View source for LIC-13-0060, Omaha Public Power District - Remaining Responses to Second Request for Additional Information License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station

{{Adams
| number = ML13144A814
| issue date = 05/21/2013
| title = Omaha Public Power District - Remaining Responses to Second Request for Additional Information License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station
| author name = Cortopassi L
| author affiliation = Omaha Public Power District
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000285
| license number = 
| contact person = 
| case reference number = LIC-13-0060, TAC ME7244
| document type = Letter type:LIC
| page count = 136
| project = TAC:ME7244
| stage = Request
}}

=Text=
{{#Wiki_filter:Omaha Public PoawerDisric 444 South 161h Street Mall Omaha, NE 68102-2247 LIC-13-0060 May 21, 2013 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==References:==
: 1. Docket No. 50-285
: 2. Letter from OPPD (J. A. Reinhart) to NRC (Document Control Desk), License Amendment Request 10-07, Proposed Changes to Adopt NFPA 805, Performance-Based Standardfor Fire Protection for Light Water Reactor Generating Plants (2001 Edition) at Fort Calhoun Station, dated September 28, 2011 (LIC-11-0099)
(ML112760660)
: 3. Letter from the NRC (L. E. Wilkins) to OPPD (David J. Bannister), Fort Calhoun Station, Unit No. 1 - Request for Additional Information Re: License Amendment Request to Adopt National Fire Protection Agency Standard NFPA 805 (TAC No.
ME7244), dated April 26, 2012 (NRC-12-0041) (ML121040048)
: 4. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandardfor Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, dated July 24, 2012 (LIC-12-0083) (ML12208A131)
: 5. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandardfor Fire Protection for Light Water Reactor GeneratingPlants," 2001 Edition, at Fort Calhoun Station, dated August 24, 2012 (LIC-12-0120) (ML12240A151)
: 6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), Responses to Requests for Additional Information Re: License Amendment Request 10-07 to Adopt NFPA 805, "Performance-BasedStandard for Fire Protection for Light Water Reactor Generating Plants," 2001 Edition, at Fort Calhoun Station, September 27, 2012 (LIC-12-0135) (ML12276A046)
: 7. Email from NRC (L. E. Wilkins) to OPPD (D. L. Lippy), DRAFT: Fort Calhoun NFPA 805, Second Round (ME7244), dated February 22, 2013 (NRC-i13-0014)
: 8. Letter from OPPD (M. J. Prospero) to NRC (Document Control Desk), Responses to Second Request for Additional Information Re: License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME7244), dated April 23, 2013 (LIC-13-0033)

==SUBJECT:==
Remaining Responses to Second Request for Additional Information Re: License Amendment Request to Adopt NFPA 805 at Fort Calhoun Station (TAC No. ME7244)
The Omaha Public Power District's (OPPD's) responses to the Nuclear Regulatory Commission (NRC) second request for additional information (RAI) regarding the license amendment request (LAR) to adopt National Fire Protection Association (NFPA) 805 at the Fort Calhoun Station (FCS) are provided in the enclosure to this letter.
Employment with Equal Opportunity                                                                                  .-
* U. S. Nuclear Regulatory Commission LIC-13-0060 Page 2 of 2 In the Reference 2 LAR, OPPD requested an amendment to Renewed Facility Operating License No.
DPR-40 for FCS, Unit No. 1, to adopt NFPA 805, Performance-BasedStandardfor Fire Protection for Light Water Reactor Generating Plants (2001 Edition). The NRC staff reviewed OPPD's application and determined that additional information was required in order to complete their review and transmitted the original RAIs in Reference 3. OPPD provided responses to the original RAIs in References 4, 5 and 6. The NRC indicated that the staff had reviewed the information provided by the licensee [in References 4-6] and determined that additional information specified in the Reference 7 email is needed for the staff to complete its evaluation.
In Reference 7, the NRC proposed a 60 calendar day response time from the date of draft issuance of the RAIs. However, it was determined that a number of the RAIs would require additional planning and analysis (e.g., sensitivity studies, etc.) in order to complete the final RAI responses. Therefore, the status and proposed extension of select RAI responses were discussed during a clarification teleconference between the NRC and OPPD staff on March 11, 2013. Based on this call and subsequent follow-up discussion with the NRC Project Manager, OPPD provided responses to a select number of the round 2 NFPA 805 RAIs in Reference 8 and provides the remainder of the RAI responses in this letter. Thus, this letter completes the responses to all draft Round 2 RAIs received from the NRC in Reference 7.
There are no new regulatory commitments being made in this letter as a result of the enclosed NFPA 805 RAI responses. Please note, as indicated in References 4 and 5, OPPD plans to supplement the NFPA 805 transition LAR, which will reflect the applicable information delineated in the enclosed RAI responses. The LAR supplement is being tracked by commitment item AR 48249.
If you should have any questions regarding this submittal or require additional information, please contact the Supervisor - Nuclear Licensing, Mr. Bill R. Hansher at 402-533-6894.
I declare under penalty of erjury that the foregoing is true and correct. Executed on May 21, 2013.
ouis P. Cortopassi Site Vice President and CNO LPC/BJV/dll

==Enclosure:==
OPPD's Remaining Responses to Second Request for Additional Information re: NFPA 805 LAR Attachments:    1. Conceptual Drawings in Response to Safe Shutdown RAIs 15 and 16
: 2. Sketches of Conceptual Proposed Design Option(s) as Described for REC-1 12 in Attachment S of the Transition LAR
: 3. Pyrocrete Encased Conduit Locations for Tray Section 34S-1, Drawing 11405-E-67, Sheet 78 and FCS Cable Route Report for Cables in Tray Section 34S-1
[Subsections C3, C3A, C4, and 14] Intersecting this Pyrocrete Assembly c: A. T. Howell, NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. M. Sebrosky, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Omaha Public Power District's (OPPD's)
Remaining Responses to Second Request for Additional Information License Amendment Request to Adopt National Fire Protection Association Standard 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants Fort Calhoun Station (FCS), Unit 1 (TAC No. ME7244)
The Nuclear Regulatory Commission (NRC) proposed a 60-calendar-day response time from the date of draft issuance of the emailed requests for additional information (RAIs) associated with the transition to National Fire Protection Association Standard 805 at FCS. It was determined that a number of the RAIs would require additional planning and analysis (e.g., sensitivity studies, etc.) in order to complete the final RAI responses. Therefore, the status of the RAI responses and proposed extension of select RAI responses were discussed during a clarification teleconference between the NRC and the Omaha Public Power District (OPPD) staff on March 11, 2013. Based on this conference call and subsequent follow-up discussion with the NRC Project Manager, OPPD provided the first set of Round 2 RAI responses by letter dated April 23, 2013 (LIC-13-0033). The remaining NFPA 805 Round 2 RAI responses are enclosed; thereby completing the Round 2 RAI responses for NFPA 805. Table 1 identifies the RAI responses contained in this Enclosure.
Table 1 - Round 2 RAI Responses in this Letter RAI Topic                RAI Number Fire Modeling                    RAI 01.02 Fire Modeling                    RAI 01.03 Fire Modeling                    RAI 06 Fire Protection Engineering      RAI 18.01 Safe Shutdown                    RAI 12.01 Safe Shutdown                    RAI 14 Safe Shutdown                    RAI 15 Safe Shutdown                    RAI 16 Probabilistic Risk Assessment    RAI 01 .c.01 Probabilistic Risk Assessment    RAI 01 .e.01 Probabilistic Risk Assessment    RAI 01 .g.01 Probabilistic Risk Assessment    RAI 01 .h.01 Probabilistic Risk Assessment    RAI 01 .h.02 Probabilistic Risk Assessment    RAI 01 .j.01 Probabilistic Risk Assessment    RAI 03.01 Probabilistic Risk Assessment    RAI 07.01 Probabilistic Risk Assessment    RAI 11.01 Probabilistic Risk Assessment    RAI 15.g.01 Probabilistic Risk Assessment    RAI 18.01 Probabilistic Risk Assessment    RAI 20 Probabilistic Risk Assessment    RAI 21 Probabilistic Risk Assessment    RAI 22 Please note that OPPD plans to supplement the NFPA 805 transition license amendment request (LAR) to reflect any applicable information delineated in the following RAI responses at a later date.
[AR 48249]
1

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Fire Modeling RAI 01.02:
In a letter dated July 24, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12208A131), the licensee responded to Fire Modeling Request for Information (RAI) 01b. Please provide the following additional information:
: a. A description of the criteria used to determine the scenarios in which ignition of intervening combustibles was judged not to expand the zone of influence (ZOI) of the ignition source.
OPPD's Response to Fire Modelinq RAI 01.02 a.:
In response to Fire Modeling RAI 01b., a plant walkdown of the modeled ignition sources was performed, and scenarios that contain non-cable intervening combustibles were noted.
Examples of non-cable intervening combustibles include foam pipe insulation and heating, ventilating, and air conditioning (HVAC) duct insulation.         For the subset of scenarios discussed in the table below, the response to Fire Modeling RAI 01b. included engineering judgments that the intervening combustible would not appreciably expand the fire scenario zone of influence. The table below provides additional bases for these engineering judgments.
FMRAI-01.02a Table 1 - Screening Bases for Intervening Combustibles Scenarios Scenario      Ignition Source Screening Basis Recognizing the subjectivity of the original engineering judgment, if a fire in this electrical cabinet were conservatively assumed to fail all targets (due to propagation of intervening combustibles) in this large FC06-3-1S4          AI-205        compartment, the scenario CDF and LERF would increase by 8.95E-10/yr and 4.78E-1 1/yr, respectively.
This increase would not be sufficient to change the total CDF, total LERF, VFDR ACDF, or VFDR ALERF within the significant digits reported by the NFPA transition LAR (LIC 11-0099).
The intervening combustible is a few feet of small FCO6-3-IS8            LP-5        diameter (-3/8 inch) temporary plastic tubing. This tubing is considered a transient combustible and is not part of the fixed LP-1 fire scenario.
Small bucket is combustible of concern. This bucket is considered a transient (walkdowns were performed FC06-3-IS12            LP-1        during shutdown conditions) and would typically be removed during power operation. The bucket is not considered part of the fixed LP-1 fire scenario.
The intervening combustible is a short length of small diameter drain hose. This is considered a transient combustible and is not part of the fixed Al-182 fire scenario.
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U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure FMRAI-01.02a Table 1 - Screening Bases for Intervening Combustibles Scenarios Scenario      Ignition Source Screening Basis The intervening combustible is demineralized water FC20-7-IS12         Al-284A     insulation. There are no targets overhead above this ignition source, and there would be no new targets to consider if the ZOI were expanded.
Intervening combustible is a small amount of insulation.
FC20-7-IS25        CH-12-MS     This insulation is judged to negligibly affect the scenario zone of influence, and there would be no new targets to consider if ZOI were expanded.
There would be no new targets to consider if ZOI were MCC-3B3 AND    expanded. Note also that this intervening combustible is MCC-4C4      considered a transient combustible, and it is therefore not part of the fixed FC31 -1S12 fire scenario.
There would be no new targets to consider if ZOI were HE-5 Power    modestly expanded. Note also that this intervening Switch    combustible is considered a transient combustible, and it is therefore not part of the fixed FC31-IS17 fire scenario.
The intervening combustible is ductwork insulation. This FC34C-IS1         MCC-3C1      insulation will not ignite as it is not within the plume ZOI, nor is it within the flame radiation ZOL.
The intervening combustible is ductwork insulation. This FC34C-IS3         MCC-3B1      insulation will not ignite as it is not within the plume ZOI, nor is it within the flame radiation ZOI.
The intervening combustible is ductwork insulation. This FC34C-IS5            RC-4A     insulation will not ignite as it is not directly over the ignition source, nor is it within the flame radiation ZOI.
Intervening combustible is a short length of thin foam CAB-SWYD-     pipe insulation. The heat release rate contribution of this FC36A-IS1            CONN      very small quantity of combustible insulation is negligible compared to the overall heat release rate of the electrical cabinet and multiple overhead cable trays.
Intervening combustible is a short length of thin foam pipe insulation. The heat release rate contribution of this FC36A-IS12          1 B3C-4C    very small quantity of combustible insulation is negligible compared to the overall heat release rate of the electrical cabinet and multiple overhead cable trays.
Intervening combustible is a short length of thin foam pipe insulation. The heat release rate contribution of this FC36A-IS25             1A1      very small quantity of combustible insulation is negligible compared to the overall heat release rate of the electrical cabinet and multiple overhead cable trays.
Intervening combustible is a short length of thin foam pipe insulation. The heat release rate contribution of this FC36B-IS38             1A4      very small quantity of combustible insulation is negligible compared to the overall heat release rate of the electrical cabinet and multiple overhead cable trays.
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U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure
: b. Justification for the basis of the revised core damage frequency (CDF) and large early release frequency (LERF) calculations for scenario FC20-1-1S8 that are based on the assumption that the 98th percentile heat release rate (HRR) is needed to ignite the pipe insulation. For example, in Figure F-1 of NUREG/CR-6850, "EPRVNRC-RES Fire PRA Methodology for Nuclear Power Facilities," the severity factor (SF) for a pump fire with an intervening combustible target at 2 m above the pump is approximately 3%.
With a SF of 3% the re-calculated CDF and LERF would be 1.13E-06 and 1.18E-07, respectively (compared to 7.63E-07 and 7.89E-08).
OPPD's Response to Fire Modelina RAI 01.02 b:
Figure F-1 uses criteria of 2050 Celsius and 6 kW/m2 (for thermoplastic cable); whereas the FCS fire PRA uses 3300 Celsius and 11 kW/m2 (for thermoset cable). Therefore, Figure F-1 of NUREG/CR-6850 is not applicable to the FCS fire PRA.
Figure F-1 also does not list any calculation inputs, such as the ambient air temperature and density, so it is unknown whether they are consistent with the FCS-specific calculations.
The subject foam insulation is in the plume of FC20-1-1S8, which has a peak heat release characterized by a gamma distribution with a=0.84, P3=59.3, and a 98th percentile value of 211 kW per Table G-1 of NUREG/CR-6850.
The following equations characterize the centerline plume temperature:
1/3   2/3 2//3 TP  -T   =9.1{ g-2 gc-p QQc (z-zo--
Q, = XC QT 2/5 Zo =o.083QT -1.02D Where, Parameter              Description                     Value                   Notes TP        Temperature at specified                 663&deg; K      Ignition temperature of height in plume, K                                   flexible foam plastic per Table 2-11.3 of the SFPE Handbook of Fire Protection Engineering, Fourth Edition.
T11       Ambient temperature, K                   2930 K g        Acceleration of gravity, m/s 2
9.81 m/s 2 cp        Specific heat of air, kJ/(kg K)    1.01 kJ/ (kg K)
Density of air, kg/m 3                 1.2 kg/m 3 Pl,,
4

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Parameter             Description                Value                   Notes Convective heat release           Calculated Q,      rate, kW QT       Total heat release rate, kW       Calculated Xc      Convective fraction, unitless         0.7 z       Specified height within              2.0 m plume, m z0      Virtual origin, m                 Calculated D       Fire source diameter, m             0.34 m       Assumes fire size is one square foot Solving the above equations for QT, the minimum heat release rate required to ignite the foam pipe insulation is conservatively calculated as 258 kW. This value is greater than the 98th percentile value of 211 kW, and therefore use of a 0.02 severity factor is conservative in response to Fire Modeling RAI 01 b.
Note that when the thermoset cable damage temperature (3300 Celsius) is conservatively used instead of the foam ignition temperature, the severity factor is calculated to be 0.02, as reported by response to Fire Modeling RAI 01 b.
Fire Modeling RAI 01.03:
In a letter dated July 24, 2012 the licensee responded to Fire Modeling RAI Old.
NUREG-1805, "Fire Dynamics Tools (FDTs) Quantitative Fire Hazard Analysis Methods for the U.S. Nuclear Regulatory Commission Fire Protection Inspection Program," states that the method of McCaffrey, Quintiere, and Harkleroad (MQH) correlation cannot be used when the vent is located in the ceiling. The correlation is therefore not valid for compartments with natural ventilation or compartments with forced ventilation that shut down in the event of a fire and that have vents in the upper part of the room.
During the walkdowns that are referred to in the response to RAI Old, please describe whether compartments were identified that fit the above description. If there are such compartments, justify the validity of the MQH-based analysis.
OPPD's Response to Fire Modeling RAI 01.03:
Per discussion with the OPPD HVAC system engineer and per plant walkdown April 2-6, 2012, HVAC vents are generally not located at the ceiling. They are, however, frequently located in the upper portion of the compartment, often close to the ceiling.
5

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure The base fire PRA supporting the NFPA 805 transition LAR (LIC-1 1-0099) implemented the MQH correlation for all upper layer temperature calculations. The MQH method is most valid for naturally ventilated compartments with an open door. This condition is likely to occur later in the fire event, after fire brigade arrival and manual suppression activities have initiated. However, prior to fire brigade arrival, the doors are typically closed and the compartment is mechanically ventilated.
To more realistically model the period prior to fire brigade arrival, the fire PRA was re-quantified using the method of Foote, Pagni, and Alvares (Equation 2-7 of NUREG-1805) to calculate upper layer temperature in mechanically ventilated compartments. When this method is implemented, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF are unchanged (within reported significant digits) as compared to the values reported by LIC-1 1-0099, which implemented the method of MQH.
This result is sensible given the low fire PRA sensitivity to severe fire scenarios leading to upper layer temperatures that exceed target damage thresholds. The frequencies of such scenarios are relatively low. In addition, automatic suppression (where installed) and manual suppression are credited to prevent damaging hot gas layer formation, further reducing the frequency of such events.
Finally, for the scenarios that do lead to a damaging hot gas layer, typically at least one train (or a significant portion of one train) of mitigating equipment remains unaffected due to electrical separation.
Fire Modelinq RAI 06:
: a. The responses to PRA RAI O1.c.ii in the July 24, 2012 letter and to Fire Modeling RAI 01.c in the August 24, 2012 letter (ADAMS Accession no. ML12240A151) discuss modeling of cable tray fires. The response to PRA RAI 01.c.ii indicates that fire is propagated from the ignition source to the overhead cables, indicating that fire is propagated vertically.
Additionally, the response states that the fire growth profile of the ignition source and ignited cable tray configuration are summed to obtain the overall fire growth profile.
However, the response to Fire Modeling RAI 01.c does not address how the combined HRR was addressed nor how the higher HRR impacts the ZOI. Please explain how the effect of the increased HRR due to vertical propagation to cable trays on the ZOI (in all aspects), and the resulting targets selected for damage in the PRA, were determined.
OPPD's Response to Fire Modeling RAI 06 a:
As described in response to PRA RAI 01.c.ii, the fire PRA supporting LIC-11-0099 models fire propagation from the ignition source to overhead cable trays. The fire growth profile of the ignition source and ignited cable tray configuration are summed to obtain the overall fire scenario heat release rate profile. The scenario heat release rate profile is then used to calculate the hot gas layer temperature profile. If at any point the hot gas layer temperature exceeds target damage temperature (e.g., 330 degrees Celsius for thermoset cables), the scenario Zone of Influence (ZOI) is expanded to fail all targets within the compartment.
If the hot gas layer temperature never exceeds target damage temperature (e.g., 330 degrees Celsius for thermoset cables), then targets within a ZOI local to the ignition source are modeled to fail. This localized ZOI is calculated using fire modeling equations that characterize radiant heat flux, plume temperature profile, and ceiling jet temperature profile. In practice, the ZOI is a cylinder, whose radius is either the distance at which the fire will cause a radiant heat flux exceeding the target damage threshold, or the distance at which the ceiling jet temperature exceeds the target damage threshold, whichever is greater. This cylinder is conservatively applied from floor to ceiling, even if the plume temperature profile is not sufficient to damage targets all the way to the ceiling.
6

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure The impact of cable tray fire propagation on the ZOI was considered using the 35 degree outward spread of fire, as it propagates up through the stack, specified by Appendix R to NUREG/CR-6850. A plant walkdown was performed April 2-6, 2012 to assess whether fire PRA targets exist outside the modeled ZOI but within the 35 degree spread of fire upward through a cable tray stack. This walkdown included all areas in which the ZOI fire modeling approach was implemented. The walkdown did not identify any cases in which this effect required revising (adding to) the existing source-target data set.
Fire PRA implementation of this approach resulted in a spectrum of modeled plant damage states, ranging from damage to the ignition source itself, damage to the larger target set within the ignition source ZOI and including 35 degree fire propagation through the tray stack, and damage to all targets within the compartment. The modeled ZOls are large and conservatively calculated, and this is confirmed when the NPP fire events contributing to the fire frequencies are reviewed (i.e., the modeled ZOls are significantly larger than those suggested by the fire event reports upon which the modeled frequencies are based).
: b. The response to FM RAI O1.c (Part 2) states that the rate of horizontal flame spread along the cable tray is conservatively not credited because the entire characteristic length is modeled to ignite instantaneously. This is consistent with the guidelines in Section R.4.2.1 of NUREG/CR-6850. However, a characteristic length of 1 ft was assumed which deviates from Section R.4.2.1 of NUREG/CR-6850. Please quantify the effect on the ZOI, hot gas layer (HGL) development and risk (CDF, LERF, delta (A)CDF and ALERF) of using a) The width of the vertical section of origin for fires in cabinets that have vertical barriers (switchgear, MCCs, control panels in relay rooms, auxiliary control rooms, etc.) or, b) The width of the cabinet if it is a single cabinet with no vertical barriers, as the characteristic length for calculating fire propagation in and HRR of horizontal cable trays.
OPPD's Response to Fire Modeling RAI 06 b:
Additional walkdowns were performed to measure the characteristic length of all electrical cabinets. Per the RAI, for cabinets with vertical dividers between each section, the characteristic length was taken as the width of the vertical section of origin. For cabinets without vertical partitions between each section, the characteristic length was taken as the entire cabinet width.
The field-measured values were incorporated in the fire PRA in place of the previously assumed one foot.
The fire PRA models cabinets with multiple vertical sections as individual fire scenarios, with each scenario frequency corresponding to the summation of all vertical section frequencies in the cabinet. For cases where a cabinet consisted of multiple vertical sections of varying characteristic length, the most conservative value was used to represent all of its sections. With consideration for the ability to create a damaging hot gas layer, a greater characteristic length is more conservative (involving a greater length of cable tray in the scenario, thereby increasing the overall scenario HRR). However, with consideration for the severity factor of a given scenario, a smaller characteristic length is more conservative (fires with smaller fire diameters have more aggressive plume temperature profiles). Such cases were evaluated both ways; using the greatest of the individual characteristic lengths, and then the smallest, with the most conservative result used for the final assessment.
7

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure When the new characteristic lengths were implemented, the CDF and LERF for all fire scenarios were either unaffected or reduced slightly. The total fire CDF and LERF decreased slightly.
Total CDF reduced by 1.89E-07 /yr, and total LERF reduced by 1.66E-09 /yr. This effect is attributed to reduced severity factors for several scenarios when a larger characteristic length (corresponding to the vertical section width) is used in place of the smaller and generically assumed one foot.
In conclusion, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF remain within RG 1.174, Revision 1, Region II when the electrical cabinet characteristic lengths are taken as either the vertical section width (for cabinets with partitions between each section) or the entire cabinet width (for cabinets without partitions).
8

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Fire Protection Engineerinq RAI 18.01:
By letter dated July 24, 2012, the licensee responded to Fire Protection Engineering RAI 18.
: a. The letter indicated that Approval #7 would be deleted as compliance with NFPA 805 section 3.11.5, is being met through Exception #2. The licensee stated that these electrical fire barrier raceway system (ERFBS) assemblies being installed prior to issuance of Generic Letter 86-10, Supplement 1, "Fire Endurance Test Acceptance Criteria For Fire Barrier Systems Used To Separate Redundant Safe Shutdown Trains Within The Same Fire Area," were tested against the end point temperature requirements similar to the acceptance criteria of NFPA 251, "Standard Methods of Tests of Fire Resistance of Building Construction and Materials." Please provide a detailed description of the ERFBS testing performed, including the end point temperatures reached and the acceptance criteria used.
OPPD's Response to Fire Protection Enqineering RAI 18.01 a:
The time-temperature data supplied by the Pyrocrete manufacturer is located in Attachment B to letter LIC-80-0062. The purpose of the testing was to experimentally determine the time the back side temperature of Pyrocrete reached 250&deg;F above ambient, when applied at varying thicknesses, and exposed to the standard ASTM E-1 19 time/temperature. The results of the testing show that a 2-inch thickness of Pyrocrete did not reach 250&deg;F above ambient for 195 minutes. These configurations were employed prior to the issuance of Generic Letter 86-10, Supplement 1, and were tested against the end point temperature requirements similar to the acceptance criteria of NFPA 251 that are identified in Generic Letter 86-10, Supplement 1.
These acceptance criteria are based on the enclosures being designed to limit temperature rise on the cable side of the enclosure to 250&deg;F over the ambient temperature of the space after a three-hour fire. Assuming a 90&deg;F space temperature at the beginning of the fire, this would give a final temperature of 340&deg;F at the end of the three-hour period at the inner surface of the enclosure. Time-temperature data supplied by the Pyrocrete manufacturer shows that the temperature on the cable side of the enclosure is held to 180&deg;F above ambient for the first 120 minutes. This would give final temperature of 270&deg;F on the inside of the enclosure after the two-hour fire. It then increases to 280&deg;F at 150 minutes and finally reaches 340&deg;F after the full three hours. Power and control cable in use at FCS are type "Pyratrol Il'" manufactured by Rockbestos. These cables have been LOCA tested to a minimum of 286 0 F and have shown no degradation. Cable with similar outer jacket (Fire Wall Ill) has been LOCA tested to a minimum of 340'F and, as per information received from Rockbestos, showed no degradation. Therefore, it is concluded that the temperature rise inside the enclosure will not affect the performance of the cables while under load.
See the revised compliance statement for NFPA 805 Section 3.11.5 in the response to FPE RAI 18.01 .b below (delineated with revision bars).
: b. Please describe whether the ERFBS enclosure protecting cable tray 54S (formerly separating fire area 36C from 36B) should also be listed under Table B-i, Section 3.11.5, Exception #2.
9

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure OPPD's Response to Fire Protection Encineerinca RAI 18.01 b:
The ERFBS enclosure protecting cable tray 54S (formerly separating fire area 36C from 36B) should also be listed under Table B-i, Section 3.11.5, Exception 2. Therefore, it is identified in the updated response to NFPA 805 Section 3.11.5 resulting from fire protection engineering RAIs 17 and 18, as follows (new text identified by revision bars):
NFPA 805     Compliance               Compliance Basis                Reference Document Ch 3 Ref , Statement 3.11.5
* Complies      COMPLIES WITH CLARIFICATION:            EA-FC-93-033, "Evaluation Electrical     with          Letter LIC-06-0076 states: "FCS uses    of Fire Barrier to GL 92-08 Raceway        Clarification 3M Interam E50A, Pyrocrete, and       and Evaluation of Fire Barrier                 Pabco materials as fire barrier        Additional Miscellaneous
* Complies by   protection for redundant trains of safe Fire Barriers," Rev. 2 /All Systems        Previous      shutdown equipment located in the (ERFBS)        NRC           same fire area to satisfy 10 CFR 50,    Letter LIC-79-192 from Approval      Appendix R III.G requirements.          OPPD (Short) to NRC Installation and inspection procedures  (Reid) dated July 9, 1979/
have verified that these fire barrier   Attachment 2, Response to materials were installed in a manner    Question 1 consistent with tested configurations.
Deviations from tested and analyzed     Letter LIC-80-0062 from configurations were evaluated in        OPPD (Jones) to NRC accordance with Generic Letter 86-      (Clark) dated May 20, 1980 10, Supplement 1. These evaluations     / Attachment B provide the necessary assurance that the installed fire barrier systems      Letter LIC-83-21 9 from would possess the commensurate          OPPD (Jones) to NRC level of fire protection."              (Clark) dated August 30, 1983 / Attachment A, Overhead horizontal Train B cabling     Sections Ill.A, IlI.B, VI.A, encased in conduit, wrapped in metal    and VI.B lath, and surrounded by 2 inches of Pyrocrete in fire area 36A between     Letter NRC-85-200 from column lines 3a and 4a, from fire area  Butcher (NRC) to Andrews 36B and terminating at panel AI-109B    (OPPD) dated July 3, 1985 in fire area 36A (Panel Al-109B is      / Enclosure 2, Safety enclosed in concrete block). Vertical   Evaluation, sections 4.2, Train B cable tray sections 22S to 5-   4.4, 5.2, 5.4, and 7.3 4A from fire area 32 (below) to fire area 41 (above) within fire area 36A    Letter LIC-06-0076 from between column lines 6d and 7a is       Faulhaber (OPPD) to NRC wrapped in metal lath, and              Document Control Desk surrounded by 2 inches of               dated August 2, 2006 / All Pyrocrete. Vertical Train A cable tray sections 10S to 5-4B from fire area 32 (below) to fire area 41 (above) within fire area 36A between column lines 6d and 7a is wrapped in metal lath, and surrounded by 2 inches of Pyrocrete. These three (3) Pyrocrete enclosures comply with Exception No. 2 of section 3.11.5.
The time-temperature data supplied by the Pyrocrete manufacturer is included as Attachment B to letter LIC-80-0062. The purpose of the testing was to experimentally 10

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure NFPA 805      Compliance            Compliance Basis              Reference Document Ch 3 Ref I    Statement determine the time the back side temperature of Pyrocrete reached 250'F above ambient, when applied at varying thicknesses, and exposed to the standard ASTM E-1 19 time/temperature. The results of the testing document that for a 2-inch thickness of Pyrocrete did not reach 250&deg;F above ambient for 195 minutes. These configurations were employed prior to the issuance of Generic Letter 86-10, Supplement 1, and were tested against the end poini temperature requirements similar to the acceptance criteria of NFPA 251 that are identified in Generic Letter 86-10, Supplement 1. Therefore, these Pyrocrete configurations are acceptable as 3-hour rated enclosures in accordance with Exception No. 2 of Section 3.11.5 of NFPA 805.
COMPLIES BY PREVIOUS NRC APPROVAL:
A Pyrocrete barrier separates redundant cabling in the air compressor room (fire area 32, room 19). This configuration was approved by the NRC as identified:
Per Sections IV.A and IV.B of attachment A to letter LIC-83-219, "This area contains two cable tray systems which serve various safe shutdown equipment in trains A, B, EA, and EB. All 480V motor control center power feeder cables are located in this area. The trays containing these cables do not meet the separation criteria of section III.G.2 of Appendix R...A fire barrier designed in accordance with Regulatory Guide 1.175 and IEEE-384 (1977) has been provided where these redundant cables cross each other in cable trays. This barrier, (similar to UL design X-719) comprised of metal lath and 2" of Pyrocrete of standard UL construction, meets the 3-hour rating per independent testing by Johns-Manville Corporation. Specifically, this barrier separates cable tray 7S from cable trays 19S and 20S. A second barrier (of same design as stated above) has been provided where cable tray 18S crosses cable tray 1 S."
11

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure NFPA 805      Compliance              Compliance Basis              Reference Document Ch 3 Ref I    Statement Per sections 5.2 and 5.4 of enclosure 2 to letter NRC-85-200, "The area contains two cable tray systems which serve various safe shutdown equipment in trains. All 480V motor control center power feeder cables are located in this area. A partial fire barrier has been provided at the point where redundant cables cross over one another in cable trays.. we conclude that the existing fire protection with the proposed modifications provides an equivalent level of safety to that achieved by compliance with section III.G."
An unrated Pyrocrete enclosure forms part of a credited barrier between fire areas 31 and 31A in the intake structure. This configuration was approved by the NRC as identified:
Per sections IIL.A and 1II.B of attachment A to OPPD letter LIC                                     219, "The power cables for all four raw water pumps are contained in individual rigid conduits. These conduits are routed through a common fire barrier enclosure, located above the circulating water pump bay, such that the cables inside the barrier do not meet the specific section IIL.G fire protection requirements of separation, detection, and suppression.. .A Pyrocrete enclosure has been installed (details of which were transmitted to the Commission with protect the cables for pumps AC-10A and AC-10B from any credible fire."
Per response to question 1 in Attachment 2 to OPPD letter LIC                                     192, "We are proposing to provide 3 hour fire rated enclosure to protect these cables from an area fire. The barrier design will be similar to Fire Area 6..." (per discussion of Fire Area 6 in same letter, "The enclosure will utilize a fire barrier design incorporating metal lath covered with Pyrocrete which is of standard UL construction. The necessary 3 hour fire rating is achieved by providing 2" Pyrocrete over metal lath.")
Per sections 4.2 and 4.4 of Enclosure 12

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure NFPA 805      Compliance              Compliance Basis                  Reference Document Ch 3 Ref      Statement   I                                          I 2 to NRC letter NRC-85-200, "The power cables for all four raw water pumps are contained in individual rigid conduits. These conduits are routed through a common noncombustible heat shield, located above the circulating water pump bay.. .we conclude that the existing fire protection provides an equivalent level of safety to that achieved by compliance with section III.G."
An unrated Pyrocrete installation forms the barrier between fire areas 36B and 36C in the west switchgear room. This configuration was approved by the NRC as identified:
Per sections VI.A and VI.B of attachment A to OPPD letter LIC                                       219, "In the west half of the switchgear room, cable tray 54S contains 3A backup pressurizer heater control cables. This tray is in the same fire area as the 4B electrical transformers which provide power to the remaining two backup heater banks. A Pyrocrete barrier has been installed to protect cable tray 54S in this area. However, this application of Pyrocrete has not been approved by the NRC.. .Although the use of Pyrocrete as a 3-hour rated fire barrier in this specific application has not as yet been approved by the Commission, it is the District's position, based on our engineering judgment, that the Pyrocrete enclosure protecting cable tray 54S effectively separates the control cables for bank 3A backup pressurizer heaters from the 4B electrical transformers, and adequately protects them from any credible fire in the area. The barrier design (similar to UL design X-719) incorporates metal lath covered with Pyrocrete which is of standard UL construction."
Per section 7.3 of Enclosure 2 to MRC letter NRC-85-200, "We consider the barrier to be an unrated heat shield that has a limited capacity to prevent damage to protected cables. But because of the reasons discussed.. .we do not expect a fire of significant magnitude or duration to 13

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure NFPA 805      Compliance                  Compliance Basis               Reference Document Ch 3 Ref      Statement occur. Therefore, because of the limited fire load and the automatic fire detection and suppression systems in this area, it is our judgment that this heat shield will provide reasonable assurance that one division of shutdown cable will remain free of damage until the activation of the fixed fire suppression and eventual fire extinguishment."
EA-FC-93-033 identifies fire endurance tests that qualify the 3M Interam fire wrap in fire area 34A as equivalent to a one-hour rating.
: c. During the site audit walk down of fire area 36A (east switchgear room), the NRC staff noticed the horizontal Pyrocrete assembly intersected with a non-protected cable tray (approximately mid-room). The Pyrocrete@ configuration at this intersection did not appear to match the normal Pyrocrete assembly, nor the description contained in Attachment L, Approval #7, page L-14. Please clarify whether the configuration at this intersection is acceptable and meets the analyzed configuration. Please provide the basis for the conclusion and any reference to the engineering analysis and testing.
Identify the non-protected cables intersecting this Pyrocrete@ assembly (e.g. division, equipment/system).
OPPD's Response to Fire Protection Enciineering RAI 18.01 c:
The cable tray in the east switchgear room is completely enclosed with 2 inches of Pyrocrete on metal lath between the adjacent intersecting exposed cable trays. This configuration is consistent with other Pyrocrete enclosures at FCS. As identified in response to Fire Protection Engineering RAI 18.01a, the results of the time-temperature testing data documented in Attachment B to letter LIC-80-0062 that a 2-inch thickness of Pyrocrete did not reach 250&deg;F above ambient for 195 minutes. Since this configuration was employed prior to the issuance of Generic Letter 86-10 Supplement 1, and was tested against the end point temperature requirements similar to the acceptance criteria of NFPA 251 that are identified in Generic Letter 86-10 Supplement 1, the Attachment L request is no longer required, as identified in the original response to Fire Protection Engineering RAI 18.
The tray section identification for the cables is 34S-1. There are four trays in the 34S-1 stack. The Pyrocrete enclosed conduits pass between the lowest tray at elevation 1019'-6" and the next highest tray at elevation 1020'-6". (Reference drawings 11405-E-73, Sheet 1 and 11405-E-67, Sheet 78) Attachment 3 provides drawing 11405-E-67, Sheet 78, delineating the Pyrocrete encased conduits location relative to the tray sections. In addition, Attachment 3 includes the FCS Cable Route Report from the FCS Automated Cable Tracking System (FACTS) cable routing database for the cables identified in tray section 34S-1 intersecting this Pyrocrete assembly.
14

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Safe Shutdown RAI 12.01:
Attachment S, Table S-2, Committed Modifications Item REC-111 of the LAR indicates that high energy arcing fault (HEAF) barriers will be installed around/near the 4 KV switchgear and bus ducts in the 4kV Switchgear Rooms. These barriers are intended to reduce the local damage association with a potential HEAF, and subsequently reduce the risk calculated for fire areas 36A and 36B.
Please provide complete design and construction information for the HEAF barriers and supporting structures including dimensions, materials, construction types, etc. In addition, describe how the zone of influence (ZOI) was translated into the physical dimensions of the HEAF barrier, and also how the HEAF barrier will be tested to ensure it will mitigate a HEAF.
Please include in the response pictures, drawings or renditions of the 4 kv switchgear and related equipment and bus ducts for Fire Areas 36A and 36B.
OPPD's Response to Safe Shutdown RAI 12.01:
During a teleconference with the NRC Project Manager and technical reviewers on March 11, 2013, clarification of this RAI was provided and the NRC is requesting only conceptual information related to this NFPA 805 transition implementation item; therefore, specific pictures, drawings and renditions of the 4kv switchgear related equipment and bus ducts for Fire Areas 36A and 36B are not required in response to this RAI. While the detailed design and construction specifications will be developed during the NFPA 805 implementation period, the proposed HEAF barriers are envisioned to have the attributes described in the following paragraphs.
Note that OPPD is considering plant modifications to reduce the scope of, or potentially replace, the HEAF barrier installation. These modifications are primarily to prevent loss of offsite power during switchgear room fire events. OPPD plans to notify the NRC if these other modifications are pursued in lieu of the HEAF barriers described herein.
The HEAF barriers are intended to minimize risk significant target failures beyond the faulted switchgear or load center, and any components electrically dependent on the faulted bus. Similarly for bus ducts, the barriers are intended to minimize risk significant target failures beyond the bus duct itself, and any components electrically dependent on the bus duct.
Switchqear and Load Center HEAFs The objective is to minimize damage to risk significant targets beyond the faulted switchgear or load center. In describing the HEAF zone of influence (ZOI), NUREG/CR-6850 Section M.4.2 states that unprotected cables in the first overhead cable tray will be ignited concurrent with the initial arcing fault provided that this first tray is within 1.5 m (5') vertical distance of the top of the cabinet.
Similarly, trays within 0.3 m (1') horizontally of the cabinet's front or rear face will ignite. The NUREG also states that "cables in conduit are protected in this context."
So, to prevent damage and ignition of the first overhead cable tray(s), the HEAF barriers will be of non-flammable construction, and they will each consist of a steel plate mounted between the HEAF source and target(s) requiring protection. Any conduits penetrating the plate, and originating from the faulted switchgear or load center, will contain elastomer plugs. Any gaps between the steel plate and conduits will be fitted snugly with a fire barrier material, such as HEMYC.
15

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure The barriers will primarily be mounted to existing supports and structural members associated with the cable trays requiring protection. The barriers will meet applicable seismic design requirements.
The HEAF barriers will be, at a minimum, of similar gauge to an electrical cabinet enclosure. Per NUREG/CR-6850 Supplement 1 Section 7.2.1.5 (for bus duct HEAFs), the first "solid surface" encountered by the blast will truncate the ZOI. Examples of a "solid surface" include a sealed cabinet top or solid (unventilated) cable tray cover. While this guidance suggests the relatively thin gauge of a tray cover would be sufficient, OPPD will conservatively use a thicker gauge similar to an electrical cabinet enclosure.
Aluminum will not be used, per the guidance of NUREG/CR-6850 Supplement 1 Section 7.2.1.5, which states that aluminum tray covers are not sufficient to prevent ignition of cables by molten materials originating from a bus duct HEAF.
Note that while the referenced guidance in NUREG/CR-6850 Supplement 1 Section 7.2.1.5 was written for bus duct HEAFs, OPPD is extending this guidance to switchgear and load center HEAFs, which are expected to be of similar (or lower) energy release.
For each postulated switchgear or load center HEAF, there is an ensuing fire that follows the growth characteristics of an electrical cabinet. For cases where minimizing damage to overhead cable trays is required, the width of the barrier will extend beyond the edge of the cable tray stack, such that the plume is deflected sufficiently away from the stack to preclude damage and/or ignition. The National Institute of Standards and Technology (NIST) Fire Dynamics Simulator will be used to verify the barrier width and plume deflection are sufficient to prevent cable temperature and incident heat flux from causing damage and/or ignition.
Bus Duct HEAFs The objective is to minimize damage to risk significant targets beyond the faulted bus duct and component electrically dependent on the faulted bus. NUREG/CR-6850 Supplement 1 Section 7.2.1.5 describes the ZOI for bus duct HEAFs. This ZOI is summarized as a sphere of 1.5 feet radius originating from the fault, in addition to a circular cone (of 30 degree solid angle) extending downward from the fault location. This ZOI is truncated by the first "solid surface" encountered.
Examples of a "solid surface" include a sealed cabinet top or solid (unventilated) cable tray cover.
So, in order to prevent damage to risk significant targets within the ZOI, a barrier of similar attributes to the switchgear / load center HEAF barrier is proposed. The barrier would be a steel plate, of similar gauge to an electrical cabinet enclosure. The barriers will primarily be mounted to existing supports and structural members associated with the cable trays requiring protection. The barriers will meet applicable seismic design requirements.
Differing from the previously described barriers, it is not envisioned that conduits would penetrate this plate (conduit penetrations are more applicable to switchgear / load center HEAF, which have conduits originating from the faulted bus cabinet). The bus duct barrier would not require fire barrier material atop the plate, which is primarily used by the switchgear / load center HEAF barrier to prevent fire propagation to overhead cable trays.
16

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Safe Shutdown RAI 14:
LAR Attachment T Clarifications to Approved Exemptions - For the requests for approval regarding the previously approved exemptions, provide clarifications as follows:
: a. Prior Approval Clarification Request 1 (page T-2): For steam generator (SG) level and pressure instrumentation, reactor coolant system (RCS) temperature instrumentation, and source range monitoring in the containment, cable routing is provided in the original exemption. Because instrument sensing line tubing was not addressed in the original exemption, Attachment T requests that this tubing be included in the exemption as well.
The original SER identifies acceptable separation criteria for cables in various areas of the containment. The LAR clarification states, "The instrument sensing line routings meet these criteria and therefore are considered to be covered under this exemption.
Based on this assumption, the instrument sensing lines have adequate separation to support NFPA 805 safe shutdown requirements for providing at least one channel of reliable indication for process monitoring of pressurizer level and pressure, and steam generator level and pressure."
Please provide a more detailed description of the instrument sensing line separation.
OPPD's Response to Safe Shutdown RAI 14 a:
From EA-89-055, Safe Shutdown Analysis:
Within the Containment, the redundant instrument channels and sensing lines have a minimum of 20 feet of horizontal separation with minimal intervening combustibles. The intervening combustibles consist of lightly loaded cable trays. The sensing lines have common points of origin (i.e., Pressurizerand Steam Generators). At the points of origin it is not possible to achieve physical separation. From the point of origin the lines are routed in different directions to the transmitters which have a minimum of 20 feet of horizontal separation. The steam generator instruments are located in separate quadrantswithin Containment and typically have 50 feet of separation. This separationis consistent with the separation discussed and credited in the NRC SER dated July 3, 1985. This SER grants an exemption from 20 feet of separation with no intervening combustibles for certain areas within Containment. The SER specifically addresses the pressurizerbays and areas where the intervening combustibles are made up of IEEE-383 qualified cables. The instrument sensing line routings meet these criteria and therefore are considered to be covered under this exemption. Based on this, the instrument sensing lines have adequate separationto supportAppendix R safe shutdown.
From Updated Safety Analysis Report (USAR) Section 8.5.6:
The criteriafor the process instrumentationinside the Containment Building were as follows:
: a. Process instruments within the containment are located in shielded areas accessible for maintenance. Redundant instruments for safety instrumentation are identified by tag numbers prefixed by a capital letter A, B, C, or D followed by a slash(/). Sensing lines to these redundant instruments are run from separate sensing points.
17

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Redundant instruments within the containment for a safety channel are located on physically separate racks or on a common rack. However, where these instruments are located on a common rack metal barrier plates are provided to maintain separationbetween all Al, B1, C/, and DI instruments and lines. Redundant instrument racks were not placed closer than three feet from each other unless they were separated by a wall or furnished with a metallic plate on their sides. Redundant instrument sensing lines were not placed closer than three feet from each other unless they are separatedby an adequate shield (steel plate, steel channel, concrete wall, etc.) to protect the lines against mechanical injury. In the case where two redundant sensing lines cross each other the mechanical separationwas provided for a radius of at least two feet from the point of crossing.
: b. Prior Approval Request 1: For SG level and pressure instrumentation, and RCS temperature instrumentation describe the redundant channel availability for fires in the containment. The background/basis describes the separation for redundant trains of safe shutdown components in this area including steam generator pressure and level transmitters, reactor coolant hot and cold leg temperature instrumentation, and neutron flux indication and all associated cables. It states that at least one channel of each will remain free of fire damage.
Please provide clarification as to whether "free of fire damage" is for both RCS/SG loops or just one loop. If only one RCS/SG loop of instrumentation is available, justify why this is sufficient for safe shutdown.
OPPD's Response to Safe Shutdown RAI 14 b:
The NFPA 805 safe shutdown strategy in Containment credits both steam generators (SGs).
Only one of the two SGs may have reactor coolant T-hot and T-cold indication available based on fire location; however, both SGs will always have at least one SG level indication loop and one SG pressure indication loop available regardless of the fire location. Both inside Containment auxiliary feedwater (AFW) flow stop valves (HCV-1107A and HCV-1108A) can be failed open from inside the MCR by opening an AI-41 breaker, and both outside Containment AFW flow control valves (HCV-1 107B and HCV-1 108B) are free of fire damage. Having delta-T indication available for one SG is adequate to verify that the RCS has natural circulation and effective DHR. Pumps FW-6, FW-10, and FW-54 are all available (start/stop), and with AFW flow control also available, and SG level and SG pressure indication available, the operators have adequate capability to control SG levels.
: c. Prior Approval Requests 1, 2, 3, 4, 5, 6, 7, 8, 9 and 10, identify that because of "conservative re-quantification and additional assumed transient combustible material" the reported amount of combustibles in the original exemption(s) have increased but are still considered low. Please provide a more detailed description of "re-quantification" and "additional transients". Describe whether a major source of combustible loading growth is attributed to additional cable(s) or modification(s) in the areas of concern. Please describe whether there have there been cables added in deference to the exemption granted in 1985, or does re-quantification make the analysis more accurate for the current cable loading. Describe how combustible loading "creep" will be controlled in the post-transition plant.
18

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure OPPD's Response to Safe Shutdown RAI 14 c:
The combustible loading identified in the exemption granted in 1985 only identified fixed and some general combustibles. OPPD, in response to condition report (CR) 2000-01737, performed a review of the NRC safety evaluation report (SER) dated July 3, 1985, and associated OPPD correspondence, and identified an average fire severity of approximately 12 additional minutes in combustible loading calculation FC05814 versus what was submitted to the NRC in the 1985 exemption. This disparity is attributed to a more rigorous accounting of combustibles in the calculation, including estimates of transient and token loading. The control room complex (fire area 42) disparity is larger than the other areas since the area was historically discussed as separate zones, whereas the combustible loading calculation considers all combustibles for the entire fire area. Although some disparity in accounting of combustibles exists, FC05814 concludes that the areas discussed in the exemption still contain low combustible loading levels; therefore, the exemption submittals are still valid.
A general area combustible token quantity is added to each fire zone to conservatively include the aggregate of low British Thermal Units (BTU) miscellaneous combustibles within that zone. This token quantity is calculated to account for miscellaneous items that are not typically figured into combustible loading (i.e., gauges, face plates, identification tags, room nameplates, etc.). The token quantity for a given area is 5% of the existing fixed and general area combustibles in that area. For fire zones with no fixed or general area loads, the token quantity is equivalent to a 5 minute fire severity.
Based on combustible control procedure SO-G-91, an expected transient combustible loading has also been added to each fire zone to support work activities that utilize combustible material that does not require a permit. This material includes 100 pounds of Class A materials, 5 gallons of Class B liquid (lube oil), and 500 ft3 of flammable gas. The expected transient combustible loading is based on the assumption that one work activity is in progress for every 200 ft2 of floor area. Therefore, the expected transient combustible loading that is added to each fire zone is 12,620 BTU/ft 2.
The combustible loading growth since the exemptions were granted in 1985 is not attributed to additional cable loading or significant modifications. Based on a comparison of the cable combustible loading identified in the 1985 exemption request to the current combustible loading calculation, FC05814, there are negligible changes to the current cable combustible loading; therefore, there are no significant changes to cable loading in deference to the exemption granted. The current combustible loading calculation provides a more accurate analysis (including specific individual combustibles, allowed transients, and a token general area quantity) as compared to the general overview of combustibles identified in the 1985 exemption.
The combustible loading "creep" is controlled via the engineering change process during which time the engineer reviews for effects on the combustible loading. The engineer reviews the combustible loading calculation and any associated memos. This review will continue to control the combustible loading "creep" in the post-transition plant.
19

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure
: d. The separation schemes in Attachment 'T' and exemptions of Attachment K describe clarification of the previously approved exemption requests of the current licensing basis of Appendix R. NFPA 805 requires more equipment to be evaluated than just traditional Appendix R safe shutdown equipment. Please describe how the following elements of the FPRA are addressed specifically with regard to the other categories of equipment in:
: i. Containment isolation (LERF) ii. Internal Events PRA (IEPRA) equipment (CDF and LERF) iii. Spurious equipment that could affect the success of the mitigating safety functions credited in the FPRA iv. Equipment whose fire-induced failure will cause an initiating event to be modeled in the FPRA Model Because equipment lists for the FPRA consist of more than just traditional Appendix R analysis, please describe how the separation scheme described in Attachment T and K is used in NFPA 805. Describe whether there are separation schemes similarly applied to other components and systems added to the NFPA 805 FPRA where separation is credited.
OPPD's Response to Safe Shutdown RAI 14 d:
The FPRA models fire impact on each category of equipment described in items i, ii, iii, and iv. The FPRA uses engineering analyses, based on the physical principals of fire behavior, (e.g., size of fire and physical layout of containment) and it does not rely on the exemption requests and licensing clarifications in the NFPA 805 transition LAR (LIC-11-0099),
Attachments T and K. The FPRA does not credit the separation schemes described in Attachments T and K.
Safe Shutdown RAI 15:
LAR Attachment S, identifies the proposed plant modifications REC-119 (Train A 125VDC power), and REC-120 (Train B 125VDC power) for additional electrical isolation. The LAR for modification REC-119 states "this proposed modification will maintain DC Control power for Train A breaker and diesel generator control with no reliance upon operator manual actions for fire area 37 [battery room #1]". The LAR for modification REC-120 states the same for Train B breaker control in fire area 38 [battery room #2].
Apparently, the current design could result in the loss of EE-8F / EE-8G (DC distribution panel(s)) because of a fire in its' respective battery room. Relocating/additional fuses to provide isolation of the DC distribution panel(s) from their respective batteries is the proposed resolution.
Please provide a more detailed description of these modifications (how the manual disconnect will be modified), and breaker/fuse coordination curves to achieve the continued availability of DC distribution panels EE-8F and EE-8G. Explain how the modifications will eliminate reliance on the operator manual actions.
20

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure OPPD's Response to Safe Shutdown RAI 15:
The Enclosure, Attachment 1 provides sketches of the conceptual proposed design option(s) to achieve the objective of the associated plant modification for NFPA 805 as described for REC-1 19 and REC-120 in Attachment S of the transition LAR (LIC-11-0099). As discussed with the NRC during the March 11, 2013, teleconference with the NRC Project Manager and technical reviewers, the specific design details, such as how the manual disconnect will be modified, breaker/fuse coordination, etc., will be developed during NFPA 805 implementation.
Safe Shutdown RAI 16:
LAR Attachment S for the proposed plant modification REC-112 states "the purpose of these modifications is to ensure that the breakers will remain functional to trip on demand for automatic load shed, overcurrent, and manual control from the main control room. These modifications generally involve wiring changes within the switchgear cubicles, installation of additional coordinated DC control power fuses within the switchgear cubicles, and/or installation of interposing relays within the switchgear cubicles." The applicable breakers are: 1A1-0 (FP-1A); 1A1-1 (FW-5A); 1A1-2 (FW-4A); 1A1-3 (FW-2A); 1A1-4 (CW-1A); 1A2-6 (CW-1B); 1A2-7 (FW-2B); 1A2-8 (FW-4B); 1A2-9 (FW-5B); 1A4-3 (CW-1C); 1A4-4 (FW-5C); 1A4-5 (FW-4C); and 1A4-6 (FW-2C).
The LAR for REC-112 also states "this proposed modification addresses issues associated with loss of overcurrent trip capability for load breakers (trip and lockout of credited switchgear and secondary fires). The proposed modification will maintain breaker manual trip capability from the main control room, protective trip, automatic load shed trip and accident signal trip for fire areas 31, 46, and 47."
Please provide a more detailed description of the modifications for various breakers (typical(s) for various breakers), including fuse coordination curves with the upstream protective devices.
OPPD's Response to Safe Shutdown RAI 16:
The Enclosure, Attachment 2 provides sketches of the conceptual proposed design option(s) to achieve the objective of the associated plant modification for NFPA 805 as described for REC-1 12 in Attachment S of the transition LAR (LIC-1 1-0099). As discussed with the NRC during the March 11, 2013, teleconference with the NRC Project Manager and technical reviewers, the specific design details will be developed during NFPA 805 implementation.
21

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Probabilistic Risk Assessment RAI 01.c.01:
Components of an analysis of hot work induced cable fires have been provided through the response to RAI 01.c.ii in a letter dated July 24, 2012 (ADAMS Accession No. ML12208A131).
Also, through the NRC staffs review, it has been established that only qualified cable is installed in the plant. A frequently asked question (FAQ 13-0005) is expected to be released for evaluating hot work induced cable fires, and self-ignited cable fires in the FPRA. Among the differences from your approach for hot work induced cable fires, no suppression credit is given prior to damage of the cable tray in which the fire initiates. Also qualified cables must be evaluated for self-ignited cable fires, if these cables are located in an under-ventilated area.
As a result, perform a sensitivity analysis on hot work induced cable fires, and self-ignited cable fires addressing the above differences. Please provide the impact on CDF, LERF, ACDF, and ALERF as a result of this change.
OPPD's Response to Probabilistic Risk Assessment RAI 01 .c.01:
FAQ 13-0005 (draft version dated February 7, 2013) requires that the potential for self-ignited cable fires be considered for cables routed through "under-ventilated" areas. As part of the FCS design process, OPPD has adequately de-rated cables to ensure that self-ignition is not of concern for cable routes where airflow is minimized. This includes both cables routed through electrical penetrations and cables routed through enclosures.
FAQ 13-0005 (draft version dated February 7, 2013) also provides scenario development guidance for Cable Fires caused by Welding and Cutting (CFWC). The following paragraphs document a sensitivity study in which the FAQ 13-0005 approach for CFWC fire scenario development is implemented. Note that this study uses the CFWC frequencies developed in response to PRA RAI 07, which incorporate more recent generic fire frequency data, as well as a more appropriate distribution of maintenance influence factors throughout the plant.
First, for each fire compartment, the CFWC fire frequency was multiplied by the CCDP and CLERP conservatively assuming failure of all FPRA targets in the compartment. No credit for suppression was taken.
Next, for compartments in which the above approach was too conservative, one CFWC fire scenario for each cable tray was defined. The fire frequency for each individual cable tray was calculated as the total CFWC frequency for the compartment, divided by the number of cable trays in the compartment. The CCDP and CLERP for each scenario were calculated with target damage limited to the tray of origin. No credit for suppression was taken.
The following table summarizes the total plant CDF, total plant LERF, total VFDR ACDF, and total VFDR ALERF for the base fire PRA (Reference LIC-1 1-0099) and for the sensitivity study implementation of FAQ 13-0005.
22

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Base Fire PRA*  Sensitivity Study**
(FAQ 13-0005)
Net VFDR ACDF for NFPA 805 Transition (/yr)                      5.72E-06         5.82E-06 Net VFDR ALERF for NFPA 805 Transition (/yr)                     6.67E-07         6.68E-07 Total CDF (internal, flood, fire) (/yr)                          6.01 E-05        5.96E-05 Total LERF (internal, flood, fire) (/yr)                         4.82E-06         4.77E-06
       *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
      **Sensitivity study case for VFDR ACDF and VFDR ALERF for several compartments used a conservative bounding approach, while others used a detailed approach, commensurate with the VFDR risk significance of the CFWC scenarios.
As shown above, the net VFDR ACDF and VFDR ALERF increased slightly, while both the total plant CDF and LERF decreased slightly. The total CDF and LERF decrease is sensible, considering that FAQ 13-0005 limits CFWC target damage to the tray of origin, whereas the base fire PRA considers CFWC target damage to collections of trays.
The increase in calculated VFDR risk is dominated by FC43. In the base fire PRA, the CFWC CCDP and CLERP values were taken as the average CCDP and CLERP across all fixed and transient ignition sources in the compartment. Because the FC43 ignition sources generally have little potential to damage cable trays, the calculated CFWC risk using the base fire PRA methodology was lower than that using the FAQ 13-0005 approach, which considers damage to every individual tray routed through the compartment.
In conclusion, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF remain within RG 1.174, Revision 1, Region II when the FAQ 13-0005 methodology for cable fires caused by welding and cutting is implemented.
Probabilistic Risk Assessment RAI 01.e.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.e stating that the review of the Halon system operating history did not identify any "repeated patterns of system unavailability" and discussed the use of a continuous fire watch when the Halon system is declared inoperable. A continuous fire watch is an acceptable DID measure for an inoperable Halon system, but is not as reliable as an operating automatic Halon fire suppression system. As a result, please discuss whether the review of the Halon system operating history identified any outlier behavior such as any periods of extended unavailability and, if so, discuss how this behavior was included in the PRA. (e.g., inclusion of a basic event representing out of service unavailability due to failures, test, and maintenance).
To credit the continuous fire watch when the Halon system is inoperable, the detection and suppression must be discussed for fires associated with all the different types of ignition sources in the rooms containing the Halon system. In the case of transient fires, the full discussion needed for crediting manual suppression in the case of a continuous fire watch is described in PRA RAI 07.01. For electrical cabinet fires, a continuous fire watch may provide prompt detection. In order to credit manual suppression for a continuous fire watch in the case of an electrical cabinet fire, several considerations must be addressed in the quantitative analysis as follows: 1) Please discuss whether the fire watch is instructed to open the cabinet door and fight the fire upon its initiation or does he/she simply relay the 23

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure occurrence of the fire to the MCR, 2) Please discuss the fire brigade response time if they must be summoned to the area to fight the fire after the fire watch reports the fire, 3) Please discuss how much time prior to cable damage in the overhead is available after fire suppression activities have started, and 4) Please discuss fire suppression equipment staging and access to that equipment. If crediting the continuous fire watch when the Halon system is inoperable, provide a discussion of both detection and suppression for both electrical cabinet fires and transient fires, and related these elements directly to the quantification provided in the PRA.
OPPD's Response to Probabilistic Risk Assessment RAI 01 .e.01:
A review of switchgear room Halon impairment reports was performed covering the five-year period between January 1, 2003 and December 31, 2007. Note that only the switchgear room Halon system is directly credited by the fire PRA. This review identified that the system was rendered out-of-service for 874 hours over the five-year period, corresponding to an annual unavailability of 0.02.
This unavailability includes the contribution of testing and maintenance directly on the Halon system, issues with penetration seals and fire doors enclosing the switchgear rooms, as well as one incidence following Halon discharge and preceding system restoration.
The FCS fire PRA models the Halon system unreliability as 0.05 per NUREG/CR-6850. Therefore, the probability that the Halon system will either randomly fail or is unavailable when demanded is (0.05) + (0.02) - (0.05)(0.02) = 0.069. Incorporating this value into the fire PRA yields the total CDF, total LERF, VFDR ACDF and VFDR ALERF summarized in the following table.
Base Fire PRA*          Sensitivity Study**
(2% unavailability)
Net ACDF for NFPA 805 Transition (/yr)                    5.72E-06                 7.79E-06 Net ALERF for NFPA 805 Transition (/yr)                   6.67E-07                 7.52E-07 Total CDF (internal, flood, fire) (/yr)                   6.01 E-05                6.22E-05 Total LERF (internal, flood, fire) (/yr)                  4.82E-06                 4.90E-06
      *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
    **Sensitivity study case for VFDR ACDF and ALERF conservatively assessed by adding the net CDF and LERF increases between the two cases to the base case VFDR ACDF and ALERF, regardless of if and how the Halon unavailability actually contributes to VFDR fire risk. That is, CDF and LERF are conservatively used as surrogates for VFDR ACDF and ALERF.
No credit is taken for a continuous fire watch when the Halon system is inoperable; therefore, the information requested in the second paragraph of this RAI is not applicable.
In conclusion, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF remain within RG 1.174, Revision 1, Region II when Halon system unavailability is quantitatively included in the fire PRA model.
24

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Probabilistic Risk Assessment RAI 01 .g.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.g which does not provide sufficient justification for the conclusion that the cable routing assumptions described in response to Safe Shutdown RAI 03 is judged to negligibly impact the FPRA results and conclusions.             Specifically, the table provided in response to "Assumption "c" of SSD RAI 03 identifies numerous scenarios where fire-induced failures of cables have not been included in the FPRA and are excluded without assessing the potential for fire damage. Thus failure of these cables could impact the FPRA results. The specific cables are as follows:
* Cables EA4220A-D, EA42222A-D - "there is minimal fire impact on AFW ....."
* Cables EB4257C-D, EB4256C-D - "there is a relatively low frequency of fire..."
* Cable EB12191G - "This cable will be walked down..."
* Cable B1641B - "the cables will be walked down..."
* Cable B1655A - "the cables will be walked down..."
* Cables 7700A-B - "modeling the exact routing of the relevant cables is not expected to appreciably increase..."
* Cables 5022C-M - "there is minimal potential fire impact..."
The treatment of these cables in the FPRA is non-conservative and is contrary to the PRA standard (i.e., supporting requirement (SR) CS-Al1, Note 11: "the Fire PRA should assume that those cables fail for any fire scenario that has a damaging effect on any raceway or location where the subject cable might reasonably exist"). For each of these cables please either provide further justification that they are not failed by a fire or provide an assessment of the impact on CDF, LERF, ACDF, and ALERF from appropriately considering their fire-induced failure. Please provide appropriate justification for any fire scenarios that are either qualitatively or quantitatively screened. Furthermore, provide an assessment of whether the FPRA meets SR FSS-E4. If this SR is not met, provide justification for why this is acceptable for the application or revise the FPRA as appropriate to meet SR FSS-E4.
OPPD's Response to Probabilistic Risk Assessment RAI 01 .c.01:
The table below provides further review of the identified cables. In all but one case, the review concluded that that the CDF, LERF, ACDF, and ALERF values reported by LIC-1 1-0099 remain valid. In the excepting case, the review identified one fire scenario in which examining credible cable routes for 7700A and 7700B added a component failure that had not been included in the base fire PRA quantification.      This scenario was re-quantified with the additional failure, and it was demonstrated that the CDF,- LERF, ACDF, and ALERF remain within the R.G. 1.174, Revision 1, Region II acceptance criteria.
The RAI also questions whether fire scenarios, which can affect cables subject to routing assumptions, could have been inappropriately screened. However, the FCS fire PRA does not implement quantitative screening, and qualitative screening is only implemented at the compartment level (not the scenario level). The cable routing assumptions are well-founded at the compartment level, as described in response to Safe Shutdown RAI 03, and pose a negligible source of uncertainty to the fire PRA.
25

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Finally, this RAI requires an assessment of the FCS fire PRA against ASME/ANS RA-Sa-2009 Supporting Requirement FSS-E4, which states "Provide a characterization of the uncertainties associated with cases where cable routing has been assumed based on SRs CS-A10 and/or CS-Al1". Through response to Safe Shutdown RAI 03 and PRA RAI 01 .g.01, OPPD has systematically reviewed its use of assumed cable routing. Through the course of this review, the underlying assumptions were either eliminated (i.e., via walkdown to identify the precise routing), or they were evaluated and determined to pose a negligible source of uncertainty to the fire PRA. FSS-E4 is met based on the work performed in response to these two RAIs.
Cable           Fire            Discussion Compartment EA4220A-D       FC06-3          There are no fixed or transient ignition sources in the vicinity of the originating junction box (JB-202A), the terminating valve (HCV-2880B), nor credible routes for this short cable run.
Therefore, knowledge of the precise routing of this short cable run would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099.
Refer to coordinate E-1 of drawing 11405-E-62 Revision 68 for junction box and valve locations.
EA4222A-D       FC06-3          There are no fixed or transient ignition sources in the vicinity of the originating junction box (JB-204A), the terminating valve (HCV-2881 B), nor credible routes for this short cable run.
Therefore, knowledge of the precise routing of this short cable run would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099.
Refer to coordinate E-1 of drawing 11405-E-62 Revision 68 for junction box and valve locations.
EB4257C-D       FC06-3          There are no fixed or transient ignition sources in the vicinity of the originating junction box (JB-138A), the terminating valve (HCV-485), nor credible routes for this short cable run. Note that the junction box is not clearly identified on the layout drawing, however, the valve is shown and the cable lengths are 10 feet (EB4257D) and 15 feet (EB4257C), and the closest ignition sources are remote from this area. Therefore, knowledge of the precise routing of this short cable run would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099.
Refer to coordinate D-1 of drawing 11 405-E-62 Revision 68.
26

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Cable          Fire            Discussion Compartment EA4256C        FC06-3         There are no fixed or transient ignition sources in the vicinity of the originating junction box (JB-137A), the terminating valve (HCV-484), nor credible routes for this short cable run.
Therefore, knowledge of the precise routing of this short cable run would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099.
Refer to coordinate E-1 of drawing 11405-E-62, Revision 68 for junction box and valve locations.
Note that the RAI refers to cables EB4256C-D; however, these cables are not discussed in response to PRA RAI 01.g. It is assumed that PRA RAI 01 .g.01 intended to refer to only cable EA4256C.
EB12191G       FC32           This cable is routed in FC32 from AI-279 to YCV-1045. This cable was walked down on April 4, 2013, and it was determined to be routed through the ZOIs of FC32-1S7-Motor, FC32-1S7-Oill0, and FC32-1S7-Oill00.
FC32-1S7-Oi1100 already models YCV-1045 as failed.
Therefore, for this scenario, knowledge of the precise cable routing would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099.
When FC32-1S7-Motor and FC32-1S7-OillO are quantified considering failure of YCV-1045, the total CDF and LERF increases (for both scenarios combined) are 2.86E-09/yr and 1.12E-11/yr, respectively. This potential CDF and LERF increase is sufficiently small such that the R.G. 1.174 acceptance criteria for CDF, LERF, VFDR ACDF, and VFDR ALERF reported by LIC-1 1-0099 are still met.
27

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Cable          Fire            Discussion Compartment B1641B         FC36B, FC32    The consequences of fire-induced failure of B1641B are loss of 161 kV offsite power, 1A4 fault, 1B4A fault, 1 B4B fault, and 11B4C fault. The routing of this cable has been identified by walkdown and drawing review. Reference Design Documents Correction Request EC47217 Revision 0 titled "JB-567A Location Clarification" dated 09/23/09.
In FC36B, ignition sources in the vicinity of and with the potential to damage this cable (FC36B-IS34, FC36B-IS35, FC36B-IS36, and FC36B-IS38) are already modeled by the base fire PRA to cause a loss of 161 kV offsite power, 1A4 fault, 11B4A fault, 11B4B fault, and 11B4C fault. Therefore, addition of cable B1 641 B to the target set for these scenarios will not change the fire PRA results.
In FC32, the ignition sources in the vicinity of and with the potential to damage this cable (FC32-IS11-QillOOb, FC32-IS12-QillOOb, and FC32-1S13-OillOOb) are already modeled by the base fire PRA to cause a loss of 161 kV offsite power.
Therefore, addition of cable B1641 B to the target set for these scenarios will not change the fire PRA results. Note that B13641 B was verified to not be within the FC32-1S1 1, 12, and 13 motor fire ZOls.
B1655A         FC36B, FC32    The consequences of fire-induced failure of B1655A are loss of 161 kV offsite power, 1A4 fault, 1B4A fault, 1B4B fault, and 1B4C fault. The routing of this cable has been identified by walkdown and drawing review. Reference design document correction request (DCR) EC47217, Revision 0, "JB-567A Location Clarification," dated September 25, 2009.
In FC36B, ignition sources in the vicinity of and with the potential to damage this cable (FC36B-IS34, FC36B-IS35, FC36B-IS36, and FC36B-IS38) are already modeled by the base fire PRA to cause a loss of 161 kV offsite power, 1A4 fault, 11B4A fault, 11B4B fault, and 11B4C fault. Therefore, addition of cable B1655A to the target set for these scenarios will not change the fire PRA results.
In FC32, the ignition sources in the vicinity of and with the potential to damage this cable (FC32-1S11-OillOOb, FC32-IS12-Oi1100b, and FC32-1S13-OillOOb) are already modeled by the base fire PRA to cause a loss of 161 kV offsite power.
Therefore, addition of cable B1655A to the target set for these scenarios will not change the fire PRA results. Note that B1655A was verified to not be within the FC32-1S11, 12, and 13 motor fire ZOls.
28

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Cable          Fire            Discussion Compartment 7700A-B        FC36B          Cable 7700A runs from 11B4A-7 to Al-109A, and cable 7700B runs from 11B4A-7 to AI-109B. Fire-induced failure of either cable may fail DG-2. With one exception, all ignition sources having cables within their ZOI and whose location is within the vicinity of the 'from' and 'to' locations, as well as credible routing pathways, are modeled to fail DG-2 and/or 4 kV bus 1A4. Therefore, inclusion of these two potential cable failures would not change the CDF, LERF, ACDF, and ALERF calculations reported by LIC-1 1-0099 for these ignition sources. Relevant ignition sources include FC36B-IS4, 6, 7, 8, 13, 14, 15, 16, 20, 21,24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, and 36.
FC36B-IS5 is a transformer whose zone-of-influence could affect credible routing pathways between 11B4A-7 and Al-109A. It has an ignition frequency of 1.74E-04 /yr, severity factor of 0.06, and non-suppression probability of 0.05.
Inclusion of cables 7700A and 7700B in the target set for this ignition source increases CCDP from 4.01E-04 to 4.59E-04 and CLERP from 2.43E-05 to 2.44E-05. This corresponds to CDF and LERF increases of 3.03E-11 /yr and 5.22E-14, respectively. This potential CDF and LERF increase is sufficiently small such that the R.G. 1.174 acceptance criteria for CDF, LERF, ACDF, and ALERF reported by LIC-11-0099 would still be met.
The uncertainty associated with cables 7700A and 7700B, therefore, does not affect the results and conclusions of the NFPA 805 transition.
5022C,F,J,M    FC46            Cables 5022C, F, J, and M are solenoid control cables supporting PC-909-1, PC-909-2, PC-909-3, and PC-909-4, respectively. The fire PRA failure of concern is spurious opening of the condenser steam dump and/or bypass valves, causing excess steam flow to the condenser, which is
                                - conservatively modeled as a main steam line break. Detailed circuit analysis of these cables indicates that that their fire-induced failure will not cause the valve(s) to spuriously open.
The uncertainty associated with this assumed cable routing therefore does not affect the results and conclusions of the NFPA 805 transition.
29

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Probabilistic Risk Assessment RAI 01.h.01:
By letter dated August 24, 2012, (ADAMS Accession No. ML12240A151) the licensee responded to Probabilistic Risk Assessment RAI 01.h and stated "automatic suppression (if present in the exposed compartment) is credited to prevent fire propagation into the exposed compartment." Please discuss if this includes exposed compartments that rely on gaseous suppression systems (e.g., Fire Areas 36A, 36B, 41, 42, and 46). Gaseous suppression systems should not be relied upon to prevent fire propagation to the exposed compartment since failure of the barrier may degrade its ability to retain the concentration of the suppressant. If relevant, identify the fire areas where this assumption was made and assess the impact on the risk results of not crediting the gaseous suppression systems in the multi-compartment analysis.
OPPD's Response to Probabilistic Risk Assessment RAI 01 .h.01:
The multi-compartment analysis currently relies on gaseous suppression for FC34B-2, FC36A, FC36B and FC41. There is no gaseous suppression installed in FC46 as previously noted in the multi-compartment analysis spreadsheet, and no credit is taken by the fire PRA for gaseous suppression in FC46. When credit for gaseous suppression is removed from the multi-compartment analysis (analysis from response to PRA RAI 01.h was used as the starting point for PRA RAI 01.h.01), the multi-compartment CDF and LERF increase by 1.04E-06 /yr and 8.50E-09 /yr, respectively.
The following table extends this sensitivity study to the total plant fire risk and total VFDR change in fire risk.
Base Fire PRA*          Sensitivity Study**
(No Credit to Gaseous Suppression)
Net VFDR ACDF for NFPA 805                              5.72E-06                 6.76E-06 Transition (/yr)
Net VFDR ALERF for NFPA 805                             6.67E-07                 6.76E-07 Transition (/yr)
Total CDF (internal, flood, fire) (/yr)                 6.01E-05                 6.11E-05 Total LERF (internal, flood, fire) (/yr)                4.82E-06                 4.83E-06
       *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
      *-Sensitivity study case for VFDR ACDF and VFDR ALERF conservatively assessed by adding the net CDF and LERF increases between the two cases to the base case VFDR ACDF and VFDR ALERF. That is, CDF and LERF are conservatively used as surrogates for VFDR ACDF and VFDR ALERF, regardless of if and how the multi-compartment scenarios actually impact VFDR cables.
In conclusion, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF remain within RG 1.174, Revision 1, Region II when credit for gaseous suppression is removed from the multi-compartment analysis.
30

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Probabilistic Risk Assessment RAI 01.h.02:
By letter dated August 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.h.ii and described what time available for manual fire suppression was assumed in the multi-compartment analysis for rated fire barriers. Discuss and justify how this time was determined and how the analysis was performed for non-rated fire barriers and barriers with non-rated propagation pathways (e.g., fire dampers, doors, penetrations, etc.).
OPPD's Response to Probabilistic Risk Assessment RAI 01 .h.02:
Response to PRA RAI 01 .h.ii assumed the time available for manual fire suppression was equivalent to half of the fire barrier rating. That analysis therefore does not account for barriers that may be failed at time zero.
In response to the current PRA RAI 01 .h.02, and to demonstrate the fire PRA relative insensitivity to time available for manual suppression, the multi-compartment analysis was revised to conservatively exclude all credit for manual suppression. To accommodate this change, modeling realism for various scenarios was improved, primarily by limiting the multi-compartment fire frequency to the frequency of fires physically capable of generating a hot gas layer within the originating compartment. In the original analysis, the entire fire frequency for several compartments was conservatively assumed capable of generating a hot gas layer.
The following table extends this sensitivity study to the total plant fire risk and total VFDR change in fire risk.
Base Fire PRA*         Sensitivity Study**
Net ACDF for NFPA 805 Transition (/yr)                      5.72E-06                6.59E-06 Net ALERF for NFPA 805 Transition (/yr)                     6.67E-07                6.75E-07 Total CDF (internal, flood, fire) (/yr)                      6.01 E-05               6.38E-05 Total LERF (internal, flood, fire) (/yr)                     4.82E-06                4.86E-06
         *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099
         **For most multi-compartment scenarios, the sensitivity study case for VFDR ACDF and VFDR ALERF was conservatively assessed by adding the net CDF and LERF increases between the two cases to the base case VFDR ACDF and VFDR ALERF. That is, CDF and LERF are conservatively used as surrogates for VFDR ACDF and VFDR ALERF, regardless of if and how the multi-compartment scenarios actually impact VFDR cables. For scenarios where this approach was too conservative, the model was re-quantified with VFDR cables protected to calculate the actual VFDR ACDF and ALERF.
In conclusion, the total CDF, total LERF, VFDR ACDF, and VFDR ALERF remain within RG 1.174, Revision 1, Region II when credit for manual suppression is removed from the multi-compartment analysis. This removes any uncertainty associated with assumed time available for manual suppression.
31

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Probabilistic Risk Assessment RAI 01 .. 01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 01.j. Please address the following issues identified in the response to PRA RAI 01.j:
: a. The response to RAI 01.j.iii justifies the use of a CCDP of 0.1 and conditional large early release probability (CLERP) of 0.01 where this failure probability represents both failures of equipment and operator actions. The justification for these CCDP and CLERP values is based on a qualitative feasibility assessment of the operator actions, which consists of a qualitative argument that the actions have been determined to be feasible. It may be acceptable to take the position that operator actions are dominant in the CCDP and CLERP. However, no quantitative assessment of failure of alternate shutdown was provided to verify the CCDP of 0.1 and CLERP of 0.01, given the operator actions dominate. Despite feasibility considerations being addressed, it is not obvious that a CCDP value of 0.1 (and CLERP of 0.01) represents the failure probability of an action of this complexity. Please provide further justification for the 0.1 and 0.01 by providing the results of the human failure event (HFE) quantification process described in Section 5 of NUREG-1921, "Fire Human Reliability Analysis Guidelines - Final Report", considering the following:
: i. The feasibility assessment of the operator action(s) associated with the HFEs, specifically addressing each of the criteria discussed in Section 4.3 of NUREG-1921.
OPPD's Response to Probabilistic Risk Assessment RAI 01 .i.01 .a.i:
The following table documents the alternate shutdown feasibility assessment in accordance with NUREG-1921, Section 4.3. This assessment confirmed that the alternate shutdown process per abnormal operating procedure AOP-06 is feasible.
Criterion                                   Assessment Time           FCS calculation FC07869, "NFPA 805 Recovery Actions Evaluation at FCS for EPU," supports that plant operators have 60 minutes (with margin) post-trip to isolate the power operated relief valves (PORVs) and establish AFW without core uncovery. Based upon operator interviews and walk-throughs, 20 minutes was conservatively selected as the time for establishing control at the alternate shutdown panels.
Manpower       There are sufficient operators available to perform the required actions.
Cues           The cues (loss of habitability and/or significant loss of plant control) that MCR abandonment is necessary are obvious and clear. The required instrumentation for corrective actions is available outside of the control room.
Procedures     AOP-06 is the procedure that governs fire-induced MCR abandonment.
and training   It is a step-by-step procedure. This procedure is reviewed in classroom training every two years. The alternate shutdown process is practiced on the simulator and in the plant every two years, though not necessarily for every operator.
32

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Criterion                                  Assessment Action          Required equipment and instrumentation are available and accessible.
location        Environmental conditions are normal (ambient, without smoke) once accessibility   operators abandon the MCR. Actions required in the MCR are performed before environmental conditions deteriorate to a point of action infeasibility.
Equipment       No special equipment or tools are required for establishing control at and tools       the alternate shutdown panels.
Required        Equipment and instrumentation required for alternate shutdown are components      available and accessible. The alternate shutdown panel and equipment operable        are electrically independent from the MCR (after transfer of control),
and they are therefore not affected by the fire. Note that random equipment failures are addressed separately.
ii. The results of the process in Section 5.2.7 of NUREG-1921 for assigning scoping human error probabilities (HEPs) to actions associated with switchover of control to an alternate shutdown location. Please address the bases for the answers to each of the questions asked in the Figure 5-4.
iii. The process in Section 5.2.8 of NUREG-1921 for assigning scoping HEPs to actions for performing alternate shutdown once switchover is accomplished.
Please address the bases for the answers to each of the questions asked in the Figure 5-5.
OPPD's Responses to Probabilistic Risk Assessment RAIs 01.i.01.a.ii. and iii.:
The actions to swap control from the MCR to the alternate shutdown panel and the actions to complete the alternate shutdown process per AOP-06 are combined into a single human failure event, which is assessed using the bounding ASD flowchart (Figure 5-5 in NUREG 1921) below. This study resulted in a scoping HEP of 0.4 (ASD26 per Table 5-5 of NUREG 1921).
Note that while the RAI requests the switchover to be assessed with Figure 5-4 and the remainder of the shutdown actions to be assessed with Figure 5-5, combining the two actions into one HFE is more consistent with the OPPD procedure AOP-06 in which the switchover to the ASD panels and the remainder of the ASD actions are continuous steps in the same procedure.
: 1) Are all the necessary cues for the required actions protected?
Yes. In the event of MCR abandonment, the necessary cues will remain available in the MCR and at the alternate shutdown panels.
: 2) For the given action, do the procedures match the scenario?
Yes. AOP-06 is the relevant procedure. It is explicitly written to address fire emergencies including those necessitating MCR abandonment, and it, therefore, matches the scenario of concern.
: 3) Is one of the following conditions met: 1) there are procedures for executing the action or 2) it is skill-of-the-craft?
33

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Yes. AOP-06 specifies actions required for fires requiring MCR abandonment.
: 4) Are both conditions met: 1) the area is accessible and 2) there is no fire in the vicinity of the action?
Yes. The alternate shutdown panel, and actions remote from the panel, are unaffected by fire and smoke within the MCR. Note that AOP-06 directs some actions (e.g., reactor trip) inside the MCR prior to abandonment; however, these actions are performed prior to loss of habitability.
: 5) Is the time available greater than 30 minutes?
Yes. Per Attachment G of the NFPA 805 Transition LAR (LIC-1 1-0099), timing for the credited NFPA 805 recovery actions for a cable spreading room (FC41) or control room (FC42) fire is based, in part, on the following: FCS calculation FC07869, "NFPA 805 Recovery Actions Evaluation at FCS for EPU," (for fire area 34B-1, used as a bounding calculation for spurious PORV mitigation, and restoration of AFW).
FCS calculation FC07869, "NFPA 805 Recovery Actions Evaluation at FCS for EPU," supports that plant operators have 60 minutes (with margin) post-trip to isolate the PORVs and establish AFW without core uncovery.
: 6) Is the execution complexity high?
Yes. Due to the number of critical execution steps, and the coordination between multiple operators required, the complexity is considered high.
: 7) Is there smoke or other hazardous elements in the vicinity?
Yes. AOP-06 directs some actions (e.g., reactor trip) inside the MCR prior to abandonment; however, these actions are performed prior to loss of habitability.
Nonetheless, smoke in the vicinity of these actions is expected.
: 8) Is SCBA required?
No. Actions from within the control room are performed prior to it becoming uninhabitable, and the environment for the ex-MCR actions is unaffected by the MCR fire.
: 9) Table 5-5: HEP AK with > 100% time margin = ASD26 = 0.4 Time Margin    = (Tavaii - Treqd) / Treqd X 100%
Time Margin = (60 min - 20 min) / 20 min x 100%
Time Margin = 200%
iv. The results of a detailed human reliability analysis (HRA) quantification, per Section 5.3 of NUREG-1921 in place of items 2 and 3 if a CCDP as low as 0.1 (and CLERP as low as 0.01) is not attainable through the scoping approach. For the detailed study, please quantify the contribution via the evaluation of different scenarios upon MCR evacuation, including the sum of those scenarios in the results for the CCDP and CLERP.
34

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 01J..01 .a.iv.:
OPPD performed a detailed HRA of the alternate shutdown process, in accordance with NUREG-1921 Section 5.3. While the option exists to develop fire scenario-specific HFEs (based on equipment and timing impacts of each scenario), more of a bounding approach focusing on the critical steps of AOP-06 was used for the purpose of this HRA, given that AOP-06 is written to mitigate the full spectrum of possible MCR fire impacts.
This analysis yielded a human error probability of 1.50E-02, which represents operator failure to prevent core damage using the alternate shutdown process.                  When equipment reliability is considered, the CCDP of control room abandonment is calculated as 1.41 E-01. The CLERP is also taken to be 1.41 E-01, since the alternate shutdown process does not include provision for containment isolation. (Containment isolation may occur automatically following control room abandonment, but this plant response has not been explicitly evaluated.) Because AOP-06 provides direction only to align one safe shutdown train, equipment reliability is the dominant contributor to the overall CCDP.
The calculated CCDP and CLERP values are higher than the 0.1 and 0.01, respectively, assumed by the base fire PRA. In light of these results, the abandonment frequency calculation was re-visited with the intent of improving its level of realism to be commensurate with the detailed HRA and equipment reliability assessment performed for alternate shutdown. The base fire PRA used the optical density abandonment criterion of 0.3 m 1 specified by Section 11.5.2.11 of NUREG/CR-6850.
A subsequent erratum to NUREG/CR-6850 clarified that the correct value is 3.0 m1 (not 0.3 m1). The FDS simulations supporting response to Fire Modeling RAI 05c-i were re-run using this revised abandonment criterion. The electrical cabinet fire soot yield was increased from 0.08 (used in response to Fire Modeling RAI 05c.i) to 0.172, and the transient fire soot yield was increased to 0.172 as well, for the purpose of demonstrating margin.
The resulting fire CDF and LERF associated with control room abandonment, considering the higher optical density abandonment criterion and the revised CCDP and CLERP values (based on HRA, equipment reliability, and equipment availability),
are both 1.35E-07 /yr. Note that CDF and LERF are equivalent because the alternate shutdown process does not include provision for containment isolation. These CDF and LERF values are less than those supporting the NFPA-805 transition LAR (LIC-1 1-0099), and the FCS total CDF, total LERF, VFDR ACDF, and VFDR ALERF for the NFPA 805 transition remain within the RG 1.174, Revision 1, Region II acceptance criteria.
: b. Please provide justification for the assumption in response to RAI O1.j.iv that a fire must spread at least 0.5 meters on the main control board (MCB) to threaten abandonment. Furthermore, revise the response to this RAI to incorporate the results of (i.) above, as applicable.
35

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 01 .J.01 .b.:
The response to PRA RAI 01 .j.iv provides a quantitative justification for the FPRA exclusion of control room abandonment caused by Main Control Board (MCB) fires. That analysis assumed that an MCB fire must be at least of sufficient size to damage targets 0.5 meters apart to threaten abandonment. This value was then used with NUREG/CR-6850 Figure L-1 to estimate an associated non-suppression probability.
If the analysis instead conservatively assumed that any fire spread on the MCB (i.e., any fire spread beyond the component of origin) would be sufficient to cause abandonment, the corresponding non-suppression probability would be 9E-03 (per NUREG/CR-6850 Figure L-1 conservatively for unqualified cables).
The revised CDF and LERF attributed to MCB fires leading to abandonment would each be 5.23E-08 /yr. These CDF and LERF estimates use the revised CCDP and CLERP values calculated in Part 'a' to this RAI response, which are equivalent because the alternate shutdown process does not include provision for containment isolation. This conservative estimate of CDF is "insignificant" in the sense that it is neither within the top 95% of total fire CDF nor does it contribute greater than 1% of total CDF reported by transition LAR LIC-1 1-0099. However, this conservative estimate of LERF is "significant" because it is within the top 95% and contributes slightly over 1% of total LERF reported by transition LAR LIC-1 1-0099.
The following table reports the total CDF, total LERF, VFDR ACDF and VFDR ALERF with the combined impact of the revised abandonment CCDP and CLERP (RAI PRA 01 .j.01 Part
       'a'), revised fire simulations (RAI PRA 01.j.01 Part 'a'), and the conservatively estimated contribution of MCB fires to abandonment.
BaseFire PRA*        Sensitivity Study**
Total VFDR ACDF for NFPA 805                              5.72E-06               1.32E-06 Transition (/yr)                                          5.72E-06_.32E-0 Total VFDR ALERF for NFPA 805                             6.67E-07               3.95E-07 Transition (/yr)
Total CDF (internal, flood, fire) (/yr)                   6.01 E-05              5.57E-05 Total LERF (internal, flood, fire) (/yr)                  4.82E-06               4.55E-06
            *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
            **Calculated by subtracting the abandonment CDF and LERF supporting LIC-11-0099 from the
            'Base Fire PRA' column, and adding the newly calculated abandonment CDF and LERF, incorporating the new CCDP and CLERP values (as delineated in RAI PRA 01.j.01 Part 'a'), the new fire simulations (per RAI PRA 01 .j.01 Part 'a'), and the MCB contribution to abandonment (per RAI PRA 01 .j.01 Part 'b').
As shown in the above table, the VFDR ACDF and                 ALERF reduced considerably. This is because abandonment risk constituted the majority             of total VFDR ACDF and ALERF, and this calculated risk was reduced considerably                  when the incorrect optical density abandonment criterion (0.3 m1 per NUREG/CR-6850               ) was replaced with the correct criterion (3.0 m 1 per erratum to NUREG/CR-6850).
36

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Probabilistic Risk Assessment RAI 03.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI
: 03. The peer review determined SR PP-B4 to be met, however, the response to PRA RAI 03 states that the FPRA credits the Pyrocrete enclosure in FC36C as a fire compartment boundary. SR PP-B4 specifically does not allow credit for raceway fire barriers, thermal wraps, fire-retardant coatings, radiant energy shields, or any other localized cable or equipment protection feature as partitioning elements in defining physical analysis units.
Please provide the updated CDF/LERF/Delta CDF/Delta LERF from the impact of not crediting the Pyrocrete barrier as a plant partitioning feature.
OPPD's Response to Probabilistic Risk Assessment RAI 03.01.:
In response to this RAI and consistent with PP-B4, the Pyrocrete enclosure has been re-characterized from its own fire compartment (FC36C) to an electrical raceway fire barrier system within the West Switchgear Room (FC36B). This re-characterization allows PP-B4 to be met. The total CDF, total LERF, VFDR ACDF, and VFDR ALERF are not affected by this re-characterization since the barrier design has been determined adequate to withstand the fire hazards within FC36B per NRC and OPPD licensing correspondence discussed in LIC-1 1-0099, Attachment A, NEI 04-02 Table B-i.
Probabilistic Risk Assessment RAI 07.01:
By letter dated September 27, 2012 (ADAMS Accession No. ML12276A046), the licensee responded to Probabilistic Risk Assessment RAI 07. The sensitivity analysis provided in response to PRA RAI 07 for transient fires in FC28, FC32, and FC41 makes three key assumptions:
: a. The sensitivity analysis credits the suppression curve for welding and cutting based on continuous fire watches 1) anytime combustibles are stored on the roof of Room 18 in FC32, 2) when greater than five pounds of combustibles are stored in FC41, and 3) anytime combustibles are stored in FC28. A continuous fire watch generally provides detection, but not necessarily suppression. To take prompt detection credit for a continuous fire watch, the combustibles must be observable at all times and the fire watch's line of sight must be unencumbered such that he/she can easily see the entire area being surveilled. [Note that the NRC staff does not consider the roving fire watches described in FCS procedures SO-M-9 and FCSG-15-35 to be equivalent to continuous fire watches because these procedures allow for the fire watch to check on hot work activity every five minutes rather than continuously.] Should the fire watch be credited for suppression with the welding and cutting suppression curve, other criteria besides those related to prompt detection must be met. In addition to the criteria for prompt detection,
: 1) one of the fire watch's purposes must be to extinguish the fire; 2) an extinguisher must be readily available for this action, including being located in the vicinity being surveilled; and 3) the fire watch must have undergone adequate training in the use of extinguishers.
A more capable suppressant system (i.e. fire hose) can be used in place of an extinguisher to qualify for this credit given proper training, and given that the prompt detection criteria are met. However, a discussion of the staging and rapidity with which the suppressant can be applied must be provided to demonstrate that the hose stream can be applied as rapidly as the fire watch would apply an extinguisher. The credit for suppression via the use of continuous fire watches credited in the sensitivity analysis should be discussed and justified in light of the criteria for both prompt detection and for suppression.
37

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure The estimate of the non-suppression factor must be justified based on detection and suppression times. If this type of non-suppression credit is used elsewhere in the fire PRA, please identify and discuss along similar lines, ensuring that the PAU/fire area in which it is used is identified. Absent a complete response that demonstrates that all the fire watches are continuous fire watches and meet the criteria for prompt detection and suppression, apply the transient fire suppression curve where the criteria are not met, and provide an assessment of the impact on the PRA results (CDF, LERF, ACDF, ALERF).
OPPD's Response to Probabilistic Risk Assessment RAI 07 a.:
The FCS fire PRA credits prompt detection and suppression via continuous fire watch if combustible control limitations are exceeded in the FC32 Compressor Area or the FC41 Cable Spreading Room. In these areas, OPPD plans to revise their combustible control procedures to require a continuous fire watch if combustibles are stored on the roof of Room 18 (which is within FC32) or if the existing five-pound combustible limitation is exceeded in the FC41 Cable Spreading Room.
Continuous fire watches at FCS meet the criteria outlined in this RAI for prompt detection and suppression. Note that hourly fire watches, implemented via SO-G-58, are not credited by the fire PRA, consistent with the RAI text.
Regarding prompt detection, SO-G-58 specifies that the fire watch continually inspect and patrol the affected area checking for possible fires. They are to remain in the designated area, and they may not leave the area until responsibility has been properly transferred to another individual.
The procedure notes that continuous fire watch duties are typically performed by a craft person associated with the work but may be performed by other personnel.
Regarding suppression, SO-G-58 states that if a fire occurs, the fire watch should notify the control room, and then attempt to extinguish the fire, if possible. SHB 1065-00 (Fire Watch Duties lesson plan) states that continuous fire watches shall obtain an A/B/C fire extinguisher from the tool room, and SO-G-58 also requires fire watches to note the location of the nearest fire extinguishers and to ensure they are rated for the type of fires that could occur in the area being surveilled. Continuous fire watches receive formal hands-on training in the use of fire extinguishers.
Consistent with the RAI text, the non-suppression probabilities applied to the FC32 and FC41 scenarios involving continuous fire watch are based on the time available for suppression (i.e.,
time prior to target damage). The time to damage is calculated on a scenario-specific basis using the distance to the nearest target, the fire growth profile, and fire modeling equations.
: b. The sensitivity analysis credits the HRR probability density function from "Motors" from NUREG/CR-6850 for transient fires, rather than the transient combustibles HRR probability density function. The 98th percentile HRR is 69 kW for "motors," rather than 317 kW for transient fires.
No basis is provided for why postulated transient combustible fires in FC32 and FC41 have an HRR distribution similar to that of the electrical motor fires included in the NUREG/CR-6850 distribution for "Motors." Furthermore, with regard to the five pound combustible limitation in FC41, Table G-7 of NUREG/CR-6850 provides numerous fire test examples where combustible quantities of five pounds and less yielded transient fires 38

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure having peak HRRs greater than 69 kW. Please provide justification that the 69 kW HRR distribution for electrical motor fires bounds the postulated transient fires in FC32 and FC41. In the response, address the full range of types and quantities of combustibles that are expected to be located in each location. If adequate justification cannot be provided that the 69 kW HRR distribution is bounding, provide a revised sensitivity analysis that either uses the normal transient HRR distribution from NUREG/CR-6850 or an appropriately justified alternate HRR distribution. Please provide a description of the revised sensitivity analysis and the impact on the PRA results (CDF, LERF, ACDF, ALERF).
OPPD's Response to Probabilistic Risk Assessment RAI 07 b.:
There is uncertainty selecting a heat release that will bound all reasonably expected transient combustibles in the FC41 Cable Spreading Room or FC32 Compressor Area.
For FC41, the CCDP and CLERP associated with the postulated transient fire scenarios are equivalent to the CCDP and CLERP values associated with damage to all targets in the compartment (i.e., 'lull compartment burnup") and subsequent credit of the alternate shutdown process. Selection of a higher heat release rate would not change the scenario CCDP and CLERPs.
For FC32, the CCDP associated with the postulated transient fire is equivalent to the CCDP assuming failure of all targets in the compartment. Selection of a higher heat release rate would not change the scenario CCDP.
The FC32 transient fire CLERP is about a factor of five lower than the CLERP assuming failure of all targets in the compartment. So, a fire larger than the postulated 69 kW could conceivably cause a higher CLERP. However, 69 kW does bound all transients reasonably expected to occur at the postulated location (roof of CCW heat exchanger room). In fact, no transient storage is expected in this area. There is no mechanical plant equipment in this area. There is no routine maintenance in this area. The area does not receive regular foot traffic. The area is only accessible by ladder, and there is no permanently installed ladder. There is no reason to access this area as part of routine plant operation and maintenance. In addition transient storage is procedurally disallowed in absence of a continuous fire watch per proposed revision to the combustible control program.
: c. The sensitivity analysis did not address the additional risk from combustible control violations where the allowed transient combustible quantities are exceeded and no continuous fire watch is present (i.e., more than five pounds of transient combustibles are stored in FC41, more than zero pounds of transient combustibles are stored in FC28 and FC32). Please provide an assessment of the impact of this effect on the PRA results (CDF, LERF, ACDF, ALERF). The transient fires suppression curve from NUREG/CR-6850 should be used for these postulated fires. Also, the HRR assigned to the modeled violation should reflect those HRRs for the transient combustibles which may exist in the room, considering the equipment and required maintenance, storage, and occupancy.
Also, the HRR for the modeled violation should consider any actual violations of administrative combustible controls which have occurred in the room or comparable locations of the plant, and exceed those HRRs identified in the previous sentence. The HRR for the modeled violation should be discussed and justified in light of these considerations.
39

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 07 c.:
To support re-sizing of the postulated transient fire sizes in FC32 and FC41, a search of OPPD corrective action documents over the past five years was performed and did not indicate a pattern of combustible control violations. Three CRs were identified in this search, all on the 989 feet elevation of FC32. 2011-6342 and 2011-6346 both involve the same issue of scaffolding in FC32, and 2011-7299 involves two plastic trash bins in FC32, contrary to SO-G-91, which requires trash receptacles to be metal. Note that the trash bin was not stored on the CCW heat exchanger roof area, which will be the area subject to enhanced controls.
Of these three CRs, the scaffolding issue is the only instance of combustible storage without obtaining the required permit. Because the trash receptacle issue does represent a violation of combustible controls, it will also be included in this assessment. The scaffolding was removed July 28, 2011, and it is unclear from the CR description at what point the scaffolding was installed. It is similarly unclear for what duration the plastic trash receptacles were in place.
Assuming both the unapproved scaffolding and the plastic receptacles were each in place for 10 days, the likelihood of unapproved combustible storage in FC32 at any given time can be approximated as 1.10E-02, which is calculated as [20 days / (5 years
* 365 days/year)]. This factor is conservatively applied to the FC41 cable spreading room, even though no combustible control violations were identified in FC41.
The fire risk contribution of a transient fire, where the combustible control procedure is violated, is conservatively estimated in Table E-1. This conservatively uses the CCDP and CLERP associated with failure of all targets in the compartment. It also conservatively does not credit severity factor and non-suppression probability, due to uncertainty in maximum fire size and the fire growth profile associated with combustible control violations. The frequencies used in Table G-1 are those used to support response to PRA RAI 07a.
Table E-1: Estimated Risk Associated with Combustible Control Violations FC        A(/yr)        P(violation)      SF       NSP       CCDP            CLERP    CDF (/yr)    LERF (/yr)
FC32      3.37E-05      1.10E-02          1.0      1.0       1.OOE+00        7.97E-02 3.71E-07     2.95E-08 FC41       1.91E-05     1.1OE-02          1.0       1.0      1.OOE-01        1.OOE-02 2.10E-08     2.1OE-09 The FC32 estimate is also conservative because it is significantly less likely that combustible control violations will occur at the postulated pinch point (roof of CCW heat exchanger room).
There is no mechanical plant equipment in this area. There is no routine maintenance in this area. The area does not receive regular foot traffic. The area is only accessible by ladder, and there is no permanently installed ladder. There is no reason to access this area as part of routine plant operation and maintenance.
The following table extends this sensitivity study to the total plant fire risk and total VFDR change in fire risk.
Base Fire PRA*   Sensitivity Study**
(Including Comb.
Control Violations)
Net VFDR ACDF for NFPA 805 Transition (/yr)                     5.72E-06         6.11 E-06 Net VFDR ALERF for NFPA 805 Transition (/yr)                    6.67E-07         6.99E-07 Total CDF (internal, flood, fire) (/yr)                         6.01 E-05        6.05E-05 Total LERF (internal, flood, fire) (/yr)                        4.82E-06         4.85E-06
* Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
40

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure
        **Sensitivity study case for VFDRACDF and VFDR ALERF conservatively assessed by adding the CDF and LERF associated with the postulated combustible control violations to the base case VFDR ACDF and VFDR ALERF, regardless of whether and how the postulated combustible control violations actually affect VFDR cables.
In conclusion, when a conservative estimate of the additional risk posed by combustible control violations in FC32 and FC41 is considered, the VFDR ACDF, VFDR ALERF, total CDF, and total LERF remain within the RG 1.174 Revision 1 Region II acceptance criteria.
: d. The sensitivity analysis did not address the additional risk of transient fires in FC41 during normal plant operations when less than five pounds of transient combustibles are being stored and no continuous fire watch is called for by procedures. Please provide an assessment of the impact of both of these effects on the PRA results (CDF, LERF, ACDF, ALERF). The normal transient suppression curve from NUREG/CR-6850 should be used for these postulated fires. Please provide justification for the HRR distribution used for these transient combustibles.
OPPD's Response to Probabilistic Risk Assessment RAI 07 d.:
In response to this RAI, OPPD proposes an additional improvement to the combustible control process for the FC41 Cable Spreading Room. The process proposed by LIC-1 1-0099 requires a continuous fire watch if the five-pound combustible limitation in FC41 is exceeded. Part 'a' to this RAI points out that even just five pounds, in the correct configuration and location, can create a more aggressive fire than the 69 kW postulated by the fire PRA. For example NUREG/CR-6850 Table G-7 cites a Von Volkinburg test where two plastic trash bags, totaling 5.2 lbs and containing polystyrene cups, paper cups, and paper towels reached a peak heat release rate of 297 kW, which would be sufficient to damage cable targets in FC41.
In place of the simple five-pound limitation, OPPD proposes revising SO-G-91 to require a continuous fire watch when transient combustibles with the potential to damage targets are stored in FC41. This will allow the combustible control process to consider factors such as combustible type, configuration, location, and fire test data to ensure that no temporary combustibles with the potential to damage targets are left in FC41. As a hypothetical example, this process might disallow leaving unattended trash bags of any weight (even less than five pounds) in FC41. Conversely, the process might allow, for example, a multi-meter and small box of tools exceeding five pounds if it is placed in an area where its ignition could not threaten cable targets.
With this process, any permitted combustible storage will not damage targets, and therefore creates no quantifiable fire risk. Risk associated with allowing combustible storage with the potential to damage targets, accompanied by continuous fire watch per the propose SO-G-91 revision, is included in the fire PRA. Risk associated with violating the combustible control process is assessed in response to part 'c' of this RAI.
Probabilistic Risk Assessment RAI 11.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI 11. The response to PRA RAI 11 describes the PRA modeling strategy for assessing variance from deterministic requirement (VFDR) risk as consisting of modeling each individual VFDR explicitly in the FPRA model (with the exception of those not considered risk-relevant or addressed using an alternative bounding approach). Calculation FC07883 (Fire Risk Assessment of FCS Variances from Deterministic Requirements of NFPA 805) describes a case on page A6-5 for Fire Compartment 34A in which the VFDR risk is stated 41

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure to be bounded by conservatism in the Plant Response Model (PRM) which does not credit ability to isolate a steam generator using the main steam isolation valve (MSIV) or MSIV bypass valves. No risk for this VFDR is calculated and the risk for Fire Compartment 3[4]A is reported to be zero CDF and LERF. In light of this, please provide the following:
: a. An explanation of how conservatism in the PRM related to inadvertent opening of condenser steam dump and bypass valves can bound the fire-induced spurious opening of the MSIV and MSIV bypass valves. In the response, please, specifically, address the frequency of the fire-induced scenarios relative to the quantitative impact of not crediting successful closure of the MSIV and MSIV bypass valves.
OPPD's Response to Probabilistic Risk Assessment RAI 11.01a:
The specific VFDRs referenced by this RAI are 34A-002 and 34A-003, which identify that MSIV Bypass Valves HCV-1041C or HCV-1042C could spuriously open, or fail to close, due to fire in FC34A.
While fire cannot physically cause a Main Steam Line Break (MSLB) via pipe rupture, the FPRA models failure to isolate (or spurious opening of) the condenser steam dump and bypass valves as an MSLB. For these sequences, prevention or termination of the excess steam flow via MSIV isolation is not credited. This approach is conservative for the NFPA 805 transition in the sense that crediting MSIV isolation would reduce the total plant CDF and LERF, as compared to the values reported in the NFPA-805 transition LAR (LIC-1 1-0099).
Note that in FC34A, the downstream condenser steam dump and bypass valves are unaffected.
However, as identified by the RAI, this approach is potentially non-conservative with respect to VFDR ACDF and ALERF, which were each reported as 0.00E+00 /yr for VFDRs 34A-002 and 34A-003. The concern is that, if the fire PRA "conservatively" does not model a VFDR component(s), whose proper operation could mitigate a fire induced initiating event(s), then the risk reduction afforded by protecting that component(s) would be underestimated (i.e.,
the VFDR ACDF and ALERF would be underestimated).
For the specific issue identified by Part 'a' to this RAI (i.e., failure to isolate MSIV bypass valves), the fire risk evaluation conclusion remains valid because flow through the MSIV bypass valves alone would not be sufficient to be considered an MSLB, even if the downstream condenser steam dump and bypass valves were to fail open. Therefore, the ACDF and ALERF for VFDRs 34A-002 and 34A-003 remain 0.OOE+00.
Note that VFDRs 34A-002 and 34A-003 relate to the MSIV bypass valves. The only VFDRs for the MSIVs are in FC41 (cable spreading room) and FC42 (main control room). Refer to the table in response to PRA RAI 11.01b for assessment of the potential to underestimate FC41 and FC42 VFDR fire risk.
: b. An assessment of the impact of this and similar conservatisms in the FPRA modeling on the determination of VFDR risk. If VFDR risk (i.e., A CDF and A LERF) is under-estimated please provide risk estimates without these conservatisms.
42

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure OPPD's Response to Probabilistic Risk Assessment RAI 11.01 b:
The remaining fire risk evaluations were reviewed for cases in which the FPRA
        ;iconservative" non-crediting of VFDR components, whose proper operation could mitigate fire-induced initiating events, resulted in the underestimation of VFDR ACDF and ALERF.
FC                                            Assessment FC20-1      No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
FC20-      No instance of modeling conservatism causing underestimation of VFDR ACDF 7ROOF       and ALERF was identified.
See response to PRA RAI 21 regarding treatment of loss of main control room HVAC.
FC28      VFDR 28-001 is that fire damage to cable EB12194 could spuriously open the turbine driven AFW pump FW-10 steam supply valve, YCV-1045. Unmitigated spurious opening of this valve may cause Steam Generator (SG) overfill, which may fail FW-10, due to water intrusion into the FW-10 steam supply.
The FPRA relies upon the AFW and MFW flow control valves to prevent SG overfill. The FPRA does not credit availability of YCV-1045 to throttle steam flow and prevent SG overfill. There is therefore a potential for underestimation of VFDR ACDF and ALERF.
However, FW-10 is modeled as failed for all FC28 fire scenarios that could impact the VFDR cable. Note that FW-10 failure is the ultimate consequence of the VFDR failure (i.e., due to SG overfill). Protection of VFDR cable EB12194 would afford no measurable risk reduction. The ACDF and ALERF are therefore not underestimated by the FPRA treatment of VFDR 28-001.
FC31      No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
FC32      The fire risk evaluation for FC32 uses a bounding approach in which the total fire compartment CDF and LERF are used as conservative surrogates for the VFDR ACDF and ALERF. Since the total compartment CDF and LERF are within the R.G. 1.174 acceptance criteria, and this includes contribution from all risk-relevant VFDRs, then by definition the VFDR ACDF and ALERF must also be within the R.G. 1.174 acceptance criteria.
With this approach, modeling conservatisms would not cause underestimation of VFDR ACDF and ALERF, since the calculated risk increase associated with the conservatisms would carry into VFDR ACDF and ALERF characterization.
FC34A      No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
VFDRs 34A-002 and 34A-003 involve spurious operation of MSIV bypass valves. Refer to Part 'a' of this RAI response.
43

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure FC                                           Assessment FC34B-1     No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
VFDRs 34B-1-003 and 34B-1-004 involve spurious operation of MSIV bypass valves. Refer to Part 'a' of this RAI response.
VFDR 34B-1-017 is that fire damage to cables EB12194 and EB12192 could spuriously open YCV-1045. The disposition of this VFDR failure in FC28 is also valid for VFDR 34B-1-017.
FC36A      No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
VFDR 36A-006 is that fire damage to cable EB12193 may spuriously open YCV-1045. It was determined that no fire scenarios in FC36A have the potential to fail this particular cable, and there is therefore no concern about model conservatism potentially causing underestimation of VFDR ACDF and ALERF.
FC36B      No instance of modeling conservatism causing underestimation of VFDR ACDF and ALERF was identified.
FC41      The fire risk evaluation for FC41 uses a bounding approach in which the total fire compartment CDF and LERF are conservatively used as surrogates for the VFDR ACDF and ALERF. Since the total compartment CDF and LERF are within the R.G. 1.174 acceptance criteria, and this includes contribution from risk-relevant VFDRs, then by definition the VFDR ACDF and ALERF must also be within the R.G. 1.174 acceptance criteria.
With this approach, modeling conservatisms would not cause underestimation of VFDR ACDF and ALERF, since the calculated risk increase associated with the conservatisms would carry into VFDR ACDF and ALERF characterization.
FC42      The fire risk evaluation for FC42 uses a bounding approach in which the total fire CDF and LERF associated with control room abandonment are conservatively used as surrogates for the VFDR ACDF and ALERF.                  Since the total abandonment CDF and LERF are within the R.G. 1.174 acceptance criteria, and this includes contribution from risk-relevant VFDRs, then by definition the VFDR ACDF and ALERF must also be within the R.G. 1.174 acceptance criteria.
With this approach, modeling conservatisms would not cause underestimation of VFDR ACDF and ALERF, since the calculated risk increase associated with the conservatisms would carry into VFDR ACDF and ALERF characterization.
FC43      The fire risk evaluation for FC43 uses a bounding approach in which the total fire compartment CDF and LERF are conservatively used as surrogates for the VFDR ACDF and ALERF. Since the total compartment CDF and LERF are within the R.G. 1.174 acceptance criteria, and this includes contribution from risk-relevant VFDRs, then by definition the VFDR ACDF and ALERF must also be within the R.G. 1.174 acceptance criteria.
With this approach, modeling conservatisms would not cause underestimation of VFDR ACDF and ALERF, since the calculated risk increase associated with the conservatisms would carry into VFDR ACDF and ALERF characterization.
In conclusion, this systematic review did not identify any instances of FPRA modeling conservatism causing underestimation of VFDR ACDF and ALERF.
44

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Probabilistic Risk Assessment RAI 15.q.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment RAI
: 15. The response, related to impact on the PRA from model uncertainty and assumptions, explains that plant specific analysis was performed to identify and characterize sources of generic modeling uncertainty. This included identifying model assumptions, putting them into a database, and characterizing them in terms of importance (i.e., Important, Medium, and Non-Important).        According to the RAI response assumptions and uncertainties were reviewed using this new approach and an additional key assumption was identified for which a sensitivity study was performed and presented. In light of the fact that this approach appears to hinge on assigning of "Important, Medium, and Non-Importance" significance levels, please discuss the process for assigning these levels and the specific criteria involved.
OPPD's Response to Probabilistic Risk Assessment RAI 15.,q.01:
The procedure that is used to characterize assumptions is documented in the OPPD PRA procedure "Identification and Assessment of Modeling Assumptions." This procedure has the PRA analyst enter several different pieces of information into the assumptions database to support its characterization; this information is discussed below.
Assumption Type:
    *    "Simplifying" Assumptions: These are generally minor assumptions made to simplify portions of the model. These may include assumptions such as: "It is appropriate to assign all Loss of Coolant Accidents (LOCAs) to loop A, because LOCA location doesn't affect accident progression," or an assumption made to exclude transferring closed of manual isolation valves.
    *    "Simplifying / Conservative" Assumptions: This type of assumption is made to simplify the PRA model and is made in such a way that it will have a conservative (risk-overestimate) impact on the baseline model.
    " "Simplifying / Optimistic" Assumptions: This type of assumption is made to simplify the PRA model and is made in such a way that it will introduce nonconservatism (risk-understatement) into the baseline model. These assumptions should only be made when their impact is small.
    " "Realistic" Assumptions: This type of assumption is made in such a way that it very closely models reality in the plant. Types of assumptions that are classified as realistic include "statements" that are tracked in the assumptions database as well as simplifying assumptions that are very close to reality.
    *    "Consensus" Assumptions: These are assumptions that are based on a model or approach that is widely accepted throughout the industry. These may include assumptions such as:
         "The generic Motor Operated Valve failure rates are applicable because the MOVs used at FCS equivalent to the population of MOVs upon which the generic failure rates are based."
    *    "Unknown" Assumptions: The majority of these assumptions are made in response to generic areas of uncertainty for which there is insufficient existing information to suggest if the assumption is simplifying, realistic or even applicable. This type of assumption was formally classified as "state-of-knowledge." However, to avoid confusion with the generic area of uncertainty surrounding the "State of Knowledge Correlation" this category was renamed "Unknown."
45

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Sensitivity Impact:
The Sensitivity Impact is the PRA analyst's qualitative estimate of the impact of replacing the current assumption with reasonable alternative assumptions. It represents the difference between reality, and the assumption that is being used to represent reality. The "impact" of this sensitivity is a qualitative measure of the change in PRA results that would be seen if the current assumption was replaced with a reasonable alternative assumption. Therefore, based on these definitions:
     "    A "High" Sensitivity Impact indicates that replacing the current assumption with one of the reasonable alternative assumptions will likely cause changes to the risk profile of the plant that could change the top contributors to risk.
* A "Medium" Sensitivity Impact indicates that replacing the current assumption with one of the reasonable alternative assumptions will change the results of the baseline PRA such that the changes will be noticeable, but will not change a dominant risk contributor.
     "    A "Low" Sensitivity Impact indicates that replacing the current assumption with one of the reasonable alternative assumptions will not noticeably change the results of the baseline quantification.
* An entry of "None," for the Sensitivity Impact indicates that either there is no "Sensitivity Issue" because the assumption has been identified as a "Statement," or the assumption has zero impact on the at power PRA model.
Classification:
The classification is qualitatively assigned by reviewing the quality of the assumption's basis and considering its type (i.e., one of the six items listed above). The following definitions should be used as a guideline to qualitatively assess the level of importance that a given assumption is assigned.
Here importance is defined relative to the amount of attention that an assumption should be given when being considered for an application. Table 1 is provided as a guide to aid in assumption classification and how it relates to the assumption type and its impact on the model.
Table 1: Guidelines For Classifying PRA Assumptions Based on the Assumption Type and Sensitivity Impact Se nsit-ivi-lssue               High                         Medium            Low                   None Assumption Ty.pe Simplifying             Medium Importance /              Non-Important     Non-Important          Non-Important Non-Important Simplifying             Medium Importance                Non-Important     Non-Important          Non-Important Conservative Simplifying                    Important                     Important  Medium Importance        Non-Important Optimistic                                                                / Non-Important         Non-Important Realistic               Medium Importance                Non-Important     Non-Important          Non-Important
_____________       Non-Important               _______
Consensus                  Non-Important                 Non-Important     Non-Important          Non-Important Unknown                       Important*                    Important*  Medium Importance*        Non-Important Unknown                       Important*          _/        Important*      Non-Important Note that these classifications are only suggested if the "Unknown" assumption has a reasonable more conservative alternative assumption identified in the "Sensitivity Issue" field.
46

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Probabilistic Risk Assessment RAI 18.01:
By letter dated July 24, 2012, the licensee responded to Probabilistic Risk Assessment (PRA)
RAIs 17, 18a and 18b acknowledging that the last peer review of the internal events PRA (IEPRA) was performed in 1999 and that certain model changes performed since then warrant a peer review (i.e., the HRA, internal flooding, loss of off-site power (LOOP), recovery actions (RAs), and the update of the LERF model). In light of this, please perform a focused scope peer review of the internal events HRA and two of the PRA elements (i.e. LOOP recovery actions, and update of the LERF model) identified in response to PRA RAI 18.a and b. Please provide the findings from these peer reviews and the resolutions to these findings. If the resolutions to the peer review findings require changes to the FPRA, provide the CDF, LERF, ACDF, and ALERF for each fire area and the total based on the updated PRA model. In addition, if these resolutions impact the sensitivity studies performed, please provide revised sensitivity studies results.
OPPD's Response to Probabilistic Risk Assessment RAI 18.01:
A focused scope peer review was performed at Fort Calhoun Station in February 2013 that reviewed three specific areas of the OPPD Internal Events (IE) PRA that qualified as PRA upgrades or changes in methodology. These areas were the HRA, which was upgraded to the Human Reliability Analysis (HRA) Calculator, the Large Early Release Frequency (LERF) assessment, which adopted the Pressurized Water Reactor Owner's Group (PWROG) Simplified Level 2 methodology, and the Loss of Offsite Power (LOOP) recovery analysis, which used a convolution approach. Table 2 documents the disposition or resolution of the Facts and Observations (F&Os) from the February 2013 focused scope peer review from a FPRA perspective and provides an explanation of why the IE PRA, specifically in relation to these areas, is acceptable for the NFPA-805 transition.
47

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O         LevelSof           Finding/Observation                               FPRA Disposition / Resolution HR-A3-01 Finding             Basis for Significance:      Work practices rarely involve mechanisms that simultaneously affect There is no discussion of    equipment in diverse systems. For example, it is unlikely that Structures, mechanisms that              Systems, and Components (SSCs) supporting auxiliary feedwater and simultaneously affect either once-through-core-cooling would be removed from service at the same different trains of a        time because the Maintenance Rule risk assessment would be redundant system or diverse  unsatisfactory. Another example is that a crew would not be dispatched to systems.                     calibrate instrumentation for Containment Pressure High Signal (CPHS) and Pressurizer Pressure Low Signal (PPLS) on the same shift, because Possible Resolution:         each would require different tools and equipment. Therefore, work practices Document a discussion on     affecting availability and reliability of diverse systems are not represented in mechanisms that              the PRA and this assumption is judged to have a negligible impact on the simultaneously affect either CDF and LERF results for FCS. With respect to work practices involving different trains of a        mechanisms that simultaneously affect equipment in redundant systems, redundant system or diverse the original HRA development document acknowledges the importance of systems.                     creating pre-initiator Human Failure Events (HFEs) at the system level and not the train level: "...naming the human failure uniquely [for each train]
rather than according to procedure or equipment functional grouping, would yield two single event, human failure event cutsets for the system failure.
Quantifying these events would then doubly count the failure probability of what really is only a single event. Redundant systems developed using
[this method] can yield non-conservative estimates ... " This is especially important for standby systems or systems that are not operating during an outage. For example, it is not uncommon for a team of instrumentation and control technicians to calibrate multiple channels for an engineered safeguards function on the same shift.
Consistent with the preceding discussion, pre-initiator HFEs were created to represent failure at the system level, not the component or train level.
Therefore, the FCS HRA identified the work practices described by SR HR-A2, and assessed the joint probabilities described in Supporting Requirement (SR) HR-D5. A new issue has been opened in the FCS PRA configuration control database to ensure that the basis for this modeling practice is more clearly documented. Thus, this is considered to be a documentation issue and will not impact the results of the FCS FPRA.
48

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scone Peer Review F&Os F&O      Level of F&O      Significance       Finding/Observation                               FPRA Disposition / Resolution HR-E1-01 Finding          Basis for Significance:        This F&O is a documentation issue that will not impact the Fire Probabilistic There is no discussion of      Risk Assessment (FPRA) results. This issue has been logged into the FCS procedures used in the HFE     PRA configuration control database and will be resolved going forward.
analysis in the HRA            The FCS HRA is primarily documented within the HRA Calculator and not all notebook. The procedures       information is available in the HRA notebook. However, the information used per the HFEs are          documented within the HRA Calculator is considered to be of the same discussed in the HRA           quality as the HRA notebook and fulfills the same function. Therefore, this Calculator but there is no     documentation issue will not impact the results of the FCS FPRA.
way to verify that the correct and/or all the applicable procedures have been reviewed.
Possible Resolution:
Add a discussion of the procedures used in the development of the HFEs.
HR-E2-01 Finding          Basis for Significance:        Appendices B and F of the PRA project plan discuss the original HFEs and There is no discussion of      the methodology used. Additional HRA work is documented for the projects how the HFE to be analyzed     performed by CeltCo (1998) in and by Scientech (2004). Additionally, PRA were determined or the         Procedure, "Maintenance of the Human Reliability Analysis," provides methodology used for this      guidance for HFEs that are added during PRA revisions.
determination in the HRA notebook. There are            Although documentation of this issue is documented throughout the actions described in the       references above, it is recognized that consolidated documentation should HRA Calculator. The            be created going forward. A new issue has been opened in the FCS PRA actions screened out are not   configuration control database to more clearly document this issue. Thus, discussed in either the HRA    this is considered to be a documentation issue and will not impact the results notebook or HRA.               of the FCS FPRA.
Possible Resolution:
Add a discussion of the HFEs that were considered for the internal PRA.
49

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance       Finding/Observation                            FPRA Disposition / Resolution HR-G6-     Finding         Basis for Significance:     The reasonableness of the HFEs in the FCS PRA model is considered on a 01                         There is no evidence that a regular basis by individuals with intimate knowledge of the plant and its past review of the HFE           and current operation. Since its inception, the FCS PRA team has been reasonableness given the    composed of OPPD employees and PRA consultants. The OPPD team scenario context, plant     member most responsible for HRA had extensive FCS experience, having history, procedures,        held an active Senior Reactor Operator license, and previous positions operational practices and   including Reactor Engineer, operations and engineering training supervisor, experience was performed. and emergency operating procedure coordinator. Additionally, dominant human failure events were reviewed by an operating crew using either Possible Resolution:        simulator or table top scenarios. This level of involvement provides Include a discussion of the assurance of HFE reasonableness given the scenario context, plant history, review of HFE for their     procedures, operational practices and experience. Therefore, this finding is reasonableness given the    judged to have negligible, if any, impact upon the results of the FCS PRA. It scenario context, plant     may be desirable to enhance the documentation that demonstrates history, procedures,        compliance with this SR; therefore, a new issue has been opened in the operational practices and   FCS PRA configuration control database for that purpose. This is experience,                 considered to be a documentation issue and will not impact the results of the FCS FPRA.
50

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance       Finding/Observation                                FPRA Disposition / Resolution HR-11-01  Finding         Basis for Significance:        This F&O is a documentation issue that will not impact the FPRA results.
There are several sections     This issue has been logged into the FCS PRA configuration control which are included in the      database and will be resolved going forward.
HRA Calculator which, should be added to the HRA     The FCS HRA is primarily documented within the HRA Calculator, and not notebook to facilitate PRA     all information is available in the HRA notebook. However, the information applications, upgrades, and    documented within the HRA calculator is considered to be of the same peer reviews. An example is    quality as the HRA notebook and fulfills the same function. Therefore, this the procedures reviewed for    documentation issue will not impact the results of the FCS FPRA.
each HFE and which were applicable to the particular scenario.
Possible Resolution:
Add the appropriate sections to the HRA notebook.
HR-12-01  Finding         Basis for Significance:        This F&O is a documentation issue that will not impact the FPRA results.
There is no methodology        This issue has been logged into the FCS PRA configuration control section in the HRA             database and will be resolved going forward.
notebook.
Possible Resolution:           The FCS HRA is primarily documented within the HRA Calculator and not all Add a methodology section      information is available in the HRA notebook. However, the information to the HRA notebook to         documented within the HRA Calculator is considered to be of the same include the objectives of this quality as the HRA notebook and fulfills the same function. The HRA SR.                            methodology is documented in the Probabilistic Risk Assessment Project for Fort Calhoun Station Project Plan," (1989) and is maintained consistent with the HRA Calculator User's Manual. This documentation issue will not impact the results of the FCS FPRA.
51

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance       Finding/Observation                             FPRA Disposition / Resolution LE-C9-01   Finding        Basis for Significance:      This F&O has no impact on the FPRA LERF results. Because the CS Credit was taken for         system is not credited for fission product reduction and is only credited with operation of Containment     respect to maintaining long term containment pressure, the CS system only Sprays (CS) during a severe  impacts the frequency of late releases due to long term containment over-accident. However, there is  pressure related failures. An equipment survivability assessment was no documentation of          performed for the containment fan coolers and resulted in the same equipment survivability      conclusion. This issue has been logged into the FCS PRA configuration assessment for the CS        control database and will be resolved going forward; however this F&O does system. Such discussion is   not impact the FPRA LERF results.
required to fully meet this SR.
Possible Resolution:
Perform an equipment survivability assessment for the CS system and document this assessment appropriately.
52

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance       Finding/Observation                               FPRA Disposition / Resolution LE-F2-01   Finding        Basis for Significance:       This F&O has been resolved. A review of the LERF cutsets was performed Although significant LERF     and documented within the FCS PRA Configuration Control Form (CCF) contributors are discussed    related to this issue. The results of this review showed that the LERF in the model development      cutsets and results were correct and consistent with expectations. The sections, there was no        dominant LERF contributors are Inter-System Loss of Coolant Accident documentation to suggest      (ISLOCA), Thermally-Induced Steam Generator Tube Rupture (TI-SGTR) that a review of the          and Level 1 Induced-SGTRs from Main Steam and Feedwater Line Break dominant LERF sequences       (MSFLB) initiators. These results are expected as early containment failure was performed post-           modes such as hydrogen burns, steam explosions and High Pressure Melt quantification.               Ejection (HPME) related phenomena typically challenge containment integrity due to large pressure differentials. The FCS containment has a Possible Resolution:          relatively large containment volume for its core size and has a high median Include a write-up in the     containment failure pressure. These containment characteristics make these LERF results section          failure modes less likely, thus increasing the relative contribution of bypass discussing the various        events to LERF.
contributors and the insights gained. Reference any         Closure of this F&O did not result in any changes in the LERF model or applicable cutsets reviews    results. Therefore, this F&O does not impact the FPRA LERF results.
or plant procedures related to cutset reviews.
53

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition / Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance      Finding/Observation                             FPRA Disposition / Resolution LE-GI-01 Finding          Basis for Significance:     This F&O is a documentation issue that will not impact the FPRA LERF There is no roadmap         results. This issue has been logged into the FCS PRA configuration control provided that indicates     database and will be resolved going forward. Upon closure, this CCF will where the conformance to    result in a document that can be used as a roadmap for the LE SRs from the the various SRs of the PRA  most recent version of the ASME/ANS PRA Standard (Reference 1).
Standard is addressed. A roadmap will facilitate the PRA Peer review. This is a documentation issue and does not impact the PRA results.
Possible Resolution:
Include a roadmap that indicates where the conformance to the various SRs of the PRA Standard is addressed.
54

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure Table 2: Disposition I Resolution of February 2013 Focused Scope Peer Review F&Os F&O      Level of F&O      Significance         Finding/Observation                                FPRA Disposition / Resolution LE-G3-01    Finding          Basis for Significance:         This F&O has been resolved. Within the CCF related to this issue, LERF results are tabulated      additional LERF results are documented and characterized. The following in Section 6.4 of CN-RRA-       items are now documented appropriately:
06-27. However, there is no
* A discussion of the significance of the LERF results discussion provided to             9 The potential to reduce the LERF frequency is identified identify the significance of
* The dominant contributors to LERF are now more clearly documented these results. The dominant
* The contribution of Level 1 initiators to LERF has been added contributors are not identified and whether there    Closure of this F&O did not result in any changes in the LERF model or is a potential to reduce the    results. Therefore, this F&O does not impact the FPRA LERF results.
result is not identified. Also, the contribution of the Level 1 initiators to LERF are not identified as has been done in Figure 3.7-1 of the PRA Summary document for Level 1 PRA. Such discussion is required to fully meet this SR.
Possible Resolution:
Add a discussion results to the tables in Section 6.4 of the report where the LERF results are summarized.
In conclusion, all issues identified in the peer review have been shown to be either documentation issues that do not impact the FPRA, or are positions that will not significantly impact the FPRA CDF or LERF results and are not expected to alter any FPRA risk insights. The issues identified as part of the peer review have either been resolved, or have been entered into the OPPD PRA configuration control form database to be resolved in the future. Therefore, no ACDF or ALERF FPRA sensitivity studies are required.
55

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Probabilistic Risk Assessment RAI 20:
Please identify if any VFDRs in the LAR involved performance-based evaluations of wrapped or embedded cables. If applicable, describe how wrapped or embedded cables were modeled in the FPRA including assumptions and insights on how the PRA modeling of these cables contributes to the VFDR delta-risk evaluations.
OPPD's Response to Probabilistic Risk Assessment RAI 20:
There are no VFDRs involving performance-based evaluation of wrapped or embedded cables.
Probabilistic Risk Assessment RAI 21:
F&O PRM-B9-01: Per Calculation FC07819 and FC07826 the MCR heating ventilation and air conditioning (HVAC) is qualitatively screened from the FPRA. One of the reasons for the screening cited in the plant disposition is that there is a low frequency of fires with the potential to damage both HVAC trains, VA-46A and VA-46B. Please indicate if the cables for these trains were traced and describe how the frequency for damage to both of these trains was established. Please discuss if a fire in other locations can result in loss of MCR HVAC and how this was considered in the fire PRA. If the cables were not traced, discuss how the feasibility of implementing AOP-13 is ensured. Provide a quantitative assessment for the failure of MCR HVAC and other forms of room cooling as identified in the plant response to the F&O and, if significant, evaluate the MCR CDF/LERF given loss of MCR HVAC.
OPPD's Response to Probabilistic Risk Assessment RAI 21:
Cables supporting the control room HVAC units VA-46A and VA-46B have been identified in support of the NFPA 805 transition. As described in the following bullets, fire compartments in which cabling and/or equipment associated with both HVAC units are co-located include FC20-7R (auxiliary building roof), FC41 (cable spreading room), and FC42 (main control room) :
* FC20-7R: This compartment houses the VA-46A and VA-46B condensers and is located on the roof of compartment FC20-7. No fixed ignition source in this area could fail both HVAC units. A transient fire could potentially fail both HVAC units. Note that no fire-induced failures beyond the HVAC units would occur for this transient fire scenario.
* FC41: No fixed ignition source in this area could fail both HVAC units. A transient fire between column lines E and slightly north of column line 7a, or a transient fire between column lines 7a and 6d, could potentially fail both HVAC units. However, these transient fires would also cause widespread damage sufficient to warrant control room abandonment and alternate shutdown, rendering the loss of MCR HVAC irrelevant. FC41 is, therefore, excluded from this analysis, and its risk contribution is included in the base FPRA.
* FC42: Overlap occurs in the mechanical equipment room where HVAC units VA-46A and VA-46B are physically located. No fixed ignition source in this area could fail both HVAC units.
There is a portion of this area where a transient fire could impact both trains. This area of the control room is roped off with a chain and not anticipated to be an area for transient storage, but nonetheless a transient fire is conservatively postulated for this analysis. Note that no fire-induced failures beyond the HVAC units would occur for this transient fire scenario.
56

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure Beyond the HVAC units themselves, EA-FC-95-014, Revision 0, systematically considers dependencies for the HVAC units (namely electrical), and it confirms that FC41, FC42, and FC20-7R are the only areas where fire may fail both trains of control room HVAC.
Note that the HVAC units contain economizers that are required when the outside air temperature is below 0&deg;F, since the condensing units are not qualified below 0&deg;F. Analysis EA-FC-95-014 states, via reference to calculation FC06311, that "...for the loss of the condensing units due to low outside temperatures, the control room would not be expected to reach elevated temperatures for approximately 25 hours." This duration exceeds the PRA mission time and is, therefore, excluded from further analysis.
The following table documents ignition frequencies for transient fires capable of damaging both trains of HVAC.
PRA-RAI-21 Table 1: Transient Fire Ignition Frequencies Failing Both Trains of HVAC Transient Fire           Fraction of          Transient Fire Frequency Fire Compartment             Frequency for FC           Floor Area          Failing VA-46A and VA-46B FC42                               8.04E-04              4.68E-02i                     3.76E-05 FC20-7ROOF                         3.1OE-04             2.69E-02 **                    8.34E-06
   *Based on the routing of the relevant HVAC cables, a transient fire occurring anywhere within approximately 50% of the mechanical equipment room floor area could damage both trains of HVAC. The fraction of the total control room floor area where loss of both HVAC trains may occur is therefore (0.5)(473)/(5056) = 4.68E-02.
   ** Based on the routing of the relevant HVAC cables, a transient fire occurring anywhere within room containing the HVAC condensers in FC20-7ROOF could damage both trains of HVAC. The fraction of the total FC20-7ROOF area where loss of both HVAC trains may occur is therefore (473)/(17,561) = 2.69E-02. The floor area of this room is assumed consistent with the MCR HVAC room and per drawing review.
AOP-13 Attachments A, B, and C provide direction to align one of the following three diverse backup methods of control room ventilation: turbine building exhaust fans, auxiliary building exhaust fans, and using portable fans. An HRA of operator alignment of backup room cooling using Attachment A yielded an HEP of 3.80E-03. For the purpose of this analysis, failure to align backup cooling is conservatively assumed to, result in CCDP and CLERP values of 1.0. The CDF and LERF for fire-induced loss of control room HVAC are conservatively assessed in the following table.
PRA-RAI-21 Table 2: Fire Induced Loss of Control Room HVAC CDF and LERF Fire            Frequency         HEP Backup          CCDP             CLERP           CDF          LERF Compartment                                Cooling FC42                    3.76E-05           3.80E-03             1.0             1.0        1.43E-07      1.43E-07 FC20-7ROOF              8.34E-06           3.80E-03             1.0             1.0        3.17E-08      3.17E-08 TOTAL        1.75E-07      1.75E-07 The OPPD total CDF, total LERF, VFDR ACDF, and VFDR ALERF would remain within RG 1.174 (Revision 1) Region II with the conservative assessment of sequences involving loss of control room HVAC numerically included. This is summarized in the following table.
57

U. S. Nuclear Regulatory Commission LIC-13-0060 Enclosure PRA-RAI-21 Table 3: Sensitivity Study Loss of MCR HVAC Summary Base            Sensitivity Study Fire       (Conservative   Modeling PRA*         of Loss of MCR HVAC)
Net VFDR ACDF for NFPA 805 Transition (/yr)                              5.72E-06             5.75E-06**
Net VFDR ALERF for NFPA 805 Transition (/yr)                             6.67E-07             6.99E-07**
Total CDF (internal, flood, fire) (/yr)                                  6.01 E-05              6.03E05 Total LERF (internal, flood, fire) (/yr)                                 4.82E-06               5.00E06
  *Base Fire PRA results as reported in Section W.2 of LIC-1 1-0099.
  ** VFDR ACDF and ALERF calculated as the base case values, added to the ACDF and ALERF for FC20-7ROOF, which have VFDRs associated with loss of control room HVAC. While the FC42 CDF and LERF contribute to total plant risk, they do not contribute to the risk associated with FC42 VFDRs.
Probabilistic Risk Assessment RAI 22:
Calculation FC07821 describes the fire ignition frequency development methodology and results. Relative to this report, please provide the following:
Section 5.2 states that a Bayesian update was not performed. SR IGN-A4 requires that a Bayesian update be performed to meet this SR. Table 5-1 shows that the plant has experienced two "potentially challenging" fires, one dated 12/19/2001 and another dated 11/29/1997. An update should be performed for the 2001 event which is not a part of the generic database. An update should be performed for the 1997 event if it is not a part of the generic database. In addition, the June 2011 Switchgear Room fire may also be classified as a "potentially challenging" fire. Please provide an assessment of the impact on CDF, LERF, ACDF, and ALERF of a Bayesian update of the fire ignition frequencies considering these plant-specific fires.
OPPD's Response to Probabilistic Risk Assessment RAI 22:
The three referenced plant specific fire events are shown in the following table:
Table PRA-RAI Three Plant Specific Fire Events Fire Event                Date                  Location                  Ignition       Mode of     "Potentially Source Bin       Operation    Challenging" CR199701629:                                                                Bin 4: Main Control Room             11/29/1997             Fire Area 42                  Control       At Power        Yes Fire                                                                    Board Tendon Stressing                  Bin 7:
CR200103787:                                  Gallery, accessed              Transient Stressing Gallery          12/19/2001          from one of two SI                Fires        At Power        Yes Fire                                     pump rooms CR 2011-5414 Halon actuated                                                              Bin 15.1:
within switchgear          06/07/2011           West Switchgear               Electrical       Mode 5         Yes room due to fire                                      Room                   Cabinets          (SDC) within West                                                              non-HEAF Switchgear 58

U. S. Nuclear Regulatory Commission LIC-1 3-0060 Enclosure The FCS fire ignition frequency calculation (Calculation FC07821) uses the generic frequencies from EPRI 1019259, which include fire events data through the year 2000. The first FCS fire event (1997), is within the range of data considered by EPRI 1019259; therefore, a Bayesian update is not required.
The occurrence of one Bin 4 event does not indicate a particular susceptibility of FCS to this fire type, as compared to the industry operating experience, and the generic frequency is therefore applicable to FCS.
Similarly, the Bin 7 event and the Bin 15.1 event do not demonstrate a particular susceptibility to these fire types, as compared to the industry operating experience. The generic frequencies for these two bins are therefore applicable to FCS. While these two events occurred outside the date range considered by the generic data, when the generic frequencies are updated, the contribution of these two events will be distributed across the total reactor years for all US reactors.
59

LIC-13-0060 Enclosure, Attachment 1 Page 1 of 3 Safe Shutdown RAI 15 Response Sketches of Conceptual Proposed Design Option(s) as Described for REC-1 19 and REC-1 20 in Attachment S of the Transition LAR (LIC-1 1-0099)
(Battery Room)

LIC-1 3-0060 Enclosure, Attachment 1              REC-1 19 and REC-1 20 Proposed Modification Conceptual Design Page 2 of 3 I                                          I          switchgear room I                                          I I                                          I I                                          I I                                           I I                                           I I     battery room                          I I                                           I I                  fuses                    I I                                           I I                                           I I                                           I I                                           I I                                           I I                                           I I-----------------------------------4 existing design switchgear room DC bus

LIC-13-0060                           REC-1 19 and REC-120 Proposed Modification Conceptual Design Enclosure, Attachment 1 Page 3 of 3 II-                                                         switchgear room II I
I          battery room
______________________l I---------
flow N1/                               proposed design switchgear room

LIC-13-0060 Enclosure, Attachment 2 Page 1 of 5 Safe Shutdown RAI 16 Response Sketches of Conceptual Proposed Design Option(s) as Described for REC-1 12 in Attachment S of the Transition LAR (LIC-1 1-0099)

LIC-1 3-0060 Enclosure, Attachment 2           REC-1 12 Proposed Modification Conceptual Design Page 2 of 5 existing design

LIC-13-0060 Enclosure, Attachment 2                     REC-1 12 Proposed Modification Conceptual Design Page 3 of 5 proposed design option #1
* coordinating fuse for calculated DC fault current at remote location representing X feet of control cable distance away from switchgear; new fuse and diode located in switchgear / switchgear room

LIC-13-0060 Enclosure, Attachment 2                     REC-1 12 Proposed Modification Conceptual Design Page 4 of 5 proposed design option #2
* coordinating fuses for calculated DC fault current at remote location representing X feet of control cable distance away from switchgear; new fuses located in switchgear
                      / switchgear room

LIC-1 3-0060 Enclosure, Attachment 2                 REC-1 12 Proposed Modification Conceptual Design Page 5 of 5 proposed design option #3 use of interposing relay to achieve contact isolation, with separate parallel fuses; new fuses and relay located in switchgear / switchgear room

LIC-13-0060 Enclosure, Attachment 3 Page 1 of 67 Fire Protection Engineering RAI 18.01c Response Pyrocrete Encased Conduit Locations for Tray Section 34S-1 Drawing 11 405-E-67, Sheet 78 and FCS Cable Route Report for Cables in Tray Section 34S-1
[Subsections C3, C3A, C4, and 14]
Intersecting this Pyrocrete Assembly

LIC-13-0060 Enclosure, Attachment 3 241      CA-C)               EC ag,     1 11322' -60 240 1l (A-C)
KPM 12" I
MIA 12" 11922' -6"
                &#xa3;2"             120                                                 ( EC)
: 24. 1(A-C)        I IEM
                                   ,(A-C)
LE P~r I 1021' _S..                j2 2 24 A-C m
tr a
a-ru "C'l 1921' -6" 8"   8         4" 4' CEC)           (N-A-C)
MA      I 11M20 -6"       24-i       I EC         (N-A-C)              -6" 1929'HIGH) 24w"       C3         I                                                                      S(6"
* m               m*
1x-               1Z"
   --                                             m 24"   i II
(-A-C C4
                               ..       p 131:' -N" 24"           12"              12L    (W   HIGH) 1819' -6" 1z" PYROCRISTE~
34S-1                       C01.JDCJ TS                 34S-2 (11485-E-73)                                             (11405-E-73)
(N-A-C) 24" 1                C1               1 1029"-6" 24"     I   1NA-C)       c2N-A-C)        1028' -6" 35S C11415J-E-73)

LIC-1 3-0060 Enclosure, Attachment 3 FCS Cable Route Reportfor 34S-1(C3)
Cable                       Status   App R    Safety     Function  System     Qty  Length W Number EC1780                    AC           Y        EC          C        EE        1     175     W040 Origin                                               Destination CB-4AUX <42>                                         1A3-2 <>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                   1780      OPLS CONTROL Routing:   34S-1 (C3)<36A>               34S-2(C3)<36A>               36S(C3)<36A>
37S(C2)<36A>                  38S(C1 )<36A>                20(C1 )<41 >
18(C1)<41>
Cable                       Status   App R    Safety     Function  System     Qty  Length W Number EC5932                    AC           N        EC          C        CA        1     85      W041 Origin                                               Destination Al-108A <36A>                                        MCC-CA-1C <>
Raceway Description                                 Associated Equipment T,1 1/2"C                                            <>
Project            Numeric Part Cable Use NONE                   5932      AIR COMPRESSOR CA-1C SEQ S1-1 START &
Routing:   34S-1(C3)<36A>
Cable                       Status   App R    Safety     Function  System     Qty  Length W Number EC5932A                   AC           N        EC          C        CA        1     85      W041 Origin                                               Destination AI-108A <36A>                                        MCC-CA-1C <>
Raceway Description                                 Associated Equipment T, 1 1/2"C                                           <>
Project            Numeric Part Cable Use NONE                   5932      AIR COMPRESSOR CA-1C SEQ S1-2 START &
Routing:   34S-1(C3)<36A>
Cable                       Status   App R    Safety     Function  System     Qty  Length W Number EC7315                    AC           Y        EC          C      AC-RW       1    245      W040 Origin                                               Destination 1A3-10 <36A>                                         CB-1 <42>
Raceway Description                                 Associated Equipment T                                                    HCV-2852 <31>
Project            Numeric Part Cable Use NONE                   7315      VALVE HCV-2852 CONTROL Routing:   34S-1(C3)<36A>                34S-2(C3)<36A>               36S(C3)<36A>
38S(Ci)<36A>                  20(Cl)<41>                   18(Cl)<41>
15(C1)<41>
Tuesday, May 14, 2013                             54 Cables                                Page I of 18

FCS Cable Route Report for 34S-1(C3)
Cable                        Status    App R     Safety     Function  System    Qty  Length W Number EC7316                      AC           Y          EC          C     AC-RW      1     790    W041 Origin                                                  Destination CB-1 <42>                                               JB-82T <31>
Raceway Description                                    Associated Equipment T,4"C                                                   HCV-2852 <31>
Project           Numeric Part Cable Use NONE                   7316       PUMP DISCH PRESS IND & HCV-2852 CONTROL Routing:   15(C1)<41>                     18(C1)<41>                    20(C1)<41>
38S(C1)<36A>                   37S(C2)<36A>                  36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>               34S(C3)<36A>
33S(C2A)<36A>                  A6(DUCT)<>                    C-7316(CND)<31A>
Cable                       Status    App R     Safety     Function  System    Qty  Length W Number EC7320                     AC           Y          EC          C      AC-RW     1     790     W041 Origin                                                 Destination JB-84T <31>                                            CB-1 <42>
Raceway Description                                    Associated Equipment 4"C,T                                                  HCV-2876A <31>
Project            Numeric Part Cable Use NONE                   7320       HCV-2876A CONTROL & HYD PRESS IND Routing:   A6(DUCT)<>                     33S(C2A)<36A>                 34S(C3)<36A>
34S-1 (C3)<36A>                34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                   38S(Cl)<36A>                  20(C1)<41>
18(C1)<41>                     15(C1)<41>                    C-7320(CND)<31A>
Cable                       Status    App R     Safety     Function   System   Qty  Length W Number EC7341                     AC           N          EC          C      AC-RW     1     215     W038 Origin                                                 Destination 1A3-10 <36A>                                           AI-30A <42>
Raceway Description                                    Associated Equipment T                                                     jAC-10C <31>
Project            Numeric Part Cable Use NONE                   7341       AC-1OC AUTO STDBY INITIATING CKT DC SEQ Routing:   34S-1(C3)<36A>                 34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                   38S(C1)<36A>                  20(C1)<41>
66(C1)<41>                     7-1 (Cl B)<41>
Tuesday, May 14, 2013                                54 Cables                              Page 2 of 18

FCS Cable Route Report.for 34S-1(C3)
Cable                       Status   App R     Safety      Function  System     Qty  Length W Number EC7341A                    AC          N          EC          C      AC-RW       1    215      W038 Origin                                                 Destination 1A3-10 <36A>                                           AI-30A <42>
Raceway Description                                    Associated Equipment T                                                     [AC-10C <31>
Project            Numeric Part Cable Use NONE                   7341      AC-10C AUTO STDBY INITIATING CKTAC SEQ Routing:    34S-1(C3)<36A>               34S-2(C3)<36A>                 36-S(C3)<>
37S(C2)<36A>                 38S(C1)<36A>                   20(Cl)<41>
66(Cl)<41>                    7-1 (Cl B)<41>
Cable                       Status   App R     Safety      Function  System     Qty  Length W Number EC7383                     AC          Y          EC          C      AC-RW       1    240      W042 Origin                                                 Destination 1A3-10 <36A>                                          CB-1 <42>
Raceway Description                                    Associated Equipment T                                                      AC-1OC <31>
Project           Numeric Part Cable Use NONE                   7383       RAW WATER PUMP AC-10C CONTROL Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                 36S(C3)<36A>
37S(C2)<36A>                  38S(C1 )<36A>                  20(C1 )<41 >
18(C1)<41>                   15(C1)<41>
Cable                       Status   App R      Safety     Function  System     Qty  Length W Number EC7384                     AC          Y          EC          C      AC-RW       1    240      W042 Origin                                                 Destination 1A3-10 <36A>                                           CB-1 <42>
Raceway Description                                    Associated Equipment T                                                     LAC-10C <31>
Project            Numeric Part Cable Use NONE                   7384       RAW WATER PUMP AC-10C CONTROL Routing:    34S-1(C3)<36A>               34S-2(C3)<36A>                 36S(C3)<36A>
37S(C2)<36A>                 38S(C1)<36A>                   20(Cl)<41>
18(C1)<41>                   15(C1)<41>
Tuesday, May 14,2013                               54 Cables                                Page 3 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number EC7385                    AC           N         EC          C      AC-RW       1    240      W040 Origin                                                Destination 1A3-10 <36A>                                         CB-1 <42>
Raceway Description                                   Associated Equipment T                                                     AC-1OC <31>
Project           Numeric Part Cable Use NONE                   7385       RAW WATER PUMP AC-10C ALARMS Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                 38S(C1)<36A>                  20(C1)<41>
18(Cl)<41>                   15(Cl)<41>
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number EC7386                   AC           Y          EC          C     AC-RW       1    240      W033 Origin                                                Destination 1A3-10 <36A>                                         CB-1 <42>
Raceway Description                                  Associated Equipment T                                                     AC-10C <31>
Project           Numeric Part Cable Use NONE                  7386       RAW WTR PUMP AC-10C MOTOR CT LEADS Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                 38S(C1 )<36A>                 20(C1 )<41 >
18(Cl)<41>                   15(Cl)<41>
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number EC7389                   AC           Y          EC          C     AC-RW       1    215      W039 Origin                                                Destination 1A3-10 <36A>                                         AI-30A <42>
Raceway Description                                   Associated Equipment T                                                     AC-1OC <31>
Project           Numeric Part Cable Use NONE                   7389       RAW WTR PUMP AC-10C AUTO START SEQ S1-1 Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                 38S(C1)<36A>                  20(C1)<41>
66(C1)<41>                   7-1 (Cl B)<41>
Tuesdav, MaV 14, 2013                              54 Cables                               Page 4 of 18

FCS Cable Route Report.for 34S-1(C3)
Cable                       Status   App R      Safety     Function System    Qty   Length W Number EC7389A                    AC          Y          EC          C     AC-RW      1      215     W039 Origin                                                 Destination 1A3-10 <36A>                                         AI-30A <42>
Raceway Description                                   Associated Equipment T                                                     AC-10C < 31 >
Project            Numeric Part Cable Use NONE                   7389      RAW WTR PUMP AC-10C AUTO START SEQ S1-2 Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                 38S(C1)<36A>                  20(C1)<41>
66(C1)<41>                   7-1 (Cl B)<41>
Cable                       Status   App R      Safety     Function System    Qty   Length W Number EC7390                    AC          N          EC          C     AC-RW       1     215     W041 Origin                                                 Destination 1A3-10 <36A>                                         AI-30A <42>
Raceway Description                                  Associated Equipment T                                                     AC-10C <31>
Project            Numeric Part Cable Use NONE                  7390      RAW WATER PUMP AC-10C ALARMS Routing:   34S-1(C3)<36A>               34S-2(C3)<36A>                36S(C3)<36A>
37S(C2)<36A>                 38S(C1)<36A>                  20(C1)<41>
66(C1)<41>                   7-1 (Cl B)<41>
Cable                       Status   App R      Safety     Function System    Qty  Length W Number EC9515                     AC          N          EC          C     VA-CON      1     135     W038 Origin                                                 Destination 1B3C-4C-3 <>                                          E-2 <34B. 1>
Raceway Description                                   Associated Equipment T                                                     VA-7C <>
Project             Numeric Part Cable Use NONE                   9515      HEATER SUPPLY Routing:    34S-2(C3)<36A>               34S-1 (C3)<36A>               46S(C1A)<36B>
54S-2(C1A)<34B.1>            50S(C1A)<34B. 1>              91 S(C2A)<34B. 1>
90S(C2)<34B. 1>
Tuesday, May 14, 2013                              54 Cables                               Page 5 of 18

FCS Cable Route Report for 34S-1(C3)
Cable                        Status  App R     Safety      Function  System    Qty  Length W Number EC9534                     AC           N         EC          C        CA       1     220     W038 Origin                                                Destination 1B3A-4A-2 <>                                          CA-1C-M <>
Raceway Description                                   Associated Equipment
-I"C,T,I",C                                            CA-1C <>
Project            Numeric Part Cable Use NONE                    9534      HEATER SUPPLY Routing:   36S(C3)<36A>                   34S-2(C3)<36A>                34S-1(C3)<36A>
Cable                        Status   App R    Safety      Function  System    Qty  Length W Number EC9542                     AC           Y         EC          C        DG       1     260     W042 Origin                                                Destination AI-30A <42>                                           AI-133A <35A>
Raceway Description                                   Associated Equipment T                                                    [DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9542      DIESEL 1 REMOTE MANUAL START/STOP Routing:   7-1 (CL B)<41>                 66(Cl)<41>                    20(Cl)<41>
38S(Cl )<36A>                  37S(C2)<36A>                  36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>               34S(C3)<36A>
32S(C1 )<36A>
Cable                        Status  App R     Safety     Function   System    Qty  Length W Number EC9542A                    AC           N         EC          C        DG       1     260     W038 Origin                                                 Destination AI-30A <42>                                            AAI-133A <35A>
Raceway Description                                   Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                     9542      DIESEL DISPLAY LIGHT SUPPLY Routing:   7-1(ClB)<41>                   66(C1)<41>                   20(C1)<41>
38S(C1)<36A>                   37S(C2)<36A>                 36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>               34S(C3)<36A>
32S(Cl)<36A>
Tuesdav, Mav 14, 2013                               54 Cables                               Page 6 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                        Status   App R      Safety      Function  System    Qty  Length W Number EC9552                      AC          Y          EC            C       DG       1     270     W038 Origin                                                  Destination CB-21 <42>                                              AI-133A <35A>
Raceway Description                                     Associated Equipment T                                                       DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9552       DIESEL 1 TRIP Routing:   16(C1)<41>                     18(C1)<41>                     20(C1)<41>
38S(C1 )<36A>                  37S(C2)<36A>                   36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>                34S(C3)<36A>
32S(C1 )<36A>
Cable                        Status   App R      Safety      Function  System    Qty  Length W Number EC9556A                     AC          Y          EC            C       DG       1             W038 Origin                                                  Destination AI-24 <42>                                              AI-133A <35A>
Raceway Description                                     Associated Equipment T                                                       DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9556      4160V BUS 1A3 BACK-UP LOSS OF VOLTAGE Routing:   12(C1)<41>                     14(C1)<41>                      18(CI)<41>
20(C1 )<41 >                   38S(C1 )<36A>                  37S(C2)<36A>
36S(C3)<36A>                   34S-2(C3)<36A>                 34S-1 (C3)<36A>
34S(C3)<36A>                   32S(C1 )<36A>
Cable                        Status   App R      Safety      Function  System    Qty  Length W Number EC9558                      AC          Y          EC           C        DG       1     290     W041 Origin                                                 !Destination AI-26 <42>                                              AAI-133A <35A>
Raceway Description                                     Associated Equipment T                                                       DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9558      DIESEL 1 REMOTE GOV & VOLT CONT Routing:   12(C1)<41>                     14(C1)<41>                      18(C1)<41>
20(C1)<41>                     38S(Cl)<36A>                   37S(C2)<36A>
36S(C3)<36A>                   34S-2(C3)<36A>                 34S-1 (C3)<36A>
34S(C3)<36A>                   32S(C1 )<36A>
Tuesday, May 14,2013                                 54 Cables                                Page 7 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                        Status    App R     Safety       Function System     Qty   Length W Number EC9562                      AC           N         EC             C      DG        1     320      W040 Origin                                                   Destination CB-21 <42>                                               AI-133A <35A>
Raceway Description                                      Associated Equipment T                                                        DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9562      &#xfd;4160V BKRS 1A13 & 1A33 LOCKOUT Routing:   16(C1)<41>                      18(C1)<41>                     20(C1)<41>
38S(C1 )<36A>                   37S(C2)<36A>                   36S(C3)<36A>
34S-2(C3)<36A>                  34S-1 (C3)<36A>                34S(C3)<36A>
32S(C1)<36A>
Cable                        Status    App R     Safety       Function System     Qty   Length W Number EC9562A                     AC           Y         EC             C      DG        1              W041 Origin                                                   Destination CB-21 <42>                                               AI-133A <35A>
Raceway Description                                      Associated Equipment T                                                      j DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9562       4160V BKRS 1A13 & 1A33 LOCKOUT Routing:   16(C1)<41A>                     18(C1)<41A>                    20(C1)<41>
38S(C1 )<36A>                   37S(C2)<36A>                   36S(C3)<36A>
34S-2(C3)<36A>                  34S-1 (C3)<36A>                34S(C3)<36A>
32S(C1)<36A>
Cable                        Status    App R     Safety       Function System     Qty  Length W Number EC9564                      AC           Y         EC             C      DG        1     260      W041 Origin                                                   Destination Al-133A <35A>                                            AI1-30A <42>
Raceway Description                                      Associated Equipment T                                                        DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9564      &#xfd;4160V BKR lAD1 AUTO CLOSE DEMAND CHNL"A" Routing:   32S(C1)<36A>                    34S(C3)<36A>                   34S-1 (C3)<36A>
34S-2(C3)< 36A>                 36S (C3)< 36A>                 37S(C2)<36A>
38S(C1)<36A>                    20(C1)<41 >                    66(C1)<41>
7-1 (C1 B)<41 >
Tuesday, May 14,2013                                 54 Cables                                  Page 8 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                         Status   App R     Safety    Function  System      Qty   Length W Number EC9566                      AC           Y         EC          C       DG         1     240      W040 Origin                                                 Destination 1A3-20 <36A>                                          AI-30A <42>
Raceway Description                                   Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9566      4160V BKR lADI AUTO CLOSE DEMAND CHNL"A" Routing:   34S(C3)<36A>                   34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                   37S(C2)<36A>                 38S(C2)<36A>
20(C1)<41>                     66(C1)<41>                   7-1 (Cl B)<41>
Cable                         Status   App R     Safety    Function  System      Qty   Length W Number EC9568                     AC           N         EC          C       DG         1      260     W038 Origin                                                  Destination Al-133A <35A>                                          AI-30A <42>
Raceway Description                                   Associated Equipment T                                                    IDG-1 <35A>
Project            Numeric Part Cable Use NONE                    9568      DIESEL 1-CIRCUIT CLOSING ALARM SUP Routing:   32S(C1)<36A>                   34S(C3)<36A>                 34S-1 (C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                   20(C1)<41>                   66(C1)<41>
7-1 (Cl B)<41>
Cable                         Status   App R     Safety    Function  System      Qty   Length W Number EC9568A                     AC           Y         EC          C       DG         1     260      W038 Origin                                                  Destination AI-1 33A <35A>                                         AI-30A <42>
Raceway Description                                    Associated Equipment T                                                       DG-1 <35A>
Project            Numeric Part Cable Use NONE                     9568      DIESEL 1-ENGINE SPEED INDICATION INPUT Routing:   32S(C1)<36A>                   34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                   20(C1)<41>                   66(C1)<41>
7-1(CIB)<41>
Tuesday, May 14, 2013                               54 Cables                                 Page 9 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                        Status    App R     Safety    Function  System     Qty  Length W Number EC9570                      AC           N         EC          C       DG        1     260     W041 Origin                                                  Destination Al-133A <35A>                                          AI-30A <42>
Raceway Description                                    Associated Equipment T                                                     &#xfd;DG-1 <35A>
Project             Numeric Part Cable Use NONE                    9570       DIESEL 1-ANNUN Routing:   32S(C1)<36A>                    34S(C3)<36A>                 34S-1 (C3)<36A>
34S-2(C3)<36A>                  36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                    20(C1)<41>                   66(C1)<41>
7-1 (Cl B)<41>
Cable                        Status    App R     Safety    Function  System     Qty  Length W Number EC9570A                     AC           Y         EC          C       DG        1     260     W038 Origin                                                  Destination AI-133A <35A>                                          AI-30A <42>
Raceway Description                                    Associated Equipment T                                                     JDG-1 <35A>
Project             Numeric Part Cable Use NONE                    9570       DIESEL 1-DISPLAY LTS Routing:   32S(C1)<36A>                    34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>                  36S(C3)<36A>                 37S(C2)<36A>
38S(Cl)<36A>                    20(Cl)<41>                   66(C1)<41>
7-1(C1B)<41>
Cable                        Status    App R     Safety    Function  System     Qty  Length W Number EC9572                      AC           Y         EC          C       DG        1     300     W041 Origin                                                 Destination D1 <35A>                                               AI-30A <42>
Raceway Description                                    Associated Equipment T                                                      DG-1 <35A>
Project             Numeric Part Cable Use NONE                    9572       DIESEL DG-1 DISPLAY LGTS Routing:   32S-2(C)<35A>                   32S-1 (C2)<35A>              32S(C1)<36A>
34S(C3)<36A>                    34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                    37S(C2)<36A>                 38S(Cl )<36A>
20(C1)<41>                      66(C1)<41>                   7-1(ClB)<41>
Tuesdav, Mav 14, 2013                                54 Cables                              Page 10 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number EC9572A                   AC           N         EC           C       DG        1     300     W041 Origin                                                 Destination D1 <35A>                                              AI-30A <42>
Raceway Description                                   Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9572       DIESEL DG-1 DISPLAY LGTS Routing:   32S-2(C)<35A>                 32S-1 (C2)<35A>               32S(C1)<36A>
34S(C3)<36A>                  34S-1 (C3)<36A>               34S-2(C3)<36A>
36S(C3)<36A>                  37S(C2)<36A>                  38S(C1 )<36A>
20(CI)<41>                    66(C1)<41>                    7-1(C1B)<41>
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number EC9572B                   AC           N         EC           C       DG        1     300     W042 Origin                                                 Destination D1 <35A>                                              AI-30A <42>
Raceway Description                                  iAssociated Equipment T                  _                                   DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9572       DIESEL DG-1 DISPLAY LGTS Routing:   32S-2(C)<35A>                 32S-1 (C2)<35A>               32S(C1)<36A>
34S(C3)<36A>                  34S-1 (C3)<36A>               34S-2(C3)<36A>
36S(C3)<36A>                  37S(C2)<36A>                  38S(C2)<36A>
20(C1)<41>                    66(Cl)<41>                    7-1(C1B)<41>
Cable                       Status    App R     Safety     Function  System    Qty   Length W Number EC9572C                   AC           N         EC           C       DG        1     300     W042 Origin                                                 Destination D1 <35A>                                              AI-30A <42>
Raceway Description                                   Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9572       DIESEL DG-1 DISPLAY LGTS Routing:   32S-2(C)<35A>                 32S-1(C2)<35A>                32S(C1)<36A>
34S(C3)<36A>                  34S-1 (C3)<36A>               34S-2(C3)<36A>
36S(C3)<36A>                  37S(C2)<36A>                  38S(C2)<36A>
20(C1)<41>                    66(C1)<41>                    7-1(ClB)<41>
Tuesdav, May 14, 2013                              54 Cables                               Page I11 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                        Status   App R     Safety      Function  System    Qty   Length W Number EC9574                      AC          Y         EC           C        DG       1     300      W038 Origin                                                  Destination D1 <35A>                                                AI-30A <42>
Raceway Description                                     Associated Equipment T                                                     - DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9574       DIESEL DG-1 AUTO CLS DEMAND CHAN "A" Routing:   32S-2(C)<35A>                  32S-1 (C2)<35A>                32S(C1)<36A>
34S(C3)<36A>                   34S-1 (C3)<36A>                34S-2(C3)<36A>
36S(C3)<36A>                   37S(C2)<36A>                   38S(C2)<36A>
20(C1)<41>                     66(C1)<41>                     7-1(C1B)<41>
Cable                        Status   App R     Safety      Function  System    Qty   Length W Number EC9576                      AC          Y         EC           C        DG       1     305      W041 Origin                                                  Destination AI-30A <42>                                             RB-D1 <>
Raceway Description                                     Associated Equipment T,1 1/2"C                                               DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9576       DAMPERS YCV-871G&H CONTROL & INDIC Routing:   7-1 (Cl B)<41>                 66(C1)<41>                     20(C1)<41>
38S(C1 )<36A>                  37S(C2)<36A>                   36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>                34S(C3)<36A>
32S(C1 )<36A>                  32S-1 (C2)<35A>
Cable                        Status   App R    Safety       Function  System    Qty   Length W Number EC9577                      AC          N         EC           C        DG       1     305      W038 Origin                                                  Destination AI-30A <42>                                              RB-D1 <>
Raceway Description                                     Associated Equipment T, 1"C                                                  DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9577       DAMPERS YCV-871G&H ALARM Routing:   7-1 (Cl B)<41>                 66(C1)<41>                     20(C1)<41>
38S(C1 )<36A>                  37S(C2)<36A>                   36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>                34S(C3)<36A>
32S(Cl)<36A>                   32S-1 (C2)<35A>
Tuesday, May 14, 2013                               54 Cables                                Page 12 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                       Status   App R    Safety     Function  System    Qty  Length W Number EC9578                     AC          N        EC           C       DG       1     305     W038 Origin                                               Destination AI-30A <42>                                          D1 <35A>
Raceway Description                                  Associated Equipment T                                                    DG-1 <35A>
Project             Numeric Part Cable Use NONE                   9578       DAMPERS YCV-871G&H CONTROL Routing:    7-1(ClB)<41>                 66(C1)<41>                   20(C1)<41>
38S(C1)<36A>                 37S(C2)<36A>                 36S(C3)<36A>
34S-2(C3)<36A>               34S-1 (C3)<36A>              34S(C3)<36A>
32S(C1 )<36A>                32S-1 (C2)<35A>              32S-2(C)<35A>
Cable                       Status   App R     Safety    Function  System    Qty  Length W Number EC9601                    AC          Y         EC          C       DG       1     290     W040 Origin                                               Destination Al-133A <35A>                                        AI-26 <42>
Raceway Description                                IAssociated Equipment T                                                    DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9601       DSL BKR 1AD1-RLY&METERING CT-S Routing:    32S(C1)<36A>                 34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>                36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                  20(Cl)<41>                   18(Cl)<41>
14(Cl)<41>                   12(Cl)<41>
Cable                       Status   App R     Safety    Function  System    Qty  Length W Number EC9602                     AC          Y         EC          C       DG       1     290     W040 Origin                                               Destination Al-133A <35A>                                       iAI-24 <42>
Raceway Description                                  Associated Equipment T                                                    DG-1 <35A>
Project             Numeric Part Cable Use NONE                   9602       DSL BKR 1AD1-DIFF CT'S Routing:    32S(C1)<36A>                 34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>               36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                 20(CI)<41>                   18(Cl)<41>
14(Cl)<41>                   12(Cl)<41>
Tuesday, May 14, 2013                             54 Cables                             Page 13 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                      Status   App R     Safety    Function  System      Qty   Length W Number EC9603                    AC          Y         EC          C       DG         1     270      W039 Origin                                              Destination Al-133A <35A>                                       CB-22 <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9603       DSL BKR 1ADI-METERING PTS Routing:   32S(C1)<36A>                 34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>               36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                 20(C1)<41>                   18(C1)<41>
16(C1)<41>
Cable                      Status   App R     Safety    Function  System      Qty   Length W Number EC9608                    AC          N         EC          C       DG         1     240      W041 Origin                                              Destination 1A3-20 <36A>                                        AI-30A <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9608       DSL BKR 1AD1-ANNUN Routing:   34S(C3)<36A>                 34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(Cl )<36A>
20(C1)<41>                   66(C1)<41>                   7-1 (Cl B)<41>
Cable                      Status   App R    Safety     Function  System      Qty   Length W Number EC9609                    AC          N         EC         C        DG         1     260      W041 Origin                                              Destination 1A3-20 <36A>                                        CB-24 <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9609      DSL BKR 1ADI-INDICATING LIGHTS (BUS 1A3)
Routing:   34S(C3)<36A>                 34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(C1 )<36A>
20(C1)<41>                   18(C1)<41>                   16(C1)<41>
Tuesday, May 14, 2013                             54 Cables                                Page 14 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                      Status   App R    Safety     Function  System     Qty  Length W Number EC9610                    AC          Y         EC          C       DG        1    265      W040 Origin                                              Destination 1A3-20 <36A>                                        AI-24 <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project           Numeric Part Cable Use EC48271               9610       DSL BKR 1AD1-DIFFER C'TS Routing:   34S(C3)<36A>                 34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(C1)<36A>
20(C1)<41>                   18(C1)<41>                   14(C1)<41>
12(C1)<41>
Cable                      Status   App R    Safety     Function  System    Qty   Length. W Number EC9611                    AC          Y         EC          C       DG        1    240      W038 Origin                                              Destination 1A3-20 <36A>                                        AI-30A <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project           Numeric Part Cable Use ECN-96-054            9611       DSL BKR 1AD1-BKR CONTROL Routing:   34S(C3)<36A>                 34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(C1 )<36A>
20(C1)<41>                   66(C1)<41>                   7-1(C1B)<41>
Cable                      Status   App R     Safety    Function  System    Qty   Length W Number EC9614                    AC          Y         EC          C       DG        1    265      W042 Origin                                              Destination AI-30A <42>                                          AI-133A <35A>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project           Numeric Part Cable Use ECN-96-054            9614       DIESEL BKR 1AD1-CONTROL Routing:   7-1(ClB)<41>                 66(C1)<41>                   20(C1)<41>
38S(C1)<36A>                 37S(C2)<36A>                 36S(C3)<36A>
34S-2(C3)<36A>               34S-1 (C3)<36A>              34S(C3)<36A>
32S(C1)<36A>
Tuesday, Mav 14,.2013                             54 Cables                              Page 15 of[18

FCS Cable Route Reportfor 34S-1(C3)
Cable                      Status   App R    Safety     Function  System     Qty  Length W Number EC9616                    AC          N         EC          C       DG        1     260     W038 Origin                                              Destination 1A3-20 <36A>                                        CB-21 <42>
Raceway Description                                 Associated Equipment T                                                    DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9616      DIESEL BKR lAD1 - BKR TRIP ALARM Routing:   34S(C3)<36A>                 34S-1(C3)<36A>               34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(C1 )<36A>
20(C1)<41>                   18(C1)<41>                   16(C1)<41>
Cable                      Status   App R    Safety     Function  System     Qty  Length W Number EC9617                    AC          N         EC          C       DG        1     240     W038 Origin                                              Destination 1A3-20 <36A>                                        AI-30A <42>
Raceway Description                                 Associated Equipment T                                                   DG-1 <35A>
Project            Numeric Part Cable Use NONE                  9617      DIESEL BKR lAD1 J/V BACKUP TRIP Routing:   34S(C3)<36A>                 34S-1 (C3)<36A>              34S-2(C3)<36A>
36S(C3)<36A>                 37S(C2)<36A>                 38S(C1 )<36A>
20(C1)<41>                   66(C1)<41>                   7-1(C1B)<41>
Cable                       Status   App R    Safety     Function  System     Qty  Length W Number EC9620                    AC          Y         EC          C       DG        1     270     W038 Origin                                               Destination Al-133A <35A>                                        CB-22 <42>
Raceway Description                                  Associated Equipment T                                                    DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9620      DIESEL 1 RELAYING PTS Routing:    32S(C1)<36A>                 34S(C3)<36A>                 34S-1 (C3)<36A>
34S-2(C3)<36A>               36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                 20(C1)<41>                   18(C1)<41>
16(C1)<41>
Tuesday, May 14, 2013                             54 Cables                              Page 16 of'18

FCS Cable Route Report for 34S-1(C3)
Cable                         Status   App R    Safety     Function  System     Qty  Length W Number EC9693                      AC           N        EC           C       DG        1      270    W038 Origin                                                 Destination ATA-D1 <35A>                                           AI-30A <42>
Raceway Description                                    Associated Equipment I"C,T                                                  DG-1 <35A>
Project             Numeric Part Cable Use NONE                     9693       DIESEL 1 DISPLAY LTS Routing:    32S(C1)<36A>                   34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                 37S(C2)<36A>
38S(C2)<36A>                   20(C1)<41>                   66(C1)<41>
7-1 (Cl B)<41>
Cable                         Status   App R    Safety     Function  System     Qty  Length W Number EC9693A                     AC           N        EC           C       DG        1    - 275    W038 Origin                                                  Destination ATD-D1 <35A>                                           AI-30A <42>
Raceway Description                                    Associated Equipment 1"C,T                                                  DG-1 <35A>
Project            Numeric Part Cable Use NONE                     9693       DIESEL 1 DISPLAY LTS Routing:    32S(C1)<36A>                   34S(C3)<36A>                 34S-1 (C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                   20(C1)<41>                   66(C1)<41>
7-1(C1B)<41>
Cable                         Status   App R    Safety     Function  System     Qty  Length W Number EC9693B                    AC           N        EC           C       DG        1      275     W038 Origin                                                IDestination ATD-D1 <35A>                                           AI-30A <42>
Raceway Description                                   Associated Equipment 1"C,T                                                j DG-1 <35A>
Project            Numeric Part Cable Use NONE                    9693       DIESEL 1 ANN 125V D-C )FER SW OFF NORM Routing:   32S(C1)<36A>                   34S(C3)<36A>                 34S-1(C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                 37S(C2)<36A>
38S(C1)<36A>                   20(C1)<41>                   66(C1)<41>
7-1 (CB)<41>
Tuesday. May 14,2013                               54 Cables                                Page 17 of 18

FCS Cable Route Reportfor 34S-1(C3)
Cable                         Status   App R     Safety       Function  System    Qty  Length W Number EC9696                       AC          N         EC            C        DG       1     125     W038 Origin                                                  Destination AI-30A <42>                                             RB-D1 <>
Raceway Description                                    Associated Equipment T,3/4"C                                               -YCV-871E      <>
Project            Numeric Part Cable Use NONE                    9696       DSL RDTR E)-I DMPR YCV-871E-INDICATION Routing:   7-1 (Cl B)<41>                 66(C1)<41>                     20(C1)<41>
38S(C1)<36A>                   37S(C2)<36A>                    36S(C3)<36A>
34S-2(C3)<36A>                 34S-1 (C3)<36A>                 34S(C3)<36A>
32S(C1 )<36A>                  32S-1 (C2)<35A>
Cable                         Status  App R     Safety       Function  System    Qty  Length W Number EC11964                     AC          N         EC            C        VA       1    400      W048 Origin                                                   Destination Al-133A <35A>                                           AI-30A <42>
Raceway Description                                    Associated Equipment T                                                        <>
Project            Numeric Part Cable Use MR-FC-90-073            11964      ALARM CIRCUIT TEMPERATUJRE HI IN EXCITER Routing:    32S(C1)<36A>                   34S(C3)<36A>                   34S-1(C3)<36A>
34S-2(C3)<36A>                 36S(C3)<36A>                   37S(C2)<36A>
38S(C1)<36A>                   20(C1)<41>                     66(C1)<41>
7-1 (Cl B)<41 >
Tuesday, May 14, 2013                               54 Cables                                Page 18 of 18

FCS Cable Route Reportfor 34S-1(C3A)
Cable                        Status   App R    Safety     Function  System     Qty  Length W Number A918                        AC          N         A          P4       EE        1     130    W038 Origin                                                Destination 1A3-6 <>                                              1C3A-0 <>
Raceway Description                                   Associated Equipment T,"11C                                                 <>
Project            Numeric Part Cable Use
-NONE                     918       SHUNT TRIP DEVICE (SIGMA-2 PWR)
Routing:    34S-1(C3A)<36A>               34S-2(C3A)<36A>              36S(C3A)<36A>
Cable                        Status   App R    Safety     Function  System     Qty  Length W Number A1303                       AC          N         A           C       CW        2            W016 Origin                                                Destination IB-1A <>                                              Ai-120 <31>
Raceway Description                                   Associated Equipment 21/2"C,T,4"C,T                                         <>
Project            Numeric Part Cable Use NONE                    1303       NORM INSTR PWR FOR AI-120(CKT-8)
Routing:    T14(C1A)<46>                  T29(C1)<46>                  35S(C1)<36A>
34S-2(C3A)<36A>               34S-1 (C3A)<36A>             34S(C3A)<36A>
33S(C2B)<36A>                 A45(DUCT)<>                  T46(C1)<31A>
T47(C1 )<31>
Cable                        Status   App R    Safety     Function  System     Qty  Length W Number 1456                        AC          N         N           C       EE        1     290     W038 Origin                                                Destination CAB-SWYD-CONN <36A>                                   JB-107T <>
Raceway Description                                   Associated Equipment T,2"C                                                  <>
Project            Numeric Part Cable Use EC50410                 1456       TRANS 'T1" CLG FAN INTLK Routing:    63S(C1)<36A>                  34S(C3A)<36A>                34S-1 (C3A)<36A>
34S-2(C3A)<36A>               35S(C1 )<36A>                T29(Cl )<46>
T14(C1A)<46>                  T13-1(ClA)<46>               T13(C1A)<46>
Tuesday, May 14, 2013                               31 Cables                               Page I oflO0

FCS Cable Route Report.for 34S-1(C3A)
Cable                       Status    App R     Safety      Function  System    Qty   Length W Number A1460C                    AC            N          A            C       EE        1    300      W036 Origin                                                  Destination JB-107T <>                                              CAB-SWYD-CONN <36A>
Raceway Description                                     Associated Equipment 2 1/2"C,T                                                <>
Project           Numeric Part Cable Use EC50410                1460       GEN PCB 3451-4 CONTROL Routing:   T13(C1A)<46>                  T13-1 (CIA)<46>                T14(C1A)<46>
T29(C1 )<46>                  35S (Cl )<36A>                 34S-2(C3A)<36A>
34S-1 (C3A)<36A>              34S(C3A)<36A>                  63S(C1 )<36A>
Cable                       Status    App R     Safety      Function  System    Qty   Length W Number 2258C                     AC            N          N            C       FP        1    480      W038 Origin                                                  Destination JB-100T <46>                                            JB-1Y <>
Raceway Description                                    Associated Equipment 2"CT4"CT1 1/2"C                                          <>
Project           Numeric Part Cable Use EC5041 0              2258       FIRE PROTECTION FOR T1 Routing:   T13(C1A)<46>                  T13-1(ClA)<46>                 T14(C1A)<46>
T29(C1 )<46>                  35S (Cl)<36A>                  34S-2(C3A)<36A>
34S-1 (C3A)<36A>              34S(C3A)<36A>                  63S(C1 )<36A>
B28(DUCT)<>                   TRENCH(N)<>
Cable                       Status    App R     Safety      Function  System    Qty   Length W Number 2258E                     AB            N          N            C       FP        1     580     W038 Origin                                                  Destination
*TRENCH <>                                             !AIPEI <>
Raceway Description                                    Associated Equipment 4 C, I 1/2C, T,                                          <>
Project           Numeric Part Cable Use EC33033                2258       FIRE PROTEC11ON Routing:   TRENCH(N)<>                   B28(DUCT)<>                    63S(C1)<36A>
34S(C3A)<36A>                 34S-1 (C3A)<36A>               34S-2(C3A)<36A>
35S(C1)<36A>
Tuesday, May 14, 2013                               31 Cables                                Page 2 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number 2259C                     AC           N          N           C       FP        1    465      W038 Origin                                                Destination JB-101T <46>                                          *T1A-1 -THERMOSTATS <>
Raceway Description                                  Associated Equipment 2"CT4"CT1 1/2"C                                        <>
Project            Numeric Part Cable Use EC50410               2259       FIRE PROTECTION Routing:   T13(C1A)<46>                  T13-1 (C1A)<46>               T14(C1A)<46>
T29(C1)<46>                   35S(Cl)<36A>                  34S-2(C3A)<36A>
34S-1 (C3A)<36A>              34S(C3A)<36A>                 63S(C1 )<36A>
B26(DUCT)<>                   TRENCH(N)<>
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number 2259E                     AC           N          N            C      FP        1    565      W038 Origin                                                Destination
 *T1A-1-THERMOSTATS <>                                 FD-SVC1-T1A1 <>
Raceway Description                                   Associated Equipment 11/2"CT4"C3/4"C                                        <>
Project            Numeric Part Cable Use EC50410               2259       FIRE PROTECTION Routing:   TRENCH(N)<>                   B26(DUCT)<>                   63S(C1)<36A>
34S(C3A)<36A>                 34S-1 (C3A)<36A>              34S-2(C3A)<36A>
35S(C1 )<36A>                 T29(C1 )<46>                  T14(C1A)<46>
T13-1(ClA)<46>                T13(C1A)<46>
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number 2259H                     AC           N          N            C      FP        1    520      W038 Origin                                                Destination JB-101T <46>                                          *T1A-3-THERMOSTATS <>
Raceway Description                                   Associated Equipment 2"CT4"CT1 1/2"C                                        <>
Project          I Numeric Part Cable Use EC50410               2259       FIRE PROTECTION (VIA JB #127T)
Routing:   T13(C1A)<46>                  T13-1(ClA)<46>                T14(C1A)<46>
T29(C1 )<46>                  35S(Ci )<36A>                 34S-2(C3A)<36A>
34S-1(C3A)<36A>               34S(C3A)<36A>                 63S(Ci)<36A>
B26(DUCT)<>                   TRENCH(N)<>
Tuesday, Mav 14,.2013                              31 Cables                                Page 3 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                         Status   App R     Safety     Function    System    Qty   Length W Number 2259K                        AC          N          N           C         FP       1     530      W038 Origin                                                  Destination
 *TIA-3-THERMOSTATS <>                                   FD-SVC1-TiA3 <>
Raceway Description                                    Associated Equipment 1 1/2"CT4"CT3/4C                                         <>
Project              Numeric Part Cable Use EC50410                  2259      FIRE PROTECTION (VIA JB #127T)
Routing:    TRENCH(N)<>                    B26(DUCT)<>                     63S(C1)<36A>
34S(C3A)<36A>                  34S-1 (C3A)<36A>                34S-2(C3A)<36A>
35S(C1)<36A>                   T29(C1)<46>                     T14(CiA)<46>
T1 3-1 (Cl A)<46>              T1 3(Ci A)<46>
Cable                         Status   App R     Safety     Function   System     Qty   Length W Number A2264                        AC          N          A           C         EE       1      165     W094 Origin                                                  Destination 1A3-6 <>                                                FT-T1 C-3A,4A <>
Raceway Description                                    Associated Equipment T, 1"C                                                  CS/FT-T1 C-3A,4A <>
Project              Numeric Part Cable Use EC14959                  2264      BUS TIE-STAT1ON LIGHTING (1A3 OR 1A4)
Routing:    34S-1(C3A)<36A>                34S-2(C3A)<36A>                 36S(C3A)<36A>
CNDI(A)<>
Cable                         Status   App R     Safety     Function   System     Qty   Length W Number 2879                          AB          N          N           C         EE       1     225      W038 Origin                                                   Destination JB-107T <>                                               1A1-7 <>
Raceway Description                                    Associated Equipment 2"C,T                                                     <>
Project              Numeric Part Cable Use EC50410                  2879      DISC/TAPED AND ABANDONED IN PLACE Routing:    T13(CIA)<46>                   T13-1(ClA)<46>                  T14(CIA)<46>
T29(CI )<46>                   35S (Ci)<36A>                   34S-2(C3A)<36A>
34S-1 (C3A)<36A>
Tuesday, May 14, 2013                                31 Cables                                  Page 4 of lO

FCS Cable Route Report for 34S-1(C3A)
Cable                       Status   App R      Safety     Function  System     Qty  Length W Number 2885                       AC          N           N           C       EE        1     285     W033 Origin                                                 Destination EE-17 <>                                               CAB-SWYD-CONN <36A>
Raceway Description                                    Associated Equipment 2"C,T                                                   <>
Project            Numeric Part Cable Use EC50410                2885       GEN PCB 3451-4&5 INTLK W/ VS-PER-HERTZ Routing:    T13(CIA)<46>                 TI 3-1 (CIA)<46>               T14(CIA)<46>
T29(C1 )<46>                  35S(C1 )<36A>                  34S-2(C3A)<36A>
34S-1 (C3A)<36A>             34S(C3A)<36A>                  63S(CI )<36A>
Cable                       Status   App R      Safety     Function  System     Qty  Length W Number A5401C                     AC          N           A           C       FW        1     320     W042 Origin                                                 Destination AI-285A <46>                                           1A1-2 <>
Raceway Description                                    Associated Equipment 3 1/2"C,T                                              FW-4A <>
Project            Numeric Part Cable Use EC26252                5401       CONTROL & INTERLOCK SGFD PMP FW-4A Routing:   T18(C1A)<46>                  T1 7(C1 A)<46>                 T3(C1A)<46>
T16(C1A)<46>                  T1 5(C1 A)<46>                 T29(C1)<46>
35S(C1 )<36A>                 34S-2(C3A)<36A>                34S-1 (C3A)<36A>
Cable                       Status   App R      Safety     Function  System     Qty  Length W Number A5411                      AC          N          A           C        FW        1     385     W038 Origin                                                 Destination WA1-1 <>                                              JB-11T <>
Raceway Description                                   Associated Equipment T,1 1/2"C                                              FCV-1216A <>
Project            Numeric Part Cable Use NONE                   5411      CONT RECIR CONT VALVE FCV-1216A Routing:    34S-1 (C3A)<36A>             34S-2(C3A)<36A>                35S(C1)<36A>
T29(C1)<46>                   T14(C1A)<46>                   T15(C1A)<46>
T16(C1A)<46>                  T3(CIA)<46>                    T17(CIA)<46>
T19(C1A)<46>                 T33(C1)<46>
Tuesday, May 14,2013                               31 Cables                                Page 5 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                        Status  App R    Safety    Function  System     ty   Length W Number 5517                        AC         N        N           C       FW       1     385      W042 Origin                                               Destination WA1-1 <>                                          FW-5A-M <>
Raceway Description                                 Associated Equipment T, I"C,F                                             FW-5A <>
Project           Numeric Part Cable Use NONE                   5517       MOTOR HEATER CIRCUIT Routing:   34S-1(C3A)<36A>              34S-2(C3A)<36A>             35S(C1)<36A>
T29(C1)<46>                  T15(C1A)<46>                T16(C1A)<46>
T3(C1A)<46>                  T17(C1A)<46>                T19(C1A)<46>
Cable                        Status  App R    Safety    Function  System    Qty   Length W Number 5541                        AC         N         N          C      FW-CD     1     195      W038 Origin                                               Destination WA1-3 <>                                           FW-2A-M <>
Raceway Description                                Associated Equipment T,1"C,F                                              FW-2A <>
Project           Numeric Part Cable Use EC43208               5541       MOTOR HEATER CIRCUIT Routing:   34S-1(C3A)<36A>              34S-2(C3A)<36A>             35S(C1)<36A>
T29(C1)<46>                  T14(C1A)<46>
I Cable                        Status  App R    Safety    Function  System    Qty   Length W Number A5562                       *R         N        A           C       FW       1     415      W034 Origin                                               Destination 1A1-2 <>                                           *CT-TERM-BOX-AT-FW-4A <>
Raceway Description                                Associated Equipment T,1 1/2"C,F                                          FW-4A-M <>
Project           Numeric Part Cable Use EC43224                5562       STM GEN FDW PMP FW-4A CT LEADS FOR DIFF Routing:   34S-1(C3A)<36A>              34S-2(C3A)<36A>             35S(C1)<36A>
T29(C1)<46>                  T15(CIA)<46>                T16(CIA)<46>
T3(C1A)<46>                  T17(C1A)<46>                T19(C1A)<46>
T33(C1 )<46>
Tuesdav, Mav 14,2013                             31 Cables                               Page 6 of 10

FCS Cable Route Report for 34S-1(C3A)
Cable                       Status  App R      Safety     Function System     Qty  Length W Number 5571                      *R          N          N          C       FW        1    320      W038 Origin                                                Destination WA1-2 <>                                            FW-4A-M <>
Raceway Description                                 Associated Equipment T, 1"C, F                                             FW-4A <>
Project           Numeric Part Cable Use EC43224               5571      MOTOR HEATER CIRCUIT Routing:   34S-1(C3A)<36A>              34S-2(C3A)<36A>              35S(C1)<36A>
T29(Cl)<46>                  T1 5(CI A)<46>               T16(C1A)<46>
T3(C1A)<46>                  T17(C1A)<46>                 T18(C1A)<46>
Cable                      Status  App R      Safety     Function System     Qty  Length W Number A6056                     AB          N          A          C       FW        1    170      W038 Origin                                               Destination 1A1-2 <>                                             CB-10 <42>
Raceway Description                                 Associated Equipment T                                                    FW-4A <>
Project            Numeric Part Cable Use NONE                  6056      DISCONNECT & TAPE BOTH ENDS Routing:   34S-1(C3A)<36A>              34S-2(C3A)<36A>              36S(C3A)<36A>
37S(C2A)<36A>                38S(C1A)<36A>                20(C1 A)<41>
18(C1 B)<41>
Cable                       Status  App R      Safety     Function System     Qty  Length W Number A6805                      *R          N          A          C       LO        1    220      W040 Origin                                                Destination MCC-3A4-B01 <>                                       1A1-2 <>
Raceway Description                                 Associated Equipment 21/2"C,T                                              FW-4A <>
Project           Numeric Part Cable Use EC43224               6805      CONT & INTERLOCK STEAM GEN FD PMP FW-4A Routing:   T3(C1A)<46>                  T16(C1A)<46>                 T15(C1A)<46>
T29(C1 )<46>                 35S(Cl )<36A>                34S-2(C3A)<36A>
34S-1 (C3A)<36A>
Tuesdav, Mav 14, 2013                             31 Cables                               Page 7 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                        Status   App R     Safety    Function   System    Qty   Length W Number 9624                       AC           N         N           C        DG        1    270      W040 Origin                                                 Destination VA-52A-MS <>                                          AI-30A <42>
Raceway Description                                   Associated Equipment 1"C,T                                                  DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9624       EXHAUST FAN VA-52A-INDIC LTS Routing:   32S(C1A)<36A>                  34S(C3A)<36A>                 34S-1(C3A)<36A>
34S-2(C3A)<36A>                36S(C3A)<36A>                 37S(C2A)<36A>
38S(C1A)<36A>                  20(CLA)<41>                   66(C1 B)<41>
7-1 (Cl)<41>
Cable                        Status   App R     Safety    Function   System    Qty   Length W Number A9823                      AC           N         A           C        FP        1    290      W038 Origin                                                 Destination AI-54B <42>                                           Ai-146 <>
Raceway Description                                   Associated Equipment T,1"C                                                VA-52A <>
Project            Numeric Part Cable Use MR-FC-90-017           9823       FAN VA-52A INTERLOCK Routing:   39(C1)<41>                     38(C1)<41>                    28(C1A)<41>
14(C1 B)<41>                   18(C1 B)<41>                  20(C1A)<41>
38S(CIA)<36A>                  37S(C2A)<36A>                 36S(C3A)<36A>
34S-2(C3A)<36A>                34S-1 (C3A)<36A>              34S(C3A)<36A>
32S(CIA)<36A>
Cable                        Status   App R     Safety    Function   System    Qty   Length W Number A11184                     AB           N         A           C        EE        1             W038 Origin                                                 Destination Al-109A <36A>                                         34S-1 (C3A) <>
Raceway Description                                   Associated Equipment 2"C                                                    <>
Project            Numeric Part Cable Use MR-FC-90-002           11184      DISCONNECTED TAPED & ABANDONED IN TRAY Routing:   34S-l(C3A)<36A>
31  Cables                                Page 8oflO Tuesday, May 14, Tuesday, May     2013 14, 2013                              31 Cables                                 Page 8 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                         Status  App R     Safety    Function  System     Qty  Length W Number Al1188                      AC          N          A    I     C       VA        1             W038 Origin                                                 Destination Al-109A <36A>                                         VA-52A-MS <>
Raceway Description                                  Associated Equipment 2"C,1"C                                                <>
Project            Numeric Part Cable Use NONE                   11188      LOAD SHED ON OPLS & SIAS Routing:    34S-1(C3A)<36A>              34S(C3A)<36A>                32S(C1A)<36A>
Cable                        Status  App R     Safety    Function  System     Qty  Length W Number A11815                      AC          N          A          C     VA-AUX      1     340     W038 Origin                                                 Destination AI-187 <46>                                           JB-191A <>
Raceway Description                                  Associated Equipment 1-1/2"C,T,1-1/2                                       <>
Project            Numeric Part Cable Use DCN10106               11815      COMPRESSOR VA-89 ANNUNCIATION Routing:    CND1(A)<>                    T1 5(Ci A)<46>               T29(C1)<46>
35S(C1 )<36A>                34S-2(C3A)<36A>              34S-1 (C3A)<36A>
34S(C3A)<36A>                32S(C1A)<36A>                SLEEV35(A)<>
CND2(A)<>
Cable                         Status  App R     Safety    Function  System     Qty  Length W Number A11816                      AC          N          A          C     VA-AUX      1     340     W041 Origin                                                 Destination Al-187 <46>                                           JB-191A <>
Raceway Description                                  Associated Equipment 1-1/2"C,T,1-1/2                                       <>
Project            Numeric Part Cable Use DCN10106               11816      COMPRESSOR VA-89 CONTROL Routing:    CNDI(A)<>                    T15(C1A)<46>                 T29(Cl)<46>
35S(C1 )<36A>                34S-2(C3A)<36A>              34S-i (C3A)<36A>
34S(C3A)<36A>                32S(C1A)<36A>                SLEEV35(A)<>
CND2(A)<>
Tuesday, May 14, 2013                              31 Cables                               Page 9 of 10

FCS Cable Route Reportfor 34S-1(C3A)
Cable                        Status   App R     Safety     Function  System    Qty  Length W Number 11839                     AC           N          N           C     VA-AUX     1     195     W041 Origin                                                 Destination JB-602A <>                                             Ai-187 <46>
Raceway Description                                   Associated Equipment Project            Numeric Part Cable Use NONE                  11839       CONT & IND Routing:   34S-1(C3A)<36A>               34S-2(C3A)<36A>               35S(C1)<36A>
T29(C1)<46>                   T15(C1A)<46>
Cable                       Status   App R     Safety     Function  System    Qty  Length W Number 11840                     AC           N          N           C     VA-AUX 1   1    235      W041 Origin                                                Destination JB-603A <>                                             Ai-187 <46>
Raceway Description                                   Associated Equipment Project            Numeric Part Cable Use NONE                  11840       CONT & IND Routing:   34S-1(C3A)<36A>               34S-2(C3A)<36A>               35S(Ci)<36A>
T29(C1)<46>                   T1 5(Ci A)<46>
Cable                        Status   App R     Safety     Function  System    Qty  Length W Number 11844                     AC           N          N           C     VA-AUX     1    200      W041 Origin                                                 Destination JB-607A <>                                             Al-187 <46>
Raceway Description                                   Associated Equipment Project             Numeric Part Cable Use NONE                   11844      CONT & IND Routing:    34S-1(C3A)<36A>               34S-2(C3A)<36A>               35S(C1)<36A>
T29(Cl)<46>                   T15(CiA)<46>
Cable                        Status   App R     Safety     Function  System    Qty  Length W Number A12121                     RE           N          A           C      FW-CD     1     195     W034 Origin                                                 Destination WA1-3 <>                                             JB-356T <>
Raceway Description                                    Associated Equipment T, iC, F                                               FW-2A-M <>
Project            Numeric Part Cable Use EC43208                12121      CT LEADS FOR DIFF Routing:   34S-1(C3A)<36A>               34S-2(C3A)<36A>               35S(C1)<36A>
T29(C1)<46>                   T14(C1A)<46>                  T25(C1)<46>
Tuesday, Mav 14, 2013                              31 Cables                              Page 10 oflO0

FCS Cable Route Reportfor 34S-1(C3A *)
Cable                       Status  App R     Safety     Function System     Qty  Length W Number A9828                     AB          N         A           C       FP        1            W038 Origin                                               Destination CB-20 <>                                             FC-4150 <>
Raceway Description                                 Associated Equipment T,3/4"C                                               <>
Project            Numeric Part Cable Use NONE                   9828      ABANDONED INPLACE Routing:    12(C1A)<41>                 14(CI B)<41 >                18(C1 B*)<>
20(C1A*)<>                  38S(CIA*)<>                  37S(C2A*)<>
36S(C3A*)<>                 34S-2(C3A*)<>                34S-1 (C3A*)<>
34S(C3A*)<>
Tuesdav, Mav 14, 2013                             I Cables                               Page I of I

FCS Cable Route Report.for 34S-1(C4)
Cable                      Status   App R     Safety    Function   System    Qty   Length W Number A1601                      AC           N        A           C        EE       1      195     W040 Origin                                               Destination 1A1-7 <>                                            AI-23 <>
Raceway Description                                 FAssociated Equipment T                                                   1<>
Project           Numeric Part Cable Use NONE                  1601      CT'S 51/1A1l & TRANSF T1A-1 DIFF PROTECT Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>                   14(C5)<41>                   12(C5)<41>
Cable                      Status   App R     Safety    Function   System    Qty   Length W Number A1602                     AC           N        A           C        EE       1      190     W042 Origin                                               Destination 1A1-7 <>                                             CB-23 <42>
Raceway Description                                 Associated Equipment T                                                    <>
Project            Numeric Part Cable Use NONE                  1602      BREAKER WAl      CONTROL Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                      Status   App R     Safety    Function   System    Qty   Length W Number A1603                      AC           N        A           C        EE       1     205      W041 Origin                                               Destination 1A1-7 <>                                            AI-23 <>
Raceway Description                                 Associated Equipment T
Project            Numeric Part Cable Use NONE                  1603       BREAKER WAll ALARM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S (C2A)<36A>               20(C4A)<41>
18(C5A)<41>                   14(C5)<41>                   12(C5)<41>
Tuesday, May 14, 2013                             86 Cables                                Page I of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status    App R     Safety    Function  System    Qty   Length W Number A1607                      AC            N        A            C      EE       1     205      W038 Origin                                                Destination 1A1-7 <>                                              AI-23 <>
Raceway Description                                   Associated Equipment T                                                      <>
Project             Numeric Part Cable Use NONE                   1607      TRANSF T1A-1 GND ALARM Routing:    34S-1(C4)<36A>                 34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                  38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                    14(C5)<41>                  12(C5)<41>
Cable                       Status    App R     Safety    Function  System    Qty   Length W Number A1608                      AC           Y          A           C      EE       1     210      W040 Origin                                                Destination 1A3-3 <36A>                                          AI-26 <42>
Raceway Description                                  Associated Equipment T                                                      <>
Project            Numeric Part Cable Use NONE                  1608       CT 51/1A13 & TRANSF T1A-1 DIFF PROTECT Routing:   34S-1(C4)<36A>                 34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                  38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                    14(C5)<41>                  12(C5)<41>
Cable                       Status    App R     Safety    Function  System    Qty   Length W Number A1609                      AC            Y         A           C      EE       1     205      W042 Origin                                                 Destination 1A3-3 <36A>                                          CB-23 <42>
Raceway Description                                   Associated Equipment T                                                      <>
Project            Numeric Part Cable Use ECN-96-054             1609       BREAKER 1A13 CONTROL Routing:   34S-1(C4)<36A>                 34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                  38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                    16(C5A)<41>
Tuesday, May 14, 2013                              86 Cables                               Page 2 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status   App R     Safety    Function  System    Qty   Length W Number A1610                      AC           N        A           C       EE       1     205      W041 Origin                                              Destination 1A3-3 <36A>                                         CB-23 <42>
Raceway Description                                 Associated Equipment T                                                    <>
Project            Numeric Part Cable Use NONE                  1610       BREAKER 1A13 ALARM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                      Status   App R     Safety    Function  System    Qty   Length W Number A1615                     AC           N         A          C       EE       1     205      W040 Origin                                              Destination 1A1-9 <>                                            AI-23 <>
Raceway Description                                 Associated Equipment T                                                    <>
Project            Numeric Part Cable Use NONE                  1615       CT51/1A31 37-1/1A31 TRANSF.T1A-3 DIFF Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   14(C5)<41>                  12(C5)<41>
Cable                      Status   App R     Safety    Function  System    Qty   Length W Number A1616                      AC           N         A          C       EE       1     200      W042 Origin                                              Destination WA1-9 <>                                           CB-23 <42>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1616       BREAKER 1A31 CONTROL Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Tuesdav, Mav 14, 2013                             86 Cables                               Page 3 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                        Status   App R    Safety     Function  System     Qty   Length W Number A1617                       AC          N        A            C        EE       1     200      W040 Origin                                                Destination 1AW-9 <>                                              CB-23 <42>
Raceway Description                                   Associated Equipment T                                                     <>
Project              Numeric Part Cable Use NONE                    1617       BREAKER 1A31 ALARM Routing:     34S-1(C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                 20(C4A)<41>
18(C5A)<41>                  16(C5A)<41>
Cable                        Status   App R    Safety     Function   System    Qty   Length W Number A1621                       AC          N        A            C        EE       1     205      W038 Origin                                                Destination 1A3-2 <>                                              AI-23 <>
Raceway Description                                   Associated Equipment T                                                      <>
Project              Numeric Part Cable Use NONE                    1621      TRANSF TIA-3 GND ALARM Routing:     34S-1(C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>                    12(C5)<41>
Cable                        Status   App R    Safety     Function  System     Qty   Length W Number A1622                       AC          Y        A            C        EE       1     205      W040 Origin                                                Destination 1A3-1 <36A>                                           AI-26 <42>
Raceway Description                                   Associated Equipment T                                                    1<>
Project              Numeric Part Cable Use NONE                    1622      CTS 51/1A33 37-1/1A33 TRANSF T1A-3 DIFF Routing:     34S-1(C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>                    12(C5)<41>
Tuesday, Afay 14, 2013                            86 Cables                                 Page 4 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status  App R     Safety    Function  System    Qty   Length W Number A1623                     AC           Y         A          C       EE       1     200      W042 Origin                                               Destination 1A3-1 <36A>                                         CB-22 <42>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use ECN-96-054            1623      BREAKER 1A33 CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41 >                 16(C5A)<41 >
Cable                      Status  App R     Safety    Function  System    Qty   Length W Number A1624                     AC           N         A          C       EE       1     200      W041 Origin                                              Destination 1A3-1 <36A>                                         CB-22 <42>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use NONE                  1624      BREAKER 1A33 ALARM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)< 36A>              20(C4A)<41 >
18(C5A)<41>                  16(C5A)<41>
Cable                       Status  App R     Safety    Function  System    Qty   Length W Number A1628                     AC           N         A          C       EE       1     220      W040 Origin                                               Destination 1A3-4 <>                                            CB-20 <>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use MR-FC-91-008           1628      OPLS / TEST SWITCH ANNUNCIATION Routing:   34S-1(C4)<36A>               36S(C4A)<36A>               37S(C3A)<36A>
38S(C2A)<36A>                20(C4A)<41 >                18(C5A)<41>
14(C5)<41>                   12(C5)<41>
Tuesday, May 14,2013                             86 Cables                               Page 5 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status    App R    Safety    Function  System    Qty   Length W Number A1659                      AC           N         A          C       EE       1     210      W040 Origin                                               Destination 1A1-1A3 <36A>                                       AI-23 <>
Raceway Description                                  Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1659       125V DC TO 4160V BUSES 1A1-1A3 OFF NORM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   14(C5)<41>                  12(C5)<41>
Cable                      Status    App R    Safety    Function  System    Qty   Length W Number A1663                      AC           N         A          C       EE       1      235     W040 Origin                                                Destination 1A3-11 <36A>                                        CB-24 <42>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1663       AMMETER LEADS FOR TRANSF T1 B-3A FEEDER Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                       Status    App R    Safety    Function  System    Qty   Length W Number A1664                      AC           Y         A          C       EE       1      235     W041 Origin                                                Destination 1A3-11 <36A>                                        CB-23 <42>
Raceway Description                                 1Associated Equipment T                                                     <>
Project            Numeric Part Cable Use ECN-96-054             1664       BKR T1B-3A CONTROL Routing:    34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Tuesday, May 14, 2013                             86 Cables                               Page 6 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status   App R     Safety     Function   System    Qty   Length W Number A1665                    AC           N         A           C         EE       1     235      W040 Origin                                              Destination 1A3-11 <36A>                                        CB-23 <42>
Raceway Description                                 Associated Equipment T                                                     <>
Project           Numeric Part Cable Use NONE                  1665       BKR T1B-3A ALARM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                  20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                      Status   App R     Safety     Function   System    Qty   Length W Number A1666                    AC           Y         A           C         EE       1      145      W Origin                                              Destination 1A3-11 <36A>                                         1B3A-0 <36A>
Raceway Description                                 Associated Equipment T                                                     <>
Project           Numeric Part Cable Use ECN-96-054            1666       BKR 1B-3A INTERLOCKS Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
Cable                      Status   App R     Safety     Function   System    Qty   Length W Number A1666A                    AC           Y         A           C         EE       1      135     W040 Origin                                              Destination 1A3-11 <36A>                                         1B3A-BT-1 B3A <36A>
Raceway Description                                 Associated Equipment T                                                     <>
Project           Numeric Part Cable Use ECN-96-054            1666       BKR BT-1B3A CLOSE & TRIP INTERLOCKS Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
Cable                      Status   App R     Safety     Function   System    Qty   Length W Number A1668                     AC           N         A           C         EE       1     235      W040 Origin                                              Destination 1A3-12 <36A>                                        CB-24 <42>
Raceway Description                                 Associated Equipment T                                                     <>
Project           Numeric Part Cable Use NONE                  1668      AMMETER LEADS FOR TRANSF T1B-3B FEEDER Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
37S(C3A)<36A>                38S (C2A)< 36A>                20(C4A)<41 >
18(C5A)<41 >                 16(C5A)<41 >
Tuesday, May 14,2013                              86 Cables                                 Page 7 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status   App R    Safety     Function  System    Qty  Length W Number A1669                      AC          Y         A          C        EE       1     235     W041 Origin                                             IDestination 1A3-12 <36A>                                       CB-23 <42>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use ECN-96-054            1669      BKR T1 B-3B CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>                  16(C5A)<41>
Cable                      Status   App R    Safety     Function  System    Qty  Length W Number A1670                     AC          N         A          C        EE       1     235     W040 Origin                                              Destination 1A3-12 <36A>                                        CB-23 <42>
Raceway Description                                Associated Equipment T                                                   <>
Project            Numeric Part Cable Use NONE                  1670      BKR T1B-3B ALARM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>                  16(C5A)<41>
Cable                      Status   App R    Safety     Function  System    Qty  Length W Number A1671                      AC          Y         A          C        EE       1     120     W040 Origin                                               Destination 1A3-12 <36A>                                        1B3B-0 <36A>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use ECN-96-054            1671      BKR 1B-3B INTERLOCKS Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>
Cable                      Status   App R    Safety     Function  System    Qty  Length W Number A1671A                     AC          N         A          C        EE       1     120     W040 Origin                                              Destination 1A3-12 <36A>                                        1B3B-BT-1B3B <>
Raceway Description                                Associated Equipment T                                                    <>
Project            Numeric Part Cable Use NONE                  1671       BKR BT-1B3B CLOSE & TRIP INTERLOCK Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>
Tuesday, May 14, 2013                            86 Cables                               Page 8 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status  App R      Safety     Function   System    Qty   Length W Number A1672                      AC          N         A           C         EE       1      125     W038 Origin                                                Destination 1A3-12 <36A>                                         1B4B-BT-1 B4B <36B>
Raceway Description                                 Associated Equipment T,"11C                                                 <>
Project            Numeric Part Cable Use EC49548               1672      BKR BT-1 B41B CLOSE INTERLOCK Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
Cable                       Status  App R      Safety     Function   System    Qty   Length W Number A1673                      AC          N         A           C         EE       1      255     W040 Origin                                                Destination 1A3-13 <36A>                                        AI-24 <42>
Raceway Description                                 Associated Equipment T                                                      <>
Project            Numeric Part Cable Use NONE                  1673      AMMETER LEADS FOR TRANSF T1B-3C FEEDER Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                  20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>                     12(C5)<41>
Cable                       Status  App R      Safety     Function   System    Qty   Length W Number A1674                      AC          Y         A           C         EE       1      240     W041 Origin                                                Destination 1A3-13 <36A>                                        CB-23 <42>
Raceway Description                                 Associated Equipment T                                                      <>
Project            Numeric Part Cable Use ECN-96-054            1674      BKR T1 B-3C CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>                 36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                  20(C4A)<41 >
18(C5A)<41 >                 16(C5A)<41 >
Tuesday, May 14, 2013                             86 Cables                                 Page 9 of 28

FCS Cable Route Report.for 34S-1(C4)
Cable                      Status   App R     Safety     Function  System    Qty   Length W Number A1675                      AC           N        A            C       EE       1     240      W040 Origin                                               Destination 1A3-13 <36A>                                         CB-23 <42>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1675       BKR T1B-3C ALARM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                      Status   App R     Safety     Function  System    Qty   Length W Number A1676                     AC          Y         A            C       EE       1      95      W040 Origin                                               Destination 1A3-13 <36A>                                         1B3C-0 <36A>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use ECN-96-054            1676       BKR 1B-3C INTERLOCKS Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>
Cable                      Status   App R     Safety     Function  System    Qty   Length W Number A1676A                     AC          Y         A            C       EE       1      95      W040 Origin                                               Destination 1A3-13 <36A>                                         1B3C-BT-1B3C <36A>
Raceway Description                                 Associated Equipment T                                                      <>
Project            Numeric Part Cable Use ECN-96-054            1676      BKR BT-1B3C CLOSE & TRIP INTERLOCK Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>
Cable                      Status   App R     Safety     Function  System    Qty   Length W Number A1678                      AC           N        A            C       EE       1     230      W040 Origin                                               Destination 1A3-6 <>                                             AI-25 <>
Raceway Description                                 Associated Equipment T                                                    <>
Project            Numeric Part Cable Use NONE                  1678      AMMETER LEADS FOR TRANSF T1C-3A FEEDER Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                   14(C5)<41>                   12(C5)<41>
Tuesday, May 14, 2013                             86 Cables                               Page 10 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status  App R     Safety    Function   System    Qty   Length W Number A1679                     ,AC          N         A          C        EE       1     225      W041 Origin                                              Destination 1A3-6 <>                                            CB-22 <42>
Raceway Description                                Associated. Equipment T                                                   <>
Project           Numeric Part Cable Use NONE                  1679      BKR T1C-3A CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                  16(C5A)<41>
Cable                      Status   App R    Safety    Function   System    Qty   Length W Number A1680                     AC          N         A          C        EE       1     225      W040 Origin                                              Destination 1A3-6 <>                                            CB-22 <42>
Raceway Description                                Associated Equipment T                                                   <>
Project            Numeric Part Cable Use NONE                  1680      BKR T1C-3A ALARM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                  16(C5A)<41>
Cable                      Status  App R     Safety    Function   System    Qty   Length W Number A1683                      AB          N         A          C        EE       1     245      W040 Origin                                              Destination 1A3-15 <>                                           CB-23 <42>
Raceway Description                                Associated Equipment T                                                    <>
Project           Numeric Part Cable Use MR-FC-98-001          1683      ABANDONED INPLACE Routing:   34S(C4)<36A>                 34S-1(C4)<36A>               34S-2(C4)<36A>
36S(C4A)<36A>                37S(C3A)<36A>                38S(C2A)<36A>
20(C4A)<41>                  18(C5A)<41>                  16(C5A)<41>
Tuesday, May 14, 2013                            86 Cables                               Page I1Iof 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status  App R     Safety    Function   System    Qty  Length W Number A1684                      &#xfd;AB         N          A          C        EE       1     250      W041 Origin                                                Destination 1A3-15 <>                                           AI-25 <>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use MR-FC-98-001            1684      ABANDONED IN PLACE Routing:   34S(C4)<36A>                 34S-1 (C4)<36A>               34S-2(C4)<36A>
36S(C4A)<36A>                37S(C3A)<36A>                 38S(C2A)<36A>
20(C4A)<41 >                 18(C5A)<41 >                  14(C5)<41 >
12(C5)<41>
Cable                        Status  App R     Safety    Function   System    Qty  Length W Number A1685                       AB         N          A          C        EE       1     250      W041 Origin                                                Destination 1A3-15 <>                                           AI-25 <>
Raceway Description                                 Associated Equipment T                                                     <>
Project            Numeric Part Cable Use MR-FC-98-001            1685      ABANDONED IN PLACE Routing:    34S(C4)<36A>                 34S-1 (C4)<36A>               34S-2(C4)<36A>
36S(C4A)<36A>                37S(C3A)<36A>                 38S(C2A)<36A>
20(C4A)<41>                  18(C5A)<41>                   14(C5)<41>
12(C5)<41>
Cable                        Status  App R     Safety    Function   System    Qty  Length W Number 1697                       AC         N          N          C        EE       1      135     W038 Origin                                                Destination 1A4-9 <36B>                                          1B3B-BT-1B3B <>
Raceway Description                                 Associated Equipment 1"C,T                                          7 Project            Numeric Part Cable Use EC49548                1697      BKR BT-1B3B CLOSE INTERLOCK Routing:   34S-1 (C4)<36A>              34S-2(C4)<36A>                36S(C4A)<36A>
Tuesday, May 14, 2013                             86 Cables                               Page 12 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                        Status   App R    Safety    Function  System    Qty   Length W Number A1710                       AC          N        A           C       EE       1      195     W040 Origin                                                Destination T1A-1 <>                                              CB-22 <42>
Raceway Description                                  Associated Equipment T                                                     <>
Project             Numeric Part Cable Use NONE                    1710       PTS FOR SYNCH VOLTMETER Routing:    34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                        Status   App R    Safety    Function  System    Qty   Length W Number A1711                       AC          N        A           C       EE       1     205      W040 Origin                                                Destination T1A-3 <>                                              CB-22 <42>
Raceway Description                                  Associated Equipment T                                                     <>
Project             Numeric Part Cable Use NONE                    1711       PTS FOR SYNCH VOLTMETER Routing:    34S-1 (C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                  38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   16(C5A)<41>
Cable                        Status   App R    Safety    Function  System    Qty   Length W Number A1712                      AC           N        A           C       EE       1     205      W041 Origin                                                Destination T1A-1 <>                                              CB-23 <42>
Raceway Description                                  Associated Equipment mT                                                    <>
Project             Numeric Part Cable Use NONE                    1712      TRANSF T1A-1 UNDERVOLTAGE 27-1,2/1A1-13 Routing:   34S-1(C4)<36A>                 34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>                   16(C5A)<41>
Tuesday, May 14, 2013                             86 Cables                              Page 13 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status    App R       Safety    Function  System    Qty   Length W Number A1713                      AC             N         A           C       EE       1      215     W041 Origin                                                   Destination T1A-3 <>                                                AI-24 <42>
Raceway Description                                    Associated Equipment T                                                       <>
Project            Numeric Part Cable Use NONE                  1713       TRANSF T1A-3 UNDERVOLTAGE 27-1,2/IAI-13 Routing:   34S-1(C4)<36A>                  34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                   38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                     14(C5)<41>                   12(C5)<41>
Cable                      Status    App R       Safety    Function  System    Qty   Length W Number A1714                      AC             N         A           C       EE        1     190     W040 Origin                                                  Destination 1A1-6 <>                                               CB-22 <42>
Raceway Description                                    Associated Equipment T                                                        <>
Project            Numeric Part Cable Use NONE                  1714       BUS PT'S FOR SYNCH VOLTMETER Routing:   34S-1(C4)<36A>                  34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                   38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                     16(C5A)<41>
Cable                       Status    App R       Safety    Function  System    Qty   Length W Number A1715                      AC             Y         A           C       EE       1     215      W040 Origin                                                   Destination 1A3-4 <>                                               CB-22 <42>
Raceway Description                                    Associated Equipment T                                                        <>
Project            Numeric Padrt  &#xfd;Cable Use NONE                  1715       BUS PT'S FOR SYNCH VOLTMETER Routing:   34S-1(C4)<36A>                  34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                   38S (C2A)< 36A>              20(C4A)<41 >
18(C5A)<41>                     16(C5A)<41>
Tuesday, May 14, 2013                               86 Cables                               Page 14 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status   App R    Safety     Function  System     Qty   Length W Number A1716                     AC           N         A          C         EE       1      195     W041 Origin                                               Destination 1A1-6 <>                                             CB-23 <42>
Raceway Description                                  Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                   1716      BUS WA1  UVOLTAGE 27-1/1A1,27-2/1A1 Routing:    34S-1(C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>                  16(C5A)<41>
Cable                       Status   App R    Safety     Function  System     Qty   Length W Number A1717                     AC           Y         A          C         EE       1     220      W041 Origin                                               Destination 1A3-4 <>                                             CB-24 <42>
Raceway Description                                  Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                   1717       BUS 1A3 UNDERVOLTAGE 27-1/1A3,27-2/1A3 Routing:    34S-1(C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                38S (C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                  16(C5A)<41>
Cable                       Status   App R    Safety     Function   System    Qty   Length W Number A1751A                    AC           N         A          C         EE       1     205      W033 Origin                                               Destination CB-24 <42>                                           1A3-3 <36A>
Raceway Description                                  Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                   1751      CT LEADS GND FAULT LOCATOR BUS 1A3 Routing:    16(C1B)<41>                  18(C1 B)<41>                  20(CLA)<41>
38S(C2A)<36A>                37S(C3A)<36A>                 36S(C4A)<36A>
34S-2(C4)<36A>               34S-1 (C4)<36A>
Tuesday, May 14,2013                             86 Cablesv                               Page 15 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status    App R    Safety     Function  System      Qty  Length W Number A1753A                     AC            N         A          C         EE        1    205      W033 Origin                                                Destination CB-23 <42>                                            1A3-1 <36A>
Raceway Description                                   Associated Equipment T                                                       <>
Project            Numeric Part Cable Use NONE                   1753      CT LEADS GND FAULT LOCATOR BUS 1A3 Routing:    16(C1B)<41>                   18(C1 B)<41>                  20(CI A)<41>
38S(C2A)<36A>                 37S(C3A)<36A>                 36S(C4A)<36A>
34S-2(C4)<36A>                34S-1 (C4)<36A>
Cable                       Status    App R     Safety    Function   System     Qty  Length W Number A1757                      AC            N         A          C         FP        1     175     W042 Origin                                                Destination 1A1-0 <36A>                                           CB-10 <42>
Raceway Description                                   Associated Equipment T                                                     FP-1A <31>
Project            Numeric Part Cable Use NONE                   1757       FIRE PUMP FP-1A (A) CONTROL Routing:   34S-1(C4)<36A>                 34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                  38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>
Cable                       Status    App R    Safety     Function  System      Qty  Length W Number A1758                      AC            N         A          C         FP        1    175      W040 Origin                                                 Destination WA1-0 <36A>                                          CB-10 <42>
Raceway Description                                   Associated Equipment T                                                      FP-1A <31>
Project            Numeric Part Cable Use NONE                   1758      FIRE PUMP FP-1A ALARMS Routing:   34S-1(C4)<36A>                 34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                  38S (C2A)< 36A>               20(C4A)<41 >
18(C5A)<41>
Tuesday, May 14, 2013                               86 Cables                               Page 16 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                       Status   App R    Safety      Function System     Qty  Length W Number A1760                     AC           N         A            C       FP       1     175     W033 Origin                                               Destination WA1-0 <36A>                                         CB-10 <42>
Raceway Description                                  Associated Equipment T                                                    FP-1A <31>
Project            Numeric Part Cable Use NONE                   1760      FIRE PUMP FP-1A CT LEADS Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41>
18(C5A)<41>
Cable                       Status   App R    Safety      Function  System    Qty  Length W Number A1787                     AC           N         A            C       EE       1     242     W041 Origin                                               Destination AI-30A <42>                                          1A3-4 <>
Raceway Description                                  Associated Equipment T                                                    S1-1 <>
Project            Numeric Part Cable Use NONE                   1787      ANN OPLS TRIP CH "A" SEQ S1-1 BUS 1A3 Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C1A)<41>
66(C1B)<41>                   7-1(C1)<41>
Cable                       Status   App R    Safety      Function System     Qty  Length W Number C1789                     AC           N         C            C       EE       1     203     W039 Origin                                               Destination AI-30A <42>                                          1A3-2 <>
Raceway Description                                  Associated Equipment T                                                    $1l-2 <>
Project            Numeric Part Cable Use
-NONE                  1789       SEQ S$1-2 BUS 1A3 VOLTAGE INDIC Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C1A)<41>
66(C1B)<41>                   7-1(C1)<41>
Tuesday, May 14, 2013                             86 Cables                               Page 17 of 28

FCS Cable Route Report.for 34S-1(C4)
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number A1791                     AC           N          A           C       EE        1     210     W038 Origin                                                Destination CB-20 <>                                               WA1-8 <>
Raceway Description                                   Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1791      IANN PRE-TRIP 345KV SYS Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41>
18(C5A)<41>                  14(C5)<41>                    12(C5)<41>
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number A1792                     AC           N          A           C       EE        1     220     W038 Origin                                                Destination CB-20 <>                                              1A3-2 <>
Raceway Description                                   Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                  1792       ANN PRE-TRIP 161 KV SYS Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>                   14(C5)<41>                    12(C5)<41>
Cable                      Status    App R     Safety     Function  System    Qty   Length W Number C1795                     AB           N          C           C       EE       1      195     W038 Origin                                                Destination AI-30A <42>                                           1A3-2 <>
Raceway Description                                   Associated Equipment T                                                     <>
Project            Numeric Part Cable Use MR-FC-79-002          1795       DISC & ABANDONED IN PLACE Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(CIA)<41>
66(C1 B)<41>                  7-1 (Cl)<41>
Tuesdav, Mov 14, 2013                              86 Cables                               Page 18 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status    App R    Safety     Function  System     Qty  Length W Number C1796                     AB           N         C           C       EE        1    205      W038 Origin                                               Destination AI-30A <42>                                            WA1-8 <>
Raceway Description                                  Associated Equipment T                                                     <>
Project           Numeric Part Cable Use MR-FC-79-002          1796       DISC & ABANDONED IN PLACE Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C1 A)<41>
66(C1B)<41>                   7-1(C1)<41>
Cable                      Status    App R    Safety     Function  System     Qty  Length W Number A3549                      AC           N         A           C       RC        1     160     W041 Origin                                               Destination 1A1-5 <36A>                                          CB-10 <42>
Raceway Description                                  Associated Equipment T                                                     RC-3A <>
Project           Numeric Part Cable Use NONE                  3549       METER LEADS (CURRENT) FOR RC-3A Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>
Cable                      Status    App R    Safety     Function  System    Qty   Length W Number A3551                      AC           N         A           C       RC        1     180     W039 Origin                                               Destination 1A1-5 <36A>                                          CB-1 <42>
Raceway Description                                  Associated Equipment T                                                     RC-3A <>
Project           Numeric Part Cable Use NONE                  3551      CONTROL INTERLOCK FOR RC-3A MTR HEATER Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                   15(C5)<41>
Tuesday, May 14,2013                              86 Cables                               Page 19 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status  App R     Safety     Function  System    Qty   Length W Number A3552                      AC          Y         A          C        RC       1      180     W042 Origin                                              Destination 1AW-5 <36A>                                         CB-1 <42>
Raceway Description                                 Associated Equipment T                                                   RC-3A <>
Project           Numeric Part Cable Use ECN-96-054            3552      BREAKER RC-3A CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41 >                 15(C5)<41 >
Cable                      Status  App R     Safety     Function  System    Qty   Length W Number A3553                     AC          N         A          C        RC       1     190      W040 Origin                                              Destination 1A1-5 <36A>                                         CB-I <42>
Raceway Description                                 Associated Equipment T                                                   RC-3A <>
Project            Numeric Part Cable Use NONE                  3553      BKR RC-3A O/L OR TRIP ALM RC-3A-1 ALARM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>                  15(C5)<41>                   9(C5)<41>
Cable                       Status  App R     Safety     Function  System    Qty   Length W Number A3554                      AC          N         A          C        RC       1     180      W039 Origin                                               Destination 1AW-5 <36A>                                         CB-1 <42>
Raceway Description                                 Associated Equipment T                                                    RC-3A <>
Project           Numeric Part Cable Use NONE                  3554      BKR RC-3A CONTROL (LOCKOUT RELAY)
Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>                  15(C5)<41>
TuesdaV, Mav 14. 2013                            86 Cables                               Page 20 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status   App R    Safety     Function  System   Qty   Length W Number C3575                     AC          N         C          C        RC      1      190     W041 Origin                                              Destination 1A3-5 <36A>                                         CB-10 <42>
Raceway Description                                Associated Equipment T                                                   RC-3C <>
Project            Numeric Part Cable Use NONE                  3575       METER LEADS (CURRENT) FOR RC-3C Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>
Cable                      Status   App R    Safety     Function System    Qty   Length W Number C3577                     AC          N         C          C        RC      1     210      W039 Origin                                              Destination 1A3-5 <36A>                                         CB-1 <42>
Raceway Description                                Associated Equipment T                                                   RC-3C <>
Project            Numeric Part Cable Use NONE                  3577      CONTROL INTERLOCK FOR MOTOR HEATER Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                  15(C5)<41>
Cable                      Status   App R    Safety     Function System    Qty   Length W Number C3578                     AC          Y         C          C        RC      1     210      W042 Origin                                              Destination 1A3-5 <36A>                                        CB-1 <42>
Raceway Description                                Associated Equipment T                                                   RC-3C <>
Project            Numeric Part Cable Use ECN-96-054            3578      BREAKER RC-3C CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>                  15(C5)<41>
Tuesday, May 14, 2013                            86 Cables                              Page 21 of28

FCS Cable Route Report.for 34S-1(C4)
Cable                       Status   App R    Safety     Function System    Qty   Length W Number C3579                      AC          N         C          C       RC        1     220     W040 Origin                                               Destination 1A3-5 <36A>                                         CB-1 <42>
Raceway Description                                 Associated Equipment T                                                    RC-3C <>
Project            Numeric Part Cable Use NONE                   3579       BKR RC-3C O/L TRIP ALM RC-3C-1 OIL ALARM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   15(C5)<41>                  9(C5)<41>
Cable                       Status   App R    Safety    Function  System    Qty   Length W Number C3580                      AC          N         C          C       RC        1     210     W039 Origin                                               Destination 1A3-5 <36A>                                         CB-1 <42>
Raceway Description                                 Associated Equipment T                                                   RC-3C <>
Project            Numeric Part Cable Use NONE                   3580       BKR RC-3C CONTROL (LOCKOUT RELAY)
Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                   15(C5)<41>
Cable                       Status   App R    Safety    Function  System    Qty   Length W Number C3582                      AC          N         C          C       RC       1     220      W039 Origin                                              Destination 1A3-5 <36A>                                         AI-21 <42>
Raceway Description                                 Associated Equipment T                                                   RC-3C <>
Project            Numeric Part Cable Use NONE                   3582       BKR RC-3C CONT (BACKUP LOAD SHED)
Routing:   34S-1 (C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>                   14(C5)<41>                  12(C5)<41>
Tuesdav, Mav 14, 2013                             86 Cables                              Page 22 of 28

FCS Cable Route Report for 34S-1(C4)
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5510                     AC          N         A          C       FW       1      195     W042 Origin                                             Destination WA1-1 <>                                          AI-12 <42>
Raceway Description                                Associated Equipment
_T                                                  FW-5A <>
Project            Numeric Part Cable Use NONE                  5510       HEATER DRAIN PUMP FW-5A CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5511                     AC          N         A          C       FW       1      195     W042 Origin                                              Destination 1A1-1 <>                                           AI-12 <42>
Raceway Description                                Associated Equipment T                                                  FW-5A <>
Project            Numeric Part Cable Use NONE                  5511       HEATER DRAIN PUMP 5W-5A CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5512                     AC          N         A          C       FW       1      195     W041 Origin                                             Destination 1A1-1 <>                                           AI-12 <42>
Raceway Description                                Associated Equipment T                                                  FW-5A <>
Project            Numeric Part Cable Use NONE                  5512       HTR DRN PMP 5W-5A STOPPED OR OVLD ALM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>
Tuesday, May 14, 2013                            86 Cables                              Page 23 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                        Status  App R     Safety    Function   System    Qty   Length W Number A5513                      AC           N        A           C        FW       1     215      W033 Origin                                                Destination 1A1-1 <>                                              CB-10 <42>
Raceway Description                                  Associated Equipment T                                                     FW-5A <>
Project             Numeric Part Cable Use NONE                    5513      HTR DRM PUMP FW-5A MOTOR CT LEADS Routing:    34S-1 (C4)<36A>               34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>
Cable                        Status   App R    Safety    Function   System     ty ILength W Number A5534                       AC          N        A           C       FW-CD     _1     190     W042 Origin                                                Destination 1A1-3 <>                                             CB-10 <42>
Raceway Description                                   Associated Equipment T                                                     FW-2A <>
Project            Numeric Part Cable Use NONE                    5534      CONDENSATE PUMP FW-2A CONTROL Routing:    34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41>
18(C5A)<41>
Cable                        Status   App R    Safety    Function   System    Qty   Length W Number A5535                       AC          N        A            C      FW-CD     1      190     W041 Origin                                                Destination 1A1-3 <>                                              CB-10 <42>
Raceway Description                                   Associated Equipment T                                                     FW-2A <>
Project             Numeric Part Cable Use NONE                    5535      CONDENSATE PUMP FW-2A CONTROL Routing:    34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>
Tuesday, May 14, 2013                             86 Cables                               Page 24 of28

FCS Cable Route Reportfor 34S-1(C4)
Cable                        Status  App R     Safety     Function  System     Qty   Length W Number A5536          _AC                      N         A           C      FW-CD      1     190     W041 Origin                                                Destination 1A1-3 <>                                             CB-10 <42>
Raceway Description                                  Associated Equipment T                                                     FW-2A <>
Project           Numeric   Part Cable Use NONE                   5536      COND PMP FW-2A STOPPED OR OVERLOAD ALARM Routing:   34S-1 (C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41 >
Cable                       Status  App R     Safety     Function  System     Qty   Length W Number A5537                      AC           N         A           C      FW-CD      1      190     W033 Origin                                               Destination 1A1-3 <>                                             CB-10 <42>
Raceway Description                                  Associated Equipment T                                                    FW-2A <>
Project           Numeric Part Cable Use NONE                   5537      COND PUMP FW-2A MOTOR CT LEADS Routing:   34S-1 (C4)<36A>               34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41>
18(C5A)<41 >
Cable                       Status  App R     Safety     Function   System    Qty               umber A5558                      AC           N         A           C        FW       1      185     W042 Origin                                               Destination 1A1-2 <>                                             AI-12 <42>
Raceway Description                                 1Associated Equipment T                                                     FW-4A <>
Project           Numeric Part !Cable Use NONE                   5558      STEAM GEN FEEDWATER PMP FW-4A CONTROL Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>                36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                 20(C4A)<41 >
18(C5A)<41>                   14(C5)<41>
Tuesday, May 14,2013                              86 Cables                                Page 25 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5559                     AC          Y         A          C       FW       1      185     W042 Origin                                             Destination WA1-2 <>                                          A1-12 <42>
Raceway Description                                Associated Equipment T                                                  FW-4A <>
Project            Numeric Part Cable Use NONE                  5559       STM GEN FEEDWATER PUMP FW-4A CONTROL Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>                  14(C5)<41>
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5560                     AC          N         A          C       FW       1      185     W041 Origin                                             Destination 1A1-2 <>                                           A1-12 <42>
Raceway Description                                Associated Equipment T                                                  FW-4A <>
Project            Numeric Part Cable Use NONE                  5560       STM GEN FDW PMP FW-4A Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>                  14(C5)<41>
Cable                      Status   App R    Safety    Function  System    Qty   Length W Number A5561                      AC          N         A          C       FW       1     230      W033 Origin                                             Destination WA1-2 <>                                          CB-10 <42>
Raceway Description                                Associated Equipment T                                                  FW-4A <>
Project            Numeric Part Cable Use NONE                  5561      STM GEN FDW PMP FW-4A CT LEADS FOR AMM Routing:   34S-1(C4)<36A>               34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                38S(C2A)<36A>               20(C4A)<41>
18(C5A)<41>
Tuesdav, Mav 14. 2013                            86 Cables                              Page 26 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                      Status    App R    Safety    Function  System    Qty   Length W Number A6618                    AC            N         A          C       CW       1      180     W042 Origin                                              Destination 1A1-4 <>                                            CB-10 <42>
Raceway Description                                 Associated Equipment T                                                   CW-1 A <>
Project           Numeric Part Cable Use
-NONE                  6618       CIRC WATER PUMP CW-1A (A) CONTROL Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>
Cable                      Status    App R    Safety    Function  System    Qty   Length W Number A6619                    AC            N         A          C       CW       1      180     W039 Origin                                               Destination 1A1-4 <>                                            CB-10 <42>
Raceway Description                                 Associated Equipment T                                                   CW-1A <>
Project           Numeric Part Cable Use NONE                  6619       CIRC WTR PUMP "A" STOPPED OR OVLD ALARM Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>
Cable                      Status    App R    Safety    Function  System    Qty   Length W Number A6622                    AC            N         A          C       CW       1      180     W039 Origin                                               Destination 1A1-4 <>                                            CB-10 <42>
Raceway Description                                 Associated Equipment T                                                    FCV-1904A <>
Project           Numeric Part Cable Use NONE                  6622       PISTON OPRD DISCH VLV FCV-1904A POSN IND Routing:   34S-1(C4)<36A>                34S-2(C4)<36A>              36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>               20(C4A)<41 >
18(C5A)<41>
Tuesday, May 14, 2013                             86 Cables                              Page 27 of 28

FCS Cable Route Reportfor 34S-1(C4)
Cable                         Status   App R    Safety     Function  System    Qty   Length W Number A6633                       AC           N        A           C        CW       1      180     W033 Origin                                                 Destination 1A1-4 <>                                               CB-10 <42>
Raceway Description                                   Associated Equipment T                                                      CW-1A <>
Project             Numeric Part Cable Use NONE                     6633      CWP CW-IA MOTOR CT Routing:     34S-1(C4)<36A>                34S-2(C4)<36A>               36S(C4A)<36A>
37S(C3A)<36A>                 38S(C2A)<36A>                20(C4A)<41 >
18(C5A)<41>
Cable                         Status   App R    Safety     Function  System    Qty   Length W Number A11801                      AC           N         A          C      VA-AUX     1     263      W039 Origin                                                 Destination JB-222A <>                                             JB-191A <>
Raceway Description                                    Associated Equipment 1-1/4"C,T,1-1/2                                       TS-6604 <>
Project            Numeric Part Cable Use DCN10106                11801       CONTROL Routing:    CND1(A)<>                     36S(C4A)<36A>                34S-2(C4)<36A>
34S-1 (C4)<36A>               34S(C4)<36A>                 32S(C1A)<36A>
SLEEV35(A)<>                  CND2(A)<>
Tuesday, May 14, 2013                              86 Cables                               Page 28 of 28

FCS Cable Route Reportfor 34S-1(I4)
Cable                       Status   App R     Safety     Function  System    Qty  Length W Number 1Z113                      AC          N          N           I    PC-ERF       1    245    W057 Origin                                                Destination 1A1-4 <>                                             JB-694A <41>
Raceway Description                            --    Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                    113      CIRC WTR PUMP A TRIP (ERF INPUT Y3305)
Routing:   34S-1(14)<36A>                34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                  38S(12)<36A>                 20(13)<41>
18(14)<41>                    14(14A)<41>                  28(14A)<41>
38(14A)<41>                   39(14)<41>                   40(11)<41>
Cable                       Status   App R     Safety     Function System     Qty  Length W Number 1Z118                      AC          N          N           I    PC-ERF       1    305    W057 Origin                                                Destination JB-694A <41>                                          1A3-9 <36A>
Raceway Description                                  Associated Equipment T                                                     <>
Project            Numeric Part Cable Use NONE                    118      RAW WTR PUMP A START ERF INPUT Y3434 Routing:   34S-1 (14)<36A>               34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                  38S(12)<36A>                 20(13)<41 >
18(14)<41>                    16(14)<41>                   13(14)<41>
30(14)<41>                    42(14)<41>                   40(11)<41>
74(12)<41>
Cable                        Status   App R     Safety    Function  System     Qty  Length W Number 1Z120                      AC          N          N           I    PC-ERF      1     310    W057 Origin                                                Destination JB-694A <41>                                           1A3-10 <36A>
Raceway Description                                   Associated Equipment T                                                      <>
Project            Numeric Part Cable Use NONE                     120      RAW WATER PUMP C START ERF INPUT Y3436 Routing:    34S-1 (14)<36A>               34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                  38S(12)<36A>                 20(13)<41>
18(14)<41>                    16(14)<41>                   13(14)<41>
30(14)<41>                    42(14)<41>                   40(11)<41>
74(12)<41>
Tuesdav, Mav 14, 2013                              18 Cables                               Page I of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                        Status   App R      Safety    Function  System      Qty Length W Number 3559                        AC           N         N            I    PC-ERF       1   225     W057 Origin                                                 Destination 1A1-5 <36A>                                           JB-694A <41>
Raceway Description                                    Associated Equipment T                                                      RC-3A <>
Project            Numeric Part Cable Use NONE                   3559       BKR RC-3A TRIP SIG (ERF CMPTR INP RC003A Routing:   34S-1 (14)<36A>                34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                   38S(12)<36A>                 20(13)<41>
18(14)<41>                     14(14A)<41>                  28(14A)<41>
38(14A)<41>                    39(14)<41>                   40(11)<41>
74(12)<41>
Cable                       Status   App R      Safety    Function  System-     Qty Length W Number 3585                       AC           N          N           I    PC-ERF       1    255    W057 Origin                                                 Destination 1A3-5 <36A>                                           JB-694A <41>
Raceway Description                                   Associated Equipment C                                                      RC-3C <>
Project            Numeric Part Cable Use NONE                    3585       BKR RC-3C TRIP SIG (ERF CMPTR INP RC003C Routing:   34S-1 (14)<36A>                34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                   38S(12)<36A>                 20(13)<41>
18(14)<41>                     14(14A)<41>                  28(14A)<41>
38(14A)<41 >                   39(14)<41 >                  40(11 )<41>
74(12)<41>
Cable                        Status   App R      Safety    Function  System      Qty Length W Number 3982                        AC           N         N            I    PC-ERF       1    275    W057 Origin                                                  Destination 1A3-7 <36A>                                           JB-694A <41>
Raceway Description                                   Associated Equipment T                                                       <>
Project            Numeric Part Cable Use NONE                   3982       BKR SI-1A CONTROL (ERF CMPTR INP Y3418)
Routing:   34S-1 (14)<36A>                34S-2(14)<36A>               36S(14)<36A>
37S(13)<36A>                   38S(12)<36A>                 20(13)<41>
18(14)<41>                     14(14A)<41>                  28(14A)<41>
38(*)<>                        39(*)<>                      40(11)<41>
74(12)<41>
Tuesday, May 14,2013                                18 Cables                               Page 2 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                        Status  App R     Safety     Function  System     Qty  Length W Number 5397                       AC          N          N           I     PC-ERF      1     280    W057 Origin                                                Destination 1A3-16 <36A>                                         JB-694A <41>
Raceway Description                                  Associated Equipment T                                                     FW-6 <32>
Project            Numeric Part Cable Use NONE                   5397      BREAKER FW-6 ERF COMPUTER INPUT Y3426 Routing:   34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                 37S(13)<36A>                  38S(12)<36A>
20(13)<41>                   18(14)<41>                    14(14A)<41>
28(14A)<41>                  38(14A)<41>                   39(14)<41>
40(11)<41>                   74(12)<41 >
Cable                        Status  App R     Safety     Function  System     Qty  Length W Number 9583                       AC          N          N           I     PC-ERF      1     365    W063 Origin                                                Destination D1 <35A>                                             JB-692A <41>
Raceway Description                                  Associated Equipment T                                                     DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9583      DIESEL DG-1 LO STD-BY L.O. PR LO IDLE, Routing:   32S-2(I)<35A>                32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                 37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                  18(12)<41>                    16(12)<41>
13(12)<41>                   30(12)<41>                    42(12)<41>
41(11)<41>
Tuesday, May 14, 2013                             18 Cables                                Page 3 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9584                       AC          N          N           I     PC-ERF      1     365    W057 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                   Associated Equipment T                                                     DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9584       DIESEL DG-1 LO LEVEL LO ERF INPUT #Y3343 Routing:   32S-2(I)<35A>                 32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                  34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                  37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                    30(12)<41>                    42(12)<41>
41 (11)<41>
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9592                      AC           N          N           I       DG        1     365    W057 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                   Associated Equipment T                                                     DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9592      DIESEL DG-I ENG WATER TEMP HI-LO ERF Routing:   32S-2(I)<35A>                 32S-1 (12)<35A>               32S(11)<36A>
34S(14)<36A>                  34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                  37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                    30(12)<41>                   42(12)<41>
41(11)<41>
Tuesdav, Mav 14, 2013                              18 Cables                                Page 4 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                        Status  App R     Safety     Function  System     Qty  Length W Number 9593                       AC          N          N           I       DG        1     365    W060 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                  Associated Equipment T                                                     DG-1 <35A>
Project           Numeric Part Cable Use NONE                   9593      DIESEL DG-1 ENG WTR PRSR LO WATER LVL Routing:   32S-2(I)<35A>                32S-1 (12)<35A>               32S(11)<36A>
34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                 37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                  18(12)<41>                    16(12)<41>
13(12)<41>                   30(12)<41>                    42(12)<41>
41(11)<41>
Cable                       Status  App R     Safety     Function  System     Qty  Length W Number 9594                       AB          N          N           I       DG        1     365    W057 Origin                                                Destination D1 <35A>                                             JB-692A <41>
Raceway Description                                  Associated Equipment T                                                     DG-1 <35A>
Project           Numeric Part =Cable Use MR-FC-83-133            9594      DIESEL DG-1 ENG CRKCASE DR HI(DISC&TAPED Routing:   32S-2(I)<35A>                32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                 37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                  18(12)<41>                    16(12)<41>
13(12)<41>                   30(12)<41>                    42(12)<41>
41(11)<41>
Tuesday, May 14, 2013                             18 Cables                                Page 5 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9595                       AC          N          N           I       DG        1     365    W057 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                  Associated Equipment T                                                     DG-1 <35A>
Project             Numeric Part Cable Use NONE                   9595       DIESEL DG-1 FO INLT (FILTER #1) HI Routing:   32S-2(I)<35A>                 32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                 37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                   30(12)<41>                    42(12)<41>
41(11)<41>
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9595A                      AC          N          N           I       DG        1     365    W057 Origin                                                Destination D1 <35A>                                             JB-692A <41>
Raceway Description                                  Associated Equipment T                                                     DG-1 <35A>
Project             Numeric Part Cable Use NONE                   9595       DIESEL DG-1 FQ INLT (FILTER #2) HI Routing:   32S-2(I)<35A>                 32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                 34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                  37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                   30(12)<41>                    42(12)<41>
41(11)<41>
Tuesday, May 14, 2013                             18 Cables                                Page 6 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                       Status    App R     Safety     Function  System     Qty  Length W Number 9596                       AC           N          N           I       DG        1     365    W057 Origin                                                 Destination D1 <35A>                                               JB-692A <41>
Raceway Description                                    Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9596       DIESEL DG-1 ENG RUN (ERF INPUT #Y3368)
Routing:   32S-2(I)<35A>                  32S-1 (12)<35A>               32S(11)<36A>
34S(14)<36A>                   34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                   37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                    18(12)<41>                    16(12)<41>
13(12)<41>                     30(12)<41>                    42(12)<41>
41(11)<41>
Cable                       Status    App R     Safety     Function  System     Qty  Length W Number 9597                       AC           N          N           I       DG        1     365    W057 Origin                                                 Destination D1 <35A>                                               JB-692A <41>
Raceway Description                                    Associated Equipment T                                                      DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9597       DIESEL DG-1 ENG STOP (ERF INPUT #Y3370)
Routing:   34S-2(I)<>                     34S-1(12)<>                   32S(11)<36A>
34S(14)<36A>                   34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                   37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                    18(12)<41>                    16(12)<41>
13(12)<41>                     30(12)<41>                   42(12)<41>
41(11)<41>
Tuesdav, Mav 14, 2013                               18 Cables                                Page 7 of 8

FCS Cable Route Reportfor 34S-1(I4)
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9598                       AC          N          N           I       DG        1     365    W057 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                   Associated Equipment T                                                     DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9598       DIESEL DG-1 ENG STRT FAILURE Routing:   32S-2(I)<35A>                 32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                  34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                  37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                    30(12)<41>                    42(12)<41>
41(11)<41>
Cable                       Status   App R     Safety     Function  System     Qty  Length W Number 9599                       AC          N          N           I       DG        1     365    W060 Origin                                                Destination D1 <35A>                                              JB-692A <41>
Raceway Description                                   Associated Equipment T                                                     DG-1 <35A>
Project            Numeric Part Cable Use NONE                   9599       DIESEL DG-1 ENG OUT OF AUTO Routing:   32S-2(l)<35A>                 32S-1(12)<35A>                32S(11)<36A>
34S(14)<36A>                  34S-1 (14)<36A>               34S-2(14)<36A>
36S(14)<36A>                  37S(13)<36A>                  38S(12)<36A>
20(12A)<41>                   18(12)<41>                    16(12)<41>
13(12)<41>                    30(12)<41>                    42(12)<41>
41(11)<41>
Tuesday, May 14. 2013                              18 Cables                                Page 8 of 8}}