ML081220873

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Response to Request for Additional Information Request for Exemption from 10 CFR 50, Appendix R, Section Iii.G, Fire Protection of Safe Shutdown Capability.
ML081220873
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 05/01/2008
From: Cowan P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD7029, TAC MD7030
Download: ML081220873 (14)
v • d • e


Text

PA 10 CFR 50.12 May 1, 2008 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

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

References:

1. Letter from P. B. Cowan, Exelon Generation Company, LLC, to USNRC~ "Request for Exemption from 10 CFR 50, Appendix R, Section III.G, 'Fire Protection of Safe Shutdown Capability'," dated October 5,2007.
2. Letter from J. D. Hughey, U.S. Nuclear Regulatory Commission, to C. G. Pardee, Exelon Generation Company, LLC, "Peach Bottom Atomic Power Station, Units 2 and 3

- Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Section III.G, 'Fire Protection of Safe Shutdown Capability' (TAC Nos.

MD7029 and MD7030)," dated April 17, 2008.

In Reference 1, Exelon Generation Company, LLC (Exelon) submitted a request for exemption from the provisions of 10 CFR 50, Appendix R, Section III.G, "Fire Protection of Safe Shutdown Capability," for the use of operator manual actions for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, in lieu of the requirements specified in Section III.G.2.

In Reference 2, the NRC requested additional information in order to complete its evaluation of the exemption request. The attachment to this letter provides a restatement of the questions along with Exelon's response.

Response to Request for Additional Information 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Docket Nos. 50-277 and 50-278 May 1, 2008 Page 2 Exelon has determined that the information provided in response to the request for additional information does not impact the conclusions of the original exemption request as stated in Reference 1.

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

Respectfully, Pamela B.

Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information cc: Regional Administrator - NRC Region I w/attachment NRC Senior Resident Inspector - PBAPS NRC Project Manager, NRR - PBAPS S. T. Gray, State of Maryland R. R. Janati, Commonwealth of Pennsylvania

Docket Nos. 50-277 and 50-278 Page 1 of 12 ATTACHMENT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50, APPENDIX R, SECTION III.G.2 EXEMPTION REQUEST In Reference 1, Exelon Generation Company, LLC (Exelon) submitted a request for exemption from the provisions of 10 CFR 50, Appendix R, Section III.G, Fire Protection of Safe Shutdown Capability," for the use of operator manual actions for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, in lieu of the requirements specified in Section III.G.2.

In Reference 2, the NRC requested additional information in order to complete its evaluation of the exemption request. The questions are restated below along with Exelon's response.

RAI-01) Provide a cross-reference for all actions submitted in Attachment 2 of the exemption request with those listed in Table A-4, Revision 3. This cross-reference should include, the fire affected component number, its system, its name, and the fire area it is located in. For the component that is to be operated, include its number, its system, its name, the fire area it is located in, and a brief description of the action required to be taken at the component. Also, include the original approved description of the action, and any differences between the approved action and the submitted action (number, name, system designation, fire area, description of action).

Response

A cross-reference for the actions submitted in Attachment 2 of the exemption request (Reference 1) with those listed in Table A-4, Revision 3, of the PBAPS Fire Protection Program (FPP) is provided in the attached table. The first column of the table contains a cross-reference to the Revision 3 FPP Table A-4 as requested. The cross-reference column contains the component number that is contained in the first column of the Revision 3 FPP Table A-4. Note that there are a number of actions listed in the Revision 3 FPP Table A-4 that are not included in the exemption request. The source of the information used to create Revision 3 FPP Table A-4 considered all actions that were identified as "manual" which included cold shutdown items, repairs, and actions for alternate shutdown areas (such as the control room).

The second column describes the purpose of the action, which explains why the action is to be performed. The third column addresses the fire affected component and system. The fourth column lists the initiating fire area, which could also be called the originating fire area. This is the fire area(s) in which the postulated fire occurs that requires the operator manual action.

The fifth column describes the action to be taken by the operator. In several cases, the action from Revision 3 FPP Table A-4 is divided into separate tasks for clarity. Also, in several cases, an additional task from that listed in the Revision 3 FPP Table A-4 is specified. The additional task is listed when the task is performed in a different room from the main action. This was done to identify the areas in which the manual actions are performed. This is an enhancement to the level of detail provided in Revision 3 FPP Table A-4, and is not a new action that did not previously exist. The sixth column identifies the location(s) where the operator manual actions are performed. The room description, room number and fire area number are provided. The "Notes" column lists the applicable notes for that row. The notes are provided at the end of the table.

Response to Requests for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 2 of 12 Docket Nos. 50-277 and 50-278 RAI-02) Attachment 1,Section II, asserts that the basis for the exemption request per 10 CFR 50.12(a)(2)(ii) is that the referenced manual actions have already been found acceptable by the NRC in a prior SER. Describe the specific special circumstances that justify why application of the regulation does not meet the underlying purpose of the rule. Alternatively, provide other bases for the special circumstances.

Response

The intent of 10 CFR 50, Appendix R, Section III.G.2, is to ensure that one train of systems necessary to achieve and maintain hot shutdown will remain available in the event of a fire. The manual actions discussed in the original exemption request (Reference 1) and the response to RAI-01 provide that assurance. If manual actions are not used to meet the underlying purpose of the rule, modifications to provide additional fire suppression systems, detection systems, or fire barriers would be required to achieve compliance. Such modifications represent an unwarranted burden on Exelon since they are not necessary to meet the underlying purpose of the rule. Therefore, the special circumstances for issuance of the exemption are satisfied in accordance with the requirements of 10 CFR 50.12(a)(2)(ii), since application of the rule is not necessary to achieve the underlying purpose of the rule.

REFERENCES

1. Letter from P. B. Cowan, Exelon Generation Company, LLC, to USNRC, "Request for Exemption from 10 CFR 50, Appendix R, Section III.G, 'Fire Protection of Safe Shutdown Capability'," dated October 5, 2007.
2. Letter from J. D. Hughey, U.S. Nuclear Regulatory Commission, to C. G. Pardee, Exelon Generation Company, LLC, "Peach Bottom Atomic Power Station, Units 2 and 3 - Request for Additional Information Regarding Request for Exemption from 10 CFR 50, Appendix R, Section III.G, 'Fire Protection of Safe Shutdown Capability' (TAC Nos. MD7029 and MD7030)," dated April 17, 2008.

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 3 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information 2AP35 Defeat 2A RHR pump (2AP35) trip External wiring 2, 57 Install U3 plug-in test Cable Spreading Note 1 signal generated by fire damage to (located in the switch 3-10A-J1B at Room, Rm 302, FA Note 2 Unit 3 RHR Logic initiating fire areas) to Panel 30C33 25 the Unit 3 RHR logic in panel 30C33 (located in Rm 302, FA 25) 2BS456 Transfer 125 VDC Battery Charger Loss of power (due to 2, 4, 6S, 57 1. Verify Breaker 52- 1. E-23 Bus Room, Note 1 2BD003 from normal source fire damage in 6011 at E234-T-B is Rm 263, FA 35 Note 4 (E224-T-B) to its alternate source initiating fire areas) to closed prior to (E234-T-B) due to fire damage 125 VDC Battery operating switch Charger 2BD003 2BS456 (located in Rm 226, FA 36) 2. Operate switch 2. E-42 Bus Room, 2BS456 to restore Rm 226, FA 36 power for Battery Charger 2BD003 from an alternate power source

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 4 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information 2DS456 Transfer 125 VDC Battery Charger Loss of power (due to 2, 6S, 38, 57 1. Verify Breaker 52- 1. E-23 Bus Room, Note 1 2DD003 from normal source fire damage in 6022 at E234-T-B is Rm 263, FA 35 Note 4 (E424-W-A) to its alternate source initiating fire areas) to closed prior to Note 5 (E234-T-B) due to fire damage 125 VDC Battery operating switch Charger 2DD003 2DS456 (located in Rm 226, FA 36) 2. Operate switch 2. E-42 Bus Room, 2DS456 to restore Rm 226, FA 36 power for Battery Charger 2DD003 from an alternate power source 3BP35 Defeat 3B RHR pump (3BP35) trip External wiring 2, 57 Install U2 plug-in test Cable Spreading Note 1 signal generated by fire damage to (located in initiating switch into test jack 2- Room, Rm 302, FA Note 2 Unit 2 RHR logic fire areas) to the Unit 10A-J1A at panel 25 2 RHR logic in panel 20C32 20C32 (located in Rm 302, FA 25) 30S546 Transfer instrument power supplies Loss of power (due to 13N Operate key switch Cable Spreading from normal source (panel fire in initiating fire 30S546 to restore Room, Rm 302, FA 30Y050) to alternate power source area) to instrument power to instrument 25 (panel 20Y033) due to fire damage power supply panel panel from 20Y033 30Y050 (located in Rm 302, FA 25)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 5 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information 3AS456 Transfer 125 VDC Battery Charger Loss of power (due to 13N 1. Verify Breaker 52- 1. E-12 Bus Room, Note 4 3AD003 from its normal power fire damage in 5934 at E124-T-B is Rm 227, FA 39 source (E134-T-B) to its alternate initiating fire area) to closed prior to power source (E124-T-B) due to 125 VDC Battery operating switch fire damage Charger 3AD003 3AS456 (located in Rm 261, FA 32) 2. Operate switch 2. E-33 Bus Room, 3AS456 to restore Rm 261, FA 32 power for Battery Charger 3AD003 from an alternate power source 3CS456 Transfer 125 VDC Battery Charger Loss of power (due to 13N, 13S, 26, 1. Verify Breaker 52- 1. E-12 Bus Room, Note 1 3CD003 from its normal power fire damage in 57, 58 5911 at E124-T-B is Rm 227, FA 39 Note 3 source (E334-R-B) to its alternate initiating fire areas) to closed prior to Note 4 power source (E124-T-B) due to 125 VDC Battery operating switch Note 6 fire damage Charger 3CD003 3CS456 (located in Rm 261, FA 32) 2. Operate switch 2. E-33 Bus Room, 3CS456 to restore Rm 261, FA 32 power for Battery Charger 3CD003 from an alternate power source

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 6 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO3 Manually operate MO-3-10-089A if Loss of power (due to 13N 1. Open breaker 52- 1. U3 RBCCW Room, 89A electrical operating capability is fire damage in the 3623 at E134-W-A Rm 162, FA 2 lost due to fire damage initiating fire area) to MO-3-10-089A, 3A 2. Manually open MO- 2. U3 RHR Pump RHR Heat Exchanger 3-10-089A Room, Rm 156, FA High Pressure 2 Service Water Heat Outlet (located in Rm 156, FA 2)

MO-2486 Manually operate valve MO-2486 Loss of power (due to 50, 54 1. Open breaker 52- 1. E2 Diesel Note 7 upon loss of electrical operating fire damage in the 5442 at E234-D-A Generator Room, capability due to fire damage initiating fire areas) to Rm 817, FA 45 MO-2486, High Pressure Service 2. Manually open MO- 2. Cardox Room, Rm Water Normal 2486 815, FA 54 Discharge Valve (located in Rm 815, FA 54)

MO-2486 Locally operate MO-2486 from the Loss of power (due to 4, 38, 57 1. Open breaker 52- 1 and 2. E2 Diesel Note 1 MCC if the fire has caused loss of fire damage in the 5442 at E234-D-A Generator Room, remote operating capability initiating fire areas) to Rm 817, FA 45 MO-2486, High 2. Open valve using Pressure Service contactor at MCC Water Normal Discharge Valve (located in Rm 815, FA 54)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 7 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO-3486 Manually operate valve MO-3486 Loss of power (due to 50, 54 1. Open breaker 52- 1. E2 Diesel Note 7 upon loss of electrical operating fire damage in the 5441 at E234-D-A Generator Room, capability due to fire damage initiating fire areas) to Rm 817, FA 45 MO-3486, High Pressure Service 2. Manually open MO- 2. Cardox Room, Rm Water Normal 3486 815, FA 54 Discharge Valve (located in Rm 815, FA 54)

MO-3486 Locally operate MO-3486 from the Loss of power (due to 57, 58 1. Open breaker 52- 1 and 2. E2 Diesel Note 1 MCC if the fire has caused loss of fire damage in the 5441 at E234-D-A Generator Room, Rm Note 3 remote operating capability initiating fire areas) to 817, FA 45 MO-3486, High 2. Open valve using Pressure Service contactor at MCC Water Normal Discharge Valve (located in Rm 815, FA 54)

MO2 Manually open valve MO-2 Loss of power (due to 4, 57 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1 034A 034A if electrical operating fire damage in the 3832 at E324-R-B Rm 212, FA 6S capability is lost due to fire damage initiating fire areas) to MO-2-10-34A, RHR 2. U2 Torus Room, Loop A Full Flow 2. Manually open MO- Rm 1, FA 5 Test Valve (located in 2-10-034A Rm 1, FA 5)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 8 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO2 Manually open valve MO-2 Loss of power (due to 4, 57 1. Open breaker 52- 1. U2 Reactor Bldg, Note 1 039A 039A if electrical operating fire damage in the 3831 at E324-R-B Rm 212, FA 6S capability is lost due to fire damage initiating fire areas) to MO-2-10-039A, RHR 2. U2 Torus Room, Loop A Torus Header 2. Manually open MO- Rm 1, FA 5 Valve (located in Rm 2-10-039A 1, FA 5)

MO3 Manually open valve MO-3 Loss of power (due to 13N, 26 1. Open breaker 52- 1. U3 Reactor Bldg, 034A 034A if electrical operating fire damage in the 3832 at E334-R-B Rm 257, FA 13S capability is lost due to fire damage initiating fire areas) to MO-3-10-34A, RHR 2. Manually open MO- 2. U3 Torus Room, Loop A Full Flow 3-10-034A Rm 37, FA 12 Test Valve (located in Rm 37, FA 12)

MO3 Manually open valve MO-3 Loss of power (due to 13N, 26 1. Open breaker 52- 1. U3 Reactor Bldg, 039A 039A if electrical operating fire damage in the 3831 at E334-R-B Rm 257, FA 13S capability is lost due to fire damage initiating fire areas) to MO-3-10-039A, RHR 2. Manually open MO- 2. U3 Torus Room, Loop A Torus Header 3-10-039A Rm 37, FA 12 Valve (located in Rm 37, FA 12)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 9 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO2 Manually open valve MO-2 Loss of power (due to 6S 1. Open breaker 52- 1. U2 RBCCW Room, 034B 034B if electrical operating fire damage in the 3933 at E424-W-A Rm 105, FA 2 capability is lost due to fire damage initiating fire area) to MO-2-10-034B, RHR 2. Manually open MO- 2. U2 Torus Room, Loop B Full Flow 2-10-34B Rm 1, FA 5 Test Valve (located in Rm 1, FA 5)

MO2 Manually open valve MO-2 Loss of power (due to 6S 1. Open breaker 52- 1. U2 RBCCW Room, 039B 039B if electrical operating fire damage in the 3942 at E424-W-A Rm 105, FA 2 capability is lost due to fire damage initiating fire area) to MO-2-10-039B, RHR 2. Manually open MO- 2. U2 Torus Room, Loop B Torus Header 2-10-39B Rm 1, FA 5 Valve, (located in Rm 1, FA 5)

MO2 Manually open valve MO-2 Loss of power (due to 6S 1. Open breaker 52- 1. U2 RBCCW Room, 89D 089D if electrical operating fire damage in the 3931 at E424-W-A Rm 105, FA 2 capability is lost due to fire damage initiating fire area) to MO-2-10-089D, 2D 2. Manually open MO- 2. U2 RHR Pump RHR Heat Exchanger 2-10-89D Room, Rm 104, FA High Pressure 2 Service Water Outlet Valve (located in Rm 104, FA 2)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 10 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO3 Manually open valve MO-3 Loss of power (due to 2, 57, 58 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1 034B 034B if electrical operating fire damage in the 3933 at E434-R-B Rm 250, FA 13N Note 3 capability is lost due to fire damage initiating fire areas) to MO-3-10-034B, RHR 2. Manually open MO- 2. U3 Torus Room, Loop B Full Flow 3-10-34B Rm 37, FA 12 Test Valve (located in Rm 37, FA 12)

MO3 Manually open valve MO-3 Loss of power (due to 2, 57, 58 1. Open breaker 52- 1. U3 Reactor Bldg, Note 1 039B 039B if electrical operating fire damage in the 3942 at E434-R-B Rm 250, FA 13N Note 3 capability is lost due to fire damage initiating fire areas) to MO-3-10-039B, RHR 2. Manually open MO- 2. U3 Torus Room, Loop B Torus Header 3-10-39B Rm 37, FA 12 Valve (located in Rm 37, FA 12)

MO3 Manually operate MO-3-10-089D if Loss of power (due to 58 1. Open breaker 52- 1. U3 Reactor Bldg, Note 3 89D electrical operating capability is fire damage in the 3931 at E434-R-B Rm 250, FA 13N lost due to fire damage initiating fire area) to MO-3-10-089D, 3D 2. Manually open MO- 2. U3 RHR Pump RHR Heat Exchanger 3-10-089D Room, Rm 159, FA High Pressure 10 Service Water Outlet Valve (located in Rm 159, FA 10)

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 11 of 12 Docket Nos. 50-277 and 50-278 Cross-Reference Between Peach Bottom Fire Protection Program, Revision 3, Table A-4 and Operator Manual Action Exemption Request, Attachment 2 (Reference 1)

Table A-4 Purpose Fire Affected Initiating Fire Actions Action Notes Cross- Component Area Location(s)

Reference. Information MO2 Manually operate MO-2-10-025B if Loss of power (due to 6S 1. Open breaker 52- 1. U2 Reactor Bldg, 25B electrical operating capability is fire damage in the 25B02 at Rm 205, FA 6N lost due to fire damage initiating fire area) to N210025B, LPCI MO-2-10-025B, RHR Swing Bus B Loop B Inboard Discharge Valve 2. Manually open MO- 2. U2 Reactor Bldg, (located in Rm 204, 2-10-025B Rm 204, FA 6N FA 6N)

MO3 Manually operate MO-3-10-025A if Loss of power (due to 13N 1. Open breaker 52- 1. U3 Reactor Bldg, 25A electrical operating capability is fire damage in the 25A02 at Rm 257, FA 13S lost due to fire damage initiating fire area) to N310025A, LPCI MO-3-10-25A RHR Swing Bus A Loop A Inboard Discharge Valve 2. Manually open 2. U3 Reactor Bldg, (located in Rm 248, valve MO-3 Rm 248, FA 13S FA 13S) 025A MO3 Manually operate MO-3-10-025B if Loss of power (due to 13S 1. Open breaker 52- 1 and 2. U3 Reactor 25B electrical operating capability is fire damage in the 25B02 at Bldg, Rm 250, FA lost due to fire damage initiating fire area) to N310025B LPCI 13N MO-3-10-025B, RHR Swing Bus B Loop B Inboard Discharge Valve 2. Open MO-3 (located in Rm 249, 025B from MCC FA 13N) Contactor

Response to Request for Additional Information Attachment 10 CFR 50, Appendix R, Section III.G.2 Exemption Request Page 12 of 12 Docket Nos. 50-277 and 50-278 TABLE NOTES Note 1: Fire Area 57 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.

Note 2: This action has been slightly modified from that described in the original submittal to make the action simpler to perform, but the action location, timing and outcome are the same. The original action was to reach inside the logic cabinet and physically manipulate a relay. A plug-in switch was fabricated so the operator would not have to handle an energized relay. The outcome is the same (the relay is actuated).

Note 3: Fire Area 58 was originally part of Fire Area 2 and was subsequently made a separate Fire Area.

Note 4: When the T-300 Fire Guides were developed, an initial step of verification of the breaker position (closed) of the alternate power source was added. Appendix R permits the assumption that equipment that is not fire affected will be in its expected position. So verification of this breaker position is not required for Appendix R compliance. Operations determined that they wanted to add a step to verify the position of the breaker as a precaution. This extra step was added to this Table since the action is performed in a different fire area than the steps associated with operating the switch. It is important to show that all actions taken by the operators are not in the same fire area where the fire is postulated.

Note 5: Fire Area 2 was omitted from the table in Revision 3. Fire Area 2 is listed in the revision 0, 1 and 2 tables. Fire Area 2 (which subsequently was split into Fire Area 2, 57 and 58) fire guide has always contained the attachment to transfer 125 VDC battery charger 2DD003 from the normal to the backup source.

Note 6: Fire Area 4 no longer credits use of this manual action.

Note 7: The action to manually open MO-2486 and MO-3486 (physically open the valve at the valve itself) is performed in the same fire area as the initiating fire area. There is 150 minutes (2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) between the start of the event and when the valve is to be opened. A fire in the Cardox Room will be extinguished and the smoke vented from the area long before the action needs to be performed. The operators will not have any delay or need SCBA to perform this action.

General Note: Table A-4 Revision 3 was a summary of information that was in the Peach Bottom Cable/Raceway analysis. This program deleted a "zero" that padded many component numbers, and some hyphens. The component number provided in the above table matches the component nomenclature that is used in the post-fire shutdown fire guides, safe shutdown calculations and plant labels.

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