ML110700150

E-mail from K. Sullivan, Bn: to D. Frumkin, NRR Et Al. on Revised Oc TERs

ML110700150
Person / Time
Site:	Oyster Creek
Issue date:	07/22/2010
From:	Sullivan K Brookhaven National Lab (BNL)
To:	Daniel Frumkin, Brian Metzger NRC/NRR/DRA/AFPB
References
FOIA/PA-2011-0069, TAC ME0756, Job Code J4242
Download: ML110700150 (55)

Text

Metzger, Brian From: Sullivan, Kenneth [ks@bnl.gov]* ,5lf-Sent: Thursday, July 22, 2010 3:26 PMIV To: Frumkin, Daniel; Metzger, Brian Cc: Sullivan, Kenneth

Subject:

Revised OC TERs Attachments: Ph2 OC R12_72210.doc; OCPhl Final DRAFT R1_72210.doc Dan / Brian As I stated this am .... Attached are revised versions of the OC Ph 1 and Ph 2 TERs ... They were revised to more closely agree with the "Final" version of the Peach Bottom SE Ken 1

Energy Sciences and Technology Department Building 130 P.O. Box 5000 NATION.'KL LABORATORY Upton, NY 11973-5000 Phone 631 344-7915 e-mail: kscbnl.qov managed by Brookhaven Science Associates for the U.S. Department of Energy www.bnl.,ov July 21, 2010 Mr. Daniel Frumkin U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Risk Assessment, Fire Protection Branch (NRR/DRA / AFPB)

Washington, DC 20555-0001

Reference:

JCN No. J-4242, Task Order No. 1, Exelon Generation Company, Oyster Creek Nuclear Generating Station TAC No. ME0756. - Phase 2 Request - OMAs Not Previously Identified In Fire Protection SERs.

Dear Mr. Frumkin:

By letter to the Nuclear Regulatory Commission (NRC) dated March 4 2009, Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50, Section Ill.G, "Fire Protection of Safe Shutdown Capability," for Oyster Creek Nuclear Generating station to allow the use of manual actions for demonstrating compliance with Section III.G.2 of Appendix R, which were not previously approved in Fire Protection Safety Evaluations issued by the staff. In accordance with the scope of work described in Task 1 of Project J-4242, I have reviewed the technical merit of the request submitted by the licensee.

As described in the enclosure, I recommend that the requested exemption be granted.

Per your request, the format and level of detail of this Technical Evaluation Report (TER) is similar to that used by the staff in its evaluation of Exelon Generating Company's exemption request to allow the use of operator manual actions (OMAs) at Peach Bottom Atomic Power Station Units 2 and 3 (TAC Nos. MD7029 AND MD7030).

If you have any questions, please contact me at the phone number or e-mail address indicated above.

Sincerely, Kenneth Sullivan, Systems Engineering and Safety Analysis Group cc: B. Grenier, NRC D. Diamond J. Higgins Project File J4242A, Task 1

ENCLOSURE EXELON GENERATION COMPANY, LLC, OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-2 19 EXEMPTION

1.0 BACKGROUND

The Exelon Generation Company, LLC (Exelon~,the licene'ein addition to PSEG Nuclear, LLC) is the holder of Facility Operatingt,*icense Nos. DPi'ibwhich authorizes the operation of the Oyster Creek Nuclear Generaiting"Station. (OCNGSTij.'T:e license provides, among other things, that the facility is subject,'tbial rules, regulations, an.idrders of the U.S.

Nuclear Regulatory Commission (NRC, the .ommission) 'effect noW'or hereafter The facility consists of a is a!sg unit Mark l,ýGneral Electric (GE) 2.1bilhng water aihgleuntMr1!%nea reactor (BWR) located in Ocean Count~yý,New Jersey. 1111 2.0 REQUEST/ACTION Title 10 of t I era Rqi Part 50, Section 50.48, requires that nuclear anuarsatisfy the requirements of 10:Pr0p R r nP3 gam for Nuclear Power Facilities Operating Prior to January 1, 1979iSection , "Fire protection of safe shutdown capability." OCNGS wrgas was liene licensed ,,muto ioperatde

.to o to J~an*ary 1, 1797'4.As such, the licensee's Fire Protection

.,t~ietbse,

• ,prio .":

Program f fpprotection as intended by 10 CFR Part 50, AppendiJbl'and ecSth II*.G.

f y letter dated, M*rch 4, 2009' Request f6r Exemption from 10 CFR 50, Appendix R, Section III bn,"Fire Protection of Safe Shutdown Capability (Phase 2)" (Agencywide Documents Access and rM1nagement System (ADAMS Accession No. ML090640225), Exelon requested an exemption for thi',lOyster Creek Nuclear Generating Station (OCNGS) to allow the use of operator manual bctions (OMA) in ilieu of meeting the requirements of Section III.G.2 of Appendix R to 1 0C*i*0 As described in Regu(atory Issue Summary 2006-10, "Regulatory Expectations with Appendix R Paragraph IIl.G.2 Operator Manual Actions," for plants licensed before January 1, 1979, an approved exemption is required for all operator manual actions (OMAs) used to achieve compliance with 10 CFR Part 50, Appendix R Section III.G.2, even those that were accepted in a previously-issued NRC Safety Evaluation Report (SER). This exemption request (Phase 2) is limited to those manual actions that were not previously reviewed by the staff or included in the licensee's previous (Phase 1) exemption request, dated March 3, 2009.

In response to the staff's request for additional information, the licensee provided supplemental information dated April 2, 2010. In response to RAI-01.2, Exelon states that it has re-evaluated its exemption request, and, based on the results of this review, has withdrawn the following fire areas/zones from the request: RB-FZ-1 F2, RB-FZ-1 F4, RB-FZ-1 H, TB-FA-3B,

OB-FZ-10B, TB-FZ-11A, TB-FZ-11G, AB-FA-13, DG-FA-15, NR-FA-20, OG-FA-21, OR-FA-19.

As a result, the scope of the licensee's Phase 2 exemption request is limited to a total of 8 specific OMAs that may be required to be performed as a result of fire in the following 21 fire areas/ zones: 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-11 B, TB-FZ-11C, TB-FZ-11D, TB-FZ-11 E, TB-FZ-11F, and TB-FZ-11H.

The largest number of actions required to be performed as a result of fire in any single location (fire area or zone) is six (6). The 21 fire areas / zones and the thirteen specific OMAs to be performed in the event of fire in each area are described below in Table 1.

In summary, by letter dated March 4, 2009, and asupplemental letter dated April 2, 2010, responding to the NRC staff's request for additional information, Exelon submitted a request for exemption from 10 CFR Part 50, Appendix R, Section !II.G, "Fire Protection of Safe Shutdown Capability," to permit the use of a total of 8 operator marnual actions (OMA) in the event of fire in 21 separate fire areas / zones of the:OCNGS.

3.0 DISCUSSION Pursuant to 10 CFR 50.12, the Commission may,Jupon 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 sec*durity; and (2) one of the special circumstances provided in sub-paragraphs (i) through (vi) of 10 CFR 50.12(a) (2) is present.

Exelon states that it had originally intended to address the special circumstances provided in both 10 CFR 50.12(a)i(2) (ii) [underlying purposeioifthe rule] and 10 CFR 50.12(a)

(2) (iii) [undue hardship]. However,,in its April 2,,2010 response to RAI-01.2, Exelon states that it no longer cites 10 CFR 50.12(a)(2)(iii) [undue hardship] as a special circumstance under 10 CFR 50.12(a)(2). In:its response, Exelon states that tihe combination of defense-in-depth and the feasibity~ad~r~eliJability of the OMAs, demonstrates that the underlying purpose of the rule is met. Consistent with the, language included inI(10CFR 50.12(a) (2) (ii).

In accordance with 10 CFR 50.48(b), nuclear power plants licensed before January 1, 1979, are required to meet Section IIl.G, o6f10 CFR Part 50, Appendix R. The underlying purpose of 10 CFR Part 50, Appendix R, and Section III.G is to ensure that the ability to achieve and maintain safe shutdown is preserved following a fire event. The regulation intends for licensees to accomplish this by extending the concept of defense-in-depth to:

1) prevent fires from starting

2) rapidly detect, control, and extinguish promptly those fires that do occur

3) provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

The stated purpose of 10 CFR Part 50, Appendix R, Section III.G.2 (III.G.2) is to ensure that one of the redundant trains necessary to achieve and maintain hot shutdown conditions remains free of fire damage in the event of a fire. III.G.2 requires one of the following means to ensure that a redundant train of safe shutdown cables and equipment is free of fire damage,

where redundant trains are located in the same fire area outside of primary containment:

a. Separation of cables and equipment by a fire barrier having a 3-hour rating;

b. Separation of cables and equipment by a horizontal distance of more that 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 automaticf suppression system installed in the fire area.

In its March 3, 2009 and April 4, 2010 submittalhas requested an exemption from the requirements of IIl.G.2 for OCNGS to the that onejof the redundant trains of systems necessary to achieve and maintain hot shu*down is not Waintained free of fire damage in accordance with one of the required means specified above for ccurring in the following 22 Fire Areas or Zones: ,!ccurrin

1. CirculatdyyWater Intake ' ',

2.

3.

4.

5. -irculati&Y'MG Set Room

6. om (35' elevation)

7. 14 Room:,'Tbh'nel and Electrical Tray Room

8. inge Room Area and Operations Support Area

9. Building elevation 51-3".

10. Building elevation 23'-6"

11. RB-FZ-1 F3 j'lR6tior Building basement -19'-6" elevation (Northwest corner)

12. RB-FZ-1 F5 Reactor Building basement -19'-6" elevation (Torus room - remaining area of Reactor

13. RB-FZ-1G Shutdown Cooling Room - north side of the Reactor Building (elevations 38' and 51'-3")

14. TB-FA-3A 4160V Emergency Switchgear 1C Vault - Turbine Building Mezzanine 23'-6" elevation - south side

15. TB-FA-26 125 VDC Battery Room 'C' - Turbine Building Mezzanine 23'-6" elevation - south side

16. TB-FZ-1 1B Turbine Lube Oil Storage, Pumping & Purification Area - Turbine Building, elevations 0'-0", 27'-0, 36-0, and 46'-6"- north side

17. TB-FZ-11C 4160V Switchgear Room 1A and 1B -Turbine Building Mezzanine 23'-6" elevation - west side

18. TB-FZ-1 1D Turbine Building Basement Floor - elevation 3'-6" - south side

19. TB-FZ-1 1E Condenser Bay - Turbine Building elevation 0'-0"

20. TB-FZ-1 1F Feedwater Pump Room - TurbirmBe iiding Basement elevation 3'6" -

east side

21. TB-FZ-11H Demineralizer Tank and,Steam Jet Aiitijector Area, Turbine Building 3-6" and 23'-6" elevaties&-2 southeast siqe?,

,Mtff*l_

MI tf i .it

22. YARD Includes the OfficeBBdilding Roof, Turbine Buiilding Roof and All remaining outside areas within the protected areaot analyzed under other existing fire areas/zones In its March 4, 2009 submittal Exelon-ha~sir~equestedlarpexemption from the requirements necessary of III.G.2an&

to achieve for 6OCNGSihtain to hothel1xtent s"-'"i'o that'bne is IMM.,,of te redundant

.... *t1, trains of systems necssay t acievs notlmaintainec.Tree of fire damage in accordance with one OTtne required means spec*fii[eaE*aoove.*te-Exeloýn states that the OMAs identified in the Marc81 uu2O09 (Phase 2) request, are new acions not previously accepted by the staff in a safety evalyation repoft.

Each OMA includedin4hi streview consists a sequence of tasks that occur in various s

fire areapad-i6onAesldentsfied!ýtbove tl~dispussedbelow, the OMAs are initiated upon confirmation of a fire'in aýpartioldlr;fire area. 'Liked in the order of the area of fire origin, the OM-sme uded in this Ph'ase 1 rev'eware as fol16bWs:

Area of Fire, Y qActions Origin Actions CW-FA-14 "'41 l,open.,iili Manua*lly V-9*2099 and V-1 1-49 and close V-1 1-63 and V-1 1-41 Manual lj "'`e -1 5-237, throttle V-15-30 using local flow indicator (FI-225-2) and close ,1t5-52 OB-FA-9 Locally read Condensate Storage Tank level at LI-424-993 due to damage to control circuits.

Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 OB-FZ-6A Locally read CST level at LI-424-993 due to damage to control circuits.

Area of Fire Actions Origin Use Remote Shutdown Panel to control equipment: RSP, CRD Hydraulic PP NC08B and 480V USS 1B2 Incoming breaker (Operate USS 1B2/CRD Transfer Switch (Partial initiation) to "Alternate" and operate Control Switches for USS-1B2 Main Breaker and B CRD Pump).

Manually open V-1 5-237, throttle V-1 5-30 using !local flow indicator (FI-225-2) and close V-1 5-52,il

,, lIN OB-FZ-6B Manually open V-9-2099 and V-1 1-49 i'i0l1o96j'] "* ,! 1-63 and 1"*,'l*,~lflow V-1 1-41 indicator (FI-225-2)

Manually open V-1 5-237, throttle Vjl,5-3' using and close V-15-52 11111011, OB-FZ-8A Manually open V-9-2099 and VI-i '149 and close V-1 1'63rbrd V-1 1-41 Manually open V-15-237, throtflt V15-30 using local floV'i~ticator (FI-225-2) and close V-1 5-52 OB-FZ-8B Manually open V-9-209,9 and V-1 1-49 ahd 13los V-1 1-63 and V-11t-41 Manually open V-15'237, ithrottle V-15-30 using local flow indicator (FI-225-2) and close V-1 5-52 ,

OB-FZ-8C Lclyra odna~

OBFZCLocally read Condensattorad`y " .. ank levelfatiLI-424-993 due to damage to control circuits. I 1.

4111 Manua ll ..... I.9-2099 anldV-1 1-409aL'djclose V*-,il1!-63 and V-1 1-41 Use Ld&6.lfYShLitd`6wrn Panels `to"confrit &jdiemient as follows: LSP-1A2, CRD Hydra"dli PP NC08ý,Wand 480VOf SS' 1A2 Incoming breaker (Operate transfer switch "Alternate" and operate Control Switch for USS-1A2 Main Breaker 1A2M and A CaDEu~mp)111 i.

!Mahually

,,jqlli openPh.15-237,t2ieottle V-15'.30 using local flow indicator (FI-225-2) and close..;V-115-562!,'}*,n..q Trip all five IReacton Recirculation Pumps (NG01-A, NG01-B, NG01-C, NG01D and NG01E) 'Also, Io but the 4160V breakers using the 69 Switch OB-FZ-10A 'Manually open,*H.l 5-237 'throttle V-15-30 using local flow indicator (FI-225-2) anrd close V-15-552, RB-FZ-1 D Maihyally open Vx-1!5-237, throttle V-15-30 using local flow indicator (FI-225-2) an d andcl' e V-15-05 RB-FZ-1 E Read C*D.!ocRf1-w1 gauge FI-225-998.

Manually"'pn'jVA'l 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-15-52 RB-FZ-1 F3 Open Core Spray System II manual valves V-20-1 and V-20-2 and close V-20-4 RB-FZ-1 F5 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 RB-FZ-1G Read CRD local flow gauge FI-225-998.

Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 TB-FA-3A Manually open V-1 5-237, throttle V-15-30 using local flow indicator (FI-225-2) and close V-15-52 Connect H.P. air cylinder to drain port of accumulator to recharge

Area of Fire Actions Origin TB-FA-26 Manually trip 4160V 1D Breakers and control USS 1 B2 and 1 B3 480V Breakers locally at LSP-1D Manually control 1 B3M Breaker from LSP-1 B3.

Manually re-close MCC 1 B32 Feeder Breaker at USS 1 B3 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 TB-FZ-11B Manually trip 4160V 1 D Breakers and 66'T6l USS 182 and 183 480V Breakers locally at LSP-1 0 Locally read Condensate Storage Trik level at LI-424-b9.93 Manually control 1 B3M Breakefjfr6"m LSP-1 B3.

Local Shutdown Panels used to'dcntrol equipment as follow/6b,LSP-1 B32 Condensate Transfer Pump 1-2 (Ope'ate trarrsfer switch to "Aiternate" and operate Control Switchfor CondensateTr.ansfekr Pump 1-2) '*

Manually re-close MOC.CIB32 Feeder B`I*&at USS 183 Manually open V-15-2837* tfhrttle V-1 5-306"Isng local flow indicator (FI-225-2) and close V-1 5-52 "11ifi,

• 1;1h. llllý,

Trip all five Reactor Reci'ddlation'P:niips (NG0'1i-A1.kNG01-B, NG01-C, NG01D and NGQliE).IAIso, lockoutithe 4166"q0Irekers using the 69 Switch TanaIy"Znp 1 C4160V 1 D Breaka rs" ardýcontrolUSS 1 B2 and 1 B3 480V Breakers locally at.'LSP-1 D Mhi*ll~h!q ManuaiH/* [6ontrol 138K Breaker'f,6'rn LSP-1 B3.

Manually r6-`ose,MCC ý1B32 Fe6d*i Breaker at USS 1 B3

, diJaually openV-15-237;At'rottle V-",15.30 using local flow indicator (FI-225-2) and close ,V-15-52:

4160\ 1 Breakers ;nd control USS 1-B2 and 1B3 480VBreakers nManuallyrip Slocally at LSP-1 D

ý!Manually control,1 B3M Breaker from LSP-1 B3.

Shutdown Panels are used to control equipment as follows: LSP-DG2, pU6cal ED*2, and its Switchgear (Operate transfer Switches (3 total) to "Alternate" and opeVtljC, ontrol :S'witch on Diesel Panel to start diesel)

Manualy.? ýe.-cl*se MCC 1B32 Feeder Breaker at USS 1B3 Manually'bp`*e`T'-15-237, throttle V-15-30 using local flow indicator (FI-225-2) and close V-1 5-52 TB-FZ-1 1E Manually trip 4160V 1 D Breakers and control USS 1 B2 and 1 B3 480V Breakers locally at LSP-1 D Locally read Condensate Storage Tank level at LI-424-993 Manually control 1 B3M Breaker from LSP-1 B3.

Local Shutdown Panels used to control equipment as follows: LSP-1 B32 Condensate Transfer Pump 1-2 (Operate transfer switch to "Alternate" and operate Control Switch for Condensate Transfer Pump 1-2)

Local Shutdown Panels are used to control equipment as follows: LSP-DG2, EDG2 and its Switchgear (Operate transfer Switches (3 total) to "Alternate" and operate Control Switch on Diesel Panel to start diesel)

7-Area of Fire Actions Origin Manually re-close MCC 1 B32 Feeder Breaker at USS 1 B3 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 Trip all five Reactor Recirculation Pumps (NG01-A, NG01-B, NG01-C, NG01D and NG01 E) Also, lockout the 4160V breakers using the 69 Switch.

TB-FZ-11F Manually open V-9-2099 and V-11-49 and close V-11-63 and V-11-41 Manually open V-1 5-237, throttle V-1 5-30 usingdlocal flow indicator (FI-225-2) and close V-1 5-52 TB-FZ-1 H Manually open V-9-2099 and V-11-49 and close- V-11-63 and V-11-41 Manually open V-1 5-237, throttle V-15-30 using lo0cal flow indicator (FI-225-2) and close V-15-52 YARD Align the CRD valves (V-15-30,;V-1i5-52 and V-15-237) while monitoring the local flow indicator (FI-225-2)

Connect H.P. air cylinder to drain.port of accumulator to recharge Exelon further states that the exemptions are being requested from the requirements of Section III.G.2 and are not part of a Mneth6dology to shutdown the plant from outside the control room. The areas identified in the exemption requests have been considered III.G.2 since the initial Appendix R submittal. Each of the.OMAs is taken to permit .shutdown of the plant from the control room. The specific requirements of II*.G.2 that are not.met are identified for each of the requested exemptions in Attachment 1 of the licensee's April 2, 2010 response.

In response to RAI-01.1 Exelon statesthat its proposed: methodology achieves the underlying purpose of the rule by accomplishing the following:

1) OMAs identified in the March-4, 2009i(Phase 2) request are both feasible and

.reliable and not impacted by' environmental conditions associated with fires in Appendix *R, Section Ill.G.2 areas4 .1

2) the equipment needed to implement OMAs remains available and the fire areas reemain accessible during or following the event.

3) the OMAs are directed by plant procedures, and the operators are trained in the use of the procedures.

4) staffing is adequate to perform the OMAs.

5) walkdowns and demonstrations have shown that adequate time is available to perform the OMAs, and

6) time margin is available to account for uncertainties that may arise during a fire event.

7) the requested OMAs are similar to activities performed by plant operators as part of their normal work assignments

8) adherence to the principles of fire protection defense-in-depth.

To address staff concerns regarding the adequacy of defense-in-depth provided for each of the fire areas / zones included in its requests, Exelon developed a Fire Hazards Analysis (FHA) which was included as Attachment 2 of its April 2, 2010 response. For each of the areas

/ zones included in the request, Exelon states that the fire protection configuration provided achieves a level of protection commensurate with that intended by Appendix R,Section III.G.2.

For each fire area / 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. 111111 In the March 4, 2009 request, the licensee outlined*the" approach that was taken to evaluate and assess the effectiveness of the operator,66hual 'actions included in the request and explains where each operator manual action is"located and the role of the actions in achieving safe shutdown. In its April 2, 2010 respbhos to a Requestifor Additional Information the licensee provides a discussion and justificationfor why the operatqý, manual actions are appropriate for maintaining consistency with thelitent of Section IIl.G.2 9ippendix R. The NRC staff reviewed the licensee's evaluation in sulport "ni"to of theisubject

ýýJJP exemption request for the Secti~ll.G2o use of operator manual actions in lieu of the requirempentss cified in Secti4 G.2 of Appendix R, and concluded

• Jr.I W h existing fire - .1o that giv'ijthe ion features in thelffected fire zones, Exelon continues to meet thd*ln purpose f10 CFR Part 50, Appendix R,Section III.G.2 for the OCNGS fire desribed in Attachment 1 The following technical evaluation provides the basis for this con 3.1 Fire Prevention 1lh, In response to staff. requests for additional ' finformation Exelon developed a Fire Hazards Analysis (FHA) .,for**'*Jl...

each fir6area,01It /;zoneidentified

4W t11M O- li1*0,1 its exemption request. For each fire area/

zone, the f!iHIescribes the ph*sical location and a rangement of equipment, combustible ioading,dlgnitiOn fieslre proection Teatres ,roximity of redundant safe shutdown equipment to in situ hazards and deOntifies devia*tions from fire protection codes and previously approved exemptions. In *dddition, fo!reach fire area/zone the licensee's response includes a tabulation of,1potential ignitionrsources as**ell as the equipment that may exhibit high energy arcing faults. Fidrteach fire area/ zone, ttieFHA states that the fire protection configuration achieves a leveiHif protection commensurate with that intended by Appendix R, Section Ill.G.2 All 22 areas I zoiIes idertified in the request have limited or low combustible fuel loading (equivalent fire severityI oflessitlan 45 minutes) except areas OB-FZ-6A, OB-FZ-6B, and TB-FZ-1 1B. Fire areas OB-FZ nd OB-FZ-6B, have low to moderate combustible fuel loading (equivalent fire severity of less than 105 minutes) and TB-FZ-1 1B has a high combustible fuel loading (equivalent fire severity of greater than 105 minutes). Areas with moderate or greater fuel loading have adequate detection and suppression systems appropriate for the hazard.

The fire areas included in the exemption are not shop areas so hot work activities are infrequent with administrative controls (e.g., hot work permits, fire watch, and supervisory controls) programs in place if hot work activities do occur. The administrative controls are described in the OCNGS Fire Protection Program (FPP), which is incorporated into the Updated Final Safety Analysis Report.

Unless noted otherwise below, all of the fire areas included in this exemption have a

combustible fuel load that is considered to be low with fuel sources consisting primarily of fire retardant cable insulation and limited floor based combustibles. Unless noted otherwise, there are no high energy ignition sources located in the areas and the areas.

Fire Area Combustible Loading CW-FA-14 Fire Area CW-FA-14 is an outdoor structure with no walls or ceiling. This fire area consists of a structure that is remote from the power block and other outdoor equipment (e.g., main transformers, etc.)jthatis open to the environment.

Combustible loading consists of transformer liquid and electrical motors although it is not quantified because there is nothi 'to contain the heat release in the event of a fire. The main combustible in thisarea that could result in the need for the OMAs is Dow Corning 561 Silicon transformer liquid. Theli.censee states that the transformer liquid has characteristics that minimize the likelihoodof a fire involving the insulating liquid itself OB-FA-9 This area has an administrative fire Ioadind:limit of less than,1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> as determined by the ASTM E119,tme-tempera urve The major comblustibles in the MUX Corridor are cable insulation and a \ i6lceing on top of the MUX enclosure.

OB-FZ-6A Fire loading in this fire zonHeis moderate. This area has an administrative fire loading limit of less than three-hours as determined byI the ASTM El 19 time-temperature curve. The main combustibles in this area are cable insulation (approximately 81%

of loading) and' Dow Corning 561 Silicon transformer liquid (approximately 15% of loading). The transformer liquidhas characteristics that minimize the likelihood of a fire ::in, olving the insulating liquiid itself.

3-FZ-6Bý Fire loading in:this fir*, zone is moderate. Fire Zone OB-FZ-6B floor area is approximately 679 sq. ft.This ar66 has an administrative fire loading limit of less than tWo hours~as determined by *the ASTM El 19 time-temperature curve. The main combustibles in this area are cable insulation (approximately 28% of loading),

Thermo-Lag: (approx:imately 29% of loading) and Dow Corning 561 Silicon transformer'liquid (approximately 31% of loading). The transformer liquid has

icharacteristics that minimize the likelihood of a fire involving the insulating liquid itself OB-FZ-8A FireZones OBrFZ-8A and 8B are evaluated together for the combustible loading and FS8D: analysis. These fire zones have an administrative fire loading limit of less OB-FZ-8B than 45 minutes as determined by the ASTM El 19 time-temperature curve. There are very 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).

OB-FZ-8C This area has an administrative fire loading limit of less than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> as determined by the ASTM El 19 time-temperature curve. The main combustibles in this area are the plastic battery cases and racks (approximately 56% of loading) and cable insulation (approximately 39% of loading).

OB-FZ-1OA This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. This limit is tied to an NRC-accepted approach for dealing with fire zone boundaries (refer to the response to

Fire Area Combustible Loading RAI-04.3 in Attachment 1 for more details). 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 (PC) supplies (approximately 20% of loading). However, since the PCs have been placed in metal cans with self-closing lids they are no longer considered a contribution to the combustibles in this area.

RB-FZ-1 D This area has an administrative fire loadingiimit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The main combustible in this area is attributed to cable insulationr (approximately 84% of loading).

RB-FZ-1 E This area has an administrative fire l~oading limit of less than 30 minutes as determined by the ASTM El 194time-temperature curve. The main combustible in this area is attributed to cable insulation (approximately. 84% of loading).

RB-FZ-1 F3 This area has an administrative'e fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The,major combustibles in this area are cable insulation (approximate'l 58% of loading), ladders (approximately 16% of loading) and liuricating oil in pumps (approximately 16% of loading).

RB-FZ-1 F5 This area has an administrative fire'*loading limit of less than 30 minutes as determined..by the ASTM E 119 time-temperature curve. The major combustibles in this area are cable insulation (approximately 19% of loading) and gratings (approximately 76% of loading). The grating, which is the largest plastic material in this area, has a flame spread'of less than 25.

RB-FZ-1G This area: has.,an administrative fire, loading limit of less than 30 minutes as determined by the ASTM E19 tim -temperature curve. The main combustibles in this area are cable. insulation (approximately 12% of loading), plastic (approximately 57% of loading) and Class A combustibles (approximately 14% of loading). The grating, which is the majority of the plastic material in this area, has a flame spread of less than 25.

TB-FA-3A This area has an administrative fire loading limit of less than 30 minutes as det*r*rinedby:ithe ASTM El 19 time-temperature curve. There are minimal amounts of cable insulation (approximately 5% of loading) miscellaneous plastic (approximately 73% of loading) and class A combustibles such as paper for procedures (approximately 20% of loading) in this area.

TB-FA-26 This area requires an administrative fire loading limit of less than 90 minutes as determined by the ASTM El 19 time-temperature curve. The major combustibles in this area are plastic, which is contributed by the battery cases (approximately 92%

of loading) and cable insulation (approximately 6% of loading).

TB-FZ-l 1B This fire zone has administrative controls such that additional combustible materials are not introduced into this zone and defense-in-depth features to control a potential oil fire in this zone The major combustibles in this area are lubricating oil (approximately 99% of loading) and cable insulation (approximately 0.3% of

Fire Area Combustible Loading loading). The amount of oil contained in the lube oil storage tanks in this fire zone drives the combustible loading in this fire zone to approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

TB-FZ-1 1C This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The main combustible loading is attributed to cable insulation (approximately 73% of loading) and plastic (approximately 17% of loading).

TB-FZ-l 1D This area has an administrative fire loadiiinlimit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The major combustibles in this area are cable insulation (appr6ximatel.29% of loading), Dow Corning 561 Silicon transformer liquid (approximately l5OXI of,loading) and lubricating oil (approximately 40% of loadinig;), 11111 TB-FZ-1 1E This Fire Zone (Condenser.Bay) is procedurally controqlled as a transient combustible free area in procedure OP-A-'201-009 while the plant 'isbperating. This area is a high radiation area during plant operationrfatid is not norma eI accessed. The area has an administrati~e fire loading j0ilfii*s than 30 minutes!!as determined by the ASTM E 119 time-temnpe6ature curve. *lTe major combustibles in this area are cable insulation (approximately,40%, of Ioading) and plastic (approximately 59% of loading). The grating, whichilthe largest plastic material in this area, is dispersed tBF-11F hi rougouiahis a

throughout Ithis

'1r1te';d~

fir o~i~o fire zond' ý(not ' ntrted) as a flame spread of less than 25.

TB-FZ-1 1F /lSaea haslaj administrativeifireioadinglillpit of less than 30 minutes as determined by the ASTM EdlU9,ftime-temperature curve. The major combustible load consistsof cablellnsulation (aoproximately 15% of loading), lubricating oil (approximately*3°9% of loading)f,;ubber (approximately 21% of loading) and plastics

';(approximatelyi 17% of loading). , The licensee states that the majority of the combustible 'loading attributed to rubber and plastic was due to the storage of hoses which____,enow n'olonger in theiarea.

TB-FZ-1 I This area has an adffiiistrative fire loading limit of less than 30 minutes as Idetermined tyhe ASTM El 19 time-temperature curve. The major combustibles

ýare cable ins lation (approximately 23% of loading), ladders and other miscellaneous plastics (approximately 55% of loading) and miscellaneous ordinary combustibles,

YARD This is anhlutdoor area. There is no ceiling and no physical boundaries, and therefore, no fire rated or non-fire rated assemblies. There is no fire detection, however, there is constant observation of the site (yard area), both by humans and electronic devices (cameras). Manual suppression is provided by a hose station from the office building and by fire hydrants located throughout the yard area. significant hazards in this area (e.g., SBO transformer, etc.).are protected by a suppression system.

The NRC staff finds that for all of the areas related to this exemption, the level of fire protection combined with the limited fuel load and minimal ignition sources in the fire areas

associated with this exemption results in a low likelihood of a fire occurring and spreading to adjacent fire areas or equipment.

3.2 Detection, Control and Extinguishment The NRC staff evaluated the fire detection, control and suppression systems associated with the areas related to this exemption. All fire areas included in this exemption have automatic detection systems installed except Fire Zones TB-FZ-1 1D, TB-FZ-1 1 E, CW-FA-14, and the Yard Area. ,*iiI For Fire Zone TB-FZ-1 1 D, an exemption was grgntedlýrom' the requirements of Appendix R Section III.G.2 in SERs dated March 24, 1986 and Jn"I,25 9!t90 for not having area-wide automatic fire detection and suppression system. ,The,primary basisfor this exemption is the presence of the automatic wet pipe sprinkler syst smllow fire Ioading' and the one-hour barrier protection for safe shutdown circuits. Also, the floW alarm will notify the control room of any sprinkler system activation. Since a fire in this area would not impede the iplant's capability for safe shutdown, this exemption does not impact tiebasis for.tl3e manual exemption request.

The lack of a fixed fire detedt'ni capability in Fir~eldz:e TB-FZ-1 1E was dldressed by the staff in an exemption granted by tl16staffln SERs datedbMarch 24, 1986 and June 25, 1990.

The primary basis for this exemption i9sithe preisence of the automatic wet pipe sprinkler system and low fire loading. Since a fire in this aIra would!iotimpedelte, plant's capability for safe shutdown, this exemptiondbees, not impactihe basis forthe manualhexemption request.

FieAe WýA1, t i lrltu atory!,*WateýVfn'N,fttttis an olu,ý Fire Area' de area greater than 100 feet from any building exc... or the fish sample pool enclosure which is constructed of non-combustible material. The lack otautomatic detection is compensated for by continuous monitoringofthearea by personel ocatedlin a nearby tower. The licensee further stts thitnriumeroussidicatibhidnd states  !*t'I~i1u1idc " 1' ," "~ "

"- symptoms o4would

" remain available in the Control Room to i~tthe need' pr~form, tle!requested1QlAs would be readily diagnosed.

ensure `o,.Ith the ne, 1,,,.

itd r A Automatic fire detection systes's:are also not installed in outside locations classified as the Yard Area) owever, since~tlhe area istunder constant observation both by humans and electronic devices (cameras),h a"fi*e would be detected and appropriate actions taken without significant delay. 'I Fire areas OB-F/-9,QBb-FZ-8A, RB-FZ-1 F3, TB-FZ-1 1B, and TB-FZ-1 1 H have partial area detection systems inst.I**d to address specific fire hazards. Fire Area OB-FA-9 consists of three floors of the Office Building. Detection which alarms locally and in the control room is provided in the main hallways and inside of a small area known as the MUX room enclosure.

The licensee states that the majority of this fire area is normally traveled since it is the main path to the control room. However, the MUX corridor, which is adjacent to the south wall of the control room, is not a normally traveled area. Detection of a fire in the MUX corridor would be by the installed suppression system.

In Fire Area TB-FZ-1 1B, detection and suppression systems are installed to protect against the lube oil hazard in the area. Automatic detection is provided by a rate of rise/fixed temperature fire detection system at the lube oil tank. Locating the detectors in close proximity to tank provides for prompt detection of an oil fire, which in turn activates a deluge suppression

system for extinguishment.

There is no area-wide detection system provided for Fire Zone OB-FZ-8A. Detection within OB-FZ-8A consists of a duct smoke detector located in the exhaust duct of fan EF-1-20.

An exemption was granted from the requirements of Appendix R,Section III.G.2, for not providing area detection in this area. This exemption was approved in the NRC SER dated June 25, 1990 based on the fact that any fire which might occur in Fire Zone OB-FZ-8A will be relatively small and will be controlled by the automatic sprinkler system. 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. In addition, OB-FZ-8A is analyzed together with OB-FZ-8B for combustible loading 1 :sf;ase shutdown purposes and area-wide detection is provided in Fire Zone OB-FZ-8B (hidclalharms locally and in the control room. ir}'*,

The detection capability provided for RB-'FZ.,iF3 consists of'6s*oke detectors which alarm locally and in the control room, that are1located in close proximityitthe hazard (i.e., over pumps and cable tray. Since they are not mounit;ed~at the ceiling this is a deViation from NFPA 72E, 1974 Edition. The licensee states that an evalueation of tliis"deviation hasIdetermined that positioning the detectors closer to the; hazard improves thelde tctors' responsivehess to the major hazards in the area. I11I1l1 Fire Zone TB-FZ-11H also lackslarea-wj 1detection coverage. For a fire in this fire zone the licensee states that the "A" trainof powAMi credited andiavailable since they are located outside of this fird 1 H , t are to "'Tr i',25 VDC control power cables associated withAe nonfptrotected train Iroute'd JIM conduis which traverse through the stairway area of thiszcn at approxdmateiy elevato 10. nnMA for utilizing fire water would be required if these conduits are affected by fireIn addition to installing a new fire detector in the stairwell area near the conduitsthe licensee states that no ignition sources are located in the portionlof.elhIZone where,.thIe condutsaitre routed.

i-fre areas OB-FZ-6A, OB-FZ-8C, OB-FZ2 ,IOA,TB-FA-3A, TB-FA-26, TB-FZ-1 1B TB-FZ-11 C, TBLFZ-1 1 D and TB-FZ71 1E hav6earea wide fire suppression systems installed to mitigate the specififire., hazards located in the area. Fire Areas OB-FZ-6A, the B Train Switchgear Portion of OIFFZ-6B and OB;FZ-8C are provided with total flooding Automatic Halon 1301 Systems, TB-FAf,3A is provided !With a manually actuated, total flooding, CO 2 system. OB-FZ-10A, TB-FA-26, TB*FZ-11B, TBE-FZ-111C TB-FZ-11D and TB-FZ-11E have automatic sprinklers.

Fire Areas OB-FA.9 6O!iZA RB-FZ-1 D, RB-FZ-1 E have partial coverage suppression to suppress fiTsithat may occur due to the specific hazard. Fire Area OB-FA-9 has closed head sprinkler systems that provide coverage of the MUX room corridor over the MUX enclosure and the MUX Enclosure. In addition, fire extinguishers and hose stations are provided for manual fire fighting. Fire Area OB-FZ-8A has partial automatic wet pipe sprinklers.

An alarm will sound in the control room when the automatic fire suppression system operates.

Fire loading in this fire zone is low, consisting primarily of lubricating oil and cable insulation.

Safety related cable trays in Fire Zones RB-FZ-1 D and RB-FZ-1 E are protected by automatic fixed deluge water spray systems which are automatically activated by cross-zoned detection systems.

Fire Areas CW-FA-14, OB-FZ-8B, RB-FZ-1F3, RB-FZ-1F5, RB-FZ-1G, TB-FZ-11H and the Yard are protected by manual fire fighting capabilities.

Fire Area CW-FA-14 is an outdoor structure that is remote from the power block and other outdoor equipment (e.g., main transformers, etc.). Since the area is continuously monitored by security personnel located in a nearby tower, prompt notification of the station fire brigade is assured.

Fire Zone OB-FZ-8B has a small floor area (approximately 479 sq. ft) and the combustibles located in this Zone are very minimal. The major combustibles in Fire Zone OB-FZ-8A are lubricating oil (approximately 83% of loading) and cable insulation (approximately 13% of loading). There are no components or cables that will cause the loss of the "B" Train of Power in Fire Zone OB-FZ-8B. This area is accessed onl~y~lthrbdgh a single locked door with a vital access door lock so access into the room -is restrict~d,'atlere are no credible ignition sources in this room that would impact the credited ca~les located in conduit in the room below,

... . t*;,;n cnu int rom e w Manual fire suppression consists of portable fire eXttiguishers with 1hose stations for backup.

Fire Zone RB-FZ-1F3 floor area is als61small (approximately 5601sq. ft.) The major combustibles in this area are cable insulation (approximately 58% of loading), ladders (approximately 16% of loading) and lubricating ojill [AMpumps,(approximately'Tl6% of loading). The fire loading in Fire Zones RB-FZ-1F3,and RB-FZ-lP5 is* defin6d as "low" in the ~lliAR. Fixed combustibles *are. *'*limited to molded fibergass 0 ,.M l 11;*. re nforceol3oyester i 't, .. grating and minor. amounts

. of lube oil in the various pumps. Manual!firelsutppression con sists of portable fire extinguishers with hose stations for backup. In a Safety Evliuation dated5J >e 25, 1990 the staff approved an exemption for not having area-wide automatic fir& asppression! 'rfire zone RB-FZ-1 F based on the low combustible loadihigahd the fact tihat~the fire, detection would alert the fire brigade to the onset of a fire in the zo~e"Iso t6atrompt mn4ai .spressounlof any' fire could be accomplished.

Fire Zone RB-FZtIG is approximately 1609 sq. ft. The main combustibles in this area are cable insulation (approximately,*12% of loading), plastic grating (approximately 57% of loading) ar ;lascombustibles (apo~6imatelyi!°4% of loading). Manual fire suppression consists."Olf-'poitabeO.fi re extingu ishers with 'hose;stations for backup.

TI1'imajor combustibIles in TB6FZ-1 1H are cable insulation (approximately 23% of loading), ladders and other mipe~lane ous plastics (approximately 55% of loading) and miscellaneodujsirdinary combustibles. The"fire loading is "low" as defined in the FHAR. No fire safe shutdown eq16pment is located in this area but there are two "B" Train 125 VDC control power cables (non-ipOrotected train) that traverse through the stairway area of this zone at approximately elevation 10 ft. Manual fire suppression consists of portable fire extinguishers with hose stations for bDdkup'.':'ý'

The Yard Area is located outside. Combustible loading is spread throughout the yard but is not quantified because there is nothing to contain the heat release in the event of a fire.

Significant hazards in this area (e.g., SBO transformer). are protected by a suppression system.

In addition, The Yard Area is in constant observation both by humans and electronic devices (cameras), so that if a fire would occur, it would be detected and appropriate actions taken without significant delay. Manual suppression is provided by a hose station from the office building and by fire hydrants located throughout the yard area.

The NRC staff finds that the fire barriers, fire detection, control and suppression systems are adequate to mitigate and contain the fire hazards in the 21 areas identified in the licensee's request.

3.3 Preservation of Safe Shutdown Capability 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. A 'feasible action' is one that is analyzed and demonstrated as being able to be performed within an available time so as to avoid a defined undesirable outcome. The feasibility review documents that procedures are in place, in the form of fire response procedures, to ensure thatdletir and accessible instructions on how to perform the manual actions are available to theoperators. A "reliable action" is a feasible action that is analyzed and demonstrated as beingigdependably repeatable within an available time, so as to avoid a defined adverse consequenc Ihile considering varying conditions that could affect the available time and/&i~the time to prorm the action. Thus, an action is considered reliable if the licensee's an~alyisidemostratest at there is adequate time available to account for uncertainties not onlyt ih*imates of the time a~yalable, but also in estimates of how long it takes to diagnose and sexecute the operator mainuail action (e.g., as based, at least in part, on a plant demonstration 'ofthe action :under non-irelconditions).

To provide assurance that theg!requested OMAS cani eliably be performeýdunder a wide range of conceivable conditions by differentýplant crews,.the licensee states that the feasibility and reliability of OMAs identified in thýe Ma:rch 4, 2009 (Phase 2) exemption request were evaluated against the criteria contained in NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator ManuaI Actions in Response to Fire," dated!October, 2007 which provides guidance actacceptble&tthe staff f6revaluatigi' jj.Iefeasibiii* y and reliability of post-fire operator manual acti 2*;, '!iI in nuc1.drpower ...

f!! qVU plants The licensee's s addreses factorssuch as environmental concerns, equipment functionalit "acessbtiyllaala iiationbmmunications, portable equipment, personn otectlon epmernpm n lp .ocedures 'aditrailing, staffing and demonstrations. In their March *4J-3009 requesta rt&ported by their April 2, 2010 response, the licensee stated tl'atIenvironmental consideratiohs such as radiological concerns, emergency lighting, temperature ntrepresn, landl*÷humidity gati, imco. .* oitins., andDer smoke and toxic gases were evaluated and found to not represent, aegative impactl n th ators'abilities to complete the OMAs. The licensee has also stated thajsufficient emhergency lighting exists at the areas where the actions are performed and along~the travelob'tes to the areas and that the noise levels at the areas where the actions are performedI shonou1Pot impede the use of normal communications.

All of the requested :.OMAs are directed by plant procedures, and the operators are trained in the use of the procedures. Specifically, 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, C02) or a fire is confirmed. In addition, 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.

• 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 eve: ,nt 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 considere*d'prompt" (i.e., those that must be done within 45 minutes or less) are identified in both ABN-29 :and.in the applicable Fire Support Procedures as an item requiring immediate attention.: The operators are trained to perform prompt actions first and prioritize them based upon existing plant co68Aditions. The FSPs are based on the worst-case loss considerations by assuming all fire dam':a'e occurs instantaneously and thus all operator manual actions will be required. The ,use of the Emergency Operating Procedures (EOPs) in conjunction with'the applicable. FSPs will permit the use of any mitigating system available first, andiif a desired;system is not aýailable, the FSP provides a contingency action to restore the system or provide another means tbperform 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.

Each of the safe shutdown calculations that provide the technical basis for the FSPs contains a timeline for operator actions forthe specific fire area. In addition, simulator exercises and walkdowns were performed to demonstrate that te operator manual actions can be performed reliably within the times allotted by thelfire safe shutdown calculations. In its April 2, 2010 response the licensee states: that the simulator demonstration proved that all of the OMAs for each fire zone could be accomplished as required.

For each of the fire areas included in thisexemption, the postulated fire scenarios and pertinent';details are summarizedcini Table 1 below:

The tNIRC staff reviewed the required operator manual action completion time limits versus the timrebefore the action becomes critical to safely shutting down the unit as presented in the feasibility analyses. In onecbase the action must be completed within 30 minutes. This action, which is identified as OMA Phase 2, #1 requires an operator to manually trip the field breakers for recirculatkion pumps MG Set so that the fuel zone level indicators can be used.

This action may be required as a result of fire in TB-FA-26, TB-FZ-1 1C, or TB-FZ-1 1D. 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 control switches or the Recirculation Pump Trip circuitry (two trip coils). If both of these methods fail on one or more pumps, the guidance is given to trip the pumps from locations outside the control room. Only one operator would be required and it would take approximately 8 minutes for access to the area and to perform the action. Given the low complexity of this action, the! \IRC staff finds that there is a sufficient amount of time available to complete the proposed operator manual actions.

3.4 Evaluation As stated in 10 CFR Part 50, Appendix R, and Section 1/: The fire protection program

shall extend the concept of defense-in-depth to fire protection with the following objectives:

1. To prevent fires from starting,

2. To detect rapidly, control, and extinguish promptly those fires that do occur, and

3. To 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 NRC staff has evaluated the elements of defense-in-depth used for fire protection at 1551-i1repth u f i o o OCNGS, applicable to the fire zones under review. BasedIupon consideration of the limited fire ignition sources and fire hazards in the affected areas )a'Pldthelexisting fire protection measures at OCNGS, the NRC staff concludes that objective onelof:defdnsenin-depth is adequately met.

Based on the evaluation of fire detectionaiap; bsuppression systems provided in the affected fire zones, the NRC staff determined thaf any postulated fire isý expected to be promptly detected by the fire detection systems in the asso*iated fire areas. The available fire detection and suppression equipment in these fire areas ensure. that a!ibstulated fir&, ilnot be left unchallenged. In addition, all fire areas are separatedaf tomaaijacent fire areaslsisuitable fire-rated barriers to provide a level of compartmentalization'etwen h.I the fire areas and/or buildings.

.rae~a, . Oil"1 This compartmentalization

• ." helps

. . to ensureitlat

• !1~~W t, 4*ltll* fires will notspread.. to adjacent fire areas and M 111ll:,

that any fire damage will be limited to t elfire 5reatof origin. Iladdltion, when fires are contained in the fire area of origin, the licensee hasz~emonstrated that tHel 'i anual actions are feasible.

Therefore, the NRC staff iddhnludes that objectives 2 ah*dlP3 of defense-in-depth are adequately met. i, lt Therefore, the NRC staff cohcludes that the requested exemption to use operator manual actions in lieu offthei requirements of 10CR Part 50 Appendix R,Section III.G.2 is consistent with the *defense-Lihdepthimethodologyinecessary at nuclear power plants and will not impact*-f*tire gafetshutdown, apabil ty!

3.5 Adt*orized By Law , 0 tI Thiseemption wouldtallow OCNGS the use of operator manual actions in lieu of meeting the requirements specified in 10 CFR Part 50, Appendix R, and Section III.G.2. As stated above, 1061( .50.12 allows_,.,, the NRC to grant exemptions from the requirements of 10 CFR Part 50. The NRC staff hasetermined.that granting of the licensee's proposed exemption will not result in a violatin. of,1tlbel Atomic Energy Act of 1954, as amended, or the Commission's regulations because special cir~cumstances exist that warrant the use of the operator manual actions to achieve safe shutdo0wn. Therefore, the exemption is authorized by law.

3.6 No Undue Risk To Public Health and Safety The underlying purpose of 10 CFR Part 50, Appendix R, Section 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. Based on the existing fire barriers, fire detectors, automatic and manual fire suppression equipment, fire protection requirements, and the absence of significant combustible loads and ignition sources in the fire areas associated with this exemption, the NRC staff has concluded that application of 10 CFR Part 50, Appendix R,

Section III.G.2 for these fire areas is not necessary to achieve the underlying purpose of this regulation.

The NRC staff has determined that the exemption to allow OCNGS the use of operator manual actions in lieu of the requirements specified in 10 CFR Part 50, Appendix R, and Section III.G.2 does not increase the probability or consequences of previously evaluated accidents. This determination is based on the NRC staff finding that the operator manual actions are not the sole form of protection relied upon due to the other fire protection features in place and the manual actions are considered feasible and provide safe shutdown capability following a fire. The combination of the operator manual actions, in conjupjition with all of the measures and systems discussed above, results in an adequate level~f~otection. No new accident initiators are created by allowing use of operator manualk t1ions in the fire areas identified in the exemption and the probability of postulated accidents ,i4siOt indteased. Similarly, the consequences of postulated accidents are not increased. Therefor ,,there is no undue risk (since risk is probability multiplied by consequenceslito public healit 'nad safety.

3.7 Consistent with Common Defense and Security The proposed exemption would allow OCNGS the use of specific operator manual actions in lieu of meeting the requirementsspPecified in 10 CFR Part 50, Appendix R, and Section Ill.G.2. This change, to the operatiorinf the plant, hiisho relation to security issues nor does it diminish the level of safety from whit was in1ended by the requirements contained in Section lll.G.2. Therefor&,ýth*ecommon defense and isecurity is notlilmpacted by this exemption.

3.8 Special Circumstances, tlhe~s,,*n,,tial circum.stances. describedin1ýd 0 CFR 50.12(a) (2) (ii) is that the applicationlfof the regdlfation is nt ecessary clIieve the underlying purpose of the rule. The underlyinigpurpose of 1OOIR Parltha50 Appendix R,Section II.G.2 is to ensure that one of the und i necessaryotfachevel and maintain hot shutdown conditions remains free of fire damage in the~event of a fire'.ltor the fireareas specified in Table 1 of this exemption, the NRC staff finds that"t -perator manual actions are feasible and the existing configuration described herein will ensure that a redundant train necessary to achieve and maintain safe shutdown of the plant will remain4re of fireldamage in the event of a fire in these fire zones. Since the underlying purpose of i0olcFal.a 50, Appendix R,Section II.G is achieved, the special circumstances required 1yj,110GFR 50.12(a)(2)(ii) for the granting of an exemption from 10 CFR Part 50, Appendix R, Sectidn'lll.G.2 exist.

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 such that application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule. Therefore, the Commission hereby grants Exelon an exemption from the requirements of Section lII.G.2 of Appendix R of 10 CFR Part 50, to

OCNGS for the 21 operator manual actions specified in Table 1.

Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (74 FR 5191).

All'*llllt

~II~lt iIIi  !*

20 TABLE 1 Phase 2 OMAs iIiii~I~

21 TABLE I Phase 2 OMAsz-ý-

OMA n~j*I ig Fire AcinsLcation OMA Purpose Fire Affected Component _ A re Actions cation Number A*re -a: Loato Trip field breakers for 1A and 1B 4160V Switchgear CabindtK3TB-FA-26 .Trip Field Breakers for Recirculation OB-FZ-8C recirculation pumps and the "C" Battery distribution par"-T. umps A through E.

MG set so the fuel TB-FZ-1 1C zone level indicators can be used ,-'B-FZF1I*D 2 Provide makeup water Control cables for 1D441'600V-.breakers; TBýFA--26 Manually manipulate valves V RB-FZ-1 E to the "A' Isolation 1D Main breaker and USS 11B33 :2L 2099, V-1 1-49, V-1 1-63 and V-1 1-41 Condenser. breaker. - TB-FZi1rI-C to align Fire Water for makeup to T:;

• I9-B--FZ-1 Isolation Condenser.

3 Manually control 480V Contr!6EC5lies farTlR=D Pump NC08B .=oTB-FA;26t- Proceed to RSP operate transfer sw. OB-FZ-6B USS 1 B2 Breakers for and IB2M & control CRD Pump B and bkr 1B2M CRD Pump NC08B TB-FZ-1 1B, to power USS-1 B2 and 1B2M from ___

Remote Shutdown " TB-FZ-1 1C, Panel. T F110

-'TB-FZ-11g,

• .-- i*..TB-FZ- 11 E 7 To provide makeup  :....

This is a contingency action-if access to TB-FA-26, Manually open V-11-36 to makeup to RB-FZ-1B water to the 'A' -.the 4160V Switchgear is delayed due the Isolation Condenser Isolation Condenser t6&ýsoke and/or C-02, and the TB-FZ-1 1C, Con-dý9sate Trarnsfer System is unavail5lel Under these conditions, TBFZ110 the safe shlýtdown analysis credits the fire water system to provide makeup water to the Isolation Condenser

22 OMA OAInitiating Purpose Fire Affected Component a reFire Actions ActionsLcto Number Area:* Location 8 Monitor Isolation This is a contingency action if access to TB-FA-26, Obtain "A" Isolation Condenser shell RB-FZ-1 B Condenser level the 4160V Switchgear is delayed due level using local mechanical gauge to smoke and/or C02, and the TB-FZ-1iC,:..

Condensate Transfer System is unavailable. Under these conditions, 'TB-FZ-1 1D the safe shutdown analysis credits the fire water system to provide makeup-:

water to the Isolation Condenser .

9 RPV Makeup Instrument Air .Y .ARD/ Align the CRD valves (V-15-30, V RB-FZ-1 E 52 and V-15-237) while monitoring the local flow indicator (FI-225-2) 1Yard Area Includes the Office Building Roof, Turbine Building Roof and All remaining outside areas within the protected area not analyzed under other existing fire areas/zones

23 OMA Initiating Fire Action NumerPurpose Fire Affected Component Ara.Actions Lcto 17 Ensure long-term V-1 1-34 RBFZDConnect H.P. air cylinder to drain port RB-FZ-1 B control of V-i 1-34 and of accumulator to recharge IC makeup --RB.:FZ-1 E1--_,

-ERB-FZ-1 F3, RB-FZ-1IF5, 7iEUR B-FZ!4IG, -.

O&3FZ.6A, OB3-FZ-8kATEz..

OB-FZ-8B, 0B-FZ-807,"

________OB-FA-9, CW-FA-1 4, YARD

24 OMA Initiating Fire Action Purpose Fire Affected Component Actions Number Area Location 18 To ensure long-term V-11-36 Connect H.P. air cylinder to drain port RB-FZ-1 B control of V-1 1-36 and of accumulator to recharge makeup to the -ýT-BmFA-26_,

Isolation Condensers.

TB-FZ-11B, TB-FZ-1 lC,

• TB-FZ--*l1D,Q TB7FZ-1 1E, TB-FZ_1 1 F, TB-FZ-1 1HA

Energy Sciences and Technology Deparl BRo-K6.AVEN NATION,*A"L LABORATORY Building 130 P.O. Box 5000 Upton, NY 11973-5000 Phone 631 344-7915 ks(c*bnl.qov managed by Brookhaven Science Associates for the U.S. Department of Energy www.bnl.gov Mr. Daniel Frumkin U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Risk Assessment, Fire Protection Branch (NRR/DRA / AFPB)

Washington, DC 20555-0001

Reference:

JCN No. J-4242, Task Order No. 1, Exelon Generation Company, Oyster Creek Nuclear Generating Station TAC No. ME0756. - Phase 1 Request - Use of OMAs Previously Approved In Fire Protection SERs.

Dear Mr. Frumkin:

By letters to the Nuclear Regulatory Commission (NRC) dated March 3, 2009, Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50, Section IlI.G, "Fire Protection of Safe Shutdown Capability," for Oyster Creek Nuclear Generating station to allow the use of manual actions for demonstrating compliance with Section III.G.2 of Appendix R, which, it asserts were previously approved in Fire Protection SER dated March 24, 1986, and June 25, 1990. In accordance with the scope of work described in Task 1 of Project J-4242, I have reviewed the technical merit of the request submitted by the licensee.

As described in the enclosure, based on the results of that review, I recommend that the requested exemption be granted. It should be noted, however, that confirmation of staff approval of operator manual actions (OMAs) described in the March 3, 2009 request, was beyond the scope of work performed by Brookhaven National Laboratory (BNL). This review assumed that all OMAs identified by the licensee (Exelon) as being previously approved in a Safety Evaluation Report (SER) were, in fact, accepted by the staff.

Per your request, the format and level of detail of this Technical Evaluation Report (TER) is similar to that used by the staff in its evaluation of Exelon Generating Company's exemption request to allow the use of operator manual actions (OMAs) at Peach Bottom Atomic Power Station Units 2 and 3 (TAC Nos. MD7029 AND MD7030).

If you have any questions, please contact me at the phone number or e-mail address indicated above.

Sincerely, Kenneth Sullivan, Systems Engineering and Safety Analysis Group cc: B. Grenier, NRC D. Diamond J. Higgins Project File J4242A, Task 1

ENCLOSURE EXELON GENERATION COMPANY, LLC, OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-2 19 EXEMPTION

1.0 BACKGROUND

VI' 1 The Exelon Generation Company, LLC (ExelOn, the licens~e~in addition to PSEG (E ci. icens*ee*i Nuclear, LLC) is the holder of Facility Operatingpilcense Nos. DPR-16;,%hich authorizes the operation of the Oyster Creek Nuclear GeneraifitgStation 0 CNGS). Tpl-,hlicense provides, among other things, that the facility is subject 't1@1,rules, regulatons, and8t*rders of the U.S.

Nuclear Regulatory Commission (NRC, the Commission) now or hereafter rihlffect.

The facility consists of a is alsihgle unit Mark 1,iqGeneral Electric (GE) 2, boiling water reactor (BWR) located in Ocean Couihty~lNew Jersey.

2.0 REQUEST/ACTION l 'Ii Title 10 of the C d.exf FederalRegulations (110!,) Part150 Section 50.48, requires that nuclear power plgricia iefor F1 ln**

• ,(,, fu 1979, satisfy the requirements of 10 CFR Part 50, Appeb'dix R, "Fre!Protection,*,*rog ram for Nuclear Power Facilities Operating Prior to January 1, 197w 9,'Section ý1, i ;G, "Fire protection of safe shutdown capability." OCNGS was licensed to operate prior-to Jaiyary,,1, 1974.'As such, the licensee's Fire Protection Program (FPP) Ustprovidtheiestablisýhledvel :'oprotection as intended by 10 CFR Part 50, Appenft1,Vn etp 3,y letter dated, March 3, 2009;'Request f&i Exemption from 10 CFR 50, Appendix R, Section III 3,,Fire Protectiton of Safe6,$hutdown Capability (Phase 1)" (Agencywide Documents Access and Mianagement Sy stem (ADAMS) " Accession No. ML090630132), Exelon requested an exemption'for the Oyster Creekl Nuclear Generating Station (OCNGS) to allow the use of operator manual actions (OMA)1,in ;lieu of meeting the requirements of Section III.G.2 of Appendix R to 1OCF1R50Q.

As described in Regiultory Issue Summary 2006-10, "Regulatory Expectations with Appendix R Paragraph I1l.Gý-'Operator Manual Actions," for plants licensed before January 1, 1979, an approved exemption is required for all operator manual actions (OMAs) used to achieve compliance with 10 CFR Part 50, Appendix R Section III.G.2, even those that were accepted in a previously-issued NRC Safety Evaluation Report (SER). Accordingly, the licensee is requesting that the NRC approve an exemption request to allow the use of manual actions for demonstrating compliance with Section III.G.2 of Appendix R, which, it asserts were previously approved in Fire Protection SER dated March 24, 1986, and June 25, 1990. These specific manual actions are addressed by Attachment 2 of the licensee's March 3, 2009, request (i.e.,

Phase 1).

In response to the staff's request for additional information, the licensee provided supplemental information dated April 2, 2010. In response to RAI-01.2, Exelon states that it has re-evaluated its exemption request, and, based on the results of this review, has withdrawn the following fire areas/zones from the request: RB-FZ-1 F2, RB-FZ-1 F4, RB-FZ-1 H, TB-FA-3B, OB-FZ-10B, TB-FZ-11A, TB-FZ-11G, AB-FA-13, DG-FA-15, NR-FA-20, OG-FA-21, OR-FA-19.

As a result, the scope of the licensee's Phase 1 exemption request is limited to a total of 13 specific OMAs that may result from fire in the following 22 fire areas/ zones: 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-3,, !jI-BLFA-26, TB-FZ-11B, TB-FZ-11C, TB-FZ-11D, TB-FZ-11E, TB-FZ-11F, TB-FZ-11HH an*Pl ARD. The 22 fire areas /zones and the thirteen specific OMAs to be performed in the evednftfire in each area are described below in Table 1. f ' II In summary, by letter dated March 3, 20091lal!and 001M% a supplementailetter

. Ii.E 1 dated April 2, 2010, responding to the NRC staffs request f:',liditional informationrxE~elon submitted a request for exemption from 10 CFR Part 50, Appendix -.:,/ R,Section I Ill.G, "irProtection I l of Safe Shutdown Capability," to permit the use of a total of1,3 openjor,r manual aibs (OMA) in the event of fire in 21 separate fire areas,/zones of the O.NG, q 3.0 DISCUSSION Pursuant to 10 CFR .

• 50.12,

.Pt VW the Cdommissionrmay,

'w*l . ".. upon application cI by any interested person or upon its own ji nitiati'lT, :grant exemptions e. requireiments of 10 CFR Part 50 when: (1) the exemptions are authorized by l Willii ot presj, an undue risk to public health or safety, and are consistent withth, commondetense and security; and (2) one of the special circumstances providedIiri-sub-paradraphs (i) through (vi) of 10 CFR 50.12(a) (2) is present.

ExelonHs"tates that it Hnadi.rgiriiallyiitendedti address the special circumstances proviaeiboth 1,0q0. (2) (ii) [undlriyng purpose of the rule] and 10 CFR 50.12(a)

(2) (iii)1i'firdue hardshiArlowev e, 2010 response to RAI-01.2, Exelon states that it no Ioner:cites 10 CFR 5012(a)(2)(i!i) [undue hardship] as a special circumstance under 10 CFR 50.12(4)(2). In its response, -xelxýi states that the combination of defense-in-depth and the feasibility'dfithe OMAs, demonstrates that the underlying purpose of the rule is met.

Consistent with the language inIcl ded in 10 CFR 50.12(a) (2) (ii).

In accordancewiith 10 0FR 50.48(b), nuclear power plants licensed before January 1, 1979, are required to meet Secuon IlI.G, of 10 CFR Part 50, Appendix R. The underlying purpose of 10 CFR Part 50'Appendix R, and Section III.G is to ensure that the ability to achieve and maintain safe shutdown is preserved following a fire event. The regulation intends for licensees to accomplish this by extending the concept of defense-in-depth to:

1) prevent fires from starting

2) rapidly detect, control, and extinguish promptly those fires that do occur

3) Provide protection for structures, systems, and components important to safety so that a fire that is not promptly extinguished by the fire suppression activities will not prevent the safe shutdown of the plant.

The stated purpose of 10 CFR Part 50, Appendix R, Section III.G.2 (III.G.2) is to ensure that one of the redundant trains necessary to achieve and maintain hot shutdown conditions remains free of fire damage in the event of a fire. III.G.2 requires one of the following means to ensure that a redundant train of safe shutdown cables and equipment is free of fire damage, where redundant trains are located in the same fire area outside of primary containment:

a. Separation of cables and equipment by a fire barrier having a 3-hour rating;

b. Separation of cables and equipment by a horizontal distance of more that 20 feet with no intervening combustibles or fire hazards and with fire detectors and an automatic fire suppression system installed in thefefearea; or

c. Enclosure of cables and equipment of onereldu'nidar nttrain in a fire barrier having a 1-hour rating and with fire detectors and an,aWt1mlatic firedfsuppression system installed in the fire area.

In its March 3, 2009 and April 4, 2010'tsýmittals, Exelon has requested an exemption from the requirements of III.G.2 for OCNGS to tlhextentthat one of the rdundant trains of systems necessary to achieve and maintain hot snutoown is'o maintainedTrdee of fire damage in accordance with one of the required means specifiedalab~oe for a fire occurr in the following 21 Fire Areas or Zones:

1. CW-FA-14 Circulatory'.vva ertiftake

2. OB-FA-9 ,,* :Office Buildin

3. OB-FZ-6A, A 480V SWGR Rm......

4. OB-FZ-6B 'ti , 480VWGR RmII

5. 0OBU......iaAor OB8 Rear ircuiation MGJSet Room

6. qbB-FZ-8B3 " Mechanical Equipment, Room (35' elevation)

7. CBLFZ-8C AMBBattery~*6oom, Tunnel and Electrical Tray Room

8. OB-FZ,-1 OA Mo~rnri and Change Room Area and Operations Support Area 10.

9. RB-FZ-1 RB-FZ-1biblE'it Readt&r Building elevation 51'-3".

10. RB-FZ-I E *ieactbr Building elevation 23'-6"

11. RB-FZ-1 F3 Reactor Building basement -19'-6" elevation (Northwest corner)

12. RB-FZ-1F5 Reactor Building basement -19'-6" elevation (Torus room - remaining area of Reactor

13. RB-FZ-1G Shutdown Cooling Room - north side of the Reactor Building (elevations 38' and 51'-3")

14. TB-FA-3A 4160V Emergency Switchgear 1C Vault - Turbine Building Mezzanine 23'-6" elevation - south side

15. TB-FA-26 125 VDC Battery Room 'C' - Turbine Building Mezzanine 23'-6"

elevation - south side

16. TB-FZ-11B Turbine Lube Oil Storage, Pumping & Purification Area - Turbine Building, elevations 0'-0", 27'-0, 36'-0, and 46-6"- north side

17. TB-FZ-11C 4160V Switchgear Room 1A and 1B -Turbine Building Mezzanine 23'-6" elevation - west side

18. TB-FZ-11D Turbine Building Basement Floor - elevation 3'-6" - south side

19. TB-FZ-11E Condenser Bay - Turbine Buildings elevation 0'-0"

20. TB-FZ-11F Feedwater Pump Room - Tutbin elloding Basement elevation 3'6" -

east side io

21. TB-FZ-11H Demineralizer Tank and $team Jet Air Ejec ir Area, Turbine Building 3'-6" and 23'-6" elev ioins - southeast side!

Exelon states that the OMAs identified in6its Phase 1 request 9 ýneyJiously found acceptable in fire protection safety evaluation ., * . .. repoht

. 1datedQfMarch II p, I ,* i,IP ' . 24, 986 andýJune 25, 1990, and, therefore, do not need to meetitheireliability criterialslppcified in NIUREG-1852, "Demonstrating the Feasibility and Reliabilityj of Operatohq1anual Actic ns in Response to Fire,"

dated October, 2007. Ihi IIii*,

Each OMA included in this revievo.n :66ftta sks that occur in various fire areas and zones idejnrii*ei1above. As 'ds OMAs are initiated upon confirmation of a firelik t Liparticularifire area'M ,9f the area of fire origin, the OMAs included in this*lqhase 1 review are as Area of Fire Originl{! IMAxctions a

CW-FA,, P*}*

1 ManualIy"open V-9-2099 and V 11 i9 and close V-1 1-63 and V-1 1-41

• M nu ll ,ttl ope VV-5-28.71. h.r1 e

' Manually open V-15-237,throttl~~te V-15-30 using local flow indicator (FI-225-2) iiband close V-15-52 OB-FA-9 L6da1y read Condensate Storage Tank level at LI-424-993 due to damage to controlicircuits.

Manually' open.V'l15-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V.iý52 OB-FZ-6A Locally read CST level at LI-424-993 due to damage to control circuits.

Use Remote Shutdown Panel to control equipment: RSP, CRD Hydraulic PP NC08B and 480V USS 1B2 Incoming breaker (Operate USS 1B2/CRD Transfer Switch (Partial initiation) to "Alternate" and operate Control Switches for USS-1 B2 Main Breaker and B CRD Pump).

Manually open V-15-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52

Area of Fire Actions Origin OB-FZ-6B Manually open V-9-2099 and V-1 1-49 and close V-1 1-63 and V-1 1-41 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 OB-FZ-8A Manually open V-9-2099 and V-1 1-49 and close V-1 1-63 and V-1 1-41 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 OB-FZ-8B Manually open V-9-2099 and V-11-49 and cqosV-'l 1-63 and V-11-41 Manually open V-1 5-237, throttle V-1 5-30,us*J*ilocal flow indicator (FI-225-2) and close V-15-52 OB-FZ-8C Locally read Condensate Storage TanklU )el at"L I-424-993 due to damage to control circuits. All .

Manually open V-9-2099 and VW,!,'49 and close V-11i-.3,and V-11-41 Use Local Shutdown Panels to co60ntrol equipment as f6liows: LSP-1A2, CRD Hydraulic PP NC08A and 480V WJSs 1A2 Incoming breakerl(©perate transfer switch "Alternate" and operate Contr'o .Switch!f6r USS-1A2 Main Breaker 1A2M and A CRD Pump). jjj, q* ,iH, Manually open V-154-23,!tlý rottle V-15-3*Oýisii'ng local flow indicator (FI-225-2) and close V-15-52 Trip all five Reactor Redirculati6nu uruips (NG'061!A, NG01-B, NG01-C, NG01D and NG01E ,,E),Also, lockoodijthe 41-60V,...yreakers lusing the 69 Switch

...... 1 -i 5-237, tlhttle V-1 5'30fusing lodliflow indicator (FI-225-2)

OB-FZ-IOA l!Vh' and c1o!se*V-1 5-52 h RB-FZ-ID Manda"Il*o°pen V-1154237' throti" K-15-30 using"'ibcal flow indicator (FI-225-2) and cloeV.i52 BRead CRD`I bal flovi gauge FI-225998.

.1FZ I,*EV-iM-a lly using local flow indicator (FI-225-2) and cilo eV-15-52'!!ý, ,!*t, RB-FZ RB-FZ-:I:

i3 Ope Open Coe'Spa CoreISpray Ih .";0NhII manual valves V-20-1 and V-20-2 and close V-20-4 RBFZIF6'"I ýWanually ope V-05-25711throttle V-15-30 using local flow indicator (FI-225-2) and close V-15-52 RB-FZ-1G ReadCRD local'flow gauge FI-225-998.

Mar*U'Ally open V.i15-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close.V-I 5-52:

TB-FA-3A Manually dope ,,* 1i5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close VZi1-52 Connect H.P. air cylinder to drain port of accumulator to recharge TB-FA-26 Manually trip 4160V 1 D Breakers and control USS 1 B2 and 1B3 480V Breakers locally at LSP-1D Manually control 1 B3M Breaker from LSP-1 B3.

Manually re-close MCC 1 B32 Feeder Breaker at USS 1 B3 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-15-52

Area of Fire Actions Origin TB-FZ-1 1B Manually trip 4160V 1D Breakers and control USS 1 B2 and 1 B3 480V Breakers locally at LSP-1 D Locally read Condensate Storage Tank level at LI-424-993 Manually control 1 B3M Breaker from LSP-1 B3.

Local Shutdown Panels used to control equipment as follows: LSP-1 B32 Condensate Transfer Pump 1-2 (Operate transfer switch to "Alternate" and operate Control Switch for Condensate Tranferl ump 1-2)

Manually re-close MCC 1 B32 Feeder Break.RRafUSS 1 B3 Manually open V-1 5-237, throttle V-1 5-30 16'y'i',"g'tlocal flow indicator (FI-225-2) and close V-15-52 .. 1 , "'11t4P!1 Trip all five Reactor Recirculation PiRudips (NG01-AIQNG01-B, NG01-C, NG01 D and NGO1E) Also, lockout the 4160V breakers usinrgthe 69 Switch TB-FZ-11C Manually trip 4160V 1D Breakersand control USS 1B2irad 1 B3 480V Breakers locally at LSP-1DD Manually control 1 B3M Breaker frorij"L*SP-1 B81.,

Manually re-close MC.01 B32 Feeder'B.reakqertt USS 1 B3 '4W' Manually open V-I 54,31throttle V-1 5-509-uusg local flow indicator (FI-225-2) and close V-1 5-52 TB-FZ-11D Manually trip 4160V 1D Breaker.4,,arnd contr6lIJSS 1B2 and 1 B3 480VBreakers locally at L DSI.

ManuallyL65..i.t.l J1B3M Bre*ker from'$SP!i*B.3. "

LocahShl' tdowri'.4nels are dUd t6dihtroi'blbipment as follows: LSP-DG2, EDG2:a-nd its Switchgear (Operate'transfer Switches (3 total) to "Alternate" and operate Conýtrol Switch on Dieselp.anel to start diesel)

Manually re-,osepM C(C1B32 Feede, Breaker at USS 1 B3

. M "a'rilly ope'HjV-15-237 throttle V- *4530 using local flow indicator (FI-225-2)

.*H!* and clo" e -i*-15 52ýV, TBFZI*E, ManuallyItbp4160VJ1TD Breaker's and control USS 1 B2 and 1B3 480V Breakers

" locally at LS*I-AD "111hb,,

jIýocally read C-6fidensat$,torage Tank level at LI-424-993

• lMjually contr6&IIiB3M Bredaker from LSP-1 B3.

Lzca ,lSh utdown tjanels used to control equipment as follows: LSP-1 B32 Condn isate Transfer Pump 1-2 (Operate transfer switch to "Alternate" and operat6 Vbntrdl'SWitch for Condensate Transfer Pump 1-2)

Local Shutdownri Panels are used to control equipment as follows: LSP-DG2, EDG2 and itsVwitchgear (Operate transfer Switches (3 total) to "Alternate" and operate Control Switch on Diesel Panel to start diesel)

Manually re-close MCC 1 B32 Feeder Breaker at USS 1 B3 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 Trip all five Reactor Recirculation Pumps (NG01-A, NG01-B, NG01-C, NG01D and NG01E) Also, lockout the 4160V breakers using the 69 Switch.

TB-FZ-1 1F Manually open V-9-2099 and V-1 1-49 and close V-1 1-63 and V-1 1-41 Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-1 5-52 T1z.:7.1 '1w , Manually open V-9-2099 and V-11-49 and close V-11-63 and V-11-41

7-Area of Fire Actions Origin Manually open V-1 5-237, throttle V-1 5-30 using local flow indicator (FI-225-2) and close V-15-52 Exelon states that the exemptions are being requested from the requirements of Section III.G.2 and are not part of a methodology to shutdown the plant from outside the control room.

The areas identified in the exemption requests have been consid6red III.G.2 since the initial Appendix R submittal. Each of the OMAs is taken to permit Ish utdown of the plant from the control room. The specific requirements of III.G.2 that areinotmet are identified for each of the requested exemptions in Attachment 1 of the licenseet~ spril 2'I"2010 response.

In response to RAI-01.1 Exelon states underlying purpose of the rule by accomplishii,

7) "thlrequested OiAj1.s are si~fiilar to activities performed by plant operators as par ofNthir normal WoIrk assignments

8) adherence to theprinciples of fire protection defense-in-depth.

9)

To address staff concerns regarding the adequacy of defense-in-depth provided for each of the fire areas / zones included in its requests, Exelon developed a Fire Hazards Analysis (FHA) which was included as Attachment 2 of its April 2, 2010 response. For each of the areas / zones included in the request, Exelon states that the fire protection configuration provided achieves a level of protection commensurate with that intended by Appendix R,Section III.G.2. For each fire area / 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 the March 3, 2009 request, the licensee outlined the approach that was taken to

evaluate and assess the effectiveness of the operator manual actions included in the request and explains where each operator manual action is located and the role of the actions in achieving safe shutdown. In its April 2, 2010 response to a Request for Additional Information the licensee provides a discussion and justification for why the operator manual actions are appropriate for maintaining consistency with the intent of Section III.G.2 of Appendix R. The NRC staff reviewed the licensee's evaluation in support of the subject exemption request for the use of operator manual actions in lieu of the requirements specified in Section III.G.2 of Appendix R, and concluded that given the existing fire protection features in the affected fire zones, Exelon continues to meet the underlying purpose of 10 .CFR Part 50, Appendix R, Section Ill.G.2 for the OCNGS fire areas described in Attachment 1 The following technical evaluation provides the basis for this conclusion. ,0 3.1 Fire Prevention '*6il, I"

In response to staff requests for additional;information Exelorideveloped a Fire Hazards Analysis (FHA) for each fire area / zone identifibdiin its exemption requestiy For each fire area /

zone, the FHA describes the physical location ancarrangement of equipmeri6f, combustible loading, ignition sources, fire protection features, an proximty of redundant safe, shutdown equipment to in situ hazards and identifies deviations from:flire protection codes and previously approved exemptions. In addition, fop eachfifre area/zon'ethe licensee's response includes a tabulation of potential ignition sources as well-asjthe equi pmnt that may exhibit high energy arcing faults. For each fire area / zone, the FHA~states that the fire protection configuration J"ý1,

',I iillp,ý '` 1,. . Ill"llli',0,.

achieves a level of protectioncommensurate with tht intended bylAppendix R,Section III.G.2 All 21 areas /,'z1ones identified in the requestihave lmited;or low combustble fuel loading (equivalent fire seveas OB-f

! less hand miutes)iexcept areas OB-FZ-6A, OB-FZ-6B, and TB-FZ-1 1 B. Fire areas OB-F!6A andB-FZ-61B have low to moderate combustible fuel loading (equivalent fire jseverity of lesthan 105minutes)and TB-FZ-1 1B has a high combustible fuel loading (elvalent~fire seventyilof greater, r.inutes).

tlba,105 Areas with moderate or greater fuel loading have adequate detect16n and supir~sston systems appropriate for the hazard.

Thei6ttrie areas included in the exemption are not shop areas so hot work activities are infrequent witl'Mradministrative controls (e"g.j, hot work permits, fire watch, and supervisory controls) programrs, in place if Iotwork activities do occur. The administrative controls are described in the OCNGS Fire Protction Program (FPP), which is incorporated into the Updated Final Safety Analysis port. l Unless noted oth i:d'below, all of the fire areas included in this exemption have a combustible fuel load that is considered to be low with fuel sources consisting primarily of fire retardant cable insulation and limited floor based combustibles. Unless noted otherwise, there are no high energy ignition sources located in the areas and the areas.

Fire Area Combustible Loading CW-FA-14 Fire Area CW-FA-14 is an outdoor structure with no walls or ceiling. This fire area consists of a structure that is remote from the power block and other outdoor equipment (e.g., main transformers, etc.) that is open to the environment.

Combustible loading consists of transformer liquid and electrical motors although it is not quantified because there is nothing to cofitain the heat release in the event of a fire.. The main combustible in this area thlht could result in the need for the OMAs is Dow Corning 561 Silicon transformer lihquid:,The licensee states that the transformer liquid has characteristics that minimi lethe ilikelihood of a fire involving the insulating liq u id itse lf .1-1 A

-111111

• . . oill ;1111' 41 M)il tl ,

OB-FA-9 This area has an administrativeifire loading limit ofiess than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> as determined by the ASTM El 19 time-temperature curve. The major combustibles in the MUX Corridor are cable insulationand a wood ceiling on top~ofthe MUX enclosure.

OB-FZ-6A Fire loading in thisnfire zone is modernate" 1is area has an a~dnnistrative fire loadig L.~rI,;*,o r as er, i, e b th limit of less than th'eeh-lours as determired by the ASTM El 19 time-temperature curve. The main combustibles in this areaware cable insulation (approximately 81%

of ofloading) loa ing and an Dowiornign561 E* 1 11 1 S transformer iý..... liquid (approximately 15% of loading). The transfor~lfr hquldl as~characterstics that minimize the likelihood of a fire involv.rTg the insulating hIquid ,tselfh IlPI OB-FZ-6B Fiiqe1 loading inI t~hs fire zoneiis4,moderate. FirpeZone OB-FZ-6B floor area is approximately 679 sq. ft. Thisa"ea has an administrative fire loading limit of less than twoihours as determined the ASTM E119 time-temperature curve. The main Scombustiblls tinsilarea are cad(le insulation (approximately 28% of loading),

,, . (aproximately,29°lo 'loading) lmo-Lag and Dow Corning 561 Silicon transfo.mer liquid(approximately 31% of loading). The transformer liquid has charactdristics that 'minimize the likelihood of a fire involving the insulating liquid itself OB-FZ-8A i, Fire Zones' OB-FZ-8Aan*d 8B are evaluated together for the combustible loading and "Kf: FSSD analynis, These fire zones have an administrative fire loading limit of less OB-FZ-8B than M'fj~ij 45 minutes

. .ElO,. as determined by the .. ASTM El 19 time-temperature curve. There are:,1 ery miqirmal combustibles in Fire Zone OB-FZ-8B. The major combustibles in Fire* Zonee.OBFZ-8A

' :,ý}1 i! are lubricating oil (approximately 83% of loading) and cable insula ion (,approximately 13% of loading).

OB-FZ-8C This area has an administrative fire loading limit of less than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> as determined by the ASTM El 19 time-temperature curve. The main combustibles in this area are the plastic battery cases and racks (approximately 56% of loading) and cable insulation (approximately 39% of loading).

OB-FZ-10A This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. This limit is tied to an NRC-accepted approach for dealing with fire zone boundaries (refer to the response to RAI-04.3 in Attachment 1 for more details). 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

Fire Area Combustible Loading Clothing (PC) supplies (approximately 20% of loading). However, since the PCs have been placed in metal cans with self-closing lids they are no longer considered a contribution to the combustibles in this area.

RB-FZ-1 D This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The main combustible in this area is attributed to cable insulation (approximately 84% of loading).

RB-FZ-1 E This area has an administrative fire loadi;g limit of less than 30 minutes as determined by the ASTM El 19 time-tempe.ature curve. The main combustible in this area is attributed to cable insula fiin*aF pioximately 84% of loading).

RB-FZ-1F3 This area has an administrativefied loading limittofless than 30 minutes as determined by the ASTM E'11,9itime-temperature curve. The major combustibles in this area are cable insulatiohn,(approximately 58% of Wading), ladders (approximately 16% of loadin)garnd lubricating oil in pump s.(approximately 16% of load ring). ,i 'ti~lll ' 1,t 1i11,'

1i;11' RBF- Thisf" F5ýare hasrxiatla6 av of RB-FZ-1 F5 This area has an anafliirative fire loading limit of less than 30 minutes as determined by the ASIojEp1,19 time-tem, erature curve. The major combustibles in this area are cable insulatiool(approximately 19% of loading) and gratings (approximately 76% of loading) Mhegrating lich is the largest plastic material in this 4arahs a flame spread of ledsstlian 25.

RB-FZ-G hisra nas astratiire loading limit of less than 30 minutes as determined by tc ASTM Elll,*time-temperature curve. The main combustibles in this arearre cable'iinsulation ('approximately 12% of loading), plastic (approximately

-15,7. of Ioading.,, .d Ss A..combustibles (approximately 14% of loading). The Orafng, whillII .the majorityof.tthe~plastic material in this area, has a flame spread

, ethan 25i TB-FA-M3A This area flds an admdinistrative fire loading limit of less than 30 minutes as determined U',the ASTKM El19 time-temperature curve. There are minimal amounts Iof cable insulation (approximately 5% of loading) miscellaneous plastic a,73o of loading) and class A combustibles such as paper for procedures (ap Iroxmately 20% of loading) in this area.

TB-FA-26 This areatrequires an administrative fire loading limit of less than 90 minutes as determined by the ASTM El 19 time-temperature curve. The major combustibles in this area are plastic, which is contributed by the battery cases (approximately 92%

of loading) and cable insulation (approximately 6% of loading).

TB-FZ-1 1B This fire zone has administrative controls such that additional combustible materials are not introduced into this zone and defense-in-depth features to control a potential oil fire in this zone The major combustibles in this area are lubricating oil (approximately 99% of loading) and cable insulation (approximately 0.3% of loading). The amount of oil contained in the lube oil storage tanks in this fire zone drives the combustible loading in this fire zone to approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

Fire Area Combustible Loading TB-FZ-1 1C This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The main combustible loading is attributed to cable insulation (approximately 73% of loading) and plastic (approximately 17% of loading).

TB-FZ-1 1D This area has an administrative fire loading limit of less than 30 minutes as determined by the ASTM El 19 time-temperature curve. The major combustibles in this area are cable insulation (approximat4 l.[9% of loading), Dow Corning 561 Silicon transformer liquid (approximately 1l,!% of loading) and lubricating oil (approximately 40% of loading). , II ,

TB-FZ-1 1E This Fire Zone (Condenser Bay) *isprocedurally controlled as a transient combustible free area in procedure OP-AA-201-009 while the' plant is operating. This area is a high radiation area during pilt operation and is no liIbrmally accessed. The area has an administrative fire Ioading limit of less than 30 mlriutes as determined by the ASTM E119 time-temperature curve. The major combustibles in this area are cable insulation (approximately 40% of 1oaiingg)1and plastic (approximately 59% of loading). The gratin4,?wlich is the laWrgeasplastic material in this area, is dispersed throughout this fire zbne6I(not concentrk'd) and has a flame spread of less than 25.

TB-FZ-1 1F This area has an administrative fire loading n1 t of less than 30 minutes as determied by the AS'I',ME119 timeteperatur~eicurve. The major combustible load consists oTf cable insulationh(approkxmately-,)°5% of loading), lubricating oil (aplpoxýmately39% of loadihg), rubber (approximately 21% of loading) and plastics (a*rbximately 17% of loadinhg)iThe licensee states that the majority of the

,,111gl combustible ghi

• w Ioadingattributedlto' h are61rr.ow,;n6_"Al ongerg.l the area. rubber and plastic was due to the storage of hoses TB F11?* 511..

• MmEýi ri .,I ? 11i *,

FT Tie 0fire loading lmit of less than 30 minutes as deterrmPd by the .ASTM El 19 time-temperature curve. The major combustibles are cablih sul atio (approximately 23% of loading), ladders and other miscellaneodUs plastics6('approximately 55% of loading) and miscellaneous ordinary

• jcombustibles!l'M.

The NRC staff fistfor all of the areas related to this exemption, the level of fire protection combined with thelimited fuel load and minimal ignition sources in the fire areas associated with this exemption results in a low likelihood of a fire occurring and spreading to adjacent fire areas or equipment.

3.2 Detection, Control and Extinguishment OCNGS has been divided into fire areas and subdivided into fire zones, as described in the OCNGS FPP. Three-hour fire barriers are normally used to provide fire resistive separation between adjacent fire areas. Subdivision of fire areas into fire zones utilizes non fire rated boundaries. In general, fire rated assemblies consist of reinforced concrete or concrete block walls which have commonly accepted fire endurance ratings

based upon thickness. For the purposes of analysis, subdivision of fire areas into fire zones takes into consideration the physical boundaries which exist between one fire zone and another within the same fire area.

The NRC staff evaluated the fire detection, control and suppression systems associated with the areas related to this exemption. Unless noted otherwise below, fire areas are provided with ionization smoke detectors in various locations within a particular fire area.

Fire Area Detection, Control and Extinguishment Capability CW-FA-14 This fire area consists of a structure thati"I'r0iote from the power block and other outdoor equipment (e.g., main transformers, etc.) that is open to the environment.

There is no fire detection or fixed firesu6ppr$ession systems in this fire area.

However, a security tower monitorsthi s area.lnetinuously; therefore, any fire of significance would be detected-and responded~tolappropriately by the station fire brigade.Manual suppressionil's provided by a fire hRant and fire hose house located approximately 75 feetý from the principal fire hazards, USS 1B3 and associated transformer.. III,,h, OB-FA-9 Detection of a fire in the MUX cOdeidor ab6Ve the MUX enclosure would be by the installed suppressib, system in that re. detection in the remaining portion of the area would be by the istalled detectioln, in the main hallways and inside of the MUX room enclosure or bylpersonnel since issa high traffic area. Extinguishment of a fire in the majority of this arealWillý,be accomplipshed by the plant fire brigade.

OB-FZ-6A This areais, protected ',automf .i"*detectioh',V,6totalflooding Halon 1301 System, and.manu .lfirefighting tapabilities i able etiguishers and hose stations)

OB-FZ-6B This'anua isler.f6cted by 6tom`ti'"`detd8ti6hi~a total flooding Halon 1301 System, andhm.anual firelf.!!ghting capiabiities (portable extinguishers and hose stations)

OB-FZ-8A OB-FZ,'8A, is pr6krided with a ý'batial area coverage closed head automatic sprinkler OBFsy8~ 1 ~stem ir sta**llt~r ~o~utglh Jority of this fire zone (over MG Sets). An alarm is Me o Co t orboom whentwater flows from a single sprinkler head. A smo'e, eecri, ItwI exhaust duct of the ventilation system. SER dated

'June un provided an e meption for not having automatic fire detection. A new fire detection sysite ' as been installed in the Mechanical Equipment Room (Fire Zone OB-F,'-8 B-35' 6lation) and the adjacent corridor where the fire alarm panel IIH(LFAP #8)[ staled ocal Fire Alarm Panel (LEAP) #8 was expanded to provide smoke detection capability for these two rooms. Fire extinguishers are provided for manp~ial fire fighting backup. Hose lines are available from outside hydrants and hoseIO 1ýfous.es...1 OB-FZ-8C A fixea t 'Iiflooding,Halon 1301 extinguishing system will discharge throughout the area. Smoke detectors are 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.

OB-FZ-10A A closed head automatic sprinkler system is throughout the area. In addition, a hose station located nearby outside the Control Room provides manual suppression capability.

RB-FZ-1 D Area-wide smoke detection system and automatic a 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

Fire Area Detection, Control and Extinguishment Capability in each original safety related cable tray as was committed to in the comparison to BTP 9.5-1, Appendix A, and intelligent smoke detectors are located in each beam pocket at the ceiling.

RB-FZ-1 E Area-wide smoke detection system and automatic a 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 as Was committed to in the comparison to BTP 9.5-1, Appendix A, and intelligent sinike detectors are located in each beam pocket at the ceiling. 41111111,11 RB-FZ-1F3 Smoke detectors which alarm local*.aip~te control room are installed over hazards (located in the vicinity oftleýý3 e Qaardsh are not located at the ceiling).

Fire extinguishers are provid ed fbr manual fire fighting backup. Hose lines are

____________available from outside hydranti{and hose h ue' I~I RB-FZ-1 F5 Due to the negligible comb'ditible loading and the rH*tre of the combustibles A fire in this zone is not expected t:b'ýe, of significant size or durcation. Extinguishment will be accomplished by the plant fire brigadeiqA111h RB-FZ-1G Due to the negligible combustible6adr,iand the nature of'tH" combustibles A fire in this zone is no[expe'ited to be of significant size or duration. Extinguishment will be accomplished byth e alnt~fire brigade.k,.

TB-FA-3A A manually. actuated'

.. . {tNm sy2"tem design681fo.,achieve l, . 11,i , a 50% concentration which is maintained for a minimum of sevenIminutes wasapproved in SER dated March 3, TB-FA-26 Arj ide ab2....atic preactionp4 ikleir6'0tection Area-wide smoke detection.

TB-FZ- 118 D~t~ction and *'d~pression systems are insf*lled to protect against the lube oil hazardtin*athe rea Automatic suppression over principal combustibles A Closed head altuomagti sprinkier systei ýprotects cable trays and open head water spray

.,mi,*,, "'*ug esstemiprotects,;, i~ihand*lingi equipment and the oil storage tank. Thermal

....teors are located in ell:pro~imity to the lube oil tank so that a lube oil fire would equickly detected, which in turn would activate the deluge system for

_____________ exinguiS~~ment.

TB-FZ-11C K Area-wide6automatic fixed preaction sprinkler system (except for the small caged

____i_ ':area located wi the east 'of Fire Area TB-FA-3A)

TB-FZ-1'1 D 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 lruIementsWof Appendix R Section III.G.2 in SERs dated March 24, 1986 and June 25,1i 9e9 f,!rit having area-wide automatic fire detection and suppression system in Fire Zonie TB-FZ-1 1D. The primary basis for this exemption is the presence of the automatic wet pipe sprinkler system, low fire loading and the one-hour barrier protection for safe shutdown circuits. Also, the flow alarm will notify the control room of any sprinkler system activation. Since TB-FZ-1 1E The Condenser Bay is procedurally controlled as a transient combustible free area in procedure OP-AA-201-009 while the plant is operating. Extinguishment of the will be accomplished by 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 An exemption was granted from the requirements of Appendix R,Section III.G.2 in SERs dated March 24, 1986 and June 25, 1990 for not having a fixed fire

Fire Area Detection, Control and Extinguishment Capability detection system in this area. The primary basis for this exemption is the presence of the automatic wet pipe sprinkler system and low fire loading.

TB-FZ-1 1F A new area-wide fire detection system (thermal detection) has recently been installed. Extinguishment of the will be accomplished by the plant fire brigade TB-FZ-1 1H A new fire detector (thermal detection) has recently been installed in the stairwell area. The system alarms locally and in the control room. Manual extinguishment of fire will be accomplished by the plant fire brigade All fire areas included in this exemption have automatic deietion systems installed except Fire Zones TB-FZ-11 D, TB-FZ-11 E, CW-FA-14, and the YarArea.,j, ex~ ~ ~TP

• t mi u, 'lll For Fire Zone TB-FZ-1 1D, an exemption wagranted fro,,,the requirements of Appendix R Section Ill.G.2 in SERs dated March 24, 1986Pa1d1 June 25, 1990:fo not having area-wide automatic fire detection and suppression systC" .1The primary basis for*this exemption is the presence of the automatic wet pipe sprinkler system low fire loading and thbe one-hour barrier protection for safe shutdown circuits. Also, the flow'alarm wilflnoitify the controlkroom of any sprinkler system activation. Since a fir~e,in this area w6,ldjpl'iýmpede the plarn' 1capability for safe shutdown, this exemption does~'0noirmpact the basis for the manual exemption request.

The lack of a fixed fire detectii Fire Zori i:B-FZ-11 E was addressed by the staff in an exemption granted by t sldated March 24 1986 and June 25, 1990.

The primary basis for this;exempion ilof thNautortit wet pipe sprinkler system and low fire loading.,,ice a firelinth lot impelethe plant's capability for safe shutdown, this exemption does not lj, 'for the ma'nal exemption request.

Fire Area CW-FA-14, Circltior!y.Water Intake, is an outside area greater than 100 feet from any ~bul exep for the pool enclosure which is constructed of non-0ishsmle combustiblernmateriaIlPThe lack ,of~automatic.detection is compensated for by continuous monitdring, of the area by.secuniytpersonnel lo6cae in a nearby tower. The licensee further

)

states tliatlumerous indicoalis andisymptoms would remain available in the Control Room to ensure that t*bneed to perforimithe requested OMAs would be readily diagnosed.

Automatibc!fite detection'systems are also not installed in outside locations classified as the Yard Area. However, sinceftIe area is under constant observation both by humans and electronic devices (cameras), a fire would be detected and appropriate actions taken without significant delay.

Fire areas OB-FA-9, OB-FZ-8A, RB-FZ-1 F3, TB-FZ-1 1B, and TB-FZ-1 I H have partial area detection systems installed to address specific fire hazards. Fire Area OB-FA-9 consists of three floors of the Office Building. Detection which alarms locally and in the control room is provided in the main hallways and inside of a small area known as the MUX room enclosure.

The licensee states that the majority of this fire area is normally traveled since it is the main path to the control room. However, the MUX corridor, which is adjacent to the south wall of the control room, is not a normally traveled area. Detection of a fire in the MUX corridor would be by the installed suppression system.

In Fire Area TB-FZ-1 1 B, detection and suppression systems are installed to protect against the lube oil hazard in the area. Automatic detection is provided by a rate of rise/fixed

temperature fire detection system at the lube oil tank. Locating the detectors in close proximity to tank provides for prompt detection of an oil fire, which in turn activates a deluge suppression system for extinguishment.

There is no area-wide detection system provided for Fire Zone OB-FZ-8A. Detection within OB-FZ-8A consists of a duct smoke detector located in the exhaust duct of fan EF-1-20.

An exemption was granted from the requirements of Appendix R, Section Ill.G.2, for not providing area detection in this area. This exemption was approved in the NRC SER dated June 25, 1990 based on the fact that any fire which might occur in Fire Zone OB-FZ-8A will be relatively small and will be controlled by the automatic sprink.rn system. Since operation of the sprinkler system will alarm in the control room, prompt notif'ica"ti'on of and response by, the fire brigade for any required manual fire fighting activities is, x' ected. In addition, OB-FZ-8A is ac~ti*vii*esi *lsdi1 analyzed together with OB-FZ-8B for combustible Ioa2,ng and *safe shutdown purposes and area-wide detection is provided in Fire Zone OB-FZ_8B which alarms locally and in the control room.

The detection capability provided for RBTZ-1 F3 consists of smokeidetectors which alarm locally and in the control room, that are locatedin 41!*', closhl,,xoximity to thehazard (i.e., over 4 *I . .t lhýI fill pumps and cable tray. Since they areinot mounted at~the ceiling this is a deviation from NFPA 72E, 1974 Edition. The licensee states tlat an evaluationof'this devaton has determined that

• glnll~iitlN* A6+t!*

positioning the detectors closer to the .lfazaridirnmproves t h1aietectors' responsiveness to the major hazards in the area. 11,11h ftih 41111, Fire Zone TB-FZ-*fII'also lacks area-wnde detection coverage, For a fire in this fire zone the licensee state~sithat the ,"W' train ofpowerlistcredit!@,and available since they are located outside of thisfire zone. However, thefelatwo "B" Ttain 125 VDC control power cables associated withtnon-protected train routed in conduits which traverse through the stairway area of this zoneiatappr omately elevat*in 10'. An OMA for utilizing fire water would Sron aaffected byf ldto to installing a new fire detector in the stairwellarea ne r-itese conduits the licensee states that no ignition sources are located in the opl f the Zoneý th&conduits e are roufted.

Firedareas OB-FZ-6A" OB-FZ-8C,1 OB-FZ-10A TB-FA-3A, TB-FA-26, TB-FZ-11B TB-FZ-11 C, TB-FZ-l11D and TB-FZ-1 A 1Ehave area wide fire suppression systems installed to mitigate the specific fire hazards located ithe area. Fire Areas OB-FZ-6A, the B Train Switchgear Portion of OB-FZ-64iand OB-FZ*8C are provided with total flooding Automatic Halon 1301 Systems. TB-FA-3A providedl.Vith a manually actuated, total flooding, 002 system. OB-FZ-10A, TB-FA-26, TB-FZ-1 1 -BT1B-Fz-1C TB-FZ-11D and TB-FZ-11E have automatic sprinklers.

Fire Areas OB-FA-9, OB-FZ-8A, RB-FZ-1 D, RB-FZ-1 E have partial coverage suppression to suppress fires that may occur due to the specific hazard. Fire Area OB-FA-9 has closed head sprinkler systems that provide coverage of the MUX room corridor over the MUX enclosure and the MUX Enclosure. In addition, fire extinguishers and hose stations are provided for manual fire fighting. Fire Area OB-FZ-8A has partial automatic wet pipe sprinklers.

An alarm will sound in the control room when the automatic fire suppression system operates.

Fire loading in this fire zone is low, consisting primarily of lubricating oil and cable insulation.

Safety related cable trays in Fire Zones RB-FZ-1 D and RB-FZ-1 E are protected by automatic fixed deluge water spray systems which are automatically activated by cross-zoned detection systems.

Fire Areas CW-FA-1 4, OB-FZ-8B, RB-FZ-1 F3, RB-FZ-1 F5, RB-FZ-1 G, TB-FZ-1 1H and the Yard are protected by manual fire fighting capabilities.

Fire Area CW-FA-14 is an outdoor structure that is remote from the power block and other outdoor equipment (e.g., main transformers, etc.). Since the area is continuously monitored by security personnel located in a nearby tower, prompt notification of the station fire brigade is assured.

Fire Zone OB-FZ-8B has a small floor area (approximately 479 sq. ft) and the combustibles located in this Zone are very minimal. The maj6hjcd3mbustibles in Fire Zone OB-FZ-8A are lubricating oil (approximately 83% of loading) arind pble insulation (approximately 13% of loading). There are no components or cables thatiillJ ause the loss of the "B" Train of Power in Fire Zone OB-FZ-8B. This area is accessed only through, a single locked door with a vital access door lock so access into the room is restiicted. Therl:aree no credible ignition sources in this room that would impact the creditedcables located in~ondut in the room below.

kj Manual fire suppression consists of portable fire' extinguishers with hoel 'stations for backup.

"111 111 Fire Zone RB-FZ-1 F3 floor area is also smali(approýiately 560 sqnJhe major combustibles in this area are cable insulation (approxphately ,% of 5oadig), laTders (approximately 16% of loading) andjlubricating oil in pumpsapproximately 16%'of loading). The fire loading in Fire Zones RB-FZ-1F3 ani'IkB.-FZ-1F5 is defined as "low" in the FHAR. Fixed combustibles are limited to molded fiber glass 'reiforced polyester grating and minor amounts of lube oil in the various pumps. Manual fiireluppressio.consists ofportable fire extinguishers with hose stations for backup4. jln a SafetyElaluationidated Junet25' 1990 the staff approved an exemption for not havfnwarea* ie automatclcf re..sUpresstýinin fire zone RB-FZ-1 F based on the low combustible loding t fire detection would alert the fire brigade to the onset of a fire in the zni*so that Irmpt manu'a'l suppression of any fire could be accomplished.

FiZ)9sRBqFZ. ft. The main combustibles in this area are cableltisaon 2approxmatel oflb g), plastic grating (approximately 57% of loadingI!ad Class A ombustible (approxim iiate14% of loading). Manual fire suppression consist,, portable fire exfinguishl §Wth hose stations for backup.

Th 'bjr, comb (apprximateyi55% filoadng) an The mqi, are cable insulation (approximately 23% of loading), laddersihd other misddIlaneous plastics (approximately 55% of loading) and miscellaneous ordi ycombustibies. The fire loading is "low" as defined in the FHAR. No fire safe shutdown equipmeht is lodated in this area but there are two "B" Train 125 VDC control power cables (non-protet~d4 itih) that traverse through the stairway area of this zone at approximately elevation 10lft.lManual fire suppression consists of portable fire extinguishers with hose stations for backup.

The Yard Area is located outside. Combustible loading is spread throughout the yard but is not quantified because there is nothing to contain the heat release in the event of a fire. Significant hazards in this area (e.g., SBO transformer) are protected by a suppression system. In addition, The Yard Area is in constant observation both by humans and electronic devices (cameras), so that if a fire would occur, it would be detected and appropriate actions taken without significant delay. Manual suppression is provided by a hose station from the office building and by fire hydrants located throughout the yard area.

The NRC staff finds that the fire barriers, fire detection, control and suppression systems

are adequate to mitigate and contain the fire hazards in the 22 areas identified in the licensee's request.

3.3 Preservation of Safe Shutdown Capability The NRC staff has evaluated the feasibility review provided by the licensee in the April 2, 2010, Response to Request for Additional Information. The feasibility review documents that procedures are in place, in the form of fire response procedute~so ensure that clear and accessible instructions on how to perform the manual actionslare available to the operators. All of the requested OMAs are directed by plant procedur es,vanatope.operators are trained in the use of the procedures. Specifically, procedure ABNI2 Plant F ', is entered whenever a fire or indication of a fire occurs on the main fire alarm (inel in the control '1 room om or oa at any local fire in thcWo alarm panel. In addition to dispatching a radio-*quipped operator toititie alarming location, ABN-29 also directs that the fire brigade be dispatc 'wheneveuppresson system has actuated (sprinkler, deluge, Halon, C02) or a firle'lis confirmed. In additi'lonYMABN-29 directs immediate entry into the Fire Support Procedure (FSPr) for the!affected fire ar*a as soon as the existence of a fire is confirmed. Theilicensee states that teJ.oIlowing indications'or symptoms are considered examples of a confirmed fire'

• Fire detection alarm arn equLip'ent malfunc ion indication or alarms within the sam e area; Q511ho, I

• Fire pump, staand either srjinkler Io, larm or doiuge flow alarm;

• Gaseous tspplesslon systemI ctuationi .

• RepotCritom FI the fiel1 tof anfollowactualfir F "ire actualtsmoke cor actual fire condition condition.

• Fire detection alarm follow upiconfirmation

• v.,ith by field operator.

Entering the FSP means Itotq1." * ":l"*i lthat the~operatoriWill t, * *,, ea}iareview l the o ioFSP, identify equipment that could be a eqiitnthati wll,be available, monitor plant equipment from the contro Irhrthe and cbntnunicateMwth the fire brigade leader. Based on the symptoms received in the conrtrol room and the'e"" I- edbalf~rom the fir'e itrade leader, the operator will decide using the proce*dUre what mitigatir actionsare necessary. In the event that a plant shutdown has occurred Iggfde the FSP is entered, theloperator will still enter the FSP based on the fire and initiate the OI,-,4,*as appropnate- OMs'h'idt are considered "prompt" (i.e., those that must be done within 45 Mi ntes or less) ar identified in both ABN-29 and in the applicable Fire Support Procedures as an item,,,,requiringin

,, . ... J ,*l imediate attention. The operators are trained to perform prompt actions first anarprioritihem based upon existing plant conditions. The FSPs are based on the worst-casteossicpf siderations by assuming all fire damage occurs instantaneously and thus a II :perator manual actions will be required. The use of the Emergency Operating Procedures (EOPs) in conjunction with the applicable FSPs will permit the use of any mitigating system available first, and if a desired system is not available, the FSP provides a contingency action to restore the system or provide another means to perform the function. Operator training, including simulator demonstrations and plant walk downs, has been performed to ensure consistency in operator and team response for each OMA.

Several potential environmental concerns are also evaluated, 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 operator manual actions were feasible because 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. An action is considered feasible if it is shown that it is possible to be performed within the available time (considering relevant uncertainties in estimating the time available). The licensee states that OMAs required for achieving and maintaining hot shutdown conditions are feasible, and 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 equipment needed to implement OMAs remains available and the fire areas remain accessible during or following the event.

An operator may need to re-enter Fire Zone RB-FZ IE1to manually manipulate three 2-inch CRD System valves V-15-237, V-15-30 and V-15-52ftl6'aare physically located within four feet of each other within the spray area of the automati¢61lbcalized fixed water spray deluge system installed in this fire zone. An exemption was g'rrated in SER dated June 25, 1990 for not providing either additional separation from in ,s'Jbombustible~trlrprotection,for CRD System valve V-1 5-30. Valves V-1 5-237, V-1 55261'd H V-i V-15-0 44kreý within four feet of 5-30 are p"hyically each other; therefore, the technical basis of tl9Iexemption is considerdi~t bbe equally valid for these two additional valves. In addition, the licensee states that the actioriscan be performed in 15 minutes and there are 204 minutes available between t,elsialrt of the t when the actions need to occur to restore CRl~flow. ,,,

IT,111 oi~lllilll'" *wI~i h For each of the fire areas includ*d 'inljiis exemptionYithe postulated fire scenarios and pertinent details are summarized in Talle M e*,'oz%111111h The NRC staff revieWed. the requir operatorý manual actioh'pompletion time limits versus the time before',kiý'tIacton becomes nritical to§afely"!hutti down the unit as presented sthioes In onietfdse te actimust be completed within 30 minutes. This action is identified a, Phasd' #16 and requires an operator to manually trip the Reactor

'1it il-M Recirculation Pumps 'A,"0B' "C,'"D" and "E- atithe 416oV Switchgear 1A and lB. The action may be required ias a resultofifir6eiriOB-FZ,-8C, TB-;FZ-1 IB, or TB-FZ-1 1E. The symptom for this actioriilthe inibility to tritle RecircultiroqPdumbps from the control room and this is detect u ing the associated pI*upreaker iidicating lights, alarms and flow indications. The Fire Support Procedures direct the'opprator to trip the pumps using the pump control switches or the Recirculation Pump T"ri~pcircuitfi(two trip coils for pumps). If both of these methods fail on one or more pumps, the guidance is g"yen to trip the pumps from the 4160V Switchgear 1A and 1 B located oLutside the control room in Fire AreaTB-FZ-l 1C. Only one operator would be required and it would take apprc xiately 13 minutes for access to the area and to perform the action of tripping the breakers ,41'en the low complexity of this action, the! \IRC staff finds that there is a sufficient a'6ynot ofi.i'md6 available to complete the proposed operator manual actions.

3.4 Evaluation As stated in 10 CFR Part 50, Appendix R, and Section 1/: The fire protection program shall extend the concept of defense-in-depth to fire protection with the following objectives:

1. To prevent fires from starting,

2. To detect rapidly, control, and extinguish promptly those fires that do occur, and

3. To 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 NRC staff has evaluated the elements of defense-in-depth used for fire protection at OCNGS, applicable to the fire zones under review. Based upon consideration of the limited fire ignition sources and fire hazards in the affected areas, and the existing fire protection measures at OCNGS, the NRC staff concludes that objective one of defense-in-depth is adequately met.

Based on the evaluation of fire detection and suppression systems provided in the affected fire zones, the NRC staff determined that any postulated fire is expected to be promptly detected by the fire detection systems in the associated fire are$s. The available fire detection and suppression equipment in these fire areas ensure that a postulated fire will not be left unchallenged. In addition, all fire areas are separated from adjacent fire areas by suitable fire-rated barriers to provide a level of compartmentalizationii between the fire areas and/or buildings.

This compartmentalization helps to ensure that fires will. not spread: to adjacent fire areas and that any fire damage will be limited to the fire area%bof 6rigin. In addition, when fires are contained in the fire area of origin, the licensee has demonstrated that the manul iactions are feasible.

Therefore, the NRC staff concludes that objectives 2 and 3 of defense-in-depth i. are adequately m et .

Therefore, the NRC staff concludes that the rquested exemption to use operator manual actions in lieu of the requirements of 10 CFR Part 50, Appendix R, Section IIl.G.2 is consistent with the defense-in-depth metho6do00gy necessar 'at nuclear power plants and will not impact OCNGS post-fire safe-shutdown capability.

3.5 Authorized By Law, This exemption would alIow OCNGS theý use, of operatornmanual actions in lieu of meeting the requirements specified in 10 CFR Part 50, Appendix R, and Section III.G.2. 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 determ ined that graInting of the licensee's proposed exemption will not resulti~n a violation of the:Atomic Energy Act of 1954, as amended, or the Commission's regulation**sbecause special circumstances exist that warrant the use of the operator manual actions 1to achieve safe shutdown. Therefore, the exemption is authorized by law.

3.6 No Undue Risk to Public Health and Safety The underlying purpose of 10 CFR Part 50, Appendix R, Section 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. Based on the existing fire barriers, fire detectors, automatic and manual fire suppression equipment, fire protection requirements, and the absence of significant combustible loads and ignition sources in the fire areas associated with this exemption, the NRC staff has concluded that application of 10 CFR Part 50, Appendix R, Section IlI.G.2 for these fire areas is not necessary to achieve the underlying purpose of this regulation.

The NRC staff has determined that the exemption to allow OCNGS the use of operator manual actions in lieu of the requirements specified in 10 CFR Part 50, Appendix R, and Section III.G.2 does not increase the probability or consequences of previously evaluated accidents. This determination is based on the NRC staff finding that the operator manual actions are not the sole form of protection relied upon due to the other fire protection features in place

- 20 -

and the manual actions are considered feasible and provide safe shutdown capability following a fire. The combination of the operator manual actions, in conjunction with all of the measures and systems discussed above, results in an adequate level of protection. No new accident initiators are created by allowing use of operator manual actions in the fire areas identified in the exemption and the probability of postulated accidents is not increased. Similarly, the consequences of postulated accidents are not increased. Therefore, there is no undue risk (since risk is probability multiplied by consequences) to public health and safety.

3.7 Consistent with Common Defense and Security The proposed exemption would allow OCNGS lf,, specific operator manual actions in lieu of meeting the requirements specifie in-tT CF','"fp 50, Appendix R, and Section III.G.2. This change, to the operation of thellolant, has no relation to security issues nor does it diminish the level of safety from what was ntended y the rejiirements contained in Section Ill.G.2. Therefore, the common defense*and security is not impacted by this exemption.

3.8 Special Circumstances One of the special circumstancl eldsk0.ibe. I 12(a) (2) (ii) is that the application of the regulation is not necessary to achieve the u rlying purpose of the ruled The undrlin p of R pgh50, ,' 'lyin tepsurpe o"thet r ue.the underlying purpose of 0OFRPart 50, Appendix R ISection Ill.G,,0~ to ensure that one of the redundant trains necessary'to, achieve and flaintanhtl itdown 'cOnditionsremains free of fire damage in the event ofla fire. Forthe fire areas:spepified in able 1 of this exemption, the NRC staff finds that the operator manualactions are.fasible and the existing configuration described herein will ensure that a redunda fttrain necessaryto achieve and maintain safe shutdown of the plant will-remain free offiIeagehe evehtof a fire in these fire zones. Since the undemrlyn,*" "r 1,0~,CR ldrt 50, Appendix Rection IIL.G is achieved, the special circumt'an*es requiremd1,110 CIFI150.12(a)(ý2)(iDQIfpr the granting of an exemption from 10 CFR Pat51"p 't LG?21xist.

Part 5 6 t Ibppendix R, Se'tion Ill., llist.

" i[!il qII 'ti*ll 4.0 Conclusion Accordingly, t F4Commission has determined that, pursuant to 10 CFR 50.12(a), the exemption is authorizedbyi laiW 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 such that application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule. 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 OCNGS for the 21 operator manual actions specified in Table 1.

Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (74 FR 5191).

21 TABLE 1 Requested OMAs and Initiating Fire Areas / Zones rIi~i! ii'*

.*1 Jl % il

22 TABLE I Phase I OMAs OMA Purpose Fire Affected Initiating Fire Act-i-rs- Action Location Number Component Area Manual actions are Cables TB-FA-26 Trip 4160V breakersani-d IockoGit*iing the 69 Switch TB-FA-3B required to isolate associated with for all FeederB?=k6rs except 1B2P-itdIB3P. Local damaged cables 4160V Shutdown-P flIused to control equipmnt as follows:

and reestablish Switchgear 1D LSP-1 D4 fWKSwitchgear 1D Breakers ftSS 11B2 control locally for and LSP-11D and 1B3 (Op&`taTejransfer Switch to "Alternatmeýand the 4160V control operate ControlFSWitch for6fd& breakers for US SI:B2 Switchgear 1D and Id.lB3 LSP-1D 2 Condensate Primary CST OB-FA-9 Lo6aily reaGd*CE'level at LV42-4993 Yard (at CST)

Storage Tank (CST) level indicator 5F-level Ind. 27 OB'FZ-6A- __....

OB13'FZ-80 3 Manual actions for Cables - TBFA-26= LocdalShutdown*Panels used to control equipment as CW-FA-14 Hot Shutdown are assocated with ,.follows: LSP 1,B3,480V USS 11B3 incoming breaker.

required to isolate 480,V*U*SS 1B3 TBTZ-11B perate transfer Switch to "Alternate" and then operate damaged cables TB-F Control Switch for USS 1B3 Breaker 1B3M) and reestablish "=--

control locally for *- TB-FZ-11D 480V USS 1B3 electrical power =TB;FZ-1 1E breakers.

23 OMA Purpose Fire Affected Initiating Fire Actions Action Location Number Component Area 4 Manual actions for Condensate TB-FZ-1 1B Local Shutdown Panels use.d.. htrol equipment as MT-FA-12 Hot Shutdown are Transfer Pump 1- follows:

required to isolate 2 TB-FZ-1 1E damaged cables LSP-1 B32 Condensai#1nif*P~ump 1-2 (Operate and reestablish transfer switch to0AlteThate" andb ate Control Switch control locally for for CondensatiT.:Iriansfer Pump 1-2)-

the Condensate Transfer Pump.

5 Manual actions for LSP-DG2 TB-FZ-1 1D, Local Shutdown~an-els arUed to control equifi-nt DG-FA-17 Hot Shutdown are ýaýfollows:

required to isolate TB-FZ-1 1E damaged cables ELSP-DG2;.EDG2 and its Swtchgear (Operate transfer and reestablish Switches (3 tal).,tq,"Alternat"Qd operate Control control locally for -_ Switdh:on DieseI[P5-iJl:to start d1*).

Emergency Diesel Generator #2 - ______

(EDG2).

6 Manual actions for USS-1 B3,-ý-- TB-FAP-26&-=.

- Relose MCC4I1B-32 Feeder Breaker at USS 1B3 after CW-FA-14 Hot Shutdown are Breaker 062C - Dieit Gerer~atosrt due to an undervoltage trip.

required to re-close +i -l1 Breaker 062C of TB-FZ1!C USS-1 B3 TB-FZ-1 1D

TB-FZ- liE

24 OMA Purpose Fire Affected Initiating Fire Actions Action Location Number Component Area 7 Manual actions for V-9-2099 OB-FZ-6B Manual valves V-9-2099 (form-r6rIyV-1 1-44 and V RB-FZ-1E Hot Shutdown are 49) are opened, and manu-LEZI'es V-1 1-63 and V required to align the OB-FZ-8A 41 are closed to provide-m-'ake'up.

Fire System water OBFZ-8B to the Isolation Condenser shell OB-FZ-8C side This action is required because TB-FZ-11F there is no power

("8" Train) available TB-FZ-1 1H to the Condensate ....

Transfer System or CW-FA-14 makeup.

Manual actions for Unit Substation :OB-FZ-8C Local Shutdow*Pa*niels u,*"djt5ontrol equipment as OB-FZ-6A Hot Shutdown are (USS) 1A2 '=,-'-follows:

required to isolate electrical -

damaged cables breakers. ._-. -iESP-- A2, C RDYydraulic PP NC08A and 480V USS and reestablish _____ 1A2 Incoming breaker (Operate transfer switch to control locally for Alternate-tad opeate Control Switch for USS-1A2 Unit Substation  :..Main Breaker 1A2M and A CRD Pump).

(USS) 1A2 electrical breakers 9 Manual actions for Unit Substatioi"i- tOB-FZ-6A Remote Shutdown Panel used to control equipment: OB-FZ-6B Hot Shutdown are (USS) 182 "=7- RSP, CRD Hydraulic PP NC08B and 480V USS 1B2 required to isolate electrical .; - Incoming breaker as follows:

damaged cables breakers and O and reestablish CRD Hydraulic .2/CRD Operate USS 1 Transfer Switch (Partial control locally for Pump. initiation) to "Alternate" and operate Control Switches for Unit Substation USS-1 B2 Main Breaker and B CRD Pump.

(USS) 182 electrical breakers and CRD Hydraulic.

25 OMA Purpose Fire Affected Initiating Fire Actions Action Location Number Component Area 11 Manual actions for Cables RB-FZ-1 E Use CRD local flow gauge EI-225-998 due to cable RB-FZ-1 D Hot Shutdown are associated with damage to the normal cont=froom flow indicator.

required to the CRD Flow RB-FZ-1G .....

determine CRD Indicator in CR flow.

12 Manual actions for Instrument air to RB-FZ-1D RB- Manually Qoi',,V'15-237, throttle V-15-30i]sing local RB-FZ-1 E Hot Shutdown are the CRD Flow FZ-1F5 TB-FA- flow indicatO-f:-(El-225-2) and close V-15-52ýt-?esftablish required to Control Valve 3A OB-FZ-6A CRD flow to R6itor due to the*loss of instrument air to The operator must re-enter Fire Zone RB-establish CRD flow OB-FZ-6B OB- the CRD Flow C6n!6l1-Valve_ FZ-1E. To manually manipulate CRD to the reactor due to The normal CRD FZ-8A OB-FZ- System valves V-15-237, V-1 5-30 and V-the loss of flow control valve 8B OB-FZ-8C 15-52. These valves are physically located instrument air to the is a single OB-FZ-10A within the spray area of the automatic CRD flow control component and OB-FA-9 RB- localized fixed water spray deluge system valve. does not have a FZ:.1E B;EZ- in this fire zone which is actuated by a redundant 1GGbTBFA2& cross-zoned fire detection system. An counterpart "B*FZ-1 1B TB*t exemption was granted in SER dated June available for use 'PZI*ICTB -FZ- 25, 1990 for not providing either additional from the control 11 D7B FZ- 11 E= separation from in-situ combustibles or room. This-valve. TB-FZ1H_TB- protection for CRD System valve V-15-30.

may faijl

• EF;Z-11 H CW7-- Valves V-15-237, V-15-52 and V-15-30 are opetratel-due to *A :-1 A physically within four feet of each other; cofftr-l*or power therefore, the technical basis of the cable dmThage, or exemption is considered to be equally valid due to th~efi-e-, for these additional valves. Inaddition, induced loss 6of there are 204 minutes between the start of instrument air. - the event and when the actions need to occur to restore CRD flow.

26 OMA Purpose Fire Affected Initiating Fire Actions Action Location Number Component Area 13 Provide Reactor Both CRD RB-FZ-1F3 Core Spray System IImanugal!les V-20-1 and V-20-2 RB-FZ-1F2 Coolant Makeup Pumps are opened and V-20-4 is~clOSed to provide Reactor using Core Spray Coolant Makeup using..Cr.-S.5ry Pump instead of the Pump instead of the CRD Pump (manipulfvlvaive --

't6align Core Spray to CRD Pump CST). This actiotis-jirequired becgorthe fire damages both CRD PU'fi7_

16 All Reactor Reactor TB-FZ-1 1B Trip all five*Ractor Recirculation Pumps 5t 41160V TB-FZ-11C Recirculation Recirculation Switchgear. 1A`Btakers A3,..A5 and A9 and Pumps must be Pumps (NG01-A, TB-FZ-1 1E Switchgear. 1B Biekers,*.'B:an , B8 Also, lockout.the tripped to allow use NG01-B, NG01- 4160V breakers usirg[t69'Switch.

of fuel zone level C, NG01D and OB-FZ-8C instruments and to NG01E) prevent the Isolation Condenser. ...... ._

from tripping on high flow.