shell level locally due to loss of 

power (contingency action).

8 

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

18 ........ TB–FZ–11D ........... Turbine Bldg. Basement Floor 

South End Elev. 3′-6′′.

Trip Field Breakers for Recirculation Pumps MG Set so that the 

Fuel Zone Level Indicators can be used.

1 

Provide Fire Water to Isolation Condenser shell by operating 

valves V–9–2099, V–11–49, V–11–63 and V–11–41 due to 

loss of power (contingency action).

2 

Manually control 480V USS 1B2 Breakers for CRD Pump 

NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.

3 

Manually open V–11–36 to provide makeup to Isolation Condenser due to loss of power (contingency action).7 

Check Isolation Condenser Shell level locally due to loss of 

power (contingency action).

8 

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

19 ........ TB–FZ–11E ........... Turbine Bldg. Condenser Bay Area 

Elev. 0′-0′′.

Manually control 480V USS 1B2 Breakers for CRD Pump 

NC08B and 1B2M from Remote Shutdown Panel due to control circuit damage.

3 

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

20 ........ TB–FZ–11F ........... Turbine Bldg. Feedwater Pump 

Room Elev. 0′-0′′ & 3′-6′′.

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

21 ........ TB–FZ–11H ........... Turbine Bldg. Demineralizer Tank 

and Steam Jet Air Ejector Area 

Elev. 3′-6′′ & 23′-6′′.

Provide makeup control air to the accumulator for V–11–36 for 

the Isolation Condenser makeup line due to the loss of instrument air.

18 

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TABLE 1—Continued 

Area of fire origin Area name Actions OMA # 

22 ........ Yard ....................... Office Bldg. Roof, Turbine Bldg. 

Roof, and All Remaining Outside 

Areas.

Manually open V–15–237, throttle V–15–30 while monitoring 

flow at FI–225–2 and close V–15–52 to establish CRD flow 

to Reactor due to the loss of instrument air to the CRD Flow 

Control Valve.

9 

Provide makeup control air to the accumulator for V–11–34 for 

the Isolation Condenser makeup line due to the loss of instrument air.

17 

In their submittals the licensee 

described elements of their fire 

protection program that provide their 

justification that the concept of defensein-depth that is in place in the above fire 

areas is consistent with that intended by 

the regulation. To accomplish this, the 

licensee utilizes various protective 

measures to accomplish the concept of 

defense-in-depth. Specifically, the 

licensee stated that the purpose of their 

request was to credit the use of OMAs, 

in conjunction with other defense-indepth features, in lieu of the separation 

and protective measures required by 

III.G.2 for a fire in the fire areas stated 

above. 

In their April 2, 2010, letter the 

licensee provided an analysis that 

described how fire prevention is 

addressed for each of the fire areas for 

which the OMAs may be required. The 

licensee developed a Fire Hazards 

Analysis (FHA) for each fire area or 

zone identified in its exemption request. 

For each fire area or zone, the FHA 

describes the physical location and 

arrangement of equipment, combustible 

loading, ignition sources, fire protection 

features, and proximity of redundant 

safe shutdown equipment to in situ 

hazards and identifies deviations from 

fire protection codes and previously 

approved exemptions. In addition, for 

each fire area or zone, the licensee’s 

response includes a tabulation of 

potential ignition sources as well as the 

equipment that may exhibit high energy 

arcing faults. For each fire area or zone, 

the FHA states that the fire protection 

configuration achieves a level of 

protection commensurate with that 

intended by III.G.2. 

The 22 areas or zones identified in the 

request have administratively limited 

combustible fuel loading with fuel 

sources consisting primarily of cable 

insulation and limited floor based 

combustibles except areas OB–FZ–6A, 

OB–FZ–6B, and TB–FZ–11B, which 

contain quantities of transformer liquid 

or lubricating oil. Combustible fuel 

loading in most areas is classified as low 

by the licensee while Fire Areas OB– 

FZ–6A and OB–FZ–6B have been 

classified as having a moderate 

combustible fuel loading and TB–FZ– 

11B has been classified as having a high 

combustible fuel loading. In addition, 

the licensee has stated that they 

maintain a robust administrative 

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

watches for hot work, and supervisory 

controls) to limit and control transient 

combustible materials and ignition 

sources in the areas. The fire areas 

included in the exemption are not shop 

areas so hot work activities are 

infrequent and the administrative 

control programs are in place if hot 

work activities do occur. 

The licensee also stated that 98% of 

the Oyster Creek cables are jacketed 

with Vulkene, which passes the 

horizontal flame test of the 

Underwriter’s Laboratory, therefore 

reducing the likelihood of the cables 

themselves contributing to a fire hazard. 

Furthermore, the areas or zones are of 

noncombustible construction with 

typical utilities installed lighting, 

ventilation, etc., and 3-hour fire 

resistance-rated barriers normally used 

to provide fire resistive separation 

between adjacent fire areas. In some 

cases, barriers with a fire resistance 

rating of less than 3 hours are credited, 

but exemptions have been approved or 

the licensee has stated they have 

performed engineering evaluations in 

accordance with Generic Letter 86–10 to 

demonstrate that the barriers are 

sufficient for the hazard. Walls 

separating rooms and zones within fire 

areas are typically constructed of heavy 

concrete. This compartmentalization of 

the areas reduces the likelihood for fire 

events in a particular area to spread to 

or impact other adjacent areas. 

Many fire areas included in this 

exemption have automatic detection 

systems installed, although the licensee 

indicated that not all systems are 

installed in accordance with a 

recognized standard with regard to 

spacing in all areas. In such cases, the 

licensee has stated that the detectors are 

located near equipment such that they 

are likely to detect a fire. Upon 

detecting smoke, the detectors initiate 

an alarm in the constantly staffed 

control room. In addition to the 

automatic suppression systems noted 

below, equipment operators are trained 

fire brigade members and may identify 

and manually suppress or extinguish a 

fire using the portable fire extinguishers 

and manual hose stations located 

throughout the fire areas if a fire is 

identified in its early stages of growth. 

The licensee stated that the postulated 

fire events that may require the use of 

the OMAs would include multiple 

failures of various components or 

equipment. In most cases, it is 

considered unlikely that the sequence of 

events required to necessitate the OMAs 

would fully evolve because of the fire 

prevention, fire protection, and physical 

separation features in place. However, 

in the event that the sequence does 

evolve, the OMAs are available to 

provide assurance that safe shutdown 

can be achieved. For each of the fire 

areas included in this exemption, the 

postulated fire scenarios and pertinent 

details are summarized in Table 2 

below. 

Each of the fire areas or zones 

included in this exemption is analyzed 

below with regard to how the concept 

of defense-in-depth is achieved for each 

area or zone and the role of the OMAs 

in the overall level of safety provided 

for each area or zone. 

3.1 CW–FA–14 Circulatory Water 

Intake 

3.1.1 Fire Prevention 

The licensee stated that combustible 

loading is not tracked in this area since 

it is an outside area. The licensee also 

stated that the primary combustible 

materials in the area are transformer 

liquid and electrical motors; although 

the amount is not quantified since the 

area is open to the atmosphere with no 

walls or ceiling to contain the heat or 

smoke that may be produced during a 

fire event. Additionally, the main 

combustible in this area that could 

result in the need for the OMAs is Dow 

Corning 561 Silicon transformer liquid, 

which the licensee states has 

characteristics that minimize the 

likelihood of a fire involving the 

insulating liquid itself. 

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3.1.2 Detection, Control, and 

Extinguishment 

CW–FA–14 is not equipped with 

automatic fire detection or suppression 

systems but since it is an outdoor area 

with no walls or ceiling, it is not 

expected that such systems would 

enhance this element of defense-indepth in this area since the area is open 

to the atmosphere with no walls or 

ceiling to contain the heat or smoke that 

may be produced during a fire event. 

However, the licensee stated that a 

security tower monitors this area 

continuously. Therefore, any fire of 

significance would likely be detected 

and responded to appropriately by the 

station fire brigade. Manual suppression 

is also provided by a fire hydrant and 

fire hose house located approximately 

75 feet from the principal fire hazards. 

3.1.3 Preservation of Safe Shutdown 

Capability 

Since Fire Area CW–FA–14 is an 

outdoor space with no walls or ceiling, 

smoke and heat would not accumulate 

within the fire area to cause damage to 

components remote to the initiating fire 

or obstruct operator actions. 

3.1.4 OMAs Credited for a Fire in This 

Area 

3.1.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the main steam 

isolation valves (MSIVs) will close, as 

well as multiple air-operated valves 

changing state. Additionally, reactor 

pressure vessel (RPV) level indication is 

also available for all fire areas or zones. 

All of these indications would help the 

operator diagnose the loss of instrument 

air and initiate mitigating procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.1.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and open nature of the area, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.2 OB–FA–9 Office Bldg. Elev. 23′-6′′, 

35′-0′′, 46′-6′′, 

3.2.1 Fire Prevention 

The licensee has classified the fire 

loading in this fire area as low. The 

licensee also stated that the major 

combustibles in the multiplexer (MUX) 

corridor, which is within OC–FA–9, are 

cable insulation and a wood ceiling on 

top of the MUX enclosure, which is 

within the MUX corridor. 

3.2.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FA–9 has 

a partial area coverage wet pipe 

sprinkler system installed. The licensee 

further stated that the area is not 

provided with a detection system but 

that there is an installed detection 

system in the main hallways and inside 

of the MUX corridor and that it is a high 

traffic area so a fire would likely be 

detected by personnel. The wet pipe 

sprinkler system, when actuated, will 

alarm in the control room to notify 

operators of a potential fire event. 

Extinguishment of a fire in the majority 

of this area will be accomplished by the 

plant fire brigade. 

3.2.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FA–9 has 

a ceiling height of approximately 10′-6′′, 

and an approximate floor area of 513 

square feet in the MUX corridor where 

the safe shutdown equipment is located 

so it is unlikely that smoke and heat 

would accumulate at the height of the 

safe shutdown equipment and cause a 

failure due to fire damage. 

3.2.4 OMAs Credited for a Fire in this 

Area 

3.2.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

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panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.2.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and volume of the space, it is unlikely 

that a fire would occur and go 

undetected or unsuppressed by the 

sprinkler system noted above, or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.3 OB–FZ–6A Office Bldg. ‘‘A’’ 480V 

Switchgear (SWGR) Room Elev. 23′-6′′, 

3.3.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is moderate and 

that there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the main combustibles in this area are 

cable insulation (approximately 81% of 

loading) and Dow Corning 561 Silicon 

transformer liquid (approximately 15% 

of loading). The transformer liquid has 

characteristics that minimize the 

likelihood of a fire involving the 

insulating liquid itself. 

3.3.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FZ–6A 

has an automatic smoke detection 

system, a total flooding automatic Halon 

1301 System, and manual fire fighting 

capabilities (portable extinguishers and 

hose stations). 

3.3.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FA–6A 

has a ceiling height of approximately 

10′-8′′, and an approximate floor area of 

1157 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.3.4 OMAs Credited for a Fire in this 

Zone 

3.3.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.3.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or Halon system noted 

above, or personnel, and damage the 

safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.4 OB–FZ–6B Office Building ‘‘B’’ 

480V SWGR Room Elev. 23′-6′′, 

3.4.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is moderate and 

that there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the main combustibles in this area are 

cable insulation (approximately 28% of 

loading), Thermo-Lag (approximately 

29% of loading) and Dow Corning 561 

Silicon transformer liquid 

(approximately 31% of loading). The 

transformer liquid has characteristics 

that minimize the likelihood of a fire 

involving the insulating liquid itself. 

3.4.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FZ–6B 

has an automatic smoke detection 

system, a total flooding Halon 1301 

System, and manual fire fighting 

capabilities (portable extinguishers and 

hose stations). 

3.4.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FA–6B 

has a ceiling height of approximately 

10′-8′′ and an approximate floor area of 

679 square feet so it is unlikely that 

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smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.4.4 OMAs Credited for a Fire in This 

Zone 

3.4.4.1 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.4.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or Halon system noted 

above, or personnel, and damage the 

safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #18 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.5 OB–FZ–8A Office Bldg. Reactor 

Recirculation MG Set Room & OB–FZ– 

8B Mechanical Equipment Room Elev. 

23′-6′′ & 35′-0′′ 

3.5.1 Fire Prevention 

Fire Zones OB–FZ–8A and 8B are 

evaluated together for the combustible 

loading and fire safe shutdown analysis. 

The licensee stated that the fire loading 

in this zone is low and that there is an 

administrative controls program in 

place to limit additional combustible 

materials and sources of ignition. The 

licensee also stated that there are 

minimal combustibles in Fire Zone OB– 

FZ–8B. The major combustibles in Fire 

Zone OB–FZ–8A are lubricating oil 

(approximately 83% of loading) and 

cable insulation (approximately 13% of 

loading). 

3.5.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FZ–8A 

has a partial wet-pipe sprinkler system 

with a flow alarm that notifies the 

control room and that the area does not 

have a smoke detection system however, 

a duct smoke detector is located in the 

exhaust duct of fan EF–1–20. Since 

operation of the sprinkler system will 

alarm in the control room, prompt 

notification of and response by, the fire 

brigade for any required manual fire 

fighting activities is expected. 

3.5.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FZ–8A 

has a ceiling height of approximately 

10′-10′′ and an approximate floor area of 

2128 square feet and OB–FZ–8B has a 

ceiling height of approximately 11′-0′′ 

and an approximate floor area of 479 

square feet so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

3.5.4 OMAs Credited for a Fire in This 

Area 

3.5.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

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becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.5.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or sprinkler systems 

noted above, or personnel, and damage 

the safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment in this zone, combined with 

the ability of OMA #17 to manipulate 

the plant in the event of a fire that 

damages safe shutdown equipment, 

provides adequate assurance that safe 

shutdown capability is maintained. 

3.6 OB–FZ–8C Office Bldg. A/B Battery 

Room, Tunnel and Electrical Tray Room 

Elev. 35′-0′′ 

3.6.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in Fire Zone 

OB–FZ–8C are electrolyte-filled plastic 

battery cases and racks (approximately 

56% of loading) and cable insulation 

(approximately 39% of loading). 

3.6.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FZ–8C 

has a fixed, total-flooding, Halon 1301 

extinguishing system, area-wide smoke 

detection that is installed at the ceiling 

level and cross-zoned to sound a local 

alarm, and an alarm in the control room 

upon actuation of one detector. 

Actuation of a second detector will 

sound a local alarm, discharge the 

Halon system, trip supply and exhaust 

fans, and close dampers. 

3.6.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FZ–8C 

has a ceiling height of approximately 

11′-0′′ and an approximate floor area of 

1292 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.6.4 OMAs Credited for a Fire in This 

Zone 

3.6.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.6.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or Halon systems noted 

above, or personnel, and damage the 

safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.7 OB–FZ–10A Office Bldg. Monitor 

and Change Room and Operations 

Support Area Elev. 35′-0′′ & 46′-6′′ 

3.7.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

cable insulation (approximate 27% of 

loading), rubber flooring (approximately 

31% of loading), miscellaneous plastics 

(approximately 17% of loading) and 

protective clothing supplies 

(approximately 20% of loading). 

However, since the protective clothing 

have been placed in metal cans with 

self-closing lids they are no longer 

considered a contribution to the 

combustibles in this area. 

3.7.2 Detection, Control, and 

Extinguishment 

The licensee stated that OB–FZ–10A 

has an area-wide smoke detection 

system and a wet-pipe automatic 

sprinkler system installed throughout 

the area. In addition, a hose station 

located nearby, outside the control 

room, provides manual suppression 

capability. 

3.7.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that OB–FZ–10A 

has a ceiling height of approximately 

13′-0′′ and an approximate floor area of 

2019 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

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3.7.4 OMAs Credited for a Fire in This 

Area 

3.7.4.1 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 29 

minutes, while the time available is 300 

minutes, which provides a 241-minute 

margin. 

3.7.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or sprinkler systems 

noted above, or personnel, and damage 

the safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #18 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.8 RB–FZ–1D Reactor Bldg. Elev. 

51′-3′′ 

3.8.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the main combustible in this area is 

attributed to cable insulation 

(approximately 84% of loading). 

3.8.2 Detection, Control, and 

Extinguishment 

The licensee stated that RB–FZ–1D 

has an area-wide smoke detection 

system and an automatic fixed deluge 

water spray system installed over cable 

trays and open hatches. The deluge 

suppression system protecting safety 

related cable trays is automatically 

activated by a cross-zoned detection 

system consisting of linear heat 

detection wire located on top of the 

cables in each original safety related 

cable tray and smoke detectors are 

located in each beam pocket at the 

ceiling. 

3.8.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that RB–FZ–1D 

has a ceiling height of approximately 

21′-0′′ and an approximate floor area of 

9,100 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.8.4 OMAs Credited for a Fire in This 

Area 

3.8.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

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3.8.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or localized water 

deluge systems noted above, or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.9 RB–FZ–1E Reactor Bldg. Elev. 51′- 

3′′ 

3.9.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the main combustible in this area is 

attributed to cable insulation 

(approximately 84% of loading). 

3.9.2 Detection, Control, and 

Extinguishment 

The licensee stated that RB–FZ–1E 

has an area-wide smoke detection 

system and an automatic fixed deluge 

water spray system installed over cable 

trays and open hatches. The deluge 

suppression system protecting safety 

related cable trays is automatically 

activated by a cross-zoned detection 

system consisting of linear heat 

detection wire located on top of the 

cables in each original safety related 

cable tray and smoke detectors are 

located in each beam pocket at the 

ceiling. 

3.9.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that RB–FZ–1E 

has a ceiling height of approximately 

26′-9′′ and an approximate floor area of 

12,140 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.9.4 OMAs Credited for a Fire in This 

Zone 

3.9.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.9.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or localized water 

deluge systems noted above, or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.10 RB–FZ–1F3 Reactor Bldg. 

Northwest Corner Elev. -19′-6′′ 

3.10.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

cable insulation (approximately 58% of 

loading), ladders (approximately 16% of 

loading) and lubricating oil in pumps 

(approximately 16% of loading). 

3.10.2 Detection, Control, and 

Extinguishment 

The licensee stated that RB–FZ–1F3 

has smoke detectors which alarm locally 

and in the control room installed over 

hazards rather than mounted at the 

ceiling. Fire extinguishers are also 

provided for manual fire fighting 

backup. Hose lines are available from 

outside hydrants and hose houses. 

3.10.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that RB–FZ–1F3 

has a ceiling height of approximately 

41′-6′′ and an approximate floor area of 

560 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.10.4 OMAs Credited for a Fire in 

This Zone 

3.10.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

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the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.10.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection system or personnel 

and damage the safe shutdown 

equipment. The low likelihood of 

damage to safe shutdown equipment 

due to a fire in this area, combined with 

the ability of OMA #17 to manipulate 

the plant in the event of a fire that 

damages safe shutdown equipment, 

provides adequate assurance that safe 

shutdown capability is maintained. 

3.11 RB–FZ–1F5 Reactor Bldg. Torus 

Room Elev. -19′-6′′ 

3.11.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

cable insulation (approximately 19% of 

loading) and gratings (approximately 

76% of loading). The grating, which is 

the largest plastic material in this area, 

has a low flame spread rating (less than 

25). 

3.11.2 Detection, Control, and 

Extinguishment 

The licensee stated that RB–FZ–1F5 

does not have detection or suppression 

systems. However, due to the limited 

combustible loading and the nature of 

the combustibles, a fire in this zone is 

not expected to be of significant size or 

duration. 

3.11.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that RB–FZ–1F5 is 

a voluminous area with an approximate 

floor area of 11,450 square feet and a 

ceiling height of approximately 41′-6′′ 

therefore, it is unlikely that smoke and 

heat from a fire in the area would 

accumulate at the location of the 

instrument air line and cause a loss of 

instrument air. 

3.11.4 OMAs Credited for a Fire in 

This Zone 

3.11.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.11.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and the large volume of the area, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.12 RB–FZ–1G Reactor Bldg. 

Shutdown Cooling Room Elev. 38′-0′′ & 

51′-3′′ 

3.12.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

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combustible materials and sources of 

ignition. The licensee also stated that 

the main combustibles in this area are 

cable insulation (approximately 12% of 

loading), plastic (approximately 57% of 

loading) and Class A combustibles 

(approximately 14% of loading). The 

grating, which is the majority of the 

plastic material in this area, has a low 

flame spread rating (less than 25). 

3.12.2 Detection, Control, and 

Extinguishment 

The licensee stated that RB–FZ–1G is 

provided with a smoke detection system 

that alarms locally and in the control 

room to provide prompt notification of 

a potential fire event. 

3.12.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that RB–FZ–1G 

has a ceiling height of approximately 

21′, measured from the 51′-3′′ elevation, 

and an approximate floor area of 1,609 

square feet so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

3.12.4 OMAs Credited for a Fire in 

This Area 

3.12.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.12.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection system or personnel 

and damage the safe shutdown 

equipment. The low likelihood of 

damage to safe shutdown equipment 

due to a fire in this area, combined with 

the ability of OMA #17 to manipulate 

the plant in the event of a fire that 

damages safe shutdown equipment, 

provides adequate assurance that safe 

shutdown capability is maintained. 

3.13 TB–FA–3A Turbine Bldg. 4160V 

Emergency Switchgear Vault 1C Elev. 

23′-6′′ 

3.13.1 Fire Prevention 

The licensee stated that the fire 

loading in this area is low and that there 

is an administrative controls program in 

place to limit additional combustible 

materials and sources of ignition. The 

licensee also stated that there are 

minimal amounts of cable insulation 

(approximately 5% of loading) 

miscellaneous plastic (approximately 

73% of loading) and class A 

combustibles such as paper for 

procedures (approximately 20% of 

loading) in this area. 

3.13.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FA–3A is 

provided with an area-wide smoke 

detection system and a total-flooding, 

manually actuated CO2 system. 

3.13.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FA–3A 

has a ceiling height of approximately 21′ 

and an approximate floor area of 336 

square feet so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

3.13.4 OMAs Credited for a Fire in 

This Area 

3.13.4.1 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

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RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.13.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or CO2 systems, or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMA #17 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.14 TB–FA–26 Turbine Bldg. 125V DC 

Battery Room C Elev. 23′-6′′ 

3.14.1 Fire Prevention 

The licensee stated that the fire 

loading in this area is moderate and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

plastic, which is contributed by the 

battery cases (approximately 92% of 

loading) and cable insulation 

(approximately 6% of loading). 

3.14.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FA–26 

has an area-wide automatic pre-action 

sprinkler system and an area-wide 

smoke detection system installed. 

3.14.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that there are no 

specific cables in this fire area 

associated with the OMAs identified for 

Fire Area TB–FA–26 and that the only 

fire safe shutdown component and cable 

located in this fire area is associated 

with the ‘‘C’’ battery. 

3.14.4 OMAs Credited for a Fire in 

This Area 

The licensee stated that this fire area 

is wholly contained within Fire Zone 

TB–FZ–11C (A and B 4160V Room) and 

that all cables to TB–FA–26 must 

traverse TB–FZ–11C. Therefore, TB– 

FA–26 and TB–FZ–11C were analyzed 

together for safe shutdown purposes and 

the OMAs are duplicated for these two 

plant areas. Refer to Section 3.16 below 

for the discussion of OMAs #1, #2, #3, 

#7, #8, and #18. 

3.14.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and lack of multiple safe shutdown 

trains in this area, it is unlikely that a 

fire would occur and go undetected or 

unsuppressed by the smoke detection or 

sprinkler systems, or personnel, and 

damage the safe shutdown equipment. 

The low likelihood of damage to safe 

shutdown equipment due to a fire in 

this area, combined with the ability of 

OMAs #1, #2, #3, #7, #8, and #18 to 

manipulate the plant in the event of a 

fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.15 TB–FZ–11B Turbine Bldg. Lube 

Oil Storage, Purification and Pumping 

Area Elev. 0′-0′′, 27′-0′′, and 36′-0′′ 

3.15.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is high and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

lubricating oil (approximately 99% of 

loading) and cable insulation 

(approximately 0.3% of loading). 

3.15.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FZ–11B 

has automatic suppression systems 

installed over principal combustibles 

and a rate of rise/fixed temperature fire 

detection system installed at the lube oil 

tank. A closed head automatic sprinkler 

system protects cable trays and open 

head water spray deluge system protects 

oil handling equipment and the oil 

storage tank. Thermal detectors are 

located in close proximity to the lube oil 

tank so that a lube oil fire would be 

quickly detected, which in turn would 

activate the deluge system for 

extinguishment. Additionally, the 

licensee stated that there are fire 

extinguishers provided throughout the 

zone and that aqueous film-forming 

foam (AFFF) is staged in the Fire 

Brigade van for use if necessary. 

3.15.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that the ceiling 

heights in the area are approximately 9′- 

0′′ in the basement hallway, 

approximately 19′-0′′ in the basement 

stairs, approximately 26′-0′′ on the first 

floor of the area, and approximately 42′- 

0′′ on the second floor of the area. 

Additionally, the licensee stated that the 

floor area, measured at the 0′-0′′ 

elevation is approximately 3175 square 

feet. 

3.15.4 OMAs Credited for a Fire in 

This Zone 

3.15.4.1 OMA #3—Manually Control 

480V USS 1B2 Breakers for CRD Pump 

at Remote Shutdown Panel 

In order for OMA #3 to be necessary, 

the credited and redundant cables 

would have to be damaged due to a fire. 

The licensee stated that these cables are 

located in the same tray with additional 

cables and are generally located 

approximately 14 feet above the floor. 

The licensee also stated that the cables 

pass over the top of potential ignition 

sources MCC 1A12 and MCC 1B12 and 

that the cables are located 

approximately 6 feet above these 

ignition sources. Additionally, the lube 

oil tanks are located below the cables, 

although not directly below, with a 

distance of approximately 26 feet 

separating the cables and the tanks. The 

cables are also located approximately 20 

feet from ignition sources MCC 1A12A 

and 1B12A. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #3 is available 

to manually control the 480V USS 1B2 

Breakers for CRD Pump NC08B and 

1B2M from the Remote Shutdown Panel 

due to control circuit damage. The 

licensee also stated that they have 

assumed a 30-minute diagnosis period 

and that the required time to perform 

the action is 8 minutes while the time 

available is 180 minutes, which 

provides a 142-minute margin. 

3.15.4.2 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

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many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.15.5 Conclusion 

Although the fire loading is high, the 

limited ignition sources, large volume of 

the space, and the detection and 

suppression system make it unlikely 

that a fire would occur and go 

undetected or unsuppressed and 

damage the safe shutdown equipment. 

Additionally, the availability of fire 

extinguishers and AFFF, which is 

effective against oil based fires, provides 

an augmented ability to suppress a fire 

prior to damaging safe shutdown 

equipment. The low likelihood of 

damage to safe shutdown equipment 

due to a fire in this zone, combined with 

the ability of OMAs #3 and #18 to 

manipulate the plant in the event of a 

fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.16 TB–FZ–11C Turbine Bldg. 4160V 

SWGR Room 1A and 1B Elev. 23′-6′′ 

3.16.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the main combustible loading is 

attributed to cable insulation 

(approximately 73% of loading) and 

plastic (approximately 17% of loading). 

3.16.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FZ–11C 

has an area-wide smoke detection 

system and an area-wide automatic 

fixed pre-action sprinkler system 

(except in the small caged area located 

to the east of Fire Area TB–FA–3A) 

installed. 

3.16.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FZ–11C 

has a ceiling height of approximately 

21′-8′′ and an approximate floor area of 

2666 square feet so it is unlikely that 

smoke and heat would accumulate at 

the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

3.16.4 OMAs Credited for a Fire in 

This Area 

3.16.4.1 OMA #1—Trip Field Breakers 

for Recirculation Pumps MG Set 

In order for OMA #1 to be necessary, 

damage to the 1A and 1B 4160V 

Switchgear Cabinets and the ‘‘C’’ Battery 

distribution panel, or the associated 

control wiring, would have to occur due 

to a fire and prevent tripping of the 

4160V motor-generator set breakers. The 

licensee stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

17 feet above the floor. The licensee also 

stated that the tray passes over the top 

of potential ignition source ‘‘B’’ 4160V 

switchgear and that the cables are 

located approximately 9 feet above this 

ignition source and 3 feet above the isophase bus duct at their closest point. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant equipment, OMA #1 is 

available to trip the field breakers for 

the recirculation pumps motor-generator 

set so that the Fuel Zone Level 

Indicators can be used. The licensee 

also stated that they have assumed a 10- 

minute diagnosis period and that the 

required time to perform the action is 8 

minutes while the time available is 30 

minutes, which provides a 12-minute 

margin. 

3.16.4.2 OMA #2—Align Fire Water to 

Isolation Condenser 

In order for OMA #2 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. The 

licensee also stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

17 feet above the floor and that the tray 

passes over the top of potential ignition 

source ‘‘B’’ 4160V switchgear and that 

the cables are located approximately 9 

feet above this ignition source and 3 feet 

above the iso-phase bus duct at their 

closest point. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #2 is available 

to provide fire water to the isolation 

condenser shell by operating valves V– 

9–2099, V–11–49, V–11–63, and V–11– 

41 due to loss of power. The licensee 

also stated that they have assumed a 10- 

minute diagnosis period and that the 

required time to perform the action is 13 

minutes while the time available is 45 

minutes, which provides a 22-minute 

margin. 

3.16.4.3 OMA #3—Manually Control 

480V USS 1B2 Breakers for CRD Pump 

at Remote Shutdown Panel 

In order for OMA #3 to be necessary, 

the credited and redundant cables 

would have to be damaged due to a fire. 

The licensee stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

17 feet above the floor. The licensee also 

stated that the tray passes over the top 

of potential ignition source ‘‘B’’ 4160V 

switchgear and that the cables are 

located approximately 9 feet above this 

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ignition source and 3 feet above the isophase bus duct at their closest point. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #3 is available 

to manually control the 480V USS 1B2 

Breakers for CRD Pump NC08B and 

1B2M from the Remote Shutdown Panel 

due to control circuit damage. The 

licensee also stated that they have 

assumed a 30-minute diagnosis period 

and that the required time to perform 

the action is 8 minutes while the time 

available is 180 minutes, which 

provides a 142-minute margin. 

3.16.4.4 OMA #7—Provide Makeup to 

Isolation Condenser via V–11–36 

In order for OMA #7 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. The 

licensee also stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

17 feet above the floor and that the tray 

passes over the top of potential ignition 

source ‘‘B’’ 4160V switchgear and that 

the cables are located approximately 9 

feet above this ignition source and 3 feet 

above the iso-phase bus duct at their 

closest point. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #7 is available 

to manually open V–11–36 to provide 

makeup to Isolation Condenser due to 

loss of power. The licensee also stated 

that they have assumed a 10-minute 

diagnosis period and that the required 

time to perform the action is 16 minutes 

while the time available is 45 minutes, 

which provides a 19-minute margin. 

3.16.4.5 OMA #8—Locally Check 

Isolation Condenser Shell Level 

In order for OMA #8 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. The 

licensee also stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

17 feet above the floor and that the tray 

passes over the top of potential ignition 

source ‘‘B’’ 4160V switchgear and that 

the cables are located approximately 9 

feet above this ignition source and 3 feet 

above the iso-phase bus duct at their 

closest point. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #8 is available 

to check the isolation condenser shell 

level locally due to loss of power. The 

licensee also stated that they have 

assumed a 10-minute diagnosis period 

and that the required time to perform 

the action is 16 minutes while the time 

available is 45 minutes, which provides 

a 19-minute margin. 

3.16.4.6 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the main 

MSIVs will close, as well as multiple 

air-operated valves changing state. 

Additionally, RPV level indication will 

not be compromised by a fire in any 

zone or area. All of these indications 

would help the operator diagnose the 

loss of instrument air and initiate 

mitigating procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.16.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

smoke detection or sprinkler systems 

noted above, or personnel, and damage 

the safe shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMAs #1, 

#2, #3, #7, #8, and #18 to manipulate 

the plant in the event of a fire that 

damages safe shutdown equipment, 

provide adequate assurance that safe 

shutdown capability is maintained. 

3.17 TB–FZ–11D Turbine Bldg. 

Basement Floor South End Elev. 3′-6′′ 

3.17.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

cable insulation (approximately 29% of 

loading), Dow Corning 561 Silicon 

transformer liquid (approximately 15% 

of loading) and lubricating oil 

(approximately 40% of loading). 

3.17.2 Detection, Control, and 

Extinguishment 

The licensee stated that an automatic 

wet-pipe sprinkler system and an 

automatic water spray system located at 

the hydrogen seal oil unit are installed 

in the area. 

3.17.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FZ–11D 

has a ceiling height of approximately 19′ 

and an approximate floor area of 9668 

square feet so it is unlikely that smoke 

and heat would accumulate at the 

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height of the safe shutdown equipment 

and cause a failure due to fire damage. 

3.17.4 OMAs Credited for a Fire in 

This Zone 

3.17.4.1 OMA #1—Trip Field Breakers 

for Recirculation Pumps MG Set 

In order for OMA #1 to be necessary, 

damage to the 1A and 1B 4160V 

Switchgear Cabinets and the ‘‘C’’ Battery 

distribution panel, or the associated 

control wiring, would have to occur due 

to a fire and prevent tripping of the 

4160V MG set breakers. The licensee 

stated that these cables are located in 

the same tray with additional cables and 

are generally located at least 15 feet 

above the floor. The primary 

combustible fuel load in the area is the 

cables themselves and storage of 

transient combustibles is limited due to 

a sump and abandoned acid/caustic 

tanks located in the area. 

The licensee also stated that the 

primary ignition sources in the area near 

the cable trays are the Turbine Building 

Closed Cooling Water Pumps and USS 

1A1 and its associated transformer 

(4160V to 480V transformer). However, 

the Turbine Building Closed Cooling 

Water Pumps contain less than 5 gallons 

of oil and are enclosed in metal casings 

and the cable tray containing the cables 

is approximately 13 feet from the top of 

the pumps/motors. The top of USS 1A1 

and its associated transformer are 

located approximately 30 feet 

diagonally from the credited cables and 

approximately 15 feet diagonally from 

the redundant cables. Additionally, 

there is a concrete ceiling beam, with a 

water curtain sprinkler system attached, 

which would provide some shielding 

for the cables from potential products of 

combustion generated by this ignition 

source. Sprinkler heads are also located 

in a ceiling pocket between the concrete 

ceiling beam and the USS 1A1 and 

transformer. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant equipment, OMA #1 is 

available to trip the field breakers for 

the recirculation pumps MG Set so that 

the fuel zone level indicators can be 

used. The licensee also stated that they 

have assumed a 10-minute diagnosis 

period and that the required time to 

perform the action is 8 minutes while 

the time available is 30 minutes, which 

provides a 12-minute margin. 

3.17.4.2 OMA #2—Align Fire Water to 

Isolation Condenser 

In order for OMA #2 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. In 

addition, the licensee stated that these 

cables are located in the same tray with 

additional cables and are generally 

located at least 15 feet above the floor. 

The primary combustible fuel load in 

the area is the cables themselves and 

storage of transient combustibles is 

limited due to a sump and abandoned 

acid/caustic tanks located in the area. 

The licensee also stated that the 

primary ignition sources in the area near 

the cable trays are the Turbine Building 

Closed Cooling Water Pumps and USS 

1A1 and its associated transformer 

(4160V to 480V transformer). However, 

the Turbine Building Closed Cooling 

Water Pumps contain less than 5 gallons 

of oil and are enclosed in metal casings 

and the cable tray containing the cables 

is approximately 13 feet from the top of 

the pumps/motors. The top of USS 1A1 

and its associated transformer are 

located approximately 30 feet 

diagonally from the credited cables and 

approximately 15 feet diagonally from 

the redundant cables. Additionally, 

there is a concrete ceiling beam, with a 

water curtain sprinkler system attached, 

which would provide some shielding 

for the cables from potential products of 

combustion generated by this ignition 

source. Sprinkler heads are also located 

in a ceiling pocket between the concrete 

ceiling beam and the USS 1A1 and 

transformer. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #2 is available 

to provide fire water to the isolation 

condenser shell by operating valves V– 

9–2099, V–11–49, V–11–63, and V–11– 

41 due to loss of power. The licensee 

also stated that they have assumed a 

10-minute diagnosis period and that the 

required time to perform the action is 13 

minutes while the time available is 45 

minutes, which provides a 22-minute 

margin. 

3.17.4.3 OMA #3—Manually Control 

480V USS 1B2 Breakers for CRD Pump 

at Remote Shutdown Panel 

In order for OMA #3 to be necessary, 

the credited and redundant cables 

would have to be damaged due to a fire. 

The licensee stated that these cables are 

located in the same tray with additional 

cables and are generally located at least 

15 feet above the floor. The primary 

combustible fuel load in the area is the 

cables themselves and storage of 

transient combustibles is limited due to 

a sump and abandoned acid/caustic 

tanks located in the area. 

The licensee also stated that the 

primary ignition sources in the area near 

the cable trays are the Turbine Building 

Closed Cooling Water Pumps and 

USS 1A1 and its associated transformer 

(4160V to 480V transformer). However, 

the Turbine Building Closed Cooling 

Water Pumps contain less than 5 gallons 

of oil and are enclosed in metal casings 

and the cable tray containing the cables 

is approximately 13 feet from the top of 

the pumps/motors. The top of USS 1A1 

and its associated transformer are 

located approximately 30 feet 

diagonally from the credited cables and 

approximately 15 feet diagonally from 

the redundant cables. Additionally, 

there is a concrete ceiling beam, with a 

water curtain sprinkler system attached, 

which would provide some shielding 

for the cables from potential products of 

combustion generated by this ignition 

source. Sprinkler heads are also located 

in a ceiling pocket between the concrete 

ceiling beam and the USS 1A1 and 

transformer. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #3 is available 

to manually control the 480V USS 1B2 

Breakers for CRD Pump NC08B and 

1B2M from the Remote Shutdown Panel 

due to control circuit damage. The 

licensee also stated that they have 

assumed a 30-minute diagnosis period 

and that the required time to perform 

the action is 8 minutes while the time 

available is 180 minutes, which 

provides a 142-minute margin. 

3.17.4.4 OMA #7—Provide Makeup to 

Isolation Condenser via V–11–36 

In order for OMA #7 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. In 

addition, the licensee stated that these 

cables are located in the same tray with 

additional cables and are generally 

located at least 15 feet above the floor. 

The primary combustible fuel load in 

the area is the cables themselves and 

storage of transient combustibles is 

limited due to a sump and abandoned 

acid/caustic tanks located in the area. 

The licensee also stated that the 

primary ignition sources in the area near 

the cable trays are the Turbine Building 

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Closed Cooling Water Pumps and 

USS 1A1 and its associated transformer 

(4160V to 480V transformer). However, 

the Turbine Building Closed Cooling 

Water Pumps contain less than 5 gallons 

of oil and are enclosed in metal casings 

and the cable tray containing the cables 

is approximately 13 feet from the top of 

the pumps/motors. The top of USS 1A1 

and its associated transformer are 

located approximately 30 feet 

diagonally from the credited cables and 

approximately 15 feet diagonally from 

the redundant cables. Additionally, 

there is a concrete ceiling beam, with a 

water curtain sprinkler system attached, 

which would provide some shielding 

for the cables from potential products of 

combustion generated by this ignition 

source. Sprinkler heads are also located 

in a ceiling pocket between the concrete 

ceiling beam and the USS 1A1 and 

transformer. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #7 is available 

to manually open V–11–36 to provide 

makeup to Isolation Condenser due to 

loss of power. The licensee also stated 

that they have assumed a 10-minute 

diagnosis period and that the required 

time to perform the action is 16 minutes 

while the time available is 45 minutes, 

which provides a 19-minute margin. 

3.17.4.5 OMA #8—Locally Check 

Isolation Condenser Shell Level 

In order for OMA #8 to be necessary, 

loss of the ‘‘B’’ train of power would 

have to occur due to a fire causing a loss 

of both condensate transfer pumps. The 

licensee stated that this OMA is 

dependent on the LSP–1D OMA, which 

was included in the licensee’s Phase 1 

request, and would not be required 

unless the OMA at the LSP–1D is 

required and access is not immediately 

available. As such, this OMA is 

considered a contingency action. In 

addition, the licensee stated that these 

cables are located in the same tray with 

additional cables and are generally 

located at least 15 feet above the floor. 

The primary combustible fuel load in 

the area is the cables themselves and 

storage of transient combustibles is 

limited due to a sump and abandoned 

acid/caustic tanks located in the area. 

The licensee also stated that the 

primary ignition sources in the area near 

the cable trays are the Turbine Building 

Closed Cooling Water Pumps and USS 

1A1 and its associated transformer 

(4160V to 480V transformer). However, 

the Turbine Building Closed Cooling 

Water Pumps contain less than 5 gallons 

of oil and are enclosed in metal casings 

and the cable tray containing the cables 

is approximately 13 feet from the top of 

the pumps/motors. The top of USS 1A1 

and its associated transformer are 

located approximately 30 feet 

diagonally from the credited cables and 

approximately 15 feet diagonally from 

the redundant cables. Additionally, 

there is a concrete ceiling beam, with a 

water curtain sprinkler system attached, 

which would provide some shielding 

for the cables from potential products of 

combustion generated by this ignition 

source. Sprinkler heads are also located 

in a ceiling pocket between the concrete 

ceiling beam and the USS 1A1 and 

transformer. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #8 is available 

to check the isolation condenser shell 

level locally due to loss of power. The 

licensee also stated that they have 

assumed a 10-minute diagnosis period 

and that the required time to perform 

the action is 16 minutes while the time 

available is 45 minutes, which provides 

a 19-minute margin. 

3.17.4.6 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.17.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources 

and the volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

suppression systems noted above, or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMAs #1, 

#2, #3, #7, #8, and #18 to manipulate 

the plant in the event of a fire that 

damages safe shutdown equipment, 

provides adequate assurance that safe 

shutdown capability is maintained. 

3.18 TB–FZ–11E Turbine Bldg. 

Condenser Bay Area Elev. 0′-′′0 

3.18.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles in this area are 

cable insulation (approximately 40% of 

loading) and plastic (approximately 

59% of loading). The grating, which is 

the largest plastic material in this area, 

is dispersed throughout this fire zone 

(not concentrated) and has a low flame 

spread (less than 25). The licensee also 

stated that this Fire Zone is 

procedurally controlled as a transient 

combustible free area while the plant is 

operating and that this area is a high 

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radiation area during plant operation 

and is not normally accessed. 

3.18.2 Detection, Control, and 

Extinguishment 

The licensee stated that a closed head 

automatic sprinkler and spray systems 

protect the south end basement area and 

the hydrogen seal oil unit. An 

exemption was granted from the 

requirements of Appendix R Section 

III.G.2 in safety evaluations dated March 

24, 1986, and June 25, 1990, for not 

having fixed fire detection in this area. 

The primary basis for this exemption 

was the presence of the automatic wet 

pipe sprinkler system and low fire 

loading. The Condenser Bay is 

procedurally controlled as a transient 

combustible free area in while the plant 

is operating. If a fire did occur, the flow 

alarm would notify the control room of 

any sprinkler system activation. 

Extinguishment of a fire can be 

accomplished by the automatic fixed 

suppression system and the plant fire 

brigade. A closed head automatic 

sprinkler system was recently expanded 

to provide fire suppression over the 

cables in cable trays in the northeast 

side of the condenser bay. 

3.18.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FZ–11E 

has a ceiling height of at least 40′ and 

an approximate floor area of 26,427 

square feet so it is unlikely that smoke 

and heat would accumulate at the 

height of the safe shutdown equipment 

and cause a failure due to fire damage. 

3.18.4 OMAs Credited for a Fire in 

This Zone 

3.18.4.1 OMA #3—Manually Control 

480V USS 1B2 Breakers for CRD Pump 

at Remote Shutdown Panel 

In order for OMA #3 to be necessary, 

the credited and redundant cables 

would have to be damaged due to a fire. 

The licensee stated that these cables are 

located in the same tray with additional 

cables and are generally located 

approximately 40 feet above the floor. 

With the exception of the cables 

themselves, there are no other ignition 

sources or combustibles located near the 

cables. 

In the unlikely event that a fire does 

occur and damages the credited and 

redundant cables, OMA #3 is available 

to manually control the 480V USS 1B2 

Breakers for CRD Pump NC08B and 

1B2M from the Remote Shutdown Panel 

due to control circuit damage. The 

licensee also stated that they have 

assumed a 30-minute diagnosis period 

and that the required time to perform 

the action is 8 minutes while the time 

available is 180 minutes, which 

provides a 142-minute margin. 

3.18.4.2 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.18.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

suppression system noted above or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMAs #3 

and #18 to manipulate the plant in the 

event of a fire that damages safe 

shutdown equipment, provides 

adequate assurance that safe shutdown 

capability is maintained. 

3.19 TB–FZ–11F Turbine Bldg. 

Feedwater Pump Room Elev. 0′-0′′ & 3′- 

6′′ 

3.19.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustible load consists of 

cable insulation (approximately 15% of 

loading), lubricating oil (approximately 

39% of loading), rubber (approximately 

21% of loading) and plastics 

(approximately 17% of loading). The 

licensee states that the majority of the 

combustible loading attributed to rubber 

and plastic was due to the storage of 

hoses that are now no longer in the area. 

3.19.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FZ–11F 

has an area-wide thermal fire detection 

system. Extinguishment of the fire will 

be accomplished by the plant fire 

brigade. 

3.19.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FZ–11F 

has a ceiling height of approximately 16′ 

in approximately 70% of the area and 

approximately 19′-6′′ in the remainder 

of the area. With an approximate floor 

area of 5650 square feet, it is unlikely 

that smoke and heat would accumulate 

at the height of the safe shutdown 

equipment and cause a failure due to 

fire damage. 

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3.19.4 OMAs Credited for a Fire in 

This Zone 

3.19.4.1 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.19.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

thermal detection system noted above or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #18 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.20 TB–FZ–11H Turbine Bldg. 

Demineralizer Tank and Steam Jet Air 

Ejector Area Elev. 3′-6′′ & 23′-6′′ 

3.20.1 Fire Prevention 

The licensee stated that the fire 

loading in this zone is low and that 

there is an administrative controls 

program in place to limit additional 

combustible materials and sources of 

ignition. The licensee also stated that 

the major combustibles are cable 

insulation (approximately 23% of 

loading), ladders and other 

miscellaneous plastics (approximately 

55% of loading) and miscellaneous 

ordinary combustibles. 

3.20.2 Detection, Control, and 

Extinguishment 

The licensee stated that TB–FZ–11H 

has a partial area thermal fire detector 

system. The system alarms locally and 

in the control room. Manual 

extinguishment of fire will be 

accomplished by the plant fire brigade. 

3.20.3 Preservation of Safe Shutdown 

Capability 

The licensee stated that TB–FZ–11H 

has a ceiling height of approximately 7′- 

0′′, measured at the 3′-6′′ elevation, and 

approximately 19′-0′′, measured at the 

23′-6′′ elevation with an approximate 

floor area of 3,944 square feet and 4,366 

square feet, respectively, so it is 

unlikely that smoke and heat would 

accumulate at the height of the safe 

shutdown equipment and cause a 

failure due to fire damage. 

3.20.4 OMAs Credited for a Fire in 

This Area 

3.20.4.1 OMA #18—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

36 Accumulator 

In order for OMA #18 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–36 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #18 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–36 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #18 is 

available to provide makeup control air 

to the accumulator for V–11–36 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #18 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

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minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.20.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

thermal detection system noted above or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this zone, 

combined with the ability of OMA #18 

to manipulate the plant in the event of 

a fire that damages safe shutdown 

equipment, provides adequate assurance 

that safe shutdown capability is 

maintained. 

3.21 Yard 

3.21.1 Fire Prevention 

The licensee stated that no specific 

quantification of fire loading was 

considered necessary for the Yard area 

since it is an outdoor area with no 

ceiling or physical boundaries to 

contain heat and smoke from a fire 

event. 

3.21.2 Detection, Control, and 

Extinguishment 

The licensee stated that there is no 

fire detection or fixed fire suppression 

systems installed in this area but that 

manual suppression is provided by a 

hose station from the office building and 

by fire hydrants located throughout the 

Yard area. 

3.21.3 Preservation of Safe Shutdown 

Capability 

Since the Yard area is an outdoor 

space with no walls or ceiling, smoke 

and heat would not accumulate within 

the fire area to cause damage to 

components remote to the initiating fire 

or obstruct operator actions. 

3.21.4 OMAs Credited for a Fire in 

This Area 

3.21.4.1 OMA #12—Establish CRD 

Flow to Reactor 

In order for OMA #12 to be necessary, 

a loss of instrument air to the CRD flow 

control valve would have to occur due 

to fire damage. The licensee stated that 

the normal CRD flow control valve is a 

single component without a redundant 

counterpart. Because of this, a manual 

bypass is provided to maintain flow 

around the CRD flow control valves that 

fail closed upon loss of instrument air 

or control cable damage. 

In the unlikely event that a fire does 

occur and causes the normal flow 

control valve to be unavailable due to a 

loss of instrument air or cable damage, 

OMA #12 is available to manually open 

V–15–237, throttle V–15–30 while 

monitoring flow at FI–225–2, and close 

V–15–52 to establish CRD flow to the 

reactor. Furthermore, OMA #12 would 

only be necessary if the Isolation 

Condenser/CRD systems are utilized for 

hot shutdown. If OMA #12 becomes 

necessary, the licensee stated that they 

have assumed a 30-minute diagnosis 

period and that the required time to 

perform the action is 15 minutes, while 

the time available is 204 minutes, which 

provides a 159-minute margin. 

3.21.4.2 OMA #17—Provide Makeup 

Air to Isolation Condenser Valve V–11– 

34 Accumulator 

In order for OMA #17 to be necessary, 

a loss of instrument air to the isolation 

condenser valve V–11–34 would have to 

occur due to fire damage. The licensee 

stated that they conservatively assume 

that instrument air is lost for all 

Appendix R fires based on the fact that 

instrument air lines run throughout 

many areas of the plant. The licensee’s 

analysis assumes that the air line could 

potentially fail in approximately 45 

minutes when exposed to the postulated 

fire. 

The licensee also stated that OMA #17 

connects a high pressure air cylinder to 

the accumulator of Condensate Transfer 

System valve V–11–34 and that these 

air-operated valves are used to control 

makeup to the isolation condensers. 

Each valve is provided with an air 

accumulator that provides a minimum 

of six full cycles. As a result, this OMA 

is only necessary to ensure long-term 

operation of these valves and makeup to 

the isolation condensers. Further, this 

OMA would only be necessary if the 

plant had to remain in hot shutdown for 

an extended time. This scenario is 

unlikely for this particular area since 

the plant would likely reach cold 

shutdown before the action is required. 

In addition, the licensee stated that 

they maintain a fire support procedure 

(ABN–35, ‘‘Loss of Instrument Air’’) that 

provides guidance to perform this OMA 

if instrument air is lost and indicates 

that there are four annunciator alarm 

windows that monitor instrument air 

pressure, plus a pressure gauge on a 

panel in the control room for instrument 

air pressure. If all of these instruments 

are not available, then ABN–35 further 

indicates that the control rods will start 

to drift into the core and the MSIVs will 

close, as well as multiple air-operated 

valves changing state. Additionally, 

RPV level indication will not be 

compromised by a fire in any zone or 

area. All of these indications would 

help the operator diagnose the loss of 

instrument air and initiate mitigating 

procedures. 

In the unlikely event that a fire does 

occur and causes a loss of instrument air 

to the air-operated valves, OMA #17 is 

available to provide makeup control air 

to the accumulator for V–11–34 for the 

isolation condenser makeup line due to 

the loss of instrument air. If OMA #17 

becomes necessary, the licensee stated 

that they have assumed a 30-minute 

diagnosis period and that the required 

time to perform the action is 26 

minutes, while the time available is 300 

minutes, which provides a 244-minute 

margin. 

3.21.5 Conclusion 

Given the limited amount of 

combustible materials, ignition sources, 

and large volume of the space, it is 

unlikely that a fire would occur and go 

undetected or unsuppressed by the 

thermal detection system noted above or 

personnel, and damage the safe 

shutdown equipment. The low 

likelihood of damage to safe shutdown 

equipment due to a fire in this area, 

combined with the ability of OMAs #12 

and #17 to manipulate the plant in the 

event of a fire that damages safe 

shutdown equipment, provides 

adequate assurance that safe shutdown 

capability is maintained. 

3.22 Feasibility and Reliability of the 

Operator Manual Actions 

This analysis postulates that OMAs 

may be needed to assure safe shutdown 

capability in addition to the traditional 

fire protection features described above. 

NUREG–1852, ‘‘Demonstrating the 

Feasibility and Reliability of Operator 

Manual Actions in Response to Fire,’’ 

provides criteria and associated 

technical bases for evaluating the 

feasibility and reliability of post-fire 

OMAs in nuclear power plants. The 

following provides the Oyster Creek 

analysis of these criteria for justifying 

the OMAs specified in this exemption. 

3.22.1 Bases for Establishing 

Feasibility and Reliability 

Using NUREG–1852, the NRC staff 

has evaluated the feasibility and 

reliability review provided by the 

licensee in the April 2, 2010, Response 

to Request for Additional Information. 

For an OMA to be considered feasible, 

the required actions must be 

proceduralized, any equipment that is 

needed to implement the OMA is 

available, the environments in which 

the OMA is to be performed must 

permit the action, and the time taken to 

diagnose the need for the OMA and 

implement it (time required) must be 

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less than the time in which the OMA 

must be completed (time available). 

3.22.2 Feasibility 

The feasibility review provided by the 

licensee documents that procedures are 

in place, in the form of fire response 

procedures, to ensure that clear and 

accessible instructions on how to 

perform the manual actions are 

available to the operators. All of the 

requested OMAs are directed by plant 

procedures, and the operators are 

trained in the use of the procedures. 

Specifically, the licensee stated that 

procedure ABN–29, Plant Fires, is 

entered whenever a fire or indication of 

a fire occurs on the main fire alarm 

panel in the control room or at any local 

fire alarm panel. In addition to 

dispatching a radio-equipped operator 

to the alarming location, ABN–29 also 

directs that the fire brigade be 

dispatched whenever a fire suppression 

system has actuated (sprinkler, deluge, 

Halon, or CO2) or a fire is confirmed. In 

addition, the licensee stated that ABN– 

29 directs immediate entry into the Fire 

Support Procedure (FSP) for the affected 

fire area as soon as the existence of a fire 

is confirmed. The licensee states that 

the following indications or symptoms 

are considered examples of a confirmed 

fire: 

• Fire detection alarm and equipment 

malfunction indication or alarms within 

the same area; 

• Fire pump start and either sprinkler 

flow alarm or deluge flow alarm; 

• Gaseous suppression system 

actuation; 

• Report from the field of an actual 

smoke condition or actual fire 

condition; or 

• Fire detection alarm with follow up 

confirmation by field operator. 

Entering the FSP means that the 

operator will review the FSP, identify 

equipment that could be affected, 

identify equipment that will be 

available, monitor plant equipment from 

the control room and communicate with 

the fire brigade leader. Based on the 

symptoms received in the control room 

and the feedback from the fire brigade 

leader, the operator will decide using 

the procedure what mitigating actions 

are necessary. In the event that a plant 

shutdown has occurred before the FSP 

is entered, the operator will still enter 

the FSP based on the fire and initiate 

the OMAs as appropriate. OMAs that 

are considered ‘‘prompt’’ (i.e., those that 

must be done within 45 minutes or less) 

are identified in both ABN–29 and in 

the applicable FSPs as an item requiring 

immediate attention. The operators are 

trained to perform prompt actions first 

and prioritize them based upon existing 

plant conditions. The FSPs are based on 

the worst-case loss considerations by 

assuming all fire damage occurs 

instantaneously and thus all operator 

manual actions will be required. The 

use of the Emergency Operating 

Procedures in conjunction with the 

applicable FSPs will permit the use of 

any mitigating system available first, 

and if a desired system is not available, 

the FSP provides a contingency action 

to restore the system or provide another 

means to perform the function. Operator 

training, including simulator 

demonstrations and plant walk downs, 

has been performed to ensure 

consistency in operator and team 

response for each OMA. 

The licensee evaluated several 

potential environmental concerns, such 

as radiation levels, temperature/ 

humidity conditions and the ventilation 

configuration and fire effects that the 

operators may encounter during certain 

emergency scenarios. The licensee’s 

feasibility review concluded that the 

operators performing the manual actions 

would not be exposed to adverse or 

untenable conditions during any 

particular operator manual action 

procedure or during the time to perform 

the procedure. The licensee stated that 

OMAs required for achieving and 

maintaining hot shutdown conditions 

are not impacted by environmental 

conditions associated with fires in the 

fire area identified in the request. Each 

of the safe shutdown calculations that 

provide the technical basis for the FSPs 

contains a timeline for operator actions 

for the specific fire area. In addition, the 

licensee stated that the equipment 

needed to implement OMAs remains 

available and the fire areas remain 

accessible during or following the event. 

The licensee’s analysis demonstrates 

that, for the expected scenarios, the 

OMAs can be diagnosed and executed 

within the amount of time available to 

complete them. The licensee’s analysis 

also demonstrates that various factors, 

as discussed above, have been 

considered to address uncertainties in 

estimating the time available. Therefore, 

the OMAs included in this review are 

feasible because there is adequate time 

available for the operator to perform the 

required OMAs to achieve and maintain 

hot shutdown following a postulated 

fire event. Table 2 summarizes the 

‘‘required’’ verses ‘‘available’’ times for 

each OMA. The licensee has included 

any diagnosis time as part of the 

required time for performing a 

particular action. Where an action has 

multiple times or contingencies 

associated with the ‘‘available’’ 

completion time, the lesser time is used. 

This is approach is considered to 

represent a conservative approach to 

analyzing the timelines associated with 

each of the OMAs with regard to the 

feasibility and reliability of the actions 

included in this exemption. The 

licensee provided a discussion of the 

times and circumstances associated 

with each of the actions in their March 

3, 2009, and April 2, 2010, 

correspondence. 

TABLE 2 

OMA Fire area/zone of fire origin OMA 

location 

Required 

time 

(min) 

Available 

time 

(min) 

Margin 

(min) 

1 ............... TB–FA–26, TB–FZ–11C, and TB–FZ–11D ............................................... OB–FZ–8A 18 30 12 

2 ............... TB–FA–26, TB–FZ–11C, and TB–FZ–11D ............................................... RB–FZ–1E 23 45 22 

3 ............... TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, and TB–FZ–11E .... OB–FZ–6B 38 180 142 

7 ............... TB–FA–26, TB–FZ–11C, and TB–FZ–11D ............................................... RB–FZ–1B 26 45 19 

8 ............... TB–FA–26, TB–FZ–11C, and TB–FZ–11D ............................................... DG–FA–17 26 45 19 

9 ............... Yard ........................................................................................................... RB–FZ–1E 45 204 159 

17 ............. CW–FA–14, OB–FZ–6A, OB–FZ–8A, OB–FZ–8B, OB–FZ–8C, OB–FA– 

9, RB–FZ–1D, RB–FZ–1E, RB–FZ–1F3, RB–FZ–1F5, RB–FZ–1G, 

TB–FA–3A, and Yard.

RB–FZ–1B 56 300 244 

18 ............. OB–FZ–6B, TB–FA–26, TB–FZ–11B, TB–FZ–11C, TB–FZ–11D, TB– 

FZ–11E, TB–FZ–11F, and TB–FZ–11H.

RB–FZ–1B 56 300 244 

OB–FZ–10A ............................................................................................... .................... 38 60 22 

mstockstill on DSKH9S0YB1PROD with NOTICES

Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices 19509 

The NRC staff reviewed the required 

operator manual action completion time 

limits versus the time before the action 

becomes critical to safely shutting down 

the unit as presented in the feasibility 

analyses. The NRC staff recognizes that, 

in some cases the time required neared 

the time available for an OMA. The NRC 

staff, however, also recognizes that there 

are conservatisms built in to these time 

estimates such as adding in the entire 

time assumed to diagnose the need for 

an OMA where in reality, the actual 

time take would likely be less. 

The NRC staff notes that, in one case, 

an OMA must be completed within 30 

minutes (i.e., it is considered a prompt 

action). This action is identified as 

OMA #1 and requires an operator to trip 

the field breakers for the recirculation 

pumps MG set so that the Fuel Zone 

Level Indicators can be used. The action 

may be required as a result of fire in 

TB–FA–26, TB–FZ–11C, or TB–FZ–11D. 

The symptom for this action is the 

inability to trip the Recirculation Pumps 

from the control room and this is 

detected using the associated pump 

breaker indicating lights, alarms and 

flow indications. The Fire Support 

Procedures direct the operator to trip 

the pumps using the pump control 

switches or the Recirculation Pump Trip 

circuitry (two trip coils for pumps). If 

both of these methods fail on one or 

more pumps, the guidance is given to 

trip the pumps from the 4160V 

Switchgear 1A and 1B located outside 

the control room in Fire Area TB–FZ– 

11C. Only one operator would be 

required and it would take 

approximately 13 minutes for access to 

the area and to perform the action of 

tripping the breakers. Given the low 

complexity of this action, the NRC staff 

finds that there is a sufficient amount of 

time available to complete the proposed 

operator manual actions. 

3.23 Reliability 

The completion times noted in the 

table above provide reasonable 

assurance that the OMAs can reliably be 

performed under a wide range of 

conceivable conditions by different 

plant crews. This is because the time 

margins associated with each action and 

other installed fire protection features, 

account for sources of uncertainty such 

as variations in fire and plant 

conditions, factors unable to be 

recreated in demonstrations and humancentered factors. Therefore, the OMAs 

included in this review are reliable 

because there is adequate time available 

to account for uncertainties not only in 

estimates of the time available, but also 

in estimates of how long it takes to 

diagnose a fire and execute the OMAs. 

This is based, in part, on a plant 

demonstration of the actions under nonfire conditions. 

3.24 Summary of Defense-in-Depth 

and Operator Manual Actions 

In summary, the defense-in-depth 

concept for a fire in the fire areas 

discussed above provides a level of 

safety that limits the occurrence of fires 

and results in rapid detection, control 

and extinguishment of fires that do 

occur and the protection of structures, 

systems and components important to 

safety. It should be understood that the 

OMAs are a fall back in the unlikely 

event that the fire protection defense-indepth features are insufficient. In most 

cases, there is no credible fire scenario 

that would necessitate the performance 

of these OMAs. As discussed above, the 

licensee has provided preventative and 

protective measures in addition to 

feasible and reliable OMAs that together 

demonstrate the licensee’s ability to 

preserve or maintain safe shutdown 

capability in the event of a fire in the 

analyzed fire areas. 

3.25 Authorized by Law 

This exemption would allow Oyster 

Creek to rely on OMAs, in conjunction 

with the other installed fire protection 

features, to ensure that at least one 

means of achieving and maintaining hot 

shutdown remains available during and 

following a postulated fire event, as part 

of its fire protection program, in lieu of 

meeting the requirements specified in 

10 CFR Part 50, Appendix R, Section 

III.G.2 for a fire in the analyzed fire 

areas. As stated above, 10 CFR 50.12 

allows the NRC to grant exemptions 

from the requirements of 10 CFR Part 

50. The NRC staff has determined that 

granting of this exemption will not 

result in a violation of the Atomic 

Energy Act of 1954, as amended, or the 

Commission’s regulations. Therefore, 

the exemption is authorized by law. 

3.26 No Undue Risk to Public Health 

and Safety 

The underlying purpose of 10 CFR 

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

ensure that at least one means of 

achieving and maintaining hot 

shutdown remains available during and 

following a postulated fire event. Based 

on the above evaluation, the NRC staff 

finds that the plant features, as 

described in the March 3, 2009, 

submittal, as supplemented by letter 

dated April 2, 2010, should limit the 

occurrence and impacts of any fire that 

may occur. This, combined with the 

ability of the OMAs to place and 

maintain the plant in a safe condition in 

the event of a fire that does damage safe 

shutdown equipment, provides 

adequate protection of public health and 

safety. Therefore, there is no undue risk 

to public health and safety. 

3.27 Consistent With Common Defense 

and Security 

This exemption would allow Oyster 

Creek to credit the use of the specific 

OMAs, in conjunction with the other 

installed fire protection features, in 

response to a fire in the analyzed fire 

areas, discussed above, in lieu of 

meeting the requirements specified in 

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

the plant, has no relation to security 

issues nor does it diminish the level of 

safety from what was intended by the 

requirements of III.G.2. Therefore, the 

common defense and security is not 

diminished by this exemption. 

3.28 Special Circumstances 

One of the special circumstances 

described in 10 CFR 50.12(a)(2)(ii) is 

that the application of the regulation is 

not necessary to achieve the underlying 

purpose of the rule. The underlying 

purpose of 10 CFR Part 50, Appendix R, 

Section III.G is to ensure that at least 

one means of achieving and maintaining 

hot shutdown remains available during 

and following a postulated fire event. 

While the licensee does not comply 

with the explicit requirements of III.G.2, 

specifically, they do meet the 

underlying purpose of 10 CFR Part 50, 

Appendix R, and Section III.G as a 

whole. Therefore, special circumstances 

exist that warrant the issuance of this 

exemption as required by 10 CFR 

50.12(a)(2)(ii). 

4.0 Conclusion 

Accordingly, the Commission has 

determined that, pursuant to 10 CFR 

50.12(a), the exemption is authorized by 

law, will not present an undue risk to 

the public health and safety, is 

consistent with the common defense 

and security and that special 

circumstances are present to warrant 

issuance of the exemption. Therefore, 

the Commission hereby grants Exelon 

an exemption from the requirements of 

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

Part 50, to utilize the OMAs discussed 

above at Oyster Creek. 

Pursuant to 10 CFR 51.32, the 

Commission has determined that the 

granting of this exemption will not have 

a significant effect on the quality of the 

human environment (75 FR 33656). 

This exemption is effective upon 

issuance. 

Dated at Rockville, Maryland, this 30th day 

of March 2011. 

mstockstill on DSKH9S0YB1PROD with NOTICES

19510 Federal Register / Vol. 76, No. 67 / Thursday, April 7, 2011 / Notices 

For the Nuclear Regulatory Commission. 

Robert A. Nelson, 

Acting Director, Division of Operating Reactor 

Licensing, Office of Nuclear Reactor 

Regulation. 

[FR Doc. 2011–8318 Filed 4–6–11; 8:45 am] 

BILLING CODE 7590–01–P 

NUCLEAR REGULATORY 

COMMISSION 

[NRC–2011–0075] 

Notice of Availability (NOA) of the 

Models For Plant-Specific Adoption of 

Technical Specifications Task Force 

(TSTF) Traveler TSTF–422, Revision 2, 

‘‘Change In Technical Specifications 

End States (CE NPSD–1186),’’ For 

Combustion Engineering (CE) 

Pressurized Water Reactor (PWR) 

Plants Using the Consolidated Line 

Item Improvement Process (CLIIP) 

AGENCY: U.S. Nuclear Regulatory 

Commission (NRC). 

ACTION: Notice of Availability. 

SUMMARY: The NRC is announcing the 

availability of the model application 

(with model no significant hazards 

consideration (NSHC) determination) 

and model safety evaluation (SE) for 

plant-specific adoption of TSTF 

Traveler TSTF–422, Revision 2, ‘‘Change 

in Technical Specifications End States 

(CE NPSD–1186),’’ for CE plants using 

the CLIIP. TSTF–422, Revision 2, is 

available in the Agencywide Documents 

Access and Management System 

(ADAMS) under Accession Number 

ML093570241. TSTF–422, Revision 2, 

modifies the Required Action with the 

preferred end state with the addition of 

a Note to prohibit the use of the 

provisions of Limiting Condition for 

Operation 3.0.4.a to enter the end state 

Mode within the Applicability during 

startup. The Bases of each Required 

Action is revised to describe the Note. 

This model SE will facilitate expedited 

approval of plant-specific adoption of 

TSTF–422, Revision 2. Please note, this 

NOA supersedes in its entirety the NOA 

for TSTF–422, Revision 1, published in 

the Federal Register on July 5, 2005 (70 

FR 38729–38731, ADAMS Package 

Accession Number ML051650144). 

You can access publicly available 

documents related to this notice using 

the following methods: 

NRC’s Public Document Room (PDR): 

The public may examine and have 

copied, for a fee, publicly available 

documents at the NRC’s PDR, Public 

File Area O1 F21, One White Flint 

North, 11555 Rockville Pike, Rockville, 

Maryland. 

NRC’s Agencywide Documents Access 

and Management System (ADAMS): 

Publicly available documents created or 

received at the NRC are available 

electronically at the NRC’s Electronic 

Reading Room at http://www.nrc.gov/ 

reading-rm/adams.html. From this page, 

the public can gain entry into the 

ADAMS, which provides text and image 

files of NRC’s public documents. If you 

do not have access to the ADAMS, or if 

there are problems in accessing the 

documents located in the ADAMS, 

contact the NRC’s PDR reference staff at 

1–800–397–4209, 301–415–4737, or by 

e-mail to pdr.resource@nrc.gov. 

The model application (with model 

NSHC determination) and model SE for 

plant-specific adoption of TSTF–422, 

Revision 2, are available electronically 

under ADAMS Accession Number 

ML103270197. No comments were 

received to the Notice of Opportunity 

for Public Comment announced in the 

Federal Register on May 4, 2005 (70 FR 

23238). 

Federal Rulemaking Web site: 

Supporting materials related to this 

notice can be found at http:// 

www.regulations.gov by searching on 

Docket ID: NRC–2011–0075. 

FOR FURTHER INFORMATION CONTACT: 

Ravinder Grover, Technical 

Specifications Branch, Mail Stop: O–7 

C2A, Division of Inspection and 

Regional Support, Office of Nuclear 

Reactor Regulation, U.S. Nuclear 

Regulatory Commission, Washington, 

DC 20555–0001; telephone: 301–415– 

2166 or e-mail; 

Ravinder.Grover@nrc.gov or Ms. 

Michelle C. Honcharik, Senior Project 

Manager, Licensing Processes Branch, 

Mail Stop: O–12 D1, Division of Policy 

and Rulemaking, Office of Nuclear 

Reactor Regulation, U.S. Nuclear 

Regulatory Commission, Washington, 

DC 20555–0001; telephone: 301–415– 

1774 or e-mail at: 

Michelle.Honcharik@nrc.gov. 

SUPPLEMENTARY INFORMATION: TSTF– 

422, Revision 2, is applicable to all CE 

PWR plants. Licensees opting to apply 

for this TS change are responsible for 

reviewing the NRC staff’s model SE, 

referencing the applicable technical 

justifications, and providing any 

necessary plant-specific information. 

The NRC will process each amendment 

application responding to this NOA 

according to applicable NRC rules and 

procedures. 

The proposed models do not prevent 

licensees from requesting an alternate 

approach or proposing changes other 

than those proposed in TSTF–422, 

Revision 2. However, significant 

deviations from the approach 

recommended in this notice or the 

inclusion of additional changes to the 

license require additional NRC staff 

review. This may increase the time and 

resources needed for the review or 

result in NRC staff rejection of the 

license amendment request (LAR). 

Licensees desiring significant deviations 

or additional changes should instead 

submit an LAR that does not claim to 

adopt TSTF–422, Revision 2. 

Dated at Rockville, Maryland, this 22nd 

day of March, 2011. 

For the Nuclear Regulatory Commission. 

John R. Jolicoeur, 

Chief, Licensing Processes Branch, Division 

of Policy and Rulemaking, Office of Nuclear 

Reactor Regulation . 

[FR Doc. 2011–8310 Filed 4–6–11; 8:45 am] 

BILLING CODE 7590–01–P 

PENSION BENEFIT GUARANTY 

CORPORATION 

Proposed Submission of Information 

Collection for OMB Review; Comment 

Request; Disclosure of Termination 

Information 

AGENCY: Pension Benefit Guaranty 

Corporation. 

ACTION: Notice of intent to request 

extension of OMB approval. 

SUMMARY: Pension Benefit Guaranty 

Corporation (‘‘PBGC’’) intends to request 

that the Office of Management and 

Budget (‘‘OMB’’) extend approval, under 

the Paperwork Reduction Act of 1995, of 

a collection of information on the 

disclosure of termination information 

under its regulations for distress 

terminations, 29 CFR part 4041, Subpart 

C, and for PBGC-initiated terminations 

under 29 CFR part 4042 (OMB control 

number 1212–0065; expires October 31, 

2011). This notice informs the public of 

PBGC’s intent and solicits public 

comment on the collection of 

information. 

DATES: Comments should be submitted 

by June 6, 2011. 

ADDRESSES: Comments may be 

submitted by any of the following 

methods: 

• Federal eRulemaking Portal: http:// 

www.regulations.gov. Follow the Web 

site instructions for submitting 

comments. 

• E-mail: 

paperwork.comments@pbgc.gov. 

• Fax: 202–326–4224. 

• Mail or Hand Delivery: Legislative 

and Regulatory Department, Pension 

Benefit Guaranty Corporation, 1200 K 

Street, NW., Washington, DC 20005– 

4026. 

mstockstill on DSKH9S0YB1PROD with NOTICES