Text

Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions
	ML090760993
Person / Time
Site:	Indian Point
Issue date:	03/06/2009
From:	Joseph E Pollock; Entergy Corp, Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-09-032, RIS 2006-010, FOIA/PA-2016-0148
	Download: ML090760993 (53)
	v • d • e

Indian Point Energy Center 450 Broadway, GSB EnfteW P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President March 6, 2009 Re: Indian Point Unit 3 Docket No. 50-286 NL-09-032 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions for Indian Point Unit No. 3

References:

1. NRC Regulatory Issue Summary (RIS) 2006-010, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions"

2. NRC Inspection Procedure 71111.05T, "Fire Protection (Triennial)"

Dear Sir or Madam:

The purpose of this letter is to request exemptions from the requirements of 10 CFR 50, Appendix R in accordance with the guidance contained in NRC RIS 2006-010 (Reference 1), and in accordance with 10 CFR 50.12, "Specific exemptions." The Exemption Request is contained in Attachment 1.

Entergy Nuclear Operations, Inc, (Entergy) has reviewed the fire protection licensing bases for Indian Point Unit 3 (IP3) relative to 10 CFR 50, Appendix R, Paragraph III.G and the use of operator manual actions (OMAs) to mitigate certain potential spurious operations or maloperation of credited safe-shutdown components that could be caused by fire damage to components and/or cables.

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NL-09-032 Docket No. 50-286 Page 2 of 3 Reference 1 allows licensees to differentiate between those credited OMAs that have been previously reviewed by the Staff with approval, acknowledgement, or concurrence of these actions documented in one or more Safety Evaluation Reports, and those credited OMAs for which there is no record of prior Staff review and approval or concurrence of the OMAs. As exemptions are required in either case, Entergy has chosen to include all OMAs in one grouping as identified in Attachment 2.

The credited OMAs have been evaluated against the acceptance criteria of NRC Inspection Procedure 71111.05T (Reference 2) and confirmed to be feasible and reliable operator actions during the post-fire coping scenario. Further, these OMAs are consistent with the Staff's acceptance criteria for use as interim compensatory actions, and it is Entergy's position that these same credited OMAs are suitable and appropriate as permanent elements of the post-fire safe-shutdown strategy. The alternate shutdown strategy that is implemented for III.G.3 areas relies extensively on local OMAs for achieving and maintaining hot shutdown conditions, and utilizes further local OMAs, augmented by post-fire repairs for achieving and maintaining cold shutdown conditions.

In contrast, the OMAs described for the listed III.G.2 fire areas are in each case representative of only a small subset of the OMAs credited for implementation of the more extensive alternate shutdown strategy.

The credited but unapproved OMAs described in Attachment 2 affect five fire areas in which compliance with one or more elements of Appendix R Paragraph III.G.2 is claimed. These OMAs, or more appropriately, sets of OMAs, in each case consist of a small number of manual actions that can be accomplished in a timely manner using the normal operations shift staff. These groupings of OMAs, in any of the affected fire areas, are bounded by the scenario presented to the operations shift staff in implementing the alternate shutdown methodology for those fire areas in which compliance with Appendix R Paragraph III.G.3 is necessary.

It is Entergy's belief that the requested exemption(s) should be granted, as:

The identified OMAs are feasible and reliably implemented with the available operations shift staff, even considering the adverse conditions encountered during the post-fire environment and in consideration of possible multiple spurious actuations;

Limited hazards and existing fire protection features provide assurance that the need to implement the OMAs is remote;

No demonstrable fire/nuclear safety benefit would be gained by implementation of additional modifications in lieu of continued crediting of the defined OMAs, as credible and reliable means of achieving and maintaining safe-shutdown conditions.

NL-09-032 Docket No. 50-286 Page 3 of 3 As required by 10 CFR 50.12(a)(1), 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.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, IPEC Licensing Manager at (914) 734-6710.

Sincerely, 64`L .-*A, Joseph E. Pollock Site Vice President Indian Point Energy Center Attachments:

1. Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 For Use of Operator Manual Actions

2. Technical Basis in Support of Exemption Request cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point Energy Center Mr. Paul Eddy, New York State Department of Public Service Mr. Robert Callender, Vice President NYSERDA

ATTACHMENT 1 Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 For Use of Operator Manual Actions ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286

NL-09-032 Docket No. 50-286 Attachment 1 Page 1 of 6 Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 For Use of Operator Manual Actions 1.0 EXEMPTION REQUEST 10 CFR 50, Appendix R, Paragraph III.G.2 requires the following:

Except as provided for in paragraph G.3 of this section, where cables or equipment, including associated non-safety circuits that could prevent operation or cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the following means of ensuring that one of the redundant trains is free of fire damage shall be provided:

a. Separation of cables and equipment and associated non-safety circuits of redundant trains by a fire barrier having a 3-hour rating. Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier;

b. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustible or fire hazards. In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; or

c. Enclosure of cable and equipment and associated non-safety circuits of one redundant train in a fire barrier having a 1-hour rating, In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area; Inside noninerted containments one of the fire protection means specified above or one of the following fire protection means shall be provided:

d. Separation of cables and equipment and associated non-safety circuits of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards;

e. Installation of fire detectors and an automatic fire suppression system in the fire area; or

f. Separation of cables and equipment and associated non-safety circuits of redundant trains by a noncombustible radiant energy shield.

NL-09-032 Docket No. 50-286 Attachment 1 Page 2 of 6 10 CFR 50, Appendix R, Paragraph III.G.3 requires the following:

Alternative or dedicated shutdown capability and its associated circuits, independent of cables, systems or components in the area, room, zone under consideration should be provided:

a. Where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section; or

b. Where redundant trains of systems required for hot shutdown located in the same fire area may be subject to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression systems.

In addition, fire detection and a fixed fire suppression system shall be installed in the area, room, or zone under consideration.

Consequently, unless alternative or dedicated shutdown capability is provided or an exemption from paragraph III.G.2 is granted, circuits which could cause maloperation or prevent operation of redundant trains for post-fire safe shutdown and are located in the same fire area must be protected in accordance with paragraph III.G.2.

As detailed in Attachment 2, Indian Point Unit 3 (IP3) credits a number of manual actions in lieu of one of the means specified in paragraph III.G.2 to ensure a train is free of fire damage when redundant trains are in the same fire area.

Therefore, Entergy Nuclear Operations, Inc. (Entergy) hereby requests an exemption from the requirements of 10 CFR 50, Appendix R, Paragraph III.G.2 for IP3 to the extent that operator manual actions are necessary to achieve and maintain hot shutdown for fire areas in which both trains of safe-shutdown cables/equipment are located in the same fire area. The fire areas involved are Fire Areas AFW-6, PAB-2, ETN-4, TBL-5, and YARD-7.

2.0 BACKGROUND

As understood by many licensees (including Entergy) since the issuance of 10CFR50, Appendix R, the use of local operator manual actions (OMAs) to facilitate post-fire safe-shutdown was not explicitly prohibited by Paragraph III.G.2, and therefore in many cases, licensees' post-fire shutdown procedures include the use of such actions to mitigate situations in which cables or components could be damaged in a given fire scenario. However, the regulatory activities leading up to the proposed (now-withdrawn) "Manual Action Rule," and the issuance of RIS 2006-010 (Reference 7.1 of Attachment 2), have confirmed the NRC Staff's position that the crediting of OMAs was not explicitly or implicitly permitted by the regulation, and that any crediting of such manual actions for

NL-09-032 Docket No. 50-286 Attachment 1 Page 3 of 6 compliance with III.G.2, without prior review and approval by the Staff in the form of an exemption, is unacceptable and noncompliant with Appendix R.

As evidenced by the development of the draft Manual Action Rule, the NRC Staff recognized this "misinterpretation" of III.G.2 was widespread among licensees, and that OMAs had been broadly integrated into the compliance basis and shutdown models for many fire areas in which compliance with III.G.2 was identified. It was further recognized and in many cases acknowledged during NRC audits/inspections that many of these OMAs had been demonstrated to be well proceduralized, feasible to implement in a sufficiently timely manner, and capable of ensuring with high confidence that the post-fire shutdown capability could be sustained through use of these specific manual actions. However, as the crediting of these OMAs without prior NRC review and approval technically constitutes noncompliance with Appendix R Paragraph III.G.2, the Staff has established guidance in RIS 2006-010 for interim acceptance of these OMAs (subject to specific conditions), pending permanent resolution of the noncompliance concerns.

The permanent resolution of "manual action" noncompliance may be achieved through the exemption process, shutdown methodology changes, plant modifications, or a combination of these approaches.

3.0 LICENSING BASIS For the fire areas for which this exemption is requested (Fire Areas AFW-6, PAB-2, ETN-4, TBL-5, and YARD-7), the plant's fire protection licensing basis indicates that IP3 is committed to compliance with 10CFR50, Appendix R, Paragraph III.G.2. The explicit requirements of 10CFR50, Appendix R, Paragraph III.G.2 mandate that (using one of the options given by III.G.2) the redundant trains should be adequately separated and protected, such that in the event of a fire in that area, at least one train will remain free of fire damage, and therefore OMAs (for mitigation or recovery) should not be required. However, as contained in the IP3 Appendix R Safe-Shutdown Analysis (Reference 7.4 of Attachment 2), in the event of a fire in one of the fire areas that are the subject of this exemption request, certain local OMAs are credited to prevent or mitigate certain undesirable equipment operations that may occur due to fire damage to cables or components located in that fire area. In each case, the OMAs described are taken in another area (outside the area affected by the fire) or, in certain cases, are implemented in the affected fire area, after 60 minutes have elapsed, to conservatively ensure that reentry to the fire-affected area is feasible.

As documented by RIS 2006-010, while the stated hot shutdown OMAs may be reasonable, achievable, and an effective means of ensuring the post-fire safe-shutdown (hot shutdown) capability, the crediting of such actions without an approved exemption is not permitted within the options listed under Appendix R, Paragraph III.G.2. Therefore, as it appears that IP3 does not have documentation of prior NRC review and approval in the form of an existing

NL-09-032 Docket No. 50-286 Attachment 1 Page 4 of 6 exemption for the OMAs contained herein, the requirements of Paragraph III.G.2 of Appendix R are not met for the affected fire areas. Therefore, in accordance with RIS 2006-010, the permanent resolution of the OMA noncompliance is to include an approved exemption from the requirements of 10 CFR 50, Appendix R, Paragraph III.G.2 in the licensing basis for the affected fire areas.

It should be noted that not all plant fire areas require an exemption. Fires occurring in some areas require no OMAs, and fires in certain other areas are mitigated in accordance with Appendix R, Paragraph III.G.3 (alternate shutdown), which incorporates the use of OMAs that do not require prior NRC review and approval. The focus of the exemption request is limited to those fire areas for which compliance with Appendix R, Paragraph III.G.2 is claimed and OMAs are credited, in part, for coping with the effects of a fire in that area, and are required to achieve and maintain hot shutdown.

4.0 TECHNICAL BASIS The technical basis to support this exemption request is contained in Attachment

2. It has been developed in accordance with the guidance of RIS 2006-010 (Reference 7.1 of Attachment 2), NRC Staff Memorandum dated July 19, 2006 (T. Dinh to S. Weerakkody) (Reference 7.2 of Attachment 2), and NRC Inspection Procedure (IP) 71111.05T (Reference 7.3 of Attachment 2).

Additional guidance was obtained from SECY 08-0093 (Reference 7.5 of Attachment 2), in the screening of OMAs that require explicit NRC review and approval via the exemption process.

5.0 REGULATORY ANALYSIS

Pursuant to 10 CFR 50.12, the Commission may grant exemptions from the requirements of 10 CFR 50 that are (1) authorized by law; (2) will not present an undue risk to the public health and safety; (3) consistent with the common defense and security; and, (4) special circumstances, as listed in 10 CFR 50.12(a)(2) are present. This exemption request meets the criteria set forth in 10 CFR 50.12, as discussed herein.

5.1 The requested exemption is authorized by law 10 CFR 50.12(a) authorizes the NRC to grant exemptions from its regulations, and no law is known that precludes the NRC from granting the requested exemption. As discussed below, since the exemption request does not present an undue risk to public health and safety, will not endanger the common defense and security, and special circumstances exist, the NRC is authorized to issue the exemption.

NL-09-032 Docket No. 50-286 Attachment 1 Page 5 of 6 5.2 The requested exemption does not present an undue risk to the public health and safety The credited OMAs in Tables 2 through 9 of Attachment 2 have been evaluated against the acceptance criteria of IP 71111.05T and have been confirmed to be feasible and reliable actions during the post-fire coping scenario. These OMAs, or more appropriately, sets of OMAs, affect five fire areas and in each case consist of a small number of manual actions that can be accomplished in a timely manner using the normal operations shift staff, even considering the potentially adverse conditions encountered during the post-fire environment and in consideration of possible multiple spurious actuations. Use of the OMAs ensures that the effectiveness of the fire protection program is not degraded, and that the credited post-fire safe-shutdown capability is not challenged since at least one train of safe shutdown equipment will remain operable. Further, these OMAs are unlikely to be required to be implemented given the defense-in-depth features of the fire protection program, and the associated low likelihood of a significant fire in any of the fire areas of concern. Based on this and on the determination that safe shutdown even in the event of a fire can be achieved and maintained through the use of OMAs instead of meeting the requirements of Paragraph III.G.2 of Appendix R in all cases, the requested exemption does not present an undue risk to the public health and safety.

5.3 The requested exemption is consistent with the common defense and security To ensure that the common defense and security are not endangered, the exemption request must demonstrate that the loss or diversion of Special Nuclear Material (SNM) is precluded. As a part of the Indian Point Energy Center (IPEC), IP3 has systems and processes in place that provide protection for the public from diversion of SNM that is licensed to be possessed on site. These systems and processes are those embodied in the "IPEC Physical Security Plan," the "IPEC Security Training and Qualification Plan," the "IPEC Safeguards Contingency Plan," and the "IPEC Security Implementing Procedures." The exemption request contained herein does not involve or affect the systems and processes contained in those documents/programs. Therefore, this exemption does not affect the common defense and security.

5.4. Special circumstances are present 10 CFR 50.12(a) requires that special circumstances be present in order for the Commission to consider granting an exemption. Per 10 CFR 50.12(a)(2)(ii), one special circumstance is that application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

NL-09-032 Docket No. 50-286 Attachment 1 Page 6 of 6 The underlying purpose of 10 CFR 50, Appendix R is to provide reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a postulated fire in any plant area. Circuits which could cause maloperation or prevent operation of redundant trains for post-fire safe shutdown and are located in the same fire area must be protected in accordance with Paragraph III.G.2 of Appendix R. If such protection is not provided, then Paragraph III.G.2 specifies that alternative or dedicated shutdown capability be provided or an exemption from Paragraph III.G.2 be granted. The NRC permits exemptions from Ill.G.2, as described in RIS 2006-10 via the use of OMAs as long as those actions are feasible and can be reliably implemented. The NRC has provided acceptance criteria set forth in NRC Inspection Procedure 71111.05T in order to evaluate if OMAs are feasible and reliably implemented.

The credited OMAs listed in Tables 2 through 9 of Attachment 2 have been evaluated against the acceptance criteria of IP 71111.05T and have been confirmed to be feasible and reliable operator actions during the post-fire coping scenario. Therefore, since an acceptable alternative to the regulation that has been provided by the NRC has been demonstrated to be acceptable for the OMAs listed in Tables 2 through 9 of Attachment 2, no demonstrable fire/nuclear safety benefit would be gained by the installation of additional modifications to comply with Paragraph III.G.2 of Appendix R in lieu of the crediting of the defined OMAs as credible and reliable means of achieving and maintaining safe-shutdown conditions.

Therefore, the underlying purpose of the rule is satisfied and the application of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of the rule.

6.0 CONCLUSION

This request for exemption is warranted under the provisions of 10 CFR 50.12, in that it is authorized by law, does not present an undue risk to the public health and safety, and is consistent with the common defense and security. Further, it meets the requirement for a special circumstance in that it satisfies the underlying purpose of 10 CFR 50 Appendix R by providing reasonable assurance that safe shutdown of the reactor can be achieved and maintained in the event of a fire using operator manual actions in certain fire areas in lieu of the separation and protection requirements of Appendix R.

ATTACHMENT 2 Technical Basis in Support of Exemption Request ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286

NL-09-032 Docket No. 50-286 Attachment 2 Page 1 of 42 Technical Basis in Support of Exemption Request

1. Backqround and Identification of Manual Actions The explicit requirements of 10CFR50, Appendix R, Paragraph III.G.2 mandate that (using one of the options given by III.G.2) redundant trains of safe-shutdown equipment should be adequately separated and protected, such that in the event of a fire in that area, at least one train will remain free of fire damage, and therefore operator manual actions (for mitigation or recovery) should not be required. In response to a review of the IP3 post-fire shutdown methodology and Appendix R compliance bases to address NRC RIS 2006-010 (Reference 7.1), it was noted that in certain fire areas in which separation would typically be expected to meet the requirements of Appendix R, Paragraph III.G.2, the use of operator manual actions (OMAs) is credited in the IP3 Appendix R Safe-Shutdown Analysis (Reference 7.4) to mitigate certain undesirable equipment operations that may occur due to fire damage to cables or components located in those fire areas in order to restore or maintain the associated safe (hot) shutdown functions.

The fire areas where OMAs are credited are Fire Areas AFW-6, PAB-2, ETN-4, TBL-5, and YARD-7. Table 1 provides a summary of the Fire Hazards Analysis for each fire zone in those fire areas. Tables 2 through 9 list the specific OMAs that may be required to be performed in each of these III.G.2 fire areas. The OMAs have been reviewed in accordance with the guidance of RIS 2006-010, NRC Staff Memorandum dated July 19, 2006 (T. Dinh to S. Weerakkody) (Reference 7.2), and the acceptance criteria provided by Enclosure 2 of NRC Inspection Procedure 71111.05 (Reference 7.3) and have been determined to provide feasible and reliable mitigating actions to compensate for the potential fire-induced failure or spurious actuation of the identified safe-shutdown components.

It should be noted that not all IP3 fire areas are listed in Table 1. Fires occurring in some areas require no OMAs, and fires in certain other areas are mitigated in accordance with Appendix R, Paragraph III.G.3 (alternate shutdown). The focus of the issue addressed herein is limited to those fire areas in which compliance with Appendix R, Paragraph III.G.2 is claimed and manual actions are credited, in part, for mitigation or recovery of certain elements of the post-fire safe-shutdown capability in the event that a postulated fire in any one of the listed fire areas causes damage to redundant safe-shutdown equipment trains located in that fire area. In each case, the manual actions described are taken in another area (outside the area affected by the fire), or in certain cases are implemented in the affected fire area, after 60 minutes have elapsed, to conservatively ensure that reentry to the fire-affected area is feasible.

Consistent with the guidance given by References 7.1 and 7.2, the OMAs listed in Tables 2 through 9 have been implemented as interim compensatory measures, in lieu of fire watches, pending permanent resolution of the stated Appendix R

NL-09-032 Docket No. 50-286 Attachment 2 Page 2 of 42 compliance concerns. The basis for acceptability of these actions, both as interim compensatory measures and as the long-term Appendix R, Paragraph III.G.2 compliance basis (pending NRC approval via the requested exemption) in this regard is discussed herein.

As shown in Table 1, each of the affected fire areas has one or more mitigating fire protection characteristics that provide a level of defense-in-depth protection, thus minimizing the necessity to use post-fire shutdown procedures for credible fire scenarios in these areas. When these defense-in-depth features are considered in concert with the station fire prevention measures of housekeeping controls, hot work constraints, and transient combustible controls, and the fire brigade manual suppression capabilities, the likelihood of the need for the identified OMAs is reduced further.

2. Binning of Manual Actions Per Guidance of SECY-08-0093 The credited OMAs have been screened to establish those that are credited for protection or recovery of the REQUIRED safe-shutdown train, versus those OMAs that are credited for protection or recovery of equipment that is "Important to Safe Shutdown," as outlined by SECY-08-0093 (Reference 7.5). Those OMAs that are identified as credited for protection of the REQUIRED SSD train, and that are not documented as acceptable OMAs in a previously granted exemption to Appendix R are the subject of this exemption request. Those OMAs that are identified as credited for protection or recovery of equipment "important to safe shutdown," i.e.,

that are NOT part of the REQUIRED SSD train, are considered acceptable actions, provided that they are demonstrated to be feasible and reliable, without requiring exemption from the requirements of Appendix R.

The IP3 Appendix R Safe-Shutdown Analysis was reviewed to identify all cases in which OMAs have been credited as an element of the safe-shutdown methodology in III.G.2 fire areas. These OMAs were then screened based on criteria given by SECY-08-0093 and NEI-00-01, Draft Rev. 2(c) (Reference 7.6) to isolate those OMAs that are credited for the protection or recovery of the required/credited safe-shutdown train in the affected fire areas. The screening criteria that were applied, and the resultant tabulation of the OMAs of concern, is captured in engineering report IP-RPT-08-00072 (Reference 7.7).

3. Review of Credited Manual Actions as Acceptable Compensatory Measures Per IP 71111.05 The guidance of Enclosure 2 of Inspection Procedure 71111.05 is referenced in the July 19, 2006 NRC Staff memorandum (T. Dinh to S. Weerakkody). Enclosure 2 of IP 71111.05 describes the criteria that must be considered when determining whether an OMA, credited as an interim compensatory measure, is appropriate and feasible to credit in this capacity. The criteria, along with the IP3-specific responses, are discussed below.

NL-09-032 Docket No. 50-286 Attachment 2 Page 3 of 42

i. Applicability The identified OMAs are those which are credited in fire areas under which compliance to Appendix R, Paragraph III.G.2 is credited, and for which manual actions there is apparently no record of prior NRC review and approval, in an SER or approved exemption, of the use of these actions to establish equivalent compliance with Ill.G.2 requirements.

ii. Diagnostic Instrumentation For fire scenarios occurring in IIl.G.2 fire areas, evacuation of the Central Control Room (CCR) and comprehensive implementation of alternative shutdown methods is not required or credited. As such, key diagnostic instrumentation can be expected to remain available in the CCR to alert operators to implement the contingency OMAs as credited in the IP3 Appendix R Safe-Shutdown Analysis. Key indicators that trigger the need for local operator intervention for the credited set of OMAs include not only the RCS and secondary system instrumentation, but also the failure of components to respond or reliably indicate status in the CCR. Based on field notes compiled from simulator exercises in which bounding fire area scenarios were modeled, it is judged that the available CCR instruments and indicators, combined with operator response in accordance with EOPs, AOPs, fire safe shutdown procedures, and other supporting procedures, provide reasonable assurance of timely diagnosis of conditions requiring the dispatch of operator(s) to perform the credited OMAs outside the CCR.

iii. Environmental Considerations Radiation levels: None of the identified OMAs require an operator to enter high radiation fields.

Emergency lighting per Appendix R, Paragraph III.J: Emergency lighting is installed per Appendix R, Paragraph Ill.J, as necessary for access/egress to OMA locations, and for task performance at those locations.

Temperature and humidity: The credited OMAs are generally not conducted in the area directly affected by the fire, and given that they are performed in support of hot shutdown operation, they are performed relatively early in the coping period. As a result, in the event of the failure of normal HVAC systems early in the scenario, zone/room heatup that creates habitability concerns is not expected. However, for those specific cases in which it is necessary to reenter the fire area no less than one hour (except for the AFW Pump Room) after the postulated fire event, sufficient time is available to initiate smoke/heat venting through fixed ventilation systems and augmented by portable smoke ejectors, consistent with the

NL-09-032 Docket No. 50-286 Attachment 2 Page 4 of 42 Pre-Fire Plans, to ensure operator habitability to implement the necessary OMAs.

Smoke and toxic gases: The identified OMAs are generally not conducted in the area directly affected by a postulated fire, and thus significant quantities of smoke and toxic gases impacting the areas where OMAs are performed are not typically expected. However, for those specific cases in which it is necessary to reenter the affected fire area, reentry is not credited in less than one hour after the start of the fire event, ensuring adequate time for extinguishment of the fire and initiation of smoke venting from the affected area. Pre-staged SCBAs, sufficient to equip the full operating crew, are available for deployment in response to post-fire environmental conditions.

iv. Staffing Timed field walkthroughs of Abnormal Operating Procedure 3-AOP-SSD-1 (Reference 7.8) have been performed to validate that the number of operators available on the watch staff (7) can safely accomplish all required actions within the required time period to meet Appendix R safe-shutdown performance goals. The broad set of operator manual actions required in implementing 3-AOP-SSD-1 bounds the smaller set of manual actions credited for coping with III.G.2 fire area scenarios. The OMAs required for the III.G.2 fire areas are directed by Off-Normal Operating Procedure 3-ONOP-FP-1 (Reference 7.9).

v. Communications Reliance is placed on radios for communication between plant operators during a post-fire shutdown event. Effective radio communications throughout all required plant areas is ensured by radio repeater stations.

The primary radio repeater for IP3 is located inside the protected area. A backup radio repeater (the IP2 repeater station) is located outside the protected area, and is not subject to disruption caused by fire events within the protected area/power block. The repeaters are also equipped with uninterruptible power supplies to ensure continued operation in the event of the loss of normal power to the buildings in which they are located. Field verifications of radio system functionality have validated that communications between the designated control and monitoring locations are feasible and reliable.

vi. Special Tools Any tools that are required in support of post-fire hot shutdown OMAs are pre-staged at the locations where they would be used. These consist of common tools such as wrenches, banding cutters, pliers. Where special tools/equipment are required, these are designated for post-fire cold

NL-09-032 Docket No. 50-286 Attachment 2 Page 5 of 42 shutdown repairs, and the necessary tools and supplies are pre-staged in designated locations. The staging of necessary tools is confirmed via periodic surveillance.

vii. Training The fire scenarios that may be encountered in III.G.2 fire areas may involve the use of EOPs and AOPs, as well as post-fire safe-shutdown procedure(s), in coping with the fire scenario. Initial and periodic requalification Operator training typically is provided on these procedures, consistent with standard licensed and non-licensed operator training programs, as well as emergent needs as identified by training evaluation action requests.

viii. Accessibility Where ladders are required for access to components to perform OMAs, appropriate ladders are staged in accordance with plant procedures and the presence of these ladders is verified periodically in accordance with plant surveillance procedures.

ix. Procedures Post-fire operator manual actions are clearly defined in procedures 3-ONOP-FP-1, 3-AOP-SSD-1, and supporting procedures. Where CCR controls and indication are not assured to be reliably operable, sufficiently detailed guidance is provided in these procedures to direct the operators to an alternate component or operating method that is assured to be available and viable for the specific fire scenario under consideration.

x. Verification and Validation The post-fire OMAs have been validated through timed operator walkthroughs, using as the basis an enveloping scenario addressed by 3-AOP-SSD-1. When utilizing 3-AOP-SSD-1, the most challenging set of local manual operator actions (number of actions and time sensitivity of actions) is presented to the operations shift crew, and this set of actions is considered to adequately bound the limited set of manual actions that are credited in 3-ONOP-FP-1, and as listed for the fire areas shown in Tables 2 through 9. Note that 3-ONOP-FP-1 also relies principally on shutdown from the CCR. The timed walkthroughs of 3-AOP-SSD-1 have consistently demonstrated that the key safe-shutdown tasks (e.g., restoration of RCS makeup; restoration of auxiliary feedwater to steam generators; mitigation of key potential spurious actuation concerns) can be accomplished in a timely manner to meet the Appendix R safe-shutdown performance goals.

NL-09-032 Docket No. 50-286 Attachment 2 Page 6 of 42 In addition to the validation of key OMAs credited in alternate safe-shutdown procedure 3-AOP-SSD-1, the plant simulator was utilized to perform evaluations of bounding III.G.2 fire scenarios, and based on the field notes compiled from these exercises, there is reasonable assurance that conditions requiring the implementation of the identified OMAs can be identified and mitigated in a sufficiently timely manner to ensure Appendix R performance goals are met.

4. Tabulation of Credited Hot Shutdown Operator Manual Actions The attached Tables 2 through 9 list, on a fire area basis, the specific OMAs credited for recovery or protection of the credited equipment train for achieving and maintaining hot shutdown conditions in these Appendix R Paragraph III.G.2 fire areas. The manual action lists were extracted from the component, cable, and raceway database used for preparation of the IP3 Appendix R Safe-Shutdown Analysis. As shown by Tables 2 through 9, the total number of OMAs that may be required in response to any single III.G.2 fire scenario to restore or protect the credited/required equipment train is minimal.

The manual action sequences in all of the Ill.G.2 areas are considered to be bounded by the sequences represented by alternate shutdown (III.G.3) Fire Area CTL-3.. The alternate shutdown scenario represented by Fire Area CTL-3 has been drilled through performance of procedure 3-AOP-SSD-1, and successful accomplishment of actions and required time targets has been demonstrated. It is further noted that in Fire Area CTL-3 (which encompasses the CCR, Cable Spreading Room, 480V Switchgear Room, and others), the high concentration of control, power, and instrumentation cables presents the greatest potential for multiple circuit damage and multiple spurious operation scenarios, and thus presents the greatest potential for the entire set of credited manual actions for this area to be performed. In the Ill.G.2 fire areas addressed by Tables 2 through 9, the cable densities and commonality of routing paths is a small fraction of those represented in Fire Area CTL-3.

5. Defense-In-Depth The IP3 Fire Protection Program, consistent with NRC guidance as given by BTP APCSB 9.5-1, 10 CFR 50, Appendix R, and supporting generic communications, is designed and implemented based on a foundation of defense-in-depth protection.

The three tiers of defense in depth consist of:

" Fire Prevention - Preventing fires from starting, through control of fuel and ignition sources and conditions.

Fire Detection and Suppression - Providing the capability to promptly detect any fires that may occur, and the capability to promptly and effectively control and extinguish any such fire.

NL-09-032 Docket No. 50-286 Attachment 2 Page 7 of 42 Protection of Safe Shutdown Capability - Providing protection for systems, structures, and components important to safety, such that any fire that is not promptly detected and extinguished will not prevent the safe shutdown of the plant.

The Fire Prevention layer of defense in depth is composed of administrative controls as well as inherent plant design features. Noncombustible materials have been used to the maximum extent practicable in original plant design and in any subsequent plant modifications, including not only structural components, but also (for example) the use of flame-resistant electrical cable insulation. Introduction of combustible materials into the power block is strictly controlled by administrative procedure EN-DC-161 (Reference 7.10) that requires fire protection engineering review and approval prior to the introduction of any significant quantity of transient combustibles into key plant areas. Routine housekeeping inspections ensure validation and enforcement of the controls on transient combustibles and fire hazards. Hot work in key areas of the plant is also controlled administratively, for processes including open-flame work, cutting, welding, and grinding. As a result of the above, the potential for exposure fires (in transient combustibles) and fires resulting from the introduction of significant ignition sources (hot work) is sharply limited.

The Fire Detection and Suppression layer of defense in depth is represented by fire detection and suppression systems that are installed in those plant areas that contain significant combustible hazards. Fire detection includes both smoke and heat detection systems that provide alarms to the CCR. Suppression systems include pre-action, deluge and wet pipe sprinkler systems, aqueous film-forming foam (AFFF) automatic suppression systems, total flooding and local application C02 suppression systems, and Halon 1301 total-flooding suppression systems. A summary of the fire detection and suppression features in all of the fire areas included in the subject exemption request is provided in Table 1.

Hose stations and fire extinguishers are located throughout the plant to facilitate firefighting activities by the fire brigade. As shown in Table 1, areas containing unique or significant hazards are provided with fire detection and/or automatic fire suppression systems. The installed fire detection and automatic suppression systems, in conjunction with fire brigade response and deployment of the available manual fire suppression features, provides assurance that a fire will be precluded from rapidly growing and involving other fire zones or areas.

The Protection of Safe-Shutdown Capability layer of defense in depth is represented by the fire barriers enclosing each fire area that provide assurance that a fire that is not promptly detected and/or not promptly controlled and suppressed, will ultimately be contained within the fire area of origination. As the IP3 Appendix R Safe-Shutdown Analysis places reliance on a postulated fire being confined to the fire area of origin, the passive (fire barrier) features ensure the continued integrity of the post-fire safe-shutdown analysis and the post-fire safe-shutdown procedures that have been developed based on that analysis.

NL-09-032 Docket No. 50-286 Attachment 2 Page 8 of 42 Each fire area is separated from adjacent fire areas with a barrier commensurate with the hazards of the area. The fire barriers typically have a 3-hour fire resistance rating, including the barrier, doors, HVAC fire dampers, and penetration seals.

However, other barrier types, including spatial separation, are used to divide fire areas. These fire area boundaries are described in the IP3 Fire Hazards Analysis (Reference 7.11). The IP3 Appendix R Safe-Shutdown Analysis documents the basis for achieving safe shutdown following a fire in any given fire area. The equipment lost and the equipment available has been reviewed and the actions necessary to ensure shutdown have been identified in the post-fire safe-shutdown procedures for each fire area. The OMAs addressed by the subject exemption request are part of the actions that may be necessary in support of the safe-shutdown methodology established by the IP3 Appendix R Safe-Shutdown Analysis.

6. Fire Hazards and Fire Protection Features in III.G.2 Fire Areas An initiating fire area is the area in which one or more OMAs are credited to mitigate maloperation of equipment in the required/credited equipment train caused by potential fire-induced damage to components or cables located in that area. The five III.G.2 fire areas in which the OMAs discussed herein are credited are:

" Fire Area AFW-6:

Auxiliary Feedwater Pump Room

Fire Area ETN-4:

Upper and Lower Electrical Tunnels including the common entryway at the Cable Spreading Room, the Upper and Lower Electrical Penetration Areas, including the connecting stairwell, and the Electrical Tunnel Fan Room

Fire Area PAB-2:

Primary Auxiliary Building (PAB), Radioactive Machine Shop (RAMS) and Fan House Buildings

Fire Area TBL-5:

Turbine Building and the Auxiliary Feedwater Pump Building with the exception of the Auxiliary Feedwater Pump Room

Fire Area YARD-7:

The external yard areas, Intake Structure, Appendix R Diesel Generator Building, Backup Service Water Pump Pad, and miscellaneous buildings not associated with power generation The details of combustible loading/fire severity and active fire protection features for all fire zones comprising the five fire areas of concern are listed in Table 1. Note that most of these fire areas are comprised of a number of fire zones consisting of

NL-09-032 Docket No. 50-286 Attachment 2 Page 9 of 42 separate compartments, or fire zone delineations based on spatial separation. As described below, the character of the localization of the hazards and combustibles by fire zone, combined with the separation between fire zones by spatial and barrier separation, provide reasonable assurance that fires that occur within a given zone will be confined to the zone of origination.

As shown in Table 1, most fire zones comprising the above five fire areas are characterized by LOW combustible loading, corresponding to less than 100,000 BTU/ft2 , or an equivalent fire severity of 75 minutes or less. All fire zones characterized as having a HIGH combustible loading (greater than or equal to 200,000 BTU/ft2 , or an equivalent fire severity of at least 150 minutes) are typically equipped with automatic fire suppression systems, appropriate for the hazards of the area, thus sharply limiting the expected extent of any fire that may occur. The remaining fire zones are characterized by MODERATE combustible loading, with a combustible load of 100-200,000 BTU/ft , or an equivalent fire severity of 75 to 150 minutes. Of the fire zones classified as containing MODERATE or HIGH combustible loading, 13 fire zones are not provided with automatic fire suppression or detection systems, although manual fire suppression equipment is available, as shown in Table 1. Of these 13 fire zones, five are categorized as exhibiting HIGH combustible loading. No safe-shutdown related components or cables are located in these fire zones. Of the remaining 8 zones, which are characterized by MODERATE combustible loading, no safe-shutdown related components are located in these zones, although several safe-shutdown cables are located in Fire Zones 4A, 6A, 20A, and 30A of Fire Area PAB-2. These fire zones are discussed further as follows:

Fire Zone 4A (PAB El. 34' Corridor), exhibits a MODERATE combustible loading principally as the result of the small floor area of the zone, and the conservative assumption of a substantial transient combustible load. In actuality, the transient combustible loading in the zone is limited by the controls of procedure EN-DC-1 61, and without appropriate compensatory measures, transient combustibles within the zone would not be permitted to accumulate to this level. The zone has few credible ignition sources. The potential fire-induced failure of the 10 safe-shutdown related cables routed through the zone is mitigated as described by the IP3 Appendix R Safe-Shutdown Analysis.

Fire Zone 6A (PAB El. 34' Valve Room) also exhibits a MODERATE combustible loading principally as the result of the extremely small floor area of the zone, and the conservative assumption of a substantial transient combustible load. In point of fact, the transient combustible loading in the zone is limited by the controls of procedure EN-DC-1 61, and without appropriate compensatory measures, transient combustibles within the zone would not be permitted to accumulate to this level. The zone has few credible ignition sources. The potential fire-induced failure of the two safe-shutdown related cables routed through the zone is mitigated as described by the IP3 Appendix R Safe-Shutdown Analysis.

NL-09-032 Docket No. 50-286 Attachment 2 Page 10 of 42

" Fire Zone 20A (PAB EI.55' Sample Room) also exhibits a MODERATE combustible loading principally as the result of the extremely small floor area of the zone, and the conservative assumption of a substantial transient combustible load. In point of fact, the transient combustible loading in the zone is limited by the controls of procedure EN-DC-161, and without appropriate compensatory measures, transient combustibles within the zone would not be permitted to accumulate to this level. The zone has few credible ignition sources. The potential fire-induced failure of the single safe-shutdown related cable routed through the zone is mitigated as described by the IP3 Appendix R Safe-Shutdown Analysis.

Fire Zone 30A (PAB El. 73' Valve Corridor) also exhibits a MODERATE combustible loading principally as the result of the extremely small floor area of the zone, and the conservative assumption of a substantial transient combustible load. In point of fact, the transient combustible loading in the zone is limited by the controls of procedure EN-DC-1 61, and without appropriate compensatory measures, transient combustibles within the zone would not be permitted to accumulate to this level. The zone has few credible ignition sources. The potential fire-induced failure of the two safe-shutdown related cables routed through the zone is mitigated as described by the 1P3 Appendix R Safe-Shutdown Analysis.

Fire Areas and Safe-Shutdown Analysis Areas The above five listed Fire Areas (AFW-6, PAB-2, ETN-4, TBL-5, and YARD-7), in addition to two fire areas not addressed herein, form the foundation upon which the IP3 Appendix R Safe-Shutdown Analysis has been developed. Note that the two remaining fire areas, CTL-3 and CNT-1, are not discussed herein, as they are not the focus of previously unapproved III.G.2 OMAs. As discussed below and as illustrated by Tables 3 through 7, Fire Areas ETN-4 and PAB-2 are further subdivided into safe-shutdown "analysis" areas, as defined and analyzed in the IP3 Appendix R Safe-Shutdown Analysis. The subdivision of Fire Area ETN-4 into Analysis Areas (ETN-4{1} through ETN-4{4} and Fire Area PAB-2 into Analysis Areas PAB-2{1 } through PAB-2{5) is based upon spatial separation, active and passive fire protection features, safe-shutdown equipment locations, and specific exemptions granted for these areas. As such, for purposes of the IP3 Safe-Shutdown Analysis, these analysis areas are effectively considered to be separate fire areas. The details of the separation bases and applicable exemptions granted for these fire areas are described in References 7.4 and 7.11. Note that not all of the Fire Area ETN-4 and PAB-2 analysis areas are discussed below, as not all of the analysis areas involve unapproved III.G.2 OMAs.

Summary descriptions of each of the III.G.2 Fire/Analysis Areas are provided below.

The combustible loading, types of combustibles, postulated fires, available detection and suppression, and smoke/hot gas ejection methods are identified.

NL-09-032 Docket No. 50-286 Attachment 2 Page 11 of 42 Fire Area AFW-6, AFW Pump Building Elevation 18'-6" (AFW Pump Room)

This fire area consists of a single room (the AFW Pump Room), and it is also designated Fire Zone 23. Alternate safe shutdown and safety-related equipment and cabling are located in the zone.

The overall combustible loading for this fire area is LOW. Combustibles in this fire area include: cable insulation, small quantities of lube oil, and small quantities of Class A combustibles. Based on the types and amounts of combustibles, the postulated fire is a slow developing cable fire or lubricating oil fire. The wet pipe sprinkler system is designed to control the fire, and its activation results in a CCR alarm which will result in subsequent response by the fire brigade to extinguish the fire, if required. Ionization detectors also result in a CCR alarm, providing early warning of a fire condition. Smoke and hot gases can be evacuated to the exterior via wall exhaust fans and portable smoke ejectors.

OMAs that may need to be performed as a result of a fire in Fire Area AFW-6 consist of four discrete action sets that are listed in Table 2.

Fire Area ETN-4, Electrical Tunnels Within Fire Area ETN-4, the anticipated fire is a slow developing cable fire located in the cable trays. Thermal detectors in the cable trays provide early warning followed by activation of the preaction sprinkler system in the cable trays, which is expected to control the fire. Early warning detection is also provided by area-wide ionization detectors. Activation of both detection systems will result in CCR alarm and subsequent response by the fire brigade to extinguish any remaining fire. Smoke and hot gases can be evacuated to the exterior via the Electrical Penetration Tunnel Ventilation System and portable smoke ejectors.

The analysis areas of concern, ETN-4{1), ETN-4{3), and ETN-4{4}, are discussed below.

Fire/Analysis Area ETN-4{11 Entrance to the Electrical Tunnels, Fire Zones 7A and 60A This analysis area includes those cable trays in the Electrical Tunnel, twenty feet in from where the floor of the Upper tunnel begins, for both the Upper and Lower tunnels and those raceways between cable tray stacks. The entrance to the tunnel is an area which contains both trains of safe shutdown equipment.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area ETN-4(1} consist of 14 discrete action ,sets that are listed in Table 3.

NL-09-032 Docket No. 50-286 Attachment 2 Page 12 of 42 Fire/Analysis Area ETN-4{3} Upper Electrical Penetration Area and Electrical Tunnel Fan Room, Fire Zones 73 and 73A The Upper Electrical Penetration Area is the normal access for cables which are routed to the Containment Building (VC). This area also contains instrument isolation cabinets and alternate power supplies for alternative shutdown.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area ETN-4{3} consist of four discrete action sets that are listed in Table 4.

Fire/Analysis Area ETN-4f4} Lower Electrical Tunnel and Penetration Area, Fire Zones 7A, 74A The Lower Electrical Tunnel analysis area contains safe shutdown cables for components located in the Primary Auxiliary Building and the Containment Building (VC). This area extends from the mouth of the tunnel up to and including the Electrical Penetration Area.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area ETN-4{4} consist of one discrete action set that is shown in Table 5.

Fire Area PAB-2, Primary Auxiliary Building Within Fire Area PAB-2, the worst case fire is expected to occur in one of the fire zones for which Appendix R exemptions have been previously granted (Zones 1, 3, 4, 5, 6, 7 or 17A) or in adjacent zones (12A, 21A, 58A or 69A) based on the hazards present and the potential consequences. The postulated fire in Zone 1, 3, 4, 5, 6, or 7 is a rapidly developing oil-based fire associated with the respective safe shutdown pump located in each of these zones (CCW, RHR or Charging). In Fire Zone 17A, the postulated fire is a slow developing cable fire. Area-wide early warning detection of the fire is provided in each of these zones, including the under-floor area at the MCCs in Zone 17A, resulting in Control Room alarm. Adjacent zones 12A, 21A, 58A and 69A contain early-warning detection systems commensurate with the hazards present in those areas to assure that a fire originating in zones adjacent to safe shutdown equipment will not affect redundant safe shutdown equipment.

Subsequent response by the fire brigade is expected to extinguish any fires. Smoke and hot gases can be evacuated to the exterior via the Primary Auxiliary Building Ventilation System and portable smoke ejectors.

The analysis areas of concern, PAB-2{3} and PAB-2{5}, are discussed below.

Fire/Analysis Area PAB-2{3} 55' Elevation Charging Pump Rooms, Fire Zones 5, 6 and 7 The three charging pumps are located on the 55' elevation of the Primary Auxiliary Building. Each charging pump is contained in a separate cubicle. Pumps 31 and 32 have indirect open doorways between the cubicles. Pump 33 is contained within its own cubicle. The safe shutdown analysis requires one charging pump to be free from

NL-09-032 Docket No. 50-286 Attachment 2 Page 13 of 42 fire damage to accomplish the required safe shutdown performance objectives. All fire scenarios have been resolved by relying on either Pump 31 or 32.

The combustible loading for the fire zones comprising this analysis area is MODERATE. Combustibles in these fire zones include: cable insulation, small quantities of lube oil, and small quantities of Class A combustibles. Based on the types and amounts of combustibles, the postulated fire is a slow developing cable fire or lubricating oil fire. Early warning detection is provided by ionization detectors that alarm in the CCR to ensure subsequent response by the fire brigade to extinguish the fire. Smoke and hot gases can be evacuated to the exterior via PAB exhaust fans and portable smoke ejectors.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area PAB-2{3} consist of one discrete action set that is listed in Table 6.

Fire/Analysis Area PAB-2{5} The Remaining PAB Fan House and RAMS Areas not Covered by Other Analysis Areas The remaining PAB areas consist of all other elevations and rooms that are not captured as part of Analysis Areas PAB-2{1 } through PAB-2{4}. As shown in Table 1, the combustible loading in the balance of the PAB-2 fire zones includes zones with LOW, MODERATE, and HIGH combustible loading characteristics, with appropriate active fire protection features provided, except as discussed above. A postulated fire encompassing all fire zones forming the balance of the PAB is highly unlikely. A fire in the 55' elevation of the PAB is not likely to travel down to the 15' elevation or horizontally through the fan house door/wall to affect all components in both fire zones and all zones in between. However, the safe-shutdown analysis conservatively assumes that all safe-shutdown cables and components located in the fire zones comprising analysis area PAB-2{5} Will fail simultaneously, as the result of fire damage.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area PAB-2{5} consist of four discrete actions, which are listed in Table 7.

TBL-5, Turbine Building and the Auxiliary Feedwater Pump Building with the exception of the Auxiliary Feedwater Pump Room Fire Area TBL-5 consists of 33 discrete fire zones, with LOW combustible loading character in all but four fire zones. The remaining four fire zones, which exhibit HIGH combustible loading, are also provided with appropriate automatic fire detection and suppression systems, to ensure that any fire in these zones is rapidly detected and controlled.

Within Fire Area TBL-5, the worst-case fire based on existing hazards would involve one of the turbine oil hazards associated with Fire Zone 16 or 17. The anticipated fire is a rapidly developing lube oil fire. Trenches surrounding each of the fire zones prevent the accumulation and spread of lube oil beyond the zone boundaries.

NL-09-032 Docket No. 50-286 Attachment 2 Page 14 of 42 Early warning detection is provided by area-wide thermal detectors that alarm in the CCR, followed by activation of an automatic foam spray suppression system which is designed to control the fire, and subsequent response by the fire brigade to extinguish the fire, if required. Smoke and hot gases can be evacuated to the exterior via the Turbine Building Ventilation System and area doors, and employing the use of portable smoke ejectors as necessary.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area TBL-5 consist of four discrete action sets that are listed in Table 8.

YARD-7, The external yard areas, Intake Structure, Appendix R Diesel Generator Building, Backup Service Water Pump Pad, and miscellaneous buildings not associated with power gqeneration Fire Area YARD-7 consists of 41 discrete fire zones, with LOW combustible loading character in all but six fire zones. These six fire zones exhibit HIGH combustible loading and are provided with appropriate automatic fire detection and suppression systems to ensure that any fire in these zones is rapidly detected and controlled, with the exception of Fire Zone 131A (Gas Turbine Substation and Switchgear Equipment). Fire Zone 131A is located remote from any safety-related SSCs, and contains only components associated with the alternate safe-shutdown capability.

Within Fire Area YARD-7, the most significant fire hazard is associated with either Main Transformer 31 (in Fire Zone 64A) or 32 (in Fire Zone 65A). The anticipated fire is a rapidly developing transformer oil fire. Early warning detection is provided by area-wide thermal detectors that alarm in the CCR, followed by actuation of an automatic deluge water spray system which is designed to control the fire, and subsequent response by the fire brigade to extinguish the fire, if required. Fire Zones 64A and 65A are naturally vented to the outside and require no special ventilation actions.

OMAs that may need to be performed as a result of a fire in Fire/Analysis Area YARD-7 consist of two discrete action sets that are listed in Table 9.

In summary, given the limited fire hazards in most fire zones comprising the III.G.2 fire areas, and the provision of appropriate active fire protection features in zones containing significant hazards, combined with the compartmental and/or spatial separation between fire zones within the III.G.2 fire areas, there is reasonable assurance that in the event of a fire in any of the affected fire areas, the likelihood of the need to invoke and implement the credited OMAs would be minimal. The likelihood to implement most or all of the potential OMAs designated for any given fire area is of even lower likelihood, given the multiple fire-induced failures that would be required to necessitate the use of these OMA measures.

NL-09-032 Docket No. 50-286 Attachment 2 Page 15 of 42

7. References 7.1. NRC Regulatory Issue Summary (RIS) 2006-010, "Regulatory Expectations With Appendix R Paragraph III.G.2 Operator Manual Actions" 7.2. NRC Staff Memorandum dated July 19, 2006, T. Dinh to S. Weerakkody, "Summary of June 9, 2006 Category 3 Meeting on Technical Issues Clarifications on Post-Fire Operator Manual Actions" 7.3. NRC Inspection Procedure 71111.05, "Fire Protection (Triennial)," revised March 6, 2003 7.4. IP3 Appendix R Safe-Shutdown Analysis IP3-ANAL-FP-01503, Rev. 2 7.5. SECY-08-0093, "Resolution of Issues Related to Fire-Induced Circuit Failures" 7.6. NEI 00-01, Draft Revision 2(c), Guidance for Post-Fire Safe Shutdown Circuit Analysis; Appendix H: "Required for Hot Shutdown Versus Important to SSD Components" 7.7. Engineering Report IP-RPT-08-00072, Rev. 0; "Operator Manual Action Screening for Appendix R,Section III.G: IP2 and IP3" 7.8. 3-AOP-SSD-1, "Control Room Inaccessibility Safe-Shutdown Control," Rev. 5 7.9. 3-ONOP-FP-1, "Plant Fires," Rev. 24 7.10. Procedure EN-DC-161, Control of Combustibles, Rev. 2 7.11. IP3 Fire Hazards Analysis IP3-ANAL-FP-02143, Rev. 4

NL-09-032 Docket No. 50-286 Attachment 2 Page 16 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

AFW-6 23 Low 19.0 Ionization Area Wide Automatic Area Wide CO 2 Wet Pipe Dry Chemical

____ ___ ____ ____ _ __ ____ ____ Sprinklers _ _ _ _ _ _ _ _

ETN-4 7A Low 59.0 Thermal/ Cable Trays/ Automatic Cable Trays CO 2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 60A Low 68.0 Thermal/ Cable Trays/ Automatic Cable Trays CO 2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 73 Low 11.0 None N/A None N/A CO 2 ETN-4 73A Moderate 96.0 Thermal/ Cable Trays/ Automatic Cable Trays CO 2 Ionization Area Wide Preaction Only Dry Chemical Water Spray ETN-4 74A Low 28.0 Thermal/ Cable Trays/ Automatic Cable Trays CO 2 -

Ionization Area Wide Preaction Only Dry Chemical Water Spray_

PAB-2 1 Low 8.0 Ionization Area Wide None N/A CO 2 ....

PAB-2 1A Low 9.0 Ionization Area Wide None N/A None CO 2 1 PAB-2 2 Low 35.0 Ionization Area Wide None N/A Hose Station ....

CO 2 PAB-2 2A Low 15.0 Ionization Area Wide None N/A Dry Chemical ....

PAB-2 3 Low 69.0 Ultraviolet Area Wide None N/A None CO 2 12A Hose Station 14A PAB-2 3A Low <1.0 None N/A None N/A None CO 2 2 1_ Hose Station PAB-2 4 Low 74.0 Ultraviolet Area Wide None N/A None CO 2 12A Hose Station 14A

NL-09-032 Docket No. 50-286 Attachment 2 Page 17 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

PAB-2 4A Moderate 87.0 None N/A None N/A Hose Station ....

Dry Chemical PAB-2 5 Moderate 85.0 Ionization Area Wide None N/A None Hose Stations 17A C02 A PAB-2 5A Low 6.0 None N/A None N/A None None --

PAB-2 6 Moderate 84.0 Ionization Area Wide None N/A None Hose Stations 17A C02 PAB-2 6A Moderate 75.0 None N/A None N/A None Hose Station 4A Dry Chemical PAB-2 7 Moderate 77.0 Ionization Area Wide None N/A None Hose Stations 17A Ionization Area Wide None N/A C02 ....

PAB-2 8 Low 19.0 PAB-2 8A Low 16.0 None N/A None N/A None Dry Chemical 12A C02 14A Hose Station PAB-2 9 Low 10.0 None N/A None N/A None Hose Station 4A Dry Chemical PAB-2 9A Low 60.0 Ionization Area Wide None N/A None C02 12A I Hose Station 14A PAB-2 1OA Low 23.0 None N/A None N/A None C02 12A Hose Station 14A PAB-2 11A High 166.0 None N/A None N/A None C02 12A Hose Station 14A PAB-2 12A Low 42.0 Ionization 15'-0" Corr. None N/A C02 ....

PAB-2 13A Low 37.0 None N/A None N/A None C02 12A I I Hose Station 14A

NL-09-032 Docket No. 50-286 Attachment 2 Page 18 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mrin) Type Coverage Type Coverage (see Note 1) (see Note 1)

PAB-2 14A Low 48.0 Ionization Area Wide Manual Separates Hose Station ....

Water Spray PAB-2 (door)

Curtain and Trans.

Yard PAB-2 15A Moderate 95.0 None N/A None N/A None CO 2 12A Hose Station 14A PAB-2 16A High > 3 Hours None N/A None N/A None CO 2 12A Hose Station 14A PAB-2 17A Low 38.0 Ionization Area Wide None N/A Hose Stations ....

CO 2 Dry Chemical Ionization Under Floor, -.....

MCC Area Ultraviolet MCC Area ..........

PAB-2 18A Low 66.0 None N/A None N/A None Hose Stations 17A CO 2 Dry Chemical PAB-2 19A Low 26.0 None N/A None N/A None Hose Stations 17A CO 2 Dry Chemical PAB-2 20A Moderate 92.0 None N/A None N/A None Hose Stations 17A CO 2 Dry Chemical PAB-2 21A Moderate 125.0 Ionization & Area Wide None N/A None Hose Stations 17A Ultraviolet CO 2 Dry Chemical PAB-2 22A Low 29.0 None N/A None N/A CO2 --

I_ I Dry Chemical

NL-09-032 Docket No. 50-286 Attachment 2 Page 19 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mrin) Type Coverage Type Coverage (see Note 1) (see Note 1)

PAB-2 23A High 152.0 None N/A None N/A None CO 2 22A Dry Chemical 22A C02 24A PAB-2 24A Low 30.0 None N/A None N/A CO 2 ....

PAB-2 25A Moderate 91.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 26A High 152.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 27A Low 15.0 None N/A None N/A Hose Stations ....

C02 PAB-2 28A Moderate 115.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 29A Moderate 127.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 30A Moderate 108.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 31A Low 63.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 32A Low 64.0 None N/A None N/A None Hose Stations 27A C02 PAB-2 58A Low 16.0 Ionization PAB 41' None N/A None Dry Chemical 2A Corridor Hose Stations 59A C02 59A PAB-2 59A Low 5.0 Ionization Area Wide None N/A Hose Stations ....

I C002 PAB-2 61A Low < 1.0 None N/A None N/A None None --

PAB-2 62A Low 15.0 None N/A None N/A Dry Chemical None --

NL-09-032 Docket No. 50-286 Attachment 2 Page 20 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

PAB-2 63A Low 38.0 None N/A None N/A None Hose Stations 17A C02 PAB-2 68A Low 42.0 None N/A None N/A None None --

PAB-2 69A Moderate 110.0 Ionization Area Wide None N/A None CO 2 12A Hose Station 14A PAB-2 79 Low 25.0 None N/A None N/A None Dry Chemical 8A PAB-2 79A Low 58.0 None N/A None N/A None C02 59A Hose Station PAB-2 88A Moderate 112.0 Ionization 72'-0" El. - Manual Containment Hose Stations ....

Filter Area Deluge Purge Exh. C02 Water Spray Charcoal Filter Dry Chemical

-- Manual PAB Exhaust ......

Deluge Charcoal Filter Water Spray Manual Cont. Pressure ....

Deluge Relief Charcoal Water Spray Filter PAB-2 89A Low 41.0 None N/A None N/A C02 ....

PAB-2 107 Low 14.0 Ionization/ el. 44'-6" Area None N/A Hose Stations ....

Thermal Wide Ion. / el. C02 54' & 73' Area Dry Chemical Wide Thermal Pressurized Water PAB-2 127 Low 50.0 Ionization Area Wide None N/A C02 ....

Pressurized Water PAB-2 128 Low 22.0 Thermal Area Wide Automatic Area Wide C02 ....

Pre-Action Dry Chemical Sprinklers PAB-2 622 Low 43.0 None N/A None N/A None Dry Chemical 74A

NL-09-032 Docket No. 50-286 Attachment 2 Page 21 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

TBL-5 16 High >3 hours Thermal Area Wide Automatic Lube Oil None Hose Stations - 42A Foam Spray Storage Tank water &foam TBL-5 17 High >3 hours Thermal Area Wide Automatic Lube Oil None Hose Stations - 42A Foam Spray Reservoir, water & foam Htrs, Separator TBL-5 18 High >3 hours None N/A Automatic Area Wide None Hose Stations - 42A Wet Pipe water & foam Sprinklers TBL-5 19 Low 24.0 None N/A Automatic Area Wide None Hose Station 37A, 38A Wet Pipe CO 2 39A, 41A Sprinklers Dry Chemical TBL-5 20 High >3 hours Thermal Area Wide Automatic Area Wide Foam Hose Stations ....

Foam Spray (Boiler Feed Pump Oil Console & Oil Accumulators)

TBL-5 21 Low 30.0 Thermal Area Wide Automatic Area Wide (H2 None Hose Stations - 37A Foam Spray Seal Oil Unit) water Hose Station -

foam CO 2 Dry Chemical

NL-09-032 Docket No. 50-286 Attachment 2 Page 22 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Type Coverage Type Coverage Suppression Equipment Fire Zone (min) Type Coverage T (see Note 1) (see Note 1)

TBL-5 37A Low 53.0 Ionization/ MCC 34, Automatic Area Wide Hose Stations -

Thermal 6.9KV Wet Pipe overhead Water Switchgear Sprinklers (except Swgr Hose Station - Foam

/Battery & Area), including CO 2 Charger Rm Battery & Dry Chemical Charger Rms Automatic Separates Water Spray TBL-5 & Trans.

Exposure Yard I Protection TBL-5 38A Low 15.0 Ionization MCC 32 Automatic Area Wide Hose Station Wet Pipe overhead CO 2 I I Sprinklers I Dry Chemical

NL-09-032 Docket No. 50-286 Attachment 2 Page 23 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

TBL-5 39A Low 37.0 Ionization MCC 33 Automatic Area Wide None Hose Stations - 40A Wet Pipe overhead Water Sprinklers Hose Station -

Foam C02 Wheeled Class D Thermal BFP Oil Automatic Boiler Feed --

Console & Foam Spray Pump Oil BFP Drive Console Turb. HP Bgs.

Manual Turbine Water Spray Building Boiler Feed Pumps Automatic Local App.,

C02 Drive Turb. HP Bgs, Boiler Feed Pumps TBL-5 40A Low 7.0 None N/A Automatic Area Wide Hose Stations -

Wet Pipe overhead water & foam Sprinklers C02 Wheeled Class D Dry Chemical TBL-5 41A Low 9.0 None N/A Automatic Area Wide Hose Station Wet Pipe overhead C02 SSprinklers Dry Chemical TBL-5 42A Low 24.0 Ionization MCC 35 Automatic Area Wide Hose Stations -

Wet Pipe overhead water & foam Sprinklers I II_ I

NL-09-032 Docket No. 50-286 Attachment 2 Page 24 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mrin) Type Coverage Type Coverage (see Note 1) (see Note 1)

TBL-5 43A Low 33.0 None N/A Automatic Area Wide Hose Stations ....

Wet Pipe overhead C02 Sprinklers Halon Pressurized Water Automatic Separates ......

Water Spray TBL-5 and Exposure Trans. Yard Protection TBL-5 44A Low 13.0 None N/A None N/A None Hose Stations 43A C02 Halon Pressurized Water TBL-5 45A Low 3.0 None N/A None N/A None ....

TBL-5 46A Low 9.0 None N/A Automatic Area Wide Hose Stations ....

Wet Pipe overhead C02 Sprinklers Dry Chemical TBL-5 47A Low 21.0 None N/A Automatic Area Wide Hose Station ....

Wet Pipe overhead C02 Sprinklers Dry Chemical Thermal R4D4 Automatic R4D4 Separator Foam Spray Separator TBL-5 48A Low < 1.0 None N/A None N/A None Hose Station 47A C02 Dry Chemical

NL-09-032 Docket No. 50-286 Attachment 2 Page 25 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (mrin) Type Coverage Type Coverage (see Note 1) (see Note 1)

TBL-5 49A Low 7.0 Ionization/ Office/Exciter Automatic Total Flooding, Hose Stations ....

Thermal Enclosure, CO2 Exciter C02 incl. Bgs 10 & Enclosure and Dry Chemical 11 Bearings 10 & Wheeled Dry Chem 11 Halon Foam Pressurized Water TBL-5 50A Low < 1.0 Thermal Governor Automatic Governor Hose Stations ....

Housing & Oil Preaction Housing & Oil C02 Lines & TG Spray Lines & TG Dry Chemical Bearings 1-9 Bearings 1-9

-- -- Manual C02 Local App., TG ....

Bgs 1,2,3 & MS Valves in Governor Enclosure Manual C02 Local App., TG ....

Bcs 4,5,6 & 7

-- Manual C02 Local App., TG Bearings 8 & 9 TBL-5 51A Low 6.0 None N/A None N/A Hose Stations ....

C02 Thermal TB pipe Automatic TB pipe bridge ......

bridge to AFW Water Spray to AFW Pump Pump Bldg Curtain Bldg_

TBL-5 52A Low 10.0 None N/A None N/A Dry Chemical --

NL-09-032 Docket No. 50-286 Attachment 2 Page 26 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

TBL-5 53A Low 7.0 None N/A None N/A None Dry Chemical 52A Hose Station 54A TBL-5 54A Low 14.0 None N/A None N/A Hose Station ....

TBL-5 57A Low 37.0 Thermal TB pipe Automatic TB pipe bridge Dry Chemical ....

bridge to AFW Water Spray to AFW Pump Pump Bldg Bidg TBL-5 58 Low 67.0 None N/A None N/A None Hose House & YARD-7 Hydrant TBL-5 59 Low 65.0 Ionization Area Wide Automatic Area Wide None Hose Station 38A Wet Pipe CO 2 Sprinklers Dry Chemical TBL-5 109 Low 32.0 Thermal Area Wide Automatic Area Wide CO 2 ....

Wet Pipe Dry Chemical Sprinklers _

TBL-5 110 Low 12.0 Ionization Area Wide None N/A Hose Station ....

CO 2 Dry Chemical TBL-5 111 Low 2.0 Thermal Area Wide Automatic Area Wide Dry Chemical ....

Wet Pipe Sprinklers TBL-5 112 Low 2.0 Ionization Area Wide None N/A Hose Station -- --

I _CO 2 TBL-5 113 Low < 1.0 Ionization Area Wide None N/A CO 2 ....

Dry Chemical TBL-5 114 Low 2.0 Ionization Area Wide None N/A Hose Station -- --

CO 2 YARD-7 22 Low 27.0 Photoelectric Area Wide None N/A Dry Chemical ....

NL-09-032 Docket No. 50-286 Attachment 2 Page 27 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

YARD-7 55A Low 2.0 Photoelectric Area Wide None N/A Hose Stations C02 YARD-7 56A Low 2.0 None N/A None N/A Adjacent Yard Hose House & YARD-7 Hydrant Hydrant YARD-7 64A High > 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Thermal Area Wide Automatic Main Adjacent Yard Hose House & YARD-7 Deluge Transformer 31 Hydrant Hydrant Water Spray XFMR Automatic Separates detectors Water Spray TBL-5 and actuate water Exposure Trans. Yard curtains Protection Automatic Separates Water Spray XFMR 31 and Curtain Unit Aux.

XFMR YARD-7 65A High > 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Thermal Area Wide Automatic Main Adjacent Yard Hose House & YARD-7 Deluge Transformer 32 Hydrant Hydrant Water Spray Manual Separates Water Spray PAB-2 (door)

Curtain and Trans.

Yard

NL-09-032 Docket No. 50-286 Attachment 2 Page 28 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

YARD-7 66A High > 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Thermal Area Wide Automatic Unit Auxiliary Adjacent Yard Hose House & YARD-7 Deluge Transformer Hydrant Hydrant Water Spray XFMR Automatic Separates ....

detectors Water Spray TBL-5 and actuate water Exposure Trans. Yard curtains Protection

-- Automatic Separates Water Spray XFMR 31 and Curtain Unit Aux.

XFMR YARD-7 67A High > 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Thermal Area Wide Automatic Station Adjacent Yard Hose House & YARD-7 Deluge Auxiliary Hydrant Hydrant Water Spray Transformer Manual Separates ....

Water Spray PAB-2 (door)

Curtain and Trans.

Yard YARD-7 90A Low 9.0 None N/A None N/A Hose Station ....

CO 2 YARD-7 91A Low 9.0 None N/A None N/A Hose Station ....

CO 2 YARD-7 92A Low < 1.0 None N/A None N/A None Dry Chemical 96A YARD-7 93A Low < 1.0 None N/A None N/A None Dry Chemical 96A YARD-7 94A Low < 1.0 None N/A None N/A None C02 98A YARD-7 95A Low < 1.0 None N/A None N/A None C02 98A YARD-7 96A Low 63.0 None N/A None N/A Dry Chemical YARD-7 97A Low 6.0 None N/A None N/A None C02 98A

NL-09-032 Docket No. 50-286 Attachment 2 Page 29 of 42 Table 1 1P3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

YARD-7 98A Low 6.0 None N/A None N/A CO 2 ....

YARD-7 105A Low N/A None N/A None N/A None None --

YARD-7 106A Low N/A None N/A None N/A None None --

YARD-7 108 Low 9.0 None N/A None N/A None Hydrant & YARD-7 Hose House YARD-7 115 Low 12.0 Thermal/ Local Automatic Area Wide Hose Stations ....

Photoelectric coverage only Wet Pipe CO 2 Sprinklers Pressurized Water Dry Chemical YARD-7 116 Low 24.0 Photoelectric Local Automatic Area Wide Hose Station ....

coverage only Wet Pipe CO 2 Sprinklers Dry Chemical Pressurized Water YARD-7 117 Low 47.0 Photoelectric Local Automatic Total Flooding, Hose Stations ....

coverage only Halon TSC Computer CO 2 Room Dry Chemical Pressurized Water Halon

-- -- Manual TSC/OSC ....

Water Spray Charcoal Filter YARD-7 118 Low 47.0 Photoelectric, Local None N/A Hose Stations ....

Thermal and coverage only CO 2 Ionization inc. underfloor Pressurized Water computer area Dry Chemical

NL-09-032 Docket No. 50-286 Attachment 2 Page 30 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R,Section III.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

YARD-7 119 Low 47.0 Thermal/ Local None N/A Hose Stations ....

Photoelectric coverage only CO 2 Dry Chemical Pressurized Water YARD-7 120 Low 47.0 Photoelectric, Local Automatic Total Flooding, Hose Stations ....

Thermal/ coverage only/ Halon Documents Dry Chemical Thermal Documents Vault Pressurized Water Vault Halon YARD-7 121 Low 47.0 Thermal/ Local Manual Filter Units AS- Hose Stations ....

Photoelectric coverage only Water Spray FU-1,2,3 CO 2 Dry Chemical Pressurized Water Halon YARD-7 122 Low 47.0 Thermal, Local None N/A Hose Station ....

Photoelectric coverage only CO 2 Dry Chemical Pressurized Water Halon YARD-7 123 Low 47.0 Ionization Area Wide None N/A Hose Station ....

CO 2 Dry Chemical Pressurized Water I Halon YARD-7 125 Low 7.0 Ionization Area Wide Automatic Area Wide Hose Stations ....

Wet Pipe CO 2 Sprinklers Dry Chemical Pressurized Water I _Halon

NL-09-032 Docket No. 50-286 Attachment 2 Page 31 of 42 Table 1 IP3 Fire Hazards Analysis Summary For Appendix R, Section IUI.G.2 Fire Areas in Which OMAs Are Credited Fire Fire Category Equiv. Fire Detection Fixed Fire Suppression Manual Adjacent Manual Area Zone Fire Fire Suppression Severity Suppression Equipment Fire Zone (min) Type Coverage Type Coverage (see Note 1) (see Note 1)

YARD-7 126 Low 3.0 Ionization Area Wide Automatic Area Wide Hose Stations ....

Wet Pipe C02 Sprinklers Pressurized Water Foam YARD-7 129 Low 30.0 Ionization/ Area Wide/ Automatic Area Wide Hose Stations ....

Thermal Men's & Wet Pipe C02 Women's Sprinklers Dry Chemical Rooms Pressurized Water YARD-7 130 Low 47.0 Ionization/ Area Wide/ Automatic Area Wide Hose Stations ....

Thermal Men's Room Wet Pipe C02

& lunch room Sprinklers Pressurized Water YARD-7 131 High 177.0 Ionization & Area Wide Automatic Total Flooding C02 ....

Thermal Halon Dry Chemical YARD-7 131A High > 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months None N/A None N/A None Hose House & YARD-7 Hydrant YARD-7 132 Low 38.0 Ionization/ Elec. Pump Automatic Area Wide, C02 ....

Infrared Room/ Diesel Wet Pipe except Elec. Dry Chemical Pump Room Sprinklers Fire Pump Rm YARD-7 133 Low < 1.0 Ionization Area Wide & None N/A CO 2 ....

in Ctrl Panels Dry Chemical YARD-7 136 Low 0.0 None N/A None N/A None None --

YARD-7 222 Low N/A None N/A None N/A None Hose House & YARD-7 Hydrant YARD-7 552 Low N/A None N/A None N/A None None --

YARD-7 553 Low N/A None N/A None N/A None None --

YARD-7 554 Low N/A None N/A None N/A None Hose House & YARD-7 I I_ I Hydrant

NL-09-032 Docket No. 50-286 Attachment 2 Page 32 of 42 NOTE

1. In this column, C0 2 , Dry Chemical, Wheeled Dry Chem[ical], Wheeled Class D, Pressurized Water, Foam, and Halon are types of Extinguishers - there is at least one in the zone when listed for a zone. Extinguishers in Area CNT-1 are stored outside Containment during normal operation. Hose stations are water unless otherwise noted.

NL-09-032 Docket No. 50-286 Attachment 2 Page 33 of 42 TABLE 2 FIRE AREA AFW-6 CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Locally start 33 AFW Preclude SG boil-dry, Pump from breaker on 30 m per Calculation IP- 7 m Action is performed in Fire Area CTL-3 Bus 6A CALC-04-00766 Locally operate valves Preclude SG boil-dry, Either 33 or 32 AFW pump is used, depending on the FCV-1123, FCV-406C, 30 m per Calculation IP- 8 m damage scenario. Action is taken in Fire Area AFW-6 or FCV-406D CALC-04-00766 following fire extinguishment.

Locally operate PCV- Either 33 or 32 AFW pump is used, depending on the 1139, PCV-1310A, PCV- Preclude SG boil-dry, damage scenario. Action is taken in Fire Area AFW-6 1310B, HCV-1118, FCV- 30 m per Calculation IP- 17 m and AFW Pump Bldg, Fire Area TBL-5 following fire 405C or FCV-405D (if CALC-04-00766 extinguishment.

32 AFW pump is used)

Locally operate Steam Control cooldown to Generator Dump Valve Atm ospheric (SGADV) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months RHR H entry en r conditions.

co dt ns 9 m Action taken in AFW Pump Building, Fire Area TBL-5 PCV-1136,PCV-134,PCV-135,IP-CALC-06-00029.

or PCV-1137

NL-09-032 Docket No. 50-286 Attachment 2 Page 34 of 42 TABLE 3 FIRE AREA ETN-4{1}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Swap 32 CCW Pump Start one CCW pump for to alternate powerP > hour charging pump cooling; 10 m Action performed in Fire Area PAB-2 (transfer switch supply reference Calculation IP-CALC- operation) and TBL-5 (MCC 312A breaker operation) 06-00029.

Operate 480V Bus PAction performed in Fire Area CTL-3. Note that only 3A breaker 3A loall beakr to locally 0 m 30 Calculation Preclude SG IP-CALC-04-00766 boil-dry, per 7 m one of 31 or 32 AFW Pump is required, thus only start 31 AFW Pump one of the two listed manual action sets is required.

Locally operate FCV- Action performed in Fire Area AFW-6. Note that 1121 in support of 30 m Preclude SG boil-dry, per 8 m only one of 31 or 32 AFW Pump is required, thus use of 31 AFW Calculation IP-CALC-04-00766 only one of the two listed manual action sets is Pump, OR required.

Action performed in Fire Area AFW-6. Note that Operallyte Hcon0 Preclude SG boil-dry, per 1only one of 31 or 32 AFW Pump is required, thus manually to control 30 m Calculation IP-CALC-04-00766 only one of the two listed manual action sets is 32 AFW Pump required.

Align Appendix R Maintain Pressurizer level within Action performed in Fire Area YARD-7, TBL-5, CTL-Diesel Generator 75 m the indicating range of the WR 50 m 3. Conservatively assumes that per distribution (ARDG) to 480V channel; per Calculation IP- system alignment per 3-SOP-EL-014, all breakers Buses 2A and 5A CALC-06-00029. require local manual operation.

NL-09-032 Docket No. 50-286 Attachment 2 Page 35 of 42 TABLE 3 FIRE AREA ETN-4{1}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Swap 31 OR 32 Maintain Pressurizer level within Action performed in Fire Area PAB-2 (transfer switch Charging Pump to 7 m the indicating range of the WR 8 m operation) and TBL-5 (MCC 312A breaker alternate power channel; per Calculation IP- operation).

supply CALC-06-00029 Start ARDG and Maintain Pressurizer level within Action performed in Fire Area YARD-7, TBL-5, and align power to 480V 70 m the indicating range of the WR 50 m CTL-3. Conservatively assumes that per distribution Buses 2A, 3A, 5A, channel; per Calculation IP- system alignment per 3-SOP-EL-014, all breakers and 312 CALC-06-00029. require local manual operation.

Locally operate FCV-405B, FCV-405D, Preclude SG boil-dry, per 17 m Actions performed in Fire Area AFW-6 FCV-406B to control 30 m Calculation IP-CALC-04-00766.

AFW flow to SG Locally open valve Maintain Pressurizer level within 7 m 227 to C75mkepcane;prmacltinI-9 establish a the indicating range of the WR m Action performed in Fire Area PAB-2 CVCS makeup channel; per Calculation IP-flowpath to the RCS CALC-06-00029.

Locally close valve Maintain Pressurizer level within LCV-112C; open the indicating range of the WR valve 288 to align 75 m channel;11 m Actions performed in Fire Area PAB-2 Charging PumpCALC-06-00029.

suction to the RWST ICI 6I0I

NL-09-032 Docket No. 50-286 Attachment 2 Page 36 of 42 TABLE 3 FIRE AREA ETN-4{1}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Locally control Support cooldown to RHR entry conditions (cold shutdown Action performed in AFW Pump Building, Fire Area PCV-1136 support action), per Calculation TBL-5 IP-CALC-06-00029 Locally operate PCV-1139 to119t ensure nue30 m Preclude SG boil-dry, per PeldSGbi-rpr17 m Action performed in Fire Area AFW-6 steam supply to 32 Calculation IP-CALC-04-00766 AFW Pump Locally operate PCV-1310A, PCV-1310B Preclude SG boil-dry, per Action performed in AFW Pump Building, Fire Area toesurl ste 30 m Calculation IP-CALC-04-00766 TBL-5 supply to 32 AFW

ýPump Locally manually perform Service Ensure adequate SW Pump Action, if required, performed in Fire Area YARD-7.

Water (SW) Pump > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months nsu 15 m Strainer backwash is limited to that associated with strainer backwash the selected operating SW Pump.

as required

NL-09-032 Docket No. 50-286 Attachment 2 Page 37 of 42 TABLE 4 FIRE AREA ETN-4{3}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Time Required OMA Time to Basis to OMA Location and Comments Complete Complete Operate HCV-1118 Preclude SG boil-dry, per manually to control 32 30 m Calculation IP-CALC-04-00766 17 m Action performed in Fire Area AFW-6 AFW Pump Locally operate PCV- Preclude SG boil-dry, per 1139 to ensure steam 30 m Calculation IP-CALC-04-00766 17 m Action performed in Fire Area AFW-6 supply to 32 AFW Pump Locally operate PCV-1310A, PCV-1310B to 30 m Preclude SG boil-dry, per 17 m Action performed in AFW Pump ensure steam supply to Calculation IP-CALC-04-00766 Building, Fire Area TBL-5 32 AFW Pump Locally operate FCV- Preclude SG boil-dry, per 405C, FCV-405D to 30 m Calculation IP-CALC-04-00766 17 m Actions performed in Fire Area AFW-6 control AFW flow to SG

NL-09-032 Docket No. 50-286 Attachment 2 Page 38 of 42 TABLE 5 FIRE AREA ETN-4{4}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Time Required OMA Time to Basis to OMA Location and Comments Complete Complete Locally operate SGADV PCV- Support cooldown to RHR 1134, PCV-1135, PCV-1136, entry conditions (cold Action performed in AFW Pump or PCV-1137 to support 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months shutdown support action), 9 m Building, Fire Area TBL-5 cooldown to RHR entry per Calculation IP-CALC conditions 00029

NL-09-032 Docket No. 50-286 Attachment 2 Page 39 of 42 TABLE 6 FIRE AREA PAB-2{3}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete yclose valve LCV- Actions are performed in PAB Analysis Locally ope valve Maintain Pressurizer level Areas PAB-2{3} and PAB-2{4}. Actions 112C and open valve within the indicating range of are not required until greater than 60 288 to align Charging 75 m the WR level channel. 11 m minutes following the start of the event, Pump suction path to Reference Calculation IP- and the fire is expected to be Storage Tank (RWST) CALC-06-00029. extinguished and smoke adequately vented by that time.

NL-09-032 Docket No. 50-286 Attachment 2 Page 40 of 42 TABLE 7 FIRE AREA PAB-2{5}

CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Time Required OMA Time to Basis to OMA Location and Comments Complete Complete Maintain Pressurizer level Locally close supply within the indicating breaker for 32 CVCS 75 m range of the WR level 7m Action performed in Fire Area CTL-3 Pump channel. Reference Calculation IP-CALC 00029.

Maintain Pressurizer level Actions are performed in PAB Analysis Areas Locally control 32 C within the indicating PAB-2{3} and PAB-2{4} and are not required pump speed via scoop 75 m range of the WR level until greater than 60 minutes following the tube positioner channel. Reference 9 m start of the event, and the fire is expected to Calculation IP-CALC be extinguished and smoke adequately vented 00029. by that time Maintain Pressurizer level Actions are performed in PAB Analysis Area entalve 227rtogwithin the indicating PAB-2{5} and are not required until greater establih RCaring 7range of the WR level than 60 minutes following the start of the pothntoal Re aound 75 m channel. Reference event, and the fire is expected to be HCV-142 Calculation IP-CALC extinguished and smoke adequately vented by 00029. that time Maintain Pressurizer level Actions are performed in PAB Analysis Area LoCal cosenvalveLCwithin the indicating PAB-2{5} and are not required until greater 2range of the WR level than 60 minutes following the start of the 288low esablisho channel. Reference 75mWhane. efrec event, and the fire is expected to be fchathin fm RsTtion Calculation IP-CALC extinguished and smoke adequately vented by charging pump suction00029. that time

NL-09-032 Docket No. 50-286 Attachment 2 Page 41 of 42 TABLE 8 FIRE AREA TBL-5 CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Locally operate FCV-1121 Preclude SG boil-dry; Actions performed in AFW Pump Room, AFW Pump recirculation 30 m reference Calculation IP- 8 m Fire Area AFW-6 valve during pump startup CALC-04-00766.

Locally operate FCV-406A Preclude SG boil-dry; Actions performed in AFW Pump Room, and FCV-406B to control 30 m reference Calculation IP- 8 m Fire Area AFW-6 AFW flow to SGs CALC-04-00766.

Locally operate SGADV Support secondary system Actions performed in AFW Pump PCV-1134, PCV-1135, PCV- cooling to transition to RHR Building, Fire Area TBL-5 and are not 1136,1or PCV-1137 CV 4hu entry conditions (cold required until greater than 60 minutes 1136, or PCV-1137 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months shutdown transition action). 9 m following the start of the event, and the control secondary system Reference Calculation IP- fire is expected to be extinguished and cooldown CALC-06-00029. smoke adequately vented by that time Locally/manually backwash SW Pump strainer as Ensure selected SW Pump required if power to suction path is not impeded Action performed in SW Pump strainer strainer associated with >1 hour by excessive delta P of 15 m pit, Fire Area YARD-7 selected SW Pump is lost associated strainer (Use one of STR PMP-31 through STR PMP-36)

NL-09-032 Docket No. 50-286 Attachment 2 Page 42 of 42 TABLE 9 FIRE AREA YARD-7 CREDITED III.G.2 OPERATOR MANUAL ACTIONS Required Actual Required OMA Time to Basis Time to OMA Location and Comments Complete Complete Provide SW for cooling of CCW, Locally start ARDG to which is being used only for Actions performed in Fire Area supply MCC 312A in >1 hour cooling of Charging Pumps 25 m YARD-7 (ARDG) and in Fire Area support of the use of during hot shutdown. Reference TBL-5 (MCC-312A)

SWP-38 Calculation IP-CALC-06-00029.

Locally/manually backwash SW Pump Ensure selected SW Pump strainer as required if >1 hour suction path is not impeded by 15 m Action performed in SW Pump power to strainer excessive delta P of associated strainer pit, Fire Area YARD-7 associated with selected strainer SW Pump is lost

NL-09-032, Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

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Subject:

References:

Dear Sir or Madam:

2.0 BACKGROUND

5.0 REGULATORY ANALYSIS

6.0 CONCLUSION

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NL-09-032, Request for Exemption from 10 CFR 50, Appendix R, Paragraph III.G.2 for Use of Operator Manual Actions

Text

Subject:

References:

Dear Sir or Madam:

2.0 BACKGROUND

5.0 REGULATORY ANALYSIS

6.0 CONCLUSION

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