TMI-09-031, Request for Exemption from 10 CFR 50, Appendix R, Section Iii.G, Fire Protection of Safe Shutdown Capability.

Request for Exemption from 10 CFR 50, Appendix R, Section Iii.G, Fire Protection of Safe Shutdown Capability.

ML090630134
Person / Time
Site:	Three Mile Island
Issue date:	03/03/2009
From:	Cowan P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RIS-06-010, TMI-09-031
Download: ML090630134 (59)

Text

PI\ 19348 10 CFR 50.12 March 3, 2009 TMI-09-031 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555-0001 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Request for Exemption from 10 CFR 50, Appendix R, Section III.G, "Fire Protection of Safe Shutdown Capability"

Reference:

Regulatory Issue Summary (RIS) 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," dated June 30, 2006.

In accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) hereby requests an exemption from the provisions of 10 CFR 50, Appendix R, Section III.G, "Fire Protection of Safe Shutdown Capability," for the use of operator manual actions for Three Mile Island Nuclear Station, Unit 1 (TMI-1), in lieu of the requirements specified in Section III.G.2. This exemption is being requested in accordance with the requirements of 10 CFR 50.12(a)(2)(ii) since the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule.

Regulatory Issue Summary (RIS) 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," indicates that an approved exemption in accordance with the requirements of 10 CFR 50.12, is required for all operator manual actions credited for satisfying the requirements of 10 CFR 50, Appendix R, Section III.G.2. This exemption request is limited to those manual actions that were not included in a previous exemption request. Attachment 1 to this letter provides the detailed exemption request, including the basis for the exemption and the defense-in-depth review for each of the initiating fire areas for which a manual action is required. Attachment 2 provides operator manual action timelines.

This exemption request will not result in undue risk to the public health and safety because Exelon has determined that the subject manual actions are feasible and the NRC has already found similar manual actions to be acceptable for use in achieving post-fire safe shutdown.

The intent of 10 CFR 50, Appendix R, Section III.G.2, is to ensure that one train of systems necessary to achieve and maintain hot shutdown will remain available in the event of a fire. The manual actions discussed in this exemption request provide that assurance. If manual actions are not used to meet the underlying purpose of the rule, modifications to: 1) provide additional fire suppression systems, detection systems, or fire barriers, or 2) reroute cables or wrap

10 CFR 50.12 Exemption Request Operator Manual Actions Docket No. 50-289 March 3, 2009 Page 2 cables, that involve issues such as accessibility, dose, structural interferences, design limitations, ampacity derating, etc., would be required to achieve compliance. Such modifications represent an unwarranted burden on Exelon since they are not necessary to meet the underlying purpose of the rule. Therefore, the special circumstances for issuance of the exemption are satisfied in accordance with the requirements of 10 CFR 50.12(a)(2)(ii), since application of the rule is not necessary to achieve the underlying purpose of the rule. In addition, the requested exemption is authorized by law and is consistent with the common defense and security. As a result, the requirements of 10 CFR 50.12(a)(1) are satisfied.

This exemption request contains two new regulatory commitments as discussed in Attachment 1 and as shown in Attachment 3.

Information supporting the exemption request is contained in the attachments to this letter.

Exelon requests approval of this exemption request by March 3, 2010.

If you have any questions or require additional information, please contact Glenn Stewart at 610-765-5529.

Respectfully,

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Pamela B. Cowan Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Operator Manual Actions Exemption Request

2. Operator Manual Action Timelines

3. Summary of Regulatory Commitments cc: Regional Administrator - NRC Region I w/attachments NRC Senior Resident Inspector - TMI-1 II NRC Project Manager, NRR - TMI-1 Director, Bureau of Radiation Protection, PA Department of Environmental Protection Chairman, Board of County Commissioners, Dauphin County, PA Chairman, Board of Supervisors, II Londonderry Township, PA R. R. Janati, Commonwealth of Pennsylvania

10 CFR 50.12 Exemption Request Operator Manual Actions Docket No. 50-289 March 3, 2009 Page 3 bcc: Sr. Vice President, Mid-Atlantic Operations w/o attachments Sr. Vice President, Operations Support "

Vice President, Engineering "

Site Vice President-TMI-1 "

Plant Manager-TMI-1 "

Director, Operations-TMI-1 "

Director, Engineering "

Director, Site Engineering-TMI-1 "

Director, Site Training-TMI-1 "

Manager, Regulatory Assurance-TMI-1 '

Manager, Licensing - KSA3-E w/attachments G. Stewart - KSA3-E "

R. Sieglitz, TMI-1 B. Smith, TMI-1 "

C. Pragman, KSA2-N "

Commitment Coordinator - KSA 3-E "

Records Management - KSA 1-N-1 "

ATTACHMENT 1 10 CFR 50.12 Exemption Request Three Mile Island Nuclear Station, Unit 1 Docket No. 50-289 Request for Exemption from 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability" Operator Manual Actions Exemption Request

10 CFR 50.12 Exemption Request Page 1 of 43 Docket No. 50-289 ATTACHMENT 1 OPERATOR MANUAL ACTIONS EXEMPTION REQUEST I. SPECIFIC EXEMPTION REQUEST In accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) hereby requests an exemption from the requirements of 10 CFR 50, Appendix R (Reference 1),Section III.G, "Fire Protection for Safe Shutdown Capability," for Three Mile Island Nuclear Station, Unit 1 (TMI-1), to the extent that operator manual actions are necessary to achieve and maintain hot shutdown for fire areas/zones in which both trains of cables/equipment could be affected by the same fire. Table 1 contains the list of manual actions for which an exemption is being requested.

Background:

The criteria for granting specific exemptions from 10 CFR 50 regulations are specified in 10 CFR 50.12. In accordance with 10 CFR 50.12(a)(1), the NRC is authorized to grant an exemption upon determining that 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.

Regulatory Issue Summary (RIS) 2006-10 (Reference 2) documents the NRC position relative to the use of operator manual actions as part of a compliance strategy to meet the requirements of 10 CFR 50, Appendix R, Section III.G.2. The RIS states that plants which credit manual actions for Section III.G.2 compliance must obtain specific NRC approval for the manual action via the exemption process in accordance with the requirements of 10 CFR 50.12. This exemption request is limited to those manual actions that were not included in a previous exemption request, or were previously approved via an exemption but the basis for the original exemption has changed.

II. BASIS FOR EXEMPTION REQUEST This exemption request includes those operator manual actions credited for 10 CFR 50, Appendix R, Section III.G.2 compliance, which were not previously submitted to the NRC for review and approval, or were previously approved via an exemption but the basis for the original exemption has changed. The basis for this exemption request is the special circumstances cited in 10 CFR 50.12 (a)(2)(ii): "Application of the regulation in the particular circumstance would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." The intent of 10 CFR 50, Appendix R, Section III.G.2, is to ensure that one train of systems necessary to achieve and maintain hot shutdown will remain available in the event of a fire. The manual actions discussed in this exemption request provide that assurance.

If manual actions are not used to meet the underlying purpose of the rule, modifications to: (1) provide additional fire suppression systems, detection systems, or fire barriers, or (2) re-route cables or wrap cables, that involve issues such as accessibility, dose, structural interferences, design limitations, ampacity derating, etc., would be required to achieve compliance. Such modifications represent an unwarranted burden on Exelon since they are not necessary to meet the underlying purpose of the rule. Therefore, the special circumstances for issuance of the exemption are satisfied in accordance with the requirements of 10 CFR 50.12(a)(2)(ii), since application of the rule is not necessary to achieve the underlying purpose of the rule.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 2 of 43 Docket No. 50-289 This exemption request provides the documentation necessary to demonstrate the feasibility and reliability of the operator manual actions. As defined in NUREG-1852 (Reference 3), a "feasible action" is one "that is analyzed and demonstrated as being able to be performed within an available time so as to avoid a defined undesirable outcome." A "reliable action" is "a feasible action that is analyzed and demonstrated as being dependably repeatable within an available time, so as to avoid a defined adverse consequence, while considering varying conditions that could affect the available time and/or the time to perform the action." A final aspect of operator manual actions that will be addressed in this exemption request is defense-in-depth. Specifically, this aspect will consider the fire protection features such as detection, suppression, physical separation and combustible loading in the fire areas under consideration (i.e., the initiating fire area).

A. OVERVIEW OF OPERATOR MANUAL ACTIONS TMI-1 utilizes operator manual actions as part of the post-fire safe shutdown strategy for Appendix R compliance. The operator manual actions are listed in the TMI-1 Fire Hazards Analysis Report (FHAR) (Reference 4), which is part of the TMI-1 Updated Final Safety Analysis Report (UFSAR). This exemption request is limited to those manual actions that were not included in previous 10 CFR 50.12 exemption requests, or were previously approved via an exemption but the basis for the original exemption has changed.

The manual actions to isolate Reactor Coolant Pump (RCP) seal return (operator manual actions #9 and #10 in Table 1) are performed in support of an interim compensatory action strategy implemented to address recognition of the change in RCP seal response to a loss of all RCP seal cooling as described in Information Notice 2005-14 (Reference 5). The NUREG-1852 evaluation of these actions described in this exemption request is based upon the expected plant design basis prior to startup from the next refueling outage (scheduled in Fall 2009), which includes the following modifications:

1. Modification to prevent a fire from causing spurious opening of DH-V-6A or DH-V-6B, which are closed to prevent the Borated Water Storage Tank (BWST) from draining to the Reactor Building sump, and

2. Installation of fixed emergency lighting in the area of the operator manual action to close MU-V-189.

Ten (10) operator manual actions are addressed by this exemption request. The operator manual actions included in this exemption request can be divided into the following general categories based on the type of action taken. This list divides operator manual actions into single basic activities; some of the operator manual actions may be a combination of the basic activities:

- Circuit Breaker manipulation (trip [open] or close),

- Operating a single switch on a panel, and

- Manually operating a valve.

Table 1 at the end of this exemption request provides a concise list of the operator manual actions. These manual actions are required as a result of several changes from the original safe shutdown analysis, or were implied by the original safe shutdown analysis, where an exemption was not obtained. The following provides a brief discussion of why an exemption for each of these actions is being requested:

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 3 of 43 Docket No. 50-289

• Operator manual actions #1 and #3These manual actions involve opening breakers and manually correcting the position of High Pressure Injection (HPI) valves MU-V-16A/B/C/D and makeup pump recirculation valves MU-V-36/37 if an inadvertent Engineered Safeguards Actuation Signal (ESAS) occurs. An ESAS signal will open the HPI valves and close the makeup pump recirculation valves. This results in overfilling the pressurizer. The ESAS system is not required for safe shutdown; however, the consequences of an ESAS could complicate plant shutdown, and therefore, the manual actions described are needed to achieve a stable hot shutdown condition. These operator manual actions were implicitly credited in the original TMI safe shutdown analysis, but were not explicitly discussed in the TMI-1 FHAR or other NRC submittals.

• Operator manual action #2This manual action involves re-establishing makeup by opening a breaker and manually throttling an HPI valve, MU-V-16B, to maintain pressurizer level. This manual action is required because all remote-operated makeup flow paths could be affected by the fire. Makeup is required to maintain adequate subcooling margin in the Reactor Coolant System (RCS). An exemption does exist for this manual action (Reference 6); however, the required time has changed from the two hours as approved in the exemption to one hour. The 1-hour time is based on the potential for a loss of all RCP seal cooling. The consequence of a loss of all RCP seal cooling is increased leakage from the RCP seals. If all makeup is lost with this additional RCS leakage, pressurizer level will decrease at a faster rate. Analysis has been completed which demonstrates RCS inventory will remain adequate to support natural circulation with a loss of all makeup and increased seal leakage due to a loss of all RCP seal cooling if makeup is restored within one hour. This operator manual action was previously approved; however, the time requirement for the action has changed.

• Operator manual action #4This manual action involves opening a breaker and manually closing NR-V-4A or NR-V-4B as a result of spurious operation. These valves are normally closed; however, certain operating conditions dictate that NR-V-4B be opened and NR-V-4A be throttled. This action has been added due to the need to provide a safe shutdown strategy for those time periods when both valves are not closed at the onset of the fire event. Closing one of these valves allows for restoration of letdown.

• Operator manual actions #5 and #6These manual actions involve the cross-tie of the A train and B train station batteries before the vital AC buses are affected. Battery depletion of one station battery train is caused by a loss of AC power to the battery chargers. At least one train of DC power remains available without the cross-tie; however, these actions are needed to ensure the long-term availability of certain instruments fed from the battery with no available charger and to avoid an inadvertent ESAS actuation resulting from a loss of two vital buses. The station battery is designed for a minimum of two hours; therefore, action within two hours is required. ESAS logic is not required for safe shutdown; however, an inadvertent ESAS may complicate plant shutdown. These items were implicitly credited in the original TMI safe shutdown analysis, but were not explicitly discussed in the TMI-1 FHAR or other NRC submittals.

• Operator manual action #7This manual action involves operating a selector switch to start a makeup pump. A loss of all makeup could result from a loss of MU-P-1B. MU-P-1B is not directly affected by the fire, but a loss of offsite power (LOOP) will shut down the pump and action from outside the Control Room is required to restart the pump.

This pump cannot be started from the Control Room until a selector switch is manually

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 4 of 43 Docket No. 50-289 positioned. Therefore, manual action is required to restore makeup capability, which ensures adequate RCS inventory. This action was implicitly credited in the original TMI safe shutdown analysis, but was not explicitly discussed in the TMI-1 FHAR or other NRC submittals.

• Operator manual action #8This manual action involves opening a breaker and manually opening MU-V-36 to support maintaining a makeup pump minimum recirculation path. An exemption does exist for this manual action (Reference 6);

however, the required time has changed from the two hours as approved in the exemption to 40 minutes. The original two-hour requirement was based on the capability of the backup air supply to the seal injection valve MU-V-20 to maintain an available flow path. However, recent testing on the MU-V-20 backup air supply demonstrated that MU-V-20 would only stay open for approximately 75 minutes. Based on this testing, the design requirement for this function was conservatively changed to 40 minutes. Therefore, the time to open the feeder breaker and locally open MU-V-36 has been changed to 40 minutes. This operator manual action was previously approved; however, the time requirement has changed.

• Operator manual actions #9 and #10These manual actions involve closing manual valve MU-V-189 or removing instrument air from valve MU-V-26 to fail the valve closed.

Closing MU-V-189 or MU-V-26 is required to isolate seal return flow to the makeup tank.

These actions have been recently added due to changes in the TMI strategy for responding to a loss of RCP seal cooling. These actions are currently part of the interim compensatory actions for dealing with a loss of all RCP seal cooling; however, they will become part of the permanent design basis prior to startup from the next refueling outage. The loss of all RCP seal cooling results in increased seal return flow. The increased seal return flow will cause heatup of the makeup tank inventory, which may challenge continued operation of the makeup pumps. The time available to complete the action depends on the availability of the seal return coolers and HPI capability.

This section of the exemption request is organized in the following manner:

B. Fire Area/Zone Descriptions and Individual Operator Manual Action Descriptions C. Integrated Timelines for Operator Manual Actions D. Review of Operator Manual Actions Against NUREG-1852 E. Defense-in-Depth B. FIRE AREA/ZONE DESCRIPTIONS AND INDIVIDUAL OPERATOR MANUAL ACTION DESCRIPTIONS There are 19 initiating fire areas/zones included in this exemption request. An initiating fire area is the area where a fire that requires the manual action to be performed originates. A description of each fire area is provided below. This information provides a summary of the type of fires that are postulated to occur in each area and the type of combustibles located in each area. Detection and suppression systems that are installed in the fire area are also discussed.

The information provided was obtained from the TMI-1 FHAR, Chapter 4 and Attachments 3-0 through 3-7. The description of each initiating fire area below provides a discussion of the fire-affected component, the required operator manual action to be performed and the reason for the operator manual action. Each manual action in this exemption request is addressed independently in the discussion of each fire area/zone provided below, since many of the actions are mutually exclusive. However, the evaluation of multiple operator manual actions in

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 5 of 43 Docket No. 50-289 a fire area/zone is addressed in the Integrated Timelines for Operator Manual Actions section of this exemption request.

The FHAR defines a Fire Area and a Fire Zone as follows:

Fire Area - That portion of a building or plant that is separated from other areas by boundary fire barriers (walls, floors or roofs) with any opening or penetrations protected with seals or closures having a fire resistance rating equal to that of the barriers.

Fire Zones - Subdivisions of fire areas in which the fire suppression systems are designed to combat particular types of fires. The concept of fire zone aids in defining to the fire fighter the fire parameters and the actions that would be necessary.

Fire area and fire designations are in the format of XX-YY-ZZ where XX is the building such as Control Building (CB), Auxiliary Building (AB), etc., YY is either Fire Area (FA) or Fire Zone (FZ) as defined above, and ZZ is a combination of numbers and letters designating different specific fire areas or fire zones.

Fire Zone AB-FZ-1 Description Auxiliary Building elevation 271' is known as the Heat Exchanger Vault. It is 116 ft. long, by 60 ft.

wide, by 34 ft. high covering a total area of 6,900 ft2. Access to this fire zone is through the north wall.

The principal combustible in this zone is cable insulation with some transient material. The fire loading is low per the FHAR definition. Fire protection in the zone consists of smoke detection over cable trays, which alarms in the Control Room, a portable fire extinguisher, and a fire hose station.

Zone boundaries consist of reinforced concrete walls, floor, and ceiling. The south and west walls and the floor are not adjacent to any other plant areas. The upper portion of the east wall is adjacent to Fire Zone AB-FZ-5. The remainder is not adjacent to any other plant area. A portion of the north wall is adjacent to fire zone AB-FZ-5 via a stairwell. The ceiling is a 3-hour rated barrier.

This zone boundary is not relied on to protect redundant trains of safe shutdown equipment on either side of the boundary. The fire load within this zone is negligible; therefore, should a fire occur it would be of insufficient duration and intensity to propagate across the zone boundaries to adjacent zones.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone AB-FZ-1 is opening the breaker for and locally closing NR-V-4A or NR-V-4B. NR-V-4A and NR-V-4B (NR-V-4A/B) are both located in the 271 elevation of the Auxiliary Building (Fire Zone AB-FZ-1). The breakers for NR-V-4A and NR-V-4B are located in Fire Zones AB-FZ-6 and AB-FZ-6a, respectively.

This manual action is required because a fire in Fire Zone AB-FZ-1 could potentially cause spurious opening of NR-V-4A and cause NR-V-4B to fail in place (open), which would rapidly divert flow from the Nuclear River (NR) water system. NR-V-4A and NR-V-4B are series

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 6 of 43 Docket No. 50-289 butterfly valves used to control flow through the NR makeup line to the Circulating Water (CW) system. Normal NR system lineup during plant operation has both NR-V-4A and NR-V-4B closed. However, there are times when this line could remain open for a prolonged period to:

(1) maintain CW system inventory, or (2) provide minimum flow for proper NR pump operation to maintain Intermediate Closed (IC) cooling water and Nuclear Services (NS) closed cooling water temperatures. When this line is open, flow is controlled by throttling NR-V-4A with NR-V-4B full open. Control cables for both valves are located in this fire zone. A postulated fire could affect both cables such that NR-V-4A spuriously opens and NR-V-4B fails open. There are no immediate unrecoverable consequences to NR-V-4A and NR-V-4B being full open, as confirmed in safe shutdown analysis. However, local manual action to close one of these valves must be taken in sufficient time to support letdown restoration within four hours, as stated in the FHAR, when required for RCS pressure control.

Re-entry into Fire Zone AB-FZ-1 after the fire has been extinguished will be required for this manual action. In an SER dated December 30, 1986 (Reference 6), the ability to re-enter the initiating fire area/zone after one hour and manually operate a valve located in the fire area/zone was approved.

The worst-case scenario, which has the most potential manual actions ahead of this action in the timeline, is Fire Zone FH-FZ-1. The timeline for this manual action is shown in Attachment 2, Scenario #4. The time to complete this action is four hours. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately one hour and six minutes.

Since there are fewer required manual actions for a fire in Fire Zone AB-FZ-1, the Attachment 2, Scenario #4 timeline for FH-FZ-1 bounds the time for operators to respond to close NR-V-4A or NR-V-4B. The timeline includes a 1-hour delay for re-entering the zone prior to taking the action. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Zone AB-FZ-4 Description Auxiliary Building elevation 281' is known as the Penetration Area or Shielded Wall Area. The fire zone is 45 ft. long by 30 ft. wide by 23 ft. high covering a total area of 1,008 ft2. Entrance to this zone is through the east boundary, which is open to Fire Zone FH-FZ-1 and the west boundary, which is open to Fire Zone AB-FZ-5.

The principal combustible in this zone is cable insulation with some transient material. The fire loading is low per the FHAR definition. Fire protection for this zone consists of an automatic pre-action sprinkler system and a hose station. Smoke detection is provided which actuates alarms in the Control Room. Additional hose protection is provided in Fire Zone AB-FZ-5 and portable fire extinguishers are provided in Fire Zones AB-FZ-5 and FH-FZ-1.

A 3-hour rated fire barrier is provided on the south boundary, which is adjacent to Fire Zone AB-FZ-2a, and on the north boundary, which is adjacent to the Reactor Building. In addition, Fire Zone FH-FZ-1 is protected by an automatic wet pipe sprinkler system as well as a fire detection system, which alarms in the Control Room.

Within this fire zone there are fire rated barriers provided for circuits ranging from a rating of 39 minutes (min. required) to one hour. Rockbestos Fire Zone R cable is installed. Terminations at

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 7 of 43 Docket No. 50-289 Reactor Building penetration assemblies are provided with 1-hour fire rated protection. Should ignition of cable occur either electrically or due to transient combustibles, the boundary features prevent fire from propagating through the zone boundary.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone AB-FZ-4 is locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored. MU-V-189 is located in the Seal Return Cooler area on the 281 elevation of the Fuel Handling Building (FH-FZ-1).

This manual action is required because a fire in Fire Zone AB-FZ-4 may potentially result in a loss of all RCP seal cooling. If RCP seal cooling is not restored before seal temperatures exceed design temperature (235ºF), then RCP seal return flow to the makeup tank must be isolated to limit heatup of the makeup tank and to protect the makeup pumps from damage due to overheating. The seal return line must be isolated within 30 minutes from the time loss of all RCP seal cooling occurs (i.e., approximately 10 minutes until RCP seal temperature exceeds design and an additional 20 minutes before makeup pump fluid temperature could exceed design (150ºF)). All action times are referenced from the point at which the action would be directed, which is after seal temperatures reach 235ºF. In most cases, RCP seal return flow is isolated by locally closing the RCP seal return filter inlet isolation valve MU-V-189.

The technical basis for the 20-minute required action time is supported by two key variables, which may be affected in some fire areas. Both of these factors are credited to establish a 20-minute required action time.

1. Additional RCS makeup flow slows the rise in makeup pump fluid temperature by mixing cool water from the BWST into the makeup pump suction. Makeup flow must be raised by opening two HPI valves after RCP seal design temperature is exceeded to provide a seven-minute delay before makeup pump fluid temperature exceeds design.

2. The RCP seal return cooler may or may not be available to reduce the amount of energy injected into the makeup tank. The availability of the RCP seal return cooler provides a five-minute delay before makeup pump fluid temperature exceeds design.

There are three fire areas/zones that have specific variations in the time available to perform this manual action or in the valves operated to accomplish seal return isolation.

• In Fire Zone AB-FZ-6, the fire may prevent any HPI valve from opening from the Control Room. Therefore, the action time is reduced to 13 minutes for a fire in this fire zone.

• In Fire Area CB-FA-2b, both RCP seal return coolers may not be available due to initial loss of all NS pumps, which provide cooling water. Therefore, the action time is reduced to 15 minutes in this fire area.

The timeline for closing MU-V-189 is shown in Attachment 2, Scenario #2. This scenario was performed for Fire Zone AB-FZ-6, but bounds all other fire areas/zones where the MU-V-189 manual action is performed since AB-FZ-6 has the most limiting time requirement for this action. The time to complete this action is either 13 minutes (for Fire Zone AB-FZ-6), 15 minutes (for Fire Area CB-FA-2b), or 20 minutes for all other fire areas/zones. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 8 of 43 Docket No. 50-289

• In Fire Zone FH-FZ-1, RCP seal return flow is isolated by failing closed air-operated valve MU-V-26 and closing the air supply valve IA-V-1214. This action is taken since MU-V-189 is located in the fire zone.

The timeline for failing closed MU-V-26 and closing IA-V-1214 is shown in Attachment 2, Scenario #7. This scenario is specific to Fire Zone FH-FZ-1. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately five minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Zone AB-FZ-5 Description Auxiliary Building elevation 281' is known as the General Area - Elevation 281'-0". This fire zone is 110 ft. long, by 160 ft. wide, by 23 ft. high and covers an area of 14,303 ft2. Entrance to this zone is through the east boundary through Fire Zones FH-FZ-1 and AB-FZ-4.

The principal combustible in this zone is cable insulation. Other combustibles in this zone consist of pump lube oil and transient material. The bulk of this material is contained in evaporators and steel tanks. The fire loading is low per the FHAR definition. Fire protection for this zone consists of a fire extinguisher and a hose station. Additional hose protection is provided in Fire Zones AB-FZ-4 and FH-FZ-1 as well as additional portable fire extinguishers located in Fire Zone FH-FZ-1.

Smoke detection is provided in the hallway that provides entrance to Fire Zone AB-FZ-1 and in Fire Zone AB-FZ-1.

Should ignition of cable occur either electrically or due to transient combustibles, the boundary features prevent fire from propagating through the zone boundary. A 3-hour rated fire barrier is provided on the south wall of this zone adjacent to Fire Zone AIT-FZ-1. The north boundary is not adjacent to any other plant area. The east boundary adjacent to the Fuel Handling Building (Fire Zone FH-FZ-1) is constructed of reinforced concrete (note passage from the Auxiliary Building to the Fuel Handling Building is through an opening in this boundary); however, an automatic wet pipe sprinkler system is provided in Fire Zone FH-FZ-1. The boundary adjacent to Fire Zone AB-FZ-3 is reinforced concrete. The portion of the east boundary adjacent to Fire Zone AB-FZ-4 does not consist of wall construction; however, this portion of the boundary is protected by a fire detection system and an automatic pre-action sprinkler system in Fire Zone AB-FZ-4. The ceiling of this zone consists of reinforced concrete. The floor of this zone is not adjacent to any other plant area except over Fire Area AB-FA-1 where the floor is a 3-hour rated fire barrier with the exception of two 1/4-inch thick steel equipment access hatches and Decay Heat/Building Spray Shield Plugs, which are unrated over Fire Area AB-FA-1. The steel hatches are monitored daily to assure they are kept closed.

Due to the limited amount of combustible material in the zone, and the features described, existing fire protection for this zone is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone AB-FZ-5 are: (1) opening the breakers for and locally closing NR-V-4A or NR-V-4B, and (2) selecting makeup pump 1B (MU-P-1B) at the 1E 4160V switchgear. The selector switch for MU-P-1B is located on the 1E 4160V bus on the 338 elevation of the Control Building (CB-FA-3b).

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 9 of 43 Docket No. 50-289

1. NR-V-4A/B Manual Actions The NR-V-4A/B manual action has been previously discussed in Fire Zone AB-FZ-1.

Access to AB-FZ-1 may be blocked for one hour due to the fire in Fire Zone AB-FZ-5.

Therefore, the discussion for Fire Zone AB-FZ-1 applies for Fire Zone AB-FZ-5. The Attachment 2, Scenario #4 timeline also bounds this manual action in Fire Zone AB-FZ-5.

2. MU-P-1B Manual Action This manual action is required because on a LOOP, which is conservatively assumed concurrent with a fire in any fire area/zone, MU-P-1B is automatically tripped and the other two makeup pumps, MU-P-1A and MU-P-1C, may not be available due to the fire.

MU-P-1A may not be available due to loss of decay heat river water cooling support and MU-P-1C may not be available due to cable failure. In the normal system lineup, MU-P-1B cannot be started from the Control Room. Therefore, manual action is required to restore makeup capability, which ensures adequate RCS inventory. Analysis has been completed which demonstrates RCS inventory will remain adequate to support natural circulation with a loss of all makeup and increased seal leakage due to a loss of all RCP seal cooling if makeup is restored within one hour.

MU-P-1B may be started from the Control Room after an operator repositions a single local selector switch on the 1E 4160V switchgear. The selector switch is a two-position switch that is normally aligned to have MU-P-1C start automatically on an ESAS.

Fire Zone AB-FZ-5 represents the worst-case conditions for this manual action because of the potential for a loss of all RCP seal cooling, which causes a higher rate of RCS inventory loss. The timeline for this manual action is shown in Attachment 2, Scenario

1. 5. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 18 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Zone AB-FZ-6 Description Auxiliary Building elevation 305' is known as the Demineralizers and A Motor Control Center (MCC) Area. The fire zone is 124 ft. long, by 30 ft. wide, by 21 ft. high covering an area of 3,779 ft2. Entrance to this zone is through the east boundary through Fire Zone FH-FZ-1, the west boundary through Fire Zone AB-FZ-6a, and through Fire Zone AB-FZ-9. Class B labeled doors are provided between Fire Zones AB-FZ-6 and AB-FZ-6a.

The principal combustible in this zone is cable insulation and some transient material. The fire loading is low per the FHAR definition. The fire protection for this zone consists of smoke detection in the MCC areas which actuates alarms in the Control Room, cross-zoned smoke detection which actuates an automatic pre-action sprinkler system to provide a water curtain for the open passageway to Fire Zone AB-FZ-7 (alarms in Control Room upon actuation), a hose station located inside the MCC area and portable fire extinguishers near the entrance to the Fuel Handling Building. Additional hose protection and a portable fire extinguisher are located in Fire

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 10 of 43 Docket No. 50-289 Zone AB-FZ-9 Should ignition of cable occur either electrically or due to transient combustibles, the boundary features prevent fire from propagating through the zone boundary.

Zone boundaries consist of reinforced concrete walls, floor and ceiling. The south boundary and portion of the ceiling are not adjacent to any other plant areas. The remainder of the ceiling adjacent to the chemical addition area and Emergency Safeguards Features (ESF) Ventilation Room is a 3-hour fire barrier. Most of the north boundary is adjacent to Fire Zone AB-FZ-7 with an open passage between the zones. The open passage is provided with an automatic pre-action type water curtain actuated by a cross-zone type smoke detection system. All other openings are sealed with material having at least a 1-hour fire rating. The remainder of the north boundary is adjacent to the Reactor Building, which is a 3-hour rated fire barrier. The east boundary is adjacent to Fire Zones FH-FZ-1 and FH-FZ-2. A 3-hour rated fire barrier is provided on the floor where this zone is adjacent to Fire Zones AB-FZ-2a, AB-FZ-2b and AB-FZ-2c. An automatic pre-action system is located in Fire Zone AB-FZ-4 where the floor of this zone is adjacent to Fire Zone AB-FZ-4.

Due to the limited amount of combustible material in the zone, and the features described, existing fire protection for this zone is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone AB-FZ-6 are:

1. locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored,

2. opening the feeder breaker to the power supply for MU-V-36 and locally opening MU-V-36,

3. opening the feeder breakers for MU-V-36, MU-V-37, MU-V-16A and MU-V-16B, and locally opening MU-V-36 and MU-V-37 (MU-V-36/37), and closing MU-V-16A and MU-V-16B (MU-V-16A/B), and

4. opening the feeder breaker and locally throttling MU-V-16B.

MU-V-36/37 are located in Fire Zone AB-FZ-3. MU-V-16A/B are located in Fire Zone AB-FZ-4.

The power supply for MU-V-36 and MU-V-16A/B is the 1A 480V Engineered Safeguards Valves (ESV) Motor Control Center (MCC). Since this is located in Fire Zone AB-FZ-6, the feeder breaker for the MCC is opened to ensure power is removed. The feeder breaker is located in the 322 elevation of the Control Building (CB-FA-2a). The power supply for MU-V-37 is the 1B 480V ESV MCC, which is located in Fire Zone AB-FZ-6a. Since the fire may block access to this power supply, the feeder breaker for the MCC is opened to ensure power is removed. The feeder breaker is located in the 322 elevation of the Control Building (CB-FA-2b).

1. MU-V-189 Manual Action The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4. The only change is that the HPI valves may not be available from the Control Room.

Therefore, the required action must be taken within 13 minutes after RCP seal temperature exceeds design if a loss of all RCP seal cooling occurs. The timeline for this manual action is shown in Attachment 2, Scenario #2. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 11 of 43 Docket No. 50-289

2. MU-V-36 Manual Action MU-V-36 and MU-V-37 are motor operated isolation valves in series on the makeup pump recirculation line. A continuous flow path is required for makeup pump operation.

Makeup pump damage due to overheating would occur if the pump is operated without a sufficient flow path. A fire in Fire Zone AB-FZ-6 may cause failures that isolate the minimum recirculation line, the normal makeup flow path, and the emergency makeup flow path. If this occurs, then makeup pump damage is prevented by continuous seal injection flow. The fire may also cause a loss of instrument air. Seal injection flow is maintained through air-operated valve MU-V-20. MU-V-20 has a dedicated air reservoir that will keep the valve open. The makeup pump recirculation flow path must be restored or MU-V-20 blocked open for makeup pump protection before the MU-V-20 back-up air supply is depleted. Because access may be blocked to MU-V-20 in this fire zone, the action is taken to restore the makeup pump recirculation flow path.

An exemption currently exists based on the 1986 SER (Reference 6) for locally opening MU-V-36 within two hours. This required action time was based on the capacity of the MU-V-20 back-up air supply. Recent testing of the MU-V-20 back-up air supply demonstrated that MU-V-20 would only stay open for approximately 75 minutes. Based on this testing, the design requirement for this function was changed to 40 minutes.

Therefore, the time to open the 1A ESV MCC feeder breaker and locally open MU-V-36 has been changed to 40 minutes.

Prior to locally opening the valve, the power source must be de-energized. The power supply (1A ESV MCC) for MU-V-36 is located in Fire Zone AB-FZ-6. Therefore, to ensure the valve is de-energized, the upstream feeder breaker for the 1A ESV MCC is opened.

The ability to complete the required action within the revised required action time was validated. This is the only initiating fire area/zone where this action is required within 40 minutes. The timeline for this manual action is shown in Attachment 2, Scenario #6.

The time to complete this action is 40 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 19 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

3. MU-V-36/37 and MU-V-16A/B Manual Action This manual action is required because a fire in Fire Zone AB-FZ-6 may cause an inadvertent A train and B train ESAS due to instrument cable failures. ESAS will actuate HPI. The fire could additionally de-energize the power supplies for the HPI valves after the valves have traveled to the HPI position. This results in excessive RCS makeup and manual action is required to restore normal pressurizer function. Analysis has been performed which demonstrates that RCS pressure stays within acceptable limits indefinitely for a worst-case excessive makeup event. (i.e., all makeup pumps operating, and all four HPI valves are full open). Although there is no upper time limit required to perform this manual action, a prudent action time of one hour has been established to support the capability to establish normal RCS pressure control (i.e.,

return pressurizer level on scale and establish a pressurizer steam bubble) within a reasonable time.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 12 of 43 Docket No. 50-289 MU-V-16A/B/C/D are the emergency makeup or HPI valves. MU-V-16A/B are the A train valves and MU-V-16C/D are the B train valves. MU-V-36 (A train) and MU-V-37 (B train) are series minimum recirculation valves for the makeup pumps. MU-V-36/37 are closed when HPI is actuated.

Since both A train and B train power supplies that support these valves may be de-energized, all valves will require manual operation to terminate excessive makeup and restore the normal makeup system lineup. This involves re-opening MU-V-36 and MU-V-37 and re-closing MU-V-16A/B. MU-V-16C/D closure is not required to terminate flow since MU-P-1C may be shutdown from the Control Room. In addition to locally correcting the position of MU-V-36/37 and MU-V-16A/B, the breakers for these valves must be opened prior to manually operating the valves. Since the power supplies are located in the initiating fire zone, or access is blocked, the feeder breakers for the 1A ESV MCC and 1B ESV MCC will be opened.

The time validation for this manual action was performed for a fire in Fire Area CB-FA-1.

A fire in Fire Area CB-FA-1 represents the worst-case conditions for this manual action because this fire area has the most potential manual actions within the timeline. The timeline for this manual action is shown in Attachment 2, Scenario #1. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 40 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

4. MU-V-16B Manual Action A fire in Fire Zone AB-FZ-6 could cause all remote-operated makeup flow paths to be closed. An existing operator manual action to open the breaker and manually throttle MU-V-16B for makeup was previously approved in the 1986 SER (Reference 6).

However, recent analysis has shown that with a loss of all RCP seal cooling, makeup must be restored within one hour. No other changes are made to this action, and Attachment 2, Scenario #2 shows that the action is still completed with adequate margin.

This operator manual action involves manually opening the feeder breaker to the power supply, 1A ESV MCC, and throttling MU-V-16B to obtain makeup flow. Once some flow is established through MU-V-16B, the action requirement is met. With the makeup pump recirculation path open, which is done prior to taking this action, makeup flow is only required to maintain pressurizer level.

The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc) to perform this action is approximately 28 minutes. Valve position may be adjusted later as required. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

For subsequent throttling, if radio or phone communication with the Control Room is not available after initial instruction, the operator will manually adjust flow as directed by the Control Room at a later time. These subsequent adjustments do not require continuous communication; therefore, face-to-face communication with the Control Room is acceptable.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 13 of 43 Docket No. 50-289 Fire Zone AB-FZ-7 Description Auxiliary Building elevation 305' is known as Decay Heat Removal and Nuclear Service Closed Cycle Cooling Pump Area. The fire zone is 64 ft. long by 20 ft. wide, by 21 ft. high and covers an area of 1,196 ft2. Entrance to this zone is through an opening in the south wall.

The combustibles in this zone consist of pump lube oil contained in sumps, cable insulation and transient materials. The fire loading is low per the FHAR definition. Each pump is located in a reinforced concrete cubicle with front wall and ceiling openings to a common area. The safety related cables within this zone are located above the cubicles. Fire protection for this zone consists of smoke detection which actuates alarms in the Control Room, and cross zoned smoke detection which actuates an automatic pre-action sprinkler system to provide a water curtain for the open passageway to Fire Zone AB-FZ-6 that alarms in the Control Room upon actuation.

Hose protection is provided outside this fire zone in the MCC area of Fire Zone AB-FZ-6. Portable fire extinguishers are located in both Fire Zones AB-FZ-6 and AB-FZ-9.

Zone boundaries consist of reinforced concrete walls, floor and ceiling. The north boundary is not adjacent to any other plant area. The east boundary is adjacent to the Reactor Building, which is a 3-hour rated fire barrier. The west boundary is adjacent to Fire Zone AB-FZ-9. The south boundary is adjacent to Fire Zones AB-FZ-6, AB-FZ-6a, and AB-FZ-9. A rated fire damper is provided in the duct penetration in the zone boundary wall between Fire Zones AB-FZ-7 and AB-FZ-6a. The floor is adjacent to Fire Zones AB-FZ-4 and AB-FZ-5. An automatic pre-action system is located where the floor of this zone is adjacent to Fire Zone AB-FZ-4. A portion of the ceiling is not adjacent to any other plant areas. The remainder of the ceiling, adjacent to the ESF Ventilation Room, is a 3-hour fire barrier.

Due to the limited amount of combustible material in this zone, and the features described, existing fire protection for this zone is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone AB-FZ-7 is selecting MU-P-1B at the 1E 4160V switchgear.

This manual action has been previously discussed in Fire Zone AB-FZ-5. The only difference for this initiating fire zone is that both MU-P-1A and MU-P-1C are not available due to loss of decay heat river water cooling support, instead of cable failures. This does not impact the timeline in Attachment 2, Scenario #5. The Attachment 2, Scenario #5 timeline bounds this manual action in Fire Zone AB-FZ-7.

Fire Area CB-FA-1 Description The Control Building, Elevation 306 is known as the Control Building Health Physics and Lab Area. The area is 100 ft. long by 60 ft. wide and 15 ft. high. The area encompasses 6,000 ft2.

Entrance to this fire area is on the north and west walls through Class A fire doors. All four walls, ceiling and floor are all constructed of reinforced concrete with a 3-hour fire rating. The doors, penetrations, and ventilation dampers through these boundaries into this fire area also have a 3-hour fire rating. Exposed structural steel is also protected with an approved 3-hour rated fireproofing material.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 14 of 43 Docket No. 50-289 This fire area is provided with an active automatic ionization fire detection system above the suspended ceiling that will actuate alarms in the Control Room and an active wet pipe sprinkler system below the suspended ceiling. There is no false ceiling in the northeast corner of the area.

Should there be a fire in this area, the fire brigade can suppress the fire with extinguishers staged directly outside of this area, or attack the fire with hose lines from either of two directions. Estimated response time for the fire brigade to commence initial suppression is within 15 minutes.

Rated Thermo-Lag fire barriers in this fire area are provided for circuits ranging from a rating of 39 minutes (minimum required) to one hour. NRC letter dated April 20, 1999 (Reference 7) approved the exemption request on these barriers from the requirements of Section III.G.2.c for 1-hour fire barriers where circuits of redundant safe shutdown equipment in the same fire area are enclosed in a 1-hour fire barrier. These barriers were originally installed as 1-hour fire barriers; however, by comparison to accepted tests, the barriers included in the exemption request have fire ratings ranging from 39 to 50 minutes.

The combustibles in the area consist of stored and transient materials and cable insulation. The fire loading is low per the FHAR definition. Postulated fires are a Class A fire due to consuming the office supplies and office furniture or a Class C fire due to electrical cables burning. Most cable insulation in the area is qualified to IEEE 383 flame test; therefore, fires would be slow to develop and spread beyond the ignition source.

The results of the analysis indicate that the boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-1 are: (1) locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored, and (2) opening the breaker for and locally opening MU-V-36 followed by opening the breakers for and locally closing MU-V-16A/B.

1. MU-V-189 Manual Action The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4.

There are no changes to this action for this initiating fire zone. Note that MU-V-189 action is not shown on Attachment 2, Scenario #1, because pre-emptive actions to open IC-V-3 and IC-V-4 to prevent a loss of all RCP seal cooling take more time for Operator 2 than closing MU-V-189. If a loss of RCP seal cooling occurred, the MU-V-189 action would be performed in lieu of the IC-V-3 and IC-V-4 actions. Therefore, the Attachment 2, Scenario #2 timeline is applicable for this operator manual action since a loss of all RCP seal cooling was simulated. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 15 of 43 Docket No. 50-289

2. MU-V-36 and MU-V-16A/B Manual Action The pressurizer overfill event and time basis have been previously discussed for this action in Fire Zone AB-FZ-6. However, due to several differences of fire effects in this fire area, an additional discussion is provided.

This manual action is required because a fire in Fire Area CB-FA-1 may cause an inadvertent A train and B train ESAS due to instrument cable failures, which results in MU-V-16A/B/C/D opening and MU-V-36 and its series valve, MU-V-37, closing.

Furthermore, the fire could cause a loss of the two A train vital 120V buses (VBA and VBC), which prevents the A train ESAS from being defeated from the Control Room.

Therefore, manual action is needed to correct the ESAS to mitigate pressurizer overfill.

Since the B train ESAS can be defeated from the Control Room and the fire does not affect any MU-V-37 circuits, MU-V-37 can be re-opened from the Control Room.

Similarly, MU-V-16C/D can be closed or throttled from the Control Room. Therefore no manual action is required for these valves.

Since the A' train inadvertent ESAS cannot be defeated, the A train HPI valves, MU-V-16A/B, must be manually closed and the A train recirculation valve, MU-V-36, must be manually opened prior to closing both A train HPI valves. Additionally, the breakers for these valves must be opened prior to manually operating the valves. MU-V-36 should be opened and then MU-V-16A/B should be closed within one hour.

Fire Area CB-FA-1 represents the worst-case conditions for these manual actions because this fire area has the most potential manual actions within the timeline of these manual actions. The timeline for these manual actions is shown in Attachment 2, Scenario #1. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 40 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Area CB-FA-2a Description The 1P Switchgear Room is located on Control Building elevation 322'. This fire area is 49 ft.

long, by 18 ft. wide, by 15 ft. high and covers an area of 882 ft2. Entrance into this fire area is through Class A doors on the west and south walls.

The combustibles in the area consist of cable insulation, transients, and the electrical equipment.

The fire loading is low per the FHAR definition. Fire protection for this area consists of HVAC duct smoke detectors, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5. In addition portable fire extinguishers are provided in Fire Zone FH-FZ-5 and portable fire extinguishers are located in the Control Building stair tower.

The north and south walls are made of rated reinforced concrete as is the east wall with the exception of a 480V bus duct. The west wall is a rated metal panel wall excluding a 480V bus duct. The ceiling and floor are made of reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 16 of 43 Docket No. 50-289 All penetrations through walls, floors and ceilings of this fire area are sealed with 3-hour rated fire seals. All ventilation duct penetrations through these walls, floors and ceilings are provided with 3-hour rated fire dampers. The passively ventilated bus ducts are sealed around the outside periphery to a 3-hour rating. The bus duct internals are sealed with a non-fire rated smoke stop, adequate to prevent passage of smoke and hot gases.

The results of the analysis indicate that the boundaries of this fire area are adequate to contain a postulated fire. Due to the features described existing fire protection for this area is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2a are:

1. locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored,

2. opening the breaker for and locally opening MU-V-36 followed by opening the breakers for and locally closing MU-V-16A/B, and

3. performing a cross-tie to energize the A train DC system.

The manual actions for performing the DC cross-tie are located in the inverter and battery rooms (Fire Areas CB-FA-2d, CB-FA-2e, CB-FA-2f, and CB-FA-2g).

1. MU-V-189 Manual Action The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4.

There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #2 timeline bounds this operator manual action. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. MU-V-36 and MU-V-16A/B Manual Action The MU-V-36 and MU-V-16A/B manual action has been previously discussed in Fire Area CB-FA-1. There are no changes to this action for this initiating fire zone. The only difference is how the ESAS is initiated. There are no instrument effects; however, a loss of vital bus power to the ESAS relay cabinets could occur causing an inadvertent ESAS that cannot be defeated. The Attachment 2, Scenario #1 timeline bounds this manual action.

3. A Train DC Cross-Tie Manual Action This manual action is required because a fire in Fire Area CB-FA-2a may cause a loss of 1A Engineered Safeguards (ES) MCC 480V power. Each of the four 120VAC vital buses is supplied by a dedicated inverter, which can provide 120VAC from a 480VAC or 125VDC (station battery) source. If 1A ES MCC 480V bus is lost, the A & C inverters will draw power from the A station battery and continue to maintain the A & C vital buses energized for a minimum of two hours. After two hours, the A station battery voltage may be insufficient to maintain the A & C vital buses energized. Loss of both vital buses A &

C would significantly reduce critical instruments available and actuate ESAS.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 17 of 43 Docket No. 50-289 Therefore, manual action is required within two hours to cross-tie the A train main DC panel to the B train DC power to allow the A train to be continuously powered. A fire in Fire Area CB-FA-2a does not affect the B train battery or B battery chargers. The procedure for cross-tie includes de-energizing (opening DC fused switches) A and B train loads not required for safe shutdown prior to closing the main DC cross-tie.

The timeline for this manual action is shown for a fire in Fire Area CB-FA-3b in Attachment 2, Scenario #3. CB-FA-3b was chosen because it is representative of all areas, since all initiating fire areas for this action are similar with respect to preceding required actions. The time to complete this action is two hours. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 54 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Area CB-FA-2b Description The 1S Switchgear Room is located on Control Building elevation 322'. The area is 49 ft. long by 19 ft. wide and 15 ft. high. The floor area is 931 ft2. The fire area has a 3-hour fire rating design. The north and south walls as well as the floor and ceiling are constructed of reinforced concrete. The east and west walls are constructed of metal clad sheet rock walls with the exception of a 480V bus duct. Exposed structural steel is also protected with an approved 3-hour rated fireproofing material. Entrance to this fire area is on the east and west walls through Class A fire doors. All penetrations through walls, floors and ceilings of this fire area are sealed with 3-hour rated fire seals. All ventilation duct penetrations through these walls, floors and ceilings are provided with 3-hour rated fire dampers. The passively ventilated bus duct is sealed around the outside periphery to a 3-hour fire rating. The bus duct internal is sealed with a non-fire rated smoke stop, adequate to prevent passage of smoke and hot gases. One-hour rated barriers are provided for redundant safe shutdown circuits in this fire area.

Fire protection for this area consists of HVAC duct smoke detectors, which actuate smoke control dampers. NRC letter dated July 11, 1997 (Reference 8), granted exemption from the requirements of 10 CFR 50, Appendix R, Section III.G.2.c for an automatic suppression system in this fire area where circuits of redundant safe shutdown equipment in the same fire area are enclosed in a 1-hour rated fire barrier. These barriers were originally installed as 3-hour rated fire barriers. The request committed to augmenting the HVAC duct smoke detection system for this area by installing an area-wide (incipient) fire detection system. The incipient detection system alarms in the presence of incipient particles of combustion that occur below the ignition temperature of the combustible material, thus providing an early warning prior to the HVAC duct smoke detection system. Both systems actuate alarms in the Control Room.

Should there be a fire in this area, the fire brigade can suppress the fire with portable fire extinguishers staged nearby in the 322 elevation Control Building patio area, which is Fire Zone FH-FZ-5, and in the stair tower that provides access to the 322 elevation of the Control Building. The fire brigade can also attack the fire with hose lines located in Fire Zone FH-FZ-5 on the 322 elevation. The fire brigade is expected to reach the area and commence initial suppression activities within 15 minutes.

The combustibles in this area consist of cable insulation, electrical equipment, and minor transient materials. The fire loading is low per the FHAR definition. Most cable insulation in the

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 18 of 43 Docket No. 50-289 area is qualified to the IEEE 383 flame test; therefore, fires would be slow to develop and spread beyond the ignition source.

The results of the analysis indicate that the boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2b are:

1. locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored,

2. opening the breaker for and locally opening MU-V-36 or MU-V-37 followed by opening the breakers for and locally closing MU-V-16C and MU-V-16D (MU-V-16C/D), and

3. performing a cross-tie to energize the B train DC system.

MU-V-16C/D breakers are located in AB-FZ-6a, while the valves are located in AB-FZ-6. The manual actions for performing the DC cross-tie are located in the inverter and battery rooms (CB-FA-2d, CB-FA-2e, CB-FA-2f, and CB-FA-2g).

1. The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4. The only difference is that in this fire area, the seal return coolers may not be available due to the loss of all NS pumps. Therefore, the required action must be taken within 15 minutes of exceeding RCP seal design temperature if a loss of all RCP seal cooling occurs. The Attachment 2, Scenario #2 timeline bounds this operator manual action.

The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. The MU-V-36 or MU-V-37 and MU-V-16C/D manual action is very similar to the MU-V-36 and MU-V-16A/B action conditions discussed in Fire Area CB-FA-1. The reason for performing this operator manual action is discussed in Fire Zone AB-FZ-6. The only differences are the following:

• Either MU-V-36 or MU-V-37 could be affected by the fire (spuriously closes), which results in the inability to re-open the valve from the Control Room,

• Both A and B train ESAS can be defeated since both 'A' train and B train vital power is maintained (see manual action #3), and

• A train HPI valves (MU-V-16A/B) are available to be controlled from the Control Room, while B train HPI valves (MU-V-16C/D) are assumed to require manual closure after an inadvertent ESAS, due to fire damage being postulated to their control circuits after they adopt their ES position.

The timeline for this manual action is shown for a fire in Fire Area CB-FA-3b in Attachment 2, Scenario #3. Fire Area CB-FA-3b was chosen because it is representative of all areas, since all initiating fire areas for this action are similar with respect to preceding required actions. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 35 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 19 of 43 Docket No. 50-289

3. The B train DC cross-tie manual action is very similar to the A train DC cross-tie manual action discussed in Fire Area CB-FA-2a. The only difference is that the B DC train is powered instead of the A DC train. The procedure for energizing the B DC train is also shorter since it does not include transfer of any non-vital buses, which is performed in the A train DC cross-tie procedure. Therefore the Attachment 2, Scenario

1. 3 timeline is conservative and bounds this manual action.

Fire Area CB-FA-2c Description The Control Building Technical Support Center Area is located on Control Building elevation 322'.

This fire area is 49 ft. long, by 22 ft. wide, by 15 ft. high and covers an area of 1078 ft2. Entrance to this fire area through the south, east, and west is through Class A rated doors. Entrance to the north wall via the Control Building stair tower is through a Class B rated door.

Combustibles in this area consist of cable insulation and transient and stored materials. The fire loading is low per the FHAR definition. The fire protection for this area consists of HVAC duct smoke detectors and an area wide incipient fire detection system, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5. In addition, portable fire extinguishers are provided in Fire Zone FH-FZ-5 and portable fire extinguishers are provided in the Control Building stair tower.

The north, south, and west walls are rated reinforced concrete. The east wall is a rated metal wall. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing. All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. One-hour rated barriers are provided for circuits.

The results of the analysis indicate that boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Actions The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2c is opening the breaker for and locally opening MU-V-37 followed by opening the breakers for and locally closing MU-V-16C/D.

The MU-V-37 and MU-V-16C/D manual action is very similar to the MU-V-36 and MU-V-16A/B action discussed in Fire Area CB-FA-1. The only differences are that A train HPI valves (MU-V-16A/B) are available to be controlled from the Control Room, while B train HPI valves (MU-V-16C/D) are manually closed and the MU-V-37 is manually re-opened instead of the MU-V-36.

The Attachment 2, Scenario #3 timeline bounds this manual action.

Fire Area CB-FA-2d Description The Control Building East Battery Charger Area is located on Control Building elevation 322'. This fire area is 24 ft. long, by 30 ft. wide, by 15 ft. high and covers an area of 720 ft2. Entrance to this fire area is on the north, south and west walls through Class A rated doors.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 20 of 43 Docket No. 50-289 The combustibles in this area consist of cable insulation, transient materials and the electrical equipment. The fire loading is low per the FHAR definition. Fire protection for this area consists of HVAC duct smoke detectors and an area wide incipient fire detection system, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5.

In addition a portable fire extinguisher is located inside this fire area and in adjacent areas.

The north and east walls are rated reinforced concrete. The south and west walls are rated metal walls. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. One-hour rated barriers are provided for circuits.

The results of the analysis indicate that boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Action The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2d are: (1) locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored, and (2) opening the breaker for and locally opening MU-V-36 followed by opening the breakers for and locally closing MU-V-16A/B.

1. The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4.

There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #2 timeline bounds this manual action. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. The MU-V-36 and MU-V-16A/B manual action has been previously discussed in CB-FA-

1. There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #1 timeline bounds this manual action.

Fire Area CB-FA-2e Description The Control Building West Battery Charger Area is located on Control Building elevation 322'. This fire area is 24 ft. long, by 30 ft. wide, by 15 ft. high and covers an area of 720 ft2. Entrance to this fire area is on the north, south and east walls through Class A rated doors.

The combustibles in this area consist of cable insulation, electrical equipment and transient materials. The fire loading is low per the FHAR definition. Fire protection for this area consists of HVAC duct smoke detectors and an area wide incipient fire detection system, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5.

In addition, a fire extinguisher is located inside this fire area and portable fire extinguishers are located in adjacent areas.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 21 of 43 Docket No. 50-289 The north and west walls are rated reinforced concrete. The south and east walls are rated metal walls. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. One-hour rated barriers are provided for circuits.

The results of the analysis indicate that boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2e is opening the breaker for and locally opening MU-V-37 followed by opening the breakers for and locally closing MU-V-16C/D.

The MU-V-37 and MU-V-16C/D manual action is very similar to the MU-V-36 and MU-V-16A/B action discussed in Fire Area CB-FA-1. The only differences are that:

• A train HPI valves (MU-V-16A/B) are available to be controlled from the Control Room, while B train HPI valves (MU-V-16C/D) are manually closed,

• MU-V-37 is manually re-opened instead of the MU-V-36, and

• ESAS may be initiated from a loss of 'B' train vital buses with the inability to defeat the B train ESAS.

The Attachment 2, Scenario #3 timeline bounds this manual action.

Fire Area CB-FA-2f Description The Control Building East Battery Room Area is located on Control Building elevation 322'. This fire area is 24 ft. long, by 30 ft. wide, by 15 ft. high and covers an area of 720 ft2. Entrance to this fire area is on the north and west walls through Class A rated doors.

Combustibles in this area consist of cable insulation, transient materials and battery cases. The fire loading is low per the FHAR definition. Fire protection for this area consists of HVAC duct ionization smoke detection and an area wide incipient fire detection system that both actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5.

In addition portable extinguishers are located in adjacent areas. The ventilation system is equipped with a loss of flow switch, which provides an alarm in the Control Room. The alarm response outlines actions to prevent any hydrogen accumulation in the battery room.

The south and east walls are rated reinforced concrete. The north and west walls are rated metal walls. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. One-hour barriers are provided for circuits.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 22 of 43 Docket No. 50-289 The results of the analysis indicate that boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2f are: (1) locally closing MU-V-189 on a loss of all RCP seal cooling that cannot be restored, and (2) opening the breaker for and locally opening MU-V-36 followed by opening the breakers for and locally closing MU-V-16A/B.

1. The MU-V-189 manual action has been previously discussed in Fire Zone AB-FZ-4.

There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #2 timeline bounds this manual action. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. The MU-V-36 and MU-V-16A/B manual action has been previously discussed in Fire Area CB-FA-1. There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #1 timeline bounds this manual action.

Fire Area CB-FA-2g Description The Control Building West Battery Room Area is located on Control Building elevation 322'. This fire area is 24 ft. long, by 30 ft. wide, by 15 ft. high and covers an area of 720 ft2. Entrance to this fire area is on the north, west and east walls through Class A rated doors.

Combustibles in this area consist of cable insulation, transient materials and battery cases. The fire loading is low per the FHAR definition. Fire protection for this area consists of HVAC duct ionization smoke detection and an area wide incipient fire detection system that both actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5.

In addition, portable extinguishers are located in adjacent areas. The ventilation system is equipped with a loss of flow switch, which provides an alarm in the Control Room. The alarm response outlines actions to prevent hydrogen accumulation in the battery room.

The south and west walls are rated reinforced concrete. The north and east walls are rated metal walls. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. One-hour barriers are provided for circuits.

The results of the analysis indicate that boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 23 of 43 Docket No. 50-289 Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-2g is opening the breaker for and locally opening MU-V-37 followed by opening the breakers for and locally closing MU-V-16C/D.

The MU-V-37 and MU-V-16C/D manual action is very similar to the MU-V-36 and MU-V-16A/B action discussed in Fire Area CB-FA-1. The only differences are that:

• A train HPI valves (MU-V-16A/B) are available to be controlled from the Control Room, while B train HPI valves (MU-V-16C/D) are manually closed,

• MU-V-37 is manually re-opened instead of the MU-V-36, and

• ESAS may be initiated from a loss of 'B' train vital buses with the inability to defeat the B train ESAS.

The Attachment 2, Scenario #3 timeline bounds this manual action.

Fire Area CB-FA-3a Description The 4160V Switchgear 1D Area is located on Control Building elevation 338-6. This fire area is 49 ft. long, by 18 ft. wide, by 16 ft. high and covers an area of 882 ft2. Entrance to this fire area is through the south and west walls through Class A rated doors.

The combustibles in this area consist of cable insulation, and the electrical equipment. The fire loading is low per the FHAR definition. The fire protection for this area consists of HVAC duct smoke detectors and an area wide incipient fire detection system, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5. In addition, portable extinguishers are located in adjacent areas.

The north and south walls are rated reinforced concrete. The east wall is also a rated reinforced concrete wall except for a 4160V bus duct. The west wall is a rated metal panel wall except for a 4160V bus duct. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing. A vertical duct chase (approximately 10 X 10) located in the northeast corner of this fire area (CB-FA-3a) extends upward to the Control Building North H&V Equipment Area located on the 380 Elevation (CB-FZ-5a). The entire length of this duct chase is considered part of CB-FA-3a, and consists of 3-hour rated sheetrock construction.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All ventilation duct penetrations through these walls, ceilings and floors are provided with 3-hour rated fire dampers. The passively ventilated bus ducts are sealed around the outside periphery to a 3-hour rating. The bus duct internals are sealed with a non-fire rated smoke stop, adequate to prevent the passage of smoke and hot gases. One-hour rated barriers are provided for circuits.

The results of the analysis indicate that the boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-3a is performing a cross-tie to energize the A train DC system.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 24 of 43 Docket No. 50-289 This manual action has been previously discussed in Fire Area CB-FA-2a. There are no changes to this action for this initiating fire zone. The Attachment 2, Scenario #3 timeline bounds this manual action.

Fire Area CB-FA-3b Description The 4160V Switchgear 1E Area is located on Control Building elevation 338-6. This fire area is 49 ft. long, by 18 ft. wide, by 16 ft. high and covers an area of 882 ft2. Entrance to this area is through the east and west walls through Class A rated doors. The southwest Class A door is permanently locked shut and therefore provides no means of egress.

The combustibles in this area consist of cable insulation, electrical equipment and transient material. The fire loading is low per the FHAR definition. The fire protection for this area consists of HVAC duct smoke detectors and an area wide incipient fire detection system, which actuate alarms in the Control Room. Hose protection is provided outside this area in Fire Zone FH-FZ-5. In addition, portable extinguishers are located in adjacent areas.

The north and south walls are rated reinforced concrete. The west wall is a rated metal panel wall as is the east wall except for a 4160V bus duct. The west wall is a rated metal panel wall except for a 4160V bus duct. The ceiling and floor are both rated reinforced concrete. Exposed steel columns and beams are covered with fireproofing.

All penetrations through walls, ceilings and floors of this fire area are sealed with 3-hour rated fire seals. All ventilation duct penetrations through the walls, ceilings and floors are provided with 3-hour rated fire dampers. The passively ventilated bus ducts are sealed around the outside periphery to a 3-hour rating. The bus duct internals are sealed with a non-fire rated smoke stop, adequate to prevent the passage of smoke and hot gases. One-hour rated barriers are provided for circuits.

The results of the analysis indicate the boundaries of this fire area are adequate to contain a postulated fire. Due to the features described, existing fire protection for this area is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Area CB-FA-3b are: (1) opening the breaker for and locally opening MU-V-37 followed by opening the breakers for and locally closing MU-V-16C/D, and (2) performing a cross-tie to energize the B train DC system.

1. The MU-V-37 and MU-V-16C/D manual action has been previously discussed in Fire Area CB-FA-2b. There are no changes to this action for this initiating fire zone. The timeline for these manual actions is shown in Attachment 2, Scenario #3. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 35 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. The manual action to perform the cross-tie to energize the B train DC system has been previously discussed in Fire Area CB-FA-2a. There are no changes to this action for this

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 25 of 43 Docket No. 50-289 initiating fire zone. The timeline for these manual actions is shown in Attachment 2, Scenario #3. The time to complete this action is one hour. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately 54 minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Zone FH-FZ-1 Description Fuel Handling Building elevation 281 is known as the Fuel Handling Building Basement. This fire zone is 54 ft. long, by 114 ft. wide, by 23 ft. high and covers an area of 6,805 ft2. Entrance to this fire zone is through an open stairwell in the southwest corner of this zone, which provides access from Fire Zone FH-FZ-2. The west boundary is open to Fire Zones AB-FZ-4 and AB-FZ-5. The wall common to Fire Zone IB-FZ-8 contains a non-rated steel door.

The combustibles in this zone consist of pump lube oil, transient materials, and cable insulation.

The fire loading is low per the FHAR definition. Fire protection for this zone consists of an automatic wet pipe sprinkler system which protects the entire floor and cable trays on elevation 281'-0", a fire hose station, and ionization smoke detection which actuates alarms in the Control Room. Portable fire extinguishers and additional hose protection are provided in Fire Zones AB-FZ-1 and AB-FZ-5.

Zone boundaries consist of reinforced concrete walls, floor and ceiling. Most of the east boundary is not adjacent to any other plant area except for a 3-hour rated fire barrier adjacent to Fire Zone IB-FZ-8, which contains a non-rated steel door, and a non-fire rated boundary adjacent to Fire Zone FH-FZ-6. The north boundary is adjacent to the Reactor Building, which is a 3-hour fire rated barrier. Containment penetrations do not have a specific fire rating due to overriding nuclear considerations, however their construction is adequate to prevent the spread of fire to the Reactor Building. The south and west boundary is adjacent to Fire Zones AIT-FZ-1, AIT-FZ-1a, AB-FZ-3, AB-FZ-4 and AB-FZ-5. An open passage exists between this zone and Fire Zone AB-FZ-5 and the boundary between this zone and Fire Zone AB-FZ-4 does not consist of wall construction. The boundaries adjacent to Fire Zones AB-FZ-3 and AIT-FZ-1 also contain unprotected openings; however, this zone (FH-FZ-1) is equipped with an automatic wet pipe sprinkler system. The floor of this zone is not adjacent to any other plant area. The ceiling of this zone is adjacent to Fire Zones FH-FZ-2 and FH-FZ-4. Note that FH-FZ-4 is the fuel pool. Rated fire barriers are provided for circuits ranging from a rating of 39 minutes (minimum required) to one hour. Rockbestos Fire Zone R cable is installed.

Due to the low fire loading in this zone and the features described, existing fire protection for this zone is considered adequate.

Manual Actions The manual actions for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone FH-FZ-1 are:

1. isolating seal return by failing closed MU-V-26 and closing IA-V-1214,

2. opening the breakers for and locally closing MU-V-16A/B,

3. opening the breaker for and locally closing NR-V-4A or NR-V-4B.

MU-V-26 and IA-V-1214 are located in the 305 elevation of the Fuel Handling Building (Fire Zone FH-FZ-2).

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 26 of 43 Docket No. 50-289

1. Since MU-V-189 is located in Fire Zone FH-FZ-1, an alternate manual action to isolate seal return is required for a fire in Fire Zone FH-FZ-1. Therefore, MU-V-26, an air-operated valve located in Fire Zone FH-FZ-2, can be used to isolate the seal return line from the makeup tank. MU-V-26 fails closed on a loss of instrument air; however, it has a local accumulator. Therefore, manual action is taken to remove the air directly at the valve diaphragm via a petcock (i.e., downstream of the accumulator). This will immediately relieve the air pressure and close the valve. The upstream instrument air supply valve IA-V-1214 is also closed to ensure additional air is not supplied to the valve. The required action time is 20 minutes.

The timeline for this manual action is shown in Attachment 2, Scenario #7. The time to complete this action is 20 minutes. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately five minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

2. The MU-V-16A/B manual action has been previously discussed in Fire Area CB-FA-1.

The only difference is that no action is required to re-open MU-V-36 since the A Train ESAS can be defeated and the fire does not affect any MU-V-36 circuits. Therefore, MU-V-36 can be opened from the Control Room. The Attachment 2, Scenario #1 timeline bounds this manual action.

3. The NR-V-4A/B manual action has been previously discussed in Fire Zone AB-FZ-1. In this fire zone, access to AB-FZ-1 may be blocked for one hour due to the fire. The timeline for this manual action is shown in Attachment 2, Scenario #4. The time to complete this action is four hours. The actual integrated time (including diagnosis time, travel time, access time, etc.) to perform this action is approximately one hour and six minutes. This demonstrates that the action can be feasibly and reliably performed in the required time limit.

Fire Zone FH-FZ-5 Description The Control Building Patio Area is located on Fuel Handling Building elevations 322'-0", 338'-6",

355'-0" and 380'-0". This fire zone is 121 ft. long, by 20.4 ft. wide, by 80 ft. high and covers an area of 2,468 ft2. Each elevation, except elevation 322'0" which is rated concrete, consists of steel grating. An instrument shop is located on the south side of elevation 355-0 of this fire zone.

The construction of the instrument shop is non-combustible (structural steel, metal studded walls and partitions with gypsum wall board).

Entrance to this fire zone is as follows:

Elevation 322'-0" provides three class A rated doors on the east wall.

Elevation 338'-6" provides two class A rated doors and one class B rated door on the east wall.

Elevation 355'-0" provides one class A rated door and one class B rated door on the east wall.

Elevation 380'-0" provides one class B rated door and two open wall sections in the east wall.

The combustibles in this zone consist of cable insulation, transient and stored materials. The fire loading is medium per the FHAR definition. Fire protection for this zone consists of two fire hose stations on each elevation except elevation 380'-0" which is provided with one fire hose station.

Portable fire extinguishers are located on elevations 322'-0", 338'-6, and on elevation 355'-0".

Additional portable fire extinguishers are provided inside the stairwell on elevation 380'-0". The

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 27 of 43 Docket No. 50-289 Instrument Shop and office facilities are provided with a combination of area and HVAC duct smoke detectors.

Zone boundaries consist of reinforced concrete walls, floor, and ceiling. The north and south boundaries are 3-hour fire rated barriers. The west boundary is adjacent to Fire Zones FH-FZ-2 and FH-FZ-4. The east boundary is a 3-hour rated fire barrier except on elevation 380' adjacent to Fire Zones CB-FZ-5a and CB-FZ-5b. A major portion of the east boundary adjacent to CB-FZ-5a and 5b consists of reinforced concrete. The wall of Fire Zones CB-FZ-5a and CB-FZ-5b does not separate redundant safe shutdown equipment. This zone boundary analysis is considered valid even though the combustible loading in Fire Zone FH-FZ-5 exceeds 40,000 BTU/sq. ft. because the concentrations of class A combustibles are situated on elevation 355'-0".

Combustibles in cable tray are situated primarily at elevation 350' and the remainder of combustibles are located below El. 350 (Instrument Shop & Repair Facilities). The floor is adjacent to Fire Zone FH-FZ-2; however, Fire Zone FH-FZ-2 is provided with an automatic wet pipe sprinkler system where adjacent to Fire Zone FH-FZ-5. The ceiling is not adjacent to any other plant areas. Three-hour fire rated barriers are provided for circuits.

Based on the medium combustible loading in this zone, and the features described, existing fire protection for this zone is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone FH-FZ-5 is opening the breakers for and locally closing MU-V-16C/D.

The MU-V-16C/D manual action has been previously discussed in CB-FA-2b. The only difference is that no action is required to re-open MU-V-37 since the B Train ESAS can be defeated and the fire does not affect any MU-V-37 circuits. Therefore, MU-V-37 can be opened from the Control Room. The Attachment 2, Scenario #3 timeline bounds this manual action.

Fire Zone ISPH-FZ-1 Description The 1R Switchgear Area is located on Intake Screen and Pump House elevation 308. This fire zone is 48 ft. long, by 42 ft. wide, by 21 ft. high and covers an area of 2,016 ft2. Entrance to this fire zone is through a Class A door on the south wall and a normally closed Class A roll-up door in the north wall. Non-maintained Class A roll-up and personnel doors provide entrance on the west wall.

The combustibles in this area consist of lube oil, cable insulation and transient materials. The fire loading in this zone is low per the FHAR definition. Fire protection for this zone consists of an automatic wet pipe sprinkler system that will alarm in the Control Room upon actuation and portable fire extinguishers. In addition a portable fire extinguisher is located in Fire Zone ISPH-FZ-3. Hose protection is available from a yard hydrant located outside the building. An ionization smoke detection system will actuate alarms in the Control Room.

Zone boundaries consist of reinforced concrete walls, floor and ceiling. The north boundary is a 3-hour rated fire barrier with the exception of ventilated (passive) bus duct internals penetrating the barrier. All other penetrations in this wall are controlled and maintained with 3-hour rated fire seals. Since automatic suppression is provided on both sides of the barrier, the bus ducts do not adversely affect the barrier rating. The east and south boundaries and the ceiling are not adjacent

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 28 of 43 Docket No. 50-289 to any other plant areas. The floor is adjacent to the intake pit. The intake pit is not considered a fire zone or area; however, this boundary is considered adequate because a full automatic wet pipe suppression system is present on Fire Zone ISPH-FZ-1. The west boundary is adjacent to Fire Zone ISPH-FZ-3. The automatic wet pipe suppression system on both sides of the west boundary is sufficient to preclude conflagration through the zone boundary. The boundary penetrations are not required to be sealed. Rated fire barriers are provided for circuits ranging from a rating of 39 minutes (minimum required) to one hour. Rockbestos Fire Zone R cable is installed.

Due to the low fire loading in this zone, and the features described, existing fire protection is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone ISPH-FZ-1 is selecting MU-P-1B at the 1E 4160V switchgear.

This manual action has been previously discussed in Fire Zone AB-FZ-5. The only difference for this initiating fire zone is that MU-P-1A and MU-P-1C are not available due to loss of decay heat river water cooling support, instead of cable failures. The Attachment 2, Scenario #5 timeline bounds this manual action.

Fire Zone ISPH-FZ-2 Description The 1T Switchgear Area is located on Intake Screen and Pump House elevation 308. This fire zone is 48 ft. long, by 42 ft. wide, by 21 ft. high and covers an area of 2,016 ft2. Entrance to this fire zone is through two door openings on the west wall and a normally closed Class A roll-up door in the south wall.

The combustibles in this area consist of lube oil, cable insulation and transient materials. The fire loading in this zone is low per the FHAR definition. Fire protection for this zone consists of an automatic wet pipe sprinkler system that will alarm in the Control Room upon actuation and a portable fire extinguisher. In addition, a portable fire extinguisher is located in Fire Zone ISPH-FZ-3 and fire extinguishers are located in Fire Zone ISPH-FZ-1. Hose protection is available from a yard hydrant located outside the building. Area ionization smoke detection is installed which actuates alarms in the Control Room.

Zone boundaries consist of reinforced concrete walls, floor and ceiling. The north boundary is a 3-hour fire rated barrier where adjacent to Fire Area ISPH-FA-2; the remainder is not adjacent to any other plant area. The south boundary is a 3-hour rated fire barrier with the exception of the ventilated (passive) bus duct internals penetrating the barrier. All other penetrations in this wall are controlled and maintained with 3-hour fire rated seals. Since automatic suppression is provided on both sides of the barrier, the bus duct does not adversely affect the barrier integrity.

The east boundary and the ceiling are not adjacent to any other plant areas. The floor is adjacent to the intake pit. The intake pit is not considered a fire zone or area; however, this boundary is considered adequate because a full zone automatic wet pipe suppression system is present in Fire Zone ISPH-FZ-2. The west boundary is adjacent to Fire Zone ISPH-FZ-3 with two open passageways. The automatic wet pipe suppression system on both sides of the west boundary is sufficient to preclude conflagration through the zone boundary. The boundary penetrations are

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 29 of 43 Docket No. 50-289 not required to be sealed. Rated fire barriers are provided for circuits ranging from a rating of 39 minutes (minimum required) to one hour. Rockbestos Fire Zone R cable is installed.

Due to the low fire loading in this zone, and the features described, existing fire protection is considered adequate.

Manual Action The manual action for which a 10 CFR 50, Appendix R, Section III.G.2 exemption is being requested as a result of a fire in Fire Zone ISPH-FZ-2 is selecting MU-P-1B at the 1E 4160V switchgear.

This manual action has been previously discussed in Fire Zone AB-FZ-5. The only difference for this initiating fire zone is that MU-P-1A and MU-P-1C are not available due to loss of decay heat river water cooling support, instead of cable failures. The Attachment 2, Scenario #5 timeline bounds this manual action.

C. INTEGRATED TIMELINES FOR OPERATOR MANUAL ACTIONS All of the operator manual actions described in this exemption request were simulated and walked down with several different operators to support reliability. Additionally, other previously approved or non-credited pre-emptive manual actions that may be performed in the selected fire areas/zones were also simulated and walked down to derive integrated timelines, as shown in . The purpose of this approach was to get an accurate simulation of the time margin to perform each operator manual action in this exemption request, considering the worst-case fire affects for a particular fire safe shutdown concern that could challenge operator response. Each manual action presented in Table 1 is required to address a particular safe shutdown concern. Examples of fire safe shutdown concerns are: (1) mitigate pressurizer overfill, isolate RCP seal return on a loss of all RCP seal cooling that cannot be restored, ensure makeup pump minimum recirculation flow path, etc. The most limiting fire areas/zones, with respect to required operator manual actions for each of these concerns, was analyzed in the timelines. In most cases, safe shutdown concerns are mutually exclusive; therefore, all the operator manual actions for a particular fire area/zone are not required simultaneously. For example, in several fire areas/zones, a loss of RCP seal cooling and pressurizer overfill are possible concerns that are addressed by separate manual actions.

However, both concerns could not occur simultaneously. Therefore, the manual actions to address both concerns are not taken simultaneously. Since each operator manual action has several initiating fire areas/zones, the selected fire areas/zones in Attachment 2 were intended to represent the most limiting fire areas/zones for operator response to the targeted operator manual action in this exemption request. These timelines provide conservative times for diagnosing the need to perform the operator manual action, since the scenarios involve several simultaneous failures due to a fire to which the operators must respond. Operator dispatch was also simulated for each timeline to ensure that no overlap occurred for each manual action.

That is, if Auxiliary Operator (AO) 1 was performing one task, the Control Room would wait until AO1 reported back that the action was completed before assigning AO1 another task. This was accurately simulated with two AOs and a reactor operator (RO), where required. See Section II.D.10 of this exemption request for required operator staffing. Where multiple walk downs of the operator manual action occurred, the worst-case times from a given operator were used in the Attachment 2 timelines for conservatism. However, the action times were generally consistent among operators.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 30 of 43 Docket No. 50-289 The timelines in Attachment 2 show that all the operator manual actions necessary to achieve and maintain hot shutdown could be accomplished within the time required by the safe shutdown analysis. The other manual actions shown on the timelines are either pre-approved with exemptions or are pre-emptive actions that are not credited to achieve safe shutdown.

These actions are noted with an asterisk on the timelines. Where mutually exclusive actions are possible, the longer action is conservatively shown on the timeline, e.g., pre-emptive action to protect RCP seal cooling vs. reactive action to respond to loss of RCP seal cooling. Actions to maintain IC-V-3 and 4 open, which prevent a loss of RCP seal cooling, are shown to represent a more time-consuming action. As a result, actions to close MU-V-189 are not shown on the , Scenario #1 timeline. contains a key to explain the types of manual action designations. The timeline shows the margin available between the simulated time to complete the operator manual action and the required time to complete the operator manual action.

D. REVIEW OF OPERATOR MANUAL ACTIONS AGAINST NUREG-1852 NUREG-1852 was used to provide guidance in reviewing the attributes of feasibility and reliability for each of the operator manual actions. The NRC guidance noted that there will be some operator manual actions that may be considered "straightforward." The operator manual actions that can be considered straightforward will not require the same level of analysis as those that may be considered more complex. This point is made several times in NUREG-1852 with statements such as; "However, not all of the criteria will usually require significant analysis or even be applicable, particularly for the simpler and more straightforward tasks." While the term "straightforward" was not specifically defined in the guidance documents, adequate information was provided to determine if an operator manual action is straightforward.

The operator manual actions addressed in this exemption request are considered straightforward. The operator manual actions are simple to perform and/or are actions that operators routinely perform as part of their normal work activities. As demonstrated in , adequate time exists to perform the operator manual actions addressed in this exemption request. The operator manual actions are performed in locations having environmental conditions that satisfy NRC operator manual action feasibility criteria. The feasibility and reliability of the TMI operator manual actions are addressed below considering the criteria in NUREG-1852.

1. Adequate Time Availability to Perform the Action There are four segments that make up the time necessary to perform an operator manual action (Note travel time and action time are discussed in the same section below):

1) The time necessary to diagnose the need for the action and dispatching an operator(s) to perform the action,

2) Travel time to the location where the action is to be performed and time to perform the action, and

3) Time necessary to verify the action has been successful and achieved the desired results.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 31 of 43 Docket No. 50-289 These time segments are addressed below.

Diagnosis Time The timelines provided for each operator manual action, as shown in Attachment 2, reflect the time required for the Control Room team to diagnose the need for operator actions. Each scenario was simulated in the TMI-1 plant simulator to obtain realistic diagnosis times. In most cases, actions were directed by procedure without reliance on any diagnosis other than confirmation of a fire. The initial time (T=0) for most actions was the time at which the failure occurred. For conservatism, it was assumed that the failure occurred simultaneous with the report of the fire. The diagnosis time is the time difference from the initial time to the time the Control Room Operator (CRO) dispatched an AO or RO to perform the manual action.

For the seal return isolation action, the initial time clock started when the RCP seal design temperature of 235°F is reached. This is estimated to be 10 minutes from the loss of all RCP seal cooling, which conservatively was assumed to occur simultaneous with the report of the fire. Since the fire abnormal operating procedures (AOPs) direct monitoring seal temperatures early in the procedure and direct immediate action to isolate seal return if the condition is met, diagnosis time is minimal. As shown in the Attachment 2 timelines, diagnosis for this action was 2-3 minutes.

In the event of a fire, a plant page is provided dispatching the fire brigade, which is composed of two plant auxiliary operators and maintenance personnel. Therefore, in the event of a fire, the operators assigned safe shutdown responsibilities (which are separate from those operators assigned to the fire brigade) would be immediately aware of the fire. The safe shutdown operators will be fully aware of the fire location and conditions and will be ready to initiate operator manual actions very close to the start of the event. Auxiliary operators designated for safe shutdown responsibility are trained to respond to a specific location in the event of a fire to be available to perform actions as required by the Control Room.

Travel & Action Time Travel time to the location(s) where the operator manual actions are performed and the time necessary to perform the operator manual actions were incorporated into the timelines. Transit times were measured from the operators normal assembly area and from operator manual action locations in the plant. Therefore, the transit times and operator manual action performance time represent expected times in the event of fire. Travel times for each operator manual action are included in the time to perform the operator manual action, as is accounted for in the timeline starting from the time at which the CRO directed the operator to perform the operator manual action. The action time for each action was based on operator walk down simulation of the action. The combined travel and action time for each operator manual action is included in the Attachment 2 timeline. For the most time-critical action in this exemption request, i.e., the RCP seal return action, the time to travel to and close either MU-V-189 or MU-V-26 and IA-V-1214 was consistently less than three minutes.

Confirmation Time The time to verify that the operator manual action was successful was incorporated into the timeline as the time when the operator manual action was reported completed. The operator manual actions are directed by procedure to perform specific action(s). Separate confirmation time is not typically required, because the success of the operator action is readily apparent to the operator performing the action.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 32 of 43 Docket No. 50-289

2. Adequate Time Available to Ensure Reliability The timelines in Attachment 2 provide significant conservatisms with respect to operator manual action times, which bound uncertainties such as unanticipated environmental conditions, equipment issues, or human performance issues. First, they assume all the worst-case fire effects for a given scenario occur simultaneous with the fire report or alarm. In a more realistic scenario, given the type of combustibles in the initiating fire areas, the fires will be slow to develop and cables failures will not occur for at least several minutes, thereby providing adequate time for pre-emptive actions (e.g., to protect RCP seal cooling), to be successful.

Additionally, in some scenarios, the fire is assumed to fail components in a worst-case time sequence. For example, an inadvertent ESAS is assumed to occur simultaneous with the fire report. One minute later the power supply to MU-V-16A/B and MU-V-36 is lost, which prevents immediate Control Room correction of valve position and requires manual action to correct.

Finally, another conservatism is that pre-emptive actions, such as actions to prevent spurious valve operation or prevent a loss of all RCP seal cooling, are not credited because fire damage may occur prior to completing the action. Again, this assumes that fire damage may occur immediately upon first detection of the fire to all components in the fire area/zone.

3. Environmental Factors This section evaluates the environmental conditions that the operators may encounter while traveling to the area where the manual action will be performed and within the area the manual action will take place. Specific environmental factors that could potentially impact the ability of the operators to successfully perform the operator manual action are considered in this section.

Radiological Exposure Radiation levels expected during travel to or at operator manual action locations are minimal.

For operator manual actions in the Auxiliary Building, dose rates would be less than 10 mR/hour. The Control Building is not a radiation area. Dose rates in operator manual action areas would not significantly change following a plant shutdown or due to any fire effects. In no case does the operator manual actions addressed by this exemption request place an operator in a high radiation area, or a situation that will result in exceeding site administrative dose limits.

Dose limits contained in 10CFR 20 are never challenged.

Emergency Lighting The availability of emergency lighting in the area of the action and the access routes to the action location have been confirmed. TMI surveillance procedures periodically test the permanently mounted eight-hour lights to ensure they are operating, have adequate battery water level, and that the lights are properly aimed. Emergency lights are provided on the pathways between the Control Room and action locations.

Additionally, operators have portable lights powered by eight-hour batteries available. The portable lights are maintained in a fully charged condition (stored in battery chargers), are tested on a periodic basis, and are replaced as necessary as part of the routine post-fire equipment inventory surveillance test procedure. The portable lights have handles for ease in carrying and have adjustable lamps, which may be positioned to illuminate the manually controlled devices.

The portable lights are conveniently located for the operators in five enclosures around the plant (each enclosure contains four portable emergency lights).

Walkdowns have been performed to ensure that emergency lighting to illuminate pathways and action locations is available. A modification to install fixed emergency lighting in the area of the

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 33 of 43 Docket No. 50-289 new manual action to close MU-V-189 will be completed prior to restart from the next refueling outage, which is scheduled to start Fall 2009. This commitment is shown in Attachment 3.

Plant Environment Conditions Temperature and humidity conditions in the access/egress routes and operator manual action locations do not affect the operators capability to perform the manual actions. Conditions in these Auxiliary Building and Control Building fire areas/zones will not undergo a significant change in the time following shutdown to when the actions must be performed. Temperature and humidity conditions will not challenge the operators performing the operator manual action.

Plant operators enter each fire area/zone where operator manual actions are performed as part of their regular job activities, so these areas are familiar to plant operators assigned to perform the operator manual actions. Additionally, operator familiarity with access/egress routes and the operator manual action locations will minimize operator anxiety while performing the operator manual actions under stressful conditions.

Fire Effects This section considers if the operators will encounter fire effects en route to the location where the action is to be performed or at the location where the action is to be performed. To determine the fire effects, the initiating fire area spatial and ventilation relationship with the action and access locations were considered. Fire effects related to this exemption request could be placed into specific categories as described below.

Separate Buildings. The initiating fire area and the action fire area are located in separate buildings. These are cases of physically separate buildings. A fire in one building would not affect the other building. There would be no impact to operators performing actions in the other building and actions within this category need no further explanation.

Separate Fire Areas and Separate Ventilation Systems. The initiating fire area and the action fire area are separate fire areas with separate ventilation systems. The access route goes through fire areas separate from the initiating fire area. There would be no impact to operators performing actions in separate fire areas with separate ventilation systems and actions within this category need no further explanation.

Separate Fire Areas with the following configurations:

1) In the Control Building, all floors, ceiling and walls adjacent to other fire areas or zones are 3-hour rated, with penetrations protected with fire rated assemblies (with the exception of bus ducts). Door openings are protected with 3-hour fire rated doors. All duct penetrations through walls and ceilings in fire areas in the Control Building are provided with 3-hour rated dampers. Fire Areas CB-FA-2a, CB-FA-2b, CB-FA-3a and CB-FA-3b feature passively ventilated bus ducts, which are sealed around the outside periphery to a 3-hour rating. These bus duct internals are sealed with a non-fire rated smoke stop, adequate to prevent passage of smoke and hot gases. Thus, fire effects in the Control Building are not expected to hinder operator performance of manual actions.

2) An open passage exists between Fire Zone FH-FZ-1 and Fire Zone AB-FZ-5, and the boundary between these zones and Fire Zone AB-FZ-4 does not consist of wall construction. However, FH-FZ-1 is equipped with an automatic wet pipe sprinkler

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 34 of 43 Docket No. 50-289 system. The FH-FZ-1 west wall ventilation duct adjacent to AB-FZ-6 need not be sealed since FH-FZ-1 has an automatic suppression system and there is no continuity of combustibles from FH-FZ-1 to AB-FZ-6. For these reasons, fire effects should not hinder performance of operator manual actions in the Auxiliary Building.

3) The floor of Fire Zone AB-FZ-6, where it interfaces with the ceiling of Fire Zone AB-FZ-3, is a concrete non-rated boundary. Between the two boundaries is a buffer with no continuity of combustibles. Due to the presence of smoke detection, automatic suppression, a hose station and portable extinguishers, early detection and response is expected to mitigate the fire. Therefore, fire effects from a fire in AB-FZ-6 should not hinder operator actions in AB-FZ-3.

4) For the scenario where a fire occurs in AB-FZ-1 and re-entry into this zone is required, a 1-hour delay has been imposed in the timeline to reflect extinguishment of the fire, as previously approved in the 1986 SER (Reference 6). The reinforced concrete walls in this zone provide a formidable barrier to fire propagation even though the walls are not fully rated. The fire load within this zone is negligible; therefore, should a fire occur it would be of insufficient duration and intensity to propagate across the zone boundaries to adjacent zones even though a limited number of unsealed penetrations exist. Because of smoke detection and manual suppression systems (portable extinguisher and hose station) in the area, the fire is expected to be detected and extinguished rapidly. Upon re-entry, significant smoke and toxic gas generation is not expected due to the low combustible loading in the area. Thus, operator manual actions are not expected to be hindered.

The potential impact of smoke on the ability to perform the operator manual actions is addressed in the section above. In most cases, the initiating fire area and the action location are separate fire areas. Therefore, heat and smoke or gas generation from the fire will not impact the operator performing the operator manual actions. In the one case that the operator must re-enter the initiating fire area, the potential for smoke to impede the operator performing the manual actions is small due to low combustible loading and the presence of detection and manual suppression systems in that area. Use of self-contained breathing apparatus (SCBAs) to perform any of the operator manual actions is available. The safe shutdown operators are qualified in the use of SCBAs and are familiar with all the locations where SCBAs are staged.

Specifically, SCBAs may be required for the A DC cross-tie manual action for initiating Fire Area CB-FA-2a. For a fire in Fire Area CB-FA-2a, the fire brigade would attack the fire from the A Inverter Room boundary (Fire Area CB-FA-2d). Opening of the fire door between Fire Areas CB-FA-2a and CB-FA-2d would result in smoke entering CB-FA-2d, which is one of the rooms utilized for the A DC cross-tie manual action. However, there is separate ventilation available in CB-FA-2d and the operator performing the manual action would use an SCBA. Additionally, it is likely that the fire would be under control or extinguished by the time the manual action would be performed since the action is required within two hours.

For a fire in Fire Zone FH-FZ-5, spurious actuation of the relay room (Fire Area CB-FA-3d) automatic CO2 fire suppression system may occur. However, access through Fire Area CB-FA-3d is not required for operator manual actions in Fire Zone FH-FZ-5. The operator manual actions submitted in this exemption request for initiating Fire Zone FH-FZ-5 are located in a separate building (Auxiliary Building) and therefore operators would not be impacted by this actuation.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 35 of 43 Docket No. 50-289

4. Equipment Functionality and Accessibility The functionality of equipment and cables needed to perform required operator manual actions is demonstrated in the TMI-1 FHAR. Procedures directing required operator manual actions reflect equipment availability demonstrated in the FHAR and provide specific direction where functionality of equipment and cables may be compromised by fire.

The FHAR analysis has been translated into the TMI-1 Fire AOPs and associated basis documents. Attachment 1 to the Fire AOP for a specific Fire Area / Zone provides a list of equipment available for a fire in the Fire Area/Zone. The basis documents also list the failures of safe shutdown equipment from the FHAR and the corresponding procedure (Fire AOP or other emergency procedure) where the failure is addressed.

In-plant operator manual action walk downs were performed and demonstrated operator manual action equipment was accessible. The physical location of the components where operator manual actions are to be performed is identified in the Fire AOP. The Fire AOP operator manual action location guidance facilitates operator access to operator manual action equipment.

Where components cannot be operated from the floor, installed ladders or portable ladders /

step stools are provided. A ladder is labeled and staged for use for manually operating MU-V-16C/D. The ladder is staged en-route to the action location. Portable stairs are also available in close proximity to makeup valve alley (Fire Zone AB-FZ-3) for operating MU-V-36 and MU-V-37, if required. In both cases, operator walk downs accounted for the time to utilize this equipment.

As previously discussed, re-entry into an initiating fire zone has been previously approved in an SER (Reference 6). Re-entry for the NR-V-4A/B operator manual action is required for initiating Fire Zone AB-FZ-1. Access to Fire Zone AB-FZ-1 is also blocked for initiating Fire Zones AB-FZ-5 and FH-FZ-1; therefore, the 1-hour re-entry also applies for these fire zones. The timeline in Attachment 2 shows that there is adequate time to perform this operator manual action after re-entry into the fire zone.

5. Available Indications Available diagnostic instrumentation that has been analyzed for safe shutdown is listed in the fire AOP for each fire area; however, instrumentation or indications are generally not relied upon to perform the operator manual actions in this exemption request. Explicit steps in the fire AOPs direct the manual actions submitted in this exemption request. The RCP seal return isolation action is dependent upon a loss of all RCP seal cooling that cannot be restored, which is indicated by RCP seal temperatures greater than 235°F. This indication may not be available in a given fire area/zone, since RCP pump temperature indication is not credited for fire safe shutdown. Therefore, if RCP seal temperatures cannot be verified, and all RCP seal cooling is lost, the RCP seal temperature is assumed to be greater than 235°F and the action is taken.

For the action to start MU-P-1B after selecting it at the 4160V switchgear, operators would enter the AOP for loss of seal injection based on low seal injection flow, which is caused by the loss of makeup pumps. If seal injection indication is unavailable, operators have additional indication of loss of makeup flow available, such as pressurizer level. Additionally, the fire AOPs include a specific step to select MU-P-1B at the 4160V switchgear.

One train of available parameter indications required for safe shutdown is always available for a fire in a given fire area/zone. The only operator manual action that requires indication is the

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 36 of 43 Docket No. 50-289 action to throttle MU-V-16B to maintain adequate makeup flow. Emergency makeup flow indication is available for a fire in Fire Zone AB-FZ-6 for this manual action. The other operator manual actions listed in Table 1 do not require any indication to support completion of the operator manual action; however, lack of indication is conservatively used to take action. For most operator manual actions, successful accomplishment of the required operator manual action is directly observable by the operator performing the operator manual action and reported to the Control Room operators when completed. For the MU-V-16B operator manual action, the Control Room will be able to verify adequate makeup flow.

6. Communications TMI has portable radio and installed phones available as part of the normal plant communications available between the Control Room and the operators. The communication system is not specifically hardened for post-fire survivability. However, the radio and phone systems are robustly designed such that they should be available following most fire scenarios.

If the various communication systems are not available, the method of communication will be face-to-face or using radios via line-of-sight (i.e., no repeaters). Face-to-face communication was simulated in the Attachment 2 timelines by having operators start the manual action from directly outside the Control Room. For actions that require concurrent coordination, radio contact was simulated; however, face-to-face communication time was factored into the timelines in Attachment 2. Task completion is normally reported by portable hand held radio and/or installed phones. Task completion may also be reported by face-to-face communication if plant communication systems are not available. Most of the operator manual actions addressed by this exemption request do not require immediate or concurrent coordination with the Control Room while performing the task. The operator manual actions that require coordination with the Control Room include:

1. Ensuring MU-V-36/37 are open and closing MU-V-16A/B (or MU-V-16C/D) in response to an inadvertent ESAS. This action requires verification that MU-V-36/37 are open prior to closing MU-V-16A/B. Adequate time margin is available to return to the Control Room to report that MU-V-36/37 are open and to get direction to close MU-V-16A/B (or MU-V-16C/D). Total travel time to the Control Room and back to the valves was conservatively timed to take four minutes. This time is already factored into the timelines in Attachment 2.

2. Performing A and B DC cross-tie actions. This action requires the Control Room to take action to place some equipment in pull-to-lock to reduce loads within the procedure.

Total travel time to the Control Room and back to the inverter rooms was conservatively timed to take two minutes each time. This is required at most three times during the procedure. This time is already factored into the timelines in Attachment 2.

The following TMI communication capabilities are available to Control Room operators and operators performing operator manual actions:

• General Announcing System

• Operations Radio System

• Plant Telephone System

• Sound Powered Phone System

• Face-to-Face Communications

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 37 of 43 Docket No. 50-289

7. Portable Equipment Other than keys, portable lighting, and portable ladders, no additional support equipment is required for the operator manual actions addressed by this exemption request. The use of portable lighting is discussed under the Emergency Lighting section of this request. In addition, the use of portable ladders is discussed under the Accessibility section of this request. Fire AOPs identify when a key is required to perform an operator manual action. Keys required by operators are in the possession of the operator. The specific key number required for the operator manual action is identified in the Fire AOP.

8. Personal Protective Equipment Operators performing operator manual actions are provided with standard personal protective equipment (PPE), including hardhat, gloves, and protective glasses. The only actions requiring additional PPE are those required for the A DC cross-tie operator manual action. PPE appropriate for 120V AC is required since a cabinet has live exposed 120V wiring. Electrical PPE is available in the switchgear rooms and outside the Control Building. In the unlikely event that smoke conditions would require SCBAs to be worn, the plant equipment operators are qualified to wear SCBAs and the SCBAs are staged at strategic locations in the plant with additional SCBAs in the fire brigade locker.

9. Procedures and Training At TMI-1, fire AOPs have been developed for each fire area/zone. Fire AOPs are staged in certain strategic locations and are easily accessible to the operators. The individual fire area procedures are presented in a standardized procedure format the operators are familiar with and comfortable to use. The fire AOPs contain both preventive actions to prevent potential adverse fire effects as well as reactive actions to direct timely action if a fire causes a particular adverse condition (i.e., valve spuriously opens or closes). The procedures for individual fire areas are used in conjunction with the symptom-based (reactive) Emergency Operating Procedures (EOPs) and other symptom-based AOPs to provide a combined preventive (fire AOPs) and reactive (EOPs and all AOPs, including fire) approach to achieve safe shutdown following a fire. The individual fire area shutdown procedures provide the operators with information as to the available equipment (including instrumentation) that can be relied upon following a fire. The fire area/zone specific fire AOP procedures provide specific guidance to the operators as to what equipment could be affected by the fire. The fire AOPs steps are written in order of time criticality (i.e., the most time critical actions are in the front of the procedure) to ensure the actions are taken within the analyzed time required in the safe shutdown analysis. The fire AOPs are not written to address every potential symptom of the fire; rather, the unique aspects and time critical actions that could result from a fire in a particular fire area or zone. Where the fire can cause a symptom, for example an inadvertent ESAS or loss of seal injection, operators will enter a separate symptom-based EOP or AOP to resolve the condition, where applicable. Fire AOP basis documents exist for each fire area/zone specific procedure, which relate the FHAR required actions to the procedure that addresses each action.

This exemption request does not involve any fire areas where Control Room habitability is affected. The Control Room environment will not adversely impact any diagnostic efforts by the Control Room operators. The fire area/zone specific procedures identify the equipment and instrumentation that remain available in the event of fire in a specific area.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 38 of 43 Docket No. 50-289 The most time critical action in this exemption request is isolating RCP seal return. To ensure this action is completed within the time frames in Table 1 (depending on the fire area/zone), this operator manual action is directed immediately upon RCP seal temperatures exceeding 235°F or if seal temperatures cannot be verified after loss of all RCP seal cooling. The placement of this action in the fire AOPs allows for the short operator action times as shown in the timelines.

The operator manual actions covered by this exemption request are similar to activities performed by plant operators as part of normal work assignments. In addition, the operator manual actions addressed by this exemption request are similar to those performed for the Control Room evacuation shutdown procedure. Since these actions are similar to those performed as part of a typical work activity, they are considered as straightforward skill-of-the-craft operator actions. As skill-of-the-craft activities, the initial and continuing operator training program provides required training and qualification (demonstration) of the operators. The physical actions addressed by this exemption request can be summarized as follows:

a) Circuit breaker operation. Manipulation of electrical breakers is considered a required skill by plant equipment operators, which is performed during normal work functions. Breakers are manipulated at the direction of the Control Room during normal plant operation. Breakers are also manipulated as part of applying clearances for safe work boundaries.

b) Key and switch operations. Operating key switches and panel isolation switches is considered a required skill of plant equipment operators that is performed during normal work functions. Panel switches are operated by plant equipment operators to accomplish other plant functions.

c) Valve operation. Operating valves is considered a required skill of plant equipment operators that is performed during normal work functions. Valves are manipulated by operators as part of many work activities.

Each of the manual actions consists of one or more of the actions above. During operator manual action walk downs conducted in support of this exemption request, operators demonstrated proficiency in performing the operator manual actions.

10. Staffing Three qualified operators are available to perform the manual actions. Current shift staffing includes two AOs and an RO that are available to perform the operator manual actions. The RO is initially dispatched to the fire to assess the potential impact on safety-related equipment if the fire is in a safety-related area of the plant (fire brigade advisor). This assessment is expected to be performed quickly (i.e., within approximately 10 minutes from arrival at the scene of the fire). After this assessment, the RO will be available to perform manual actions, if requested to do so by the Control Room. The only operator manual action performed by the RO in this exemption request is the DC cross-tie. An operator's license is not required to perform this action. There is adequate time available, as shown in Attachment 2, Scenario #3, for the RO to perform the initial fire assessment and support completion of this manual action. The DC cross-tie actions are also in the same general area of the plant as the postulated fire; therefore, the RO, while acting as the fire brigade advisor, will be able to remain cognizant of the fire impact and provide updates to the Control Room if conditions change. The two AOs and available RO (after performing initial fire assessment) provide sufficient staffing to perform post-fire manual actions within the time allowed with acceptable margin, as shown in Attachment 2.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 39 of 43 Docket No. 50-289 Although two AOs and one RO are currently utilized for safe shutdown actions, any operator qualified to perform safe shutdown actions may be used in these roles.

11. Demonstrations Demonstrations were performed in the TMI-1 plant simulator and in the plant by operator walk downs to show that the operator manual actions can be performed within the times as described in the safe shutdown analysis. Demonstrations can show reliability by achieving similar results when the operator manual actions are performed by different crews and at different times.

Operators were not pre-conditioned in any way prior to walk downs or simulator validation. TMI performed at least one demonstration for each action, as shown on the Attachment 2 timelines.

Where more than one demonstration was performed, the most conservative time was used for the analysis. Each timeline represents the most limiting scenario for the given manual actions.

The initial time (T=0) for most actions was the time at which the failure occurred. For conservatism, it was assumed that the failure occurred simultaneous with the report of the fire.

For the RCP seal return isolation action, the initial time clock started when the RCP seal design temperature of 235°F is reached. This is estimated to be 10 minutes from the loss of all RCP seal cooling, which conservatively was assumed to occur simultaneous with the report of the fire.

TMI Fire AOP procedures were written to address the potential loss of all equipment susceptible to fire damage in a fire area and assumed that the equipment losses could occur concurrently or subsequently, whichever presented the worst case. The timelines developed to support the operator manual actions in this exemption request demonstrate that all the manual actions required to successfully complete a given operator manual action can be accomplished with the minimum plant staffing.

Table 1 provides a list of the operator manual actions addressed by this exemption request.

The timeline margins identified in Table 1 and Attachment 2 were determined via the operator walk downs and plant simulation of each scenario performed to support this exemption request.

The following methodology was employed to determine manual action feasibility:

• Procedure(s) used to mitigate the fire induced equipment failure(s) were determined by the Control Room based on diagnosis of event symptoms. For most failures, the fire AOPs were used for the operator manual actions.

However, for some symptoms, such as inadvertent ESAS, other EOPs or AOPs may be used in parallel with the fire AOP.

• In-plant walk downs of procedure steps directing specific operator manual actions to mitigate the fire induced failure(s) were conducted. The following criteria were observed and evaluated during the in-plant walk downs:

o Timing to be used in development of an operator manual action timeline, and o Inspection criteria used by NRC inspectors to evaluate operator manual actions (Reference 9).

• Simulator scenarios were conducted to demonstrate operator response to fire-induced equipment failure(s). The scenarios were conducted for fires in fire areas/zones presenting the greatest challenges for operator response. Multiple simulator crews were used for the fire scenarios in Attachment 2.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 40 of 43 Docket No. 50-289

• Additional in-plant walk downs of operator manual actions directed by Control Room Operators during simulator fire scenarios were conducted. The following manual action criteria were observed and evaluated during the additional in-plant walk downs:

o Timing to be used in development of an operator manual action timeline, and o Inspection criteria used by NRC inspectors to evaluate operator manual actions (Reference 9).

• Timelines demonstrating operator manual action feasibility were developed. The timelines incorporated times observed during conduct of the simulator scenarios and in-plant operator manual action walk downs.

• The operator manual actions were evaluated for feasibility and reliability.

The following operator manual action table identifies the operator manual actions for which an exemption is being requested, the location where the operator manual action is performed, the fire areas/zones where the FHAR credits the operator manual action, the simulated time (combination simulator diagnosis and in-plant walk down time), the required time for completing the operator manual action, and the time margins determined for the operator manual action.

Table 1. Operator Manual Action (OMA) Table Fire Attach. 2 Time for Operation OMA Areas/Zones Scenario OMA Location Crediting (Fire Area Simulated Required Margin OMA Simulated)

Valves:

1. Open AB-FZ-3, breakers, AB-FZ-4 AB-FZ-6, Ensure Breakers:

CB-FA-1, MU-V- AB-FZ-6, CB-FA-2a, 1 36/37 AB-FZ-6a 40 minutes 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 20 minutes CB-FA-2d, (CB-FA-1) open and Feeder CB-FA-2f, locally Breakers FH-FZ-1 close MU- (Note 1):

V-16A/B CB-FA-2a, CB-FA-2b

2. Open 1P 480V Valve:

Switchgear AB-FZ-4 Unit 4C Feeder 2 and AB-FZ-6 28 minutes 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 32 minutes Breaker: (AB-FZ-6)

Manually CB-FA-2a throttle MU-V-16B (Note 2)

3. Open breakers, Valves: CB-FA-2b, Ensure AB-FZ-3, CB-FA-2c, MU-V- AB-FZ-6 CB-FA-2e, 3 36/37 (CB-FA-3b) 35 minutes 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 25 minutes Breakers: CB-FA-2g, open and locally AB-FZ-6, CB-FA-3b, close MU- AB-FZ-6a FH-FZ-5 V-16C/D

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 41 of 43 Docket No. 50-289 Fire Attach. 2 Time for Operation OMA Areas/Zones Scenario OMA Location Crediting (Fire Area Simulated Required Margin OMA Simulated)

4. Open Valves:

Breaker AB-FZ-1 AB-FZ-1, and Breakers: AB-FZ-5, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Ensure 4 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, AB-FZ-6, 6 minutes NR-V-4A FH-FZ-1 (FH-FZ-1) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 54 minutes AB-FZ-6a, (Note 3) or NR-V-4B is Closed

5. Energize CB-FA-2d, CB-FA-2e, CB-FA-2a, 3 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, A DC 54 minutes 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> CB-FA-2g CB-FA-3a (CB-FA-3b) 6 minutes Cross-tie

6. Energize CB-FA-2d, CB-FA-2e, CB-FA-2b, 3 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, B DC 54 minutes 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> CB-FA-2g CB-FA-3b (CB-FA-3b) 6 minutes Cross-tie

7. Select AB-FZ-5, MU-P-1B AB-FZ-7, 5 for ES at CB-FA-3b 18 minutes 1 Hr. 42 minutes ISPH-FZ-1, (AB-FZ-5) 1E 4160V ISPH-FZ-2 Switchgear

8. Open 1P 480V Valve:

Switchgear AB-FZ-3 Unit 4C Feeder AB-FZ-6 6 19 minutes 40 minutes 21 minutes and Breaker: (AB-FZ-6)

Locally CB-FA-2a Open MU-V-36 AB-FZ-4, CB-FA-1, CB-FA-2a, 2 6 minutes 20 minutes 14 minutes (AB-FZ-6)

9. Close MU- CB-FA-2d, FH-FZ-1 CB-FA-2f, V-189 AB-FZ-6 2 6 minutes 13 minutes 7 minutes (AB-FZ-6)

CB-FA-2b 2 6 minutes 15 minutes 9 minutes (AB-FZ-6)

10. Fail MU-V-26 7

Closed FH-FZ-2 FH-FZ-1 5 minutes 20 minutes 15 minutes (FH-FZ-1) and Close IA-V-1214 Note 1: Required for initiating Fire Zone AB-FZ-6 only Note 2: Operator manual action previously approved. Only change is in time required.

Note 3: One-hour delay for re-entering the Fire Area/Zone that credits the manual action.

This table shows that adequate margin exists for all the operator manual actions, which demonstrates feasibility and reliability. These times adequately account for all the time

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 42 of 43 Docket No. 50-289 requirements (i.e., diagnosis, travel, action, and confirmation) required by NUREG-1852. The margin allows for additional uncertainties including unanticipated environmental, equipment, or human performance issues that may exist during a fire scenario.

E. DEFENSE IN DEPTH The principles of fire protection defense in depth are:

- To prevent fires from starting,

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

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

TMI-1 has a Fire Protection administrative control program that addresses controls on ignition sources, hot work activities, combustibles, and fire system impairments. These controls are reviewed by NRC Regional Inspectors, insurance inspectors and Nuclear Oversight auditors.

The administrative control program is described in the TMI-1 Updated Final Safety Analysis Report (UFSAR) and in the FHAR, which is incorporated by reference into the UFSAR.

TMI-1 has fire detection and suppression systems in many areas of the plant. The locations of the fire detection and suppression systems have previously been described to the NRC in correspondence and are currently summarized in the TMI-1 FHAR.

TMI-1 has been divided into fire areas and fire zones, as described in the TMI-1 FHAR. Three-hour rated fire barriers are normally used to provide fire resistive separation between adjacent fire areas. In some cases, barriers with a fire resistance rating of less than three hours are credited but exemptions have been approved as documented in the FHAR. The TMI-1 FHAR provides a summary of the rating of the fire barriers separating adjacent fire areas. Information regarding the fire protection defense-in-depth features in each of the initiating fire areas addressed by this exemption request was discussed previously. This information is a summary to what is available in the TMI-1 FHAR.

III. ENVIRONMENT ASSESSMENT The exemption request provides a formal vehicle for NRC approval of operator manual actions associated with Appendix R post-fire safe shutdown. The results of reviews by Exelon confirm that the operator manual actions are feasible. Application of the rule in this circumstance is not necessary to achieve the underlying purpose of the rule.

The proposed exemption will not significantly increase the probability or consequences of accidents, no changes are being made in the types or quantities of any radiological effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed exemption. In addition, the proposed exemption does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed exemption. As a result, in accordance with the requirements of 10 CFR 51.32, the proposed exemption will not have a significant effect on the quality of the human environment.

10 CFR 50.12 Exemption Request Attachment 1 Operator Manual Actions Page 43 of 43 Docket No. 50-289 IV. CONCLUSION The requested exemption will not result in undue risk to the public health and safety because Exelon has determined that the subject manual actions are feasible and reliable, and the defense in depth is adequate as described in the TMI-1 FHAR. The underlying intent of 10 CFR 50, Appendix R, to achieve and maintain shutdown following a fire, is accomplished using the operator manual actions described in this exemption request. If manual actions are not used to meet the underlying purpose of the rule, modifications to: (1) provide additional fire suppression systems, detection systems, or fire barriers, or (2) re-route cables or wrap cables, would be required to achieve compliance. Such modifications represent an unwarranted burden on Exelon since they are not necessary to meet the underlying purpose of the rule. Therefore, the special circumstances for issuance of the exemption are satisfied in accordance with the requirements of 10 CFR 50.12(a)(2)(ii), since application of the rule is not necessary to achieve the underlying purpose of the rule. In addition, the requested exemption is authorized by law, and is consistent with the common defense and security.

V. REFERENCES

1. 10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."

2. Regulatory Issue Summary (RIS) 2006-10, "Regulatory Expectations with Appendix R Paragraph III.G.2 Operator Manual Actions," dated June 30, 2006.

3. NUREG-1852, "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," dated October, 2007.

4. Three Mile Island Nuclear Station, Unit 1, Fire Hazards Analysis Report, Revision 23.

5. NRC Information Notice 2005-14, "Fire Protection Findings on Loss of Seal Cooling to Westinghouse Reactor Coolant Pumps," dated June 1, 2005

6. Letter from John F. Stoltz, U.S. Nuclear Regulatory Commission, to Henry D. Hukill, GPU Nuclear Corporation, Fire Protection for TMI-1, dated December 30, 1986.

7. Letter from Timothy G. Colburn, U.S. Nuclear Regulatory Commission, to James W.

Langenbach, GPU Nuclear Corporation, Three Mile Island Nuclear Generating Station, Unit 1, 10 CFR Part 50 Appendix R Exemption Request (TAC No. M97747), dated April 20, 1999.

8. Letter from Bart C. Buckley, U.S. Nuclear Regulatory Commission, to James W.

Langenbach, GPU Nuclear Corporation, Three Mile Island Nuclear Generating Station, Unit 1, 10 CFR Part 50 Appendix R Exemption Request (TAC No. M96473), dated July 11, 1997.

9. NRC Inspection Procedure 71111.05, "Fire Protection," March 6, 2003.

ATTACHMENT 2 10 CFR 50.12 Exemption Request Three Mile Island Nuclear Station, Unit 1 Docket No. 50-289 Request for Exemption from 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability" Operator Manual Action Timelines

10 CFR 50.12 Exemption Request Page 1 of 9 Docket No. 50-289 ATTACHMENT 2 OPERATOR MANUAL ACTION TIMELINES Scenario #1- Fire in Fire Area CB-FA-1 OMA(s): Ensure MU-V-36 is open and MU-V-16A and MU-V-16B are locally closed. Open breakers for all valves locally operated.

Concern: Mitigate pressurizer overfill Required Time: 1 Hr.

Initial Worst-Case Failures due to Fire: Loss of Vital Bus A and C (Both ES trains actuate, A train cannot be defeated), Loss of Instrument Air T0 Indication Of Fire, T60:00 Initial Failures Time Available to Complete Manual Action - 1 Hr.

AO 1 Directed to go to 6900V Switchgear*

T2:31 AO 2 AO 2 AO 2 Directed to AO 2 AO 2 AO 2 AO 2 Directed to Reports Open Directed to Directed to Directed to Directed to Locally Open IC-V-3 Locally MU-V-16A/B Open MU-V-36 Locally Open Locally Close Locally Close IC-V-3/4* Opened* Breakers Breaker MU-V-36 MU-V-16A MU-V-16B T7:40 T11:40 T18:50 T22:05 T26:16 T31:01 T35:16 AO 2 AO 2 AO 2 AO 2 AO 2 AO 2 Reports IC-V-4 Reports Reports MU- Reports Reports Reports Locally MU-V-16A/B V-36 Breaker MU-V-36 MU-V-16A MU-V-16B Opened* Breakers Open Open Open Closed Closed T14:40 T21:50 T25:05 T30:46 T35:01 T39:16 Margin 20 Minutes

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 2 of 9 Docket No. 50-289 Scenario #2- Fire in Fire Area AB-FZ-6 OMA(s): (1) Close MU-V-189 and (2) Manually throttle MU-V-16B Concern: (1) Seal Return Isolation on a loss of all RCP seal cooling and (2) Loss of makeup Required Time: (1) 13 Min for AB-FZ-6, 15 Min for CB-FA-2b (bounded by this scenario), and 20 Min for all other Fire Zones, and (2) 1 Hr.

Initial Worst-Case Failures due to Fire: MU-V-16A/B/C/D fail closed, MU-V-17 and MU-V-18 fail closed, MU-V-217 fails closed, Inadvertent 30 psig A and B train ESAS MU-V-189 MU-V-189 MU-V-189 Fire MU-V-189 OMA MU-V-16B OMA OMA Reported OMA (All other fire OMA (AB-FZ-6) (CB-FA-2b)

T0 T0 areas/zones) T60:00 T13:00 T15:00 T20:00 Time Available to Complete Manual Actions AO 1 RCP Seal Directed to temps > 235F Throttle T10:00 MU-V-16B T24:00 AO 1 AO 1 AO 2 AO 1 AO 2 AO 1 AO 1 Directed to Reports Directed to Reports Reports Reports Directed to Prevent MU-V-36 and Open 1P & 1S MU-V-1A/B and 1P & 1S 480V MU-V-16B Close Spurious Valve MU-V-37 480V Unit 4C IC-V-1A/B Unit 4C Throttled MU-V-189 Ops (Open Open**

T2:40 Breakers Breakers open* Breakers Open Open Breakers)* T23:45 T17:08 T18:45 T19:08 T28:00 T16:05 AO 1 AO 1 Directed to Reports Locally Ensure MU-V-189 MU-V-36 and Closed MU-V-37 T5:40 Margin Open**

T20:45 14 Minutes Margin Margin 9 Minutes 32 Minutes Margin 7 Minutes

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 3 of 9 Docket No. 50-289 Scenario #3- Fire in Fire Area CB-FA-3b OMA(s): (1) Ensure MU-V-36 and MU-V-37 are open and MU-V-16C and MU-V-16D are locally closed. Open breakers for all valves locally operated.

(2) Perform B DC Cross-tie (A Cross-tie action walk-down time was used for conservatism since procedure has more steps)

Concern: (1) Mitigate pressurizer overfill and (2) Long-term power to vital-powered B Train instrumentation Required Time: (1) 1 Hr. and (2) 2 Hrs.

Initial Worst-Case Failures due to Fire: Inadvertent 1600 psig ESAS (Both Trains), Unable to defeat B Train ESAS T0 Fire Reported T120:00 Time Available to Complete Manual Actions AO 1 AO 1 Directed to Directed RO verify 1C to place Directed RO ESV MCC 1S toggle to Reports is Selected switch to Energize B DC to 1P Bus* TEST* B DC energized T21:48 T23:45 T28:17 T53:42 AO 1 Margin AO 2 Reports AO 2 AO 1 AO 2 1 Hour 6 AO 1 AO 1 Reports 1C ESV Reports Reports Reports Minutes Directed Reports MU-V- MCC not MU-V- 1S MU-V- AO 2 To Open 1M ES 36/37 Selected 36/37 Toggle 16C/D Reports 1M ES Switch 5 Breakers to 1P Locally switch to Breakers MU-V-16C/D Switch 5* Opened* Open Bus* Opened TEST* Open Closed T4:57 T5:54 T16:25 T23:30 T23:50 T25:45 T29:50 T34:55 T60:00 AO 2 AO 2 AO 2 AO 2 AO 2 AO 2 Directed Directed Directed Directed to Reports Directed to to Open to Locally to Open Open IC-V-2 Locally MU-V- Close MU-V-36/37 IC-V-2 Breaker Open 16C/D MU-V-Breakers Breaker* Open* MU-V-36/37 Breakers 16C/D T13:25 T6:25 T8:55 T19:30 T26:50 T29:55 Margin 25 Minutes

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 4 of 9 Docket No. 50-289 Scenario #4- Fire in Fire Zone FH-FZ-1 OMA(s): Locally close NR-V-4A or NR-V-4B. Open breaker for valve to be closed.

Concern: Restore NR flow to support restoration of letdown Required Time: 4 Hrs.

Initial Worst-Case Failures due to Fire: NR-V-4A spuriously opens and NR-V-4B fails open Fire Reported T240:00 T0 Time Available to Complete All Manual Actions -

4 Hours AO 2 Reports 1E DC AO 1 AO 2 panel Reports Directed to Switch #15 AO 1 1P & 1S Continued on Open 1E DC and Open Directed Units 4B panel Switch to Open Next Page 1M DC Breakers

1. 15 and Open Panel 1P & 1S Open*

1M DC Panel Switch #5 Units 4B T23:39 Switch #5* Opened* Breakers*

T4:30 T6:30 T21:39 AO 1 Directed AO 2 AO 2 to Prevent AO 1 Directed Report AO 1 Spurious Reports to Open IC-V-2 Reports Valve Ops MU-V-1A/B IC-V-2 Breaker IC-V-3/4 (Open breakers Breaker* Open* Open* Breakers)* Open*

T7:00 T10:00 T11:13 T26:13 T28:43 AO 1 AO 2 AO 2 AO 2 AO 2 AO 2 AO 2 AO 2 AO 2 Directed Directed Reports Directed Reports Directed Reports Directed to Reports to Open to Open MU-V-36 to Open MU-V-37 to Open MU-V-16A Open MU-V-16B IC-V-3/4 MU-V-36 Breaker MU-V-37 Breaker MU-V-16A Breaker MU-V-16B Breaker Locally* Breaker* Open** Breaker** Open** Breaker** Open** Breaker** Open**

T6:13 T10:26 T13:26 T13:35 T16:35 T16:50 T19:50 T20:18 T23:18

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 5 of 9 Docket No. 50-289 Fire Reported T240:00 T0 Time Available to Complete All Manual Actions -

4 Hours AO 2 Directed AO 2 AO 2 to Open Reports Reports Breaker for Access Blocked NR-V-4B Breaker for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> NR-V-4B NR-V-4B Open, but Cannot T60:00 Closed and then Access Valve Locally Close T33:48 T65:30 Valve T29:48 Margin 2 Hours 54 Minutes

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 6 of 9 Docket No. 50-289 Scenario #5- Fire in Fire Zone AB-FZ-5 OMA(s): Select MU-P-1B for ES using selector switch at 1E 4160V switchgear Concern: Restore normal makeup Required Time: 1 Hr.

Initial Worst-Case Failures due to Fire: Loss of MU-P-1A and MU-P-1C, LOOP causes MU-P-1B to trip, IC-V-2 spuriously closes. At 10 minutes, RCP seal design temperature of 235F is exceeded due to loss of all RCP seal cooling Indication of Fire T60:00 T0 Time Available to Complete Manual Action - 60 Minutes Margin 42 Minutes AO 2 AO 2 RCP Seal Directed to Reports temps > 235F ES Select MU-P-1B T10:00 MU-P-1B is ES Selected T14:52 T17:10 AO 1 AO 1 Directed to Reports MU-P-1B Open MU-V-76A/B STARTED MU-V-76A/B* Open* from CR T7:04 T14:04 T17:40 AO 2 AO 2 Directed to Reports Open IC-V-79A/C IC-V-79A/C Breakers Breakers* Open*

T11:23 T14:23

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 7 of 9 Docket No. 50-289 Scenario #6- Fire in Fire Zone AB-FZ-6 OMA(s): Open 1P 480V Switchgear Unit 4C and Locally Open MU-V-36 Concern: Ensure makeup pump minimum recirculation flow path Required Time: 40 Min.

Initial Worst-Case Failures due to Fire: Loss of instrument air, MU-V-17 and MU-V-18 fail closed, MU-V-217 fails closed, MU-V-36 spuriously closes Indication of Fire T40:00 T0 Time Available to Complete Manual Action - 40 Minutes Margin 21 Minutes AO 2 Directed to Open RSTSP B and place Intermediate Clg. Transfer Sw. AO 2 in EMERG and Reports AO 2 AO 2 ensure IC-V-2/4 IC-V-2/4 are Directed Reports are open and IC- open and IC-P- to Open 1P ES 1P ES Unit 4C P-1B is running at 1B is running at Unit 4C Breaker RSD panel B* RSD panel B* Breaker Open T6:00 T9:45 T12:30 T14:30 AO 1 AO 1 AO 1 Directed to AO 1 AO 1 AO 1 Directed to Reports Open Reports Directed to Reports Block Open IC-V-3 MU-V-37 MU-V-37 Locally Open MU-V-36 IC-V-3* Blocked Open* Breaker* Breaker Open* MU-V-36 Opened T4:22 T8:02 T11:25 T14:25 T15:00 T19:00 AO 1 AO 1 Reports Directed to Cannot Open Open MU-V-36 MU-V-36 Breaker* Breaker*

T9:10 T11:10

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 8 of 9 Docket No. 50-289 Scenario #7- Fire in Fire Zone FH-FZ-1 OMA(s): Fail closed MU-V-26 and close IA-V-1214 Concern: Seal Return Isolation on a loss of all RCP seal cooling Required Time: 20 Min. (13 Min for AB-FZ-6, 15 Min for CB-FA-2b)

Initial Worst-Case Failures due to Fire: Inadvertent 30 psig A Train ESAS, MU-P-1A fails to start, LOOP, IC-V-79s unable to close, MU-V-25 unable to close. At 10 minutes, RCP seal design temperature of 235F is exceeded due to loss of all RCP seal cooling Fire Reported T0 T20:00 T0 for OMA for OMA Time Available to Complete Manual Action -

20 Minutes RCP Seal temps > 235F T10:00 AO 2 Directed to AO 1 AO 2 Open 1E DC AO 2 Reports Directed to AO 2 panel Switch 1E DC panel MU-V-36/37 Open 1S Unit Reports

1. 15 and Open Switch #15 and Breakers 4B and 1P 1S Unit 4B and 1M DC Panel 1M DC Panel Open* Unit 4B 1P Unit 4B Switch #5* Switch #5 Open* T0:48 Breakers* Breakers Open*

T3:53 T7:55 T1:13 T3:13 AO 1 AO 1 AO 1 Dispatched to AO 1 Directed Directed Fail Closed MU-V-26 to Open to Open MU-V-26 Failed Closed MU-V-36/37 MU-V-16A/B and Close and IA-V-1214 Breakers* Breakers*

IA-V-1214 Closed T7:18 T0:58 T1:55 T4:55 Margin 15 Minutes

10 CFR 50.12 Exemption Request Attachment 2 Operator Manual Action Timelines Page 9 of 9 Docket No. 50-289 Key:

BOLD = OMA validated for this scenario in this exemption request

• = Previously approved OMA or pre-emptive OMA that is not credited for safe shutdown

• • = OMA validated in this exemption request, but not required for the given scenario (i.e., pre-emptive OMA for the particular scenario)

ATTACHMENT 3 10 CFR 50.12 Exemption Request Three Mile Island Nuclear Station, Unit 1 Docket No. 50-289 Request for Exemption from 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability" Summary of Regulatory Commitments

10 CFR 50.12 Exemption Request Page 1 of 1 Docket No. 50-289 ATTACHMENT 3 Summary of Regulatory Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC OUTAGE (Yes/No) (Yes/No)

Install modification to prevent DH-1R18 Yes No V-6A and DH-V-6B from spuriously opening.

Install modification to add fixed eight-hour emergency lighting to 1R18 Yes No support the MU-V-189 manual action.